TABLE OF CONTENTS 

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 4-i 

April 2012

Table of Contents 

4.0 ENVIRONMENTAL PROTECTION MEASURES, MONITORING, 

AND IMPACTS................................................................................................ 4.1-1

4.1 Resource Impact Evaluations ................................................................ 4.1-1

4.1.1 Impact Significance .................................................................... 4.1-2

4.1.2 Impact Scale ............................................................................... 4.1-2

4.1.3 Impact Duration .......................................................................... 4.1-3

4.2 Land Use ............................................................................................... 4.2-1

4.2.1 Agency-Required Measures ....................................................... 4.2-1

4.2.2 Monitoring of Land Use Impacts ............................................... 4.2-2

4.2.3 Impact Significance Criteria ....................................................... 4.2-2

4.2.4 Land Use Impacts from the Proposed Action ............................ 4.2-2

4.2.4.1 Livestock Grazing ............................................................... 4.2-3

4.2.4.2 Wildlife Habitat .................................................................. 4.2-5

4.2.4.3 Dispersed Recreation .......................................................... 4.2-6

4.2.4.4 Mineral and Energy Development ...................................... 4.2-7

4.2.4.5 Infrastructure ....................................................................... 4.2-8

4.2.5 Land Use Impacts from Other Alternatives ............................... 4.2-9

4.2.5.1 No Action Alternative ......................................................... 4.2-9

4.2.5.2 Other Action Alternatives ................................................... 4.2-9

4.3 Transportation ....................................................................................... 4.3-1

4.3.1 Agency Required Measures ........................................................ 4.3-1

4.3.1.1 Road Installation or Improvement ...................................... 4.3-1

4.3.1.2 Road Maintenance .............................................................. 4.3-1

4.3.1.3 Road Removal ..................................................................... 4.3-1

4.3.1.4 Safety .................................................................................. 4.3-2

4.3.2 Transportation Monitoring ......................................................... 4.3-2

4.3.3 Impact Significance Criteria ....................................................... 4.3-3

4.3.4 Transportation Impacts from the Proposed Action .................... 4.3-3

4.3.4.1 Construction ........................................................................ 4.3-8

4.3.4.2 Operation............................................................................. 4.3-8

4.3.4.3 Reclamation ........................................................................ 4.3-9

4.3.5 Transportation Impacts from Other Alternatives ..................... 4.3-10

4.3.5.1 No Action Alternative ....................................................... 4.3-10

4.3.5.2 Other Action Alternatives ................................................. 4.3-10

4.4 Geology ................................................................................................. 4.4-1

4.4.1 Agency-Required Measures ....................................................... 4.4-1

4.4.2 Monitoring of Geologic Impacts ................................................ 4.4-1

4.4.3 Impact Significance Criteria ....................................................... 4.4-2

4.4.4 Geologic Impacts from the Proposed Action ............................. 4.4-2

4.4.4.1 Construction ........................................................................ 4.4-2

4.4.4.2 Operation............................................................................. 4.4-3

4.4.4.3 Reclamation ........................................................................ 4.4-4

4.4.5 Geologic Impacts from Other Alternatives ................................ 4.4-5
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April 2012

4.4.5.1 No-Action Alternative ........................................................ 4.4-5

4.4.5.2 Not Fencing the Pattern Areas ............................................ 4.4-5

4.4.5.3 Drying Yellowcake On-Site ................................................ 4.4-5

4.5 Soils....................................................................................................... 4.5-1

4.5.1 Agency-Required Measures ....................................................... 4.5-1

4.5.1.1 Disturbance Minimization .................................................. 4.5-1

4.5.1.2 Appropriate Excavation and Storage .................................. 4.5-1

4.5.1.3 Erosion and Compaction Minimization .............................. 4.5-2

4.5.1.4 Soil Contamination Prevention ........................................... 4.5-3

4.5.2 Monitoring of Soil Impacts ........................................................ 4.5-3

4.5.3 Impact Significance Criteria ....................................................... 4.5-4

4.5.4 Soil Impacts from the Proposed Action ..................................... 4.5-4

4.5.4.1 Construction ........................................................................ 4.5-9

4.5.4.2 Operation........................................................................... 4.5-11

4.5.4.3 Reclamation ...................................................................... 4.5-11

4.5.5 Soil Impacts from Other Alternatives ...................................... 4.5-12

4.5.5.1 No Action Alternative ....................................................... 4.5-12

4.5.5.2 Not Fencing the Pattern Areas .......................................... 4.5-12

4.5.5.3 Drying Yellowcake On-Site .............................................. 4.5-12

4.6 Surface Water........................................................................................ 4.6-1

4.6.1 Agency-Required Measures ....................................................... 4.6-1

4.6.1.1 Measures Related to Sediment Transport ........................... 4.6-1

4.6.1.2 Measures Related to Spills and Leaks ................................ 4.6-4

4.6.2 Monitoring of Surface Water Impacts ........................................ 4.6-4

4.6.3 Impact Significance Criteria ....................................................... 4.6-4

4.6.4 Surface Water Impacts from the Proposed Action ..................... 4.6-5

4.6.4.1 Surface Water Quantity and Use......................................... 4.6-5

4.6.4.2 Surface Water Quality......................................................... 4.6-5

4.6.5 Surface Water Impacts from Other Alternatives ........................ 4.6-6 

4.7 Groundwater ......................................................................................... 4.7-1

4.7.1 Agency-Required Measures ....................................................... 4.7-1

4.7.1.1 On-Site Required Measures ................................................ 4.7-2

4.7.1.2 Off-Site Required Measures ............................................... 4.7-8

4.7.2 Groundwater Monitoring ............................................................ 4.7-8

4.7.2.1 On-Site Groundwater Monitoring ....................................... 4.7-8

4.7.2.2 Off-Site Groundwater Monitoring .................................... 4.7-11

4.7.3 Impact Significance Criteria ..................................................... 4.7-11

4.7.4 Differentiation of Impacts to Groundwater - Consumption and 

Quality ....................................................................................... 4.7-12

4.7.4.1 Groundwater Consumption ............................................... 4.7-15

4.7.4.2 Groundwater Quality ........................................................ 4.7-16

4.7.5 Construction ............................................................................. 4.7-17

4.7.5.1 Permit Area, Storage Ponds, Pipelines and Related 

Equipment ........................................................................ 4.7-17

4.7.5.2 Mine Units ........................................................................ 4.7-18
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April 2012

4.7.5.3 UIC Class I Wells ............................................................. 4.7-20

4.7.6 Operation .................................................................................. 4.7-21

4.7.6.1 Groundwater Consumption during Operation .................. 4.7-21

4.7.6.2 Groundwater Quality during Operation ............................ 4.7-28

4.7.7 Reclamation .............................................................................. 4.7-31

4.7.7.1 Groundwater Consumption during Reclamation .............. 4.7-31

4.7.7.2 Groundwater Quality during Reclamation ........................ 4.7-33

4.7.8 Groundwater Impacts from Other Alternatives ........................ 4.7-35

4.7.8.1 No Action Alternative ....................................................... 4.7-35

4.7.8.2 Not Fencing the Pattern Areas .......................................... 4.7-35

4.7.8.3 Drying Yellowcake On-Site ............................................ 4.7-35 

4.8 Vegetation ............................................................................................. 4.8-1

4.8.1 Agency-Required Measures ....................................................... 4.8-1

4.8.2 Vegetation Monitoring ............................................................... 4.8-2

4.8.2.1 During Construction, Operation, and Final Reclamation ... 4.8-2

4.8.2.2 Monitoring Revegetation Success....................................... 4.8-2

4.8.3 Impact Significance Criteria ....................................................... 4.8-3

4.8.4 Vegetation Impacts from the Proposed Action .......................... 4.8-4

4.8.4.1 Construction ........................................................................ 4.8-5

4.8.4.2 Operation............................................................................. 4.8-6

4.8.4.3 Reclamation ........................................................................ 4.8-6

4.8.5 Vegetation Impacts from Other Alternatives ............................. 4.8-7

4.8.5.1 No Action Alternative ......................................................... 4.8-7

4.8.5.2 Not Fencing the Pattern Areas ............................................ 4.8-7

4.8.5.3 Drying Yellowcake On-Site Alternative ............................. 4.8-7

4.9 Wildlife ................................................................................................. 4.9-1

4.9.1 Agency-Required Measures ....................................................... 4.9-1

4.9.1.1 Road and Right-of-Way Measures ...................................... 4.9-2

4.9.1.2 Fencing and Screening Measures ........................................ 4.9-2

4.9.1.3 Transmission Lines ............................................................. 4.9-3

4.9.1.4 Disease ................................................................................ 4.9-3

4.9.1.5 Wildfire ............................................................................... 4.9-3

4.9.1.6 Potentially Harmful Materials............................................. 4.9-4

4.9.1.7 Reclamation ........................................................................ 4.9-4

4.9.1.8 Reduction of Human Disturbance and Incidental Loss of 

Wildlife .............................................................................. 4.9-5

4.9.1.9 Wildlife Closures and Timing Windows ............................ 4.9-5

4.9.1.10 Greater Sage-Grouse Protection ......................................... 4.9-7

4.9.1.11 Raptor Protection ................................................................ 4.9-9

4.9.1.12 Wildlife Enhancements ..................................................... 4.9-10

4.9.2 Wildlife Monitoring ................................................................. 4.9-10

4.9.2.1 Annual Monitoring and Report ......................................... 4.9-10

4.9.2.2 General Wildlife................................................................ 4.9-11

4.9.2.3 Big Game .......................................................................... 4.9-11

4.9.2.4 Greater sage-grouse .......................................................... 4.9-11
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April 2012

4.9.2.5 Raptors .............................................................................. 4.9-19

4.9.2.6 Migratory Birds of High Federal Interest ......................... 4.9-20

4.9.2.7 Threatened and Endangered Species ................................ 4.9-20

4.9.2.8 Lagomorphs ...................................................................... 4.9-21

4.9.3 Impact Significance Criteria ..................................................... 4.9-21

4.9.4 Wildlife Impacts from the Proposed Action ............................. 4.9-21

4.9.5 Construction ............................................................................. 4.9-22

4.9.5.1 General Impacts on Wildlife ............................................. 4.9-22

4.9.5.2 Big Game .......................................................................... 4.9-24

4.9.5.3 Greater Sage-Grouse ......................................................... 4.9-24

4.9.5.4 Raptors .............................................................................. 4.9-31

4.9.5.5 Waterfowl and Shorebirds ................................................ 4.9-33

4.9.5.6 Migratory Birds of High Federal Interest ......................... 4.9-33

4.9.5.7 Threatened and Endangered Species ................................ 4.9-36

4.9.5.8 Reptiles and Amphibians .................................................. 4.9-37

4.9.6 Operation .................................................................................. 4.9-37

4.9.6.1 General Impacts on Wildlife ............................................. 4.9-37

4.9.6.2 Big Game .......................................................................... 4.9-38

4.9.6.3 Greater Sage-Grouse ......................................................... 4.9-38

4.9.6.4 Raptors .............................................................................. 4.9-40

4.9.6.5 Waterfowl and Shorebirds ................................................ 4.9-40

4.9.6.6 Migratory Birds of High Federal Interest ......................... 4.9-42

4.9.6.7 Threatened and Endangered Species ................................ 4.9-43

4.9.6.8 Reptiles and Amphibians .................................................. 4.9-43

4.9.7 Reclamation .............................................................................. 4.9-44

4.9.7.1 General Impacts on Wildlife ............................................. 4.9-44

4.9.7.2 Big Game .......................................................................... 4.9-45

4.9.7.3 Greater sage-grouse .......................................................... 4.9-45

4.9.7.4 Raptors .............................................................................. 4.9-45

4.9.7.5 Waterfowl and Shorebirds ................................................ 4.9-46

4.9.7.6 Migratory Birds of High Federal Interest ......................... 4.9-46

4.9.7.7 Threatened and Endangered Species ................................ 4.9-46

4.9.7.8 Reptiles and Amphibians .................................................. 4.9-47

4.9.8 Wildlife Impacts from Other Alternatives ................................ 4.9-47

4.9.8.1 No Action Alternative ....................................................... 4.9-47

4.9.8.2 Not Fencing the Pattern Areas .......................................... 4.9-47

4.9.8.3 Drying Yellowcake On-site .............................................. 4.9-47

4.10Wild Horses ........................................................................................ 4.10-1

4.10.1 Agency-Required Measures ..................................................... 4.10-1

4.10.2 Monitoring of Wild Horse Impacts .......................................... 4.10-1

4.10.3 Impact Significance Criteria ..................................................... 4.10-1

4.10.4 Impacts from the Proposed Action ........................................... 4.10-1

4.10.4.1 Construction ...................................................................... 4.10-2

4.10.4.2 Operation........................................................................... 4.10-3

4.10.4.3 Reclamation ...................................................................... 4.10-5
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April 2012

4.10.5 Wild Horse Impacts from Other Alternatives .......................... 4.10-6

4.10.5.1 No Action Alternative ....................................................... 4.10-6

4.10.5.2 Not Fencing the Pattern Areas .......................................... 4.10-6

4.10.5.3 Drying Yellowcake On-Site .............................................. 4.10-6

4.11Air Quality .......................................................................................... 4.11-1

4.11.1 Agency-Required Measures ..................................................... 4.11-1

4.11.2 Monitoring of Air Quality Impacts .......................................... 4.11-2

4.11.3 Impact Significance Criteria ..................................................... 4.11-3

4.11.4 Air Quality Impacts from the Proposed Action ........................ 4.11-3

4.11.4.1 Construction ...................................................................... 4.11-5

4.11.4.2 Operation........................................................................... 4.11-7

4.11.4.3 Reclamation ...................................................................... 4.11-9

4.11.4.4 Greenhouse Gases and Climate Change ......................... 4.11-10

4.11.5 Air Quality Impacts from Other Alternatives ......................... 4.11-11

4.11.5.1 No Action Alternative ..................................................... 4.11-11

4.11.5.2 Other Action Alternatives ............................................... 4.11-11

4.12Noise ................................................................................................... 4.12-1

4.12.1 Agency-Required Measures ..................................................... 4.12-1

4.12.2 Noise Monitoring ..................................................................... 4.12-1

4.12.3 Impact Significance Criteria ..................................................... 4.12-1

4.12.4 Noise Impacts from the Proposed Action ................................. 4.12-1

4.12.4.1 Construction ...................................................................... 4.12-2

4.12.4.2 Operation........................................................................... 4.12-3

4.12.4.3 Reclamation ...................................................................... 4.12-5

4.12.5 Noise Impact from Other Alternatives ..................................... 4.12-5

4.12.5.1 No Action Alternative ....................................................... 4.12-5

4.12.5.2 Other Action Alternatives ................................................. 4.12-5

4.13Historic and Cultural Resources ......................................................... 4.13-1

4.13.1 Agency-Required Measures ..................................................... 4.13-1

4.13.2 Monitoring of Historic and Cultural Resources Impacts .......... 4.13-1

4.13.3 Criteria for Significance Evaluation and Impacts .................... 4.13-2

4.13.4 Historic and Cultural Resources Impacts from the Proposed 

Action ........................................................................................ 4.13-3

4.13.5 Historic and Cultural Resources Impacts from Other 

Alternatives ............................................................................... 4.13-3

4.13.5.1 No Action Alternative ....................................................... 4.13-3

4.13.5.2 Other Action Alternatives ................................................. 4.13-4

4.14Visual and Scenic Resource Impacts .................................................. 4.14-1

4.14.1 Agency-Required Measures ..................................................... 4.14-1

4.14.2 Monitoring of Visual and Scenic Resource Impacts ................ 4.14-1

4.14.3 Impact Significance Criteria ..................................................... 4.14-1

4.14.4 Visual and Scenic Resource Impacts from the Proposed 

Action ........................................................................................ 4.14-2

4.14.4.1 Construction ...................................................................... 4.14-2

4.14.4.2 Operation........................................................................... 4.14-2
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April 2012

4.14.4.3 Reclamation ...................................................................... 4.14-8

4.14.5 Visual and Scenic Resource Impacts from Other Alternatives 4.14-8

4.14.5.1 No Action Alternative ....................................................... 4.14-8

4.14.5.2 Other Action Alternatives ................................................. 4.14-8

4.15Socioeconomic Conditions ................................................................. 4.15-1

4.15.1 Agency-Required Measures ..................................................... 4.15-1

4.15.2 Monitoring of Socioeconomic Impacts .................................... 4.15-1

4.15.3 Impact Significance Criteria ..................................................... 4.15-1

4.15.4 Demographic Impacts from the Proposed Action .................... 4.15-2

4.15.4.1 Construction ...................................................................... 4.15-2

4.15.4.2 Operation........................................................................... 4.15-3

4.15.4.3 Reclamation ...................................................................... 4.15-4

4.15.5 Revenue and Taxation Impacts from the Proposed Action ...... 4.15-4

4.15.5.1 Gross Domestic Product ................................................... 4.15-4

4.15.5.2 Revenue and Taxation....................................................... 4.15-4

4.15.6 Labor, Employment and Income Impacts from the Proposed 

Action ........................................................................................ 4.15-7

4.15.6.1 Construction ...................................................................... 4.15-7

4.15.6.2 Operation........................................................................... 4.15-9

4.15.6.3 Reclamation ...................................................................... 4.15-9

4.15.7 Cost of Living and Housing Impacts from the Proposed 

Action ...................................................................................... 4.15-10

4.15.7.1 Construction .................................................................... 4.15-10

4.15.7.2 Operation......................................................................... 4.15-11

4.15.7.3 Reclamation .................................................................... 4.15-11

4.15.8 Impacts to Infrastructure and Services from the Proposed 

Action ...................................................................................... 4.15-12

4.15.8.1 Education ........................................................................ 4.15-12

4.15.8.2 Health Care ..................................................................... 4.15-13

4.15.8.3 Law Enforcement and Fire Protection ............................ 4.15-14

4.15.8.4 Communications and Utilities......................................... 4.15-14

4.15.8.5 Recreation ....................................................................... 4.15-14

4.15.9 Socioeconomic Impacts from Other Alternatives .................. 4.15-15

4.15.9.1 No Action Alternative ..................................................... 4.15-15

4.15.9.2 Other Action Alternatives ............................................... 4.15-15

4.16Environmental Justice ......................................................................... 4.16-1

4.16.1 Agency-Required Measures ..................................................... 4.16-1

4.16.2 Monitoring of Environmental Justice Impacts ......................... 4.16-1

4.16.3 Environmental Justice Impacts from the Proposed Action ...... 4.16-1

4.16.3.1 Identification of Minority, Low-Income, and Tribal 

Populations ....................................................................................... 4.16-1

4.16.3.2 Fair Treatment and Meaningful Involvement ................... 4.16-5

4.16.4 Environmental Justice Impacts from Other Alternatives ......... 4.16-6

4.16.4.1 No Action Alternative ....................................................... 4.16-6

4.16.4.2 Other Action Alternatives ................................................. 4.16-6
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April 2012

4.17Public and Occupational Health.......................................................... 4.17-1

4.17.1 Agency-Required Measures ..................................................... 4.17-1

4.17.1.1 Protection Measures for Radiological Impacts ................. 4.17-1

4.17.1.2 Protection Measures for Non-Radiological Impacts ......... 4.17-2

4.17.2 Monitoring of Public and Occupational Health Impacts .......... 4.17-2

4.17.2.1 Radiological Impacts ........................................................ 4.17-2

4.17.2.2 Non-Radiological Impacts ................................................ 4.17-3

4.17.3 Impact Significance Criteria ..................................................... 4.17-3

4.17.4 Public and Occupational Health Impacts from the Proposed 

Action ........................................................................................ 4.17-3

4.17.4.1 Radiological Impacts ........................................................ 4.17-4

4.17.4.2 Non-Radiological Impacts .............................................. 4.17-10

4.17.5 Public and Occupational Health Impacts from Other 

Alternatives ............................................................................. 4.17-11

4.17.5.1 No Action Alternative ..................................................... 4.17-11

4.17.5.2 Other Action Alternatives ............................................... 4.17-11

4.18Waste Management ............................................................................. 4.18-1

4.18.1 Agency-Required Measures ..................................................... 4.18-1

4.18.2 Monitoring of Waste Disposal Impacts .................................... 4.18-1

4.18.3 Impact Significance Criteria ..................................................... 4.18-2

4.18.4 Waste Disposal Impacts from the Proposed Action ................. 4.18-2

4.18.4.1 Gaseous Emissions and Airborne Particulates .................. 4.18-2

4.18.4.2 Liquid Wastes ................................................................... 4.18-3

4.18.4.3 Solid Wastes...................................................................... 4.18-5

4.18.5 Waste Disposal Impacts from Other Alternatives .................... 4.18-7

4.19Mitigation Measures ........................................................................... 4.19-1

4.20Residual Impacts ................................................................................. 4.20-1

4.21Irreversible and Irretrievable Commitments of Resources ................. 4.21-1

4.22Relationship between Short-Term Uses and Long-Term 

Productivity .................................................................................... 4.22-2

 

List of Figures 

Figure 4.3-1 Regional Transportation Network....................................... 4.3-6

Figure 4.3-2 Project Road Layout ........................................................... 4.3-7

Figure 4.7-1 Simulated Drawdown, HJ Horizon at Maximum Production 

Rate- Mine Unit 1 ............................................................. 4.7-24

Figure 4.7-2 Simulated Drawdown, HJ Horizon at End of Reverse OsmosisMine Unit 1 ....................................................................... 4.7-25

Figure 4.7-3 Drawdown Observation Points, Mine Unit 1 Simulation, 

Production-Restoration-Recovery..................................... 4.7-26

Figure 4.7-4 Drawdown at Permit Boundary during Mine Unit 1 Simulation, 

Production-Restoration-Recovery..................................... 4.7-27 

Figure 4.9-1 Greater sage-grouse Study Areas ...................................... 4.9-13
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4-viii DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 

April 2012

Figure 4.9-2 Greater sage-grouse Leks and Facility Locations ............. 4.9-27

Figure 4.9-3 Raptor Nests (2010) and Facility Locations ..................... 4.9-35 

Figure 4.12-1 Drilling Rig Noise versus Distance................................... 4.12-3

Figure 4.14-1 Photograph of Existing ISR Project in Nebraska, 

July 2010 ........................................................................... 4.14-4

Figure 4.14-2 Photograph of Project Area from Sooner Road, 

October 2011 ..................................................................... 4.14-4

Figure 4.14-3 Viewshed Analysis............................................................ 4.14-6

Figure 4.14-4 Viewshed and VRM Classes ............................................. 4.14-7

Figure 4.17-1 Locations of Modeled Receptor Points ............................. 4.17-7

Figure 4.17-2 TEDE at Boundary Receptor Points ................................. 4.17-8

Figure 4.17-3 MILDOS-Calculated Doses to a Hypothetical Worker 328 feet 

(100 meters) from the Plant, Averaged over Direction..... 4.17-9

List of Tables 

Table 4.3-1 Estimated Number of Vehicles On-Site and Traveling To/From 

the Site (Page 1 of 2) ........................................................... 4.3-4

Table 4.5-1 Vegetation and Topsoil Disturbance (Page 1 of 4) ............. 4.5-5

Table 4.7-1 Summary of Consumptive Water Use Impacts ................. 4.7-13

Table 4.7-2 Summary of Water Quality Impacts ................................. 4.7-14

Table 4.7-3 Comparison of Water Quality in the Injection Stream and the 

Receiving Formation ......................................................... 4.7-30 

Table 4.8-1 Permanent Seed Mix ........................................................... 4.8-2

Table 4.9-1 Surface Activity Restrictions for the Protection of 

Wildlife ............................................................................... 4.9-6

Table 4.9-2 Estimated Water Quality of the Storage Ponds................. 4.9-42 

Table 4.11-1 Estimated Engine Emissions during Initial Construction 

(tons/year) ......................................................................... 4.11-6

Table 4.11-2 Estimated Annual Engine Emissions during Mine Unit 

Development (tons/year) ................................................... 4.11-7

Table 4.11-3 Estimated Annual Emissions during Operation (tons/year, 

unless otherwise noted) ..................................................... 4.11-9

Table 4.11-4 Estimated Annual Engine Emissions during Reclamation 

(tons/year) ....................................................................... 4.11-10

Table 4.12-1 Field Measurements of Equipment Noise in the 

Permit Area ....................................................................... 4.12-4

Table 4.15-1 Estimated Internal Project Costs ....................................... 4.15-5

Table 4.15-2 Estimated Tax Revenues Based on Project’s Annual 

Production ......................................................................... 4.15-6

Table 4.15-3 Estimated Labor and Employment.................................... 4.15-8

Table 4.16-1 Populations by Race and Ethnicity, 2000 ......................... 4.16-4

Table 4.16-2 Low Income Populations, 1999 ........................................ 4.16-5
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DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 4-ix 

April 2012

Table 4.18-1 Summary of Liquid Wastes Generated during Different Phases 

of the Project ..................................................................... 4.18-3

Table 4.18-2 Summary of Solid Wastes Generated during Different Phases 

of the Project ..................................................................... 4.18-5

Table 4.18-1 Summary of Liquid Wastes Generated during Different Phases 

of the Project ..................................................................... 4.18-3

Table 4.18-2 Summary of Solid Wastes Generated during Different Phases 

of the Project ..................................................................... 4.18-5
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4.0 ENVIRONMENTAL PROTECTION MEASURES, 

MONITORING AND IMPACTS

DRAFT EIS – LOST CREEK IN SITU URANIUM PROJECT 4.1-1 

April 2012 

4.0 ENVIRONMENTAL PROTECTION 

MEASURES, MONITORING, AND IMPACTS 

This section describes the direct and indirect environmental impact of the 

Proposed Action and alternatives. Direct and indirect impacts are disclosed in 

Section 4.0 and the cumulative impact analysis is discussed later in Section 5.0. 

Each resource section begins with a summary of the agency-required measures 

and LCI’s project design commitments necessary to comply with all federal and 

State environmental statutory and regulatory requirements. A description of the 

monitoring protocols for each resource follows the agency and LCI required 

measures summary. References to the sources of the required protection 

measures, such as the NRC SEIS and license or the WDEQ-LQD Permit to Mine 

(Section 1.4), are cited as well. The impact significance criteria and the impacts 

are then presented. The impacts from the Proposed Action are evaluated first. 

The impacts from the No Action Alternative and the Other Alternatives are then 

evaluated. 

Mitigation measures, residual impacts, irreversible and irretrievable commitments 

of resources, and the relationship between short-term uses and long-term 

productivity are separate subsections at the end of Section 4.0. 

4.1 Resource Impact Evaluations 

The evaluation of impacts from the Proposed Action is, for the most part, 

organized by resource, e.g., vegetation, and by phase of the Proposed Action, e.g., 

construction. For more effective evaluation of impacts for some resources, e.g., 

environmental justice, the evaluation of impacts may be organized somewhat 

differently. 

The resources are presented in the same order as in Section 3.0. As discussed in 

detail in Section 2.1.1, three phases of the Project are defined: Construction; 

Operation; and Reclamation. Construction applies to the initial major facility 

construction, e.g., the Plant, access roads, and the five UIC Class I deep wells. For 

the purposes of this evaluation, it has been assumed that all of the equipment 

staging areas and deep wells would be installed at the beginning of the Project, 

although this would probably not be the case. The first deep well was installed in 

2008 to provide the necessary subsurface information on the feasibility of the 

wells, and fewer than five deep wells will probably be needed. Construction also 

includes Mine Unit Development, e.g., the drilling, testing, and installation of 

each mine unit, which would occur throughout the life of the Project. The 

facilities being constructed during the Mine Unit Development, e.g., header 

houses, are smaller than those in the initial Construction. Because of the 

similarities of impacts from exploration and delineation drilling, exploration 
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drilling is included under Mine Unit Development, although it may occur outside 

a designated mine unit. Operation includes the production of ore from the mine 

units, and Reclamation includes the reclamation of each mine unit, as well as the 

Final Reclamation of the major facilities, such as the Plant. As noted in Section 

2.1, the operation and reclamation of the mine units would progress sequentially. 

The Other Alternatives for the Project are described in detail in Section 2.3, of 

which two were chosen for additional evaluation: Not Fencing the Pattern Areas 

and Drying Yellowcake On-Site. Environmental and social impacts were 

evaluated and presented in this section for these alternatives. In large part, the 

impacts of the Other Alternatives differ little from those of the Proposed Action. 

For the impact evaluations, it has been assumed that in addition to the permits and 

licenses already acquired (Table 1.4-2), LCI would acquire any additional 

necessary federal, state and local permits/licenses and approvals for the Project, 

and the requirements of those permits would be met. It has also been assumed 

that LCI’s committed environmental and social management measures, including 

those described in Section 2.1 and the agency-required and LCI committed 

measures and monitoring measures described in this section are fully and properly 

implemented. For comparison and easier reference, the findings from the NRC 

SEIS are included for each resource. 

4.1.1 Impact Significance 

For each resource, the criteria used to gauge the significance of the impact are 

discussed. In many cases, the criteria are based on quantitative regulatory 

requirements and scientific documentation. In other cases, the criteria may be 

more qualitative. The vulnerability of a given resource and perceptions about 

resource impacts are also considered. 

4.1.2 Impact Scale 

For each resource, a different scale is necessary for substantive evaluation of 

direct and indirect impacts. For example, vegetation impacts can be evaluated 

within the vicinity of the site because of the similarity of the vegetation types in 

the area. However, the socioeconomic impacts must be evaluated over a much 

larger area, e.g., 100 miles, because of the limited number of population centers in 

this part of Wyoming. In some cases, e.g., for noise, the impacts on-site and offsite have been differentiated. Another consideration in the impact scale is the 

geographic setting, e.g., inside or outside the Basin. 

4.1.3 Impact Duration 

For all resources, unless specific exceptions are stated, ‘short-term’ impacts are 

those that would occur over a five-year period or less, in some cases, only over a 
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period of weeks. The ‘long-term’ impacts are those that would exceed five years. 

Impacts that could affect future usage of the site are considered as residual 

impacts. 
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4.2 Land Use 

4.2.1 Agency-Required Measures 

The existing land uses, all of which may be affected by the Project, are: livestock 

grazing, wildlife habit, dispersed recreation, mineral and energy development, and 

infrastructure. The planned post-operational use of the Permit Area is livestock 

grazing and wildlife habitat. Since the disturbed land would be reclaimed after 

the Operation phase, the Project is compatible with the planned future use. The 

Project would conform to the land use regulations of Carbon and Sweetwater 

Counties in Wyoming as well as the RMPs of the BLM-Rawlins and Lander Field 

Offices (BLM, 2008a and 1987). 

The required environmental protection measures are summarized below from 

Sections OP 2.5, OP 2.9, OP 3.5, RP 3.3, and RP 4.5 of the WDEQ-LQD Permit 

to Mine (LCI, 2011b), Section 7.5.2 of the NRC Technical Report (LCI, 2010), 

Sections 2.1.1.1.2.1, 2.1.1.1.4.4, 2.1.1.1.4.5, and 2.1.1.1.5, and 6.2.2 of the NRC 

SEIS (NRC, 2011a), and Conditions 11.6 and 12.13 of the NRC License (NRC, 

2011b). 

Livestock Grazing and Wildlife Habitat 

The primary protection measures are to: limit disturbance wherever possible; 

locate new disturbance on old, unreclaimed disturbance wherever possible (e.g., 

new roads following old two-tracks); locate disturbance in upland areas, rather 

than the less common lowland areas; and reclaim the disturbance as soon as 

possible in a manner that would support the post-mining land uses. More 

protection measures related to specific resources or activities are discussed in the 

sections on those resources or activities. For example, increased dust from 

Construction activities could make forage along the access roads less palatable. 

Required measures to reduce dust (and other traffic-related impacts) are discussed 

in more detail in Sections 4.3.1 (Transportation) and 4.3.11 (Air Quality) and 

would include wetting unpaved roads and establishing speed limits on unpaved 

roads. Similarly, seeding inactive Construction areas to limit erosion and reestablish vegetation cover is discussed in Section 4.8.1 (Vegetation). 

Dispersed Recreation 

The primary protection measure is to limit access, only to the extent necessary to 

protect the health and safety of the public. More protection measures related to 

specific resources or activities related to dispersed recreation are discussed in the 

sections on those resources or activities. For example, required measures to limit 

visual impacts are discussed in Section 4.14. 
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Mineral and Energy Development 

To avoid interference among mineral and energy development projects, it is 

anticipated that any development in the Permit Area, other than uranium, would 

either be delayed for the duration of the Project or intermixed within the overall 

Permit Area. However, there are no known minerals (other than uranium), or oil, 

gas or coal resources in the Permit Area proposed for mining or development. To 

minimize potential interference with future subsurface activities, all the Project 

drill holes and wells would be abandoned in accordance with applicable 

requirements. The abandonment requirements for the drill holes and mine unit 

and water supply wells are listed in Sections OP 2.12 and RP 3.1 of the WDEQLQD Permit to Mine (LCI, 2011b), and the requirements for the UIC Class I wells 

are in Attachment J of the WDEQ-WQD application, which is included in 

Attachment ADJ-2 of the WDEQ-LQD Permit to Mine. In addition, notice of the 

presence of the abandoned wells is also required via a deed notice and/or 

individual well markers (WDEQ-LQD NonCoal Rules, Chapter 11, Section 8(h) 

[WDEQ, 2005b]). 

Infrastructure 

The only junctions with the regional infrastructure are where the Permit Area 

access roads tie into existing roads and where the transmission line to the Plant 

ties into the existing power line along the western boundary of the Permit Area. 

Required measures for road construction and installation of the transmission line 

are discussed under the resource heading that could be impacted (e.g., surface 

water or wildlife). 

4.2.2 Monitoring of Land Use Impacts 

No monitoring of land use impacts is currently planned. 

4.2.3 Impact Significance Criteria 

Interference with existing or planned land uses within or near the Permit Area is 

the impact significance criterion for land use. 

4.2.4 Land Use Impacts from the Proposed Action 

The existing land uses, all of which may be affected by the Project, are: livestock 

grazing, wildlife habit, dispersed recreation, mineral` and energy development, 

and infrastructure. There may be some limits to these land uses in portions of the 

Permit Area during the Project, but they would not be precluded from occurring. 
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4.2.4.1 Livestock Grazing 

Livestock grazing, the predominant land use within the Permit Area, would be 

directly affected by the Project as a result of fencing that affects livestock 

movement and reduces available grazing area. As noted in Section 3.1, affected 

grazing allotments within the Permit Area include: 0.7 percent of the Stewart 

Creek grazing allotment, 0.7 percent of the Cyclone Rim grazing allotment, and 

0.2 percent of the Green Mountain grazing allotment. For the 4,254 acre Permit 

Area, the total AUMs for the Permit Area is as much as 285 AUMs of cattle 

grazing in the Stewart Creek and Cyclone Rim allotments and as much as 125 

AUMs of grazing in the Green Mountain allotment. If year-round grazing were 

allowed in the Permit Area, the Stewart Creek and Cyclone Rim allotments would 

provide year-round forage for the equivalent of 25 cattle; the Green Mountain 

allotment would provide year-round forage for the equivalent of 11 cattle. 

However, as outlined below, only a portion of the grazing allotments within the 

Permit Area would be precluded from livestock grazing. 

Construction 

In order to ensure the health and safety of the cattle, fences would be constructed 

to limit access to livestock grazing in parts of the Permit Area. Restricted access 

to the Plant (including the Storage Ponds) and active mine unit pattern areas 

provide a beneficial impact to cattle and rangeland. Fencing ensures not only the 

health and safety of cattle currently using the land, but also provides for the 

proper reclamation of rangeland. 

If all of the proposed disturbance areas of the Project were fenced at once, 345 

acres (eight percent) of the 4,254-acre Permit Area would be removed from 

livestock grazing. Therefore, the AUMs of the Permit Area would decrease by 34 

AUMs from 410 AUMs to 376 AUMs (reducing the number of livestock that may 

be supported by year-round forage from 36 to 31 cattle). However, the number of 

directly impacted AUMs is a conservative estimate because the affected acreage 

at any time should be less than 345 acres due to the development and reclamation 

of the mine units in succession. The BLM calculated cattle production would 

produce $65.07 per AUM of total economic impact, which includes both direct 

and secondary returns (BLM, 2004a). Using this figure, and depending on the 

allotment terms, livestock production on the grazing allotments within the Permit 

Area that may be impacted by the Project has a potential value of about $2,215 

per year for cattle (34 AUMs x $65.07/AUM). This assumes all the cattle would 

be sold; however, some of the cows are generally kept for breeding. 

Fencing would also create an obstacle to livestock movement. The greatest 

potential obstacle would be fencing of all the mine unit pattern areas at once, 

presuming the pattern areas in the mine units were continuous. Fencing of all the 

pattern areas at once would create an oblong obstacle with the greatest length of 

about 2.5 miles. Livestock would need to travel around the fencing. 
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Some AUMs may be indirectly affected due to the surface disturbance from 

Construction activities that generate dust and noise, which could affect land use 

outside of the 345-acre disturbed area. Less than one percent of the three grazing 

allotments may be directly impacted; therefore, the temporary exclusion of 

livestock grazing is not expected to have a notable impact on livestock grazing. 

Impacts to livestock grazing during Construction would be confined to less than 

345 acres at any given time due to the sequential nature of the ISR operation and 

ongoing reclamation. 

Section 4.2.1.1 of the NRC SEIS summarizes the impacts the Construction phase 

could have on livestock grazing. These impacts include fencing that restricts 

grazing activities; incidental kills from vehicle accidents; and fugitive dust that 

could settle on plants making them undesirable for grazing purposes. The SEIS 

summarizes that because of the relatively small portion of land affected and the 

management measures that would be put in place to prevent vehicle-related 

livestock deaths, that the actual impact on livestock grazing would be minimal 

(NRC, 2011a). 

Operation 

Direct and indirect impacts from Operation activities would be similar to 

Construction impacts regarding access restrictions for livestock due to the existing 

infrastructure. The primary difference between Operation and Construction 

impacts would be the timing and magnitude of disturbance. Operation activities 

are estimated to occur for about seven years, versus the relatively short 

Construction period of less than one year. During the Operation phase, the 

primary changes to land use would be the expansion of mine units. This 

expansion would have similar direct and indirect impacts as those of 

Construction. Sequentially moving active operations from one mine unit to the 

next would reduce the impact of the activities. 

In the NRC SEIS, Section 4.2.1.2 discusses the impact the Operation phase may 

have on livestock grazing. It is described as similar to the Construction phase, 

with potential problems with fugitive dust, vehicle-related livestock deaths, and 

restriction to livestock management activities being of potential concern, but 

likely leading to only minimal impacts (NRC, 2011a). 

Reclamation 

Direct and indirect impacts from Reclamation activities on livestock grazing are 

expected to be similar to Construction and Operation impacts due to the 

temporary increase in land-disturbing activities from dismantling, removing and 

disposing of facilities and equipment, restoring roads, and replacing soil. Fences, 

which restrict livestock movement, would remain in place until vegetation is 

established. The sequential nature of the individual mine units and the ongoing 
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Mine Unit Restoration and Reclamation would help minimize impacts. The land 

would be reclaimed to support livestock grazing. 

Sections 4.2.1.3 and 4.2.1.4 of the NRC SEIS describe the potential impacts on 

livestock grazing during the reclamation phase. These impacts would be similar 

to the Construction phase, but with the emphasis that after the land is disturbed, it 

would be returned back to a condition that would support livestock grazing and 

increase the grazing land back to its original size (NRC, 2011a). 

4.2.4.2 Wildlife Habitat 

General impacts to wildlife habitat are discussed in the following section. A 

complete evaluation of impacts to vegetation and habitat and to specific wildlife 

species is included in Sections 4.8 and 4.9. 

Construction 

Impacts to wildlife habitat generally result from activities affecting food sources 

(i.e., forage and prey), water availability, available habitat, and loss of 

effectiveness of migration corridors. Impacts to wildlife habitat would most 

likely occur during the Construction phase of the Project due to the increased 

surface disturbance. The Project, along with the associated infrastructure, is 

expected to disturb a total of 345 acres of vegetation, or about eight percent of the 

total Permit Area, throughout the duration of the Project. However, the area of 

impacted vegetation at any one time should be less than eight percent due to the 

sequential nature of the Mine Unit Development and Production as well as 

ongoing Restoration and Reclamation. This is a very small percentage of the 

north central portion of the Great Divide Basin with similar ecological conditions 

(Chapman et al, 2004). 

Impacts to forage would occur during Construction as the result of stripping 

topsoil and vegetation to construct the Plant, roads, and other infrastructure. 

Since the affected area is small when compared with surrounding habitat, wildlife 

would likely avoid the Permit Area and use surrounding lands for sustenance and 

habitat. Increased dust from the Construction activities could also adversely 

affect available and desirable forage within the Permit Area and surrounding land. 

Water resources for wildlife consumption would not likely be impacted during the 

Construction phase. The increased noise level from Construction activities may 

adversely affect the occurrence of wildlife and deter them from the area. It is also 

possible that restricted, fenced areas within the Permit Area would fragment 

wildlife habitat. However, the size of the Permit Area is minor in comparison to 

the surrounding identical habitat areas, to which wildlife would be able to exist 

uninhibitedly. It is expected that the direct effects to wildlife habitat during 

Construction for each mine unit would be small, short-term and confined to 
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certain areas due to the sequential nature of the ISR operation and ongoing 

reclamation. 

Section 4.2.1.1 of the NRC SEIS summarizes that the impact of the land 

disturbance is insignificant, given that there is an expanse of undisturbed land that 

can serve the same function as the small portion of disturbed land (NRC, 2011a). 

Operation 

Direct and indirect impacts to wildlife habitat occurring during the Operation 

phase would be similar to those in the Construction phase. However, since there 

would be less surface disturbance activities during the Operation phase, fewer 

impacts on vegetation and wildlife habitat are expected. Additional impacts may 

occur, most likely to water resources for wildlife. The Storage Ponds that would 

intermittently contain water would be fenced to restrict wildlife access in order to 

ensure the health and safety of these animals. 

The NRC SEIS concludes that the land inaccessible to wildlife because of mining 

operations is a small portion of the region, and therefore, wildlife habitat would 

not be significantly impacted (NRC, 2011a). 

Reclamation 

Direct and indirect impacts from Reclamation activities on wildlife habitat are 

expected to be similar to Construction and Operation impacts due to the 

temporary increase in land-disturbing activities from dismantling, removing and 

disposing of facilities and equipment, restoring roads, and replacing soil. Fences, 

which limit access to Project lands, would remain in place until vegetation is 

established. The sequential nature of the individual mine units and the ongoing 

Mine Unit Restoration and Reclamation would help minimize impacts. The land 

would be reclaimed to support wildlife habitat. 

As with Construction and Operation, the NRC SEIS discussion of impacts due to 

Reclamation would be minimal, with a return to conditions that would support a 

variety of land uses, including wildlife habitat (NRC, 2011a). 

4.2.4.3 Dispersed Recreation 

Construction 

Impacts to dispersed recreation during Construction would be negligible due to 

the availability of equivalent surrounding land and the small area of impact. To 

protect the health and safety of the public, recreationists (including hunters) 

would have restricted access – albeit minimal – to areas within the Permit Area 

that were previously available for general use. The Plant, mine units and other 
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related infrastructure would be fenced during the Construction, Operation and 

Reclamation phases. Though the general public would have restricted access to 

the Permit Area, recreationists would continue to have access to the general area 

surrounding the Project via existing roads (Wamsutter-Crooks Gap Road and 

Sooner Road)) for the duration of the Project. Traffic on these roads may be 

increased due to the additional use of the roads by vehicles bringing supplies and 

labor to the Permit Area during Construction. While the additional volume of 

traffic is not expected to affect recreational access, the increased volume of traffic 

is expected to reduce the quality of the recreational experience in the area. 

Section 4.2.1.1 of the NRC SEIS states that while recreational activity would be 

limited near the construction areas, this represents a small percentage of the total 

land of the area, and the overall impact on recreational activities is insignificant 

(NRC, 2011a). 

Operation 

As with the Construction phase, impacts to dispersed recreation during the 

Operation phase would be negligible due to continued access to the general area 

via existing roads. 

The NRC SEIS (Section 4.2.1.2) states that the Operation phase would have a 

similar influence on recreational activities as in the Construction phase (NRC, 

2011a). 

Reclamation 

As with the Construction and Operation phases, impacts to dispersed recreation 

during Reclamation would be negligible due to continued access to the general 

area via existing roads and the relatively small restricted area of the Project. 

 

The NRC SEIS (Sections 4.2.1.3 and 4.2.1.4) states that the Reclamation phase 

would have a similar influence on recreational activities as in the Construction 

phase (NRC, 2011a). 

4.2.4.4 Mineral and Energy Development 

Construction 

In order to reduce the cumulative effects of mineral and energy development 

projects in the region, it is anticipated that future mineral rights for resources in 

the Permit Area, other than uranium, would either be delayed for the duration of 

the Project or intermixed within the overall Permit area. However, there are no 

known minerals (other than uranium), or oil, gas or coal resources in the Permit 

Area proposed for mining or development. Thus, the direct and indirect impacts 
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of the Project to minerals and energy development are negligible. If potential 

projects were to arise, it is expected that coexistence and conflicts would be 

negotiated and agreed upon between the different mineral rights owners, surface 

owners, and land management agencies. 

The NRC, in Section 4.2.1.1 of the SEIS, acknowledges that other mining 

activities would not be able to occur while the project is underway. However, it 

also states that there are no current projects or potential projects to mine coal, oil, 

or gas, and as a result any significant impacts to other mining or resource 

development projects are unlikely (NRC, 2011a). 

Operation 

Impacts to mineral and energy development would be similar throughout the 

Construction, Operation and Reclamation phases of the Project. 

The NRC, in Section 4.2.1.2 of the SEIS, concludes the Operation phase would 

have similar limitations on mineral and energy development as in the 

Construction phase (NRC, 2011a). 

Reclamation 

Impacts to mineral and energy development would be similar throughout the 

Construction, Operation and Reclamation phases of the Project. 

The NRC, in Section 4.2.1.3 of the SEIS, concludes the Reclamation phase would 

have similar limitations on mineral and energy development as in the 

Construction phase (NRC, 2011a). 

4.2.4.5 Infrastructure 

Construction, Operation, and Reclamation 

As mentioned above, about 345 acres of the 4,254 acres within the Permit Area 

would be disturbed by the construction of facilities such as access roads, utility 

corridors, the Plant, Storage Ponds, wells and mine units. However, 

decommissioning, removal, and surface reclamation is required for all these 

facilities, so they would not become part of the regional infrastructure unless there 

were a specific request by the landowner (the BLM or State of Wyoming) and 

approval was obtained from the BLM and WDEQ-LQD to leave the facilities in 

place to improve post-operational access or land use. 

The only junctions with the regional infrastructure are where the Permit Area 

access roads tie into existing roads and where the transmission line to the Plant 

ties into the existing power line along the western boundary of the Permit Area. 
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Required measures for road construction and installation of the transmission line 

are discussed by the resources that could be impacted (e.g., surface water or 

wildlife). 

4.2.5 Land Use Impacts from Other Alternatives 

4.2.5.1 No Action Alternative 

Under the No Action Alternative, there would be no change in current uses. 

4.2.5.2 Other Action Alternatives 

Not Fencing the Pattern Areas would reduce the impacts of the Project on all 

existing land uses, except minerals and energy development. Without fencing, 

livestock, wildlife, and recreationists would not be physically precluded from the 

mine unit pattern areas. However, access to such areas could be hazardous or 

harmful to livestock, wildlife, and recreationists. Additionally, Not Fencing the 

Pattern Areas would decrease the Project’s infrastructure. 

With the exception of infrastructure, the short-term land use impacts from Drying 

Yellowcake On-Site would not be appreciably different than those from the 

Proposed Action. During Construction, an on-site dryer may slightly increase the 

use of roads in the Project Area due to the increased material transport and 

construction activity necessary to build the dryer. However, during Operation, 

use of a dryer would result in fewer shipments from the site due to the difference 

in volume between yellowcake slurry and dried yellowcake. Therefore, traffic 

necessary for the transport of the shipments and use of the roads would also be 

decreased. 
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4.3 Transportation 

4.3.1 Agency Required Measures 

The required environmental protection measures are summarized below from 

Sections OP 2.6 and RP 3.2 and 4.4 of the WDEQ-LQD Permit to Mine (LCI, 

2011b) and Sections 2.1.1.1.2.3 and 2.1.1.1.5.4 of the NRC SEIS (NRC, 2011a). 

4.3.1.1 Road Installation or Improvement 

The Operations Plan in the WDEQ-LQD Permit to Mine (LCI, 2011b) establishes 

a series of steps for route selection, road design, and construction practices to help 

ensure the roads are located to minimize disturbance and are appropriate for the 

traffic load. Roads would be built in accordance with BLM guidance found in 

“Engineering: Road Standards: Excerpts from the BLM Manual, Section 9113” 

(1996a) and erosion would be mitigated according to the SWPPP (Attachment 

ADJ-3 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). 

4.3.1.2 Road Maintenance 

Maintenance costs for the county roads could accrue to both Carbon and 

Sweetwater Counties, although most Project revenues would be generated in 

Sweetwater County. LCI is working with the Counties to develop agreements for 

maintenance of roads accessing the Permit Area. 

If not already done prior to BLM approval of the proposed action, LCI would 

prepare and submit a Road Use Maintenance Agreement for Sweetwater County 

review and approval. The Agreement would comply with the standards and 

conditions of the Sweetwater County Public Works Director, the Sweetwater 

County Attorney's Office, and the Sweetwater County Board of County 

Commissioners, and would address roadway maintenance, surfacing, dust control, 

weight limits, traffic, snow removal, improvements, and related topics. In 

addition, LCI would obtain the necessary Access Permit or License from the 

Sweetwater County Department of Engineering for any crossing, access to, or use 

of a Sweetwater County Road right-of-way. 

4.3.1.3 Road Removal 

Per the requirements of the Reclamation Plan in the WDEQ-LQD Permit to Mine 

(LCI, 2011b), removal of roads is required upon Project completion. If a 

landowner specifically requests that a road (or structure) be left in place, then it is 

generally possible to revise the Permit to accommodate that request. However, 

the existing Permit language specifies road removal, and the reclamation bond for 

the WDEQ-LQD Permit to Mine includes costs for road removal. Improved or 
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constructed roads would be reclaimed by removal of culverts, removal of road 

surfacing and road bed materials, and recontouring, as necessary. Unimproved 

roads would be recontoured, if necessary, and scarified, ripped, or disced to 

reduce compaction. The roads would then be reclaimed through preparation of 

the seed bed and reseeding, in accordance with the Permit requirements. 

4.3.1.4 Safety 

In the application for NRC licensing, LCI submitted the transportation logistics to 

the NRC, who determined that the transportation plan and associated safety 

measures were adequate. All transportation activities associated with the project 

would adhere to existing transportation regulations, including those found in 10 

CFR Part 71 (NRC, 2004) and 49 CFR 171-180 (USDOT, 2005). An emergency 

response manual would be available in the event of an accident involving vehicles 

transporting radioactive materials. Any non-radioactive chemical spills would be 

reported to the State environmental agency, USEPA, and USDOT. Additionally, 

several measures would be taken in order to reduce the potential for accidents. 

These include: 

x All delivery truck drivers would hold appropriate licenses and 

certifications, and submit to a mandatory drug testing program; 

x All delivery trucks used to transport Project materials would carry the 

certifications of the relevant safety inspections; 

x Speed limits would be at 30 miles per hour or less, and an active driver 

safety and accident avoidance program would be carried out; 

x On-site and local roads would be plowed, maintained, and improved as 

appropriate; and 

x An internal report would be filed in the case of a near-miss or accident, 

and drivers would be briefed on how to avoid similar future incidents. 

4.3.2 Transportation Monitoring 

Records of on-site road maintenance would be kept along with records of 

shipping and receiving goods, driver training, and truck safety certifications. 

Inspections would also be performed quarterly, at a minimum, to examine the 

condition of the road surface and culverts to maintain the quality of the road for 

safe transportation. On-site fuel storage tanks would be examined weekly to 

check for leakage and spills from the tank to reduce any impacts that could be 

associated with such chemical leakage. LCI would also install traffic counters on 

the smaller, improved surface roads for which no data currently exists to help 

determine Greater sage-grouse impacts, as described in Attachment OP-6 of the 

WDEQ-LQD Permit to Mine (LCI, 2011b). 
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4.3.3 Impact Significance Criteria 

Transportation impacts are evaluated on the relative increase in traffic levels and 

whether the increase would degrade safety conditions. The impacts of the 

transportation on specific resources are evaluated in the respective resource 

sections (e.g., the impacts on wildlife are discussed in the Section 4.9). 

