Overview of the Draft Environmental Impact Statement for the Silver Peak Lithium Operation Expansion.
Just a few miles from the California-Nevada border in the high desert of Esmeralda County lies a stretch of irregularly shaped ponds that range in color from pale blue to turquoise. Since 1965, these ponds have produced lithium, the lightest metal known to man, and after the Kings Mountain Mine in North Carolina closed in 1988, followed by the shutdown of its facilities in 1991, they became the United States’ only site for lithium from primary sources.
Silver Peak first commenced operations as a project owned and operated by Leprechaun Mining Company. After several changes in ownership, the site is now owned and operated by Albemarle Corporation, which in 2022 submitted a revised Mining Plan of Operations to detail the expansion they were planning.
These changes would include new additions as well as actions that were previously completed without proper authorization, which the Amended Plan of Operations (APO) seeks to have formally approved. The proposed APO would reconcile approximately 938 acres of existing but previously unauthorized disturbance and add an expansion of about 658 acres. Together, these areas would increase the total authorized disturbance by 1,596 acres, bringing it to 8,058 acres.
The reconciliation disturbance covers 168 acres of private land and 770 acres of BLM-administered land and includes the following facilities:
Two impoundments, which are engineered ponds used to store brine
A transfer pump station and additional piping infrastructure
A 1.6-mile-long conveyance trench
The expansion disturbance includes 375 acres of private land and 283 acres of BLM-administered land and would consist of:
Two transfer pump stations and related pipelines
Two weak brine ponds
Future production well drilling
The expansion of the project onto additional BLM land triggered the need for an Environmental Impact Statement (EIS). Before the completion of the draft, recent changes to NEPA review procedures implemented by the Trump Administration had established new rules and guidelines. Under these rules, evaluating the social cost of greenhouse gases or environmental justice was not legally required to make a NEPA decision, so these analyses are not included in the draft EIS.
An interim final rule updating NEPA procedures was published by the Department of Interior on July 3, 2025. However, because the Silver Peak project review was already underway and the Notice of Intent (NOI) had been published prior to this rule, the EIS follows the earlier regulations in 43 CFR Part 46 and Part 516 of the Department Manual rather than the updated procedures.
The proposed changes to the Silver Peak Lithium Operations (SPLO) are intended to improve site efficiency and provide more flexibility in lithium production, which can have a lead time of six months to a year due to the nature of the harvesting process. These changes do not affect the estimated 30-year remaining life of the site or increase lithium production.
Lithium at SPLO is harvested from brine through a solar evaporation process. Lithium-rich brine is pumped from underground aquifers into a series of evaporation ponds. It first enters weak brine ponds, where solar evaporation gradually increases lithium concentration. The brine then flows into strong brine ponds, where lithium is further concentrated and leasable minerals precipitate. The brine in the final pond of the strong brine complex is then pumped via a transfer pump and 8-inch pipeline to the existing final reservoir pond. Over time, the precipitated minerals are removed using SPLO’s existing salt stockpiling methods.
Two new weak brine ponds, designated as 12W and 13N, would be constructed, covering 269 acres and 261 acres respectively. These ponds, along with the other currently active weak brine ponds, serve as early-stage solar evaporation ponds. The brine remains in these ponds until it reaches concentrations sufficient for magnesium removal through the liming process.
The liming process involves adding slaked lime (calcium hydroxide) to the brine, which reacts with magnesium to produce magnesium hydroxide and calcium sulfate as byproducts. By expanding the weak brine system, the project increases natural evaporation capacity and overall site efficiency.
The lithium in the brine at SPLO is considered a locatable mineral under federal mining law. The other minerals that precipitate during the evaporation process, primarily sodium, potassium, and magnesium salts, are classified as leasable minerals. These minerals have been stockpiled within the project area for use by the United States and the BLM Nevada State Office at a future date following completion of lithium mining operations.
As part of the APO, Albemarle would continue limited surface disturbance to drill new wells as existing production wells fail. Failed wells would be converted to monitoring wells, if permitted, or properly plugged and abandoned. Concurrent reclamation would be conducted where practical.
Each well pad would cover approximately 150 by 200 feet (0.69 acre), though exact locations are not yet determined. Pads would use material from Albemarle’s borrow pits, and well construction would follow NAC 534 standards for construction, compliance, contamination prevention, and suspension of drilling activities.
