DRC-2022-020222 - 0901a068810d1c98

State of Utah
SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL

Douglas J. Hansen
Director

M E M O R A N D U M

TO: Project FileC-2022-25

THROUGH: Phil Goble, Manager

FROM: Heather Mickelson, P.E., P.G.

DATE: July 6, 2022

SUBJECT: DWMRC Review of the 2022 Biennial Land Use Survey, Energy Fuels Resources
(USA) INC., White Mesa Mill, Radioactive Materials License No. UT1900479,
Amendment 10, Condition 12.3

Review Summary

The Utah Division of Waste Management and Radiation Control (DWMRC) has reviewed the
2022 Biennial Land Use Survey (Survey) submitted by Energy Fuels Resources (USA) INC.
(EFRI) for the five-kilometer radius surrounding the White Mesa Mill (Mill). The Survey was
dated June 23, 2022 and received by the DWMRC on June 27, 2022. The Survey was submitted
to comply with Condition 12.3 of the Radioactive Materials License No. UT1900479,
Amendment 10 (“License”).

License Condition 12.3

The licensee shall conduct a survey of land use (private residences, grazing areas, private and
public potable water and agricultural wells, non-residential structures and uses and assess
population growth or industry growth) in the area within five kilometers radius once every two
years of the White Mesa Uranium Mill facility property boundaries and submit a report of this
survey to the Director. The report shall be submitted on or before June 30 on even numbered
years. This report shall indicate any differences in land use from that described in the last report
including the following: 1) providing references and/or a description of methods utilized to obtain
information included in the report; 2) listing all water wells, owners, approved use, and contact
information within the specified search radius; and 3) including information on an updated land
use map to be included with the report. [Applicable UDWMRC Amendment: 8 Renewal]

July 6, 2022
Phil Goble 07/06/2022
Energy Fuels Resources (USA) Inc. 2022 Land Use Survey
Page 2

Survey Contents

The 2022 Survey reviews the current land use and then compares the land use from the 2020
Survey. The cover letter, tables, and lists, and maps were submitted via hard copy. All
information was submitted electronically, which contains high-resolution maps.

The submitted information included:
1. A cover letter describing the contents of the Survey.
2. A narrative describing the changes that have occurred since the 2020 Survey
3. Water Rights with Water Rights owner (Map and List), Land Use information including
Oil and Gas information (Map and List), Land Use Ownership (Map and List), Land Use
Map, (Map and List)
4. Population and job and industry information
5. References and Methods for Data Collection Table

DWMRC Review

Independent of the EFRI submittal, DWMRC staff performed a cursory review to verify the
completeness and accuracy of the submitted information.

It appears that all parcel boundaries, land ownership type, water wells, and oil and gas activities
were plotted on the submitted maps. In addition, changes from the 2020 Survey were verified.

A cursory review was performed to verify the accuracy and completeness of the submitted
information for water rights and well logs. This review consisted of querying the Utah Division
of Water Rights Website (http://maps.waterrights.utah.gov/asp/wrplatGE.asp) to obtain the
records for approximately 3.1 mile radius (16500 ft) from a point located 639 feet to the south
303 feet from the west from the Northwest corner, section 33, township 37S, range 22E, SL and
BM. This information was then compared to the submitted information.

DWMRC staff also reviewed oil and gas well information of the area surrounding the former mill
from the Utah Department of Natural Resources, Oil and Gas and Mining Division website
(https://datamining.ogm.utah.gov/).

Land ownership type and parcel boundaries were also reviewed and compared to submitted
information. This information was obtained from the Utah Automated Geographic Reference
Center (http://gis.utah.gov/data/sgid-cadastre/parcels/).

Land Use Survey Submission Conclusions

The 2022 Survey appears to comply with the requirements of License Condition 12.3. This is
based on the attached review of the survey with Ground Water Module 32 (Biennial Land Use
Survey Report Review).

Energy Fuels Resources (USA) Inc. 2022 Land Use Survey
Page 3

References

Energy Fuels Resources (USA) Inc., June 23, 2023, 2022 Biennial Land Use Survey

Utah Dept. of Environmental Quality, Radioactive Material License Number UT 1900479,
Amendment 10

Energy Fuels Resources (USA) Inc. 2022 Land Use Survey
Page 4

Appendix 1 – Energy Fuels Resources (USA) Inc, Module 32 Inspection Form

Energy Fuels Resources (USA) Inc. 2022 Land Use Survey
Page 5

Regulatory Requirements Inspected Against: Radioactive Materials License # UT 1900479, Amendment 10
Condition 12.3 dated July 27, 2021
Last Previous Inspection Date: 2020
Date of Current Inspection: 2022
Violations Recommended: Yes No Comments: NA

INSPECTION ITEM – Annual Land Use Survey (Ground Water Module 32):

Land Use Survey Requirements (Condition 21)

1. Report Submittal Date - Was the report submitted on or before June 30, 2022?
Yes No

Notes:
The survey (report, tables, lists, and electronic copy) was received on June 27, 2022 and was dated June 23,
2022.