4.3.4 Transportation Impacts from the Proposed Action 

Potential impacts to transportation could occur throughout all phases of the 

Project. Table 4.3-1 includes an estimate of the number and size of vehicles that 

would be needed during the life of the Project. It is anticipated that traffic would 

usually be equally divided among the three primary routes to the Permit Area 

(Figures 4.3-1 and 4.3-2): 

x From Rawlins via US 287 to the Minerals Exploration Road and Sooner 

Road; 

x From Casper via WY 220 to the Bairoil Road and Sooner Road; and 

x From Rock Springs via I-80 to the Wamsutter Crooks Gap Road. 

Traffic could also come from Lander via US 287 to the Wamsutter Crooks Gap 

Road, but this was assumed to be a less-used route. 

Transportation could be affected by the Proposed Action due to increased traffic 

on existing roads and, in turn, potential increases in traffic-related accidents. 

However, with the required road construction and maintenance practices, 

transportation conditions both outside and inside the Permit Area are not 

anticipated to result in any different traffic accident rates than are typical for 

Wyoming. Specific conditions during Construction, Operation, and Reclamation 

are discussed in the following subsections. 

 
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Table 4.3-1 Estimated Number of Vehicles On-Site and Traveling To/From the Site (Page 1 of 2) 
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Table 4.3-1 Estimated Number of Vehicles On-Site and Traveling To/From the Site (Page 2 of 2) 
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Figure 4.3-1 Regional Transportation Network 
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Figure 4.3-2 Project Road Layout 
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4.3.4.1 Construction 

Improvements to the existing East and West Access Roads would be necessary in 

the earliest stages of Construction to provide adequate access for personnel, 

equipment, and materials. The equipment and materials would be general 

construction materials and the ISR-specific equipment (e.g., ion exchange resin 

tanks). Most of the initial Construction activities would be concentrated at the 

Plant, although installation of secondary roads to the deep wells would be 

necessary prior to drilling of the wells. It is anticipated that the deliveries of 

larger equipment (e.g., tanks) would come in by rail and then by truck on the 

Wamsutter Crooks Gap Road and that the rest of the traffic to/from the Permit 

Area would be equally divided among the three routes to the site. 

Comparison of existing and additional traffic volume (Tables 3.2-1 and 4.3-1) 

indicates the increased volume during initial Construction would not be noticeable 

on any of the major transportation routes. The increased traffic volume might be 

noticeable on WY 73, on which the volume would increase by five to ten percent 

during the seven months of initial Construction. 

During Construction for Mine Unit Development, secondary access roads would 

be built to connect the header houses within a mine unit and connect the mine unit 

to the Plant. Two-track roads would provide access to the wells in the monitor 

ring, with local improvements if needed to prevent erosion (e.g., gravel surface to 

prevent creation of a mud hole in a low spot). These roads would remain in place 

until removed and reclaimed during Mine Unit Reclamation. On-site traffic 

during the Mine Unit Development would include movement of equipment and 

associated personnel, such as moving rigs from well to well during pattern 

installation. 

Section 4.3.1.1 of the NRC SEIS describes the changes in transportation expected 

during the Construction phase of the Lost Creek ISR project, including 

transportation of workers and materials to and from the site. Potential impacts 

included in this analysis are dust, emissions, noise, increased traffic on main 

roads, and the potential for accidents. However, the increase in traffic is expected 

to be small, therefore making the potential impacts small as well (NRC, 2011a). 

4.3.4.2 Operation 

Maintenance of the East and West Access Roads would continue throughout the 

Operation phase. During the Operation phase, the overall volume of traffic would 

decline (Table 4.3-1). The number of vehicles used by personnel commuting to 

and from the Permit Area during the Operation phase is estimated to be about half 

that during Construction. As noted in the table, some equipment would be 

brought to the site and then remain on-site for the duration of the Project. Other 
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equipment and materials would be transported to and from the Project on a 

regular basis, including shipments of: 

x Supplies to the Plant, including potable water, office supplies, CO2, 

oxygen, diesel fuel, gasoline, salt, soda ash, sulfuric acid, hydrogen 

peroxide and drilling mud. Most of these supplies would be delivered to 

the Plant, although some supplies would be delivered to the staging areas 

for use in the mine units; 

x Shipments of yellowcake slurry from the Plant to a toll drying facility; and 

x Shipments of waste material to be disposed of off-site. 

On-site traffic during the Operation phase would include regular, periodic 

movement of personnel, such as travel around an operational monitor ring for 

sampling once every two weeks. 

The NRC SEIS describes the changes in transportation expected during the 

Operation phase of the Lost Creek ISR project in Section 4.3.1.2. These impacts 

include transportation of workers and materials to and from the site, particularly 

the radioactive materials the result from the process. Potential impacts included 

in this analysis are dust, emissions, noise, increased traffic on main roads, and the 

potential for accidents, specifically involving vehicles transporting the radioactive 

materials. However, due to low increase in traffic and the management practices 

put in place to provide safe transport, the potential impacts are expected to be 

minimal (NRC, 2011a). 

4.3.4.3 Reclamation 

During reclamation of each mine unit, all of the secondary and tertiary roads 

associated with that mine unit would be removed and reclaimed, unless needed 

for access to another mine unit. During Reclamation, all remaining on-site roads 

would be removed and reclaimed; although before the on-site roads are reclaimed, 

the surface management agency (primarily BLM), would be consulted and given 

the option to retain the roads established for the Project. The impacts on traffic 

during the Reclamation of the Project are expected to be similar to those incurred 

during Construction, although the overall volume would be less. In addition, 

rather than the majority of truck traffic consisting of deliveries to the site, the 

majority of the truck traffic would consist of removal of materials from the site 

either for reuse, recycling, or disposal. 

The NRC SEIS (Sections 4.3.1.3 and 4.3.1.4) addresses transportation during the 

reclamation phase by recognizing that there would be more larger trucks used 

during decommissioning, but the relative impacts to transportation in the area 

would be insignificant on main roads and minimal on smaller roads (NRC, 

2011a). 
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4.3.5 Transportation Impacts from Other Alternatives 

4.3.5.1 No Action Alternative 

Under the No Action alternative, current access, uses, and maintenance would 

continue. 

4.3.5.2 Other Action Alternatives 

The impacts of other alternatives (Not Fencing the Pattern Areas and Drying 

Yellowcake On-Site) on transportation would be similar to those for the Proposed 

Action. If the pattern areas were not fenced, the potential for personnel to cut 

across open areas could increase; however, the measures for topsoil and 

vegetation protection (Sections 4.5 and 4.8) are intended to reduce this potential 

with or without the pattern area fences. If a dryer were installed on-site, the 

number of shipments of yellowcake would be reduced from about one shipment 

every five days to about one shipment every 15 days. There would be a 

corresponding decrease in impacts, although the overall effect would be minimal. 
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4.4 Geology 

4.4.1 Agency-Required Measures 

The required environmental protection measures are summarized below from 

Sections OP 3.3 through 3.6, and RP 3.1 of the WDEQ-LQD Permit to Mine 

(LCI, 2011b) and Sections 2.1.1.1.2.1 and 2.1.1.1.5.5 of the NRC SEIS (NRC, 

2011a), and Condition 10.5 the NRC License (NRC, 2011b). 

To prevent unanticipated impacts to the subsurface materials, wells would be 

constructed in accordance with appropriate designs for their use, tested at required 

intervals, and operated in accordance with calculated injection pressures. These 

construction and operation requirements are included in Sections OP 3.3, 3.4, and 

3.6 of the WDEQ-LQD Permit to Mine (LCI, 2011b). 

With respect to future subsurface activities, all the Project wells would be 

abandoned in accordance with applicable requirements. The abandonment 

requirements for the mine unit and water supply wells are listed in Section RP 3.1 

of the WDEQ-LQD Permit to Mine, and the requirements for the UIC Class I 

wells are in Attachment J of the WDEQ-WQD application, which is included in 

Attachment ADJ-2 of the WDEQ-LQD Permit to Mine (LCI, 2011b). In addition, 

notice of the presence of the abandoned wells is also required via a deed notice 

and/or individual well markers (WDEQ-LQD NonCoal Rules, Chapter 11, 

Section 8(h) [WDEQ, 2005b]). 

To prevent unanticipated impacts from geologic conditions, in particular 

earthquakes, facilities would be constructed on appropriately prepared surfaces 

and in accordance with applicable building codes. Pressure monitoring, leak 

detection, and similar measures would provide information of adverse effects 

from any ground movement, and automatic shut-offs would allow for prevention 

and minimization of leaks. (This equipment is described in detail in Sections OP 

3.5 and 3.6 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). 

4.4.2 Monitoring of Geologic Impacts 

To ensure formation fracture pressures are not exceeded, injection pressures and 

flow rates for the mine unit production and injection wells would be monitored as 

detailed in Section OP 3.6 of the WDEQ-LQD Permit to Mine and reported in the 

Annual Report submitted to NRC and WDEQ. Similarly, injection pressure, flow 

rate, and annulus pressure in the UIC Class I wells would also be monitored and 

reported in accordance with the requirements of the UIC Class I Permit, and an 

evaluation of the well performance would be included in the Annual Report 

submitted to NRC and WDEQ. 
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Should an earthquake of unusual intensity occur, a program of well testing, such 

as MITs or using down-hole cameras, could be implemented to ensure subsurface 

damage to the wells had not occurred. 

4.4.3 Impact Significance Criteria 

The criteria used to evaluate impacts to geology, e.g., subsidence, are the 

likelihood of an impact occurring, and, if it did occur, what the magnitude and 

consequences would be. In addition, the impacts from geologic conditions, i.e., 

geologic hazards such as earthquakes, on the Project were evaluated. 

4.4.4 Geologic Impacts from the Proposed Action 

The potential impacts to geology from the Proposed Action are limited to impacts 

during Construction and Operation. Impacts from geologic conditions could 

occur throughout the life of the Project. 

4.4.4.1 Construction 

Initial Construction 

There are no bedrock outcrops in the Permit Area, and drilling logs indicate that 

bedrock is a few feet below the surface. Earth moving during Construction would 

not disturb bedrock formations at depth, e.g., pipeline burial depths and key cuts 

for the pond embankments are less than six feet. Based on the results from 

geotechnical borings completed in the vicinity of the Plant, no extraordinary 

measures are needed to stabilize building foundations. The results of the 

geotechnical drilling and recommendations and requirements for building site 

preparation are included in Attachment OP-7 of the WDEQ-LQD Permit to Mine 

(LCI, 2011b). 

The deep well in the southwest corner of the Permit Area (Figure 1.2-3) was 

installed in 2008 to provide the necessary subsurface data to determine the 

feasibility of using deep wells for waste disposal. Based on the information 

obtained from that well, well completions in the target interval of the Fort Union 

Formation would not impact the subsurface geologic conditions. In particular, 

hydraulic fracture treatments are not considered necessary to provide sufficient 

injection capacity. (Impacts to the water quantity and quality in the Fort Union 

Formation are discussed in Section 4.7.) With respect to geologic hazards, no 

unanticipated conditions, such as an unknown fault, were discovered during 

drilling of the deep well. 

An earthquake could potentially damage a facility, such as a building, under 

construction because the structural integrity of the facility would be less during 

construction than when completed. However, given the relatively low probability 
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of an earthquake of sufficient magnitude to cause damage (Section 3.3), this is an 

unlikely scenario. 

The above assessment is in general agreement with that in the NRC SEIS. (In the 

NRC SEIS, geology and soils impacts are included in the same section; this was 

not done in this EIS because of the importance of topsoil salvage and protection to 

ensure adequate surface reclamation.) Section 4.4.1.1 of the NRC SEIS, states 

that no rock matrix would be altered during this project; therefore, there would be 

little to no subsidence, and the overall impact of the Construction phase is 

minimal (NRC, 2011a). 

Mine Unit Development 

Impacts on geology during Mine Unit Development would be the result of drilling 

to further delineate the ore body and to install wells within the mine units. Drill 

pit and trench excavation would not impact the geology because the pits would be 

relatively shallow (ten feet deep or less). Drilling would have a direct albeit 

minor impact on the geology due to the removal of subsurface materials as a 

result of the drill bit cutting action. However, the amount of material removed 

from the subsurface formations (sandstones, siltstones, and shales) would not be 

sufficient to impact the structural integrity of the formations. In addition, 

pressures used during drilling are not sufficient to adversely impact subsurface 

conditions. 

A beneficial impact of Mine Unit Development, which would occur during 

aquifer testing (and is one of the purposes of the aquifer testing), would be 

location of improperly abandoned wells from previous exploration. Efforts are 

made before Mine Unit Development to locate old drill holes, but records of all 

prior drilling locations may not exist or it may not be possible to locate all of the 

old drilling locations to check abandonment methods. If an improperly 

abandoned drill hole is found during aquifer testing, it would be abandoned in 

accordance with the permit requirements. Additional information is included in 

Section D5.2.4.1 in Appendix D5 of the WDEQ-LQD Permit to Mine (LCI, 

2011b). 

4.4.4.2 Operation 

Potential impacts of the Operation phase to the subsurface geologic conditions are 

discussed below. No impacts from geologic hazards are anticipated during 

Operation, other than the existing potential for earthquakes. 

Future Resource Development 

Removal of uranium from the target sandstones would result in a permanent 

change to the composition of these sandstones, which is a direct and permanent 

impact to the geology of the Permit Area. However, the impacts would not 
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preclude recovering other minerals that might be discovered in economic 

quantities within the Permit Area in the future. 

Injection and Production Rates and Pressures 

In the uranium production formation, no significant matrix compression or ground 

subsidence from injection or pumping of fluids is expected. Injection pressures 

are calculated to ensure fracture formation pressures are not exceeded, and 

pumping rates are balanced with injection rates and are calculated to be 

sustainable. The net withdrawal of fluid (bleed) would typically be one percent or 

less. Once groundwater restoration is complete, groundwater levels would 

approximate pre-operational levels. 

Theoretically, changes to the aquifer pressure may impact the transmissivity (e.g., 

resistance to flow) of the Fault. The pressure of the produced aquifer would be 

increased during Mine Unit Operation and Restoration activities; however, this 

pressure would be balanced by the production and recovery wells. It is very 

unlikely that the planned ISR operations would reactivate the Fault, and extremely 

unlikely that any earthquakes would be generated. Documented cases where fluid 

withdrawal or injection has impacted fault transmissivity or resulted in 

earthquakes have occurred when the change in reservoir pressure was on the order 

of 1,000 to 5,000 psi or higher. Operations at the Permit Area are expected to 

induce much lower pressure changes, in the range of 50 to 150 psi. 

In the deeper formation in which the Class I wells would be completed, injection 

pressures are also calculated to ensure fracture formation pressures are not 

exceeded. As with the shallower uranium production formation, the pressure 

changes would be less than those in the documented cases of earthquakes or 

changes in fault transmissivity. 

Matrix Effects

The uranium mobilization and recovery process in the target sandstones does not 

result in the removal of rock matrix or structure. Rather, the lixiviant mobilizes 

uranium that was deposited within the sandstone long after the sands were 

deposited and lithified (Section 2.1.2 of the NRC GEIS [NRC and WDEQ, 

2009]). The lixiviant is selected to optimize dissolution of the uranium mineral 

coatings on sediment grains in the target sandstones and minimize potential 

interference with the host formation (Section 2.4.1.1, NRC GEIS [NRC and 

WDEQ, 2009]). This assessment is in agreement with that in Section 4.4.1.2 of 

the NRC SEIS (NRC, 2011a). 

4.4.4.3 Reclamation 

No impacts would occur to the geology of the Permit Area during Mine Unit 

Restoration or Reclamation. The wells in the mine units would be abandoned, but 
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the pressures used for well abandonment are similar to those for well 

construction. This assessment is in agreement with that in Section 4.4.1.3 of the 

NRC SEIS (NRC, 2011a). 

 

During Final Reclamation, decommissioning, facility removal, topsoil placement 

and revegetation would occur. These activities would have no impact on the 

geology in the Permit Area. Abandonment of the deep wells would be done in 

accordance with the UIC Class I Permit. 

4.4.5 Geologic Impacts from Other Alternatives 

4.4.5.1 No-Action Alternative 

Under the No-Action Alternative, the Project would not go forward and there 

would be no changes to the geologic conditions in the Permit Area or in the 

surrounding region. Existing land use activities that could potentially impact the 

geology (such as mineral and oil and gas drilling) would still occur. Existing 

wells would be plugged but this would not have an additional impact on the 

geology. 

4.4.5.2 Not Fencing the Pattern Areas 

Under this alternative, the pattern areas would not be fenced. This alternative 

would have no impacts on the geology. Geologic hazards would not impact this 

alternative. 

4.4.5.3 Drying Yellowcake On-Site 

This alternative would have no impact on geology. The dryer would be within the 

Plant, so the measures taken to prevent impacts from geologic hazards on the onsite facilities, e.g., construction in accordance with appropriate building codes, 

would be in place, as well as applicable procedures for spill control should 

unanticipated damage occur. 
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4.5 Soils 

4.5.1 Agency-Required Measures 

The required environmental protection measures are summarized below from 

Sections OP 2.5, OP 2.9, OP 3.5, RP 3.3, and RP 4.5 of the WDEQ-LQD Permit 

to Mine (LCI, 2011b), Section 7.5.2 of the NRC Technical Report (LCI, 2010), 

Sections 2.1.1.1.2.1, 2.1.1.1.4.4, 2.1.1.1.4.5, 2.1.1.1.5, and 6.2.2 of the NRC SEIS 

(NRC, 2011a), and Conditions 11.6 and 12.13 of the NRC License (NRC, 2011b). 

The following measures would be put in place to minimize the amount of topsoil 

disturbed (Table 4.5-1), ensure suitable material is used to replace the same depth 

of material after removal, and minimize erosion and compaction of soils. 

4.5.1.1 Disturbance Minimization 

Site selection for all facilities would take into account the protection of 

environmental features, such as vegetation and topsoil, as well as safety, cost, and 

efficiency of operation (Section OP 2.5.2.2 of the WDEQ-LQD Permit to Mine 

[LCI, 2011b]). Topsoil would be removed in situations where it cannot be 

protected from loss of the soil resource unless it is removed, such as underneath 

buildings; topsoil would also be removed from a monitor well road (or portion of 

the road) if the road must be upgraded to maintain its integrity. 

Topsoil would not be stripped from areas where there is minor disturbance, such 

as light-use-roads, fences, and monitoring stations (such as the meteorological 

station (Section 3.10). In the pattern areas and in the monitor well ring, topsoil 

would not be removed except at the excavated mud pits, unless it is determined 

that use of a portable mud pit and disposal of the drill cuttings at an alternate 

location would be preferable. 

4.5.1.2 Appropriate Excavation and Storage 

Topsoil removal would be supervised by a qualified person using detailed soil 

survey data, which would be field checked. Based on the detailed soil surveys 

and field experience to date, the upper materials that would be salvaged can be 

readily distinguished from the lower materials. Topsoil surveys and anticipated 

stripping depths for areas of the Plant, supporting facilities, and Mine Unit 1 are 

included in Section 3.4. Surveys for future mine units would be included as part 

of the Hydrologic Plan and Report for each unit (Section 2.1.1). As a field check 

along roadways and pipelines, LCI would dig pits at intervals where changes in 

stripping depths are anticipated to help ensure the most productive portion of the 

soil profile is salvaged. 
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Excavated soils would be stockpiled or windrowed to protect them from wind and 

water erosion and from impacts due to site activities, e.g., traffic. All long-term 

topsoil stockpiles would be labeled and inspected periodically. These stockpiles 

would be sloped on all sides to a slope of no greater than 3:1 and would be 

reseeded with the approved permanent seed mixture (Table 4.8-1), minus shrub 

specie(s), at the next appropriate season after the stockpile is created. As an 

alternative, the topsoil stockpile may be seeded with a rigorous certified weed free 

annual cover crop such as sterile rye grass or millet in order to establish a cover 

on the topsoil pile. A seed drill would be used to the extent possible, however, 

when slopes dictate, seed may be broadcast and racked in by hand. Topsoil 

stockpiles would generally be located north or east of roads so they do not serve 

as snow fences. Locations of the long-term stockpiles are noted in Table OP-2a

of the WDEQ-LQD Permit to Mine (LCI, 2011b). Other measures, including toe 

ditches, would also be used to minimize wind and water erosion. (Additional 

information on short-term and long-term topsoil stockpile protection is included 

in Section OP 2.5 of the WDEQ-LQD Permit to Mine [LCI, 2011b].) 

Excavated soils would be replaced at the location from which they were 

excavated; unless, the area from which the soils were excavated is approved for a 

different post-mine land use (e.g., the landowner requests that a road or building 

remain in place and that request is approved by WDEQ-LQD). In such a case, the 

excavated soil from the road or building area would be used in another area where 

the original topsoil depth was thin or non-existent (e.g., it was disturbed by 

historic exploration activities), if such replacement is approved by WDEQ-LQD. 

Prior to replacement of soils from long-term stockpiles, the soils would be 

sampled for fertility and the sampling results compared to the baseline results. If 

necessary based on the sampling results, soil amendments or changes to the soil 

reapplication or seeding practices would be proposed to the BLM and WDEQLQD ensure the topsoil is sufficiently productive for successful revegetation. 

Replaced soil thicknesses would correspond to depths and acreages salvaged 

during Construction. The replacement would be along contour, where necessary 

to prevent soil erosion. To avoid clods, soils would not be replaced when the 

ground is wet or frozen. The replaced topsoil would be disced to create a proper 

seed bed. (Section RP 4.5.3 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). 

4.5.1.3 Erosion and Compaction Minimization 

Soil loss from wind erosion would be controlled by removing vegetation only 

where necessary, and by techniques that may include surfacing roads with gravel, 

limiting traffic speeds, watering unpaved roads, spreading soil binding agents, 

mulching, inclusion of wind breaks, and timely reclamation. Soil loss from water 

erosion would be reduced by timely reclamation, installing drainage controls and 

sediment trapping structures, and reseeding and installing water bars across 

reclaimed areas. 
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To stabilize soils and support the ecosystem, vegetation would be established at 

disturbed areas as soon as conditions allow. For short-term disturbances during 

the life of the Project, such as pipeline installation, the temporary or permanent 

seed mix may be used, depending on the time of seeding and the erosion risk. For 

Reclamation, the permanent seed mix would be used. The permanent seed mix 

was approved by the BLM Rawlins Office on January 14, 2010 and WDEQ-LQD 

(Section RP 4.5.4 of the WDEQ-LQD Permit (LCI, 2011b). The temporary seed 

mix would be a rigorous certified weed-free annual cover crop, such as sterile rye 

grass or millet. 

The negative effects on soil properties resulting from the high volume and degree 

of constant activity at the Permit Area would be minimized where possible. Soils 

compacted during construction and operational activities would be disced and 

seeded as early as possible following use. Vehicular traffic would be minimized 

and restricted to specific routes. In particular, traffic routes would be established 

within mine units. This would reduce the occurrence of compacted soils. 

4.5.1.4 Soil Contamination Prevention 

Tank containments would be designed to prevent releases to soil from tank 

failure. Pipelines would be buried five to six feet below ground surface (i.e., 

below the frost line) and constructed of a corrosion-free HDPE material. Mine 

unit and pipeline flow and pressure would be continuously monitored during 

Operation to ensure timely detection of any releases from pipeline breaks or 

ruptures. An automatic shutdown system would be installed to limit the volume 

of such releases. To minimize potential impacts from accidental spills, LCI 

would develop and implement a Spill Prevention, Control, and Countermeasure 

(SPCC) plan. The SPCC plan would include directions on spill prevention 

inspection, accidental discharge reporting procedures, spill response, and cleanup 

measures. 

Prevention and remediation of accidental releases, which could potentially 

contaminate soils, would be enacted as described in Section OP 2.9 of the 

WDEQ-LQD Permit to Mine (LCI, 2011b). Measures would be taken to ensure 

the operational safety and integrity of pipelines, fittings, valves, tanks, wells, 

buildings, Storage Ponds, and fuel storage areas. Additional practices for the 

minimization of spills are described in Section 7.5.2 of the NRC Technical Report 

(LCI, 2010). 

4.5.2 Monitoring of Soil Impacts 

Regular inspection of topsoil removal practices, erosion controls, topsoil 

stockpiles, reapplication practices, and reclamation/revegetation status would be 

conducted to ensure that soil protection measures are working properly. 
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4.5.3 Impact Significance Criteria 

The criteria used to evaluate soil impacts are both quantitative and qualitative. 

For evaluating soil disturbance, the amount of topsoil that would be disturbed has 

been estimated, and the actual disturbance would be evaluated against that 

estimate to ensure it is not substantially exceeded. In order to adequately restore 

soil, it would be necessary to assess that the same depth of material is placed after 

removal. Furthermore, the material used to replace the disturbed soils would need 

to be suitable, viable topsoil in order to ensure vegetative success after 

reclamation. Finally, success in stabilizing topsoil and minimizing erosion would 

be evaluated. 

4.5.4 Soil Impacts from the Proposed Action 

Total short-term and long-term acreage of soil disturbance and amounts of 

removal and stockpiling of topsoil were estimated for the life of the Project. For 

purposes of topsoil removal, short-term was defined as a few days to a few 

months, while long-term was defined as the duration of the Project. Long-term 

disturbances would occur with the construction of buildings, which would exist 

for the life of the Project, e.g., under the Plant, and the area would only be 

reseeded during Final Reclamation, after the facilities are removed and topsoil 

replaced. Short-term disturbance would occur in areas where topsoil would be 

removed, but topsoil would be replaced shortly after the disturbance, and the area 

would be reseeded to reestablish vegetation for erosion control (e.g., pipeline 

installation during Mine Unit Development and pipeline removal during Mine 

Unit Reclamation). 

Table 4.5-1 shows the estimated acreage for topsoil stripping and vegetation 

disturbance. The location of the soils with respect to Project infrastructure can be 

seen in Figure 3.4-1. It was estimated that a total of approximately 72 acres and 

231,295 cubic yards of topsoil could potentially be removed and stockpiled on a 

short-term basis and a total of approximately 103 acres and 332,238 cubic yards 

of topsoil could potentially be removed and stockpiled on a long-term basis 

(Table 4.5-1). However, as outlined below, this soil disturbance is progressive, 

i.e., it does not all occur in the Initial Construction phase. 

Soils could also have the potential to erode if improper construction or excavation 

design were enacted. Also, the possibility of spills could potentially cause soil 

contamination; however, both of these impacts are expected to be minimized by 

the protective measures in place (Section 4.5.1). 
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Table 4.5-1 Vegetation and Topsoil Disturbance (Page 1 of 4) 
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Table 4.5-1 Ve

getation and To

psoil Disturbance (Pa

ge 2 of 4) ge op ( ag ) Table 4.5-1 Ve

getation and To

psoil Disturbance (Pa

ge 2 of 4)
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Table 4.5-1 Ve

getation and To

psoil Disturbance (Pa

ge 3 of 4)
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April 2012 Table 4.5-1 Vegetation and Topsoil Disturbance (Page 4 of 4) 
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4.5.4.1 Construction 

During Initial Construction, principal impacts on soils would result from earthmoving activities associated with construction and excavation of the Plant, 

staging areas, the five deep wells and associated pipelines (some of which might 

not be installed or installed later), the trunkline (which would actually be 

constructed in stages as the mine units are brought on-line); and the access road 

improvements. 

The soil impacts depend on the number of acres disturbed, the type of 

disturbance, and the time period of disturbance. The amount of long-term topsoil 

removal and stockpiling during Initial Construction is on the order of 61 acres and 

195,210 cubic yards. The amount of short-term topsoil removal and stockpiling 

during Initial Construction is on the order of 33 acres and 107,018 cubic yards 

(Table 4.5-1). 

During Mine Unit Development, surface disturbance would result from activities 

related to development of new mine units, which includes drilling of injection, 

production and monitor wells, and construction of pipelines, header houses and 

necessary access roads. The impacts would be similar to those discussed above, 

but the facilities being constructed would be smaller, e.g., header houses, and the 

facilities would be in place for the life of the mine unit, but not the life of the 

Project. For the purpose of determining the acres of soil disturbance during 

Construction, the mine unit facilities are listed below and in Table 4.5-1: 

x pipelines outside the pattern areas; 

x drill pads outside the pattern areas (This includes exploration holes and the 

monitor well rings. The MU1 monitor wells were installed in 2006 to 

2008 to obtain the necessary subsurface information for permitting the 

Project. The surface disturbance associated with those wells is still 

included in this estimate.); 

x secondary and two-track roads to and within the mine units; and 

x pattern areas. 

The amount of long-term topsoil removal and stockpiling during the Mine Unit 

Development phase for the HJ Horizon is on the order of 43 acres and 137,027 

cubic yards. The amount of short-term topsoil removal and stockpiling during 

Mine Unit Development is on the order of 39 acres and 124,276 cubic yards. 

Based on available information, the underlying KM Horizon ore body footprint is 

similar to the HJ Horizon. Therefore, existing roads and pipelines could be used 

to develop the KM Horizon, but additional drilling for monitoring wells and the 

KM pattern area would be needed. The additional area is estimated to be 15 

acres, and assuming topsoil removal would be needed for all of that 15 acres, the 

increased topsoil volume would be about 48,400 cubic yards (Table 4.5-1). A 
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more detailed assessment of the projected surface disturbance related to 

development of the KM Horizon would be available when LCI submits a permit 

revision to WDEQ-LQD. 

Facility development would displace topsoil, which would adversely affect the 

structure and microbial activity of the soil. Loss of vegetation would expose soils 

and could result in a loss of organic matter in the soil. Excavation would cause 

mixing of soil layers and breakdown of the soil structure. Removal and 

stockpiling of soils for reclamation would result in mixing of soil profiles and loss 

of soil structure. However, measures would be taken to ensure that soils are 

properly excavated and stored to maintain topsoil integrity (Section 4.5.1). 

Construction activities have the potential to compact soils. While soils sensitive 

to compaction, such as clay loams, do not exist in the Permit Area, the intense 

volume and degree of constant activity could damage soil properties and cause 

compaction. Compaction of the soil could decrease pore space and cause a loss of 

soil structure as well. This would result in a reduction of natural soil productivity. 

Wind erosion is also a potential concern at the Permit Area. Most of the soils in 

the Permit Area have a significant percentage of silt, which has been shown to be 

directly related to dust emissions from unpaved roads. Vehicular traffic on these 

unpaved roads and construction presents the greatest threat to soils with potential 

for wind erosion. Traffic in the Permit Area, however, would be restricted 

(Section 4.5.1), which would minimize erosion and compaction impacts. 

Water erosion is not a large concern at the Permit Area due to very low (flat) 

surface slopes, limited amount of precipitation and the lack of perennial and 

intermittent streams. However, removal of vegetation for any activity exposes 

soils to increased erosion. Excavation could break down soil aggregates, 

increasing runoff and gully formation. These impacts would be minimized by 

appropriate drainage designs and excavation techniques (Section 4.5.1). 

Saline soils are very susceptible to soil loss caused by development. Saline soils 

are not common within the Permit Area. Only one of the 28 soil samples 

collected from the Permit Area was slightly saline. 

Surface spillage of fuels, lubricants and other chemicals used during Construction 

could occur at the Permit Area. If not remediated quickly, these materials have 

the potential to adversely impact soil resources. Proper preventative and 

protective practices would help minimize these risks (Section 4.5.1). 

The NRC SEIS (Section 4.4) concludes that most impacts to the soil would occur 

during the Construction phase, when new infrastructure is being constructed and 

soil is being moved. Due to the small nature of the disturbed soils (less than one 

percent of the total project area), the impacts to the soil are expected to be 

minimal (NRC, 2011a). 
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4.5.4.2 Operation 

During the Operation phase, there would be little, if any, new disturbance. Wind 

and water erosion due to loss of vegetation, as well as soil compaction and loss of 

soil structure would still occur, but at a slightly smaller scale compared with those 

in the Construction phase. Protective measures (Section 4.5.1) would be followed 

during the Operation phase as well, thus, minimizing these impacts. 

Surface spillage of process materials (such as barren and pregnant solutions, as 

well as effluents), fuels, lubricants and other chemicals used during Project 

operations could occur in the Permit Area, which, if not remediated quickly, has 

the potential to adversely impact soil resources. However, as mentioned in the 

Construction discussion above, proper preventative and protective practices 

would help minimize these risks (Section 4.5.1). 

Section 4.4.1.2 of the NRC SEIS discusses that the potential for leaks, spills, or 

pipeline breaks could contaminate the soils. However, with the response and 

protective measures in place, there would likely be no long-term impacts to the 

soil (NRC, 2011a). 

4.5.4.3 Reclamation 

Impacts on soil from Reclamation are minimal. During Mine Unit Reclamation, 

disturbance would again occur during some activities, e.g., when wells are 

abandoned and pipelines are removed from reseeded areas. This ‘re-disturbance’ 

of the same areas is not counted twice in the assessment of the acres disturbed. 

During Final Reclamation, short-term, limited impacts could result from 

dismantling process facilities and associated structures, removing buried piping, 

and plugging and abandoning wells. Disruption and/or displacement of existing 

soils would be relatively slight. 

While there may be some short-term impacts as reclamation is in progress, the 

objective of these activities is to return the Permit Area to pre-mining land use. 

Reclamation of disturbed areas (especially long-term disturbance areas) would 

improve soil quality in the Permit Area and offset any adverse impacts. 

Sections 4.4.1.3 and 4.4.1.4 of the NRC SEIS discuss the potential impacts to the 

soil as a result of this project. Similar to Construction, there is soil excavation 

and replacement, however, the purpose of reclamation is to return the land surface 

to its previous condition. Similar to the Operation phase, there is a concern for 

soil contamination. Due to protective measures and the small scale of the 

disturbed land, impacts to the soil during Reclamation are expected to be minimal 

(NRC, 2011a). 
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4.5.5 Soil Impacts from Other Alternatives 

4.5.5.1 No Action Alternative 

The No Action Alternative would result in no change to existing soil conditions at 

the Permit Area or in the region. Surface disturbance would be avoided and the 

area would retain its soil characteristics for the region. Existing land use activities 

(livestock grazing, wildlife habitat, dispersed recreation, minerals and energy 

development, and infrastructure) that impact the soils of the Permit Area would 

still occur. 

4.5.5.2 Not Fencing the Pattern Areas 

There would be only a slight reduction in the soil disturbance if the fences around 

the patterns areas were not constructed. However, the protective measures in the 

pattern areas, specifically reseeding, to reduce erosion risks and maintain topsoil 

viability, would be adversely impacted as the new vegetation growth in the 

reseeded areas would be preferred by livestock and wild horses and less likely to 

take root efficiently. 

4.5.5.3 Drying Yellowcake On-Site 

This alternative would have no impact on soil resources at the Permit Area, as the 

dryer would be within the existing Plant footprint. 
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4.6 Surface Water 

The proposed mine units are in confined aquifers several hundred feet below 

ground surface, and there is no known hydraulic connection between the surface 

of the Permit Area and those aquifers (Section 3.6). Therefore, the discussion of 

hydrologic impacts is separated on the basis of surface water impacts and 

groundwater impacts. 

4.6.1 Agency-Required Measures 

Environmental protection measures to address potential impacts to surface water 

quality include measures to reduce sediment transport and measures to prevent 

and remediate spills and leaks. The required environmental protection measures 

are summarized below from Sections OP 2.9, OP 2.11.1, OP 3.5, Attachments 

OP-2 & OP-4, and Sections RP 3.0 and 4.0 of the WDEQ-LQD Permit to Mine 

(LCI, 2011b), Sections 4.2.5.5, 5.7.1.4, and 5.7.6.6 of the NRC Technical Report 

(LCI, 2010), and Sections 2.1.1.1.2.3 and 2.1.1.1.5.4, 6.2.2, 6.2.4, 6.3.2, and 6.3.3 

of the NRC SEIS (NRC, 2011a). 

Based on the BLM review of the agency-required measures, a BLM management 

action was added. The BLM would require that surface disturbing activities be 

avoided within 100 feet of the inner gorge of ephemeral channels. Exceptions to 

this would be granted by the BLM based on an environmental analysis and sitespecific engineering and mitigation plans and only those actions within areas that 

cannot be avoided and that provide protection for the resource identified would be 

approved. 

4.6.1.1 Measures Related to Sediment Transport 

The primary measures to address surface water quality impacts related to 

sediment transport would include: 

x limiting soil compaction and removal and protecting excavated topsoil and 

subsurface material from erosion in accordance with Standard Operating 

Procedures (SOPs) and the Spill Prevention Control and Countermeasures 

(SPCC) Plan; 

x ensuring that runoff from disturbed areas meets WYPDES permit 

guidelines for stormwater management and sediment reduction; 

x minimizing well or other facility installation within/near the ephemeral 

channels; and 

x completing appropriate reclamation practices in a timely manner. 

No unstable surface areas, including areas so defined in the Rawlins RMP 

(landslides, slopes of greater than 25 percent, slumps, and areas exhibiting soil 
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creep) are present within the Permit Area. Similarly, no 100-year floodplains, 

perennial waters, springs, wetlands, or riparian areas are present within the Permit 

Area. Ephemeral areas within 100 feet of the inner gorge of ephemeral channels 

may be affected by the Project. The road routes and well locations within a mine 

unit cannot be specifically delineated until the locations of the monitor well ring 

and pattern area within the mine unit are selected based on the delineation of the 

ore body during exploration drilling. If potential travel routes or well locations 

within a mine unit are near ephemeral channels, the BLM hydrologist would be 

contacted to determine if additional protection measures, other than those listed in 

this EIS are necessary. Plans for drainage diversion around the Plant, road 

culverts, and other protection measures are included in Attachment OP-4, Figure 

OP-3c, and related text in Section 2.5, 2.6, and 2.11.1 of the WDEQ-LQD Permit 

to Mine (LCI, 2011b). 

Protection from Compaction/Erosion 

During well development and pump testing, extracted groundwater would be 

discharged to the surface under the provisions of a general WYPDES permit, in a 

manner that mitigates erosion, or would be reused in the drilling process. Soil 

compaction during drilling and pipeline installation can be limited by using 

existing roads to the extent possible. Once a drill site, pipeline route, or facility 

location has been selected, topsoil and subsurface materials would be removed 

and protected in accordance with established procedures to prevent erosion and 

movement of sediment into drainages. To the extent practical, pipe and power line 

installation would occur alongside access roads to limit the overall disturbance 

footprint. When the road is not the shortest path, the utilities would follow the 

most direct path available. Vegetation buffers would be maintained between the 

disturbed area and the drainage whenever possible. The compaction/erosion 

protection measures are described in greater detail in the Section OP 2.5 and 

1.22.1.1 of the WDEQ-LQD Permit to Mine (LCI, 2011b). In addition, runoff 

would be diverted away from exposed soils. There are several practices that 

would mitigate impacts to surface water and ephemeral drainages, including use 

of silt fences, earth dikes, drainage swales, sediment traps, check dams, straw 

bales, construction of water contour bars, application of rip rap, grading and 

contouring, temporary or permanent sediment basins, temporary seeding, 

permanent seeding, mulching, use of geotextiles, sod stabilization, vegetative 

buffer strips, and preservation of mature vegetation, WDEQ-LQD Permit to Mine 

(Sections OP 2.5 and OP 2.11.1.1) (LCI, 2011b). 

Runoff Control 

The physical presence of small facilities (e.g., header houses) are not expected to 

significantly change peak surface water flows because of the relatively flat 

topography of the drainages at the sites, the low regional precipitation, the 

absorptive capacity of the soils, and the small area of disturbance relative to the 

large drainage area within and adjacent to the Permit Area. However, in areas 
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where larger structures (such as the office building and parking lot) may affect 

surface water drainage patterns, diversion ditches and engineered culverts would 

be used to prevent erosion and to control runoff. The drainage control plan for the 

Plant and the road and culvert designs are included in Attachment OP-4 and 

Section OP-2.6 of the WDEQ-LQD Permit to Mine, respectively (LCI, 2011b). 

In areas where runoff is concentrated, energy dissipaters may be used to slow the 

flow of runoff to minimize erosion and sediment loading in the runoff. 

No paved areas are currently planned for the Permit Area. However, if any areas 

are paved, storm water runoff from those areas would be collected by a storm 

water system. The storm water would be temporarily retained in a detention basin 

to reduce the amounts of oils and other pollutants from entering surface water and 

ephemeral drainages. These detention ponds would be designed to control the 

release of storm water runoff at a rate equal to or slightly less than that of the preexploration period. 

The SWPPP (Large Construction General Permit WYR10-0000) would also be 

implemented in accordance with WYPDES requirements. Drainage plans and 

culvert designs are included in the WDEQ-LQD Permit to Mine (e.g., Section OP 

2.6 and Attachment OP-4) (LCI, 2011b). 

Well Placement 

In very rare instances, it may be necessary to install wells in or near an ephemeral 

channel. This would only be done with the authorization of the BLM. If 

approved, the following measures would be implemented to minimize potential 

impacts to the channel. Also see drainage plans and culvert designs included in 

the WDEQ-LQD Permit to Mine (e.g., Section OP 2.6 and Attachment OP-4) 

(LCI, 2011b): 

x installation would be conducted during the dry season; 

x drilling fluid and residual cuttings in the mud pit would be emptied and 

cleaned upon the completion of the installation; and 

x wellheads would be designed to withstand storm water flows using 

exterior protection measures. (Protection measures may include barriers 

surrounding the wellhead, protective steel casing, cement blocks or other 

means to protect the wellhead from damage that may be caused by runoff.) 

Reclamation 

After short-term disturbances during Construction and Mine Unit Development, 

such as pipeline installation, the disturbed areas would be revegetated with either 

a temporary seed mix or with the permanent seed mix (Sections 4.5 and 4.8). The 

specific reclamation practices are detailed in the WDEQ-LQD Permit to Mine 

(e.g., Sections OP 2.5 and RP 4.5) (LCI, 2011b). 
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4.6.1.2 Measures Related to Spills and Leaks 

These environmental protection measures include: selection of appropriate 

materials for pipelines, wellheads, and tanks; proper installation and testing of 

those materials prior to use; and inspection and maintenance. Piping and 

associated fittings would only be constructed of materials that are chemically 

compatible, able to withstand the expected operating pressures, and compatible 

with ambient conditions. Piping would also be buried at sufficient depth (48 TO 

72 inches below surface) to prevent freezing or pressure impacts from the surface. 

Pipelines and wellheads would be pressure checked before being placed into 

operation and after significant repairs. Automated monitoring would be installed 

so any significant change in flow or pressure is detected and operators are 

notified. Berms, including perimeter and internal berms, would be in place to 

control the movement of spills. Each operating mine unit would be inspected at 

least once per day, and the entire Plant also would be inspected at least daily when 

operating. Should a spill or leak occur, remediation and reporting procedures 

have also been developed. The protection measures are described in greater detail 

in the WDEQ-LQD Permit to Mine (e.g., Sections OP 2.9, OP 3.5, and OP 4.4 

and Attachment OP-2) (LCI, 2011b) and with more focus on radiological 

concerns in the NRC Technical Report (e.g., Sections 4.2.5.5, 5.7.1.4, and 5.7.6.6) 

(LCI, 2010). 

4.6.2 Monitoring of Surface Water Impacts 

The drainages throughout the Permit Area are ephemeral and flow only in 

response to spring runoff or occasional strong thunderstorms. Because of the 

limited flows, and lack of anticipated impacts, continued surface water sampling 

is not planned except as necessary in response to a specific concern, such as a 

spill. 

4.6.3 Impact Significance Criteria 

The factors identified in the Rawlins RMP were used to assess the significance of 

surface water impacts on the environment (BLM, 2008c). 

x Degradation of water quality beyond the designated use of the 

receiving waterbody, or other violations of federal or state water 

quality standards, or negatively impacting a waterbody listed on 

the State 303d list of Impaired or Threatened Waterbodies. 

x Unmitigated loss of wetlands or wetland function (EO 11990 and 

EO 11988) or activities that would degrade wetland/riparian areas 

such that, as a minimum physical state, proper functioning 

condition and Standards for Healthy Rangelands (USDI-BLM 

1997) are not being maintained. 

x Streamflow characteristics of perennial streams are altered such 

that established uses by the public and by federal, state, and local 
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agencies for fisheries and wildlife and for livestock, recreational, 

municipal, and industrial uses are affected. 

x The alteration of stream channel geometry or gradient by 

accelerated runoff and erosion (e.g., undesirable aggradation, 

degradation, or side cutting) beyond what would be expected by 

natural processes. 

The WDEQ-WQD and LQD criteria were also used to assess the significance of 

surface water impacts on the environment. 

4.6.4 Surface Water Impacts from the Proposed Action 

Because of the limited quantity of surface water within the Permit Area and the 

operational measures that would be taken to avoid impacts to the surface water, 

no impacts are anticipated. However, potential impacts outlined are presented to 

better illustrate the need for the protection measures described in Section 4.6.1. 

The nature and scale of the potential impacts that the Project will have on surface 

water are very similar through all of the three phases (i.e., Construction, 

Operation and Reclamation) of the Project. The surface water impact evaluation 

is, therefore, organized by water quantity (including water use) and water quality. 

4.6.4.1 Surface Water Quantity and Use 

As noted in Section 3.5, perennial or intermittent streams do not exist within the 

Permit Area or on adjacent lands; and there are no surface water use permits 

inside or within two miles of the Permit Area. There are however, ephemeral 

drainages within the Permit Area, which may be affected by erosion. Erosion 

controls would be in place to minimize this impact (Section 4.6.1). 

4.6.4.2 Surface Water Quality 

Potential impacts to the surface water quality in the ephemeral drainages in the 

Permit Area relate to increased sediment transport and spills and leaks. 

Sediment Transport 

The primary surface disturbances associated with ISR operations occur with well 

drilling, pipeline installations, road and facility construction and reclamation 

activities. These disturbances generally involve relatively small areas and have 

short-term impacts, as defined in Section 4.1.3. The larger areas of surface 

disturbance, such as the Plant, would require the diversion of stormwater runoff, 

and culverts would need to be installed under some roads. Without the required 

protection measures, the disturbances and diversions could result in adverse 

impacts, especially at places where relief is high, due to increased erosion 

potential from surface water runoff and/or due to transport of sediment. Because 
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of the low relief across the Permit Area, the ephemeral nature of the drainages, 

and limited precipitation and runoff, the primary areas of concern for sediment 

accumulation are low spots along the roads and drainages where runoff 

accumulates. 

Activities associated with drilling, pipeline installations, and road and mine unit 

construction reduce vegetation cover and soil compaction from heavy machinery 

and frequent traffic. Without vegetation, topsoil is vulnerable to erosion from 

storm events. Soil compaction can result in decreased infiltration rates and 

increased surface runoff, which can increase peak flows and further increase 

surface erosion. Roads to and from the drill sites can become preferential 

pathways for surface water runoff due to compaction and rut depressions. 

Although soil would be stripped from specific areas, such as drill pits and the 

Plant, and stockpiled for replacement during Reclamation, improperly protected 

stockpiles can also erode, increasing sediment loads in surface water runoff. 

During Reclamation, activities, such as discing to loosen compacted soil, could 

result in increased sedimentation to surface water runoff if the increased erosion 

potential were not considered, e.g., discing across the direction of flow. 

The NRC SEIS states that the changes to sediment transport can come from the 

construction activities and vehicular traffic. However, due to the topography of 

the area and the lack of annual surface water, the overall impact on surface water 

quality would be minimal, similar to the assessment in Section 4.6.2 of this EIS 

(NRC, 2011a). 

Spills and Leaks 

Surface water runoff could be impacted due to a spill or leak from wellheads, 

pipelines, or tanks in use during Construction, Operation, or Reclamation. The 

most common accidental release from ISR operations is from breaks, leaks, or 

separations in the piping that transfers mining fluids to and from the Plant and the 

mine units. Failures of fittings and valves at the wellheads, in the header houses, 

at tanks, and other junctions are also a common cause of accidental releases at 

ISR operations. Spill and leak prevention measures would be outlined in the plan 

for Spill Prevention Control and Countermeasures (SPCC). 

The NRC SEIS addresses spills and leaks to surface water in Section 5.1.1. The 

NRC states that the protection and clean-up measures are such that impacts to 

surface waters would be minimal (NRC, 2011a). 

4.6.5 Surface Water Impacts from Other Alternatives 

The No Action Alternative would not generate any additional impacts to the 

existing surface water resources. 
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The Proposed Action includes fencing the pattern area in each mine unit. If the 

pattern areas were not fenced, the potential for soil erosion and subsequent 

sediment in runoff could be slightly increased because of grazing in the pattern 

areas. There would also be a substantial increase in the risk of spills and leaks 

because of livestock damage to wellheads and pipelines. 

No significant differences are expected between the potential impacts from the 

Proposed Action and the other alternatives (Drying Yellowcake On-Site). 
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4.7 Groundwater 

As described in Section 3.6, groundwater occurs within the Battle Spring 

Formation in a series of relatively flat-lying sandstones. Five distinct uraniumbearing sandstones have been identified in the Permit Area and include, from the 

shallowest to the deepest, the BC, DE, FG, HJ, and KM Horizons. The horizons 

consist of very fine- to coarse-grained arkosic sandstone separated by layers of 

shale, mudstone and siltstone. Groundwater occurs in confined aquifers several 

hundred feet below the ground surface; and there is no known hydraulic 

connection between the surface of the Permit Area and those aquifers. The DE 

Horizon is the first aquifer within the Permit Area, the top of which ranges from 

100 to 200 ft bgs. The depth to the groundwater in the DE Horizon ranges from 

155 feet to over 257 feet. The BC Horizon overlying the DE Horizon is 

unsaturated and separated from the DE Horizon by shale. The HJ Horizon is the 

primary target for the Project and it ranges from 300 to 450 ft bgs. 

4.7.1 Agency-Required Measures 

The required environmental protection measures are summarized below from: 

Sections OP 2.9, 2.11, and 3.0, Attachments OP-2, OP-7, & OP-8, and Sections 

RP 1.0 and 2.0 of the WDEQ-LQD Permit to Mine (LCI, 2011b); Sections 

2.1.1.1.2.4.1 through 2.1.1.1.2.4.3, 2.1.1.1.3.1.1 through 2.1.1.1.3.1.3, 2.1.1.1.4, 

6.2.5, and 6.3.1 of the NRC SEIS (NRC, 2011a); and Conditions 10.1, 10.5, 10.7 

through 10.13, 11.1, 11.3 through 11.6, 12.4, 12.7, and 12.15 of the NRC License 

(NRC, 2011b). References to specific subsections of the WDEQ-LQD Permit to 

Mine are also included. Based on the BLM review of the agency-required 

measures, one management action was added. To provide additional monitoring 

data on Stabilization (Section 4.7.1.1) for on-going reviews of regulatory 

requirements (EPA, 2011b), at least two additional stability monitoring samples 

would be collected, once every three months over a six-month period, after the 

initial stability period. 

The discussion of required measures is separated on the basis of on-site and offsite measures because of the different concerns. On-site, the concerns are related 

to conducting Mine Unit Operation and Reclamation as efficiently as possible and 

emphasizing water quality monitoring. Off-site, the concern is related to the 

extent to which on-site groundwater extraction would draw down water levels in 

the four off-site BLM wells. 

Although not a direct protective measure, the requirement that LCI post a bond 

for site reclamation, including groundwater restoration, provides an assurance that 

the restoration and reclamation activities can be conducted by the permitting and 

licensing agencies should LCI not fulfill its obligations. The bond amount is 

detailed in Table RP-4 of the WDEQ-LQD Permit to Mine (LCI, 2011b). The 
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BLM has access to that bond, if necessary, for site reclamation on public lands 

administered by the BLM. 

4.7.1.1 On-Site Required Measures 

Permit Area 

Water from the supply wells would be used as efficiently as possible, and regular 

maintenance would be conducted to check for leaks in the distribution system and 

make the necessary repairs. Procedures and training for spill prevention and, if 

necessary, remediation would reduce the possibility of a spill or other accidental 

release that could impact groundwater. 

Storage Ponds 

To mitigate the likelihood of pond failure, the two Storage Ponds would be 

designed and built to NRC standards using impermeable synthetic liners. A leak 

detection system would also be installed, and all ponds would be inspected on a 

regular basis. In the event that a problem is detected, the contents of any given 

pond can be transferred to another pond while repairs are made. The proposed 

pond design and operation is discussed in greater detail in Section 2.1.2.2. 