Albemarle’s predecessors acquired water rights for 20,000 acre-feet of brine annually, representing the perennial yield of the Clayton Valley Hydrographic Basin. All of Albemarle’s rights are granted and administered by the Nevada State Engineer and remain in good standing. Albemarle continues to expand brine production by rehabilitating existing wells and drilling new production wells to use the full permitted 20,000 acre-feet annually. The Proposed Action would not change current water use or operating conditions.
Currently, the site’s Air Quality II Operating Permit caps production at 10,950 tons of lithium carbonate per year. None of the proposed changes would increase the capacity of the processing facility, only efficiency and flexibility in overall operations.
Because of the number of proposed projects within 50 miles of Silver Peak, there is strong interest in the potential environmental and social impacts that may arise in NEPA reviews for that region. While the Silver Peak EIS may not cover every issue relevant to other projects, and some issues may not relate at all, the analyses it does include can provide investors with valuable insight into what to expect for the project in which they are invested.
Air Quality:
During construction, operation, and reclamation, air pollutant concentrations in the Air Quality Analysis Area would increase above current levels but remain within applicable standards. Following mine closure and successful reclamation, emissions would cease, and no long-term irreversible impacts would occur. While construction would cause temporary, irretrievable air quality impacts, the Project would not result in an irreversible commitment of air quality or greenhouse gas resources, as emissions would end after the eight-month construction period.
Cultural Resources:
No archaeological sites are within the area of the Proposed Action; therefore, the Project would have no adverse effect on historic properties.
Socioeconomic:
The construction of the Proposed Action is expected to last approximately 8 months and would require fewer than 50 workers drawn from the existing SPLO workforce or local contractors. Consequently, the potential commitment of resources affecting socioeconomic conditions would be limited to the existing SPLO workforce. No irretrievable or irreversible commitment of resources to general socioeconomic conditions is anticipated.
Water Resources:
The lithium-bearing brine at SPLO comes from six confined and semi-confined aquifer systems: the Tula, Salt, Marginal Gravel, Main Ash, Lower Ash, and Lower Gravel aquifers. All six aquifers have been tapped for lithium extraction over the life of the project. The Main Ash aquifer is the most developed, with 94 production wells drilled since the 1960s. As additional aquifers were identified, production wells were added to target them.
Overall, SPLO has drilled 160 exploration wells and 258 production wells, with 69 production wells currently active. The site’s WPCP allows for up to 17.86 million gallons of lithium brine per day, which closely matches SPLO’s 20,000-acre-feet annual groundwater rights.
Freshwater
There are no known freshwater sources in the Project Area. Both the company and Esmeralda County have freshwater wells approximately 2 miles southwest of the Silver Peak community, on the playa margins. The freshwater wells are located topographically higher than the Project Area and are considered up gradient of operations.
The water supply for SPLO is derived mostly from two site-owned and operated freshwater wells, primarily used for processing in the plant. In other areas where potable water is needed, the Esmeralda County water supply is used. All of Albemarle’s water rights were granted and are administered by the Nevada State Engineer, and Albemarle’s permitted and certificated rights remain in good standing. Albemarle continues to expand brine production by rehabilitating existing wells and drilling new production wells to use their full permitted 20,000 AFY.
Surface Water
There are no permanent surface water bodies within the playa, but there are dry ephemeral washes leading from the mountain ranges to the valley floor. Flow in these washes occurs only after significant rainfall events, with water evaporating or infiltrating into the groundwater before or upon reaching the playa.
Groundwater
Since no new water rights are being sought as part of the Proposed Action, and pumping at the facility would not change with construction and implementation, impacts on groundwater resources are expected to be negligible, long-term, and regional. Solar evapotranspiration is the natural system by which groundwater exits the playa and is also necessary for concentrating lithium brine in the ponds at SPLO. Since the Proposed Action would not increase groundwater withdrawal, the proposed improvements would not alter the existing Clayton Valley Hydrographic Basin.
Noxious Weeds and Invasive Non-Native Species:
Two invasive weeds, tamarisk and halogeton, occur in the Project Area.
Tamarisk establishes along watercourses and rangelands, survives in arid environments, and can dominate depending on water and climate.
Halogeton is a saline-tolerant annual that produces toxic sodium oxalate, posing risks to livestock, and thrives in disturbed soils; it was observed throughout the Project Area, especially along road berms.