In the event of a detected leak in a Storage Pond, corrective actions would include 

lowering the pond level and locating the leak to allow repairs. Impacts to 

groundwater from a leak associated with the Storage Ponds are remote, since the 

outer pond liner is designed to prevent a release of the pond contents, and the 

depth to the in the DE Horizon. However if a leak went undetected and the 

contaminated water reached the groundwater in the DE Horizon the impact to 

groundwater would be high and long-term. All pond leaks, causes, and corrective 

actions would be reported to NRC and WDEQ. 

With respect to potential overflow of a pond, operating procedures would require 

that pond levels be closely monitored as part of the daily inspection. Process flow 

to the ponds would be minimal in comparison to the pond capacity, thus 

facilitating diversion to another pond if necessary. In addition, sufficient 

freeboard would be maintained on the Storage Ponds to allow for a significant 

addition of rainwater with no threat of overflow. Finally, the dikes and berms 

around the Storage Ponds would channel runoff away from the Storage Ponds. 

Pipelines and Related Equipment 

Groundwater impacts from a spill of injection or production solutions from a 

header house or associated piping are unlikely due to the depth to groundwater. 

In addition, any impacts can be prevented by proper design, construction, and 

testing. Pipelines would generally be buried from 48 to 72 inches below the 
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surface, minimizing the possibility of freezing in adverse weather and of being 

damaged by surface traffic. In general, piping to and from the Plant and the mine 

units and within the mine units would be constructed of HDPE with butt-welded 

joints or the equivalent. All pipelines and related equipment that would be under 

pressure during Operation would be pressure tested before use. In addition, 

pressures in the pipelines and related equipment are monitored to ensure pressure 

drops or surges do not occur, which could indicate a leak or the potential for well 

or formation damage. Sections OP 3.5 and 3.6.4 of the WDEQ-LQD Permit to 

Mine (LCI, 2011b) contains additional information about leak detection and 

pressure monitoring measures in the mine units. 

Mine Units 

The measures to address impacts from ISR begin before the mine units are 

installed and continues through operation and groundwater restoration. The 

measures include a variety of actions and techniques, including aquifer testing, 

mechanical integrity testing, and reverse osmosis treatment after mining, as 

outlined below. 

Before Construction (Baseline Data) 

A critical initial measure is to ensure the hydrogeologic conditions in a mine unit 

are well understood. Exploration and delineation drilling, geophysical logging, 

and aquifer testing are conducted to ensure undetected high permeability strata, 

geologic faults, improperly abandoned exploration drill holes, and/or 

discontinuous confining units that could allow movement of the lixiviant out of 

the ore zone are identified prior to mine unit operations. Appropriate actions, 

such as additional drill hole abandonment and/or additional monitoring, can then 

be taken to address such conditions. In older ISR operations, this preliminary 

measure was not necessarily conducted as stringently as today. Regulatory 

review of the plans for, and results of, baseline data collection for each mine unit 

is also required through the Hydrologic Test Plan and Report (Section 2.1.2.3). 

Mechanical integrity testing of wells and piping prior to use also reduces the 

possibility of groundwater impacts. The aquifer testing of the mine unit monitor 

well system also demonstrates that the wells in the monitor well ring can 

efficiently detect excursions and that an excursion can be recovered within a 

specified time. 

During Operation 

Mechanical integrity testing continues during operation, and the schedule for 

monitoring (Section 4.7.2) and actions to be taken should an excursion occur are 

specified in the WDEQ-LQD Permit to Mine and NRC License. For an ISR 

operation, the key to efficient mining and reduction of any potential impacts is the 

balance of production and injection within the pattern area. The design of the 
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Project addresses instrumentation and monitoring systems (and review of the 

information from those systems) ensures that the water balance throughout the 

mine units and Plant are working as planned (Sections OP 3.5, 3.6, and 4.0 and 

Attachment OP-2 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). 

If an excursion occurs, appropriate corrective actions would be instituted 

including: conducting a preliminary investigation to determine the probable 

cause; adjusting production and/or injection rates in the vicinity of the excursion 

to generate an effective net process bleed and forming a hydraulic gradient toward 

the production zone; pumping individual wells to enhance recovery of the ISR 

solution, and suspending injection into the pattern area near the excursion, thereby 

increasing the overall bleed rate and the recovery of the ISR solution. Section OP 

3.6.4 of the WDEQ-LQD Permit to Mine (LCI, 2011b) provides more detail on 

excursion response, including evaluation of the ability to control an excursion. 

During Restoration 

The groundwater restoration techniques, including the more traditional techniques 

of sweep, reverse osmosis (RO), and recirculation, and ones that may be used, 

including groundwater transfer, reductant addition, and biorestoration, are 

designed to mitigate groundwater quality impacts from ISR by returning the water 

quality to the uses for which it was suitable before ISR and to applicable 

standards, in accordance with federal and state regulatory requirements. Timely 

application of the restoration techniques and planned monitoring also mitigate 

groundwater quality impacts from ISR and from the restoration activities by 

establishing that the restoration techniques are working as planned and 

determining if adjustments needed. 

Of the restoration techniques, groundwater sweep has the most impact on water 

levels, and to mitigate those impacts, use of alternate techniques, such as 

groundwater transfer, would be used where possible and if they prove as effective. 

During Restoration, the water level changes from would be evaluated to minimize 

interference among the mine units. The vast majority (e.g., on the order of 99 

percent) of groundwater used during Restoration would be treated and re-injected. 

The highest rate of groundwater withdrawal would be on the order of 100 gpm. 

After it has been determined that uranium recovery is complete in a given mine 

unit the lixiviant injection ceases and the groundwater restoration begins. The 

objective of restoration and reclamation is to return the affected groundwater to 

the pre-operational class-of-use in accordance with WDEQ-WQD requirements 

on the basis of baseline water quality data. Active restoration would take between 

18 to 36 months for each mine unit followed by stability monitoring and 

regulatory approval (Section 2.1.6.3). 

Groundwater Sweep 

During groundwater sweep, water is pumped from the mine unit without 

offsetting with water injection. This pumping creates an influx of baseline quality 
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native groundwater into the unit, thereby flushing contaminants from areas 

affected by the horizontal and vertical spreading (flare) of the lixiviant during 

mining. The affected water in the edge patterns of the mine unit is also drawn 

back into more central portions of the pattern area, making the later restoration 

phases more efficient. 

Groundwater produced during sweep would contain uranium and other 

constituents mobilized during production. Initial concentrations of the 

constituents would be similar to those during the later stages of production. With 

enough pumping, constituent concentrations would decline gradually, reflecting 

the influx of baseline quality water. The groundwater produced during sweep is 

treated through the restoration plant ion exchange circuit to capture uranium and 

then either treated with reverse osmosis or pumped directly to disposal. 

Reverse Osmosis Treatment 

RO with permeate injection is used following the groundwater sweep phase. This 

treatment is most effective in returning the concentrations of total dissolved solids 

and trace metals and the aquifer pH to baseline values. 

 

During this restoration phase, uranium in the groundwater is removed by passing 

the water through an ion exchange circuit. The ion exchange resins remove the 

majority of the soluble uranium in recovered solutions and yield chloride, sulfate 

or bicarbonate ions in the place of the uranium compounds. The chemistry of the 

ion exchange circuit used in the restoration is identical to the chemistry of the ion 

exchange circuit used in the production circuit. Ion exchange resins preferentially 

remove the uranyl dicarbonate and/or uranyl tricarbonate compounds from the 

solution. Chloride, sulfate and/or bicarbonate compounds are displaced from the 

resin and set into the solution. 

After ion exchange, other chemical constituents in the groundwater including 

TDS and trace metals, such as arsenic, molybdenum, selenium, and/or vanadium, 

are removed by passing the water through an RO system. The RO process yields 

two fluids: clean water (permeate) that can be reinjected into the aquifer; and 

concentrated water (brine) that cannot be reinjected directly. Water sent to the 

RO system usually requires some pre-treatment to prevent fouling of the 

membranes. Commonly, the pH is lowered by addition of sulfuric or 

hydrochloric acid and antiscalant additives may be used. These additives (along 

with the sulfate and/or chloride ions of the acid) are rejected in the RO unit and 

become part of the brine. Therefore, the additives do not become part of the 

permeate which would be injected into the restoration aquifer. After reverse 

osmosis, the permeate may be depressurized to release entrained gasses. This 

process commonly results in a pH increase as carbon dioxide is typically present 

in the permeate and readily released at atmospheric pressure. Sodium hydroxide 

may also be added to increase the pH of the permeate stream prior to injection. 
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Groundwater Transfer 

Groundwater transfer (or exchange) involves moving groundwater between a 

mine unit in restoration and another mine unit where uranium production is 

beginning. Both mine units will first have received approval for UIC Class III 

injection. The transferred groundwater may undergo treatment using one or more 

of the permit-approved processes (such as ion exchange, chemical pH adjustment, 

and/or reverse osmosis) prior to injection. Groundwater transfer is generally used 

to replace operationally-affected waters in the restoration mine unit with baseline 

quality water from the production mine unit. The operationally-affected waters 

from the restoration mine unit are then used as the basis for the lixiviant in the 

production mine unit. Because water is transferred (or exchanged) between mine 

units at equal rates, the transfer typically does not generate liquid effluents and 

has the benefit of reducing groundwater consumption. This technique has been 

successfully used at one other ISR operation, and if the opportunity arises to use 

the technique at the Lost Creek Project, it is projected that the transfer will 

involve between zero and two pore volumes. 

Reductant 

If reductant is added to the injection stream during the RO, it would scavenge 

oxygen and reduce the oxidation-reduction potential (Eh) of the aquifer. During 

ISR operations, certain trace elements are oxidized. By adding a reductant, the Eh 

of the aquifer is theoretically lowered, thereby decreasing the solubility of these 

elements. As warranted, hydrogen sulfide, sodium sulfide, or a similar compound 

may be added as a reductant. LCI is more likely to use sodium sulfide as a 

reductant due to the chemical safety issues associated with proper handling of 

hydrogen sulfide. A comprehensive safety plan regarding reductant use would be 

prepared for regulatory review prior to implementation. 

Biorestoration 

Biological reductants may be evaluated as experimental technology, if site 

conditions are suitable for this restoration technology; however, no biorestoration 

will be conducted without prior regulatory approval. 

Recirculation 

At the completion of RO in a mine unit, recirculation would be initiated. 

Recirculation consists of pumping from the mine unit and re-injecting the 

commingled solution (untreated) into the aquifer it came from. Recirculating 

solution is intended to homogenize the overall groundwater conditions. It is 

anticipated that one pore volume of groundwater would be recirculated. 

Stabilization 

Upon completion of restoration and notification of WDEQ, a stabilization 

monitoring program would begin in which the pattern monitor wells used to 

evaluate restoration success would be sampled. Each pattern monitor well would 

be sampled at the beginning of stabilization and once every three months for a 
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period of 12 months, for a total of five samples, and analyzed for the parameters 

listed in Table RP-1b of the WDEQ-LQD Permit to Mine (LCI, 2011b). 

The stability period would be a minimum of 12 months. Following the end of the 

12-month stability period, LCI would perform a regression analysis on each 

monitored constituent within the pattern monitor wells. This statistical method 

would assist in determining if the concentration of a given constituent exhibits a 

significantly increasing trend during the stability period. The regression analysis 

would be performed in accordance with Chapter 17 on trend analyses in the EPA 

guidance document, "Statistical Analysis of Groundwater Monitoring Data at 

RCRA Facilities: Unified Guidance” (EPA, 2009). If the statistical analysis 

indicates the results are stable, at least two additional samples would be collected, 

once every three months over a six-month period, to provide data for on-going 

reviews of regulatory requirements (EPA, 2011). 

If a constituent exhibits a strongly increasing trend (or in the case of pH a strongly 

increasing or decreasing trend), the action that LCI would take to resolve this 

situation would depend on the constituent and the status of the restored 

groundwater system. As stated in the EPA guidance document, statistical analysis 

provides a “workable decision framework”. However, due to the complexity of 

the aqueous geochemical groundwater systems involved, these statistical 

techniques should not be relied on as the sole determinant when evaluating the 

effectiveness of groundwater restoration. Therefore LCI would consider which 

constituent(s) is showing an increasing trend in concentration and base the 

decision on further action on the status of the mining zone groundwater 

geochemistry. These actions may include extending the stability period or LCI 

may return to a previous phase of active restoration. The phase of active 

restoration that would be used would be determined by the constituent and the 

process required to decrease its concentration. 

During stability monitoring, all overlying, underlying and perimeter monitor wells 

would be analyzed for all UCL parameters once every two months. If 

groundwater restoration has not been successful and an excursion occurs during 

stabilization, then the sampling would revert to weekly for affected monitor wells 

until the excursion is resolved. 

 

If the analytical results continue to meet the appropriate standards for the mine 

unit and do not exhibit significant increasing trends, LCI would submit supporting 

documentation to the regulatory agencies that the restoration parameters have 

remained at or below the restoration standards and request that the mine unit be 

declared restored. 

UIC Class I Wells 

Addressing impacts of the Class I wells begins before the wells are installed and 

continues through operation and reclamation. The initial measures include 
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evaluating the target formation for hydrologic properties, characteristics of the 

formation fluids, compatibility of injected and formation fluids. The results of 

these evaluations are included in the WDEQ-WQD UIC Class I Permit, a copy of 

which is included in the WDEQ-LQD Permit (Attachment ADJ-2, LCI, 2011b). 

Regularly scheduled inspections and maintenance, recording and reviewing 

monitoring results, and personnel training to follow established procedures for 

proper operation of the overall disposal system would reduce the possibility of 

damage to a well from overpressuring or other action that could affect the well 

performance. These requirements are also outlined in the Class I Permit, as are 

well abandonment and financial surety requirements. 

4.7.1.2 Off-Site Required Measures 

The water levels in four BLM stock wells within one mile of the Permit Area 

boundary could be impacted due to the drawdowns associated with groundwater 

withdrawal during Mine Unit Operation and Reclamation. If significant impacts 

to those wells are observed (e.g., water levels drop to a point that impairs the 

usefulness of the wells), the following measures would be considered: 

x lowering the pump level in the wells; 

x deepening the wells; and 

x replacing the wells with new wells completed in deeper sands that are not 

impacted by the Project. 

4.7.2 Groundwater Monitoring 

Similar to the discussion of agency-required measures, the discussion of 

groundwater monitoring is separated on the basis of on-site and off-site 

monitoring because of the different concerns. On-site, the concerns are related to 

ensuring that Mine Unit Operation and Reclamation are conducted as efficiently 

as possible, and emphasize monitoring of water levels and water quality, in 

addition to pattern balancing. The monitoring is also intended to ensure 

excursions do not occur, or if they do occur, they are controlled as quickly as 

possible to prevent movement of lixiviant and production fluid outside of the 

monitor well ring. Off-site, the concern is related to the extent to which on-site 

groundwater extraction, particularly during the first phase of restoration, would 

draw down water levels in off-site wells. 

4.7.2.1 On-Site Groundwater Monitoring 

Permit Area 

Water level measurements would be taken quarterly in the 27 wells that were used 

to establish baseline conditions within the Permit Area as described in Section 
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3.6.4.2. Other samples may be collected from these wells, depending on the 

development of mine units near or encompassing the wells. 

Storage Ponds 

To help ensure shallow groundwater is not impacted by the two Storage Ponds, 

which are part of the waste treatment and handling system, the Storage Ponds 

would be designed, inspected and monitored in accordance with NRC Regulatory 

Guide 3.11 (2008). The Storage Ponds, associated inspection schedule and 

monitoring system, and corrective actions that would be taken in case a leak is 

detected, are briefly described in detail in Sections 3.0 and 5.0 of the NRC 

Technical Report (LCI, 2010). In addition to installation of a leak detection 

system as the Storage Ponds are constructed, four wells would provide additional 

monitoring capability. The monitor wells would be drilled to the first shale below 

the surface. Three of the four wells have already been installed and groundwater 

was not encountered in the wells above the first significant aquitard. The wells 

would be checked prior to operation to determine if groundwater exists and, if it 

does exist, the quality of the groundwater. If groundwater does exist, it would be 

sampled on a quarterly basis for conductance, alkalinity, sodium, and sulfate 

(NRC Technical Report [LCI, 2010]). 

Pipelines and Related Equipment 

Flow through the pipelines would be monitored and would be at a relatively low 

pressure. Sensors wired to automatic alarms and pipeline shutoffs would be 

installed to detect significant changes in flow rates or pressures in the pipelines 

and tanks to help prevent significant releases. All the Plant equipment is specified 

and designed for the life of the Project, and equipment for the mine units is 

similarly designed. Visual inspection of pipelines and related facilities is the 

daily responsibility of all mine site staff. Particularly, it is the responsibility of 

the mine unit operators to inspect these items on a routine basis. 

Mine Units 

In addition to the baseline monitoring already conducted for the Permit Area, 

extensive groundwater monitoring would be conducted on a mine unit basis prior 

to, during and following production to identify any potential impacts to water 

resources of the area. This monitoring is summarized below and described in 

more detail in Section OP 3.6 of the WDEQ-LQD Permit to Mine (LCI, 2011b) 

and Sections 5.7.8.2 and 6.2 of the NRC Technical Report (LCI, 2010). 

Prior to use of any of the monitoring, production, or injection wells, the 

mechanical integrity of the well would be tested. MITs would also be conducted 

at specified intervals thereafter and after well repairs (Section OP 3.4 of the 

WDEQ-LQD Permit to Mine [LCI, 2011b]). The purpose of this monitoring is to 

ensure that fluids in the well cannot migrate into sands other than the one(s) in 

which the well is completed. 
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Mine unit monitoring, prior to production, provided information on aquifer 

characteristics needed to refine anticipated operating parameters, such as pumping 

rates and monitor well spacing, and baseline water quality, needed to establish 

excursion indicators and restoration criteria. The WDEQ-LQD MU1 documents 

(LCI, 2011b) includes the results of the aquifer testing and baseline water quality 

for that mine unit, and similar detail would be provided for the other mine units. 

The mine unit monitoring during Mine Unit Operation has two purposes: to 

ensure the operations are being conducted as efficiently as possible to prevent an 

excursion; and to detect any excursions that might occur. During ISR operations, 

water levels would be routinely measured in the production zone and overlying 

and underlying aquifers. Sudden changes in water levels within the production 

zone may indicate that the mine unit flow system is out of balance. Flow rates 

would be adjusted to correct this situation. Increases in water levels in the 

overlying aquifer or underlying aquifers may be an indication of fluid migration 

from the production zone. Adjustments to well flow rates or complete shut-down 

of individual wells may be required to correct this situation. Increases in water 

levels in the overlying aquifer may also be an indication of casing failure in a 

production, injection or monitor well. Isolation and shut down of individual wells 

can be used to determine the well causing the water level increases. These 

monitoring procedures and the operational procedures to address any concerns 

found during monitoring are described in detail in Attachment OP-2 of the 

WDEQ-LQD Permit to Mine (LCI, 2011b). 

LCI would monitor for lateral movement of lixiviant using a horizontal excursion 

monitoring system. This system consists of a ring of monitor wells completed in 

the same aquifer and zone as the injection and production wells (Figure 2.1-4). It 

is anticipated that monitor wells would be installed about 500 feet from the mine 

unit boundary and appropriately spaced (approximately 500 feet apart) to detect 

an excursion in a timely manner based on the hydrologic characteristics of each 

mine unit. Monitor wells would be sampled semi-monthly for approved 

excursion indicators, commonly called Upper Control Limits (UCLs). 

Selection of UCLs is based on background water quality, lixiviant characteristics, 

and parameters that move quickly through the aquifer. For example, chloride is 

often a UCL parameter because it moves quickly, in contrast with uranium which 

generally reacts with the aquifer material and, as a result, moves more slowly in 

the groundwater. WDEQ-LQD Guideline No. 4 (2000a) specifies procedures for 

selecting UCL parameters and calculating the UCL concentrations that would 

indicate an excursion had occurred. If an excursion is detected, specific 

requirements for monitoring and controlling the excursion are included in Section 

OP 3.6.4.3 of the WDEQ-LQD Permit to Mine (LCI, 2011b) per the WDEQ-LQD 

NonCoal Rules, Chapter 11, Sections 12 and 13. 

LCI would also monitor for vertical excursions in the overlying and underlying 

aquifers using shallow and deep monitor wells, respectively. Per existing state 
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and federal guidance, these wells would be located within the mine unit boundary 

at a density of about one well per four acres, depending on the hydrologic 

characteristics of each mine unit. Shallow and deep monitor wells would be 

sampled semi-monthly for approved UCLs. Section 5.2 of the WDEQ-LQD MU1 

documents (LCI, 2011b) includes the results of UCL calculations for that mine 

unit, and similar detail would be provided for the other mine units. 

The emphasis of monitoring during groundwater restoration is to ensure the 

groundwater quality is restored to the specified criteria determined from the 

baseline sampling and that the quality remains stable (Section RP 2.4 of the 

WDEQ-LQD Permit to Mine [LCI, 2011b]). 

UIC Class I Wells 

These wells are part of the waste treatment and handling system and would be 

much deeper than any mine unit. Mechanical integrity testing of these wells is 

required prior to use, and periodically thereafter, and monitoring injection rates, 

pressures, and injectate quality is also required, in accordance with the WDEQWQD Permit, which is included in Attachment ADJ-2 of the WDEQ-LQD Permit 

to Mine (LCI, 2011b). These wells are briefly described in Section 2.1.2.4 and 

Sections 3.0 and 5.7 of the NRC Technical Report (LCI, 2010). 

4.7.2.2 Off-Site Groundwater Monitoring 

The operational BLM stock wells near the Permit Area (Figure 3.6-15) would be 

sampled on a quarterly basis with BLM’s consent. At a minimum, the samples 

would be analyzed for U-nat and Ra-226. Water level data would be collected 

before sampling if the wellhead design allows access. LCI would also correspond 

with BLM to ensure that the stock reservoirs and wells are not impacted in a 

manner that restricts their intended use. 

4.7.3 Impact Significance Criteria 

The BLM and WDEQ criteria used to evaluate groundwater impacts include both 

qualitative and quantitative assessment of changes in groundwater quantity and 

quality during the Project. The quantitative assessments include calculation of 

anticipated drawdowns in water levels and comparison of operational and restored 

water quality to baseline conditions. 

The BLM Groundwater Impact Significant Criteria are as follows: 

x The natural flow or level of groundwater to existing local springs, seeps, 

flowing artesian wells, or permitted water supply wells is interrupted or 

reduced to the point beneficial uses cannot be maintained. 

x Groundwater quality in any aquifer is degraded such that it can no longer 

be classified for its current and potential use(s). 
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WDEQ-LQD requires an assessment of impacts that may reasonably be expected 

as a result of the mining operation to water resources and water rights, which 

includes assessment of the areal extent of drawdown, usually to the extent of the 

five-foot drawdown contour, potential effects on existing water rights, and water 

quality changes (WDEQ-LQD, 2005a and b). WDEQ-WQD has criteria for 

evaluating potential water uses based on water quality (WDEQ-WQD Rules, 

Chapter 8, Table I). The requirements for restoration of groundwater quality after 

ISR, which apply throughout the mine units, are specified in WDEQ-LQD 

NonCoal Rules (Chapter 11, Section 5) and are based on restoring the quality to 

the uses for which it was suitable prior to mining, as established by WDEQ-WQD 

(Section RP 2.2 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). 

To establish requirements for restoration of groundwater quality after ISR, the 

NRC may allow a somewhat different approach than WDEQ-LQD in that the use 

of Alternate Concentration Limits (ACLs) may be approved. Depending on the 

baseline water quality in the Permit Area, the production zone generally must be 

reclassified and exempted per the water use classifications of WDEQ and the 

aquifer exemption provisions of the EPA UIC regulations. The ACLs, if 

approved by NRC, would apply at the exemption boundary. 

4.7.4 Differentiation of Impacts to Groundwater - 

Consumption and Quality 

Potential impacts to groundwater could occur during all phases of the Project 

(Construction, Operation, and Reclamation). The impacts are from both 

groundwater consumption and changes to groundwater quality. The impacts 

related to groundwater consumption are summarized in Table 4.7-1 and Section 

4.7.4.1, and the impacts related to groundwater quality are summarized in Table 

4.7-2 and Section 4.7.4.2. 

Detailed discussion of the potential impacts to groundwater is provided in the 

following sections for each phase of the Project (Section 4.7.5 – Construction, 

Section 4.7.6 – Operation, and Section 4.7.7 – Reclamation). For each phase, the 

discussion is organized on the basis of the facility or activity that could cause the 

impact or be impacted. Specifically, the discussion is separated on the basis of 

the overall Permit Area, pipelines, related equipment, the Storage Ponds, the mine 

units, the UIC Class I wells, and off-site wells. Impacts from the No Action 

Alternative and the Other Action Alternatives are evaluated in Section 4.7.8. 
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Table 4.7-2 Summary of Water Quality Impacts Table

4.7-2 Summar

y of Water Qualit

y Impacts
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4.7.4.1 Groundwater Consumption 

Groundwater extraction is a key component of ISR production and aquifer 

restoration. As discussed in Section 2.1, during production, most of the extracted 

groundwater is re-injected into the mine units. Mine units would be operated with 

a 0.5 to 1.5 percent bleed for two to three and a half years depending on the mine 

unit. The bleed would create an inward hydraulic gradient to the mine unit. This 

bleed rate at a maximum scenario of 1.5 percent would produce a volume of 90 

gpm of liquid waste (47,304,000 gallons per year). This accounts for the majority 

of the groundwater consumptive use during Mine Unit Operation. LCI proposes 

to manage the liquid waste through the UIC Class I well(s). The water balance 

for the life of the Project is summarized in Section 2.1.6.2, including Figures 2.1-

9 through 2.1-14, and discussed in more detail in Section OP 3.6.3.1 (Figures OP5a through 5f) of the WDEQ-LQD Permit to Mine (LCI, 2011b). 

During aquifer restoration, the primary methods include groundwater sweep 

(GWS) and reverse osmosis (RO). Other methods, including groundwater 

transfer, RO with permeate reinjection, or reductant addition may also be used. 

Section 4.7.1.1 of this EIS and Section RP 2.3 of the WDEQ-LQD Permit to 

Mine provides additional detail on these methods, including volume calculations. 

During groundwater sweep, groundwater is initially extracted without re-injection 

to hydraulically capture water impacted by production and to draw ambient, 

baseline-quality water into the mine unit from the surrounding aquifer. During 

this sweep, an inward hydraulic gradient is created causing an influx of baseline 

quality native groundwater into the unit, thereby flushing any residual lixiviant 

from areas affected by the horizontal and vertical spreading (flare) of the lixiviant 

during mining. This sweep accounts for the largest consumptive use of 

groundwater during the Project. 

Following the sweep, groundwater is extracted and treated using RO. RO is a 

water treatment process that works by forcing a solution from a region of high 

solute concentration through a semipermeable membrane to a region of low solute 

concentration by applying a pressure in excess of the osmotic pressure. This 

treatment is most effective in returning the concentrations of total dissolved solids 

and trace metals and the aquifer pH to baseline values. The bulk of the treated 

water is re-injected into the affected aquifer to improve water quality, but a bleed 

rate is maintained, which would result in continued groundwater consumption, 

although at a much reduced rate compared to sweep. 
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4.7.4.2 Groundwater Quality 

LCI has committed to return the groundwater to the pre-operational class-of-use 

in accordance with WDEQ statutes and regulations. Best Practicable Technology 

(BPT), as defined in the Wyoming Statutes, would be used during restoration. 

The uranium deposits underlying the Permit Area are primarily roll front deposits 

in fluvial sandstones. The uranium was deposited when oxidized groundwater 

containing the uranium entered reducing conditions in the subsurface aquifers. 

ISR operations essentially reverse the natural processes that deposited the 

uranium. During operations, barren lixiviant would enter the formation through 

the injection wells and flow to the production wells. Lixiviant is a liquid medium 

used to selectively extract (or leach) uranium from ore bodies. This liquid 

medium typically contains an oxidant such as oxygen and/or hydrogen peroxide 

mixed with sodium carbonate or carbon dioxide. For the Lost Creek Project, 

carbonate lixiviant would be made from varying concentrations and combinations 

of sodium carbonate, sodium bicarbonate, carbon dioxide, oxygen, and/or 

hydrogen peroxide and antiscalant added to the native groundwater. The 

combined carbonate/bicarbonate concentration in the injected solution typically 

would be maintained at less than five grams per liter (g/L), and the hydrogen 

peroxide and/or oxygen concentration typically would be less than one g/L. 

These limits help reduce the possibility of “gas lock” in the formation, which 

reduces ISR efficiency (LCI, 2011b). Section D5.2.3, OP1.2, and OP3.1 of the 

WDEQ-LQD Permit to Mine provide additional information on the ore deposition 

and geochemistry. 

Injection wells introduce the carbonate lixiviant into the mineralized zone to 

oxidize the reduced uranium and to complex it with bicarbonates. Pumping from 

production wells draws the lixiviant through the mineralized zone, oxidizing 

additional ore between the injection and production wells. In turn, groundwater 

restoration essentially reverses the effects of the oxidation during ISR operations 

and re-establishes the reducing conditions that were present prior to Mine Unit 

Operation. During the groundwater sweep the affected water in the edge patterns 

of the mine unit is also drawn back into more central portions of the pattern area, 

making the later restoration phases more efficient. Groundwater produced during 

the sweep phase would contain uranium and other constituents including total 

dissolved solids (TDS) and trace metals such as arsenic, molybdenum, selenium, 

and/or vanadium mobilized during production. The initial concentrations of the 

constituents would be similar to those during the later stages of production. With 

enough pumping, the constituent concentrations would decline gradually, 

reflecting the influx of baseline quality water. The water produced during 

groundwater sweep is treated through the restoration plant ion exchange circuit to 

capture uranium and then either treated with reverse osmosis or pumped directly 

to disposal (LCI, 2011b). 
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4.7.5 Construction 

The Construction phase includes both the Initial Construction of the Plant and 

other life-of-mine facilities and the progressive Mine Unit Development. Initial 

Construction is expected to last for approximately seven months, and activities 

include building access roads, utility corridors, the Plant, the Storage Ponds, 

pipelines, and drilling and installation of the UIC Class I injection wells. Mine 

unit development has been included in the Construction Phase although it is 

progressive (one mine unit may be in development while another is in operation). 

Section 4.5.2 in the NRC SEIS summarizes the potential impacts to water 

resources. Groundwater is expected to be influenced during the construction 

phase by the installation of wells, roads, and pipelines; and the usage of 

groundwater during construction. Due to the various BMPs in place, no 

significant impacts to the groundwater are expected. Additionally, groundwater 

would only be used for limited purposes, reducing the quantity being drawn out of 

the ground. 

4.7.5.1 Permit Area, Storage Ponds, Pipelines and Related 

Equipment 

Impacts to groundwater during Construction would primarily be from 

consumptive use of groundwater and changes in water quality. Groundwater 

consumptive use would primarily be for dust control, drilling, and employee use 

(e.g. showers and toilets). Groundwater quality could be impacted from spills of 

solvents, lubricants or other materials, and the introduction of drilling fluids. The 

impacts to groundwater would be direct and on a short-term basis at specific 

locations within the Permit Area, such as the Plant and utility corridors. 

Groundwater for dust control, drilling, aquifer testing, and employee use would be 

pumped from the water supply wells during the Construction phase. Two wells 

would be installed in the FG Horizon, one well in the HJ Horizon, three wells in 

the KM Horizon, and one well in the N Horizon. Groundwater, estimated at a 

maximum of 35 gpm, would be pumped from the seven water supply wells to 

meet the needs of the Project. The wells would be located away from the ore 

body and the water quality would be tested prior to use. 

The FG aquifer occurs at depths ranging from 250 to 275 ft bgs and is 

approximately 100 feet thick. It is hydrologically separated from the DE aquifer 

and the HJ aquifer. The top of the HJ aquifer ranges from approximately 300 to 

450 ft bgs and ranges in thickness from 100 to 160 feet. It is hydrologically 

separated from the FG aquifer by the Lost Creek Shale and from the underlying 

KM aquifer by the Sagebrush Shale. The top of the KM aquifer ranges from 450 

to 600 ft bgs and is about 100 feet thick. It is hydrologically separated from the 

HJ aquifer and the underlying L Horizon. Minor drawdown could occur as the 

groundwater is withdrawn from the water supply wells. However, because of the 
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relatively small volume of water withdrawn relative to the water supply available 

in the aquifers, only minor short-term drawdown impacts are expected. 

The volume of water for dust control, drilling and employee use would be limited. 

For the life of the Project, a very conservative calculation of the drawdown from 

pumping of the water supply wells is less than five feet in the FG, KM and N 

Horizons at distances greater than three miles from the center of the Permit Area; 

therefore, the drawdown would be much less during the seven months of 

Construction. The calculation and associated assumptions, e.g., no recharge and 

continuous pumping for the life of the Project, are discussed in Section OP 3.6.3.4 

of the WDEQ-LQD Permit to Mine (LCI, 2011b). 

The potential volume of stored fuels and lubricants in the Permit Area is expected 

to be small and any leaks or spills would be cleaned up immediately to prevent 

soil contamination and infiltration to the groundwater in accordance with the 

SPCC Plan. 

Water for construction of the Storage Ponds (e.g., for compaction and dust 

suppression) would come from the water supply wells. There is a possibility that 

groundwater could be impacted during installation of the monitor wells for the 

Storage Ponds, although the volume of water required for drilling is not expected 

to create any drawdown. Four wells are required by NRC and WDEQ, and three 

of the four have been installed to demonstrate the absence of groundwater above 

the DE Horizon. Groundwater quality could be impacted from spill of fuels or 

lubricants during construction of the Storage Ponds, but any spills would be 

cleaned up immediately to prevent soil contamination and infiltration to the 

groundwater in accordance with the SWPPP. In addition, the Storage Ponds 

would be constructed in accordance with NRC and WSEO standards. 

4.7.5.2 Mine Units 

The schedule for Mine Unit Development is generally three plus years for each 

mine unit. It includes installing monitoring wells, injection wells, and production 

wells, well development, well sampling, aquifer testing, pipeline installation and 

construction of the header houses and installation of mine unit piping. 

Groundwater levels would be affected during the life of each mine unit. The 

primary consumptive impact to groundwater would occur during Mine Unit 

Operation and Reclamation, which are described in more detail below. However, 

during Mine Unit Development, prior to Operation, all of the wells must be 

drilled, developed, tested, and sampled. On an individual well basis, none of 

these development processes require extensive consumption of water, and even in 

aggregate, the influence is negligible compared with Mine Unit Operation and 

Reclamation. However, the processes do represent a definable impact, if 

measurable only during the short-term (e.g., during the multi-day aquifer test of a 

new monitor well ring). 
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During Mine Unit Development, groundwater would be recovered from well 

installation activities, including drilling, well development, sample collection and 

aquifer testing. The groundwater is “native” groundwater that has not been 

exposed to any ISR process or chemicals. This “native” groundwater would be 

discharged to the surface under the provisions of a general WYPDES permit or 

reused in the drilling process. The surface discharge permits would mitigate 

impacts to the Permit Area aquifers by limiting the discharge volume and 

prescribing concentration limits to discharged waters. In addition, Alternate 

Sediment Control Measures (ASCMs) as described in the WDEQ/LQD Guideline 

15 would be used for erosion and sediment control. No impacts to groundwater 

are anticipated due to the relatively small volume of water discharged at any 

given time. 

Drilling fluids would consist of “native” groundwater and may contain bentonite 

based muds, polymers, inert lost circulation material, and minor amounts of soda 

ash. Hazardous chemicals would not be used in the drilling mud. The drilling 

fluids would be contained in drill pits during the drilling; and the drill pits would 

be backfilled with subsoil either after the drilling fluid has evaporated or to 

prevent displacement of the drilling fluid. Because of the relatively small 

quantities of water used for drilling and the nature of the drilling fluid, no impacts 

to groundwater are anticipated. LCI has estimated that 10 drill rigs per week 

would be used during the drilling phase of the project and each rig would use 

approximately 3,400 gallons of water per day. 

Groundwater would be pumped for sample collection and aquifer characterization 

prior to Mine Unit Operation or from portions of the Permit Area not affected by 

ISR operations. This “native” groundwater has not been exposed to any ISR 

process or chemicals. During sample collection and aquifer testing, the water 

would be discharged to the surface in accordance with WYPDES permits or 

would be reused in the drilling process. The surface discharge permits would 

mitigate impacts to the Permit Area aquifers by limiting discharge volumes and 

concentration limits and ASCMs would be used for erosion and sediment control. 

It is not anticipated that withdrawal of groundwater from the water supply wells 

would cause significant drawdown based on the duration of the Mine Unit 

Development stage. Because of the relatively small quantities of water 

discharged and the implementation of BMPs (as described in the Operations Plan 

of the WDEQ Permit to Mine), impacts on water quality would be insignificant. 

Non-hazardous drilling fluids, as described above, would be limited and would be 

contained in drill pits to minimize the area of potential soil contamination and to 

enhance evaporation. Fluid leakage from drill pits or spills of drilling mud during 

well installation activities should not have any impacts on groundwater, due on 

the depth of the groundwater and the low-permeability mudstone/shale overlying 

the DE aquifer. During drilling the procedures detailed in the Operations Plan of 

the WDEQ Permit to Mine (LCI 2011b) would be implemented to prevent, 

identify, and correct any impacts to groundwater in the event of spills. In the 
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unlikely event that the drilling fluid does migrate down to the groundwater in the 

DE Horizon there would be a minor long-term impact to the groundwater quality. 

For wells drilled in active mine units, the groundwater generated during well 

development and aquifer testing would be treated as 11(e)(2) byproduct material. 

This affected groundwater would be disposed of on-site through a system of 

Storage Ponds and UIC Class I wells. Procedures for the Prevention and 

Remediation of Accidental Releases are discussed in the Operations Plan of the 

WDEQ Permit to Mine (LCI, 2011b). Because of the controlled on-site disposal 

procedures, no impacts to groundwater from the liquid waste are anticipated. If a 

release does occur and if the 11(e)(2) byproduct material does migrate to the 

groundwater in the DE Horizon the impact would be high and long-term. 

4.7.5.3 UIC Class I Wells 

Up to five UIC Class I wells would be installed in the Permit Area. The wells 

would be completed at depths ranging from approximately 6,170 to 8,100 ft bgs. 

As discussed in Section 2.1.1, LCI obtained Permit No. 09-586 from the WDEQWQD to dispose process waste water in the Fort Union Formation, which is 

estimated to be approximately 4,800 thick in the Permit Area. A 300-foot thick 

low-permeability shale sequence at the base of the Wasatch/Battle Springs 

Formations overlies the Fort Union Formation and would act as the confinement 

layer. The confining layer below the injection zone is the Cretaceous-age 1,900-

foot thick Upper Lance Formation, which consist of shales, siltstones, and lesser 

sandstone. Additional information regarding the 300-foot shale confining layer is 

in the Application for an Underground Injection Control Permit, Class I prepared 

for LCI by Petrotek, 2010. The document is in the Adjudication File for the 

WDEQ-LQD Permit to Mine (LCI, 2011b). 

Impacts to deeper groundwater could occur from the introduction of drilling mud 

and fluids during drilling and installation of the deep wells. However, the impacts 

would be minimal because the drilling muds are designed to seal the permeable 

zones by depositing the mud filter cake on the wellbore wall. 

Drilling fluids would be contained in mud pits to minimize the area of potential 

soil contamination and to enhance evaporation. Leakage from mud pits or spills 

or leaks during Construction should not have any detectable impacts on the 

groundwater, based on the depth of the groundwater below the surface, the clay 

content in the mud pits, and the low-permeability shale overlying the aquifers. 

Drill stem tests would be conducted to ensure the wells have the required 

injection capacity; however, water consumption during such testing is minimal 

because of the emphasis on pressure measurement rather than water pumping. As 

noted in previous sections, the deep well in the southwest corner of the Permit 

Area was installed in 2008 to confirm the viability of using the deep wells for 

disposal. The groundwater recovered from well development, sample collection 
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and drill-stem testing would be evaporated in the mud pit or reused in the drilling 

process. No impacts to groundwater quality are anticipated due to the relatively 

small volume of water that would be discharged. 

4.7.6 Operation 

The Operation phase for the Project is scheduled for seven plus years. Potential 

environmental impacts to groundwater during the Operation phase include 

changes to groundwater levels and quality due to the ISR process and 

consumptive use of groundwater. The ISR process uses a carbonate lixiviant that 

is pumped through buried pipelines to injection wells in the mine units. The 

lixiviant is circulated through the ore zone from the injection wells to the 

production wells, where it is then pumped from the mine units through buried 

pipelines to the ion exchange circuit in the Plant. Waste water would be 

temporarily stored in the Storage Ponds and then pumped into the deep disposal 

wells. Leaks of lixiviant from the wells, pipelines and header houses or waste 

water leaks from the Storage Ponds could impact groundwater resources in the 

Permit Area. However near-surface aquifers are not present within the Permit 

Area; therefore, the risk of impacting the deeper groundwater resources is small. 

The potential impacts are discussed below on the basis of Consumptive (Section 

4.7.4.1) and Water Quality (Section 4.7.4.2). 

Section 4.5.2 in the NRC SEIS summarizes the potential impacts to water 

resources. Groundwater is expected to be influenced during the operation phase 

by the potential for leaks and spills of chemicals and pumping for use on for the 

project. Due to the protective measures and chemical clean-up in place, only 

minor long-term impacts to the groundwater are expected. Also, groundwater 

usage is limited to only a few purposes, limiting the amount of water that would 

be pumped from the ground. 

4.7.6.1 Groundwater Consumption during Operation 

Permit Area 

Groundwater for dust control, drilling, cement mixing and employee use would 

continue to be pumped from on-site water supply wells, and as described under 

Construction, a very conservative calculation of the drawdown from pumping of 

the water supply wells is less than five feet in the FG, KM and N Horizons at 

distances greater than three miles from the center of the Permit Area. It is not 

anticipated that withdrawal from the water supply wells would cause significant 

drawdown in the HJ Horizon based on the intervening shale(s) between the HJ 

Horizon and the supply well completion intervals and the low projected pumping 

rates. It is possible that pumping from the UFG could result in drawdown within 

the LFG, which is the overlying aquifer to the production zone. If drawdown 

becomes apparent within the LFG monitor wells inside a mine unit, the shallow 
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water supply well (e.g., LC1W) would be temporarily shut-in and the water level 

response in the LFG monitor wells would be observed. If the water levels recover 

within the LFG wells once the pumping in the UFG is stopped, then the water 

supply well would be identified as the cause of water level decreases. If water 

level recovery does not occur in the LFG, then LCI would act on the assumption 

that operation of the mine unit is causing the drawdown and would proceed 

accordingly with corrective action, if necessary. Similarly, pumping from a UKM 

completed well (e.g., LC28M) could result in unanticipated drawdown in the KM 

Horizon, which would be addressed in a comparable manner. 

Storage Ponds, Pipelines and Related Equipment 

None of these facilities would impact the consumptive use of groundwater. As 

discussed in Section 4.7.4.2, the potential exists for leakage to create an area of 

perched groundwater, but this would require corrective action. 

Mine Units 

During Operation the water level changes, including both drawdown and 

mounding from production and injection, respectively, would be evaluated to 

minimize interference among the mine units and to determine cumulative impacts. 

Overall, the bleed rate of 0.5 percent to 1.5 percent, which has been historically 

applied at numerous ISR facilities, would create a cone of depression around each 

pattern area. The bleed water would be disposed of in the UIC Class I Injection 

Wells. The vast majority (e.g., on the order of 99 percent) of groundwater used 

during Mine Unit Operation would be treated and re-injected. The average rate of 

groundwater withdrawal (consumptive use) during production is around 70 gpm. 

The highest rate of groundwater withdrawal during production, groundwater 

sweep and RO treatment would be on the order of 115 gpm. The water balance 

for the life of the Project is summarized in Section 2.1.6.2, including Figures 

2.1-9 through 2.1-14, and discussed in more detail in Section OP 3.6.3.1 (Figures 

OP-5a through 5f) of the WDEQ-LQD Permit to Mine (LCI, 2011b). 

 

Results of the hydrologic investigations to date indicate that the HJ aquifer is 

laterally extensive and hydraulically connected, except where separated by the 

Fault (Section 3.6). Furthermore, the HJ aquifer is hydraulically separated from 

the overlying and underlying aquifers by laterally continuous confining units. 

Groundwater consumption during Mine Unit Operation would generally be 

limited to the HJ aquifer. 

Drawdown during Operation would be greatest in the immediate vicinity of the 

mine units. A numerical model was used to assess drawdown impacts from 

Project. The model was developed using site-specific geologic and hydrologic 

data collected from site characterization activities. The model development, 

calibration and simulations are described in the report, “Numerical Modeling of 

Hydrologic Conditions at the Lost Creek In-Situ Recovery Uranium Project, 
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Wyoming,” in Addendum 5-1 of the WDEQ-LQD MU1 document (LCI, 2011b). 

Simulations were run representing the full production-restoration sequence for 

MU1. The simulation included a maximum production rate of 5,838 gpm (with a 

net bleed of 38 gpm or 0.65 percent) for a period of 26 months (791 days), 

groundwater sweep at 30 gpm for 12 months (365 days), and treatment with RO 

at 541 gpm for 18 months (548 days). The total simulation period was 56 months 

(4.75 years). During RO, the simulated consumptive use (reject brine) was 67.6 

gpm. Simulated drawdown during the maximum production rate is shown on 

Figure 4.7-1. Drawdown during the RO phase is shown on Figure 4.7-2. The 

five-foot drawdown contour extends a maximum of 3.3 miles (17,250 feet) 

beyond the Permit Area boundary. The maximum drawdown outside the Permit 

Area boundary is slightly greater than 25 feet. This occurs where MU1 is closest 

to the Permit Area boundary. Although this simulation only represents MU1 

production and restoration, the production and RO rates are maximized. During a 

portion of the Project, full production and restoration could occur simultaneously; 

thus, the cumulative effect is represented by combining the predictions 

represented on the figures and accounting for some shift in mine unit location. 

Simulated recovery of water levels in the HJ Horizon aquifer after termination of 

ISR operations in MU1 is illustrated by placing observation points on the 

northwest, southwest, northeast and south-central edges of the Permit Area. 

Figure 4.7-3 shows the location of the simulation monitoring points. Figure 

4.7-4 illustrates the simulated drawdown that occurs during ISR operations at 

MU1 and the recovery following termination of operations. The water levels are 

projected to recharge within ten to 15 years, once groundwater extraction ceases. 

The model development, calibration and simulations are described in the report 

“Numerical Modeling of Hydrologic Conditions at the Lost Creek In-Situ 

Recovery Uranium Project, Wyoming”, which is included as Attachment MU1 

5-1 in the WDEQ-LQD MU1 documents (LCI, 2011b)). 

UIC Class I Wells 

The UIC Class I injection wells would be competed in the Fort Union Formation. 

Process waste water would be injected at an average rate of 70 gpm. The 

proposed locations of the five UIC Class I wells are widely scattered to 

accommodate regulatory requirements and meet the necessary injection criteria 

(Figure 1.2-3). These wells would be used for injection, not pumping; therefore, 

no consumptive use would occur. With respect to injection capacity, testing 

results from the first well installed in the southwest corner of the Permit Area 

indicate sufficient capacity for the planned disposal quantities. In addition, the 

TDS concentration in the formation water was in excess of 10,000 mg/L and the 

concentration of other organic and inorganic constituents exceeded groundwater 

quality standards (Section 3.6.4). Although LCI has permitted five wells, 

installation of only two to three wells is planned initially, with installation of the 

fourth and fifth wells based on the need for redundant capacity if another well 

must be taken out of service. 
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Figure 4.7-1 Simulated Drawdown, HJ Horizon at Maximum 

Production Rate- Mine Unit 1 East Eagle Nest Draw Boundary Well No. 4775 Battle Spring Draw Well No. 4451 Battle Spring Well No. 4777 Source: Plate OP-4a of the WDEQ-LQD Permit to Mine. Model development, calibration, and simulations are described in Attachment MU1 5-1 of the WDEQ-LQD permit MU1 documents (LCI, 2011b). 
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Figure 4.7-2 Simulated Drawdown, HJ Horizon at End of Reverse 

Osmosis- Mine Unit 1 East Eagle Nest Draw 

Boundary Well No. 4775 

Battle Spring Draw Well No. 4451 

Battle Spring Well No. 4777 

Source: Plate OP-4b of the WDEQ-LQD Permit to Mine. Model development, calibration, and simulations are described in Attachment MU1 5-1 of the WDEQ-LQD permit MU1 documents (LCI, 2011b). 

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Figure 4.7-3 Drawdown Observation Points, Mine Unit 1 

Simulation, Production-Restoration-Recovery 

 
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Figure 4.7-4 Drawdown at Permit Boundary during Mine Unit 1 

Simulation, Production-Restoration-Recovery 
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Off-Site 

BLM has four wells located outside of the Permit Area (Figure 3.6-15). The 

completion depths of two of these wells are shallower than the HJ Horizon; the 

completion depth of another is substantially greater than the HJ Horizon (although 

the screened interval is not known). The completion depth of the fourth well may 

coincide with the LFG Sand; as such, potential drawdown may affect this well. 

4.7.6.2 Groundwater Quality during Operation 

Permit Area 

No groundwater quality impacts are anticipated from pumping of the water supply 

wells. Any water level declines in these wells are not expected to impact the 

water quality because of the relative similarity in the water quality at these depths. 

Storage Ponds, Pipelines and Related Equipment 

Groundwater quality could potentially be impacted during the Operation phase 

due to an accident such as Storage Pond leakage/failure or an uncontrolled release 

of liquids due to a mine unit accident. Because of the depth to water in the DE 

Horizon and the presence of shale layers between DE Sands and the surface, 

direct leakage to the groundwater is considered unlikely and would be the result 

of a slow leak or catastrophic failure. However, it could be possible for a leak to 

create an area of perched groundwater. To minimize the chance of a leak, the 

Storage Ponds would be designed and built to NRC standards using double liners 

with a leak detection system between the two liners. The liner material would 

consist of impermeable polypropylene geomembrane and each liner would be 41 

millimeters thick. The ponds would be inspected on a regular basis. If a major 

release does occur and if the 11(e)(2) byproduct material does migrate to the 

groundwater in the DE Horizon the impact would be high and long-term. 

Mine Units 

ISR from a uranium deposit is accomplished by reversing the natural processes 

that deposited the uranium, i.e., ISR reoxidizes the ore zone to mobilize the 

uranium from the reduced conditions in the ore zone. A small portion of radium 

would be mobilized with the uranium, and depending on the conditions within a 

given sand other metals such as arsenic, molybdenum, selenium, and/or vanadium 

may also be mobilized during ISR. 

The native formation waters in the ore zones of the HJ Horizon are not suitable 

for human consumption because of naturally high levels of dissolved radioactive 

materials, including uranium and Ra-226 (Section 3.6.4). The ISR process affects 
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the pattern area within the mine unit, which was exempted per the water use 

classifications of the WDEQ and the aquifer exemption provisions of the EPA 

UIC regulations. The area so designated was limited both laterally and vertically. 

During Mine Unit Operation, injection of the lixiviant into the pattern area results 

in a temporary degradation of water quality in that area compared to preproduction conditions. However, proper balancing of pumping and injection rates 

and pressures, as described in Section OP 3.6 and Attachment OP-2 of the 

WDEQ-LQD Permit to Mine (LCI, 2011b), restricts these water quality changes 

to the pattern area and improves mining efficiency. Subsequent restoration 

activities, described in Section RP 2.3 of the WDEQ-LQD Permit to Mine (LCI, 

2011b), are also designed to affect the pattern area. 

The target horizon for the Project is the HJ Horizon. Hence, the ISR operations 

would impact water quality only in the HJ Horizon provided excursions do not 

occur. Inadvertent movement of the affected water out of the pattern area is 

termed an excursion. Excursions represent an impact on the groundwater outside 

of the pattern area, and possibly the mine unit (Figure 2.1-5). Excursions can 

result from an improper balance between injection and recovery rates, undetected 

high permeability strata or geologic faults, improperly abandoned exploration drill 

holes, discontinuity of the confining units that could allow movement of the 

lixiviant out of the ore zone, poor well integrity, or hydrofracturing of the ore 

zone or surrounding units if the injection wells were operated above fracture 

pressure. Protective measures are required to avert these scenarios (Section 

4.7.1), and systematic monitoring is designed to detect them as early as possible 

(Section 4.7.2). Mitigation measures and time frames for implementing those 

measures are required if an excursion occurs (Section 4.7.1.1) 

A problem due to poor well construction or well damage could result in migration 

of fluids between aquifers. Because of the depth to water in the DE Horizon and 

the presence of shale layers between DE Sands and the surface, a shallow leak 

from a well could create an area of perched groundwater. 

UIC Class I Wells 

As with any well, a problem due to poor well construction or well damage could 

result in migration of fluids between aquifers. However, the construction and 

monitoring requirements described in Sections 4.7.1 and 4.7.2 are designed to 

prevent, detect, and correct this problem. Another potential concern would be the 

loss of injection capacity due to precipitates forming in the injection zone. 

Comparison of the anticipated composition of the waste stream and the existing 

water quality in the injection zone does not indicate chemical incompatibility 

between the fluids, as shown in Table 4.7-3. Because of the elevated 

concentrations of Total Dissolved Solids in the target formation fluids, an aquifer 

exemption for the target formation was not a requirement. 

 
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Table 4.7-3 Comparison of Water Quality in the Injection Stream and the Receiving 

Formation 
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Off-Site 

No water quality impacts to the BLM wells are expected because the completion 

intervals coincide only partially, if at all, with the HJ Horizon. In addition, 

because of the distance of these wells from the pattern areas and excursion 

control, any water level declines in the BLM wells are not expected to impact the 

water quality because of the relative similarity in the water quality at these depths. 

4.7.7 Reclamation 

Reclamation includes progressive Mine Unit Restoration and Final Reclamation. 

Groundwater impacts are related to water quantity, through consumptive use, and 

to water quality through waste management practices including discharge to the 

storage ponds and deep wells. The potential impacts are discussed on the basis of 

Consumption (Section 4.7.5.1) and Water Quality (Section 4.7.5.2). 

Section 4.5.2 in the NRC SEIS (NRC, 2011) also summarizes the potential 

impacts to water resources during reclamation. Groundwater is expected to be 

influenced during the reclamation phase by the decommissioning of the wells, 

potential leaks and spills, and use of the groundwater. Due to the various BMPs 

in place, no significant impacts from leaks and spills are expected to the 

groundwater are expected. Well abandonment is conducted to return the 

hydrological conditions to their previous state and use of the groundwater is 

limited to certain purposes. As such, while the groundwater may be affected in 

the short-term, in the long-term it would be returned to its previous state. 

4.7.7.1 Groundwater Consumption during Reclamation 

Permit Area 

Groundwater for dust control, well plugging and abandonment, cement mixing 

and employee use would continue to be pumped from on-site water supply wells 

during Mine Unit Reclamation. The drawdown from pumping of the water 

supply wells would be less than five feet in the FG, KM and N Horizons at 

distances greater than three miles from the center of the Permit Area. It is not 

anticipated that withdrawal from the water supply wells would cause significant 

drawdown in the HJ Horizon based on the intervening shale(s) between the HJ 

Horizon and the supply well completion intervals and the low projected pumping 

rates. It is possible that pumping from the UFG could result in drawdown within 

the LFG, which is the overlying aquifer to the production zone. If drawdown 

becomes apparent within the LFG monitor wells inside a mine unit, the shallow 

water supply well (e.g., LC1W) would be temporarily shut-in and the water level 

response in the LFG monitor wells would be observed. If the water levels recover 

within the LFG wells once the pumping in the UFG is stopped, then the water 

supply well would be identified as the cause of water level decreases. If water 

level recovery does not occur in the LFG, then LCI would act on the assumption 
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that operation of the mine unit is causing the drawdown and would proceed 

accordingly with corrective action, if necessary. Similarly, pumping from a UKM 

completed well (e.g., LC28M) could result in unanticipated drawdown in the KM 

Horizon, which would be addressed in a comparable manner. 

The potential impacts to groundwater during Final Reclamation would be similar 

to those during Construction. An additional water use during Final Reclamation 

would be for decommissioning the Plant. LCI estimates that approximately 

34,000 gallons of water would be required to decontaminate and decommission 

the Plant and associated equipment. Using a 100 percent contingency factor, the 

total volume of water required for decontaminating and decommissioning is 

around 68,000 gallons of groundwater. The waste water generated during the 

decontaminating and decommissioning would be disposed in the UIC Class I 

wells in accordance with NRC requirements. 

Storage Ponds, Pipelines and Related Equipment 

None of these facilities would impact the consumptive use of groundwater during 

Mine Unit Reclamation or Final Reclamation. 

Mine Units 

Drawdown during mine unit reclamation would be greatest in the immediate 

vicinity of the mine unit in restoration and greatest during groundwater sweep 

(GWS), when water is pumped from the mine unit without offsetting with water 

injection. As discussed in Section 4.7.4.1, a numerical model was used to assess 

drawdown impacts from Project. The model was developed using site-specific 

geologic and hydrologic data collected from site characterization activities. 

Simulated recovery of water levels in the HJ Horizon aquifer after termination of 

ISR operations in MU1 is illustrated by placing observation points on the 

northwest, southwest, northeast and south-central edges of the Permit Area. 

Figure 4.7-3 shows the location of the simulation monitoring points. Figure 

4.7-4 illustrates the simulated drawdown that occurs during ISR operations at 

MU1 and the recovery following termination of operations. The water levels are 

projected to recharge within ten to 15 years, once groundwater extraction ceases. 

During reverse osmosis (RO), the simulated consumptive use (reject brine) was 

67.6 gpm. Drawdown during the RO phase is shown on Figure 4.7-2. The fivefoot drawdown contour extends a maximum of 3.3 miles (17,250 feet) beyond the 

Permit Area boundary. The maximum drawdown outside the Permit Area 

boundary is slightly greater than 25 feet. This occurs where MU1 is closest to the 

Permit Area boundary. Although this simulation only represents MU1 production 

and restoration, the production and RO rates are maximized. During a portion of 

the Project, full production and restoration could occur simultaneously; thus, the 

cumulative effect is represented by combining the predictions represented on the 

figures and accounting for some shift in mine unit location. 
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UIC Class I Wells 

These wells would be used for injection, not pumping; therefore, no consumptive 

use would occur during reclamation. During Final Reclamation, the UIC Class I 

wells would be plugged and abandoned in accordance with the WDEQ-LQD 

Permit (LCI, 2011b). 

Off-Site 

The locations of the four BLM wells located outside of the Permit Area are shown 

on Figures 4.7-1 and 4.7-2. As noted previously, the completion depths of two of 

these wells are shallower than the HJ Horizon; the completion depth of another is 

substantially greater than the HJ Horizon (although the screened interval is not 

known). The completion depth of the fourth well may coincide with the LFG 

Sand; as such, potential drawdown may affect this well. Even if the completion 

intervals of these wells coincided with the HJ Horizon, the drawdown would not 

exceed 15 feet, based on the simulation illustrated on Figure 4.7-2. 

4.7.7.2 Groundwater Quality during Reclamation 

Permit Area 

No groundwater quality impacts are anticipated from the pumping of the water 

supply wells. Any water level declines in these wells are not expected to impact 

the water quality because of the relative similarity in the water quality at these 

depths. 

Storage Ponds, Pipelines and Related Equipment 

Groundwater quality could potentially be impacted during Mine Unit Reclamation 

due to an accident such as Storage Pond leakage or an uncontrolled release of 

liquids due to a mine unit accident. Because of the depth to water in the DE 

Horizon and the presence of shale layers between DE Sands and the surface, 

direct leakage to the groundwater is considered unlikely and would be the result 

of a slow leak or catastrophic failure. However, it could be possible for a leak to 

create an area of perched groundwater. The Storage Ponds would be designed and 

built to NRC standards using impermeable synthetic liners with a leak detection 

system, and all ponds would be inspected on a regular basis. If a major release 

were to occur and if the 11(e)(2) byproduct material migrated to the groundwater 

in the DE Horizon the impact would be high and long-term. 

Groundwater quality could potentially be impacted during Final Reclamation due 

to an accident, such as or an uncontrolled release of liquids when the ponds are 

being emptied. 
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Mine Units 

Groundwater restoration after ISR returns the ore zone to reducing conditions, 

reprecipitating any residual uranium mobilized during ISR. TDS and other trace 

metals such as arsenic, molybdenum, selenium, and/or vanadium which may have 

also been mobilized during Operation are also reprecipitated. 

The native formation waters in the ore zones of the HJ Horizon are not suitable 

for human consumption because of naturally high levels of dissolved radioactive 

materials, including uranium and Ra-226 (Section 3.6.4). The ISR process affects 

the pattern area, which was exempted per the water use classifications of the 

WDEQ and the aquifer exemption provisions of the EPA UIC regulations. The 

area so designated was limited both laterally and vertically. Ideally, Mine Unit 

Restoration activities affect only the pattern area. An excursion has been known 

to occur during restoration in rare circumstances, e.g., due to immediate proximity 

to an underground uranium mine, but monitoring is required until restoration is 

deemed complete, and such conditions do not exist at the Lost Creek Permit Area. 

A problem due to poor well construction or well damage could result in migration 

of fluids between aquifers. However, the requirements for monitoring, including 

MITs, continue during mine unit restoration. 

After Mine Unit Restoration is completed and approved by WDEQ-LQD and 

NRC, the wells would be abandoned in accordance with established protocols 

(Section RP 3.1 of the WDEQ-LQD Permit [LCI, 2011b]). No impact from the 

abandonment of the wells is anticipated. 

UIC Class I Wells 

As with any well, a problem due to poor well construction or well damage could 

result in migration of restoration or abandonment fluids between aquifers. 

Another potential concern would be the loss of injection capacity during 

restoration due to precipitates forming in the injection zone. Comparison of the 

anticipated composition of the waste stream and the existing water quality in the 

injection zone does not indicate chemical incompatibility between the fluids, as 

shown in Table 4.7-3, taken from Attachment J of the WDEQ-WQD Permit, 

which is included in Attachment ADJ-2 of the WDEQ-LQD Permit to Mine (LCI, 

2011b). Similarly, the abandonment fluids, which are primarily cement, must 

also be suitable for the subsurface conditions. 

During Final Reclamation, the UIC Class I wells would be plugged and 

abandoned in accordance with the WDEQ-LQD Permit. No impact from the 

abandonment of the wells is anticipated. 
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Off-Site 

No water quality impacts to the BLM wells are expected because the completion 

intervals coincide only partially, if at all, with the HJ Horizon. In addition, 

because of the distance of these wells from the pattern areas and excursion 

control, any water level declines in the BLM wells are not expected to impact the 

water quality because of the relative similarity in the water quality at these depths. 

4.7.8 Groundwater Impacts from Other Alternatives 

4.7.8.1 No Action Alternative 

Under the No Action Alternative, the Project would not be constructed. Existing 

wells drilled for the Project would be plugged in accordance with WDEQ 

regulations. There would be no Project-related impacts to groundwater. 

4.7.8.2 Not Fencing the Pattern Areas 

Considering operational health and safety, the Proposed Action involves fencing 

the pattern areas within the operational mine unit(s) to reduce the possibility of 

damage to the wellheads and other surface facilities by livestock and wild horses. 

Although any damage by livestock and wild horses would likely be restricted to 

surface damage, it is possible that a well could be damaged to such an extent that 

a subsurface leak could occur. However, if a well is damaged to such an extent, 

repair and integrity testing is required before it could be put back into use. In 

addition, an assessment of impacts to soil or water due to leakage from the 

damaged well would be required. 

4.7.8.3 Drying Yellowcake On-Site 

This alternative would have no impact on groundwater. The dryer would be 

within the Plant, so the measures taken to prevent impacts to groundwater from 

the Plant operation, e.g., construction in accordance with appropriate building 

codes, would be in place, as well as applicable procedures for spill control should 

unanticipated damage occur. 
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4.8 Vegetation 

4.8.1 Agency-Required Measures 

The required environmental protection measures are summarized below from 

Sections OP 2.7 and RP 4.5 of the WDEQ-LQD Permit to Mine (LCI, 2011b) and 

Sections 2.1.1.1.2.1, 2.1.1.1.5.5, and 6.2.3 of the NRC SEIS (NRC, 2011a). 

Minimization of vegetation removal, reseeding, and traffic and weed control are 

part of the Proposed Action. Vegetation removal would be minimized whenever 

possible to protect topsoil, preserve wildlife habitat, and improve revegetation 

success. The acreages of the two vegetation communities identified on-site 

(Upland and Lowland Big Sagebrush Shrublands), and the acreages of 

disturbance in those communities are listed in Table 4.5-1. The disturbance 

acreages do not differentiate between areas where topsoil and vegetation are 

removed, i.e., where both the plant and roots are removed, and areas where the 

vegetation is crushed but the roots remain in place. In most of the pattern areas, 

the roots would remain in place, which should help reduce erosion and leave 

organic material in place, and, for shrubs, may provide for more rapid 

reestablishment than just from seed. 

To stabilize soils and support the ecosystem, vegetation would be established at 

disturbed areas as soon as conditions allow. For short-term disturbances during 

the life of the Project, such as pipeline installation, the temporary or permanent 

seed mix may be used, depending on the time of seeding and the erosion risk. For 

Final Reclamation, the permanent seed mix would be used. The temporary seed 

mix would be a rigorous certified weed-free annual cover crop such as sterile rye 

grass or millet. The permanent seed mix, approved by the BLM Rawlins Office 

on January 14, 2010 and WDEQ-LQD (Section RP 4.5.4 of the WDEQ-LQD 

Permit (LCI, 2011b), is shown in Table 4.8-1. 

During the Operation phase, mine units and supporting facilities would be 

accessed using a defined road network. Employees would be trained to minimize 

the impact to vegetation by staying on defined roadways and reducing the amount 

of vehicle traffic to the extent possible. Drilling and construction activities would 

be limited or halted when field conditions are muddy in order to minimize 

damage to vegetation. Alternatively, activities may be shifted to areas where they 

would not impact vegetation. Weed prevention measures following BLM 

guidelines and recommendations would be implemented (BLM, 1996b and 

2004b). 
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Table 4.8-1 Permanent Seed Mix 

4.8.2 Vegetation Monitoring 

Monitoring of vegetation impacts would occur throughout the life of the Project to 

ensure protective measures are working as planned, and vegetation would be 

monitored during Reclamation to ensure reestablishment to required standards. 

4.8.2.1 During Construction, Operation, and Final Reclamation 

LCI personnel would inspect active work areas to ensure employees are 

minimizing impacts to vegetation. Any problems noted during inspections would 

be brought to the supervisor’s attention for correction. Activities throughout the 

Permit Area would also be periodically checked to ensure no unanticipated 

impacts are found. It should be noted that a detailed estimate of the topsoil and 

vegetation disturbance acreage, such as Table 4.5-1 has not been previously 

required for an ISR operation in Wyoming. Therefore, part of the periodic checks 

would be to ensure the approach used to develop this estimate is effective and 

efficient. 

4.8.2.2 Monitoring Revegetation Success 

Both interim and final revegetation efforts would be evaluated. Interim 

revegetation efforts, such as reseeding of a mine unit pattern area after 

construction, would be checked regularly for effectiveness e.g., reducing the 

potential for erosion and controlling weeds. (Interim revegetation is discussed 

Common Name 1 Scientific Name Application 

(pounds per acre) 

Thickspike wheatgrass Agropyron dasystacum 4.0 

Slender wheatgrass Agropyron trachycaulum 2.5 

Western wheatgrass Agropyron smithii 2.0 

Indian ricegrass Achnatherum hymenoides 2.0 

Great Basin wildrye Leymus cinereus 2.0 

Winterfat Ceratoides lanata 1.5 

Sandberg bluegrass Poa secunda 1.5 

Big Sagebrush 2 Artemesia tridentata 1.0 

TOTAL 16.5 

1

 Alternative selections if one or two of primary selections (other than Big Sagebrush) are 

not available: Needle-and-thread (Stipa comata); and Bottlebrush squirreltail (Elymus 

elymoides) 2

 Sage seed would not be mixed with the other seeds but would be broadcast separately 

after the other seed has been drilled
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under Drilling and under Surface Facilities in Mine Unit Development in Section 

2.1.3.) 

Revegetation after Final Reclamation would be monitored annually for plant 

germination and growth, weeds, and overall progress toward meeting the 

reclamation success criteria. The monitoring results would be submitted to BLM 

and WDEQ-LQD as part of the Annual Report. If reclamation progress was 

deemed insufficient, then a program to address the concerns (e.g., additional weed 

control or reseeding of poorly germinated area) would be developed in 

conjunction with BLM and WDEQ-LQD. Revegetation after Final Reclamation 

would be deemed complete no earlier than the fifth full growing season after 

seeding and when: 

x the revegetation is self-renewing under the site conditions; 

x the total vegetation cover of perennial species (excluding noxious weed 

species) and any species in the approved seed mix is at least equal to the 

total vegetation cover of perennial species (excluding noxious weed 

species) of the undisturbed portions of the Permit Area; 

x the species diversity and composition are suitable for the post-operational 

land use; and 

x the total vegetation cover and species diversity and composition are 

quantitatively assessed in accordance with procedures approved by BLM 

and WDEQ-LQD. 

Because many of the reclaimed areas are relatively small in comparison with the 

Permit Area and because of the similarity of the vegetation communities at the 

site, LCI would delineate a comparison area in an undisturbed portion of the site 

at least six months prior to evaluation of revegetation success for bond release 

(The reclamation bond is discussed under Financial Assurance in Section 2.1.5). 

In addition, LCI would describe the quantitative methods to be used for 

comparing the total vegetation cover in the reclaimed and undisturbed areas and 

for evaluating species diversity and composition. These methods, as well as the 

size and location of the comparison area, would be submitted to BLM and 

WDEQ-LQD for review and approval at least six months prior to the fifth full 

growing season. The sampling results from the evaluation of the reclamation 

success would be reviewed and approved by BLM and WDEQ-LQD prior to 

approval of bond release for surface reclamation. 

4.8.3 Impact Significance Criteria 

Revegetation success after short-term disturbances, e.g., pipeline installation, 

would be evaluated to determine effectiveness in stabilizing topsoil and 

minimizing erosion. Revegetation success after Final Reclamation would be 

evaluated in accordance with BLM and WDEQ-LQD criteria discussed in Section 

2.1.5.2 and 4.8.2. These criteria are in accordance with the Rawlins RMP 
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Management Goals for Vegetation, which are to manage vegetation such that the 

region maintains a diverse and healthy community of plants that continue to 

support and promote ecosystem functions. Additionally, the control of weeds or 

invasive plants would support these management goals. 

4.8.4 Vegetation Impacts from the Proposed Action 

During the life of the Project, a total of approximately 345 acres of the land 

surface and associated vegetation could potentially be disturbed, which is about 

eight percent of the 4,254-acre Permit Area. The disturbance is progressive, i.e., 

it does not all occur during Initial Construction. The disturbance associated with 

each of the Project facilities is listed in Table 4.5-1, and is differentiated by 

vegetation type. Most of the disturbance follows the ore trend, which extends 

east-west through the Permit Area (Figure 2.1-1), and is in the West Battle 

Springs Draw drainage (Figure 3.5-1), which drains most of the Permit Area. 

The disturbance is not concentrated in any one of the three grazing allotments 

(Figure 3.1-2). The acreage that would be disturbed in each vegetation 

community has been estimated, and the actual disturbance would be evaluated 

against that estimate to ensure it is not substantially exceeded. 

Some of the surface disturbance would be long-term, where topsoil and vegetation 

would be removed for the life of the Project, e.g., under the Plant. These areas 

would only be reseeded during Final Reclamation, after the facilities are removed 

and topsoil replaced. Other surface disturbance is considered short-term, e.g., 

pipeline installation, where vegetation and topsoil would be removed, but topsoil 

would be replaced shortly after the disturbance. These areas would be reseeded 

after topsoil replacement to reestablish vegetation for erosion and weed control 

(Section 4.8.1). However, in the following estimates of the affected acres of 

vegetation, all of the disturbance is assumed to be long-term, i.e., no ‘credit’ is 

taken in the acreage estimates for interim reseeding with either the temporary or 

permanent seed mix. This was done because the success of vegetation 

reestablishment, after reclamation is completed in any area, cannot be evaluated 

in accordance with WDEQ-LQD criteria before the fifth full growing season after 

seeding. 

Other vegetation disturbance is due to crushing of the plants by equipment, e.g., 

as drill rigs drive through the pattern areas. Although the roots may remain intact 

in these areas, making vegetation regrowth easier, these areas are included in the 

disturbance estimates. 

Vegetation in the Permit Area could also be impacted by changes in the 

proportions of the species present. Of particular concern is the introduction of 

weeds. Based on the use of effective protection measures (Section 4.8.1), no 

specific acreage estimate was assigned to this impact. The effectiveness of 

reseeding, with either the temporary or permanent seed mix (Section 4.8.1), could 

be impacted by grazing or drought. 
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Spills of fuels, lubricants and other chemicals used during Construction could also 

have an impact on vegetation, if not remediated quickly. Because these impacts 

would be tied to the impacts on soil and because soil conditions would affect the 

ability for vegetation to reestablish itself after such an impact, the discussion of 

these impacts and associated monitoring and mitigation are discussed under Soil 

Impacts (Section 4.5). 

4.8.4.1 Construction 

The Construction phase includes Initial Construction and the progressive Mine 

Unit Development. Initial Construction would require about seven months. Most 

of the disturbance during Initial Construction would be long-term, i.e., lasting for 

the duration of the Project, because it would include vegetation removal from the 

areas on which Project facilities would be built. For the purpose of determining 

the acres of vegetation disturbance during Initial Construction, the ‘life-ofProject’ facilities are listed below and in Table 4.5-1: 

x the Plant and related facilities (e.g., the Storage Ponds); 

x staging areas (even though two of them may not be needed); 

x deep wells and associated pipelines (The deep well in the southwest corner 

of the Permit Area was installed in 2008 to obtain the necessary 

subsurface information on the feasibility of this disposal option. The 

disturbance associated with that well is still included in this estimate. Not 

all of the deep wells may be needed and not all of them would be installed 

initially.); 

x the trunkline (which would actually be constructed in stages as the mine 

units are brought on-line); and 

x access road improvements. 

The area of vegetation disturbance (primarily vegetation removal) during Initial 

Construction is about 95 acres (rounded to closest 5 acres). Approximately 80 

percent of this disturbance is in the Upland Big Sagebrush Shrubland, with the 

rest, about 20 percent, in the Lowland Big Sagebrush Shrubland. 

During Mine Unit Development, most of the surface disturbance would result 

from activities related to drilling of injection, production and monitor wells and 

construction of pipelines, header houses and necessary access roads. During 

Mine Unit Development, the impacts would be similar to those during Initial 

Construction, but the facilities being constructed would be smaller, e.g., header 

houses, and the facilities would be in place for the life of the mine unit, but not 

the life of the Project. For the purpose of determining the acres of vegetation 

disturbance during Mine Unit Development, the mine unit facilities are listed 

below and in Table 4.5-1: 
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x pipelines outside the pattern areas; 

x drill pads outside the pattern areas (This includes exploration holes and the 

monitor well rings. The MU1 monitor wells were installed in 2006 to 

2008 to obtain the necessary subsurface information for permitting the 

Project. The surface disturbance associated with those wells is still 

included in this estimate.); 

x secondary and two-track roads to and within the mine units; and 

x pattern areas. 

The area of vegetation disturbance (primarily vegetation crushing in the pattern 

areas) during Mine Unit Development is on the order of 240 acres. All but about 

85 percent of this disturbance is in the Upland Big Sagebrush Shrubland, with the 

rest, about 15 percent, in the Lowland Big Sagebrush Shrubland. Based on the 

Project schedule presented in Figure 2.1-8, about 50 acres of disturbance would 

occur during the development of MU1, which would be at about the same time as 

the Initial Construction of the life-of-Project facilities. Approximately another 95 

acres of disturbance would occur about two years later, during development of 

Mine Unit 2; and another 95 acres two years after that for Mine Unit 3. 

Based on available information, an additional 15 acres would be disturbed for 

Mine Unit Development in the KM Horizon because the underlying KM Horizon 

ore body footprint is similar to the HJ Horizon. Therefore, the total disturbance 

area is 345 acres (330 acres for the Initial Construction and Mine Unit 

Development in the HJ Horizon and 15 acres for Mine Unit Development in the 

KM Horizon). A more detailed assessment of the surface disturbance related to 

development of the KM Horizon would be available when LCI submits a permit 

revision to WDEQ-LQD. 

Section 4.6 of the NRC SEIS discusses the impacts to ecological resources in the 

Permit area, including impacts on the vegetation in the area. While vegetation 

would be removed as a result of the Construction activities, the small percentage 

of affected area makes the overall impact small (NRC, 2011a). 

4.8.4.2 Operation 

During the Operation phase, there would be little, if any, new disturbance. 

The NRC SEIS states in Section 4.6.1.2.1 that the impacts to vegetation during 

the Operation phase would be minimal since most of the land used was cleared 

during the Construction phase (NRC, 2011a). 

4.8.4.3 Reclamation 

The Reclamation phase includes the progressive Mine Unit Reclamation and the 

Final Reclamation. During Mine Unit Reclamation, disturbance would again 
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occur during some activities, e.g., when wells are abandoned and pipelines are 

removed from reseeded areas. However, this ‘re-disturbance’ of the same areas, 

e.g., a pipeline corridor, is not counted twice in the assessment of the acres 

disturbed. 

There should be no additional vegetation removal or crushing during Final 

Reclamation. Disturbance of reseeded areas, e.g., pipeline corridors, would occur 

during some activities. However, this ‘re-disturbance’ of the same areas is not 

counted twice in the assessment of the acres disturbed. As the areas are reseeded 

with the permanent seed mix, there could be changes in the proportion of various 

species, including an increase in weeds. 

Section 4.6 of the NRC SEIS discusses the impacts to ecological resources, 

including vegetation in the area. New damage from reclamation may result from 

spills or leaks during the decommissioning process, but with the mitigation 

measures this is not expected to be significant. However, the NRC discusses 

some concern that the slow reestablishment of sagebrush shrubland and the 

woody plant species could lead to slightly more significant impacts (NRC, 

2011a). 

4.8.5 Vegetation Impacts from Other Alternatives 

4.8.5.1 No Action Alternative 

Under the No Action Alternative, surface disturbance would be avoided and there 

would be no impacts to surface vegetation related to the Project. Impacts from 

other existing activities, such as cattle grazing, mineral exploration, recreation and 

hunting would continue. 

4.8.5.2 Not Fencing the Pattern Areas 

There would be a slight reduction in the acres of vegetation disturbance if the 

fences around the patterns areas were not constructed. However, the mitigation 

measures in the pattern areas, specifically reseeding, would be adversely 

impacted, as the new vegetation growth in the reseeded areas would be preferred 

by livestock and wild horses. 

4.8.5.3 Drying Yellowcake On-Site Alternative 

This alternative would have no impact on vegetation resources at the Permit Area, 

as the dryer would be within the Plant footprint. 

 
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4.9 Wildlife 

4.9.1 Agency-Required Measures 

This section describes the agency-required measures which would be included in 

the Proposed Action for the protection of wildlife in and near the Permit Area. 

All wildlife management practices were established in conjunction with the BLM, 

WGFD and USFWS guidelines and are designed to be consistent with regional 

recommendations by land and wildlife management agencies (BLM, 2008c; 

WGFD 2008b; and WGFD 2009). The Wildlife Protection Plan for the Project is 

included in Attachment OP-6 of the WDEQ-LQD Permit to Mine, and 

correspondence with USFWS and WGFD about these Plans is provided in 

Addendum OP-A6-A of that attachment (LCI, 2011b). Standard construction, 

erosion control, and other BMPs described in other sections of this EIS would 

also help to minimize wildlife impacts. 

Particular attention was given to protection measures for Greater sage-grouse. 

The Project is located on the edge of the South Pass Greater sage-grouse Core 

Breeding Area (WGFD, 2008b), as shown on Figure 3.8-5. The measures for 

Greater sage-grouse were adapted from the Core Population Area Stipulations 

(WGFD, 2008b) and the stipulations developed by the Sage Grouse 

Implementation Team (Mead, 2011) to be practical in an ISR environment. The 

stipulations and their application are included in Table OP-A6-1 of the WDEQLQD Permit to Mine (LCI, 2011b). A detailed assessment of the impacts on 

Greater Sage-Grouse using the SGIT Stipulations is included in Section 4.9.5.3 of 

this EIS. 

Based on the BLM review of the agency-required measures, three BLM 

management actions were added (Section 4.9.1.10). The first measure addresses 

the specific dates for prohibition of disruptive activities near Greater sage-grouse 

leks. Based on bird behavior in the Rawlins Field Office area, the dates are 

slightly different than the dates in other areas in Wyoming. The second measure 

addresses continued consultation with agencies and incorporation of annual 

monitoring data through an Adaptive Management Plan. The third measure 

relates to new fence construction (Section 4.9.1.2) and addresses potential 

discrepancies between BLM and WDEQ-LQD fencing criteria. Fences would be 

constructed according to BLM standards unless modified following consultation 

with affected parties. All fencing would be ‘wildlife’ friendly fencing, with 

appropriate perching and collision deterrents, with the exception of the fencing 

around the Storage Ponds, which would be exclusion fencing. 
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4.9.1.1 Road and Right-of-Way Measures 

The East and West Access Roads would be upgraded and access roads within the 

Permit Area would use existing two-track roads to the extent possible to help 

minimize new disturbance of sagebrush habitat. The roads would be upgraded or 

constructed following the BLM and WGFD recommendations to minimize the 

road width, revegetate road shoulders, and limit vehicular speeds. 

All employees and contractors would be trained to recognize types of wildlife in 

the area, their susceptibility to disturbance or to collisions with motor vehicles, 

and measures that should be taken to avoid disturbance and wildlife/vehicle 

collisions. Speed limits within the Permit Area would be set based on the 

following considerations: the condition of the road, design of the road, safety 

factors, protection of equipment, wildlife and livestock protection, and dust 

protection measures. Generally, the speed limit on main roads would be 30 miles 

per hour and on secondary roads the speed limit would be 20 miles per hour. 

However, in no case would the speed limit be greater than 30 miles per hour. All 

employees would receive training regarding speed limits during indoctrination 

training. Site visitors would be advised of the Permit Area speed limits during 

site-specific training. Speed limit signs would be posted on the main roads with 

the permission of the BLM. 

An additional protective measure that may be implemented in concert with the 

BLM would be to gate or sign existing two-track roads that are adjacent to the 

main access road and Plant in order to help prevent additional traffic disturbance 

in the area. Project personnel travel outside of primary construction and drilling 

areas would be minimized through education and required use of main and 

secondary access roads. 

4.9.1.2 Fencing and Screening Measures 

Mine unit pattern areas would be fenced with standard wildlife friendly fencing 

based on the BLM Manual Handbook 1741-1, Fencing (1989), which would keep 

cattle and wild horses out but would allow the passage of pronghorn and other 

wildlife. The fences would be removed after ISR operations are complete and 

vegetation has become reestablished in accordance with permit requirements as 

described in Section RP 4.5.4 of the WDEQ-LQD Permit to Mine Reclamation 

Plan (LCI, 2011b) unless otherwise approved by the BLM. Access to the fenced 

areas would be through gates (e.g., at the Storage Ponds). Because there is the 

potential for gates to be inadvertently left open on occasion, pitless cattle guards 

or automatic gates may be installed to prevent cattle and wild horses from 

entering an open gate and becoming trapped in the fenced area. 

All mud pits outside of fenced areas would be fenced during the drilling phase, 

while the pits are open. 
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The Plant and Storage Ponds would be fenced for the duration of the Project. The 

fence around the Plant would be standard wildlife friendly fencing based on the 

BLM Manual Handbook 1741-1, Fencing (1989). The fence around the Storage 

Ponds would be constructed to prevent access by terrestrial mammals and to 

improve safety (Type I fencing per WDEQ-LQD Guideline No. 10 [1994c]). The 

Storage Ponds would be monitored daily for wildlife mortality. If evidence of 

mortality is present, additional measures may be taken to prevent access. 

Additional deterrents would be consistent with agency recommendations. 

Anti-perch measures on fence lines would be taken to reduce excessive predation 

of Greater sage-grouse. 

4.9.1.3 Transmission Lines 

The proposed pipelines, transmission line, and any other utilities would be placed 

in or adjacent to the access road right-of-way to help minimize habitat impacts 

where possible. To prevent the electrocution of raptors, the primary and 

secondary transmission lines and power poles would be built to the latest 

approved methods (APLIC, 2006). This would include cross-arm and transformer 

design. Tertiary transmission lines would be buried in order to minimize risks to 

raptors and large birds. In addition, to discourage roosting by raptors and corvids 

(and, in turn, increased predation of Greater sage-grouse), appropriate antiperching and anti-roosting devices would be placed on power poles and crossarms. The design would follow the BLM guidelines (Oles, 2007) or other 

appropriate guidelines. 

4.9.1.4 Disease 

To reduce the threat of mosquito-borne illnesses in wildlife, LCI would treat the 

two Storage Ponds with an approved insecticide to prevent mosquito hatches. 

Drilling mud pits would be backfilled as soon as possible after use in order to 

eliminate their use by mosquitoes. Equipment and materials would be stored in a 

manner that minimizes the accumulation of stagnant water. Used tires would be 

disposed of as they are generated or would be stored in a manner that prevents 

accumulation of water until taken off-site for disposal. 

4.9.1.5 Wildfire 

LCI would implement procedures to minimize the likelihood of starting a wildfire 

(including Hot Work Permits, Site Inspections, and Proper Storage of Waste). All 

field personnel would be trained in Emergency Response Procedures, including 

reporting of fires. ISR uranium facilities generally use plastic piping, therefore, 

minimal welding and cutting takes place in the field. In addition to the 

preventative measures described in the NRC Technical Report (e.g., Sections 

5.7.1.4 and 7.6) (LCI, 2010), LCI would have a supply of fresh water from the 
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water supply wells (Section 4.7.5.1) that could be used to help with wildfire 

suppression, if necessary. 

LCI would not use prescribed fires or weed burners to remove vegetation or to 

control invasive species unless prior approval is granted by the BLM and WGFD. 

4.9.1.6 Potentially Harmful Materials 

Several measures would be used to prevent exposure to potentially harmful 

materials, and should an accident occur, procedures would be in place to promptly 

remove/remediate any releases. All liquid chemicals and petroleum products in 

and around the Plant would be maintained within bermed areas sufficient to 

contain any potential spill. No bulk hazardous chemicals would be used in the 

mine units. The mining solutions would have a pH of around 8.0 and would not 

contain any petroleum-based chemicals or elevated levels of heavy metals that 

present an acute hazard to wildlife or employees. 

Any wildlife mortality that could be attributed to exposure to toxic substances 

would be reported immediately to WDEQ-LQD (and other WDEQ divisions as 

necessary), the BLM, USFWS, and WGFD. The goal of such reporting would be 

to identify and resolve the problem as quickly as possible. 

As previously discussed, the water quality in the Storage Ponds would be 

monitored quarterly and whenever a process change may result in a significant 

change in water quality. The Storage Ponds would contain produced groundwater 

and process waters with a near neutral pH. No petroleum-based products would 

be sent to the Storage Ponds. Due to implementation of fencing, deterrents, and 

the control of algae and plankton, the water quality in the Storage Ponds is not 

expected to pose a risk to birds. However, if mortalities or frequent habitation of 

the Storage Ponds are noted, LCI will work with WGFD to develop additional 

protective measures to ensure the protection of birds. 

4.9.1.7 Reclamation 

Reclamation would be practiced throughout the Construction and Operation 

phases. Disturbed surfaces would be revegetated at the next appropriate season 

using a temporary or permanent mix seed, depending on whether the area would 

be redisturbed (Section 4.8). LCI would continue to reclaim disturbed areas as 

soon as possible after exploration and ISR activities to help ensure 

reestablishment of habitat, as described in Section RP 4.5 of the WDEQ-LQD 

Permit to Mine (LCI, 2011b). 

Weed control is an important issue for Reclamation and protection of existing 

habitats for Greater sage-grouse and other species, and plant communities. Weed 

prevention measures, following the BLM guidelines and recommendations, would 

be implemented (BLM, 1996b and 2008c). 
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4.9.1.8 Reduction of Human Disturbance and Incidental Loss of 

Wildlife 

All employees would be informed of applicable wildlife laws and penalties 

associated with unlawful taking and harassment of wildlife. Employees would 

also be trained to recognize types of wildlife in the area, understand exclusion 

areas and dates, and report unusual activity or sightings, accidents, and other field 

conditions related to wildlife. Adherence to rules and procedures established for 

wildlife and habitat protection, such as speed limits, traffic routes, would also be 

monitored to reduce disturbance and mortality. 

4.9.1.9 Wildlife Closures and Timing Windows 

Both Greater sage-grouse and raptors have been identified by the BLM and 

WGFD to have seasonal time periods where restriction of activities can be 

particularly effective for their protection. The wildlife exclusion periods 

recommended by the BLM and WGFD are presented in Table 4.9-3. LCI would 

follow exclusion periods, as applicable, by species to protect key wildlife 

resources in the Permit Area. During exploration drilling, the standard timing 

restrictions identified by the BLM would continue to be followed, unless 

otherwise approved by the BLM. 

 
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4.9.1.10 Greater Sage-Grouse Protection 

A variety of protection measures would be implemented for Greater sage-grouse 

protection as required by the Governor’s Executive Order for Greater sage-grouse 

(2011-05) (Mead, 2011). These measures include road design, traffic controls; 

fencing, habitat enhancement, personnel scheduling, and facility maintenance, as 

described in more detail below. Furthermore, a detailed discussion of how the 

project meets the SGIT (Mead, 2011) stipulations is included in Section 4.9.5.3. 

An Adaptive Management Plan would also be adopted, as outlined below. 

As previously discussed, access roads would follow existing two-track roads to 

the extent possible to help minimize disturbance of habitat. Road widths would 

be minimized, while still conforming to the International Fire Code, as requested 

by county zoning. Increased traffic due to Construction and the addition of new 

roads could increase accidental fatal collisions with Greater sage-grouse. In an 

effort to mitigate strikes and comply with the Executive Order, main hauling 

roads would be located farther than 1.9 miles away from occupied leks. This 

stipulation applies to new roads; however, existing roads are exempt through the 

“grandfather clause”. The BLM states that, “any areas already disturbed or 

approved in mine plans prior to the Governor’s Executive Order, dated August 1, 

2008, are not subject to new Greater sage-grouse stipulations, except that these 

mine operations may not initiate activities resulting in new surface occupancy 

within 0.6 miles of the perimeter of a Greater sage-grouse lek” (Mead, 2011). 

Protection measures, such as reduced speed limits and watering the road, would 

be implemented to reduce the amount of dust generated, which would potentially 

affect palatability of sagebrush. 

Protection measures involving fencing in order to reduce impacts to Greater sagegrouse were discussed previously in the fencing section (Section 4.9.1.2). 

Adaptive Management 

In addition to the above mentioned protection measures, per Mead (2011), the 

following adaptive management plan would be implemented to manage Greater 

sage-grouse populations within the area of impact of the Project. 

Baseline data has been collected from 2007 through 2011 providing a reference to 

compare future population trends and habitat use. This baseline data collection 

protocol established both an impact zone and a control area for Greater sagegrouse for this project. The impact zone is simply defined as the area within a 

4.0-mile buffer surrounding the mine project area. The area outside of a 4.0-mile 

buffer would not be disturbed by project activities and would be the control area. 

The control area contains 15 Greater sage-grouse leks which would be continued 

to be monitored through development and on into, and through production. 

Concurrently, a suite of control leks (39 total) would also be monitored during the 
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same time frame. Monitoring of leks would follow protocol established by the 

WGFD. As new leks are discovered within the impact or control areas they 

would be included in the analyses. 

A technical advisory committee (TAC) consisting of the BLM, WGFD, the 

proponent, and appropriate consultant(s) would be created. The TAC would meet 

on an annual basis, and as called upon by the proponent, to review and discuss the 

annual wildlife report findings related to Greater sage-grouse. The report would 

include, at a minimum, the past year’s lek monitoring data. Lek attendance would 

be summarized at impact leks and control leks on an annual basis. Trends would 

be determined across three-year running averages, comparing impact area leks to 

control area leks. If a decline is observed at impact area leks as compared to 

control leks (using a 3-year running average during any five-year period), the 

trends would be analyzed to determine statistical significance and to determine if 

the downward trend is likely attributable to Project activity. If so, this would 

indicate that an impact threshold has been reached. The TAC would discuss an 

appropriate protection measures to apply in an attempt to reverse or minimize the 

impact(s). In the event that an impact has been determined but the cause of the 

impact cannot be determined the TAC would discuss and implement protection 

measures with the assumption that the ISR project has some relation to the 

determined impact. It would be incumbent on the proponent to pay for a study to 

determine actual cause of the determined impact if the proponent wishes to avoid 

applying additional protection measures to the company’s operations. All 

additional protection measures would be monitored and their effectiveness 

analyzed during the annual meeting. If, after a two-year period, the additional 

protective measures show no positive effect on the impacted leks, additional 

measures would be applied. This cycle would repeat until all possible protection 

measures have been applied or the impacted leks show a positive effect from the 

applied measures. 

Based upon Greater sage-grouse research related to energy development, the most 

likely impacts would occur from human activity and disturbance. Primarily 

actions that are perceived by Greater sage-grouse either visually or auditorily 

would elicit a behavioral response from Greater sage-grouse. Thus, most 

disturbance issues would likely involve movement and noise. Traffic levels and 

speeds, traffic noise, machinery movement or noise, are examples of impactinducing factors. Thus, protective practices would include options that can help 

reduce or eliminate disturbance issues. Practices to consider include; setting 

vehicle speed limits, traffic timing, reducing traffic, or sound reduction 

techniques, as well as other protective measures discussed above. 
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Additional Protective Measures to be Considered Based on Results from 

Monitoring 

Based on available information, it can be conservatively anticipated that at least 

some Project activities within the Permit Area would negatively influence 

populations. Enhancement of selective habitats could be considered as an 

optional protective measure. Habitats to be prioritized for enhancement would be 

selected according to the analyses described in Section 4.9.2.4. Enhancement 

considerations would be based on patch-size and large spatial scales, in order to 

increase the probability of a population-level effect and would also focus on the 

seasonal habitat(s) most influenced by Project activities. For example, if suitable 

nesting habitat is most influenced, then habitat enhancements would focus on 

increasing grass height and cover within relatively dense sagebrush stands and 

maintaining that height and cover to the following nesting season as residual 

grass. This enhancement plan would be developed and implemented with the 

assistance of the BLM and WGFD rangeland specialists. 

Greater sage-grouse show remarkable fidelity, especially to nesting locations, and 

it has been shown in a developing natural gas field that adult females would not 

vacate their nesting areas regardless of the level of development that occurs 

within those areas (Holloran, 2005). Because of this fidelity, maintaining 

individuals that are using habitats within the Small Greater sage-grouse 

Monitoring Area (Section 4.9.2.4) may expedite recolonization of the Permit 

Area following completion of Production. Therefore, personnel activities that 

may disturb females using habitats would be curtailed (e.g., dogs must be leashed 

at all times, walking into undisturbed habitats would be discouraged, and speed 

limits would be strictly enforced). Trash and road kill would be collected on a 

regular basis to minimize corvid occurrence within the Small Greater sage-grouse 

Monitoring Area. Whenever a nesting female is discovered, additional protective 

measures may be instituted, including but not limited to delaying or limiting 

Project activities close to the nest until the female has left the area. Protective 

measures would be determined on a case-by-case basis, depending on factors such 

as proximity and timing relative to critical Project activities. More details on the 

protective measures described in this section can be found in section 2.2 of 

Attachment OP-6 in the WDEQ-LQD Permit to Mine (LCI, 2011b). 

4.9.1.11 Raptor Protection 

Spatial and seasonal buffers recommended for the protection of raptors by the 

Rawlins Field Office RMP (BLM, 2008c) and the USFWS (2010d) would be 

adhered to, as previously discussed. 
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4.9.1.12 Wildlife Enhancements 

In coordination with the BLM and WGFD, wildlife enhancements could be 

orchestrated in the Permit Area or nearby areas that are not proposed for 

Operation or disturbance. These enhancements could include placement of new 

raptor nest platforms, creation of new water sources, or habitat 

modifications/improvements to improve specific habitat conditions for Greater 

sage-grouse (Section 4.9.1.10) or other high interest species. All seeding would 

be completed with native species; sagebrush would be included in all seed mixes. 

4.9.2 Wildlife Monitoring 

Monitoring of wildlife resources in and near the Permit Area would be completed 

on an annual basis throughout the life of the Project. The purpose of the annual 

monitoring would be to document wildlife resources, population trends, and 

habitat conditions to help minimize adverse impacts to wildlife. 

4.9.2.1 Annual Monitoring and Report 

Annual wildlife monitoring would be coordinated with the Rawlins BLM Field 

Office and WGFD. Consultation with the BLM and WGFD would be conducted 

prior to completing any annual survey work. Wildlife inventory and monitoring 

would be completed by BLM or WGFD biologists, or a third-party contractor 

paid for by LCI. 

An annual monitoring report would be prepared and submitted to the BLM, 

WGFD, and other interested parties by November 15 of each year. The report 

would include: survey methods, results, any trends, an assessment of protection 

measures implemented during the past year; recommendations for protection 

measures for the coming year; recommended modifications to monitoring or 

surveying; and any recommendations for additional species to be monitored (e.g., 

a newly listed species). The Annual Wildlife Monitoring Report, data and 

mapping would be formatted to meet WDEQ-LQD requirements. Only qualified 

wildlife biologists or ecologists would be employed for wildlife monitoring. 

In addition to the specific annual monitoring for wildlife, LCI would document all 

known instances where Project activities may have impacted wildlife (such as 

wildlife/vehicle collisions on roads, or other mortality within the Permit Area). 

Any large die-offs or other evidence of possible wildlife exposure to toxic 

chemicals would be reported immediately to WDEQ-LQD (and other WDEQ 

divisions as necessary), the BLM, USFWS, and WGFD. A record of wildlife 

mortality would be kept at the Permit Area and included in the Annual Wildlife 

Monitoring Report. 

Monitoring and survey methods are designed to be consistent with standard 

protocol used by WGFD (2007), and to also follow monitoring requirements and 
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recommendations from WDEQ-LQD (Wildlife Monitoring Requirements for 

Surface Coal Mining Operations). 

Table OP-A6-6 in the WDEQ-LQD Permit to Mine (LCI, 2011b) includes the 

wildlife monitoring schedule, which is described in the following sections. 

4.9.2.2 General Wildlife 

No specific monitoring measures are proposed for most wildlife species. Any 

known mortality of sensitive wildlife species due to Project activities would be 

recorded and reported. Any large die-offs or other evidence of possible wildlife 

exposure to toxic chemicals would be reported immediately to the BLM, WGFD, 

and USFWS. 

4.9.2.3 Big Game 

An annual record of all big game mortality due to fence entanglements, vehicle 

collisions, and other factors would be completed. Winter mortalities would be 

estimated each spring from observations taken during wildlife surveys and other 

mine activities. The data to be recorded include: species, date, probable cause of 

mortality, and location. A table summarizing big game mortality would be 

submitted in the Annual Wildlife Monitoring Report. 

If concentrations of pronghorn appear suddenly or if apparent migration blocks 

(fences, snow drifts along roads or other blocks) are observed, local WGFD 

personnel would be notified immediately. Any big game concentrations or 

migration blocks would be reported in the Annual Wildlife Monitoring Report. 

4.9.2.4 Greater sage-grouse 

The Greater sage-grouse monitoring protocols presented here are designed to 

assess the effects of Project activities on: Greater sage-grouse populations; 

seasonal habitat selection; and productivity within the Greater sage-grouse 

Monitoring Areas (Figure 4.9-1). Section 4.9.1.10 discusses how the Greater 

sage-grouse monitoring data would be used for adaptive management. As 

previously noted in Section 3.8, the Greater sage-grouse Monitoring Areas are: 

x The Small Greater sage-grouse Monitoring Area, which is delineated to 

conservatively establish the area where nesting and early brood-rearing 

females may be influenced by Project activities; and 

x The Large Greater sage-grouse Monitoring Area, which is delineated to 

maximize the probability that control leks would be included. Control 

leks are considered to be leks within and/or near Core Area boundaries 

that are not influenced by the Project, major highways, or other 

anthropogenic activities, except livestock grazing and public recreation. 
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LCI would use lek search and lek count protocols to assess potential impacts of 

Project activities on Greater sage-grouse populations. The objective of lek counts 

is to track male breeding population size within the Greater sage-grouse 

Monitoring Areas throughout the life of the Project. The objective of lek searches 

is to determine if new leks become active within the Greater sage-grouse 

Monitoring Areas during the life of the Project. 

To determine the potential effects of the Project on habitat selection, LCI would 

model the seasonal habitats existing within the Small Greater sage-grouse 

Monitoring Area. The objectives of these models are to quantify the amount of 

habitat functionally influenced by the Project on a seasonal basis (e.g., nesting, 

early brood-rearing, summering and wintering habitats). 

LCI would use brood survey routes and wing surveys to assess potential Project 

impacts on Greater sage-grouse productivity. The objective of both surveys is to 

track chick productivity of females potentially influenced by Project activities 

throughout the life of the Project. 

Greater sage-grouse surveys discussed below would follow standard protocol as 

recommended by the WGFD Greater sage-grouse Technical Committee and by 

Connelly et al. (2003). 

This comprehensive Greater sage-grouse monitoring plan is designed to 

accomplish definitive monitoring of the effects of Project activities on Greater 

sage-grouse. The monitoring would lead to and guide effective protection 

actions. However, it is a cost intensive, long-term commitment and is timed to 

establish baseline conditions. Should a situation arise that prohibits or 

significantly delays LCI’s activities (before or after regulatory approvals for the 

Project are issued), the commitment may be curtailed and may be limited to only 

the required annual lek counts within the Small Greater sage-grouse Monitoring 

Area. LCI would inform WGFD, the BLM, WDEQ-LQD, and NRC should this 

monitoring change be necessary. 

 
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Figure 4.9-1 Greater sage-grouse Study Areas 

 
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Populations 

Lek Counts 

Lek count data would be the primary data used to assess the population-level 

effects of developing the Lost Creek uranium deposits. The lek monitoring 

methods are therefore as comprehensive as possible. The objective of lek count 

monitoring is to track, as inclusively as possible, male breeding populations on 

leks potentially influenced by Project activities concurrent with leks not 

influenced by such activities but similar in other aspects throughout the life of the 

Project. 

Counts would be conducted at all known leks within the Greater sage-grouse 

Monitoring Areas starting with the 2010 baseline list of known leks, established 

from existing data (e.g., the WGFD Greater sage-grouse database) and a 

comprehensive lek search of the Greater sage-grouse Monitoring Areas conducted 

in April 2010. The list of known leks would be updated on a three-year cycle 

based on lek search flight results. 

All known leks within the Greater sage-grouse Monitoring Areas would be 

counted annually. This number of leks may increase, depending on results of lek 

searches conducted throughout the life of the Project; however, the number would 

not be decreased from the 2010 baseline unless leks are established as 

‘unoccupied’ following protocols outlined by the WGFD Greater sage-grouse 

Technical Committee. LCI would coordinate monitoring efforts with the BLM 

and WGFD to avoid duplicative efforts and, as a result, undue disturbance of the 

leks. The count methodology that LCI would use is outlined below. 

The general lek count methodology is as follows: 

x Counts would be conducted during the month following the peak of 

mating activity (April 1 to May 7). Research has shown that the highest 

number of male Greater sage-grouse is observed during this period. The 

increased number of males is due to young males showing up later in the 

strutting season even though most of the breeding has already occurred. 

x Counts would be conducted from the ground as close to sunrise as possible 

and extended for one-half hour after sunrise. The phase of the moon may 

affect lek use patterns. During a full moon, Greater sage-grouse may 

display at night and consequently terminate activities earlier in the 

morning. This variation in activity may influence the choice of counting 

dates. 

x Counts would be conducted a minimum of three times each year for each 

lek (at least one count every seven to ten days). 

x All leks within a lek complex would be counted on the same day, with lek 

complexes estimated from spatial orientation of leks within the Greater 

sage-grouse Monitoring Areas. 
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x Counts would be completed on days with good weather conditions. 

Optimum weather conditions for counts are clear, calm days. Wind 

speeds should be less than 20 mph because high winds reduce lek activity. 

Temperature seems to have little effect on activity. Weather conditions 

would be recorded during each count. 

x Known lek locations are sited in mid-day periods prior to completing any 

counts. Access routes and counting points are predetermined to allow the 

observer to count the lek without disturbing birds by driving or hiking. 