Within the Noxious Weeds Analysis Area, their effects are negligible. With less than 1% vegetation cover in the Project Area, plant communities would not be substantially altered, and no measurable effect on biological value or distribution is anticipated.
Migratory Birds and Raptors:
Recorded Groups (2020–2024)
Shorebirds
Diving birds
Wading birds
Gulls and terns
Waterfowl
Raptors (1 undetermined in 2023)
Eight Most Common Species (~95% of ~361,000 annual observations)
Eared grebe (Podiceps nigricollis) – 26%
Ruddy duck (Oxyura jamaicensis) – 23%
Red-necked phalarope (Phalaropus lobatus) – 16%
Wilson’s phalarope (Phalaropus tricolor) – 14%
American avocet (Recurvirostra americana) – 8%
Western sandpiper (Calidris mauri) – 4%
California gull (Larus californicus) – 3%
Least sandpiper (Calidris minutilla) – 1%
Breeding Observations
American avocet (chicks observed)
Western snowy plover (Anarhynchus nivosus) (chicks observed)
Seasonal Patterns
Peak activity in April and September (migration)
Yearly variation due to migration and breeding cycles
Special Status Avian Species (BLM sensitive, moderate to high potential)
Bank swallow (Riparia riparia)
Common nighthawk (Chordeiles minor)
Golden eagle
Loggerhead shrike (Lanius ludovicianus)
Long-billed curlew (Numenius americanus)
Peregrine falcon (Falco peregrinus)
Western snowy plover (Anarhynchus nivosus nivosus)
Weak Brine Ponds
Potential effects: minor habitat loss, fragmentation, vehicle collisions, chemical exposure, and noise/disturbance
Total surface disturbance: 1,596 acres (adjacent to existing facilities, low-value habitat)
Impacts expected to be minimal
Low-TDS ponds increase foraging, loafing, and nesting habitat for waterbirds
Strong Brine Ponds
Can be harmful or fatal to exposed birds
Impacts: long-term, localized, potentially substantially adverse
Avian Protection Plan (APP) used for mitigation (hazing, monitoring, rehabilitation)
Low recorded mortality: 0.01% (2018), 0.04% (2019)
Expansion ponds will follow same mitigation measures; impacts expected to remain not substantially adverse
Raptors and Eagles
2019–2020 surveys: no occupied golden eagle or raptor nests in Project Area or 4-mile buffer
1 deteriorated golden eagle nest (3.9 miles NE) – inactive for several years
1 unoccupied nest (2.9 miles W) – condition good but no species confirmed
Special Status Wildlife, ESA-Listed Species, and Plants
Special Status Wildlife
152 wildlife species in Nevada are listed as BLM sensitive (BLM 2023). 25 species were identified as potentially occurring in the Project Area; five have moderate or high potential:
Desert kangaroo rat (Dipodomys deserti)
Pale kangaroo mouse (Microdipodops pallidus)
Merriam’s shrew (Sorex merriami)
Townsend’s big-eared bat (Corynorhinus townsendii)
Western small-footed myotis (Myotis ciliolabrum)
Amphibians, fish, aquatic macroinvertebrates, reptiles, and insects are unlikely due to high salinity of evaporation ponds and barren playa conditions.
The Proposed Action would disturb 1,596 acres, but habitat fragmentation is minimal. Loss of playa has no substantial adverse effects, and creation of low-TDS ponds may enhance habitat for waterbirds.
Bats may experience minor, short-term, localized disturbance from daytime construction, but foraging habitat could increase with additional ponds. No roosting resources are expected to be affected within 0.25 mile of the Project.
ESA-Listed Species
Bi-State DPS of greater sage-grouse: no suitable habitat in or near the Project Area.
Monarch butterfly: no milkweed or nectar sources observed; presence in the Project Area is unlikely.
Fish Lake Valley tui chub: no suitable habitat within the Project Area.
No substantial adverse impacts are expected for these ESA-listed species.
Special Status Plants
Two species with potential to occur near the Project Area:
Tiehm’s buckwheat (Eriogonum tiehmii)
Candelaria blazingstar (Mentzelia candelariae)
Site surveys found no special status plant species within the Project Area. Vegetation cover is sparse (<1%), mainly iodinebush, horned seablite, and fourwing saltbush. No substantial direct or indirect adverse impacts are anticipated.