Counts are made by using binoculars and spotting scopes from observation 

points. Observation points for each lek would be established and noted in 

2010 and each lek would be counted from these points in subsequent 

years. 

x The location of each lek would be accurately determined and recorded 

using the Universal Transverse Mercator geographic coordinate system 

and the North American Datum 83. Observers should not disturb Greater 

sage-grouse to obtain lek locations. If a lek is active, the observers should 

make the best estimate of the lek location and return later to confirm. 

x Data would be recorded on the standardized statewide reporting form. 

Lek Searches 

Breeding Greater sage-grouse may be displaced by some Project activities and 

thereby occupy other existing active leks or form new leks farther from those 

activities. Thus, lek searches would be required to accurately assess the 

population-level response of Greater sage-grouse to Project activities. 

During the peak breeding period in April 2010, a systematic search for leks within 

the Greater sage-grouse Monitoring Areas would be conducted from the ground to 

ensure the baseline survey is as thorough as possible. Ground searches would be 

conducted from 0.5 hours prior to sunrise to 1.5 hours after sunrise. If the April 

full moon coincides with the peak breeding period, additional searches throughout 

the nights with good moonlight would be conducted. The ground at all potential 

leks would be searched once the birds have left the site for evidence of consistent 

use (e.g., fecal droppings and feathers). Ground searches for leks can be more 

effective than aerial searches due to the birds’ reaction to aircraft (crouching), 

which makes the birds difficult to see and thus the leks difficult to identify, 

especially smaller leks. Ground searches can also be more effective as a result of 

focusing all locating techniques, such as listening and habitat inspection. 

Additionally, as Greater sage-grouse display all night during the full moon at the 

peak of the breeding period, night surveys can be effective at finding leks by 

sound. 

Lek searches of the Greater sage-grouse Monitoring Areas would be conducted 

from fixed-wing aircraft every third year following establishment of baseline (i.e., 

2013, 2016, and continuing through the Project). Searches would be conducted 
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during the peak of the breeding period between 0.5 hours before and 1.5 hours 

after sunrise. Transects (approximately 1.0 kilometer [0.6 miles] apart) would be 

flown along north-south lines. Flights would be limited to days with good 

visibility and weather. Transects would be flown from approximately 100 to 150 

meters (328 to 492 feet) above ground level. Return visits from the ground to all 

potential new sites would be conducted to confirm a location as a lek as soon as 

feasible following aerial searches. If a new lek is found, it would be added to the 

known lek list and counted annually. Although, counting of new leks during the 

year of discovery would be initiated later in the breeding period (i.e., after the lek 

search), since maximum male attendance generally occurs after the peak of 

breeding due to the behavior of yearling males (thus counts should not be biased). 

As noted above, aerial searches may not be as effective as ground searches; 

however, ensuring the data are collected in a standardized manner throughout the 

life of the Project is critical. Aerial searches do not require the same level of 

experience as a ground-based search and logistical considerations are less 

daunting. Therefore, aerial searches increase the likelihood that comparable data 

can be collected throughout the life of the Project. 

In addition to determining Project-related impacts on Greater sage-grouse, lek 

data will also be used to assess the extent of impacts attributable to non-Project 

related activities such as other energy development project activities, grazing, and 

non-Project related traffic. Lek data will also be used to focus any potential Great 

sage-grouse habitat enhancements on areas used by birds, which are most 

impacted by the Project. Section 2.2.1.3 of attachment OP-6 in the WDEQ-LQD 

Permit to Mine (LCI, 2011b) describes these analyses in detail. 

Habitat Selection 

Non-invasive techniques for monitoring Greater sage-grouse nesting and early 

brood-rearing habitat selection and success are limited to radio telemetry 

[Spotlight capture and collaring of females during the peak of breeding appears to 

have negligible effect on subsequent behavior (Holloran, verbal communication, 

January 2010)]. However, given the potential reaction of females to Project 

activities, the probability of maintaining a sample of radio-equipped birds in areas 

affected by Project activities throughout the life of the Project may be low 

(deduced from Walker et al., 2007). Therefore, for the purposes of designing the 

monitoring program, it has been assumed that uranium extraction in the Permit 

Area would have an influence on nesting and early brood-rearing females similar 

to the influence of natural gas development. 

Information from nesting female long-term reactions to natural gas development 

suggests that the area within one kilometer (0.6 miles) of infrastructure associated 

with energy development is functionally lost as nesting habitat (Holloran et al., 

2010). Holloran et al. (2010) also report that Greater sage-grouse females in 

Wyoming rear their broods during the early brood-rearing period within 1.65 
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kilometers (1.0 mile) of their nest. Thus, the amount of nesting and early broodrearing habitat that would be influenced by developing the Project would be 

conservatively estimated as all suitable habitats within the Permit Area and within 

2.65 kilometers (1.65 miles) of the Permit Area. Additionally, Ur-E’s (LCI’s 

parent company) two-year proposed exploratory drilling plan suggests activity 

south and southeast of the Permit Area. In anticipation of future actions (Section 

5.1.1) LCI would buffer this area of proposed activity by 2.65 kilometers and 

include this as potentially impacted habitat (i.e., as part of the Small Greater sagegrouse Monitoring Area). Given the nature of exploratory drilling, this portion of 

the Small Greater sage-grouse Monitoring Area may be modified to reflect onthe-ground activities that occur and differ from proposed future plans. 

To establish suitable habitats within the Small Greater sage-grouse Monitoring 

Area, LCI began seasonal habitat selection monitoring in 2010, and continued the 

monitoring in 2011, using radio-equipped female Greater sage-grouse. Data from 

2010 was summarized in the annual monitoring report (LWR Consultants, Inc. 

and Wyoming Wildlife Consultants, Inc., 2011), and the 2011 monitoring report 

is being completed. Thirty-six female Greater sage-grouse were captured in April 

2010 from nine leks closely associated with the Permit Area using spotlighting 

and hoop-netting techniques. Each captured female was: fitted with a 19.5-gram 

Advanced Telemetry Systems necklace-style radio-transmitter; identified as 

yearling or adult (at least two years old) by shape of outermost wing primaries; 

and released at point of capture. An additional 11 females had been collared in 

2008-09 on leks situated in the southeastern portions of the Large SG Monitoring 

Area for a research project being conducted through the University of Wyoming. 

These females were also included in the monitoring. Starting in late April, prenesting females were located at least twice weekly to determine nest initiation. 

Nesting locations of radio-equipped females were found by circling the signal 

source until females can be observed; nest sites were marked with a GPS to 

facilitate location identification following the completion of incubation. 

Incubating females were be monitored at least twice weekly. 

Nest success (hatched or not) was assessed by visual examination of eggshell 

fragments after a female has left her nesting area. Conditions at unsuccessful 

nests were examined to determine cause of failure. Females with broods were 

found twice between 5 and 14 days post-hatch to determine early brood-rearing 

habitat selection. At 14 days post-hatch, early brood-rearing success was 

determined (at least one chick alive 14 days post-hatch is a successful female); the 

existence of chicks was assessed either through direct visual confirmation of a 

chick, or through the reaction of the female to the researcher. Brooding females 

were located at least once per week from 14 days post-hatch through August. (It 

was expected that late brood-rearing habitat selection would be associated with 

mesic sites.) Barren females (e.g., females that were unsuccessful nesters or 

brooders) were located at least monthly from nest or brood loss through August to 

determine seasonal habitats selection. 
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From September through March, all radio-equipped Greater sage-grouse were 

located from fixed wing aircraft at least bimonthly. Reference transmitters (i.e., 

transmitters of known location deployed pre-flight by observers) were used to 

determine flight location accuracy. 

Seasonal habitat selection data (nest, early brood, late brood, summer, and winter) 

from the 2010 and 2011 monitoring will be used to generate Resource Selection 

Functions (RSFs) in a ‘used’ versus ‘available’ analysis. RSFs would be applied 

to map the suitable seasonal habitats existing within the Small Greater sagegrouse Monitoring Area. For this analysis, it would be assumed that Project 

activities within the Permit Area would influence the total acreage of suitable area 

by season that occurs within the boundaries of the Small Greater sage-grouse 

Monitoring Area. 

Productivity 

Three approaches would be used in evaluating Greater sage-grouse productivity: 

transects; wing barrels; and climate. 

Transects 

Late brood-rearing and barren female summer locations from radio-equipped 

birds would be used to identify areas where birds using nesting or early broodrearing habitats closely associated with the Permit Area concentrate during the 

summer. Eight permanent walking transects 1000-m in length were established in 

each of these areas. Attachment A, Figure 2.2G shows the locations, start and stop 

points, dominant vegetation, and maps of these transects. Transects were surveyed 

twice during a one-week period in late July from sunrise to two hours after sunrise to 

ensure feeding times were captured in monitoring efforts. All Greater sage-grouse 

observed were counted and classified (adult male, adult female, young of the year). 

These 2010 established transects will be surveyed annually through the life of the 

Project. Data collected from these efforts will be compared by total grouse use by sex 

and numbers of chicks per female.

Wing Barrels 

LCI would work with biologists from WGFD to establish wing-barrel locations to 

further investigate annual differences in productivity relative to Project activities. 

Wing barrels with signs designed to explain the reasoning for monitoring have 

been placed at access routes to areas where females closely associated with the 

Permit Area are located during nesting or early brood-rearing summer (treatment 

area). A comparable area in terms of available summering habitats and spatial 

scale would also be monitored in this fashion to act as a control. Barrels would be 

placed and monitored each hunting season throughout the life of the Project. 

Wings collected from these barrels would be compared (treatment versus control 

area) by the number of chicks per female in the harvest. 
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Climate 

Seasonal weather patterns may dictate Greater sage-grouse use of traditional 

summering areas. In particular, brood-rearing females would remain in sagebrush 

upland habitats until range desiccation forces them onto more mesic sites. 

Seasonal weather data would be used to assist in assessing the potential effects of 

this behavior on productivity results. 

4.9.2.5 Raptors 

Annual monitoring of known raptor nests would be completed each spring 

between April and July to determine nest status. Nest surveys would be 

completed from the ground. 

A ground survey of the Permit Area and surrounding one-mile radius would be 

completed during the first two weeks of February each year for signs of golden 

eagle and great-horned owl nesting and or courtship. Early courtship behavior 

would be documented in new nesting areas; and the BLM, USFWS, and WGFD 

would be consulted to determine appropriate protection measures. 

Three thorough surveys for nesting raptors would be completed for the Permit 

Area and surrounding one-mile perimeter through the spring. One survey would 

be completed during March to locate great-horned owl and golden eagle nests. A 

second survey would be completed early in the raptor nesting season. Field 

surveys for potential nesting raptors within 0.5 miles of existing Project activities 

and those activities proposed for the coming year shall be conducted. The 

objective is to document early courtship behavior in potential conflict situations, 

because, once eggs are laid, protective options become restricted. Reporting 

would indicate whether nesting territory is: not occupied (inactive); occupied by 

one raptor (active); or occupied by a pair (active). 

One survey would be completed from mid-May to mid-June to locate new raptor 

nests (nests that have become established since the April survey) and to check the 

status (activity, number of young birds) of all nests. Follow-up visits to 

previously identified nests would be timed to facilitate documentation of nesting 

activity, according to the biology of the species present and variations in breeding 

chronology, including: nest building; reproductive attempts and success; and 

fledging success. The status and productivity of the nests would be reported 

annually by location, nest type and characteristics, species, and number of fledged 

birds. 

Nest surveys would be completed from the ground. Nest checks would be brief 

and conducted to avoid flushing incubating raptors. 

The linear distance of each nest site (active and inactive) from the nearest known 

regular human or equipment activity would be determined each breeding season. 
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The presence of visual barriers (i.e., direct line of site blocked between the 

disturbance and the nest) would be noted. It would be determined if the 

activity/disturbance is unrelated or related to Project activities. This information 

would be shown on a raptor monitoring map in the Annual Wildlife Monitoring 

Report. 

4.9.2.6 Migratory Birds of High Federal Interest 

Nesting non-game bird surveys would be conducted in representative 

vegetation/habitat types within the Permit Area. These surveys would be used to 

document breeding MBHFI that are present in the area. 

Surveys would follow techniques recommended by WDEQ-LQD (1994b). Two 

transects would be established in each vegetation type of the Permit Area. 

Transects would be 1,000 meters (0.62 miles) in length (2,000 meters [1.24 miles] 

per habitat type – Upland Big Sagebrush Shrubland and Lowland Big Sagebrush 

Shrubland). 

In both vegetation types, 100-meter (328-foot) -wide belt transects would be 

walked. Birds (including non-game and non-MBHFI birds) observed or heard 

would be recorded. Transect start and stop points would be located by GPS. 

Transect locations would be shown on a 1:24,000-scale quadrangle map. 

Surveys would be completed during the peak of the nesting season, during the 

first week of June. Surveys would be completed from 0.5 hours before sunrise to 

9:30 AM. 

4.9.2.7 Threatened and Endangered Species 

Federally Listed or Candidate Species 

Any observation of a federally listed (T&E) species would be recorded and 

promptly reported. Any mortality of a listed species would be reported to the 

USFWS within one day of discovery. 

If new species (that are present in the Permit Area) are listed as threatened or 

endangered during the Operation phase, the USFWS would be consulted to 

develop specific protection and monitoring measures. 

BLM Special Status Species 

Pygmy Rabbits 

Based on current wildlife inventories, Pygmy rabbits are restricted to Lowland 

Big Sagebrush Shrubland habitat areas within the Permit Area. Pygmy rabbits 

would be surveyed using techniques described by Ulmschneider (2004). Four 

transects would be established in Pygmy rabbit occupied lowland sagebrush 
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swales within the Permit Area. Lowland sagebrush occurs in narrow swales and 

drainages of the Permit Area. Transect length (from start and stop point) would 

be 0.5 miles. Transects would not be linear but would meander through the 

habitat area. Meandering transects would start and end at the same points each 

year. Data would be recorded on standard data forms using the recommended 

data recording methods (Ulmschneider, 2004). Annual transect tracts would be 

recorded and presented on a map in the Annual Wildlife Monitoring Report. 

4.9.2.8 Lagomorphs 

Prey abundance would also be monitored. Desert cottontail and white-tailed 

jackrabbit populations would be evaluated using spotlight surveys through native 

habitat in the Permit Area. Surveys would be completed at night as close to the 

full moon as possible. One survey would be completed in June and another 

survey would be completed in August of each year. Transects would be 

established along approximately 1.5 miles of road within the Permit Area. Once 

reclaimed/restored areas are established, transects would be established in these 

areas. All transect locations would be presented on a map in the Annual Wildlife 

Monitoring Report. 

4.9.3 Impact Significance Criteria 

Habitat loss or alteration, incremental habitat fragmentation, displacement of, and 

stresses on, wildlife, and direct and/or indirect mortalities were considered in 

order to assess the significance of impacts on wildlife. The availability of, and 

proximity to, the same or similar habitat, as well as the size of the population 

were also used to evaluate the significance of impacts on wildlife. 

The Rawlins RMP Management Goals for wildlife focus on maintaining a 

functioning habitat to support and sustain native populations. The significance 

criteria used to address wildlife examine both the habitat availability and a healthy 

population size, which address the management goals of the Rawlins RMP. 

4.9.4 Wildlife Impacts from the Proposed Action 

A detailed discussion of the potential impacts to wildlife is provided in the 

following sections for each phase of the Project (Section 4.9.5 – Construction, 

Section 4.9.6 – Operation, and Section 4.9.7 – Reclamation). Because the 

majority of the wildlife species in the northeast portion of the Basin rely on 

sagebrush habitats for survival, they would generally be impacted in similar ways. 

Therefore, unless a unique impact to a particular species is anticipated, the effects 

of the Project on all wildlife are assessed as a whole. Wildlife species which 

could be uniquely impacted are discussed in detail in separate subsections, 

including: big game; Greater sage-grouse; raptors; waterfowl and shorebirds; 

migratory birds of high federal interest; threatened and endangered species; and 
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reptiles and amphibians. The impacts from the No Action Alternative and the 

Other Action Alternatives are evaluated in Section 4.9.8. Agency-required 

protective measures and monitoring associated with the Proposed Action are 

discussed in Sections 4.9.1 and 4.9.2, respectively. 

During the life of the Project, a total of approximately 345 acres of wildlife 

habitat would be disturbed, which is approximately eight percent of the 4,254-

acre Permit Area. As outlined in Section 4.8.4, the disturbance is progressive. 

The two major vegetation/habitat types disturbed are the Lowland and Upland Big 

Sagebrush Shrublands. Of the 330 acres disturbed, approximately 85 percent 

would be in the Upland Big Sagebrush Shrubland and approximately 15 percent 

would be in the Lowland Big Sagebrush Shrubland (Table 4.5-1). 

4.9.5 Construction 

The Construction phase includes both the construction of the Plant and other lifeof-mine facilities (Initial Construction) and the progressive construction of mine 

units during the Project (Mine Unit Development). The seven-month Initial 

Construction includes construction/upgrading of access roads/utility corridors, the 

Plant, the Storage Ponds, and the UIC Class I wells. Mine Unit Development 

includes exploration drilling, installation of monitoring wells, installation of the 

production and injection wells, and construction of the associated surface 

facilities. As construction of facilities is completed, surrounding areas would be 

reclaimed, in order to minimize long-term disturbances. During Construction, 

potential impacts to wildlife include habitat disturbance/loss, stress due to 

increased noise from traffic and construction activities, and direct mortality from 

increased traffic and construction activities. 

4.9.5.1 General Impacts on Wildlife 

During Initial Construction, approximately 95 acres (rounded to the nearest 5 

acres) would be disturbed (two percent of the total Permit Area). Of the acres 

disturbed, approximately 80 percent corresponds to disturbance of the Upland Big 

Sagebrush Shrubland and approximately 20 percent correspond to disturbance of 

the Lowland Big Sagebrush Shrubland (Table 4.5-1). These 95 acres of disturbed 

land represent a long-term direct impact to a small percentage of the available 

wildlife habitat. During Initial Construction and throughout the life of the Project, 

approximately ten acres around the Plant would be restricted from cattle and wild 

horses, but not wildlife, and approximately 2 acres around the Storage Ponds 

would be fenced to restrict all wildlife (Section 2.1.2.6). Since only a small 

percent of the total Permit Area would be disturbed, wildlife is expected to 

disperse from the Permit Area ahead of sequential Construction and mining. 

During Mine Unit Development, the habitat disturbance would be similar to that 

during Initial Construction, but the facilities being constructed would be smaller, 
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e.g., header houses, and the facilities would be in place for the life of the mine 

unit but not the life of the Project. The total area of habitat disturbance during 

Mine Unit Development, which would consist primarily of vegetation crushing in 

the pattern areas, is on the order of 240 acres. Approximately 85 percent of this 

disturbance is in the Upland Big Sagebrush Shrubland, with the remainder, about 

15 percent, in the Lowland Big Sagebrush Shrubland. Approximately 50 acres of 

disturbance would occur for the first mine unit, and 95 acres for the next two mine 

units (Section 4.8). The pattern areas within these mine units would be fenced to 

restrict cattle and wild horses, but not wildlife, from entering (Figure 2.1-5 and 

Section 2.1.2.6). During drilling, mud pits would be fenced if they are located 

outside of the fenced portion of the mine units. Inside the fenced portion of the 

mine units, mud pits would not be fenced, in part due to the limited time the pits 

are open and the level of activity around the pits while they are open. Temporary 

mud pits have not been the cause of significant wildlife mortality at other ISR 

operations. If conditions are found to differ from those at other ISR operations, 

more protective measures, such as temporary fencing, would be evaluated. The 

ISR process is iterative; new mine units are brought into production as older mine 

units are reclaimed. Therefore, not all disturbance would occur at once and the 

disturbance would be clustered.. In addition, as discussed in Section 2.1.5.1, 

disturbed areas would be reseeded as soon as possible after Construction and 

maintained through Operation to help minimize the duration of the disturbance. 

Species displaced during Construction would relocate to adjacent, undisturbed 

areas and likely return to their previously occupied habitats after Construction 

ends and suitable habitats are reestablished. Small mammals and songbirds 

dependent on shrubs for food, nesting, and cover would be impacted most in areas 

where vegetation clearing is needed for Construction. Birds are mobile and 

would likely disperse into adjacent areas with an abundance of similar habitat. 

The Lowland Big Sagebrush Shrubland habitat has the highest diversity and 

density of nesting birds and small mammals in the Permit Area (LCI, 2010); less 

than one percent of this habitat type in the Permit Area is to be disturbed during 

Construction. In general, because only a small percentage of the total Permit 

Area would be disturbed, wildlife species are expected to disperse as Construction 

activities approach, minimizing the occurrence of direct mortality. However, 

direct mortality of smaller, less mobile species, such as passerine birds, 

amphibians, reptiles, and small mammals, could occur due to vehicle traffic or 

equipment use. Direct mortality is not expected to have a population-level effect. 

Increased noise from Construction equipment could cause wildlife to relocate; 

however, equipment noise is expected to be indistinguishable from wind noise at 

the Permit Area boundary (Section 3.11). Therefore, noise from Construction 

activities would not affect wildlife receptors outside of the Permit Area and is not 

expected to impact receptors in many parts of the Permit Area that are further 

from the Construction activities. 
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During the Construction phase, increased heavy equipment would be transported 

to the Permit Area. Increased on-site traffic in the Permit Area could impact 

wildlife due to an increase in noise and an increased chance of direct mortality 

due to vehicle collisions. However, the volume of traffic associated with the 

Project is expected to be relatively small compared to the current traffic on nearby 

off-site roads. Due to the comparatively small workforce associated with the 

Project; and the restricted time of work hours, impacts to wildlife from increased 

traffic on-site and off-site would be negligible. 

4.9.5.2 Big Game 

The Permit Area provides Winter/Yearlong Pronghorn Range and seasonal range 

for elk and mule deer. Elk and mule deer have been spotted only rarely in the 

Permit Area; thus, impacts to these species are expected to be minimal. 

Impacts to pronghorn may include loss and modification of habitat, increased 

mortality from increased traffic on local and regional roads, increased 

disturbances due to human presence, and increased poaching and/or harvest from 

improved access on newly constructed roads. At most, about eight percent of 

pronghorn habitat (Lowland and Upland Big Sagebrush Shrublands) in the Permit 

area would be disturbed during the Construction phase. However much of this 

disturbance would be short-term as the individual mine unit areas are reclaimed. 

Pronghorn have been shown to become habituated to increased traffic volumes 

and heavy equipment if the traffic and equipment move in a predictable way 

(Reeve, 1984). Construction activities and unpredictable traffic flows; however, 

may cause pronghorn to disperse from the area. Pronghorn displacement of up to 

0.6 miles has been observed from construction activities (Easterly et al., 1991). 

There is, however, adequate Winter/Yearlong Pronghorn Range habitat 

surrounding the Permit Area to accommodate this displacement and pronghorn 

may possibly return to the Permit Area once Construction activities have 

concluded. Impacts to pronghorn are expected to be minimal because the species 

is highly mobile and impacts are not expected to threaten the continued existence 

of the species’ population in the Permit Area and surrounding habitat. 

Section 4.6.1.1.1.2 of the NRC SEIS discusses the Project impacts to wildlife. 

Since no crucial habitats for big game animals are affected by the construction 

and big game animals are mobile and can move to areas away from the Project, 

impacts on big game animals are expected to be minimal (NRC, 2011a). 

4.9.5.3 Greater Sage-Grouse 

Impacts to Greater sage-grouse during Construction would include loss and/or 

modification of habitat from facility construction, fencing and increased 

disturbances due to human presence. The Greater sage-grouse leks found in the 

study area (Section 3.8.3.2) are located in the Upland Big Sagebrush Shrubland 

community in areas with cushion plants, blowouts and bare ground. Less than 10 
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percent of this habitat in the Permit Area would be disturbed during Construction. 

Potential impacts from the Project are discussed below. 

The NRC SEIS, Section 4.6.1.1.1.2 discusses wildlife impacts from the project, 

including impacts to Greater sage-grouse. Habitat could be destroyed and human 

activity could disrupt normal behavior of the bird. The NRC suggests that due to 

the protected nature of this bird, the effects from construction could have a larger 

impact, but with protective measures, could be mitigated (NRC, 2011a). 

The orientation of the Project facilities and existing Greater sage-grouse leks are 

shown on Figure 4.9-2. The Plant and the majority of the mine units are outside 

the two-mile buffers for the closest active and occupied leks, which are the Green 

Ridge Lek to the east and the Discover and Discover South Lek to the west. 

(Although the two-mile buffers are no longer applicable in Greater sage-grouse 

Core Areas, the buffers were recognized when baseline monitoring began in 2006 

(Section 3.8.3.2).) The necessary support facilities were sited, in part, based on 

distance from existing occupied Greater sage-grouse leks. In particular, the Plant 

was sited between the two-mile buffers for the closest active and occupied leks. 

The closest lek to the permit area (Crooked Well Lek) is considered Occupied - 

Inactive based on data from the last several years (Section 3.8.3.2 and Attachment 

D9-4 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). As discussed in section 

4.9.1.10, the Proposed Action would include adherence to the Wyoming Greater 

sage-grouse Implementation Team (SGIT) stipulations (Mead, 2011 and 

Wyoming Interagency, 2011). Potential impacts to Greater sage-grouse were 

assessed in accordance with these stipulations and are discussed in detail below in 

order of Surface Disturbance, Surface Occupancy, Seasonal Use, Transportation, 

Noise, Overhead Lines, Vegetation Removal and Sagebrush Treatment, and 

Specific Stipulations. 

Assessment of Impacts on Greater Sage-Grouse using SGIT Stipulations 

Surface Disturbance 

As advised by WGFD, LCI completed the Project Impact Analysis Area (PIAA) 

process (now known as the Density and Disturbance Calculation Tool [DDCT]) 

outlined by the SGIT stipulations (Mead, 2011 and Wyoming Interagency, 2011) 

in order to evaluate potential effects of the Project on Greater sage-grouse. 

Results of the PIAA/DDCT process and WGFD review are documented in 

Appendix B. The analysis was sent to WGFD for review and they commented 

that they approved of the way the analysis was carried out and the results 

indicated that the surface disturbance resulting from the Project was in line with 

the SGIT stipulations. In accordance with the PIAA defined methodology, a 

PIAA boundary was determined (total size 147,060 acres). A total of 1,341 acres 

(including both proposed and existing disturbance) was determined to be the 

Maximum Disturbance based on the Project’s PIAA disturbance calculations, 

which includes the 330 acres of surface disturbance anticipated for the Initial 
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Construction and development of the HJ Horizon. Therefore, the Maximum 

Disturbance would equate to 0.90 percent of the defined PIAA, which is less than 

the SGIT maximum disturbance stipulation of five percent. 

Habitat Assessment is critical to determining Maximum Disturbance. Habitat 

Assessment involves the collection of baseline Greater sage-grouse population 

data. To complete the Habitat Assessment, LCI initiated a detailed Greater sagegrouse monitoring program for the Project. During 2010, Greater sage-grouse 

telemetry was started along with other components of the Habitat Assessment. 

Sections 3.8.3.2 and 4.9.1.1 describe the Greater sage-grouse monitoring program 

that commenced in 2010 and would continue during the Project. The initial 

monitoring results are summarized in the Project’s 2010 Annual Wildlife 

Monitoring Report (LWR Consultants, Inc. and Wyoming Wildlife Consultants, 

Inc., 2011). This monitoring is also being completed as part of the 

Monitoring/Adaptive Response component of the SGIT General Stipulations 

(Stipulation No. 9). 

 
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Figure 4.9-2 Greater sage-grouse Leks and Facility Locations 

 
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Surface Occupancy 

According to the SGIT stipulations (Mead, 2011 and Wyoming Interagency, 

2011), there should be no surface occupancy within 0.6 miles of the perimeter of 

occupied Greater sage-grouse leks. One active lek (Discover) and one OccupiedInactive lek (Discover 2) to the west of the Permit Area are within 0.6 miles of the 

West Access Road. The Discover South Lek is occupied, active, and just outside 

of the 0.6 mile buffer of the West Access Road. This road is currently a two-track 

road, and would be upgraded for Project use. Two active leks (Green Ridge and 

Sooner) to the east of the Permit Area boundary are within 0.6 miles of Sooner 

Road. Sooner Road is already an established road and no new surface occupancy 

would be associated with this road. The Green Ridge Lek is just outside the 0.6-

mile buffer of the East Access Road. The Crooked Well Lek, which intersects the 

Permit Area boundary, is currently classified as Occupied-Inactive (Section 

3.8.3.2). Greater sage-grouse have not been observed at this lek for many years. 

As seen in Figure 4.9-2, this lek is within 0.6 miles of the East Access Road 

(existing currently as a two-track road). Seasonal restrictions (described in the 

section below) would be adhered to if this road is upgraded. 

As discussed above, three occupied leks, two Occupied-Inactive (Discover 2 Lek 

and Crooked Well Lek) and one occupied, active lek (Discover) are within 0.6 

miles of the access roads, which would be upgraded. This surface occupancy 

could impact the status of Greater sage-grouse occupation of these leks. This is 

contrary to the stipulations set forth in the SGIT; however, the executive order 

does allow for exceptions to be considered on a case-by-case basis. Both BLM 

and WGFD staff attended a field site visit to the Permit Area. The three lek sites 

were visited and it was confirmed from being on site that the natural topography 

blocked the pre-existing two-track road from view of the leks. This visit 

confirmed the finding of the view shed analysis conducted by the proponents 

(Appendix C). WGFD reviewed the potential impacts to Greater sage-grouse 

associated with upgrading the existing two-track road and determined that 

upgrading the existing two-track road to provide access to the Permit Area would 

have less impact to the Greater sage-grouse than creating a new road outside the 

0.6-mile lek buffer (WDEQ, 2011a). (Alternate routes considered for the East 

and West Access Roads are discussed in Section 2.2.3.8.) 

Seasonal Use 

In accordance with the SGIT stipulations (Mead, 2011 and Wyoming Interagency, 

2011), Project activity, including initial exploration and construction, would take 

place only between July 1 and March 14 in areas outside of the 0.6-mile perimeter 

of a lek in Core Areas where breeding, nesting, and early brood-rearing habitat is 

present. Production and maintenance activity (Project operation) would be 

exempted from this timing restriction. In accordance with the Rawlins Field 

Office RMP (BLM, 2008c), surface disturbing and disruptive activities would 
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occur only between July 16 and February 28 in Core Area where breeding, 

nesting, and early brood rearing habitat is present. 

Transportation 

According to the SGIT stipulations (Mead, 2011 and Wyoming Interagency, 

2011), main roads used to transport production and/or waste products should be 

located greater than 1.9 miles from the perimeter of an occupied Greater sagegrouse lek. Other roads used for access and maintenance should be greater than 

0.6 miles from the perimeter of an occupied Greater sage-grouse lek. As 

discussed in the surface occupancy section above, Sooner Road is a preexisting, 

established road, as is Wamsutter-Crooks Gap Road. The East and West Access 

roads are existing two-track roads, which would be upgraded. Any scheduled 

improvements to these roads would comply with seasonal restriction guidance 

provided by the SGIT. Wamsutter-Crooks Gap Road and the West Access Road 

would be used to transport production and waste. Three occupied leks, one 

Occupied-Inactive (Discover 2 Lek) and two occupied, active leks (Discover Lek 

and Discover South Lek) are within 1.9 miles of these roads. 

To assess the potential impact of the road use, topographical visual assessments 

and analysis of opportunity costs of habitat fragmentation due to implementation 

of new access roads were performed. WGFD reviewed the potential impacts to 

Greater sage-grouse and determined that this option would have less impact to the 

Greater sage-grouse than creating new roads outside the 1.9-mile lek buffer 

(WDEQ, 2011a). (Alternate routes considered for the East and West Access 

Roads are discussed in Section 2.2.3.8.) Furthermore, the estimate increased 

production transport of one 18-wheeler truck per day was not expected to have 

significant impacts. Impacts from roads within 0.6 miles of leks are discussed in 

the surface occupancy section above. Increases in traffic would occur primarily 

during scheduled working hours, 7 AM to 5 PM, which overlap by one hour with 

the primary hours of concern for breeding Greater sage-grouse (6 PM to 8 AM) 

(Attachment OP-6 of the WDEQ-LQD Permit to Mine [LCI, 2011b]). 

Noise 

Noise caused by traffic and construction-related activity also may pose an adverse 

impact to Greater sage-grouse. Anthropogenic noise can reduce lek attendance 

and cause animal displacement. According to the SGIT stipulations (Mead, 2011 

and Wyoming Interagency, 2011), noise should be limited to 10 dBA above 

ambient noise measured at the perimeter of a lek from 6 PM to 8 AM during 

initiation of breeding (March 1 to May 15). The distance from occupied leks to 

areas of construction or traffic is at least 0.25 miles (1,320 feet), with the 

exception of Sooner Lek, which is approximately 300 feet from the existing 

Sooner Road. As discussed in Section 4.12, noise from heavy construction 

equipment would be indistinguishable from the ambient wind noise at a distance 
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of 1,000 feet. Therefore, the adverse impacts of noise on Greater sage-grouse at 

most leks are expected to be negligible. 

Sooner Road would not be expected to undergo any additional construction or 

improvements; therefore any increase in noise in the vicinity of Sooner Lek would 

be a result of increased traffic use. It is expected that increases in traffic on 

Sooner Road would be primarily due to commuter traffic rather than 

transportation of heavy construction equipment, which would primarily use the 

Wamsutter-Crooks Gap Road. Therefore, the impacts to Greater sage-grouse 

from traffic noise were assessed using an approximate commuter traffic noise 

level. A summary of noise effects on wildlife populations (Federal Highway 

Administration, 2004) includes reference to measured average traffic noise levels 

at 50 feet (15 meters) of 54 to 62 dBA for passenger cars and 58 to 70 dBA for 

heavy trucks. Using the highest value of 70 dBA for the starting source, a 

calculation from Golden et al. (1979), and a distance of 300 feet., noise from 

heavy trucks would not exceed background noise levels (58 dBA at 200 feet). 

Furthermore, the bulk of increased traffic would not occur in the time frame of 

most concern for Greater sage-grouse (6 PM to 8 AM). 

Traffic on unpaved roads also creates dust and may reduce the palatability of 

sagebrush plants both in and out of the Permit Area boundaries. The increased 

traffic adjacent to the Sooner Lek could result in lower lek attendance if dust 

emissions were high. Dust emissions would be less of a problem, however, 

during the winter (due to increased precipitation/snow cover). 

Overhead Lines 

According to the SGIT stipulations (Mead, 2011 and Wyoming Interagency, 

2011), new power lines should be buried when possible. New overhead lines 

should be located at least 0.6 miles from the perimeter of occupied Greater sagegrouse leks and should be raptor-proofed. As shown in Figure 4.9-2, the power 

line for the Project would connect with the existing transmission line, which runs 

along the western boundary of the Permit Area. The new powerline would be 

located more than 0.6 miles from the nearest leks. Appropriate anti-perching and 

anti-roosting devices would be placed on power poles and cross-arms. Tertiary 

transmission lines within the Permit Area would be buried. In cases where 

transmission line burial is not an option, overhead lines would be constructed to 

current standards using publications such as those from the Avian Power Line 

Interaction Committee (APLIC, 2006). This would include cross-arm and 

transformer design. 

Vegetation Removal and Sagebrush Treatment 

In accordance with the SGIT stipulations (Mead, 2011 and Wyoming Interagency, 

2011), vegetation removal would be minimized and all topsoil and vegetation 

removal would occur between July 1 and March 14 in areas within 4.0 miles of an 
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occupied lek. In accordance with the Rawlins Field Office RMP (BLM, 2008c) 

disturbance restrictions, no vegetation removal would occur within 0.25 miles of 

occupied Greater sage-grouse leks and would occur only between July 16 and 

February 28 in Core Area where breeding, nesting, and early brood rearing habitat 

is present. Furthermore, all requirements regarding the treatment of sagebrush 

would be followed. 

Specific Stipulations 

Specific stipulations relevant to the Project are: 

x For development drilling or ore body delineation drilled on tight centers, 

(approximately 100 feet by 100 feet), the area of disturbance would be 

delineated by the external limits of the development area. Assuming a 

widely-spaced disturbance pattern, the actual footprint would be 

considered the area of disturbance. 

x The number of active mining development areas (e.g., operating 

equipment and significant human activity) is not to exceed an average of 

one site per square mile (640 acres) within the PIAA/DDCT. Monitoring 

results would be reported annually in the Annual Wildlife Monitoring 

Report submitted to the BLM, NRC, WDEQ, and WGFD. Predisturbance surveys would be conducted as required by the appropriate 

regulatory agency. 

The first two conditions were adequately addressed in the PIAA/DDCT 

assessment performed (Appendix B) and, as mentioned in Section 4.9.2, annual 

monitoring and reporting would continue. 

Efforts have been made to meet all stipulations designed for the protection of 

Greater sage-grouse. In the cases of the conflicting aspects (no surface 

disturbance within 0.6 miles of occupied leks and no main roads used to transport 

production and/or waste products located within 1.9 miles of an occupied Greater 

sage-grouse lek), consideration on the part of WGFD supported exemption from 

these stipulations in the specific case of the Project, as the current road layout is 

anticipated to create less disturbance than if new roads meeting these stipulations 

were required. Therefore, though these specific aspects of the Project may impact 

Greater sage-grouse leks near the Permit Area, the currently proposed approach is 

considered to cause the least impact. Furthermore, annual monitoring and 

reporting would occur in order to adequately track the presence and productivity 

of Greater sage-grouse in the Permit Area. 

4.9.5.4 Raptors 

Impacts to raptors during Construction could include loss and/or modification of 

nesting and foraging habitat, nest abandonment and decreased reproductive 
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success due to human presence and Construction activities, direct mortality from 

collisions with infrastructure or vehicles, and reduction in prey populations. 

Several species of raptors have been observed in the Permit Area including: 

Swainson’s hawk, red-tailed hawk, northern harrier, golden eagle, kestrel, prairie 

falcon, turkey vulture, and ferruginous hawk. The bald eagle occurs only as a 

sporadic migrant and only forages on-site occasionally. The nearest known bald 

eagle nest to the Permit Area is more than five miles away from the Permit Area. 

The ferruginous hawk is the only raptor that is known to nest within the Permit 

Area; there are currently no active nests within the Permit Area (Section 3.8.3.3). 

Ferruginous hawks have been shown to be sensitive to human disturbance, 

especially during periods of courtship, nest building, incubation, and brood 

rearing (Collins and Reynolds, 2005). Nest abandonment and loss of eggs or 

fledglings could occur with human disturbance during the early nesting period. 

These adverse effects could occur with an increase in land-disturbing activities, 

such as road and building construction as well as increased traffic. As discussed 

in Section 4.9.1.9, it is recommended by the USFWS, Wyoming Ecological 

Services Field Office that, for the protection of raptors in general and ferruginous 

hawks particularly, there should be a spatial buffer of one mile around any nest, in 

which no temporary or permanent surface occupancy should occur. Furthermore, 

a seasonal activities buffer is recommended from March 15 to July 31 for 

ferruginous hawks. Additionally, according to the Rawlins Field Office RMP 

(BLM, 2008c), no surface occupancy should occur within 1,200 feet of active 

ferruginous hawks nests, and surface disturbance or disruptive activities are 

prohibited within one mile of ferruginous hawk nests from March 1 through 

July 31. 

Based on 2010 nesting raptor surveys, only one active raptor nest 

(AFH25921004) was found within the one-mile buffer zone, and three active 

nests were just outside the one-mile buffer. Nest AFH25921004 is occupied by a 

pair of ferruginous hawks annually. Two of the active ferruginous hawk nests are 

on artificial nest platforms, and one newly inhabited nest was found on a 

transmission line pole/nest platform adjacent to the existing transmission line 

(FH24930201). Another dilapidated, inactive nest (FH25921601) was noted to be 

within the Permit Area; this nest has not been active within the last four years, and 

is nearly completely gone. An additional active ferruginous hawk nest was found 

during 2011 BLM field surveys. This nest is located on the western border of the 

Permit Area. Figure 4.9-3 shows the status of the nests sited in 2010 in the 

Permit Area and in or near the one-mile buffer zone. The nest sited by the BLM 

in 2011 is also shown. 

As is shown in Figure 4.9-3, the one-mile buffer around nest AFH25921004 only 

intersects the Permit Area boundary at the northeast corner. No construction 

activity is expected to occur in this area. The nest found by the BLM in 2011 is 

located in the path of an existing transmission line and two-track road. A UIC 

Class I Well located about 2,010 feet southeast of this nest was installed as a test 
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well in 2010. A pipeline from this well is planned to be constructed along the 

existing road. This surface disturbance would be in conflict with the 1,200-foot 

restriction for active ferruginous hawk nests. However, the location of the 

pipeline was chosen in order to minimize disturbance in previously undisturbed 

areas. The seasonal activity restriction would be met for the construction of the 

pipeline. A new transmission line would be constructed that connects to the preexisting powerline running along the western boundary of the Permit Area; 

however, this is not near any active nests (Figure 4.9-3). Overhead transmission 

lines could impact raptors by encouraging perching and nesting on these lines. As 

discussed in section 4.9.1, appropriate anti-perching and anti-roosting devices 

would be placed on power poles and cross-arms to discourage roosting by raptors. 

Tertiary transmission lines would be buried in order to minimize risks to raptors 

and large birds. In cases where transmission line burial is not an option, overhead 

lines would be constructed to current standards using publications such as those 

from the APLIC (2006). This would include cross-arm and transformer design. 

This design would minimize potential mortality due to electrocution. 

As discussed above, only approximately two percent of the Permit Area would be 

disturbed during Construction. Therefore, raptor prey populations are not 

anticipated to be affected due to the low percentage of habitat disturbance in the 

Permit Area and the contiguous, suitable prey habitat outside of the Permit Area. 

As of the time of publication, the NRC SEIS reported that there are no active 

nests in the Permit area, and as a result, impacts to raptors are expected to be 

minimal (NRC, 2011a). 

4.9.5.5 Waterfowl and Shorebirds 

Just two waterfowl species (mallard, Canada goose) have been observed during 

bird and wildlife surveys. Waterfowl and shorebird use of the Permit Area is very 

limited. Wetlands, ponds, riparian zones and other potential waterfowl and 

waterbird habitat are almost nonexistent. No significant impacts are expected for 

these birds during the Construction phase. 

The NRC SEIS (Section 4.6.1.1.1.2) states that due to the lack of surface water in 

the region, the habitat is not suitable for important functions of the few waterfowl 

and shorebird species found in the area. Any impact would be insignificant 

(NRC, 2011a). 

4.9.5.6 Migratory Birds of High Federal Interest 

Level I MBHFI species documented in the Permit Area were the ferruginous 

hawk, Greater sage-grouse, Brewer’s sparrow, and sage sparrow. The mountain 

plover and burrowing owl have been noted in adjacent areas. Level II species 

documented in the Permit Area include the sage thrasher, loggerhead shrike, 

vesper sparrow, and lark sparrow (Section 3.8.3.6). 
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Anticipated impacts to the ferruginous hawk were previously discussed in this 

section, as were Greater sage-grouse impacts. Potential impacts to other MBHFI 

species include loss of habitat, displacement due to human activities, and 

mortality due to vehicle collisions. The breeding Brewer’s sparrow and sage 

sparrow were found throughout the Big Sagebrush Shrubland habitats of the 

Permit Area. Breeding sage thrasher, loggerhead shrike, vesper sparrow, and lark 

sparrow were also located within the Permit Area. Lowland Big Sagebrush 

Shrubland vegetation provided the greatest species diversity for MBHFI species 

use. Only a small portion of this habitat would be disturbed (less than one percent 

of the Permit Area during Construction), and where possible, Project activities 

would be located outside of this habitat type. Therefore, population level effects 

due to habitat loss for MBHFI species are not expected. 

Good potential mountain plover nesting habitat is not present in the Permit Area 

and no mountain plover have been observed on-site during extensive field studies. 

Therefore, it is unlikely that mountain plovers nest within the Permit Area. 

Section 4.6.1.1.1.2 of the NRC SEIS discusses the impacts to migratory birds, 

both direct and indirect. Direct impacts include vehicle collisions and increase 

human activity which may deter birds from the Permit Area. Indirect impacts 

include loss of habitat and displacement of birds. While these impacts may affect 

a few individuals, there would likely be no significant impact on entire species 

due to the small Project relative to the surrounding region (NRC, 2011a). 
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Figure 4.9-3 Raptor Nests (2010) and Facility Locations 

 
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4.9.5.7 Threatened and Endangered Species 

Federally Listed or Candidate Species 

No federally or state listed sensitive species, T&E species, or designated critical 

habitats occur in the Permit Area; therefore, no adverse impacts from 

Construction or any other phase of the Project are anticipated. The bald eagle 

(formerly listed as threatened, currently delisted) and black-footed ferret 

(endangered) are the only federally listed, previously listed, or candidate wildlife 

species that may potentially occur in the local vicinity (USFWS, 2008). The bald 

eagle may occur as a sporadic migrant, and may forage on-site occasionally. The 

nearest known bald eagle nest to the Permit Area is more than five miles away. 

The black-footed ferret is found in active prairie dog colonies. However, there 

are no active white-tailed prairie dog colonies in the Permit Area and the nearest 

active prairie dog colonies are one to two miles south and southwest of the Permit 

Area. Therefore, no impacts are anticipated to the black-footed ferret or the bald 

eagle. 

BLM Special Status Species 

Pygmy Rabbits 

One species of concern that may be uniquely impacted is the Pygmy rabbit, which 

has a preferred habitat limited to the Lowland Big Sagebrush Shrubland (Section 

3.8.3.8). Construction of infrastructure in Lowland Big Sagebrush Shrubland may 

result in a decrease in available and suitable habitat within the Permit Area. 

However, Project facilities and activities would be limited on Lowland Big 

Sagebrush Shrubland and avoided when possible (approximately one percent 

disturbance of this habitat type is expected to occur in the Permit Area during 

Construction). Limited direct mortality of Pygmy rabbits would be expected 

where Project activities disturb Lowland Big Sagebrush Shrubland habitats. The 

overall impact to Pygmy rabbit population in the area is expected to be minimal 

due to the relative small area of disturbance and the proposed protection measures 

discussed in Section 4.9.1. 

The NRC SEIS states in Section 4.6.1.1.1.5 that a few individual Pygmy rabbits, 

due to their burrowing habits in and near the construction site, could be lost 

during the construction phase. However, since there is a large area of untouched 

habitat, the impacts to the species as a whole would be small (NRC, 2011a). 

Wyoming Pocket Gophers 

Project Construction would result in long-term direct impacts to the Wyoming 

pocket gophers within the Permit Area. Wyoming pocket gopher active burrow 

complexes were located throughout the Lost Creek Permit Area (Section 3.8.3.8). 

Burrow complexes were located within very small open and grassy pockets within 
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the Upland Big Sagebrush Shrubland habitat. Project Construction would result 

in ground and vegetation disturbances, ground compaction, and fragmentation of 

sagebrush habitat. At most, eight percent of vegetation within the Permit Area 

would be disturbed during Construction. Wyoming pocket gopher burrow 

complexes can be expected to disappear in the disturbed areas for the life of the 

Project. Because of the very similar surrounding habitat conditions, Wyoming 

pocket gophers are expected to exist throughout the Permit Area and outside the 

Permit Area; thus, a population-level effect is not expected for the surrounding 

areas. It is also possible that Wyoming pocket gophers would recolonize the 

Permit Area after Reclamation. 

4.9.5.8 Reptiles and Amphibians 

Reptiles observed during general surveys included the greater short-horned lizard, 

prairie rattlesnake, and western terrestrial garter snake. No amphibians were 

observed within the Permit Area. No Great Basin spadefoot toad vocalizations 

were heard during auditory surveys completed for this species during the spring 

and early summer of 2010 and 2011. This species is not thought in be present in 

the Permit Area (Section 3.8.3.9). 

Potential impacts to reptiles and amphibians during construction would include 

habitat loss or alteration, incremental habitat fragmentation, and direct and/or 

indirect mortalities. Since only a small percent of the total Permit Area would be 

disturbed, herpetofauna are expected to disperse somewhat from the disturbed 

areas within the Permit Area as Construction activities approach, minimizing the 

occurrence of direct casualties. However, direct mortality could occur due to 

vehicle traffic or equipment use. These direct casualties are not expected to have 

a population-level effect. 

4.9.6 Operation 

The Operation phase includes ISR of uranium from the mine units and subsequent 

processing in the Plant. 

4.9.6.1 General Impacts on Wildlife 

The primary Operational impacts on wildlife are displacement/stress to wildlife 

from human activity and direct and/or indirect mortalities. There is also a 

potential for exposure to toxic chemicals and compounds during the Operation 

phase. Habitat alteration and incremental habitat fragmentation are expected to be 

minimal as no additional habitat disturbance would occur (Section 4.8). 

During Operation, spills around wellheads and leaks from pipelines could expose 

wildlife to toxic chemicals. LCI's leak detection systems and SPCC plan to 
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remove affected soils and capture release fluids would reduce impacts. If spills or 

leaks are handled using BMPs, impacts to wildlife would be minimal. 

Wildlife use of areas adjacent to ISR operations is anticipated to increase as 

animals become habituated to the activity. Because wildlife may be in proximity 

to Project buildings, roads, and mine units, some impacts to wildlife would be 

expected to occur from direct conflict with vehicular traffic and the presence of 

on-site personnel. Traffic volume during the Operation phase would likely be on 

the same order as for Construction; however, there would be less transport of 

heavy equipment and more transport of wastes and yellowcake slurry off-site 

(Section 4.3). These activities could reduce species use within the Permit Area, 

resulting in a concentration of species in the surrounding habitat. Increased 

predation and competition for forage may also occur. Noise from Operation 

activities is expected to be less than that generated from Construction phase 

activities (Section 4.12). Also, considering the size of the comparable 

surrounding habitat, these impacts would be minimal because they would affect 

only a few individuals and would not threaten the continued existence of any 

particular species in the Permit Area. 

4.9.6.2 Big Game 

During the Operation phase, there would be little, if any, new habitat disturbance. 

Increases in mortality from motor vehicle collisions are expected to remain at a 

minor level during Operation. Additional impacts during Operation include the 

potential for exposure to toxic chemicals during incidental spills, and avoidance 

of the Permit Area due to human activity. However, the potential for these 

impacts would be minimized due to protective efforts discussed in section 4.9.1. 

The NRC SEIS states in Section 4.6.1.2.2 that the Operation would have fewer 

impacts than the Construction on big game in the Permit area (NRC, 2011a). 

4.9.6.3 Greater Sage-Grouse 

Potential impacts to Greater sage-grouse during Operation could include 

increased disturbances due to human presence and Operation activities and direct 

mortality from fencing and the Storage Ponds. 

During the Operation phase, there would be little, if any, new habitat disturbance. 

Potential impacts to Greater sage-grouse during all phases of the Project from 

surface disturbance, seasonal timing, transportation, noise, and other disturbances 

were assessed in accordance with the SGIT stipulations (Mead, 2011 and 

Wyoming Interagency, 2011), and were previously discussed. 

Fences used to restrict cattle and wild horses from entering the mine unit pattern 

areas would not restrict Greater sage-grouse. Cattle may, however, be displaced 

to adjacent lands shared by Greater sage-grouse. Cattle graze on grasses and 
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forbs that provide crucial nesting and brooding habitat for the birds. An increased 

concentration of both Greater sage-grouse and cattle may cause adverse effects to 

habitat (Perry, 2010). However, considering few cattle would be displaced by the 

Project (Section 4.2.4.1) and the large amount of analogous habitat surrounding 

the Permit Area, the potential impact from shifts in grazing patterns is low. 

Fences installed around the pattern areas of the mine units (Section 2.1.2.6) could 

pose a direct adverse effect to Greater sage-grouse because collisions have been 

anecdotally reported to cause injury and mortality. After the WGFD conducted a 

study on this matter, it was found that the highest risk fences are those that: are 

constructed with steel t-posts; are constructed near leks; bisect winter 

concentration areas; and/or border riparian areas (Christiansen, 2009). The fences 

would not be within a quarter mile of the leks nor would they be adjacent to 

riparian areas. Wintering Greater sage-grouse prefer dense sagebrush stands that 

extend above snow cover and provide escape and thermal cover to the birds. 

Locations from 30 individual radio-equipped females were documented during the 

winter of 2010; however, no detailed on-the-ground surveys for winter Greater 

sage-grouse use have been completed in the Permit Area. Based on habitat 

conditions, the Lowland Big Sagebrush Shrubland habitat areas likely provide 

important Greater sage-grouse winter habitat (Naugle et al., 2006; WGFD, 2003). 

As discussed in Section 4.9.1.10, in order to mitigate Greater sage-grouse 

collisions with fences, fence markers would be installed on new fence lines to 

increase the visibility of the lines. New fences would also be monitored for 

evidence of Greater sage-grouse strikes. 

Fences may also be a hazard to Greater sage-grouse because they offer potential 

raptor perches, which may increase predation. As discussed in Section 4.9.1.2, 

anti-perch measures on fence lines would be taken to reduce excessive predation 

of Greater sage-grouse. Fences would be used around Storage Ponds (Section 

2.1.2.6). If Greater sage-grouse use the ponds as a regular water source there is an 

exposure potential. However, the amount of freeboard, and water depth 

maintained for the two ponds should make it difficult for Greater sage-grouse to 

drink from the ponds. Hazards associated with the quality of the Storage Ponds 

along with protection efforts are discussed in detail below in the section 

discussing waterfowl and shorebird impacts. The Storage Ponds would be 

designed to minimize access to all wildlife, including Greater sage-grouse. The 

Storage Ponds would be monitored daily for wildlife mortality. If evidence of 

mortality is present, additional measures may be taken to prevent access. 

The NRC SEIS states in Section 4.6.1.2.2 that the Operation phase could disrupt 

the reproductive stage of Greater sage-grouse nesting near the Project 

infrastructure. This could have some localized significant impacts to Greater 

sage-grouse, but would likely not affect the entire population in the region (NRC, 

2011a).
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4.9.6.4 Raptors 

During the Operation phase, there would be little, if any, new habitat disturbance. 

Noise associated with traffic and the potential for mortalities from collisions with 

vehicles or overhead lines would remain potential adverse effects. As discussed 

in Section 4.9.1, overhead transmission lines would have anti-perch devices. 

Header houses, fences, well heads and other operational infrastructure would also 

employ anti-perch technology to minimize damage to facilities and ensure the 

health and safety of the raptors. 

During Operation, routine maintenance of the UIC Class I well located southeast 

of the nest found by the BLM in 2011 would be necessary and would require 

minimal traffic on the existing two-track road. This disturbance would be in 

conflict with the 1,200-foot restriction for active ferruginous hawk nests and may 

have an impact on this nest. 

The NRC SEIS states in Section 4.6.1.2.2 that the Operation phase could disrupt 

the reproductive stage of raptors nesting near the Project infrastructure. This 

could have some significant impacts to raptors, but would likely not affect the 

entire population in the region (NRC, 2011a). 

4.9.6.5 Waterfowl and Shorebirds 

The only fluid-holding structures would be the Storage Ponds, which would be 

used during the Operation phase and are described in detail in Section OP 2.9.4 of 

the WDEQ-LQD Permit to Mine (LCI, 2011b). The Storage Ponds would be 

fenced to prevent access by wildlife on the ground and for safety reasons (Section 

2.1.2.6). Based on the anticipated poor quality of the water in the Storage Ponds 

(Table 4.9-2), fencing and deterrents would be used to prevent waterfowl from 

inhabiting the ponds and becoming exposed via ingestion. If local sagebrush 

endemic passerine bird species were to use the Storage Ponds as a regular water 

source, there would be an exposure potential. The amount of freeboard, and water 

depth maintained for the two Storage Ponds should make it difficult for land birds 

(such as Greater sage-grouse), passerine birds, and wading birds (such as herons) 

to drink from the Storage Ponds. An exception might be swallows, if present in 

the area, that drink water on the wing. Waterfowl are not expected to reside on 

the Storage Ponds for more than a few days. A study of waste water ponds in 

central Idaho noted that waterfowl resided from one to 25 days, with an average 

residence time at the ponds of six days (Halford et al., 1982). 

As described in detail in Section OP 2.9.4 of the WDEQ-LQD Permit to Mine 

(LCI, 2011a), the water quality of the Storage Ponds would be checked quarterly, 

to ensure unanticipated changes in the water quality are detected, and whenever a 

process change may result in a significant change in water quality. As noted in 

Section OP 5.2.3.1 of the WDEQ-LQD Permit to Mine (LCI, 2011b), the 

concentration of selenium would be less than or equal to 0.02 mg/L, the level at 
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which selenium concentrations can become detrimental to some wildlife. The 

location of the Storage Ponds adjacent to the Plant, and associated human activity 

(including daily checks of the Storage Ponds), is anticipated to reduce the 

attractiveness of the Storage Ponds to wildlife. Deterrents, such as flagging and 

predator silhouettes or decoys, would also be used. The growth of algae and 

plankton would be monitored, and if necessary, an herbicide approved for use in 

pond settings would be used to reduce or eliminate such growth, thereby reducing 

the potential for bioaccumulation of selenium. If the level of selenium in the 

Storage Ponds cannot be maintained at a level of less than or equal to 0.02 mg/L 

selenium, the Storage Ponds would be covered to prevent access by birds and/or 

the affected water would be drained. Safe limits for birds for other constituents 

were explored and discussed in detail in the WDEQ-LQD Permit to Mine (LCI, 

2011b). Briefly, Maximum Threshold Limits (MTLs) for poultry regarding 

aluminum, arsenic, fluoride, manganese, selenium, and vanadium are equal or 

greater than the anticipated maximum concentrations for these analytes in the 

Storage Ponds (Table 4.9-2). 

 
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Table 4.9-2 Estimated Water Quality of the Storage Ponds 

Analyte Estimated Range (mg/L) 

Major Constituents Low High 

Aluminum ND 0.2 

Ammonia as Nitrogen ND 4 

Bicarbonate as HCO3 1,200 2,500 

Calcium 50 300 

Carbonate as CO3 ND 25 

Chloride 200 1,000 

Magnesium 4 50 

pH 7 9 

Potassium 10 200 

Ra-226 (pCi/L) 200 1,500 

Silica 14 20 

Sodium 150 2,000 

Sulfate 50 500 

TDS 1,600 6,500 

Uranium as U3O8 1 15 

Trace Parameters Low High 

Arsenic 0.002 0.020 

Barium ND ND 

Boron ND ND 

Cadmium ND ND 

Chromium ND ND 

Copper ND ND 

Fluoride 0.2 0.5 

Lead ND ND 

Manganese 0.04 0.5 

Mercury ND ND 

Molybdenum ND ND 

Nickel ND ND 

Selenium 0.01 0.2 

Vanadium ND 0.01 

4.9.6.6 Migratory Birds of High Federal Interest 

As discussed before, the Lowland Big Sagebrush Shrubland vegetation was found 

to provide the greatest species diversity for MBHFI species use. During the 

Operation phase, there would be little, if any, new habitat disturbance. Migratory 

birds and other wildlife could be affected by exposure to constituents in Storage 

Ponds, but perimeter fencing and netting would limit impacts. Therefore, 

population level effects due to habitat loss or increased competition are not 

expected for MBHFI species. 
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The NRC SEIS discusses that migratory birds could be exposed to toxic chemical 

in the storage ponds. However, the protection measure put in place would limit 

their interaction with this water and result is minimal impacts (NRC, 2011a). 

4.9.6.7 Threatened and Endangered Species 

Federally Listed or Candidate Species 

No federally or state listed sensitive species, T&E species, or designated critical 

habitats occur within the Permit Area; therefore, no adverse impacts from 

Operation or any other phase of the Project are anticipated. 

The NRC SEIS also makes this comment that the lack of these species eliminates 

the potential impacts (NRC, 2011a). 

BLM Special Status Species 

Pygmy Rabbits 

During the Operation phase, there would be little, if any, new habitat disturbance. 

The overall impact to Pygmy rabbit populations in the area is expected to be 

minimal due to the limited number of individuals affected, the relatively small 

area of disturbance, and the proposed protection measures. 

Wyoming Pocket Gophers 

Impacts to Wyoming pocket gophers would be smaller during the Operation 

phase to those in the Construction phase. During the Operation phase, there 

would be little, if any, new habitat disturbance. Ongoing activities during the 

Operation phase would continue to make site conditions unfavorable for 

recolonization of Wyoming pocket gophers. However, undisturbed areas in the 

Permit Area and areas outside the Permit Area with similar habitat type may still 

support Wyoming pocket gophers; therefore, a population-level effect is not 

predicted. 

4.9.6.8 Reptiles and Amphibians 

During the Operation phase, there would be little, if any, new habitat disturbance. 

The overall impact to reptile and amphibian populations in the area is expected to 

be minimal due to the relatively small area of disturbance and the proposed 

protection measures described in Section 4.9.1. 
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4.9.7 Reclamation 

4.9.7.1 General Impacts on Wildlife 

Reclamation includes the progressive Mine Unit Reclamation and Final 

Reclamation stage. During Mine Unit Reclamation, additional disturbance would 

occur during some activities, e.g., when wells are abandoned and pipelines are 

removed from reseeded areas. However, this ‘re-disturbance’ of the same areas, 

e.g., a pipeline corridor, is not counted twice in the assessment of the acres 

disturbed. 

There should be no additional habitat acreage disturbance during Reclamation. 

Short-term land disturbance would occur during decommissioning of supporting 

facilities and roads, as soils are excavated, buried piping is recovered and 

removed, and structures are demolished and removed. Revegetation would 

restore habitat previously altered during Construction and Operation. After 

removal of structures such as the Plant and Storage Ponds, the surface would be 

regraded and topsoil replaced. Disturbed areas would be seeded with native 

vegetation once the buildings are removed. No loss of additional vegetative 

communities is expected beyond those previously disturbed during Construction 

and Operation. The removal of piping would impact vegetation that has 

reestablished itself, although this, too, would be temporary once the disturbed soil 

is reseeded. Wildlife habituated to the Operation would be temporarily displaced, 

but are expected to return after Reclamation is completed and vegetation and 

habitat are reestablished. As the areas are reseeded with the permanent seed mix, 

there could be changes in the proportion of various species, including an increase 

in weeds. This alteration of habitat could potentially affect habitat desirability. 

However, actions would be taken to mitigate weed invasion (Section 4.8.1). 

Overall, impacts would be considerably less for this phase than for Construction 

and Operation. 

Contamination of soils could result from leaks and spills during Reclamation. 

However, detection and response techniques, and eventual survey and treatment 

(if necessary) of all impacted soils and sediments, would limit the magnitude of 

overall impacts to terrestrial wildlife. 

Similar to construction activities, reclamation activities are expected to create 

added noise and traffic (in comparison with Operation) as buildings are taken 

down and hauled away. During this time, wildlife could come in conflict with 

heavy equipment, or may move elsewhere on the property to avoid higher-thannormal noise. However, these impacts would be short-term in nature. 
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4.9.7.2 Big Game 

No impacts are expected for mule deer and elk. No additional impacts are 

expected for pronghorn from Reclamation. Furthermore, detrimental impacts 

occurring in past phases would be further minimized as recovered land is 

vegetated to pre-construction conditions. The fences would be removed after ISR 

operations are complete and vegetation has become reestablished in accordance 

with permit requirements (Section RP 4.5.4 of the WDEQ-LQD Permit to Mine 

[LCI, 2011a]) unless otherwise approved and agreed upon with the landowner 

(BLM). Increases in mortality from motor vehicle collisions due to increases in 

traffic are expected to remain at a minor level during Reclamation. Additional 

impacts during Reclamation are the potential for exposure to toxic chemicals 

during incidental spills, and avoidance due to human activity. However, 

protection efforts discussed in Section 4.9.1 would minimize risks. 

The NRC SEIS states the impacts to big game species during the Reclamation 

phase would be similar to the impacts suggested in the Construction phase (NRC, 

2011a). 

4.9.7.3 Greater sage-grouse 

Short-term impacts to Greater sage-grouse from noise and disturbance during the 

influx in activity from the removal of infrastructure during Reclamation are 

possible. A potential indirect impact from Reclamation is the stripping of topsoil 

and vegetation, which could allow noxious weeds to seed before native grasses 

and sagebrush. Therefore, weed control is an important issue for Reclamation and 

protection of existing habitats for Greater sage-grouse. As discussed in Section 

4.8.1, BLM-approved weed prevention measures, such as prompt reseeding with 

native vegetation, cleaning of equipment, and minimizing soil disturbance, would 

be implemented. 

The NRC SEIS reports that Greater sage-grouse impacts during Reclamation 

phase could be significant in the short-term. After reseeding and restoring the 

land to a functioning ecosystem, the impacts would be significantly reduced 

(NRC, 2011a). 

4.9.7.4 Raptors 

No additional acres would be disturbed during reclamation for the removal and 

decommissioning of Project infrastructure beyond those impacted in Operation 

and Construction. If the BLM and other land owners were to agree to retain any 

upgraded roads associated with the Project after Reclamation, there may be 

potential long-term impacts to raptors from the road and associated traffic. 
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However, all other Project related facilities would be removed and the preexisting 

state of the landscape would be, at a minimum, restored and likely enhanced; 

therefore, adverse effects to raptors during the Reclamation phase are expected to 

be negligible. 

The NRC SEIS states the impacts to raptors during the Reclamation phase would 

be similar to the impacts identified for the Construction phase (NRC, 2011a). 

4.9.7.5 Waterfowl and Shorebirds 

No further impacts to this group are expected during Reclamation. 

4.9.7.6 Migratory Birds of High Federal Interest 

Impacts to MBHFI species are expected to be similar in the Reclamation phase as 

in the Construction phase. However, effects would be minimized as recovered 

land is vegetated to pre-construction conditions. 

4.9.7.7 Threatened and Endangered Species 

Federally Listed or Candidate Species 

No federally or state listed sensitive species, endangered or threatened species, or 

designated critical habitats occur within the Permit Area; therefore, no adverse 

impacts from Reclamation or any other phase of the Project are anticipated. 

The NRC SEIS also states that the lack of these species eliminates the potential 

impacts (NRC, 2011a). 

BLM Special Status Species 

Pygmy Rabbits 

Impacts to Pygmy rabbits during Reclamation would be short-term habitat 

disturbance, which would occur as structures are demolished and removed and the 

ground surface is recontoured. Upon completion of decommissioning, 

revegetation, and recontouring, habitat would be reestablished. 

Wyoming Pocket Gophers 

Impacts would be limited during Reclamation. Based on surrounding habitat 

conditions, and the fact that Wyoming pocket gophers were captured throughout 

the areas that would be disturbed during Construction and Operation, it is 

expected that Wyoming pocket gophers are present in appropriate habitats within 

the larger Permit Area, and also surrounding areas. Re-colonization from 
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surrounding, undisturbed areas may occur if habitat conditions following the 

Reclamation phase provide adequate soil and vegetation conditions. Loss of the 

Wyoming pocket gopher population within the disturbed area would not impact 

local populations and would not cause a trend towards Federal listing of the 

species. 

4.9.7.8 Reptiles and Amphibians 

Impacts to reptiles and amphibians are expected to be similar in the Reclamation 

phase as in the Construction phase. However, effects would be minimized as land 

is vegetated to pre-construction conditions. 

4.9.8 Wildlife Impacts from Other Alternatives 

4.9.8.1 No Action Alternative 

Under the No Action Alternative, there would be no ISR facility construction 

associated with the Project, and therefore no habitat disturbance associated with 

Construction, Operation, and Reclamation would occur. The area would continue 

to provide vegetation communities and wildlife habitat typical of the region. 

Land would continue to be used for rangeland and grazing leases would continue. 

Impacts from other existing activities, such as cattle grazing, mineral exploration, 

recreation and hunting would continue. 

4.9.8.2 Not Fencing the Pattern Areas 

There would be a slight reduction in the acres of vegetation and habitat 

disturbance if the fences around the patterns areas are not constructed. However, 

the protection measures in the pattern areas, specifically reseeding, would be 

adversely impacted as the new vegetation growth in the reseeded areas would be 

preferred by livestock and wild horses. Also, collisions of wildlife with fences 

and increased predation due to perching on fences would not occur. 

4.9.8.3 Drying Yellowcake On-site 

This alternative would have minimal additional impacts on habitat resources at 

the Permit Area, as the dryer would be within the Plant. Since a vacuum dryer 

would be installed, impacts to wildlife in the Permit Area from toxic emissions 

would not be expected. There would be an added potential for harmful leaks to 

occur; however, this potential would be mitigated through proper operational 

precautions and risk management. 
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4.10 Wild Horses 

4.10.1 Agency-Required Measures 

The management practices for wildlife (Section 4.9) would be beneficial to wild 

horses as well as wildlife and are established in conjunction with the BLM, 

WGFD and USFWS guidelines and regional recommendations (BLM, 2008b; 

WGFD 2008c; and WGFD 2009). In addition to the measures discussed in 

Section 4.9, the BLM would require installation of pitless cattle guards under the 

gates to the mine units. The purpose of these cattle guards is to deter wild horses 

from entering a mine unit should the gate to that mine unit be left open 

inadvertently. Alternately, an automatic closure would be put on the gate. 

The management practices would also help minimize impacts to plant 

communities and associated forage and habitat. Standard construction, erosion 

control, and other agency-required measures described in other sections would 

also help to minimize impacts to wild horses. 

4.10.2 Monitoring of Wild Horse Impacts 

An annual record of all wild horse mortality due to fence entanglements, vehicle 

collisions, and other factors would be completed to help minimize adverse 

impacts to wild horses. 

4.10.3 Impact Significance Criteria 

Habitat loss or alteration, incremental habitat fragmentation, displacement of, and 

stresses on, wild horses, and direct or indirect mortalities were considered in order 

to assess the significance of impacts on wild horses. The availability of adjacent 

habitat and the size of the horse population were also considered. 

These criteria are in accordance with the Rawlins RMP Management Goals, 

which aim to protect the health and viability of herds while retaining the freeroaming nature of wild horses. 

4.10.4 Impacts from the Proposed Action 

Wild horses rely on the same available habitats for survival as wildlife big game; 

as a result, direct habitat impacts would generally be similar to Project impacts to 

big game in the region (Section 4.9). 
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4.10.4.1 Construction 

The Construction phase includes the Initial Construction and progressive Mine 

Unit Development. Initial Construction would require about one year. Most of 

the disturbance during Initial Construction would be long-term, i.e., lasting for the 

duration of the Project, because it would include vegetation removal from the 

areas on which Project facilities would be built. During Mine Unit Development, 

the impacts would be similar to those during Initial Construction, but the facilities 

being constructed would be smaller, e.g., header houses, and the facilities would 

be in place for the life of the mine unit, but not the life of the Project. Section 

4.8.2.1 includes a more detailed discussion. 

During the Construction phase, potential impacts to wild horses include loss 

and/or modification of habitat, increased disturbances due to human presence, and 

direct mortality (from vehicle collisions, entanglement in new fences or cattle 

guards, or getting stuck in trenches). 

During Initial Construction, approximately 95 acres (rounded to closest 5 acres) 

would be disturbed (two percent of the total Permit Area). Approximately 80 

percent of this disturbance is in the Upland Big Sagebrush Shrubland, with the 

rest, about 20 percent, in the Lowland Big Sagebrush Shrubland (Table 4.5-1). 

These 95 acres of disturbed land represent a long-term direct impact of a small 

percentage of available habitat within any of the HMAs (Figure 3.9-1). Since 

only a small percent of the total Permit Area would be disturbed, wild horses are 

expected to disperse from the Permit Area as Construction activities approach. 

During Initial Construction, approximately ten acres within the Permit Area 

would be restricted from wild horses due to fencing around the Plant (Section 

2.1.2.6). 

During Mine Unit Development, the habitat disturbance would be similar to that 

during Initial Construction, but the facilities being constructed would be smaller, 

e.g., header houses, and the facilities would be in place for the life of the mine 

unit, but not the life of the Project. The total area of vegetation disturbance 

(primarily vegetation crushing in the pattern areas) during Mine Unit 

Development of all mine units is on the order of 240 acres. All but about 85 

percent of this disturbance is in the Upland Big Sagebrush Shrubland, with the 

rest, about 15 percent, in the Lowland Big Sagebrush Shrubland. Approximately 

50 acres of disturbance would occur for the first mine unit, and 95 acres for the 

next two mine units (Section 4.8). The pattern areas within these mine units 

would be fenced to restrict wild horses from entering (Figure 2.1-5 and Section 

2.1.2.6). The ISR process is iterative; new mine units are brought into production 

as older mine units are reclaimed. Therefore, not all of the disturbance would 

occur at once, and the disturbance is clustered, which would help minimize 

disruptions to wild horses. 
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Increased noise from Construction equipment could cause wild horses on-site to 

relocate; however, the equipment noise is expected to be indistinguishable from 

the wind noise at the Permit Area boundary nearest to the Construction activity 

(Section 3.11). Therefore, noise from Construction activities would not affect 

wild horses outside of the Permit Area and is not expected to impact horses in 

many parts of the Permit Area that are further from the Construction activities. 

Increased traffic in the Permit Area could impact wild horses due to an increase in 

noise and an increased chance of direct casualties due to vehicle collisions. 

During Construction, increased heavy equipment would be transported to the 

Permit Area. The volume of traffic associated with the Project is expected to be 

relatively small; and, due to the concentrated nature of the resource, the 

comparatively small workforce associated with the Project; and the restricted time 

of work hours, impacts to wild horses from increased traffic would be negligible. 

The increased traffic would create dust that may settle on vegetation, making it 

temporarily less palatable and creating a short-term reduction in forage available 

to the wild horses. 

Increased human presence due to Construction may affect wild horse use of areas 

adjacent to the Permit Area (e.g., the stock pond south of the East Access Road). 

Although these indirect impacts are possible, wild horses are transitory and would 

likely find nearby suitable habitat free from areas of human activity and 

disturbance. More detrimental impacts could occur if the disturbed area included 

a source of water for the wild horses, but, as discussed in Section 3.5, the Permit 

Area has no standing water for nearly the entire growing season, and no wetlands 

were identified. Forage losses due to Construction would be mitigated via staged 

reclamation of disturbed areas, providing grass and forb forage within a few years 

of habitat disturbance. Impacts to wild horses would be minimal because these 

species are highly mobile, the area of disturbance is relatively small compared to 

adjacent similar habitats, and on-site water sources are not present. Therefore, 

impacts are not expected to threaten the continued existence of the wild horse 

population in the Permit Area and surrounding habitat. 

Section 4.6 of the NRC SEIS summarizes the potential impacts to wildlife in the 

Permit Area and includes an analysis of wild horses. Since wild horses are 

mobile and only a small percentage of the land would be influenced by the 

Construction, Operation, and Reclamation associated with this Project, no 

significant impacts to the population are expected (NRC, 2011a). 

4.10.4.2 Operation 

The Operation phase of the Project includes the production from the mine units. 

During the Operation phase, there would be little, if any, new habitat disturbance. 

The primary impacts of Operation on wild horses are habitat alteration and 

incremental habitat fragmentation, displacement/stress from human activity, and 
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direct and/or indirect mortalities. There is also a potential for exposure to toxic 

chemicals and compounds during the Operation phase. 

Approximately 300 acres within the Permit Area would be fenced to keep out 

cattle and wild horses. While this fencing may affect the movement of horses, 

requiring them to travel around the fenced areas, the fencing is not expected to 

increase fragmentation of herds, due to the relatively small area fenced. 

Temporary mud pits would be fenced if they are located outside of the fenced 

portion of the mine units. Inside the fenced portion of the mine units, mud pits 

would not be fenced, in part due to the limited time the pits are open and the level 

of activity around the pits while they are open. Temporary mud pits (within the 

fenced pattern area or individually fenced if not within the pattern area) have not 

been the cause of significant mortality to big game at other ISR operations. (Most 

other ISR operations are in areas with more domestic than wild horses.) 

Therefore, the mud pits are not anticipated to impact wild horses. 

During Operation, spills around wellheads and leaks from pipelines could expose 

wild horses to toxic chemicals. LCI's leak detection systems and SPCC plan to 

remove affected soils and capture release fluids would eliminate or reduce such 

impacts. 

Similarly to the Construction phase, increased traffic creates dust that could land 

on the adjacent vegetation, reducing the quality of available forage in the shortterm, and creating a higher competition for the remaining plant resources. 

Wild horse use of areas adjacent to ISR operations is anticipated to increase as 

animals become habituated to mining activity. Because wild horses may be in 

proximity to Project buildings, roads, and mine units, some impacts to the horses, 

such as collisions with fences, would be expected to occur. 

Traffic volume during the Operation phase would likely be on the same order as 

for Construction; however, there would be less transport of heavy equipment and 

more transport of wastes and yellowcake slurry off-site (Section 4.3). These 

activities could reduce wild horse use within the Permit Area, resulting in a higher 

concentration of animals in the surrounding habitat. Noise from Operation 

activities is expected to be lower than that generated during Construction 

activities (Section 4.12). Also, considering the size of the comparable 

surrounding habitat, impacts would are expected to be minimal because only a 

few bands of wild horses would be affected in each HMA. Operational impacts 

are not expected to threaten the continued existence of the wild horse population 

in the Permit Area and surrounding habitats. 

Section 4.6 of the NRC SEIS summarizes the potential impacts to wildlife in the 

Permit area and includes an analysis of wild horses. Since wild horses are mobile 

and only a small percentage of the land would be influenced by the Construction, 
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Operation, and Reclamation associated with this Project, no significant impacts to 

the population are expected (NRC, 2011a). 

4.10.4.3 Reclamation 

There should be no additional habitat disturbance during Mine Unit or Final 

Reclamation. Short-term land disturbance would occur during decommissioning 

of supporting facilities and roads, as soils are excavated, buried piping is 

recovered and removed, and structures are demolished and removed. 

Revegetation and recontouring would restore habitat previously altered during 

Construction and Operation. Once the structures were removed, the area of the 

Plant and Storage Ponds would be regraded to pre-construction contours, and then 

topsoil would be reapplied and seeded with native vegetation. 

No loss of additional vegetative communities is expected beyond those previously 

disturbed during Construction and Operation. The removal of piping would 

impact vegetation that has reestablished itself, although this, too, would be 

temporary once the disturbed soil is reseeded. Wild horses would be temporarily 

displaced, but are expected to return after Reclamation is completed and 

vegetation and habitat are reestablished. As the areas are reseeded with the 

permanent seed mix, there could be changes in the proportion of various species, 

including an increase in weeds. The presence of weeds could potentially affect 

habitat desirability and forage availability. However, actions would be taken to 

mitigate weed invasion. Wild horses are mainly grazers, increased grazing 

intensity could occur on newly seeded areas. Fences would be removed after ISR 

operation is complete and vegetation has become reestablished in accordance with 

permit requirements (Section RP 4.5.4 of the WDEQ-LQD Permit to Mine [LCI, 

2011b]) unless otherwise approved and agreed upon with the landowners (BLM 

and the State of Wyoming). Overall, impacts from Reclamation would be 

considerably less than those associated with Construction and Operation. 

Soil contamination could result from leaks and spills during Reclamation, and 

wild horses could then be exposed to the contaminated soils. However, detection 

and response techniques, and survey and treatment (if necessary) of all impacted 

soils, would limit the magnitude of overall impacts to wild horses. 

The Reclamation activities are expected to create temporary increases in noise 

and traffic (in comparison with the Operation phase) as buildings are taken down 

and hauled away. During this time, wild horses could come in conflict with heavy 

equipment, or may move elsewhere on the property due to higher-than-normal 

noise. However, these impacts would be short-term in nature. 

Section 4.6 of the NRC SEIS summarizes the potential impacts to wildlife in the 

Permit area and includes an analysis of wild horses. Since wild horses are mobile 

and only a small percentage of the land would be influenced by the Construction, 

Operation, and Reclamation associated with this Project, no significant impacts to 

the wild horse population are expected (NRC, 2011a). 
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4.10.5 Wild Horse Impacts from Other Alternatives 

4.10.5.1 No Action Alternative 

Under the No Action Alternative, there would be no ISR facility construction 

associated with the Project, and therefore no habitat disturbance associated with 

Construction, Operation, and Reclamation would occur. The area would continue 

to provide vegetation communities and habitat typical of the region. Land would 

continue to be used for rangeland available to wild horses within the HMAs. 

Impacts from other existing activities, such as cattle grazing, mineral exploration, 

recreation and hunting would continue. 

4.10.5.2 Not Fencing the Pattern Areas 

There would be a slight reduction in the acres of vegetation and habitat 

disturbance if the fences around the patterns areas are not constructed. However, 

the protection measures in the pattern areas, specifically reseeding, would be 

adversely impacted as the new vegetation growth in the reseeded areas would be 

preferred by livestock and wild horses. Also, without the fencing in place, 

collisions or entanglement of wild horses with fences would not occur. Without 

fencing there would be a higher likelihood of wild horse exposure to toxic 

substances and other operational hazards, such as collision with well heads. 

4.10.5.3 Drying Yellowcake On-Site 

This alternative would have minimal additional impacts on habitat resources at 

the Permit Area, as the dryer would be within the Plant. There would be an added 

potential for harmful leaks to occur; however, this potential would be mitigated 

through proper operational precautions and risk management. 
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4.11 Air Quality 

4.11.1 Agency-Required Measures 

The required environmental protection measures are summarized below from 

Sections OP 2.10 and OP 5.1.1 of the WDEQ-LQD Permit to Mine (LCI, 2011b), 

the WDEQ-AQD Permit, Section 7.5 of the NRC Technical Report (LCI, 2010), 

Sections 2.1.1.1.6.1 and 6.4 of the NRC SEIS (NRC, 2011a), and Condition 12.8 

of the NRC License (NRC, 2011b). Emissions and potential impacts from radon 

gas are discussed in Section 4.17. 

LCI would use BMPs to reduce fugitive dust and emissions. These BMPs 

include: 

x Per the Air Quality Permit issued by WDEQ-AQD (Permit CT-7896), LCI 

would necessarily reduce fugitive dust emissions using standard dust 

control measures (e.g., water or chemical dust suppressant application on 

roads controlled by LCI on a schedule “sufficient to control fugitive dust 

from vehicular traffic”, reduced speed limits, encourage employee 

carpooling, etc.); 

x Reduce maximum fugitive dust by coordinating dust-producing activities; 

x Use fossil-fuel vehicles that meet applicable emission standards; 

x Reclaim or revegetate disturbed areas; 

x Reduce diesel particulate matter emissions using measures such as particle 

traps and other technological or operational methods; 

x Ensure that diesel-powered construction equipment is properly tuned and 

maintained; 

x Use ultra-low sulfur diesel fuel; 

x Use newer, cleaner equipment; 

x Avoid leaving equipment unnecessarily idling or operating; 

x Standardize delivery procedures to minimize material loss (as well as 

address health and safety concerns); 

x Use efficient construction and demolition practices; 

x Ensure vapor control equipment (e.g., laboratory hoods) is operating 

correctly to both reduce emissions and protect personnel: and 

x Per the Air Quality Permit issued by WDEQ-AQD (Permit # CT-7896), a 

scrubber would install and maintain a scrubber for used during loading of 

the HCl storage tank. 

Many of the above BMPs address minimizing use of or burning fossil fuels more 

efficiently. These practices would effectively reduce GHG emissions as well. 
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4.11.2 Monitoring of Air Quality Impacts 

Specific monitoring is not required per the provisions of the WDEQ-AQD Air 

Quality Permit. Dust would be the most visible component of the emissions from 

the Project; therefore, attention to visibility conditions would be necessary to 

ensure the environmental protection measures required by the permit are applied 

timely for best effect. Several air monitoring networks exist in the region of the 

Permit Area, as outlined below. 

There are three State and Local Air Monitoring Sites (SLAMs) in Sweetwater 

County; the sites are located in Rock Springs, Moxa, and Wamsutter. The closest 

SLAM to the Permit Area is in Wamsutter (approximately 25 miles southsouthwest of the Permit Area), which records NOx, ozone, and continuous 

particulate concentrations (PM10 tapered element oscillating microbalance 

(TEOM)) and houses a camera system and meteorology monitors. The Wamsutter 

site is upwind, as is the Rock Springs site (approximately 80 miles southwest of 

the Permit Area), which records PM2.5 and PM10 concentrations. The site in 

Moxa (approximately 110 miles west-southwest of the Permit Area) has the same 

capabilities as the Wamsutter site and also monitors SO2. There are no SLAMS in 

Carbon County, the nearest downwind county. However, there are SLAMs in 

Natrona County and Albany County (approximately 100 miles northeast and 

approximately 150 miles southeast of the Permit Area, respectively). Both of 

these downwind sites collect only PM2.5 and PM10 concentrations. The nearest 

downwind site measuring gaseous emissions is in Campbell County 

(approximately 200 miles northeast (WDEQ, 2010b). 

The purpose of the Interagency Monitoring of Protected Visual Environments 

(IMPROVE) network is to establish current visibility and aerosol conditions along 

with characterization of broad regional trends and visibility conditions using 

monitoring data collected in or near Class I Areas across the United States. 

Wyoming has five IMPROVE locations which include: Yellowstone National 

Park (approximately 200 miles northwest of the Permit Area), Bridger Wilderness 

Area (approximately 100 miles northwest of the Permit Area), North Absaroka 

Wilderness Area (approximately 180 miles northwest of the Permit Area), 

Thunder Basin National Grasslands (approximately 200 miles northeast of the 

Permit Area), and Cloud Peak Wilderness Area (approximately 180 miles north of 

the Permit Area) (WDEQ, 2010b). There are no IMPROVE sites downwind of the 

Permit Area in Wyoming. 

The purpose of the National Atmospheric Deposition Program (NADP) is to 

measure atmospheric deposition and study its effects on the environment. 

Deposition is measured at various sites, nationwide, through the National Trends 

Network (NTN). There are currently eight active NTN sites in Wyoming. The 

nearest NTN site to the Permit Area is in South Pass City (approximately 60 miles 

west-northwest of the Permit Area. The nearest upwind site is in Murphy Ridge, 

Utah (approximately 180 miles southwest of the Permit Area). The nearest 
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downwind site is in Newcastle (approximately 200 miles northeast of the Permit 

Area) (NADP, 2011). 

Finally, there are three active Clean Air Status and Trends Network (CASTNET) 

sites in Wyoming: Centennial, Pinedale, and Yellowstone National Park. These 

sites have been designed to provide data to assess trends in air quality, 

atmospheric deposition, and ecological effects due to changes in air pollutant 

emissions. The closest site to the Permit Area is in Centennial (approximately 100 

miles southeast of the Permit Area. There are no nearby upwind CASTNET sites 

and the closest downwind site is in Wind Cave National Park in South Dakota 

(approximately 200 miles northeast of the Permit Area) (EPA, 2011a). 

4.11.3 Impact Significance Criteria 

The airborne emissions of the Project are identifiable, and emission levels are 

estimated to evaluate the potential impacts on ambient air quality from the 

different phases of the Project, i.e., Construction, Operation, and Reclamation. 

Potential impacts on air quality from the Project are evaluated in consideration of 

the WAAQS, NAAQS, PSD, and Regional Haze Regulations. The WAAQS and 

NAAQS set legally enforceable upper limits for specific air pollutant 

concentrations. If an area meets the standards, it is considered to be in 

“attainment”. PSD requirements provide maximum allowable increases in 

concentrations of pollutants for areas already in compliance with the NAAQS. 

PSD standards are, therefore, expressed as allowable increments in the 

atmospheric concentrations of specific pollutants. Allowable PSD increments 

currently exist for three pollutants: NO2, SO2, and PM10. One set of allowable 

increments exists for Class II areas, which cover most of the US. A much more 

stringent set of allowable increments exists for Class I areas, which are 

specifically designated areas where the degradation of ambient air quality is 

severely restricted. Regional Haze Regulations were developed to maintain and 

improve visibility in PSD Class I areas. 

The Project was also evaluated in consideration of whether it would be a major 

source in accordance with WDEQ regulations and whether any Hazardous Air 

Pollutants (HAPs) would be present. The potential impacts of those portions of 

the emissions that are greenhouse gases and contribute to climate change are more 

difficult to quantify and depend on relative comparisons to other sources. 

Therefore, the potential impacts of greenhouse gases and climate change from the 

Project as a whole are evaluated by comparing Project greenhouse gases (GHGs) 

emissions to statewide emissions. 

4.11.4 Air Quality Impacts from the Proposed Action 

The Project is expected to be a source of airborne emissions throughout the life of 

the Project. Emissions would include: 
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x fugitive dust; 

x combustion engine exhausts; 

x particulates and gaseous emissions from materials used in Project 

activities, such as drilling (e.g., drilling mud) and ore processing (e.g., 

salt); and 

x radon gas. 

The significance of the impacts of fugitive dust, engine exhausts, particulates, and 

other gaseous emissions on the ambient air quality from the Project depends on 

the emission levels of the Proposed Action, the existing air quality in the region of 

influence, and the threshold to separate significant from non-significant effects. 

This section discusses predicted emissions from each phase of the Project in 

relation to relevant air quality regulations and potential impacts with 

consideration of site-specific conditions. Emissions and potential impacts from 

radon gas are discussed in Section 4.17. The only potential non-radiological HAP 

emission is hydrogen chloride, which is used for ore processing in the Plant and is 

discussed in Section 4.11.4.2. 

PSD applies to new major sources or major modifications at existing sources for 

pollutants when the area the source is located is in attainment or unclassifiable 

with the NAAQS. The Permit Area and surrounding land is classified as in 

attainment for NAAQS and WAAQS, and does not include any PSD Class I or 

Sensitive Class II areas. The nearest PSD Class I areas, Bridger Wilderness, 

Fitzpatrick Wilderness, and Mt Zirkel (WDEQ, 2011b), are located about 60, 100, 

and 90 miles, respectively, to the northwest and south (Mt. Zirkel) of the Lost 

Creek site. The Popo Agie Wilderness area is the closest Sensitive Class II area 

and is located about 58 miles to the northwest of the Lost Creek site (NRC, 

2011a). 

WDEQ-AQD issued an air quality permit for the Project on January 4, 2010. The 

Project is not considered a “major source” as defined in Chapter 6, Section 3 of 

the Wyoming Air Quality Standards and Regulations (WDEQ, 2010a). 

Therefore, air quality modeling is not necessary. Air emissions from the proposed 

Lost Creek ISR Project would comply with the conditions of the WDEQapproved construction air permit and the required WDEQ minor source operating 

permit. Due to the wind and relative instability of the air, emissions would 

generally be quickly dispersed (Section 3.10). As such, it is not expected that the 

predicted Project emissions would impact attainment for ambient air quality 

standards in the region surrounding the Permit Area. Furthermore, emissions are 

not expected to impact air quality in the Class I or Class II areas in the vicinity of 

the proposed Lost Creek ISR Project, as the areas are located at least 50 miles 

from the Permit Area and are upwind the majority of the time (Figure 3.10-4). 
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4.11.4.1 Construction 

Air quality impacts during Initial Construction would come primarily from 

ground-clearing activities and transportation of materials and personnel. The 

primary emissions would be dust and emissions from combustion engines, which 

would power equipment ranging from light trucks to heavy equipment. Emissions 

other than dust or engine exhausts would be minimal. 

Mine Unit Development is included under construction, although the development 

of the mine units is progressive (one mine unit may be under development while 

another mine unit is in operation). During Mine Unit Development, there would 

be some air quality impacts from emissions and dirt-moving activities during 

header house and pipeline installation. However, the quantity of dust from these 

activities would be a small fraction of that from road traffic. 

According to Section 4.7.1.1 of the NRC SEIS, potential impacts to air quality in 

the region during Construction result from fugitive dust and combustion 

emissions from the vehicles and equipment used. It is believed that all of these 

emissions would not result in concentrations above the air quality standards, and 

that the only potentially significant impact would be the visual impact the fugitive 

dust emissions could have (NRC, 2011a). 

Dust 

Localized, short-term and intermittent visible dust would be possible in the 

immediate vicinity of the Permit Area (i.e., when vehicles travel on unpaved 

roads). These impacts would be reduced, but not eliminated, by road treatments 

required per the WDEQ-AQD permit (WDEQ, 2010a). To estimate the 

maximum annual amount of dust generated from Project traffic, calculations 

using EPA Emission Factors for unpaved and paved roads were made. These 

calculations do not include any reduction for road treatment. The equations and 

assumptions for these calculations can be found in Appendix D. 

Most of the dust, generated from all vehicles, originates from travel on unpaved 

roads. The greatest amount of dust, assuming no road treatment, would be 

generated from employee and contractor vehicles during Initial Construction 

(approximately 170 tons per year of PM10). Mine Unit Development would also 

generate dust emissions, but less than during Initial Construction due to the 

reduced vehicular traffic (e.g., less than half the number of commuting vehicles 

with some vehicles remaining on-site). 

Combustion Engines 

Emissions would originate from a variety of engines on employee vehicles, 

tractor/trailers delivering equipment and supplies, scrapers and other earth moving 

equipment, welding machines, drilling rigs, and other equipment used for 
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Construction. Most of the combustion emissions from the employee vehicles are 

expected to be from gasoline engines and from the heavier equipment are 

expected to be from diesel engines. 

Table 4.11-1 includes the estimated engine emissions during Initial Construction. 

Estimating the number of vehicles and type of equipment is difficult because of 

overlapping uses of the equipment for different Project phases. In addition, to 

simplify the estimate, it is assumed that some activities all occur during the initial 

seven-month period. For example, it was assumed that all of the UIC Class I 

wells would be drilled during the initial seven-month Construction period. 

However, one of the wells was installed in 2008 to provide the necessary 

subsurface information to determine the feasibility of deep well disposal, and it is 

unlikely that the other four would be drilled in the same year, due in part to rig 

availability and expense. In addition, only those wells needed would be drilled. 

Table 4.11-1 Estimated Engine Emissions during Initial Construction 

(tons/year) 

Drilling Activity NOx CO SO2 PM10 CO2 Formaldehyde VOCs

Commuting Traffic 1 0.66 8.6 -- 2 <0.01 279 -- -- 

Truck Deliveries 3 5.24 0.48 -- <0.1 251 -- <0.1 

Construction 

Equipment 4 2.5 0.55 0.17 0.18 94 0.00068 0.20 

Total Estimate 8.40 9.63 0.17 0.18 624 0.00068 0.20 1

 Using emission factors from EPA (2005) for a single vehicle multiplied by the expected number of 

vehicles in Table 4.3-1, for initial construction this was estimated to be 33 trucks/SUVs. 2

 Dashes (--) indicate information not provided in reference. 

3

 Using emission factors from Federal Highway Administration (2005) for combination 

(tractor/trailer) diesel trucks built in 2002 on rural freeways for all parameters except CO2; using 

emission factors from EPA (2004b) for CO2 from moderate, heavy duty diesel vehicles. Mileage 

for calculating emissions assumed two 500-mile round trips (1,000 miles total) per week for 

seven months. Emissions were then multiplied by the expected number of vehicles in Table 4.3-

1, for initial construction this was estimated to be five tractor/trailers. 4

 Table D.3-2 of Appendix D of NRC SEIS (NRC, 2011a).

It should also be noted that this estimate includes emissions from activities that do 

not occur exclusively on-site. In particular, the emissions attributable to off-site 

employee traffic and truck deliveries are included. Another important 

consideration is that the definition of Initial Construction for this estimate 

includes the installation of the Plant and associated facilities, but not Mine Unit 

Development, which is considered separately. This was done because the 

equipment needed for installation of the Plant and associated facilities, such as 

scrapers and dozers, is not the same as that needed for installation of the mine 

units, such as drill rigs and backhoes. Estimated engine emissions during Mine 

Unit Development are included in Table 4.11-2. The estimate is provided on an 

annual basis because the work would progress throughout each year mine units 

are being installed, which occurs over about five years. 
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Other Particulate or Gaseous Emissions 

Construction activities may also generate airborne particulates other than dust or 

those generated during combustion. Examples of such particulates during the 

Initial Construction might be welding fumes or dust from grinding on steel, and 

examples of such particulates during Mine Unit Development might be drilling 

mud or cement dust during the installation of wells. However, because of the 

relatively small size of the Project facilities, these emissions are estimated to be 

negligible and the primary concern would be potential health impacts to workers 

in the immediate vicinity of the emission-generating activity. 

Table 4.11-2 Estimated Annual Engine Emissions during Mine 

Unit Development (tons/year) 

Drilling Activity NOx CO SO2 PM10 CO2 Formaldehyde VOCs

Commuting 

Traffic 1 0.3 3.9 -- 2

 <0.01 126 -- -- 

Truck Deliveries 3 3.6 0.33 -- <0.1 186 -- <0.1 

Mine Unit Well 

Drilling & Support 

Equipment 4

17 4.2 0.44 0.66 800 0.0013 0.66 

Total Annual 

Estimate 20.9 8.43 0.44 0.66 1112 0.0013 0.66 

1

 Using emission factors from EPA (2005) for a single vehicle multiplied by the expected 

number of vehicles in Table 4.3-1; for mine unit development, this was estimated to be 15 

trucks/SUVs. 2

 Dashes (--) indicate information not provided in reference. 

3

 Using emission factors from Federal Highway Administration (2005) for combination 

(tractor/trailer) diesel trucks built in 2002 on rural freeways for all parameters except CO2; 

using emission factors from EPA (2004b) for CO2 from moderate, heavy duty diesel vehicles. 

Mileage for calculating emissions assumed two 500-mile round trips (1,000 miles total) per 

week. Emissions were then multiplied by the expected number of vehicles in Table 4.3-1, for 

mine unit development this was estimated to be two tractor/trailers. 4

 Table D.3-1 of Appendix D of NRC SEIS (NRC, 2011a). 

4.11.4.2 Operation 

Air quality impacts during the Operation phase would come primarily from 

transportation of personnel and materials, and the primary emissions would be 

dust and emissions from combustion engines on lighter vehicles, such as SUVs, 

and heavier equipment, such as drill rigs. In addition to dust and to emissions 

from combustion engines, small amounts of particulates from materials used in 

Project activities, such as ore processing (e.g., salt) would be emitted. 

Section 4.7.1.2 of the NRC SEIS discusses the potential impacts to air quality 

during the Operation phase. Several concerns involve fugitive dust, combustion 

emissions from the vehicles and equipment used, and the release of radon during 

Operation. It is believed that all of these emissions would generate concentrations 
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below the air quality standards, and that the only potentially significant impact 

would be the visual impact the fugitive dust emissions could have (NRC, 2011a). 

Dust 

Significantly fewer personnel vehicles are needed during Operation than during 

Construction, so the quantity of dust generated would be less than that during 

Construction. Trucks used for resin shipments are estimated to generate 4.3 tons 

of dust per year; and delivery trucks are estimated to generate 2.7 tons per year. 

Combustion Engines 

Most of the emissions during Operation would originate from a variety of engines 

in employee vehicles, and tractor/trailers delivering equipment and supplies. 

Most of the combustion emissions from employee vehicles are expected to be 

from gasoline engines and those from heavier equipment are expected to be from 

diesel engines. The quantities would be significantly less than those generated by 

the Mine Unit Development activities. 

Other Particulate or Gaseous Emissions 

Airborne particulates may include minor amounts of salt and soda ash releases 

during deliveries to and use at the Plant. An analysis of soda ash emissions shows 

that approximately 13.5 pounds of particulate would be released per year. The 

analysis assumes that 5.2 pounds of particulate is created per ton used, and 521.1 

tons of soda ash would be used each year. Although 1.35 tons of particulate is 

created each year, a standard passive bag house filter would capture 99.5 percent 

of the material (using emission factors from EPA’s AP-42, Compilation of Air 

Pollutant Emission Factors, Volume 1 (EPA, 2006), resulting in a total emission 

of 13.5 pounds. A similar analysis of salt emissions, using a passive bag house 

filter, indicates that approximately 17.5 pounds of salt would be emitted per year, 

a minor contribution to the Project PM10 emissions, which are primarily dust. 

Liquid chemicals may be used in controlled amounts during groundwater 

restoration and for laboratory procedures. Venting of pressure at the mine units 

and supporting facilities would occasionally produce a low volume of nonradioactive gaseous emissions, such as CO2, oxygen, and water vapor. These can 

come out of solution from the lixiviant or from the underground environment. 

The only potential HAP emission is hydrogen chloride (HCl), which is used for 

ore precipitation at the Plant (Section 2.1.4). Permit # CT-7896, issued to LCI by 

WDEQ-AQD, includes specific conditions for use of a scrubber during loading of 

the HCl storage tank; therefore, no discernible impact is anticipated. 

Table 4.11-3 shows the estimated annual emissions during Operation, which is 

expected to be approximately seven years in duration. 
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Table 4.11-3 Estimated Annual Emissions during Operation 

(tons/year, unless otherwise noted) 

Drilling 

Activity NOx CO SO2 PM10 CO2 Formaldehyde VOCs Soda Ash 

(lbs/yr) 

Salt 

(lbs/yr) 

Commuting 

Traffic 1 0.06 0.78 -- 2

 <0.01 25.4 -- -- -- -- 

Truck 

Deliveries 3 5.39 0.50 -- <0.1 258 -- <0.1 -- -- 

Plant 

Deliveries & 

Drilling4

-- -- -- -- -- -- -- 13.5 17.5 

Total 

Annual 

Estimate 

5.45 1.28 -- 0.1 283 -- <0.1 13.5 lbs 17.5 lbs 

1

 Using emission factors from EPA (2005) for a single vehicle multiplied by the expected number of 

vehicles in Table 4.3-1; for mine unit development, this was estimated to be three trucks/SUVs. 2

 Dashes (--) indicate information not provided in reference. 

3

 Using emission factors from Federal Highway Administration (2005) for combination (tractor/trailer) 

diesel trucks built in 2002 on rural freeways for all parameters except CO2; using emission factors 

from EPA (2004b) for CO2 from moderate, heavy duty diesel vehicles. Mileage for calculating 

emissions assumed two 500-mile round trips (1,000 miles total) per week. Emissions were then 

multiplied by the expected number of vehicles in Table 4.3-1, for mine unit development this was 

estimated to be three tractor/trailers. 4

 Using emission factors from EPA’s AP-42, Compilation of Air Pollutant Emission Factors, Volume 1 

(EPA, 2006) and usage information discussed above.

4.11.4.3 Reclamation 

Reclamation would occur after completion of each mine unit (Mine Unit 

Restoration) as well as at the end of the project (Final Reclamation). Restoration 

of each mine unit is expected to take approximately one year, while Final 

Reclamation would take approximately three years. Potential air quality impacts 

during reclamation would include fugitive dust and emissions from combustion 

engines from many of the same sources identified for Construction. Impacts 

during Mine Unit Reclamation would be similar to those during Mine Unit 

Development, though of smaller quantities. During Final Reclamation, emission 

levels could increase in the short term, especially for particulate matter from 

activities such as dismantling buildings and equipment and grading the surface as 

part of Reclamation activities. Potential air quality impacts from Final 

Reclamation are initially expected to be similar to Initial Construction impacts 

and would decrease significantly as reclamation proceeds. Table 4.11-4 shows 

the upper limit of emissions during reclamation for the final year of the Project, 

where Mine Unit Restoration would overlap with Final Reclamation. Emissions 

would be far less during the remainder of reclamation. 
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According to Section 4.7.1.1 of the NRC SEIS, potential impacts to air quality in 

the region from the Reclamation phase result from fugitive dust and combustion 

emissions from the vehicles and equipment used. It is believed that all of these 

emissions would result in air concentrations below the air quality standards, and 

that the only potentially significant impact would be the visual impact the fugitive 

dust emissions could have (NRC, 2011a). 

Table 4.11-4 Estimated Annual Engine Emissions during 

Reclamation (tons/year) 

Drilling Activity NOx CO SO2 PM10 CO2 Formaldehyde VOCs

Commuting 

Traffic 1 0.24 3.1 -- 2

 <0.01 101 -- -- 

Truck Deliveries 3 8.98 0.83 -- 0.11 430 -- 0.11 

Construction 

Equipment 

Needed for 

Reclamation of 

One Mine Unit & 

Plant Facilities3

17 3.6 1.1 1.2 620 0.0045 1.3 

Total Annual 

Estimate 26.2 7.53 1.1 1.31 1151 0.0045 1.41 

1

 Using emission factors from EPA (2005) for a single vehicle multiplied by the expected number 

of vehicles in Table 4.3-1; for reclamation, this was estimated to be 12 trucks/SUVs. 2

 Dashes (--) indicate information not provided in reference. 

3

 Using emission factors from Federal Highway Administration (2005) for combination 

(tractor/trailer) diesel trucks built in 2002 on rural freeways for all parameters except CO2; 

using emission factors from EPA (2004b) for CO2 from moderate, heavy duty diesel vehicles. 

Mileage for calculating emissions assumed two 500-mile round trips (1,000 miles total) per 

week. Emissions were then multiplied by the expected number of vehicles in Table 4.3-1, for 

reclamation this was estimated to be five tractor/trailers. 3

 Table D.3-6 of Appendix D of NRC SEIS (NRC, 2011a). 