Noise:
There are no known sensitive noise receptors for wildlife within the Noise Analysis Area. The closest potential human receptor to Project-generated noise is the town of Silver Peak. The westernmost boundary of the APO is approximately 200 feet south of the town of Silver Peak; however, the Project reconciliation and expansion areas are located much farther away, approximately 8,450 feet east of the town of Silver Peak.
Native American Religious Concerns:
The BLM provided Tribes with an invitation to the Project NEPA kickoff meeting in December 2023. The BLM will continue to coordinate and consult with Tribes with ancestral connections to the Project Area.
Concerns have not been raised by consulted Tribes regarding this Project, and no sites eligible for the NRHP exist within the Project Area, hence no irretrievable and irreversible commitment of resources are anticipated for Native American Religious Concerns with the Proposed Action.
Hazardous and Solid Waste:
Overall, based on the small quantities of hazardous waste that would be generated by the Proposed Action, an accident resulting in a release to the environment during transportation from the Proposed Action area is not anticipated. Additionally, implementation of Albemarle’s SHWMP, Emergency Response Plan, and Applicant-committed EPMs HAZ-1, HAZ-2, and HAZ-3 would further minimize the risk of impacts should a spill or release occur.
Visual Resources:
The Proposed Action is unlikely to attract attention from sensitive viewers due to distance and topography. Planed activities are 2 to 4 miles from Silver Peak and 2 miles from the nearest public road. Temporary visual impacts from construction staff and equipment are expected but minimal, given existing disturbance and the Project’s small scale.
Paleontological Resources:
The Proposed Action covers 1,596 acres, including the reconciliation and expansion areas, which are mapped with Playa, Lakebed, and Flood Plain Deposits with low to moderate paleontological potential. Excavation for ponds, trenches, and associated infrastructure generally reaches less than five feet below the ground surface and remains within sediments of low potential. Impacts from prior disturbance, continued pond use, and expansion activities are therefore negligible.
Current and future production wells, drilled to depths between 300 and 1,950 feet below the ground surface, primarily target basin infill deposits with low paleontological potential. Each well pad disturbs an area of approximately 150 by 200 feet and is expected to remain within younger sediments. Minimal drilling may reach older sediments or bedrock with moderate to high paleontological potential, but the limited diameter of the drilled holes would result in minor impacts. Overall, ground disturbance across the reconciliation areas, expansion areas, and well activities is expected to have negligible effects on paleontological resources.
Soils:
Surface disturbance can affect soils by changing their physical, chemical, or biological properties. In the Project Area, soils would be disturbed by construction and operations, but impacts are expected to be minimal because playa soils are poor in quality and productivity. Playa soils are saline and mostly barren, though they do help manage water in the watershed. Best management practices would reduce overall disturbance, erosion, and contamination.
About 1,596 acres of soils would be affected. Most of this comes from existing ponds (904 acres) and new expansion ponds (658 acres), causing minor, long-term, localized impacts. Salt piles cover 34 acres and would also experience minor, permanent effects. About 5 acres are associated with pump systems, trenches, and well pads; these would have minor, long-term effects but would be removed during reclamation.
After mining, ponds would be abandoned by stabilizing embankments and outflows, salt piles graded and left to harden, and equipment removed. Playa surfaces would not be revegetated, and soils would not be reused for topsoil. Reclamation would cause negligible to minor short-term impacts. Albemarle will prepare a detailed reclamation plan with the BLM before mine closure.
Vegetation:
Construction would remove plants and disturb soils, but because the playa is barren, vegetation loss would be minor. Reclamation would focus on playa margins, with revegetation coordinated with the BLM and Nevada Division of Environmental Protection as needed. Direct impacts are expected to be minimal.
Indirect impacts from dust could reduce plant growth and increase susceptibility to invasive weeds. These effects would be short-term and minimized through soil stabilization, weed control, and reclamation measures.
The EIS and all related documents can be found on the BLM website https://eplanning.blm.gov/eplanning-ui/project/2035664/570
DISCLAIMER: This article should not be construed as an offering of investment advice, nor should any statements (by the author or by other persons and/or entities that the author has included) in this article be taken as investment advice or recommendations of any investment strategy. The information in this article is for educational purposes only. The author did not receive compensation from any of the companies mentioned to be included in the article.
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