4.11.4.4 Greenhouse Gases and Climate Change 

With respect to evaluation of the cumulative impacts on air quality of energyrelated projects with overlapping potentially affected areas, e.g., coal mining and 

oil and gas drilling, there are often concerns not only on the impacts of mining of 

the materials, but also on the impacts of the complete fuel cycle for those 

materials, especially as it relates to greenhouse gases and climate change. 

Conversely, there may also be concerns about the impacts of climate change on 

the Project. 

No practical methods exist to evaluate the contribution to climate change in a 

particular place from a single project. The Center for Climate Strategies 

generated a report for the WDEQ, showing the inventory and future greenhouse 

gas emissions for the State of Wyoming (CCS, 2007). Carbon dioxide is expected 

to be emitted at much higher levels than other GHGs during all phases of the 
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Project. Comparing the annual emissions of CO2 from the Project to the statewide 

CO2 estimated annual emissions, the Project would produce less than 0.01 percent 

of the net total greenhouse gases produced in Wyoming (NRC, 2011a). The 

percentages for other GHGs would be even less. The potential impacts of CO2

and the other GHGs from the Project would thus be negligible. Evaluating the 

contribution to climate change from the complete nuclear fuel cycle indicates a 

low impact compared to other energy-related projects (IAEA, 1999). 

Due to the negligible CO2 contribution, and the natural decreases and increases in 

temperature in this part of Wyoming, attributing part of the climate change to the 

Project is speculative. In turn, the projected temperature change would have little, 

if any, impact on the Project (GCRP, 2009). With respect to an increase in 

precipitation, the natural variability is greater than 10 to 15 percent per year. 

Therefore, presuming the projected precipitation change was incremental over the 

next century, the impact on the Project would be negligible (GCRP, 2009). 

In Section 4.7 of the NRC SEIS, the amount of greenhouse gases emitted as a 

result of this Project is calculated to be a small fraction of the total projected 

emissions from the entire state of Wyoming and is considered insignificant (NRC, 

2011a). 

4.11.5 Air Quality Impacts from Other Alternatives 

4.11.5.1 No Action Alternative 

Under the No Action Alternative, there would be no change in the air quality at 

the Permit Area or at any surrounding receptor sites. The Permit Area currently 

meets the NAAQS for attainment status, and it is expected that this area would 

continue to meet the NAAQS. As noted in Section 3.10, current activities in the 

vicinity, including ranching, hunting, and grazing, do produce some emissions. 

4.11.5.2 Other Action Alternatives 

The impacts on air quality from the Other Action Alternatives (Not Fencing the 

Pattern Areas and Drying Yellowcake On-Site) would not increase the impacts of 

the Proposed Action in terms of duration, significance and scale. 
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4.12 Noise 

4.12.1 Agency-Required Measures 

The required environmental protection measures are summarized below from 

Section OP 2.8 of the WDEQ-LQD Permit to Mine (LCI, 2011b), and Sections 

3.8, 4.8.1.1, 4.8.1.2, 4.8.1.3, 4.8.1.4, 4.8.2, and 4.8.3 of the NRC SEIS (NRC, 

2011a). The required environmental protection measures are primarily associated 

with wildlife and public and occupational health, which are discussed in Sections 

4.9 and 4.17, respectively. The discussion in this section focuses on off-site 

human receptors. 

The noisiest aspects of the Project would be during Initial Construction and Final 

Reclamation, due to the heavy equipment that would be in use. To reduce the 

noise generated, these activities would primarily occur during daylight hours 

(between 7 a.m. and 5 p.m.), and the 70 dBA 24-hour average sound-energy 

guideline to protect hearing (EPA, 1978) would not be exceeded. Once mining 

operations begin, i.e., pumping and injection of production solutions, the 

operations would continue around the clock, but continuously operating 

equipment (e.g., pumps) would be located inside buildings. During a routine 

night shift, only one employee would be in the field in a light truck to monitor 

equipment. Use of protective devices, such as mufflers and personal hearing 

protection, would be used to maintain noise levels in work areas in the immediate 

vicinity of the equipment below Occupational Health and Safety Administration 

(OSHA) regulatory limits. 

4.12.2 Noise Monitoring 

Because Project noise is not expected to cause any substantial impact, no 

monitoring is planned. 

4.12.3 Impact Significance Criteria 

The 55-dBA guideline, which was established by the EPA’s Office of Noise 

Abatement and Control to protect against activity interference and annoyance 

(1978), was used to assess the significance of noise impacts on the human 

environment. The Rawlins RMP does not specifically state any pertinent factors 

concerning noise with respect to activities such as those of the Proposed Action. 

4.12.4 Noise Impacts from the Proposed Action 

Unlike conventional open-pit mine sites, impacts from increased noise levels are 

minimal at ISR project sites because major dirt-moving equipment is used for 
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only a short period of time as large-scale excavations are not conducted. Noise 

impacts were assessed by comparing background noise levels with projected noise 

levels on-site and off-site during Construction, Operation, and Reclamation. The 

proximity of sensitive receptors was considered in the impact analysis. The 

closest residence, church, or school (i.e., Bairoil) is about 15 miles from the 

northeast Permit Area boundary and would be more than 16 miles from the 

nearest mine unit or the Plant. 

4.12.4.1 Construction 

During Initial Construction, noise would be created due to the use of heavy 

equipment (e.g., dozers, graders, and cranes). Construction would occur for about 

seven months at the beginning of the Project, and would be concentrated near the 

Plant. Average noise levels 50 feet from the heavy construction equipment are on 

the order of 75 to 110 dBA, as shown in Table 4.2-1 of the GEIS (NRC and 

WDEQ, 2009). Beginning at a distance of 50 feet, noise levels diminish by six 

dBA for each doubling of the distance from the source (Golden et al., 1979). The 

Plant is about 1,000 feet from the closest Permit Area boundary (Figure 1.1-3), 

and, given the ambient wind noise (Sections 3.10 and 3.11), the equipment noise 

would be indistinguishable from the wind noise at that boundary. 

There would be negligible adverse effects from on-site noise to the nearest off-site 

receptors due to the considerable distance from the Plant to the nearest populated 

area. Workers commuting to the site and the transport of materials, via truck, 

would be the sources of off-site noise impacting off-site receptors, and these 

would be distributed among the three access routes to the Permit Area. Less than 

ten deliveries per day would be required during the Construction phase, and heavy 

trucks would only pass occupied residences once they reached US-287. This is a 

well-traveled road, and the increase in heavy truck traffic and commuters caused 

by the Project would be approximately two percent (Sections 3.2 and 4.3). This 

incremental increase is not expected to be noticeable. Due to the limited need for 

materials transport and the existing noise created by the highway, adverse effects 

from noise by the Project would be negligible. 

During the Construction for Mine Unit Development, smaller equipment would 

generally be needed, with a corresponding decrease in the noise generated. Onsite measurements of the noise from equipment that would be commonly used at 

the site confirm that the noise levels reduce quickly with distance from the 

equipment, particularly given the generally windy conditions (Figure 4.12-1 and

Table 4.12-1). 

The above assessment of Construction impacts is in agreement with that in the 

NRC SEIS and includes more specific on-site noise measurements. Section 

4.8.1.1 of the NRC SEIS discusses noise generation during Construction. 

Specifically, noise is generated from the construction equipment and the increased 

traffic to and from the site. The SEIS suggests that the smaller roads would be 
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more impacted than the larger, heavily travelled roads by the increase in traffic, 

and that the construction noise impacts would largely depend on distance from the 

source of the sound (NRC, 2011a). 

Figure 4.12-1 Drilling Rig Noise versus Distance 

4.12.4.2 Operation 

Overall, noise levels during Operation would be expected to be lower than during 

Construction. Noise generated during the Operation phase would be mostly 

attributed to operation of pumps inside the header houses. 

During Operation, periodic truck traffic for material transport, worker commuting, 

and traffic for maintenance and inspections would also contribute noise off-site. 

Less than one delivery per day would be required, and the associated increase in 

truck traffic on US-287 would be less than 0.1 percent, which would not be 

noticeable. Therefore, on-site sources would result in negligible noise increases 

to off-site receptors during this phase. No exceedance of any applicable noise 

criteria for off-site receptors or for on-site personnel is expected during the 

Operation phase. 

The above assessment of Operation impacts is in agreement with that in the NRC 

SEIS and is based on more specific on-site noise measurements. Section 4.8.1.2 

of the NRC SEIS discusses noise generation as a result of the Operation phase. 

Specifically, noise is generated from the increased traffic to and from the site and 

60

65

70

75

80

85

90

95

100

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the processing equipment. The SEIS suggests that the smaller roads would be 

more impacted than the larger, heavily travelled roads by the increase in traffic, 

and that the processing noise impacts would largely depend on distance from the 

source of the sound (NRC, 2011a). 

Table 4.12-1 Field Measurements of Equipment Noise in the 

Permit Area 

Equipment Location Comment 

Noise Level in 

Decibels 

Low High Average 

Background Northwest HiVol 

Station 

HiVol station off and no other 

equipment running; light breeze 60.1 70.1 65.7 

Pulling 

Unit 

(swabbing) 

100 feet upwind Light breeze blowing east; unit running 60.0 70.0 65.0 

50 feet upwind Light breeze blowing east; unit running 60.0 68.0 65.0 

At operators station 

at end of truck Light breeze blowing east; unit running 66.0 77.0 70.0 

50 feet downwind Light breeze blowing east; unit running 64.0 70.0 67.0 

100 feet downwind Light breeze blowing east; unit running 64.0 67.0 65.0 

Eu 6500is 

Honda 

Generator 

100 feet upwind Light breeze blowing east; unit running 65.0 65.0 65.0 

50 feet upwind Light breeze blowing east; unit running 65.0 65.8 65.2 

At unit Light breeze blowing east; unit running 80.9 

50 feet downwind Light breeze blowing east; unit running 65.0 66.1 65.3 

100 feet downwind Light breeze blowing east; unit running 65.0 65.1 65.0 

110KeV 75 

HP 

Generator 

100 feet upwind Light breeze blowing east; unit running 65.0 65.1 65.1 

50 feet upwind Light breeze blowing east; unit running 65.0 65.0 65.0 

At fender of unit Light breeze blowing east; unit running 76.6 

50 feet downwind Light breeze blowing east; unit running 65.0 65.3 65.0 

100 feet downwind Light breeze blowing east; unit running 65.0 65.2 65.1 

John Deere 

710J 

Backhoe 

(idling) 

100 feet upwind Light breeze blowing east; unit running 65.0 65.0 65.0 

50 feet upwind Light breeze blowing east; unit running 65.0 65.1 65.1 

At unit Light breeze blowing east; unit running 81.5 

50 feet downwind Light breeze blowing east; unit running 65.0 65.7 65.4 

100 feet downwind Light breeze blowing east; unit running 65.0 65.0 65.0 

Water 

Truck 

(idling) 

100 feet upwind Light breeze blowing east; unit running 65.0 65.1 65.0 

50 feet upwind Light breeze blowing east; unit running 65.0 65.8 65.1 

At front left fender Light breeze blowing east; unit running 76.6 

50 feet downwind Light breeze blowing east; unit running 65.0 65.2 65.1 

100 feet downwind Light breeze blowing east; unit running 65.0 65.0 65.0 

* Measurements were performed on February 6, 2009, using a Metrosonics Model db-4000EZ Dosimeter, 

which accurately measures noise between 40 and 140 dBA with a resolution of 0.1 dBA. The instrument was 

checked against a calibrated standard both before and after the spot surveys were completed and found to be 

within 0.1 dB of the standard. The standard had been calibrated within the past year by the manufacturer. 
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4.12.4.3 Reclamation 

During Mine Unit Reclamation and Final Reclamation, noise impacts are 

anticipated to be similar to Construction for Mine Unit Development and Initial 

Construction, respectively. During Mine Unit Reclamation, equipment would be 

used for well abandonment rather than well drilling, with similar or lower noise 

impacts. Truck traffic and heavy equipment activity would be similar to the 

Construction phase due to transportation of waste material to disposal sites and 

decommissioning of structures. 

The above assessment of Reclamation impacts is in agreement with that in the 

NRC SEIS and is based on more specific on-site noise measurements. In Section 

4.8.1.4 of the NRC SEIS, noise generated from Reclamation is expected to be the 

same, or less than, the noise generated during Construction, due to the earth 

moving and deconstruction of the site, and the impacts are not expected to be 

significant (NRC, 2011a). 

4.12.5 Noise Impact from Other Alternatives 

4.12.5.1 No Action Alternative 

Under the No Action Alternative, baseline levels of noise would remain and not 

be increased. Baseline noise levels at the site are described in Section 3.11. 

4.12.5.2 Other Action Alternatives 

The impacts on noise from other alternatives (Not Fencing the Pattern Areas and 

Drying Yellowcake On-Site) would not be appreciably different than those from 

the Proposed Action. The dryer would be located inside the Plant, so no 

additional noise from the dryer operation would be anticipated. Traffic noise 

would be reduced because fewer shipments of dried yellowcake would be needed, 

as compared to yellowcake slurry shipments. 
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4.13 Historic and Cultural Resources 

Discussion of specific locations and characteristics of archaeological resources 

are confidential; disclosure of site locations are prohibited under 43 CFR 7.18. 

Therefore, the information in this section is presented in general terms. 

4.13.1 Agency-Required Measures

The required environmental protection measures are summarized below from 

Sections OP 2.4 of the WDEQ-LQD Permit to Mine (LCI, 2011b), Section 3.9 of 

the NRC SEIS (NRC, 2011a), and Condition 9.8 of the NRC License (NRC, 

2011b). 

The best mitigation for known sites is avoidance whenever possible. If avoidance 

of a site is not possible, regulatory requirements exist for mitigation of the 

impacts to a site. Because the locations of the sites eligible for the NRHP are 

already known, the potential impacts on those sites have been evaluated, and 

appropriate mitigation measures have been prepared. 

Site 48SW16604, which is one of three sites determined eligible for the NRHP, 

would be disturbed by Project activities. Therefore, a treatment plan was 

developed in consultation with the BLM, NRC, Wyoming SHPO, the Eastern 

Shoshone Tribe and the Northern Arapaho Tribe (Appendix E of the NRC SEIS 

[NRC, 2011a]). Implementation of the treatment plan would mitigate the adverse 

effects to site 48SW16604. 

Mitigation also includes procedures to be taken after unanticipated discovery of 

archaeological resources. As noted in Section OP 2.4 of the WDEQ-LQD Permit 

to Mine (LCI, 2011b) and the memorandum of agreement among NRC, BLM, 

Wyoming SHPO, the Eastern Shoshone Tribe and Northern Arapaho Tribe 

(Appendix E of the NRC SEIS [NRC, 2011a]), LCI would halt work in the 

immediate area of any such discovery and stabilize the location, so further 

degradation would not occur. An archaeologist would examine and evaluate the 

discovery for significance in accordance with applicable laws and regulations 

including the Archaeological Resources Protection Act, National Historic 

Preservation Act, American Indian Religious Freedom Act, and Native American 

Graves Protection and Repatriation Act. 

4.13.2 Monitoring of Historic and Cultural Resources Impacts 

The restrictions to keep archaeological information confidential are intended to 

prevent intrusion for curiosity or looting. Therefore, information on 

archaeological site boundaries is maintained on controlled maps, and monitoring 

of Project activities near the NRHP sites must be done by an archaeologist. 
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4.13.3 Criteria for Significance Evaluation and Impacts

Cultural resources are regarded as significant if they are enrolled in, or meet the 

eligibility criteria of, the NRHP. NRHP eligibility criteria are enumerated in Title 

36 CFR Part 60 and are described as follows: 

The quality of significance in American history, architecture, archaeology, and 

culture is present in districts, sites, buildings, structures, and objects that possess 

integrity of location, design, setting, materials, workmanship, feeling, and 

association, and that: 

x are associated with events that have made a significant contribution to the 

broad patterns of our history; or 

x are associated with the lives of persons significant in our past; or 

x embody the distinctive characteristics of a type, period, or method of 

construction, or that represent the work of a master, or that possess high 

artistic values, or that represent a significant and distinguishable entity 

whose components may lack individual distinction; or 

x have yielded, or may be likely to yield, information important in 

prehistory or history. 

To qualify for NRHP eligibility, a property must meet two separate types of 

requirements. It must exhibit integrity of location, design, materials, and related 

criteria, and it must meet one or more of the four additional criteria. The National 

Historic Preservation Act makes it clear that a site need not be of national historic 

significance to be considered eligible (Advisory Council on Historic Preservation, 

2006). Sites of local, state, and regional importance may also be listed and, thus, 

are significant in the legal sense. The phrasing of the National Historic 

Preservation Act of 1966 (as amended) is critical with respect to actual 

management of cultural resources. A site does not have to be included on the 

NRHP to receive protection under the law, but must simply meet the requirements 

of eligibility (Kinneer et al., 2007). 

Under NEPA, impacts to cultural resources may be direct (the result of an action 

that occurs at the same time and place), indirect (the result of an action that occurs 

at a later time or in a different place), or cumulative (incremental, resulting from 

accrued past, present, and reasonably foreseeable future actions). Under Section 

106 of the National Historic Preservation Act, an adverse effect is any impact that 

alters the attributes that qualify the site for inclusion on the NRHP by diminishing 

the integrity of the site. Possible adverse impacts might include physical damage 

or destruction, alternation, deterioration, or modification of original setting. An 

adverse effect on a cultural property would constitute a significant impact unless 

mitigation measures are undertaken to reduce or counter the harm that an 

undertaking would cause. 
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4.13.4 Historic and Cultural Resources Impacts from the 

Proposed Action 

Direct impacts on cultural resources would come from the surface disturbance in 

the footprint of the Project infrastructure. During the life of the Project, a total of 

approximately 345 acres of the land surface would be disturbed, which is eight 

percent of the 4,254 acres in the total Permit Area. The surface disturbance would 

occur during the Construction phases. There should be no additional surface 

disturbance during the Operation and Reclamation. 

Indirect impacts could result from erosion of soils after surface disturbance and 

vegetation removal. The erosion could result in deposition of material onto 

archaeological sites or removal of soil and subsequent exposure of sites. The 

increased number of people accessing the Permit Area could also lead to intrusion 

onto or looting of sites. 

One prehistoric archaeological site recorded in the Project Area, 48SW16604, 

would incur adverse effects. Site 48SW16604 lies within an area where 

construction related to the well field, an access road, and a pipeline would occur. 

It is anticipated that the entire site would be subjected to surface scraping. As 

described in Section 4.13.1, above, mitigative excavation would take place prior 

to initiation of these activities, and the impacts would therefore not be significant. 

 

Section 4.9 of the NRC SEIS (NRC, 2011a) discusses the potential impacts to the 

historic and cultural resources in the Permit area. The largest potential for 

impacts occurs during the Construction phase, when resources could potentially 

be excavated or damaged. There is also a potential for the construction process to 

temporarily restrict access to these resources. Management practices that would 

be used during construction with regards to discovery of historical or cultural 

artifacts serve to protect these resources, which would result in a smaller potential 

for significant impacts to the resources (NRC, 2011a). 

4.13.5 Historic and Cultural Resources Impacts from Other 

Alternatives 

4.13.5.1 No Action Alternative 

Under the No Action Alternative, there would be no impacts to the cultural 

resources related to the Project, although on-going activities, such as livestock 

grazing, could disturb surface archaeological sites. The No Action Alternative 

would not create significant impacts to cultural properties. 

4.13.5.2 Other Action Alternatives 

Not Fencing the Pattern Areas 
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The fences are included within the mine unit boundaries; therefore, this 

alternative would not reduce potential impacts on archaeological resources. This 

alternative would not avoid site 48SW16604, and adverse effects to that site 

would occur. Impacts to site 48SW16604 would not be regarded as significant 

because mitigation would take place prior to the time that impacts are sustained. 

Drying Yellowcake On-Site 

The dryer would be located within the Plant; therefore, this alternative would 

create no additional impacts on the archaeological resources at the Permit Area. 

This alternative would not avoid site 48SW16604, and adverse effects to that site 

would occur. Impacts to site 48SW16604 would not be regarded as significant 

because mitigation would take place prior to the time that impacts are sustained. 
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4.14 Visual and Scenic Resource Impacts 

4.14.1 Agency-Required Measures 

The required environmental protection measures are summarized below from 

Sections 3.10, 4.10.1.1, 4.10.1.2, 4.10.1.3, 4.10.1.4, 4.10.2 and 4.10.3 of the NRC 

SEIS (NRC, 2011a). 

The following protection measures are planned to minimize the Project impacts 

on visual and scenic resources. 

x building materials and paint would be chosen to blend with the natural 

environment, according to BLM guidelines; 

x all structures have been designed to be low profile, in order to minimize 

the number of vantage points from which they would be visible; 

x the site would remain clean and well-maintained according to operational 

protocols; and 

x Any necessary night lights would be designed to reduce light pollution. 

4.14.2 Monitoring of Visual and Scenic Resource Impacts 

Since impacts to visual and scenic resources would be negligible, no monitoring 

is currently planned. The Annual Report submitted to NRC and WDEQ would 

document any changes to the status of the visual resources, as necessary. 

4.14.3 Impact Significance Criteria 

The significance of the impacts was evaluated by determining if the visual 

changes would be consistent with the BLM visual resource classification of the 

area, discussed in the Rawlins RMP in the Visual Resource Management Section. 

The Permit Area is within a BLM-designated VRM Class III area and proximal to 

a VRM Class IV area. The management objective for Visual Resource 

Management Class III areas is to, “Partially retain the existing character of the 

landscape. The level of change to the landscape should be moderate. 

Management activities may attract the attention of the casual observer but should 

not dominate the view of the casual observer. Changes should repeat the basic 

natural elements found in the predominant natural features of the characteristic 

landscape” (BLM, 1984). 
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4.14.4 Visual and Scenic Resource Impacts from the 

Proposed Action 

As outlined below, the nature of the Project impacts would be consistent with the 

visual resource classification of the area. Project facilities would be discernible 

during the day, but would not be a dominant landscape feature to observers 

outside the Permit Area. Night time operations would be minimal. 

4.14.4.1 Construction 

During the seven months of Construction, there would be short-term visual 

impacts due to on-site equipment for the construction of the Project facilities and 

road improvements. This equipment will likely contrast with the forms, lines, 

colors, and textures present in the area, but will only be on-site during 

Construction, not posing a long-term impact on the visual resources of the area. 

Construction activities would result in an increase of vehicles and traffic in the 

area. (The increased potential for dust is discussed in Section 4.11). Vegetation 

disturbance would also take place during Construction. As discussed in Section 

4.8.4.1, the total disturbance acreage during Construction would be on the order 

of 345 acres, which would be scattered throughout the Permit Area. Construction 

activities would occur during the day, so other than occasional lights for safety 

and security, night time impacts would be minimal. 

Section 4.10.1.1 of the NRC SEIS examines the impacts to the visual and scenic 

resources from Construction. The impacts are primarily related to construction 

equipment, the infrastructure being built, land alterations, emissions, and lighting. 

According to the SEIS, the topography is such that most of the infrastructure 

would not be visible from more than one kilometer away. Additionally, the shortterm nature of Construction activities limits the time that the equipment and land 

disturbances would be impacting the visual resources. As such, the impacts to 

visual and scenic resources are not expected to be significant (NRC, 2011a). 

4.14.4.2 Operation 

After Construction, the majority of visual impacts would occur from the facilities 

used during the Operation phase, in particular, the Plant. In general, ISR uranium 

mines can retain the form and line of the existing landscape better than open pit or 

surface mines because less earthwork is necessary. Header houses, wellheads, 

and roads would contribute to the visual impacts, but less so than the Plant. 

Header houses may be visible from the Sooner Road, which is about two miles 

from the site, and the closest road other than the Project access roads. However, 

the header houses, which would be about 12 feet in height at the roof apex and 

painted to blend with the landscape, would only have a weak effect on the form 

and line of the landscape from the key observation points (Appendix E). The 

wellheads, which would be on the order of four feet in height or less, would not 

be noticeable from Sooner Road because they would have weak to no effect on 
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the form, line, color, or texture of the landscape from that distance. Due to the 

height and abundance of sagebrush throughout the Permit Area (Section 3.7), as 

well as the rolling topography, the on-site roads would not be visible unless the 

angle of view is directly in-line with the road. The Plant would be the largest 

building on-site, about 160 feet wide, 260 feet long, with a wall height of 22 feet 

and a peak roof height of 29 feet. 

Figure 4.14-1 is a photograph taken slightly less than 0.25 miles from an existing 

ISR project in Nebraska and helps to visualize how the Permit Area will look. 

However, there are important differences between this project in Nebraska and the 

Project. First, the Plant at the Nebraska site is taller than the Plant would be at the 

Permit Area because of different configurations of the ion exchange columns. 

Second, the vegetation is primarily grassland at the Nebraska site, rather than the 

shrubland at the Permit Area. Figure 4.14-2 is a photograph of the Project Area 

taken from the Sooner road (4.4 miles from the proposed Project). Even though 

there are two white trailers (approximately 4 miles from the photographer and 

approximately 10 feet in height and 20 feet in length) in this photograph, one 

cannot locate them without magnifying the photograph. The trailers are visible 

from the location of the photograph, but are difficult to locate without prior 

knowledge of their location. 

Because of the varying topography of the area, and the presence of the 

Continental Divide Trail and the Rawlins-Ft. Washakie Stage Road in the vicinity 

of the Permit Area, a viewshed analysis was conducted for the Plant using a 

Spatial Analyst add-on to ArcGIS 9.3. The height of the Plant was estimated to 

be ten meters and the viewshed was limited to approximately 25 miles from the 

Plant. Figure 4.14-3 shows the result of the viewshed analysis, illustrating areas 

within 25 miles that are visible from the Plant and from which the Plant would be 

reciprocally visible. The analysis allows identification of any local potential 

visual receptor sites such as the Sooner Road, Wamsutter Crooks Gap Road, the 

Continental Divide Trail, the Rawlins-Ft. Washakie Stage Road, and dispersed 

recreational areas. 
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Figure 4.14-1 Photograph of Existing ISR Project in Nebraska, July 2010 

Figure 4.14-2 Photograph of Project Area from Sooner Road, October 

2011 

Trailers 
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Figure 4.14-3 illustrates that the largest potential impacts from the Plant to the 

local visual resources lie in the southwesterly to southeasterly directions. The 

Plant would be viewable from the Mineral Exploration Road (County Road 63), 

Sooner Road (BLM 3215), and Wamsutter Crooks Gap Road (County Road 23). 

The Plant would potentially be visible from the Continental Divide Trail, but in 

only very limited areas (less than 0.5 miles in total). However, at a distance of 

about 8 miles away, the Plant would not dominate the landscape from the closest 

viewpoints along the Continental Divide Trail. The plant would be visible for 6.9 

miles along the Rawlins-Ft. Washakie Stage Road. Of this total distance, 

approximately half (3.5 miles) is within 6.5 miles of the Plant, and half (3.4 miles) 

is over 17 miles from the proposed Project (Figure 4.14-3). These distances limit 

the impact that Plant can have on the view from the road. The Plant would not be 

visible from Bairoil (the closest town) or Jeffery City (the next closest town). 

Figure 4.14-4 illustrates that most of the areas where visual resources may be 

impacted are within the Visual Resource Inventory Class IV. Although VRI 

classes do not establish management direction, Class IV represents areas with the 

least amount of visual value. 

A Visual Contrast Rating Worksheet was completed for an observation point on 

the Sooner Road (Appendix E). 

As during Construction, night time activities would be minimal. Therefore, other 

than occasional lights for safety and security, there should be only minimal visual 

impact. 

In Section 4.10.1.2 of the NRC SEIS, the NRC discusses that the size or color of 

most of the infrastructure reduces the potential for a significant impacts and the 

visual impacts associated with the Operation phase would be less than the 

Construction phase. (NRC, 2011a). 

 
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Figure 4.14-3 Viewshed Analysis 
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Figure 4.14-4 Viewshed and VRM Classes 
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4.14.4.3 Reclamation 

The Reclamation of the Project would not introduce any new visual impacts. 

When Reclamation begins, the impacts are anticipated to be similar to those 

during the Construction because there would be an influx in construction 

equipment (for decommissioning and demolition of certain facilities) and in 

traffic due to the increase in personnel. The visual impact would decline as 

decommissioning progresses. The Project would not cause modifications to 

scenery or topography that would persist after Reclamation. It is unlikely that any 

Reclamation activities would occur at night, so, other than occasional lights for 

security and safety, no impacts are anticipated. 

In Sections 4.10.1.3 and 4.10.1.4 of the NRC SEIS, the Reclamation phase is 

compared to the Construction phase, stating that since the two phases require 

similar equipment and short time frames, the overall visual impact of the phase 

would be minimal (NRC, 2011a). 

4.14.5 Visual and Scenic Resource Impacts from Other 

Alternatives 

4.14.5.1 No Action Alternative 

The No Action Alternative would present no change to the visual resources of the 

area. 

4.14.5.2 Other Action Alternatives 

If no fences were installed around the pattern areas, there would be a slight 

reduction to the visual impact of the Project. However, fences are not likely to be 

more visible than the wellheads, which may be visible, but would not dominate 

the landscape or distract potential observers from the natural landscape. In 

addition, the types of fences around the pattern areas are typical of most fences in 

the vicinity. Since the dryer for the Drying Yellowcake On-site alternative would 

be inside the Plant, there would be minimal additional impact to the visual 

resources. 
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4.15 Socioeconomic Conditions 

4.15.1 Agency-Required Measures 

While there are no agency-required measures related to socioeconomic 

conditions, LCI and LCI’s contractors and subcontractors would be encouraged to 

deliver construction materials “Free on Board” to the County in which the 

materials would be used to help ensure that the sales tax would be properly 

allocated and paid to the County where construction and related impacts would 

occur. 

In addition, LCI has commitments and initiatives to minimize socioeconomic 

impacts. LCI would support local hiring and procurement to the extent 

practicable and would continue working with Sweetwater and Carbon Counties on 

topics of interest. 

4.15.2 Monitoring of Socioeconomic Impacts 

Significant socioeconomic impacts are not anticipated, so no monitoring is 

planned. 

4.15.3 Impact Significance Criteria 

In accordance with the Rawlins RMP Management Goals, the Proposed Action 

provides an opportunity to develop a national energy source on BLMadministered lands while not interfering substantially with development of other 

resources, such as tourism, and provides for mitigation of impacts to development 

of other resources (e.g., grazing and wildlife). The following criteria were used to 

assess the significance of socioeconomic impacts to ensure the continued viability 

of the local and regional communities: 

x An increase of the local and regional population that would strain the 

ability of communities and/or counties to provide adequate housing and 

services; 

x Increasing demands on government expenditures that would inhibit the 

maintenance and/or provision of infrastructure and services; 

x An increase in the local or regional cost of living; 

x A reduction in socioeconomic viability of local and regional communities; 

and conversely, 

x An increase in government revenues that would offset increased demands 

for services; and 

x An improvement in socioeconomic viability due to indirect economic 

activity (e.g., purchase of local goods). 
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Socioeconomic impacts would occur during all phases of the Project, and LCI has 

met with county and local governments to help ensure a cooperative effort to 

sustain and improve the economies and conditions. The potential impacts to 

demographics, economic trends and characteristics, and infrastructure and 

services are discussed in the following sections by subject. Each subject is then 

described by Project phase unless the socioeconomic impact is similar throughout 

the Project phases or is generally evaluated over the life of the Project. 

4.15.4 Demographic Impacts from the Proposed Action 

4.15.4.1 Construction 

The local population is anticipated to increase as a result of increased employment 

opportunities generated both directly and indirectly by the Project. Direct 

employment during Initial Construction is anticipated to peak at 74 employees. 

It is assumed the majority of the workforce would come from outside the region. 

Although many towns are within the region, much of the workforce is anticipated 

to reside in larger, more economically diversified population centers, such as 

Rawlins and Casper. The duration of Construction would be less than one year. 

If the majority of the Construction workforce is from outside of the region, 

demographics would change. If the majority of the Construction workforce is 

from within the region, demographic impacts would be negligible. 

Indirect employment is estimated by assuming an employment multiplier. 

Assuming an employment multiplier of 0.7 for the milling/mining industry (NRC, 

2011a), an estimated 51 to 52 additional jobs would be generated (i.e., 74 

positions multiplied by 0.7). 

The total of direct and indirect employment would range from 125 to 126 

positions. Assuming an average of 2.5 people per household, the population of 

the region would increase by 312 to 315 people (i.e., 125 to 126 positions 

multiplied by 2.5). However, since a portion of the Construction workforce 

already resides in the region, the population increase would be less than this 

estimate. In an extreme case, if the population did increase by 312 to 315 people, 

in Rawlins alone, the population would increase by 3.8 percent. Realistically, 

migrants would be dispersed throughout other communities in the region as well. 

The assessment of Initial Construction impacts in this EIS is similar to that of the 

Construction assessment in the NRC SEIS with more focus on whether the 

workforce would come from outside or within the region. Section 4.11.1.1 of the 

NRC SEIS discusses how in the short-term, the influx of Construction employees 

would likely not significantly impact the demographics of the region. Since the 
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Construction phase is for a short time, the long-term impact would be negligible, 

and the overall impact would be small (NRC, 2011a). 

During Mine Unit Development, direct employment is expected to average 106 

employees. Of these 106 employees, about 54 are anticipated to have been 

employed during Initial Construction. The remaining 52 employees would be 

technical staff trained in health physics, chemistry, geology, hydrogeology, and 

engineering and would likely come from outside the region. As during Initial 

Construction, the Mine Unit Development workforce is anticipated to reside in 

larger population centers that offer more amenities and economic diversity. 

Because the majority of the workforce would work through Initial Construction 

and Mine Unit Development, the demographic change during Mine Unit 

Development would be less than during Initial Construction. Overall, the number 

of employees would increase by 32 employees from Initial Construction (74 

employees) to Mine Unit Development (106 employees). However, as noted in 

the paragraph above, 52 of the average 106 employees would likely be hired from 

outside of the region for their technical skills. Therefore, it is deduced that as 

little as 32 people to as many as 52 people would be new, direct employees of the 

Project during Mine Unit Development. Assuming an employment multiplier of 

0.7 for the milling/mining industry (NRC, 2011a), an estimated 22 to 37 indirect 

jobs would be generated (i.e., 32 to 52 positions multiplied by 0.7). 

The total of additional direct and indirect employment from Initial Construction to 

Mine Unit Development would range from 54 to 89 positions. Assuming an 

average of 2.5 people per household, the population of the Project region would 

increase by 135 to 222 people (i.e., 54 to 89 positions multiplied by 2.5). In an 

extreme case, if the population did increase by 135 to 222 people in Rawlins 

alone, the population would increase by 1.7 to 2.7 percent. Realistically, migrants 

would be dispersed throughout other communities in the region as well. 

The Mine Unit Development assessment in this EIS is similar to that of the 

Operation assessment in the NRC SEIS with more focus on whether the 

workforce would come from outside or within the region. Section 4.11.1.2 of the 

NRC SEIS (NRC, 2011a) describes how the workforce associated with the 

Operation phase might change the socioeconomic conditions. However, because 

of the small number of Operation employees, the impact to demographics is not 

expected to be significant (NRC, 2011a). 

4.15.4.2 Operation 

Demographics are not anticipated to change from Mine Unit Development to 

Operation. 
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4.15.4.3 Reclamation 

Demographics are not anticipated to change from Operation to Mine Unit 

Reclamation. 

Final Reclamation would require a similar, if not the same, workforce of Initial 

Construction. As such, demographics are not anticipated to change until Project 

closure. At that time, the Project workforce would likely be drawn to other ISR 

facilities or other regional extractive industries. 

The overall assessment of Final Reclamation in this EIS is similar to the 

assessment of Reclamation in the NRC SEIS with more focus on where the 

workforce could go after Project Closure. Section 4.11.1.4 of the NRC SEIS 

discusses how in the short-term, the influx of Reclamation employees could 

impact the region. However, since it is for a short time, the long-term impact to 

demographics would be negligible (NRC, 2011a). 

4.15.5 Revenue and Taxation Impacts from the Proposed 

Action 

The Project would contribute to the local economy through taxes generated, job 

creation, employee wages, and direct and indirect economic activity in the local, 

regional, and national economies. 

4.15.5.1 Gross Domestic Product 

The Project would contribute to Wyoming’s dominant GDP industry: mining. 

Using February 2010’s market price of U3O8 (about $42 per pound), the Project 

would contribute $360,000,000 to the nation’s GDP. The price increased to about 

$73 per pound at the beginning of 2011, and the price has been about $52 per 

pound in the first part of 2012. The Project would boost the immediate area’s 

diversity and economic health. 

The NRC SEIS does not specifically address the nation’s or the State’s GDP. 

4.15.5.2 Revenue and Taxation 

The purchases made by and the taxes collected from the Project would generate 

revenue. The primary internal costs of the Project would include: 

x capital costs associated with obtaining claims and regulatory approvals, 

including permits, and environmental studies; 

x capital costs of facility construction; 

x operation and maintenance costs; 

x costs of groundwater restoration; 
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x costs of facility decommissioning, including radiological decontamination; 

and 

x costs of surface reclamation. 

These estimated costs are provided in Table 4.15-1. The total Project costs are 

estimated at $225 million, not including local, state and federal taxes. A portion 

of this would be spent in the local area (Rawlins) for diesel fuel, propane, and 

miscellaneous supplies and repairs. This would be considered a positive impact 

to the local economy. The majority of supplies would come from Casper. 

Oxygen and CO2 would come from Wyoming or Colorado, and soda ash would 

come from Green River, Wyoming. Major construction materials would be bid 

out regionally, with a large portion anticipated to come from the ColoradoWyoming-Utah region. 

Table 4.15-1 Estimated Internal Project Costs 

Item Present Worth 

(US dollars x 1,000) 

Obtaining the right to mine (claims and permits) 13,000 

Facility construction 68,000 

Operation and maintenance 74,000 

Groundwater restoration 13,000 

Decommissioning (including decontamination) 12,000 

Surface reclamation 3,000 

The Project would contribute substantially to the local and state economies in the 

form of tax revenues generated. Tax revenues from the Project would depend on 

the production of U3O8 and the cost of production. Future tax revenues are 

dependent on uranium prices, which may considerably fluctuate. To the extent 

that uranium prices remain at current levels, uranium production would contribute 

significantly to local tax revenues. 

As shown in Table 4.15-2, tax revenues generated from the Project would include 

property taxes and ad valorem (gross products) taxes in Sweetwater County, 

severance taxes for the State of Wyoming, and federal income taxes. Equipment 

would be registered at the County Assessor's Office and a discount (50 percent) 

would be applied to the market value, then 11.5 percent of the adjusted value 

would be taxed at a rate of 63.088 mills (NRC, 2011a). This property tax revenue 

would accrue to Sweetwater County. Since the Permit Area is located in 

Sweetwater County, ad valorem taxes would also accrue in Sweetwater County. 
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Table 4.15-2 Estimated Tax Revenues Based on Project’s Annual 

Production 

Year U3O8

Production 1

Estimated 

Federal 

Income 

Taxes 

Wyoming 

Severance 

Taxes 

County Ad 

Valorem 

Taxes 

County 

Property 

Taxes 

1 45,000 

2 1,000,000 900,000 1,600,000 300,000 

3 1,000,000 9,000,000 1,000,000 1,900,000 300,000 

4 1,000,000 10,000,000 1,000,000 2,000,000 300,000 

5 1,000,000 10,000,000 1,000,000 2,000,000 250,000 

6 1,000,000 10,000,000 1,000,000 2,000,000 250,000 

7 1,000,000 10,000,000 1,000,000 2,000,000 100,000 

8 400,000 3,000,000 700,000 900,000 50,000 

9 50,000 

Total 6,445,000 52,000,000 6,600,000 12,400,000 1,600,000 

1

 Assuming a realized sales price of 60.00 US dollars per pound U3O8

Section 4.11.1 of the NRC SEIS discusses the potential impacts to taxes and 

revenue. The region would benefit slightly from the small increase in spending 

from the additional workforce, however, this impact is expected to be small. The 

State of Wyoming would benefit from mining taxes on the Project, but this is also 

expected to be fairly small relative to the total State revenue (NRC, 2011a). 

A four-percent severance tax of taxable market value would be levied by the State 

of Wyoming’s Mineral Tax Division of the Department of Revenue. Assuming 

an estimated production of 8,000,000 pounds of U3O8 over the life of the Project 

and a market value of $60 per pound of U3O8, the severance tax revenues 

generated from the Project would equal $19,200,000. 

Other tax revenues include sales, use, and lodging taxes. These amounts would 

represent an increase in local revenues throughout the region. The Project's 

operation and its employees would contribute to local, regional, and state 

revenues through the purchase of goods and services and through the taxes levied 

on such goods and services. Sales taxes and increased demand for goods and 

services would support the local economy. Additional spending would result 

from payrolls and other on-going expenditures. Expenditures generally multiply 

as the monies are circulated throughout the community several times. 

Money would be reinvested in the community as the Project replenishes its 

resources and operates throughout the life of the mine, including costs associated 

with exploration and evaluation, maintenance, sustaining capital, and routine 

operation. Increases in taxes and revenues would provide counties and 

communities with more discretionary dollars to develop infrastructure and support 
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the population. However, short-term budgetary impacts to local governments 

would occur, due to population growth and its effects on housing and local 

infrastructure and services. Receipt of taxes generally lags one year behind 

production; therefore, affected counties and communities would not receive any 

funds until two years after the beginning of the Construction phase. 

4.15.6 Labor, Employment and Income Impacts from the 

Proposed Action 

Nationally, the Project would reduce dependence on foreign sources of uranium 

while helping to maintain a viable domestic workforce with the necessary 

technical skills to recover uranium resources. Due to market conditions over the 

past 20 years, the technical expertise required to recover uranium has declined. 

LCI estimates that less than 20 engineers and 20 geologists in the US have 

adequate experience to successfully and safely operate an ISR uranium facility. A 

large percentage of these experts are at retirement age. 

The Project would increase the number of jobs and employment in the counties of 

interest without federal assistance. Given the existing economic downturn and 

associated unemployment, the Project would increase regional construction and 

service industry jobs. Throughout its life, the Project would support about 106 

direct jobs locally and a number of indirect jobs. However, similar to tax 

revenue, labor and employment would depend on the amount of U3O8 produced. 

Federal income tax would be collected from the Project’s workforce. Since 

Wyoming does not tax personal income, local, regional, and state income benefits 

would be related to the purchase of goods and services and through the taxes 

levied on such goods and services. As previously discussed, sales and use taxes 

and increased demand for goods and services would support the local economy. 

Additional spending would result from payrolls and other on-going expenditures. 

The economic benefit of expenditures related to the Project would magnify as 

funds are dispersed throughout the communities. 

4.15.6.1 Construction 

During Construction, the Project would require approximately 50 independent 

contractors , 24 LCI employees, and other intermittent contract employees at the 

Permit Area. Once the Plant is constructed, the number of independent 

contractors would be reduced to 30 drillers in order to focus on Mine Unit 

Development. In total, the Project would employ 74 people throughout 

Construction. The estimated direct-hire labor force is presented and described in 

Table 4.15-3. As previously discussed, the total of direct and indirect 

employment is estimated to range from 125 to 126 positions. 
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Table 4.15-3 Estimated Labor and Employment 

Project Phase/Stage Labor Employees 

Initial Construction Stage 

Drill contractors (10) 30 

LCI construction employees 7 

Other LCI employees (samplers, 

geologists, supervision, drilling support) 17 

Plant construction contractors 20 

Total 74 

Mine Unit Development Stage, 

Operation Phase, Mine Unit 

Reclamation Stage 

LCI construction employees 7 

LCI employees (Plant & mine units) 69 

Drilling contractors 30 

Total 106 

Final Reclamation Stage LCI employees 11 

Total 11 

Local contractors would be hired, as available, and local building materials and 

building supplies would be used to the extent practicable. Many of the workers 

are anticipated to come from Casper. Some workers may commute from Casper 

on a daily basis; others coming from Casper would stay in temporary 

accommodations during the week and commute back to Casper on the weekend. 

Construction workers coming from outside the region would likely use local 

temporary housing (e.g., apartments, hotels, motels, trailers, RVs). Some workers 

would commute to and from their permanent residence on a daily basis if within a 

one-hour drive of the Permit Area. 

The mean earnings rate for construction workers was $26,239 per year in 2008 

(Wyoming Department of Employment, 2009). The mean earnings rate for 

natural resources and mining workers was $54,183 per year in 2008. Workers 

would be paid wages typical of the area. 

The Initial Construction assessment in this EIS is similar to that of the 

Construction assessment in the NRC SEIS. Section 4.11.1.1 of the NRC SEIS 

discusses how in the short-term, the influx of Construction employees could 

impact the income and employment in the region. However, since it is for a short 

time and the pay rates would be typical of the region, the long-term impact would 

be negligible (NRC, 2011a). 

During Mine Unit Development, the Project would require an additional 52 LCI 

employees. In total, approximately 106 people (30 contract drillers and 76 LCI 

personnel) would be employed. LCI personnel would include: Project and 

operation managers; a Project engineer; a chief site geologist; a drill foreman; a 

casing crew; a restoration engineer and crew; a construction foreman and crew; 

geologists; a secretary; personnel responsible for environmental, health, and 
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safety related tasks; a plant manager; plant operators; equipment operators; an 

electrician; a chemist; and lab technicians. 

Impacts to income during Operation would be similar to those of Construction. 

Technical LCI employees would average approximately $45,000, with an 

estimated total annual payroll of $2,900,000. 

The combination of Mine Unit Development, Operation, and Mine Unit 

Reclamation is similar to that of the Operation phase evaluated in the NRC SEIS. 

Section 4.11.1.2 of the NRC SEIS describes how the workforce associated with 

the Operation phase might change the income and employment in the region. 

However, since it is for a short time and the pay rates would be typical of the 

region, the long-term impact would be negligible (NRC, 2011a). 

4.15.6.2 Operation 

The labor, employment, and income impacts during the Operation phase are not 

anticipated to differ from Mine Unit Development. 

4.15.6.3 Reclamation 

The labor, employment, and income impacts during Mine Unit Reclamation are 

not anticipated to differ from the Operation phase. 

During Final Reclamation, technical staff would decrease to less than the Initial 

Construction staff (11 LCI employees). Additional contract employees would be 

hired as necessary during Project decommissioning. The income levels during 

Final Reclamation are anticipated to be similar to those during Initial 

Construction. 

The staff would decrease as the Project nears completion. At that time, the 

Project workforce would likely apply their skills at other ISR facilities or 

extractive industries. 

Final Reclamation in this EIS is similar to that of the Reclamation phase 

evaluated in the NRC SEIS. Section 4.11.1.4 of the NRC SEIS discusses how, in 

the short-term, the influx of Reclamation employees could impact the income and 

employment in the region. However, because of the short duration and pay rates 

typical of the region, the long-term impact would be negligible (NRC, 2011a). 
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4.15.7 Cost of Living and Housing Impacts from the Proposed 

Action 

Due to the size and duration of the Project as well as the anticipated population 

centers of residence for personnel, impacts to the cost of living are not 

anticipated. 

The increase in population directly and indirectly caused by the Project would 

increase regional housing demand. In the recent past, housing availability has 

increased in Casper and Rawlins, where the majority of the Project’s workforce is 

anticipated to live. 

Since 2007, Wyoming’s active residential real estate markets have eased 

somewhat with increased inventories and lower transactions in many communities 

(EAD, 2010e). As of January 13, 2010, 504 homes were listed under the MultiListing Service in Casper (Glasspoole, T. GRI, CRS Sales Associate/Owner, 

RE/MAX, The Group. Personal communication. January, 2010.). This total does 

not include the homes that were for sale by owners, without the aid of a listing 

agency. The largest rental agency in Casper, Casper Rental Agency, had a total of 

173 vacant rental properties on January 12, 2010. Rawlins had at least 88 homes 

on the market on January 25, 2010 (Shepard, A. Broker/Owner, ERA Shepard & 

Associates. Personal communication. January, 2010.). This total does not include 

homes for sale by owners, without the assistance of a listing agency. Rawlins had 

a total of 30 vacant rental units on January 16, 2010 (based on a count of rentals 

advertised in the Rawlins Daily Times and information from contacting rental 

agencies). Additionally, both Casper and Rawlins have a large number of 

residential lots for sale. Therefore, the minimum number of rentals and homes 

available as of January 2010 in Casper and Rawlins is 795. 

Data were not collected for other communities within driving distance from the 

Permit Area, such as Wamsutter, Bairoil, and Jeffrey City. 

4.15.7.1 Construction 

As previously noted, 74 people would be directly employed by the Project during 

the Initial Construction stage. Indirect and direct employment by the Project 

would range from 125 to 126 positions. Therefore, as many as 126 housing units 

would be required during the Initial Construction stage. However, a portion of 

the workforce already resides in the area. 

The Plant construction workforce and intermittent contractors are anticipated to 

commute from their residences within the region or use local temporary housing 

(e.g., apartments, hotels, motels, trailers, RVs). The remainder of the Initial 

Construction workforce (54 personnel) would likely support activities of the Mine 

Unit Development stage, Operation phase and Reclamation phase; therefore, the 

majority of the workforce would likely rent or purchase houses. 
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Initial Construction in this EIS is similar to that of the Construction phase 

evaluated in the NRC SEIS. Section 4.11.1.1 of the NRC SEIS discusses how in 

the short-term, the influx of Construction employees could impact the demand for 

rental units in the region. However, since it is for a short time, the long-term 

impact would be negligible (NRC, 2011a). 

Upon starting Mine Unit Development, the majority of the workforce (54 

personnel) would already have established residence in the region during Initial 

Construction. An additional 32 to 52 technical LCI employees would likely move 

from outside of the region. Thus, 54 to 89 housing units would be required to 

support the direct (32 to 52 employees) and indirect (22 to 37 employees) 

employees of the Project. 

The combination of Mine Unit Development, Operation, and Mine Unit 

Reclamation in this EIS is similar to that of the Operation phase evaluated in the 

NRC SEIS. Section 4.11.1.2 of the NRC SEIS describes how the workforce 

associated with the Operation phase might increase the demand for permanent 

housing in the region. However, since there is a small number of Operation phase 

employees and the housing development in the region has kept pace with the 

population changes, the impact is not expected to be significant. 

4.15.7.2 Operation 

The cost of living and housing impacts during Operation are not anticipated to 

differ from those during Mine Unit Development. 

4.15.7.3 Reclamation 

The cost of living and housing impacts during Mine Unit Reclamation are not 

anticipated to differ from the Operation phase. 

The housing required during Final Reclamation would be similar to that required 

during Initial Construction. The technical staff from Mine Unit Development, 

Operation, and Mine Unit Reclamation would be reduced and would likely apply 

their skills at other nearby ISR facilities or extractive industries. Meanwhile, the 

contract employees hired for deconstruction and decommissioning would likely 

commute from their residences within the region or use local temporary housing 

(e.g., apartments, hotels, motels, trailers, RVs). Similar to the reduced technical 

staff at the beginning of the Final Reclamation stage, the LCI employees and 

contractors that remain at the time of Project completion would likely apply their 

skills at other nearby ISR facilities or extractive industries. 

Final Reclamation in this EIS is similar to that of the Reclamation phase 

evaluated in the NRC SEIS. Section 4.11.1.4 of the NRC SEIS discusses how in 

the short-term, the influx of Reclamation employees could impact the demand for 
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rental units in the region. However, since it is for a short time, the long-term 

impact would be negligible (NRC, 2011a). 

4.15.8 Impacts to Infrastructure and Services from the 

Proposed Action 

With a population influx, improvements to infrastructure and services may be 

required sooner than anticipated and, if so, would have budgetary effects on local 

governments. Increases in taxes and revenues would provide counties and 

communities with funding to develop and/or maintain infrastructure and to 

support the increased population. 

Due to the taxing system, impacted localities may not receive adequate funds in a 

timely manner to keep pace with increased demand. As previously noted, receipt 

of taxes generally lags one year behind production; therefore, affected counties 

and communities would not receive funds until two years after construction 

begins. Therefore, the following discussion is based on the impacts from the 

Project as a whole to specific items (e.g., education) rather than the individual 

phases of the Project. 

Additionally, the distribution of increased tax revenue generated by the Project 

may not accrue or be proportionately distributed to the localities experiencing 

increased demand. Tax revenue would accrue mainly in Sweetwater County and 

in the State, even though the majority of the Project’s workforce is anticipated to 

reside in Carbon and Natrona counties. Similarly, communities experiencing 

increased infrastructure and service demand may not receive a proportionate level 

of tax increase as sales tax tends to accrue in the larger population centers with 

more amenities. For example, even though Sweetwater County communities near 

the Permit Area would experience increased demand on infrastructure and 

services, a large portion of goods and services would be purchased in Carbon and 

Natrona counties. However, the costs associated with increased demand of public 

facilities and services are expected to be minimal. 

4.15.8.1 Education 

The Project’s peak direct employment would be about 106 employees, with an 

indirect employment of 74 people. Assuming each employee has a family that 

would move from outside of the region, the children of about 180 families would 

be enrolled in the region’s school districts. If an average person has a working 

career of 45 years and school-age children reside in the household for 

approximately 17 years, then 38 percent of the employee’s working career would 

be associated with school-age children. Assuming each family has 1.86 children 

(US Census Bureau, 2004), the following equation would be used to estimate the 

number of school-age children: 
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The Project region’s school capacity is sufficient for a conservative estimate of an 

additional 127 students. In 2008, Bairoil enrolled 5 elementary school students; 

Wamsutter enrolled 83 elementary and middle school students; Rawlins enrolled 

1,569 elementary, middle, and high school students; and Casper enrolled 10,786 

elementary, middle, and high school students. Thus, an increase of 127 students 

in these schools would increase student enrollment by 1.0 percent. Impacts to 

education would likely be minimal because: a portion of the anticipated families 

already reside in the region; the majority of the families are anticipated to reside 

in Rawlins or Casper, which would easily accommodate this increase; and the 

schools that could be impacted (in Bairoil and Wamsutter) already use Rawlins’ 

schools for at least high school if not middle school and high school. In addition, 

the regional school districts have accommodated more students than those 

enrolled in 2008. For example, Sweetwater School District One’s enrollment was 

5,033 students in 2009 and was 6,127 students in 1991 (Wyoming Department of 

Education, 2010). Carbon County School District One’s enrollment was 1,803 

students in 2009 and was 2,420 students in 1991. Natrona School District One’s 

enrollment was 11,743 students in 2009 and was 13,100 students in 1994. 

According to Section 4.11.1.2.6 of the NRC SEIS, the Operation phase may have 

a small impact to the number of students in the schools. (The combination of the 

Mine Unit Development stage, Operation phase, and Mine Unit Reclamation 

stage is similar to that of the Operation phase evaluated in the NRC SEIS.) 

However, the number is expected to be so small that the schools would not 

experience any significant changes (NRC, 2011a). 

4.15.8.2 Health Care 

Basic medical and emergency services that may be required in the event of an 

accident would be available at the Permit Area. Potential impacts to local health 

services, such as hospitals or emergency clinics, would be minimal. Local 

communities would need a minimal increase in emergency response and medical 

treatment capabilities due to the small risk of industrial accident of the Project. 

Existing emergency response and medical treatment capabilities handle industrial 

accidents similar to those that could occur at the Permit Area; and a variety of 

industrial and hazardous materials are transported on Interstate 80 through 

Rawlins, which is about a 50-mile drive southeast of the Permit Area. Therefore, 

basic services are already established that can support the Project. 

According to Section 4.11.1 of the NRC SEIS, the demand for health services 

would increase with the influx of new employees. However, the small number of 

workers would have a small influence on the region (NRC, 2011a). 
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4.15.8.3 Law Enforcement and Fire Protection 

Law enforcement and fire protection services have adequate capacity for the 

increased population. 

4.15.8.4 Communications and Utilities 

Communication services have adequate capacity for the increased population. 

An overhead electrical power line would be constructed to supply power for the 

Project at the Permit Area. The power line would connect to the pre-existing 

transmission line located directly west of the Permit Area. In addition, water 

supply and some waste disposal facilities for the Project would be developed by 

LCI due to the lack of such facilities in the vicinity of the Permit Area. 

The communities of interest have ample utilities to accommodate the increase in 

population. However, the Rawlins utility infrastructure is in need of repair. With 

the population influx, improvements to public water, sewer, and street facilities 

and services may be required sooner than anticipated and would have budgetary 

effects on the local government. 

4.15.8.5 Recreation 

The population increase would directly affect recreational use and participation. 

Since the current recreational infrastructure and regulatory oversight are adequate 

to accommodate the population increase, the revenue generated by the increased 

recreation would benefit the local communities and the State. 

In addition, data collection and increased economic activity would enhance 

cultural, educational, and recreational opportunities. The social, cultural, and 

environmental data collected for the Project would enhance the understanding and 

value of the Permit Area and its environs. 

As discussed in Section 4.2, impacts to recreational land use would be negligible 

due to the short-term duration of the Project and the small area of disturbance 

and/or restriction. For instance, hunting, which is the primary recreational 

activity, would be restricted to areas outside fenced portions of the Permit Area 

for safety reasons, but would not be permanently affected, and may be improved 

due to wildlife habitat reclamation and improved transportation routes. 
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4.15.9 Socioeconomic Impacts from Other Alternatives 

4.15.9.1 No Action Alternative 

Under the No Action Alternative, the local, regional and national socioeconomics 

would reflect the baseline conditions described in Section 3.14. 

4.15.9.2 Other Action Alternatives 

Not Fencing the Pattern Areas would minimally reduce the Project’s expenditures 

(thus, revenue and taxation) and employment. The overall socioeconomic impact 

of Drying Yellowcake On-Site would be limited compared to the socioeconomic 

impact of the Project as a whole. 
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4.16 Environmental Justice 

Environmental justice is the fair treatment and meaningful involvement of all 

people, regardless of race, color, national origin, or income. In 1994, President 

Bill Clinton passed Executive Order 12898 to address environmental justice 

through federal agencies. 

Per this executive order and subsequent guidelines, this section identifies known 

minority, low-income, and Tribal populations within the socioeconomic study 

area, evaluates whether or not these populations may have disproportionately high 

or adverse human health or environmental effects from the Project, and discusses 

the manner in which all populations would be treated fairly and meaningfully 

involved. 

The results of the following assessment are in general agreement with the Section 

4.12 of the NRC SEIS which determined that the environmental and 

socioeconomic impacts of the Proposed Action would not disproportionately 

affect the populations of concern. The NRC SEIS also evaluated potential 

radiological impacts from subsistence consumption of fish and wildlife as part of 

traditional lifestyles and concluded there would not be any disproportionate 

impacts (NRC, 2011a). 

4.16.1 Agency-Required Measures 

The need for protective measures of environmental justice impacts is not 

anticipated. 

4.16.2 Monitoring of Environmental Justice Impacts 

Monitoring of environmental justice impacts is not anticipated. 

4.16.3 Environmental Justice Impacts from the Proposed 

Action 

4.16.3.1 Identification of Minority, Low-Income, and Tribal 

Populations 

Minority Populations 

Consequent to Executive Order 12898, the Interagency Working Group on 

Environmental Justice was created, comprising twelve federal agencies and 

several White House offices (EPA, 2010b). The Interagency Working Group 
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developed guidance on key environmental justice terms. The Interagency 

Working Group defines a minority as an individual who is a member of the 

following races and ethnicity: American Indian or Alaskan Native; Asian or 

Pacific Islander; Black, not of Hispanic origin; or Hispanic (Council on 

Environmental Quality, 1997). A minority population is a population in which: 

the minority population represents more than 50 percent of the total population; or 

the minority to general population ratio of the affected area is meaningfully 

greater than the minority to general population ratio of the larger, general area. A 

minority population may be either a group of individuals living in geographic 

proximity to one another, or a geographically dispersed/transient set of 

individuals (e.g., migrant workers or Native Americans), where either type of 

group experiences common conditions of environmental exposure or effect. A 

minority population also exists if there is more than one minority group present 

and the minority percentage, as calculated by aggregating all minority persons, 

meets one of the above-stated thresholds. 

As shown in Table 4.16-1, at least 90 percent of the population of each county of 

interest and the State of Wyoming was white in 2000, with the exception of 

Fremont County. Fremont County’s population was 77 percent white and 20 

percent American Indian or Alaskan Native (largely from the Wind River Indian 

Reservation). The communities of interest were also predominantly white. The 

white population in Bairoil, Wamsutter, Jeffrey City, and Casper represented 94 

to 100 percent of the total population. Rawlins had the lowest percentage (86 

percent) of white population; the general remainder of Rawlins’ population was 

either some other race (eight percent) or more than two races (three percent). 

As noted in Section 3.14, six percent of the State’s population was of Hispanic or 

Latino ethnicity in 2000. About four to five percent of Fremont and Natrona 

counties’ populations were of Hispanic or Latino ethnicity, whereas Sweetwater 

and Carbon counties’ Hispanic or Latino ethnic populations were 9 and 14 

percent, respectively. The Hispanic or Latino population in Bairoil, Jeffrey City, 

and Casper represented no more than five percent of the total population. 

Wamsutter’s and Rawlins’ Hispanic or Latino populations were 13 and 21 percent 

of the total population, respectively. 

In 2000, within the socioeconomic study area, the population of minorities was 

less than 50 percent of the total population. In addition, the minority to general 

population ratio of the affected area was comparable (within 20 percent) to the 

minority to general population ratio of the larger, general area. Therefore, 

disproportionately high or adverse impacts to any minority race or ethnicity are 

not anticipated. 

Low-Income Populations 

Low-income populations are identified with the annual statistical poverty 

thresholds from the Bureau of the Census’ Current Population Reports, Series P-
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60 on Income and Poverty (Council on Environmental Quality, 1997). The 

thresholds represent the minimal annual cash income to support various-sized 

families, and are updated annually to account for inflation. 

As shown in Table 4.16-2, from zero to 13 percent of families and from four to 

17 percent of individuals within the places and areas of interest lived in poverty in 

1999. These percentages are similar (within 20 percent) to the State-wide average 

of 8 and 11 percent for families and individuals below the poverty level, 

respectively. Based on the data above, low-income populations are not 

anticipated to be disproportionately affected by the Project. 
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Table 4.16-1 Po

pulations b

y Race and Ethnicity, 2000 
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Table 4.16-2 Low Income Populations, 1999 

Place 

Families Individuals 

Families 

Below 

Poverty Level 

Total 

Families 

Individuals 

Below 

Poverty Level 

Total 

Individuals 

# % # % # % # % 

State of Wyoming 10,585 8 131,508 100 54,777 11 493,782 100 

Sweetwater County 548 5 10,194 100 2,871 8 37,613 100 

Bairoil 2 8 25 100 4 4 97 100 

Wamsutter 8 11 70 100 28 11 261 100 

Carbon County 411 10 4,180 100 1,879 12 15,639 100 

Rawlins 235 10 2,259 100 1,114 13 8,538 100 

Fremont County 1,267 13 9,495 100 6,155 17 35,804 100 

Jeffrey City 1 0 0 27 100 7 7 106 100 

Natrona County 1,548 9 17,772 100 7,695 12 66,533 100 

Casper 1,122 8 13,238 100 5,546 11 49,644 100 

* US Census Bureau, 2000 

1 Census Designated Place 

Tribal Populations 

Table 4.16-1 shows the American Indian and Alaskan Native populations within 

the socioeconomic study area. Fremont County has 63 percent of the American 

Indian and Alaskan Native population of the State of Wyoming. A large portion 

of the tribal population in Fremont County resides at the Wind River Indian 

Reservation, which is centered approximately 75 miles north-northwest of the 

Permit Area and would not be directly impacted by the Project. The tribal 

populations in other places and areas of interest represent less than two percent of 

the total populations. As such, tribal populations would not be disproportionately 

or adversely impacted by the Project. 

4.16.3.2 Fair Treatment and Meaningful Involvement 

To ensure environmental justice, all people are and would be treated fairly and 

meaningfully involved. Fair treatment is defined as when no group of people 

bears a disproportionate share of negative environmental consequences resulting 

from industrial, governmental, and commercial operations or policies (EPA, 

2010a). Meaningful involvement is defined as when: people have the opportunity 

to participate in decisions about activities that may affect their environment 

and/or health; the public can influence the regulatory agency’s decision; public 
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concerns are considered in the decision making process; and the decision makers 

seek out and facilitate the involvement of potentially affected people. 

Fair treatment and meaningful involvement has been and would continue to be 

implemented by the following: 

x publishing Notices of Intent and Notices of Availability to announce the 

scoping meeting(s) and document accessibility in the Federal Register 

and/or the local media (e.g., newspaper, radio, television); 

x consulting with other federal agencies, Tribal leaders, the State and local 

governments, community groups, and similar groups (Section 6.0); 

x developing stakeholder mailing lists; 

x overcoming linguistic, cultural, institutional, and geographic barriers; 

x providing public access to pertinent notices, documents, and meetings; 

x scheduling meetings at convenient times and places that are local and 

accessible; 

x sharing information through different meeting sizes, formats, media, or 

other methods; 

x soliciting feedback and recommendations through written communication, 

personal interviews, audio/video recording devices, or other methods; and 

x periodically updating stakeholders about the NEPA process. 

4.16.4 Environmental Justice Impacts from Other Alternatives 

4.16.4.1 No Action Alternative 

The No Action Alternative would have no environmental justice impacts. 

4.16.4.2 Other Action Alternatives 

Differences in environmental justice impacts are not anticipated between the 

Proposed Action and Other Action Alternatives described in Section 2.0. 
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4.17 Public and Occupational Health 

Potential impacts on public and occupation health are discussed on the basis of 

radiological and non-radiological impacts. 

4.17.1 Agency-Required Measures 

The required environmental protection measures are summarized below from 

Appendix D10 of the WDEQ-LQD Permit to Mine (LCI, 2011b), Sections 3.12.1, 

3.12.2, 3.12.3, 4.13.1.1, 4.13.1.2, 4.13.1.3, 4.13.1.4, .4.13.2, and.4.13.3 of the of 

the NRC SEIS (NRC, 2011a), and Conditions 9.7, 10.4, 10.14, 10.15, 10.16, 

10.17, 11.6, 12.2, 12.3, 12.5, 12.10, 12.11, and 12.14 of the NRC License (NRC, 

2011b). 

Efficient ISR operation, including mine unit balancing and monitoring, and up-todate techniques for ore processing and for waste storage, handling, and disposal, 

would be used to keep contaminants of concern out of any pathways that could 

result in impacts to public or occupational health. Employee training for both 

routine procedures and for unseen circumstances would help reduce the potential 

for accidents. There are requirements for personnel training, specifying the chain 

of command, equipment calibration, record keeping, and reporting to both the 

agencies and workers. Because of the relatively remote location of the Project, 

mitigation of impacts to the public comes from primarily ensuring visitors to the 

site receive the appropriate training and monitoring, and are only allowed access 

to areas outside of the established exclusion zones. 

4.17.1.1 Protection Measures for Radiological Impacts 

As previously discussed, radiological impacts from the Project are minimal. Mine 

unit and Plant design are intended to result in effective and efficient mining and 

ore processing. For example, the water balance details, the mine unit 

instrumentation, and the Plant design are described in Sections OP 3.6.3.1, OP 

3.6.1.1, and OP 4.4 of the WDEQ-LQD Permit to Mine (LCI, 2011b), 

respectively. Worker training and worker and environmental monitoring would 

be conducted throughout the life of the Project, to ensure that the practices and 

procedures developed prior to the Project are properly implemented and effective 

(Section 5.0 of the NRC Technical Report [LCI, 2010]). In addition to the 

practices and procedures developed before the Project is started, periodic 

reporting to and inspections by the NRC are also required throughout the life of 

the Project. 

As discussed in Section 6.0 of the NRC Technical Report (LCI, 2010), the NRC 

also requires licensed facilities to submit a decommissioning plan for review prior 

to the reclamation of each Mine Unit and prior to Final Reclamation. The plan 

would include details of how a radiation safety program, compliant with 10 CFR 
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Part 20, would be implemented during decommissioning to ensure the safety of 

workers and the public is maintained and applicable safety regulations are 

followed. The existing reclamation plan in the NRC Technical Report specifies 

the necessary surveys prior to reclamation to double check that no unanticipated, 

elevated radiation levels exist in the area to be reclaimed. The plan also specifies 

the radiation levels for determining whether decontaminated equipment must be 

disposed of in a licensed facility or can be reused. 

4.17.1.2 Protection Measures for Non-Radiological Impacts 

Similar to the protection measures of radiological impacts, measures used for nonradiological impacts depend on proper facility design, operation, and maintenance 

and on worker training and worker and environmental monitoring. The Wyoming 

Department of Employment (State OSHA Program) requirements and regulations 

will be followed. In addition to general practices and procedures, specific 

requirements for unique situations are also required. For example, protection 

practices related to facility design and handling and storage of the chemicals that 

would be used at the Project are detailed in Sections 7.5 and 7.6 of the NRC 

Technical Report (LCI, 2010). 

4.17.2 Monitoring of Public and Occupational Health Impacts 

4.17.2.1 Radiological Impacts 

The radiological monitoring required by the NRC is detailed and extensive. 

LCI’s radiological monitoring program is included in Section 5.0 of the NRC 

Technical Report (LCI, 2010). In addition to specifying monitoring locations, 

parameters, and frequency, there are requirements for personnel training, 

specifying the chain of command, equipment calibration, record keeping, and 

reporting to both the agencies and workers. 

The required monitoring addresses both workers and the public. With respect to 

workers, monitoring of the workers, the work place, and the environment is 

required. For example, monitoring of the workers includes radiation badges and, 

for specific work circumstances, may also include breathing zone sampling. 

Examples of work place monitoring include gamma surveys of the ion exchange 

tanks and smear samples of work surfaces. Examples of environmental 

monitoring include routine soil sampling and air particulate sampling at specific 

locations relative to the Plant and Permit Area. 

With respect to the public, the radiological monitoring required by NRC specifies 

monitoring procedures for contractors and visitors to the Project, in addition to 

establishment of exclusion zones where only specified, trained LCI personnel are 

allowed. At the Permit Area boundary, monitoring for radon, gamma, and air 

particulates is required. 
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4.17.2.2 Non-Radiological Impacts 

The monitoring requirements for the non-radiological health impacts of the 

Project are those typical for industries, such as drilling, which are regulated by 

OSHA. In particular, reporting of all accidents, investigating the circumstances 

causing the accident, and implementing improved practices where necessary are 

essential to monitoring the effectiveness of the Project’s health and safety 

practices. The regular inspections of work areas, as described in Section 2.9 of 

the WDEQ-LQD Permit to Mine (LCI, 2011b) and Section 5.0 of the NRC 

Technical Report (LCI, 2010), would also help ensure the Project’s health and 

safety practices are effective. 

4.17.3 Impact Significance Criteria 

Radiological impacts were evaluated on the basis of potential exposures to 

workers and the public during the Project phases compared to naturally occurring 

and anthropogenic exposures. Both worker and public radiological exposures are 

addressed in NRC regulations in 10 CFR Part 20, which requires licensees to 

implement an NRC-approved radiation monitoring and protection program. 

The non-radiological impacts were evaluated on the basis of relative hazards of 

the work processes (e.g., drilling) and materials (e.g., chemicals). Although the 

Project is a mining operation, the industrial safety aspects associated with the 

Project are regulated by the Wyoming Department of Employment (State OSHA 

Program) because most of the Project activities are more similar to other 

industries (e.g., drilling and manufacturing) than traditional mining. 

4.17.4 Public and Occupational Health Impacts from the 

Proposed Action 

The Project would use ISR technology to extract uranium from permeable, 

uranium-bearing sandstones. Once extracted, the uranium would be recovered by 

means of ion exchange, elution, and precipitation/filtration to ultimately produce 

yellowcake slurry. The operation plan for the Proposed Action is presented in 

Section 2.0. 

There are no permanent residents within 15 miles of the Permit Area, significantly 

reducing the possibility of public impacts. Potential public health impacts, 

however, were evaluated to ensure the health of occasional near/on-site members 

of the public, such as hunters and ranchers. In addition, the workforce for the ISR 

operation would be relatively small, especially as compared to the work force 

needed for surface mining of uranium and conventional mill operation, reducing 

the possibility of occupational impacts. 
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4.17.4.1 Radiological Impacts 

The purpose of this section is to evaluate the potential impacts for radiological 

exposures above the levels of naturally occurring exposures. Naturally occurring 

exposures are due to the presence of radioactive materials in the earth. (For 

example, radon-222 is a radioactive gas that escapes into ambient air from the 

decay of uranium found in most soils and rocks.) As a result, radioactive 

materials are also found in drinking water and foods. Cosmic radiation from outer 

space is another natural source of radiation. There are also anthropogenic 

sources, such as medical diagnostic procedures using radioisotopes. The National 

Council for Radiation Protection (NCRP) estimates the annual average dose to the 

public from all natural background radiation sources (terrestrial and cosmic) is 

310 millirems (mrem), and the annual average dose to the public from all sources 

(natural and anthropogenic) is 620 mrem (NCRP, 1987). 

Construction 

None of the activities during Construction involve worker exposure to uranium 

ore and associated radiological parameters, with the possible exceptions of shortterm exposure drilling of the deep wells and potential movement of soil with 

elevated radionuclide concentrations. With respect to the deep wells, the 

locations were selected on the basis of minimizing interference with production of 

known uranium resources. Therefore, interception of uranium ore during drilling, 

and subsequent movement of the material to the surface via the drilling process, is 

unlikely. With respect to movement of soil with elevated uranium concentrations, 

the results of the site-wide gamma scan and soil sampling (Section 3.15) do not 

indicate the presence of radionuclides in excessive quantities in Construction 

areas at the surface due to the presence of ore (e.g., an outcrop) or prior 

exploration activities. Practices to prevent worker exposure to inhalation of 

fugitive dust, e.g., dust masks, and to minimize creation and transport of dust, 

e.g., application of magnesium chloride (Section 4.11), that are implemented for 

air quality concerns would reduce the potential for transport of radionuclides in 

soil if they were encountered. 

Exclusion of the public from Construction zones, following standard health and 

safety regulations and practices, along with practices to minimize creation and 

transport of dust, would preclude radionuclide exposure to the public during 

Construction. 

During Mine Unit Development, the drilling of wells in the pattern areas increases 

the potential for exposure to radionuclides as the water and drill cuttings from the 

ore zone are brought to the surface and circulated through the mud pit. However, 

the relative volume of the water and cuttings from the ore zone, which is on the 

order of a few feet thick, relative to the overall volume of drill cuttings from a 

given well, which is several hundred feet deep, is minimal. In addition, periodic 

monitoring of mud pits is required by NRC. 
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Section 4.13.1.1 of NRC SEIS discusses that workers would most likely be 

exposed during well construction, disturbing surface soils, and fugitive dust, but 

that concentrations would be low, and any health impacts for employees and the 

general public would be low (NRC, 2011a). 

Operation 

During the Operation phase, radon would be released from the solutions at the 

mine units and vented from the Plant building to the atmosphere during routine 

operation or when vessels are opened for maintenance. Experience from other 

ISR projects shows that these releases would only be a small fraction of the 

natural background dose contribution and would not result in a significant off-site 

impact. Potential public exposures to radiation could occur from the same radon 

releases. The MILDOS-AREA computer code (ANL, 1998) was used to estimate 

potential exposures and doses to human receptors and populations surrounding the 

Permit Area, and the results are summarized below. Details on input parameters, 

exposure pathways, as well as the results of the MILDOS modeling are presented 

in the NRC Technical Report (LCI, 2010). The potential for exposures due to 

accidental releases during the Operation phase was also evaluated as part of the 

Technical Report, and the results are also summarized below. 

Section 4.13.1.2 of the NRC SEIS summarizes how employees and the public can 

become exposed during normal operations and accidents. The expected doses 

during normal operations are below the regulated limits, and any impacts from 

this exposure would not be expected. Additionally, the mitigation efforts to 

prevent accidents and the response plans if an accident does occur minimize the 

threat from spills and reduce the potential impact (NRC, 2011a). 

Operational MILDOS Modeling Results 

Since there are no permanent residents in the vicinity of the Permit Area, radon 

doses were modeled at 17 locations around the perimeter of the Permit Area 

boundary (Figure 4.17-1). The map shows modeled receptor locations, as well as 

centroids of each mine unit. MILDOS calculations and output use metric units; 

this discussion refers to English and metric length units for the sake of 

consistency. 

MILDOS modeling indicates that releases from the site lead to a maximum 

calculated total effective dose equivalent (TEDE) to a potential resident at the 

SEB1 boundary location of 3.01 mrem, which is well below the 100-mrem-peryear limit of Title 10 CFR Part 20 (Figure 4.17-2). No other boundary location 

exceeds 2 mrem in a given year and most are below 1 mrem. The vast majority of 

the calculated doses at the SEB1 location are from venting during operation, 

which occurs at the centroid of the mine unit. Most mine units are upwind of the 

SEB1 location. 
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There are no towns of any size within 15 miles of the Permit Area. While there 

are no standards for population dose, it is interesting to compare population doses 

from the Project, calculated from MILDOS, to the natural background for the 

same region. The average US resident receives 360 mrem per year (NRCP, 

1987). When applying this average US effective dose to the MILDOS population 

(8,985 residents), the natural background population dose (TEDE) would be 

approximately 3,200 person-rem per year, which is over 170,000 times higher 

than that of the calculated maximum 0.019 person-rem-per-year population dose 

within 50 miles of the Permit Area. 

 
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Figure 4.17-1 Locations of Modeled Receptor Points 

 
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Figure 4.17-2 TEDE at Boundary Receptor Points 

MILDOS is not commonly used to calculate occupational doses, because such 

doses are calculated using results of personnel monitoring during facility 

operation. However, a hypothetical worker location was used in MILDOS to 

calculate doses through the operation of the Plant. The worker location was 

modeled once for 328 feet (100 meters) to the north, east, south and west of the 

ion exchange facility. For each worker receptor location, a dose was calculated, 

multiplied by 0.22 to represent an occupational year (2,000 work hours in an 

8,760-hour year), and averaged. The maximum worker dose would be 0.3 mrem 

in 2014, which is well below the occupational standard of five rem (Figure 

4.17-3). This value is likely an overestimate for a worker at the specified 

locations, because MILDOS includes contributions from pathways, such as 

ingestion of vegetation, which would not apply to the Permit Area. During 

operation of the facility, workers at the site would be monitored and occupational 

doses calculated in accordance with the NRC License. 

There are no current dosimetric standards for protection of biota. However, it has 

been assumed by the International Commission on Radiological Protection that if 

humans were protected, then biota in the same exposure environment would also 

be protected. 

TEDE by Receptor by Year

0.00E+00

5.00E-01

1.00E+00

1.50E+00

2.00E+00

2.50E+00

3.00E+00

3.50E+00

2009 2010 2011 2012 2013 2014 2015 2016 2017

mrem

NB NEB EB1 SB SWB4 WB 

NWB EB2 EB3 SEB1 SEB2 SEB3 

SWB3 SWB2 SWB1 SEB4 SEB5
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Figure 4.17-3 MILDOS-Calculated Doses to a Hypothetical Worker 

328 feet (100 meters) from the Plant, Averaged over 

Direction 

Accidental Releases 

The precautions put into place for the Project are intended to reduce the risk of 

accidents and associated releases as much as possible. Even so, the consequences 

of various on-site accidents and transportation accidents were evaluated as part of 

the NRC Technical Report (LCI, 2010). Specifically, Sections 4.1.2, 7.4.1, and 

7.4.2 include evaluations of the consequences of releases from areas in the Plant 

with the higher concentrations of radioactive material, such as the yellowcake 

slurry storage tanks. Similarly, Section 7.2.7 includes evaluations of the 

consequences of off-site transportation accidents. 

Reclamation 

Exposures to workers could occur during disassembly of equipment used to 

convey production fluids from the mine units and equipment used in the Plant. 

Decontamination of equipment could also result in exposures, and for equipment 

that cannot be decontaminated, packaging of the equipment for transport to a 

designated disposal facility could also result in exposure if not done in accordance 

with specified practices and procedures. 
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Sections 4.13.1.3 and 4.13.1.4 of the NRC SEIS discuss that while there is a 

potential for some exposure during the reclamation efforts, the mitigation efforts 

and the clean-up of the area reduces these, and the impact on public and worker 

health is expected to be minimal (NRC, 2011a). 

4.17.4.2 Non-Radiological Impacts 

Increased traffic from the Project would increase the amount of gaseous emissions 

and airborne particulates. Potential impacts from these emissions are discussed in 

Section 4.11. 

Construction 

During Construction, most of the potential non-radiological impacts are related to 

mechanical hazards, such as operation of heavy equipment and drilling, and to 

exposure of emissions from engines on vehicles and equipment. Potential impacts 

include injuries or irritation of the eyes, nose, or respiratory system. 

Section 4.13.1.1 or the NRC SEIS discusses the potential exposure to emissions 

from diesel exhaust fumes, but explains that the short exposure time and the quick 

dispersal into the atmosphere lead to minimal impacts (NRC, 2011a). 

Operation 

During the Operation phase, there are potential chemical exposures. Chemicals 

used in bulk quantities at the Permit Area would include sodium chloride, sulfuric 

acid, oxygen, hydrogen peroxide, CO2, sodium carbonate, hydrochloric acid, as 

wells as fuels (diesel and gasoline), and smaller quantities of chemicals may be 

needed for laboratory procedures. As with radioactive materials, the precautions 

put into place for the Project are intended to reduce the risk of accidents and 

associated releases as much as possible. Even so, the consequences of various onsite accidents and transportation accidents were evaluated as part of the NRC 

Technical Report (LCI, 2010). Specifically, Sections 7.5 and 7.6 include 

evaluations of the consequences of releases from areas in the Plant in which 

chemicals would be stored and used, such as the hydrochloric acid storage tanks. 

Similarly, Section 7.4.7 includes evaluations of the consequences of off-site 

transportation accidents. 

Section 4.13.1.2.3 of the NRC SEIS discusses the potential impacts from working 

with the chemicals present on-site. Any spills would have a minimal impact on 

the public off-site, but a potentially higher impact on workers if proper clean-up is 

not accomplished shortly after the spill. However, with the spill prevention and 

mitigation measures the impact from these spills is reduced since if one occurs, it 

would be properly addressed (NRC, 2011a). 
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Reclamation 

The primary concerns during Reclamation would be similar to those during 

Construction, including operation of heavy equipment and exposure to engine 

emissions. 

Section 4.13.1.4 of the NRC SEIS discusses the potential health impacts that 

could occur during Reclamation. The NRC suggests that as cleaning efforts 

progress in the Permit area, the likelihood for health impacts decreases, and that 

overall, the impact would be minimal (NRC, 2011a). 

4.17.5 Public and Occupational Health Impacts from Other 

Alternatives 

4.17.5.1 No Action Alternative 

The No Action Alternative would generate no impact on public and occupational 

health. 

4.17.5.2 Other Action Alternatives 

The alternative of Not Fencing the Pattern Areas increases the potential for access 

to the pattern areas. The primary concern is that cattle or wild horses would 

damage the well heads, resulting in a release of production fluid, i.e., a 

radiological exposure. Procedures that are in place for detecting releases, 

repairing equipment, and implementing appropriate remediation measures would 

reduce the potential for exposure to radiological materials. With respect to nonradiological hazards, fencing the pattern areas reduces the potential access for 

someone unfamiliar with the pattern area hazards (e.g., trip and fall hazards in the 

header houses). 

The alternative for Drying Yellowcake On-Site increases the potential radiation 

exposure to workers in the Plant. The potential exposure is not during operation 

of the dryer, because the vacuum system is designed to prevent release of 

radiological particulates. The potential exposure could occur during maintenance 

and reclamation of the dryer or during an accidental release, and this exposure 

would be similar to that of the Proposed Action. In addition, before a dryer could 

be installed, an NRC license amendment would be required, which would include 

further detail on dryer operation, monitoring, and decommissioning. The vacuum 

dryer and associated equipment would not be significantly more complex than the 

other processing equipment in the Plant; therefore, the potential increase in nonradiological impacts would be minimal. Because the dryer would be located 

within a restricted area of the Plant, there would be no potential for public 

exposure during routine operations. 
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4.18 Waste Management 

During the Project, gaseous/airborne, liquid, and solid effluents would be 

generated from the processes associated with ISR operations. All of the effluents 

are typical for ISR projects currently operating in Wyoming, and existing 

technologies are amenable to all aspects of effluent control in the Permit Area. 

Waste streams from different phases of the Project and waste management 

practices for the Project are described in Section 2.1. The waste management 

control practices are also described in Section OP 5.0 of the WDEQ-LQD Permit 

to Mine (LCI, 2011b) and Section 4.0 of the NRC Technical Report (LCI, 2010). 

4.18.1 Agency-Required Measures 

The required environmental protection measures are summarized below from 

Sections OP 5.2, 5.3 and RP 4.2 of the WDEQ-LQD Permit to Mine (LCI, 

2011b), Sections 2.1.1.1.6.2 and 2.1.1.1.6.3 of the NRC SEIS (NRC, 2011a), and 

Conditions 9.6, 9.9, 11.1(D), and 12.6 of the NRC License (NRC, 2011b). 

The monitoring programs for non-radioactive emissions and particulates and for 

radon are described in Sections 4.11 and 4.17, respectively. 

Liquid and solid wastes would be reduced by reusing/recycling materials 

whenever possible. The primary measures that would be employed to mitigate 

waste management impacts would be reduction of wastes and proper storage, 

handling, and disposal of wastes. Similarly, instrumentation and inspection of 

process facilities for timely identification and remediation of leaks and spills 

would reduce the potential for generating large volumes of wastes that would 

need to be disposed of at a licensed facility. In addition, by disposing of solid 

non-hazardous wastes at licensed facilities off-site, solid wastes would not be 

present in the Permit Area after the Project is completed. (For example, at 

conventional open pit mines, building rubble is often disposed of on-site.) The 

exception is that well casings may remain in place; however, the casing must be 

cut off below grade and a deed notice completed to document the well locations 

(WDEQ-LQD NonCoal Rules, Chapter 11, Section 8(h)(i) [WDEQ, 2005b]). 

4.18.2 Monitoring of Waste Disposal Impacts 

Gaseous Emissions and Airborne Particulates 

The monitoring programs for non-radioactive emissions and particulates and for 

radon are described in Sections 4.11 and 4.17, respectively. 

Liquid and Solid Wastes 
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The Storage Ponds and UIC Class I wells would be routinely inspected, 

maintained and tested to ensure that any impact-generating potential is kept to 

minimum. The septic system would be maintained in accordance with the 

Sweetwater County permit. The UIC Class I wells would be monitored in 

accordance with the requirements of the UIC permit. An evaluation of the well 

performance would be included in the Annual Report submitted to NRC and 

WDEQ. 

Monitoring of solid wastes would include inspection to ensure proper storage, 

selection of licensed disposal contractors, and periodic audits of labels, manifests, 

and disposal practices. 

4.18.3 Impact Significance Criteria 

The criteria used to evaluate the impacts of waste management activities are the 

availability of appropriate treatment options and disposal facilities, the capacity of 

those disposal facilities (e.g., whether the volume of Project wastes would overtax 

the facilities), and efficiency of the disposal option (e.g., disposal versus reuse). 

The impacts of the waste management facilities on specific resources are 

evaluated in the respective resource sections (e.g., the impacts of the Storage 

Ponds on wildlife are discussed in the Section 4.9). 

Section 4.14 of the NRC SEIS addresses waste management impacts. Wastes 

identified include liquid waste, both radiological and non-radiological, and solid 

wastes. However, due to the contents, quantity, and management measures, the 

impact from waste is expected to be small (NRC, 2011a). 

4.18.4 Waste Disposal Impacts from the Proposed Action 

The following discussion is separated on the basis of the type of effluent, i.e., 

gaseous/airborne, liquid, or solid effluent, and then on the basis of the phase of 

the Project, i.e., Construction, Operation, and Reclamation. 

4.18.4.1 Gaseous Emissions and Airborne Particulates 

As described in Section 2.1, non-radioactive and radioactive airborne effluents 

are anticipated during the Project; however, the relative quantities vary among the 

Construction, Operation, and Reclamation phases of the Project. 

Non-Radioactive Emissions and Particulates 

Most non-radioactive emissions and particulates would be generated during 

Construction, when the most earth moving would occur and heavy machinery 

would be used for building the Plant. The impacts are, however, short-term. 
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Compared with the Construction phase, fewer amounts of non-radioactive 

effluents are expected during the Operation phase and, thus, less impact is 

anticipated. Impacts during the Reclamation phase are short-term; and the 

amount of emission and particulates generated would be less than those from 

Mine Unit Development but more than those from Operation. Detailed 

discussions of non-radioactive emissions and particulates generated during the 

Project, as well as their potential impacts, are presented in Section 4.11. 

Radioactive Emissions 

Almost all of the expected radioactive emissions would occur during the 

Operation phase. There would be minimal radioactive emission, if any, during 

Construction, and limited amount during Reclamation. Radon would be the 

radioactive gaseous emission from ISR production and processing, as it is 

naturally present in the orebody and concentrated in the lixiviant solution. Radon 

would be released occasionally from the mine unit wells as gas is vented from the 

injection and production wells. Radon would also be released during ion 

exchange resin transfers and subsequent processing steps, as described in more 

detail below. Detailed discussions of radioactive emissions generated during the 

Project, as well as their potential impacts, are presented in Section 4.17. 

4.18.4.2 Liquid Wastes 

Most of the liquid wastes (in terms of both type and amount [Table 2.1-1]) would 

be generated during Operation. Table 4.18-1 summarizes the types of liquid 

wastes generated during the Project phases. 

Table 4.18-1 Summary of Liquid Wastes Generated during 

Different Phases of the Project 

Liquid Waste Construction Operation Reclamation 

Native Groundwater Yes Yes No 

Storm Water Runoff Yes Yes Yes 

Waste Petroleum Products and 

Chemicals Yes Yes Yes 

Domestic Sewage Yes Yes Yes 

11(e)(2) Byproduct Materials No Yes Yes 

“Native” Groundwater Recovered during Well Development, Sample 

Collection, and Pump Testing 

In Construction, groundwater is recovered during well installation, sample 

collection, and pump testing conducted prior to Operation or from portions of the 

Permit Area not affected by ISR operations. This “native” groundwater has not 

been exposed to any ISR process or chemicals. During well development, sample 

collection, and pump testing, this water would be discharged to the surface under 
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the provisions of a general WYPDES permit, in a manner that mitigates erosion, 

or reused in the drilling process. Because of the relatively small quantities of 

water discharged at any given time, no impacts are anticipated. 

Storm Water Runoff 

Throughout the Project, the storm water discharge permits applicable per the 

WYPDES would be maintained. The associated SWPPP would be implemented 

as part of LCI’s compliance with applicable WDEQ-WQD rules. A copy of the 

SWPPP is included as Attachment ADJ-3 of the WDEQ-LQD Permit to Mine 

(LCI, 2011b), and a copy would be in an accessible area at the site. /Because of 

the limited precipitation at the Permit Area, no impacts are anticipated. 

Waste Petroleum Products and Chemicals 

LCI would generate about 40 to 80 gallons of waste petroleum products per 

month, which would be periodically collected by a commercial business for 

recycling or energy recovery purposes. With respect to hazardous wastes, LCI 

would be a Conditionally Exempt Small Quantity Generator (CESQG), per EPA 

definition. About five to ten gallons of waste chemicals not immediately 

associated with laboratory operations would be generated per year. These waste 

chemicals would be periodically collected by a commercial business for recycling 

or disposal in a licensed disposal facility. As a CESQG, LCI could send the 

hazardous waste to the Sweetwater County District #1 Landfill in Rock Springs 

(Section 4.18.4.3). However, if recycling or reuse alternatives are available, 

those alternatives would be used to reduce the potential waste disposal impact. 

Waste chemicals typically associated with the laboratory operations would be 

captured in the drains and/or sumps within the laboratory and would go straight to 

Plant waste tanks for eventual deep well disposal. An estimated five to ten 

gallons of these waste chemicals would be disposed of per year. The impacts of 

the UIC Class I wells are discussed in Section 4.7. 

Domestic Sewage 

Domestic liquid waste would be disposed of in an approved septic system that 

meets the requirements of the WDEQ-WQD. A permit would be obtained for the 

septic system prior to construction of the system. The septic system would receive 

waste from the restrooms, shower facilities, and miscellaneous sinks located 

within the office. The septic system, which is also permitted by Sweetwater 

County, would be maintained by a licensed contractor. Given the lack of shallow 

groundwater at the site, the remote location, and the relatively small work force, 

impacts to the Permit Area would be limited. 
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In addition, chemical toilets may be temporarily placed at mine units and other 

drilling areas. The chemical toilets would be maintained by a licensed contractor, 

and no impacts are anticipated in the Permit Area. 

Liquid 11(e)(2) Byproduct Materials 

The three 11(e)(2) byproduct materials (liquid process wastes, ‘affected’ 

groundwater generated during well development, and groundwater generated 

during aquifer restoration) would be treated and disposed of on-site through the 

Storage Ponds and UIC Class I wells. Because of the controlled on-site disposal 

procedures, no impacts from the liquid process wastes, other than those associated 

with the UIC Class I wells, are anticipated in the Permit Area. The Storage Pond 

impacts and the UIC Class I well impacts are discussed in Section 4.7. 

The WDEQ has issued a permit to the applicant to drill, operate, and complete the 

UIC Class I wells in specific geologic formations. The permit specifies well 

construction, testing and operating conditions the applicant must follow to ensure 

adequate protection of the public and environmental health and safety. The 

permitted disposal rate is 250 gpm, based on a 50 gpm rate for each well. The 

maximum anticipated disposal rate based on the water balance for the Project is 

115 gpm. Therefore, even allowing for redundancy, there is sufficient disposal 

capacity for the Project. 

4.18.4.3 Solid Wastes 

Table 4.18-2 summarizes the solid wastes generated during the Project phases. 

Most solid wastes generated during Construction would be non-hazardous (Table 

2.1-1); no 11(e)(2) byproduct materials would be produced during Construction. 

Table 4.18-2 Summary of Solid Wastes Generated during Different 

Phases of the Project 

Solid Waste Construction Operation Reclamation 

Non-Hazardous Wastes Yes Yes Yes 

Hazardous Wastes Yes Yes Yes 

11(e)(2) Byproduct Materials No Yes Yes 

Non-Hazardous Solid Wastes 

During Construction, most solid wastes would be typical construction debris, 

including scrap metal, paper, wood, and plastic. Based on empirical assessments 

of non-residential construction debris (Franklin Associates, 1998), an estimated 

average weight to volume conversion rate of 100 for such debris (California 

Department of Resources Recycling and Recovery, 2001), and a construction area 

of 100,000 square feet, about 150 cubic yards of construction debris would be 

generated. (The Plant covers about 41,600 square feet, but because of the variety 
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of facilities, such as the Storage Ponds, a larger square footage was assumed.) 

During Operation, about 55 cubic yards of non-hazardous solid wastes would be 

generated each year (LCI, 2011b). During Reclamation, an estimated 1,400 cubic 

yards of non-hazardous materials would be generated (NRC, 2011a). 

The non-hazardous materials would be recycled when possible or temporarily 

stored in commercial bins prior to disposal by a contracted waste disposal 

operator at a licensed waste disposal facility. As noted in the NRC SEIS, “The 

closest location for disposal of non-hazardous solid wastes is the Carbon County 

landfill north of Rawlins, Wyoming”. . . “The municipal waste and the 

construction and demolition waste cells at the Carbon County landfill are not at or 

near capacity” (NRC, 2011a). The Rawlins Landfill has an anticipated life 

expectancy of 50 years, based on its current rates of waste disposal. The landfill 

does not accept liquid, industrial, or hazardous wastes. All wastes received at the 

landfill are disposed there, and no wastes are transferred to other facilities. 

Hazardous Solid Wastes 

Hazardous wastes, such as solvents, paints, used oil, batteries, and fluorescent 

bulbs, would be a significantly smaller percentage of the solid wastes generated 

during the Project than non-hazardous wastes. The closest location for disposal of 

hazardous solid wastes is the Rock Springs Landfill. As noted in the NRC SEIS, 

the facility has the capacity and is also in the process of permitting additional 

capacity that would expand the life of the landfill about 30 years (NRC, 2011a). 

Solid 11(e)(2) Byproduct Materials 

Solid 11(e)(2) byproduct materials would include process wastes, such as spent 

ion exchange resin, filter media, and tank sludge, generated during ISR and ore 

processing, and would include equipment that becomes contaminated during ISR 

and ore processing. These items include tanks, vessels, PPE, and process pipe 

and equipment. Such wastes could also include soils contaminated from spills. 

No solid 11(e)(2) byproduct materials would be generated during Construction. 

Approximately 80 to 100 cubic yards of solid 11(e)(2) by-product materials 

would be generated each year during Operation (LCI, 2011b), including 

maintenance and housekeeping items, such as cleaning equipment, replacement 

components, filters, protective clothing, solids removed from process pumps and 

vessels, and any soils or other materials that cannot be decontaminated. The 

annual amounts would be somewhat higher during reclamation of the mine units 

as the equipment from the mine units is taken out of service. The total estimated 

amount of 11(e)(2) byproduct material from the Project, including Reclamation, is 

estimated to be 4,000 cubic yards (NRC, 2011a). 

Where possible, equipment would be decontaminated for disposal as non-11(e)(2) 

byproduct material or for reuse. Equipment that cannot be decontaminated and 

process wastes would be placed in clearly labeled, covered containers and 
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temporarily stored in restricted areas with clearly visible radioactive warning 

signs. The materials would be temporarily stored on-site in containers called 

‘super-sacs’. Sacs that are full would be sealed and stored in secure areas in the 

Plant or outdoors in covered roll-off containers approved by the US DOT for 

transport of Low Specific Activity material until sufficient volume is generated 

for shipment to a facility that is licensed for treatment and/or disposal. Safe 

handling, storage, and disposal of decommissioning wastes are addressed in 

Sections 4.0 through 6.0 of the NRC Technical Report (LCI, 2010), and these 

procedures would be reviewed and updated, if necessary, in the decommissioning 

plan which must be submitted to NRC for review and approval prior to initiation 

of decommissioning activities. Because of the controlled off-site disposal 

procedures, no impacts from the non-hazardous solid waste disposal are 

anticipated in the Permit Area. 

The solid 11(e)(2) byproduct materials would be disposed off-site, at a facility 

licensed by the NRC to accept such wastes, by personnel qualified to dispose of 

such wastes. At present, LCI does not have an agreement with such a facility; 

however, prior to the start of operations, LCI would enter into a written agreement 

with a disposal site as required by the NRC. A licensed facility may be a uranium 

mill tailings impoundment, and the closest would be the Pathfinder Shirley Basin 

Facility in Wyoming. Other NRC-licensed facilities that can accept byproduct 

material for disposal include: the Rio Algom Ambrosia Lake facility near Grants, 

New Mexico; the Energy Solutions site in Clive, Utah; the White Mesa facility in 

Blanding, Utah; and the Waste Controls Specialists site in Andrews, Texas. 

4.18.5 Waste Disposal Impacts from Other Alternatives 

The No Action Alternative would not generate any of the ISR wastes and thus no 

impacts would be created. With respect to waste management, there are no 

significant differences in the anticipated impacts, or in the monitoring and 

mitigation, between the Proposed Action and the Other Action Alternatives 

described in Section 2.2. Slightly less solid waste, specifically fencing materials, 

would be generated if the pattern areas were not fenced. However, the difference 

in volume of solid waste, if the fencing material was disposed of rather than 

reused, is minimal compared to the overall Project. 

Processing wet yellowcake into a dry powder is not expected to change the nature 

or magnitude of waste disposal impacts as a vacuum dryer would be used. In a 

vacuum dryer, the heating system is isolated from the yellowcake so no 

radioactive materials are entrained in the heating system or its exhaust. The 

drying train would operate under a negative pressure to avoid atmospheric 

emissions, and drying would take place at relatively low temperatures. Emissions 

from the drying chamber would be normally treated through a bag filter to remove 

yellowcake particulates, and air from the bag filter dust collection system would 

typically be routed to the dryer offgas line and scrubber. A small volume of 

liquid effluent from the vacuum dryer would be cooled and condensed for 
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disposal as 11(e)(2) byproduct material in the UIC Class I wells; however, the 

volume would be minimal compared to the total volume of material from the 

Project. During loading of the dried yellowcake into a drum, the typical shipping 

container, the drum would also be kept under negative pressure via a drum hood 

with a suction line. The packaging area also has a bag filter dust collection 

system to protect personnel and to minimize yellowcake release. The vacuum 

drying equipment would need to be decommissioned in accordance with NRC 

requirements. Filters and dryer equipment that could not be decommissioned 

would be disposed of as solid 11(e)(2) byproduct material; however, the volume 

would be minimal compared to the total volume of material from the Project. 
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4.19 Mitigation Measures 

Mitigation includes specific means, measures, or practices that would reduce or 

eliminate effects of the Proposed Action or alternatives. The agency-required 

measures, LCI’s commitments and initiatives, and monitoring presented in the 

previous subsections of Section 4.0 would provide adequate protection of 

resources and mitigation of impacts from the Proposed Action and alternatives. 

No additional mitigation measures are identified. 

4.20 Residual Impacts 

Residual impacts are adverse effects that remain after mitigation measures have 

been applied. Since the agency-required measures, LCI’s commitments and 

initiatives, and monitoring presented in the previous subsections of Section 4.0

would provide adequate protection of resources and mitigation of impacts from 

the Proposed Action and alternatives, no additional mitigation measures were 

proposed in Section 4.19 (Mitigation Measures). Since no additional mitigation 

measures have been proposed, no residual impacts discussion is required. All 

impacts would remain as previously described in the subsections of Section 4.0. 

4.21 Irreversible and Irretrievable Commitments of Resources 

Irreversible commitments of resources are actions that disturb or remove a 

resource to the point that it can only be renewed over a long period of time 

(centuries). A resource is irreversibly committed when it cannot be restored or 

returned to its original or pre-disturbance condition and when it, its productivity 

or its utility would be consumed, committed, or lost forever. 

An irretrievable commitment of a resource directly removes the resource from 

availability or renders its productivity or utility lost for a period of time (e.g., 

closure of an area to resource extraction). An irretrievable commitment is the loss 

of opportunities for production or use of a renewable resource for a short to 

medium period of time (years). A resource is irretrievably committed when a 

decision results in the loss of production or future use of the resource. 

The removal of uranium from the subsurface would be an irreversible and 

irretrievable commitment of resources. While the uranium is irreversibly 

removed from the ground, it is also irretrievably committed to present-day uses 

rather than potential uses at some undetermined future time. Other irretrievably 

committed resources of the Proposed Action and alternatives include building 

materials, electricity, fuels, office supplies, and other products consumed during 

the Project. 
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While surface disturbing and disruptive activities of the Proposed Action and 

alternatives are considered an irretrievable commitment of resources during the 

Project life, the environmental protection measures required for the Proposed 

Action and alternatives would reduce or eliminate the magnitude of this 

irretrievable commitment of resources. In the long-term, however, the resource 

commitment of surface disturbing and disruptive activities would be retrievable. 

4.22 Relationship between Short-Term Uses and Long-Term 

Productivity 

The Proposed Action and alternatives would result in the potential for loss in 

long-term productivity; however, the required environmental protection measures 

for the Proposed Action and alternatives would minimize the effect of short-term 

uses on long-term productivity. 

The extracted uranium would support present-day objectives and not contribute to 

the national long-term productivity or production and use of uranium. Currently, 

the national nuclear energy industry (including domestic uranium production) is 

expanding to meet increasing energy demands, increased interest in energy 

security, and increased demand for alternative energy sources. At present, the US 

is importing most of the uranium used to fuel existing nuclear reactors in the 

country. Recent national programs, statutes, and initiatives include: 

x the Nuclear Power 2010 program of the US Department of Energy; 

x the Energy Policy Act of 2005; 

x the American Recovery and Reinvestment Act of 2009; 

x the Nuclear Energy Research Initiative; 

x Nuclear Energy University Programs; and 

x Generation IV Nuclear Energy Systems. 

The State of Wyoming is historically, culturally, and economically tied to the 

mining industry. With its long-standing mining background and the largest 

uranium reserves in the US, Wyoming is well-equipped to play a leading role in 

the nation’s uranium production. Uranium mining in Wyoming would not only 

help to diversify the nation’s energy sources, it would offset the boom and bust 

cycles of other Wyoming natural resource development industries through 

diversification. 

The short-term extraction of uranium would limit the long-term productivity of 

mineral resource extraction in the Permit Area at some point in the future. The 

uranium mineral resource remaining after the Proposed Action would be minimal 

since the Proposed Action anticipates at least an 80-percent recovery rate of the 

resource. However, other mineral resources could be discovered in economic 

quantities and recovered within the Permit Area in the future. 
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Present-day removal of uranium may indirectly improve long-term productivity 

by reducing the radioactivity of material associated with extracted uranium, 

thereby benefitting the health of humans and the environment by minimizing 

potential exposure.