2. Did the report include private residences, grazing areas, private and public potable water and
agricultural wells, and non-residential structures and uses within five kilometers (3.1 miles) of the
site boundary?
Yes No

Notes:
The survey included four maps titled: Water Rights Maps, Oil and Gas Wells Map, Land Ownership Map,
and Land Use Map. All maps are centered on the Mill with a line designating five kilometers from the
boundary of the Mill. In addition, tables supply additional information that corresponds to features on the
maps.

Two Water Rights Maps were submitted. The first shows the water right at the point of diversion for those
outside of the Mill’s boundary. The second shows the water right point of diversion inside of the Mill’s
boundary.

The Oil and Gas Wells Map shows many of the oil and gas wells types and a previous uranium mine.

The Land Ownership Map shows the type of ownership that includes Bureau of Land Management, Indian
Reservation, State, and Private.

The Land Use Map shows the structures and the grazing allotments. Residential and non-residential
structures are not differentiated. Previously identified structures are differentiated from new structures
identified in 2022 Survey. Grazing allotments have not changed since the 2020 Survey.

Utah Division of Waste Management and Radiation Control Inspection Form
Ground Water Module 32 (Biennial Land Use Survey Report Review)
Energy Fuels Resources (USA) Inc.
Energy Fuels Resources (USA) Inc. 2022 Land Use Survey
Page 6

3. Were those items listed above appropriately plotted on the Annual Land Use Map?
Yes No

Notes:
DWMRC notes that the electronic and hard copy versions of the maps in the survey are plotted at an
appropriate scale and that they are provided in sufficient resolution to allow viewing of a large size. It is
possible to zoom in and out of the electronic maps and the hard copy map information is easily accessible.

4. Did the plotted wells include references and/or a description of methods utilized to obtain all
information included in the report?
Yes No

Notes:

A table that references the data collection method and source was included in the submittal. Additional
information is also given on the figures.

Data collection occurred April to June 2022 and was obtained using publicly available sources. Data used
in the Survey are the most current available.

5. Did all plotted items include contact information?
Yes No

Notes:
The plotted identification numbers on the on the maps are included in spreadsheets listing the oil and gas
well operators, the names and phone numbers for water well owners, and the mailing address of property
owners.

6. Did the survey include well identification numbers that could be used to correlate the plotted well
locations with contact listings?
Yes No

Notes:
The water, oil and gas well, and parcel identification numbers on the maps correlate with those on their
respective table.

7. Did the survey include the approved use for the plotted wells?
Yes No

Notes:
Different types of oil and gas wells are differentiated and a previous uranium mine are shown on the Oil and
Gas Wells Map. The status of the oil and gas wells are listed. These include oil well - location abandoned,
dry hole-plugged, well type unknown – plugged and abandoned, and oil well -plugged and abandoned.

Water wells with active water rights and the intended water use were included on the Water Rights maps
Energy Fuels Resources (USA) Inc. 2022 Land Use Survey
Page 7

and Water Well Owner List. Potential water use types are: domestic, irrigation, municipal, stock watering.

The DWR no longer includes non-production application use in their search results. The 2022 Survey does
not include these wells on the 2022 Water Well Owner list.

The water right changes that occurred between 2020 and 2022 are listed on Table 1b. List of Additions and
Subtractions from 2020 Water Well Owner List to Table 1a 20222 Well Owner List.

It is noted that the Figure 1a incorrectly states the time period wells were added. The figure states that the
“Wells added since 2018”. This statement should read “Wells added since 2020”. However, the map was
correctly changed to show the new water rights locations and removed water rights. Submittal of a
corrected map is not necessary.

8. Are differences in land use from the previous survey discussed in the survey?
Yes No

Notes:
Differences between the 2022 and the 2020 Survey’s were identified. There were no changes in oil and gas
production or land use. New structures, water right changes, and land ownership changes were identified.

9. Do any of these changes represent a concern with regard to ground water at the Mill property?
Yes No

Notes:
Six new non-Energy Fuels Resources (USA) Inc. wells have been installed since 2020. These wells are east
and southwest of the Mill’s boundaries. One Water Right that was north of the Mill’s boundary has lapsed..
Three new Energy Fuels Resources (USA) Inc. monitoring wells have been installed within the Mill’s
boundaries.

10. Additional Records Requested/Inspected:

Population and industry growth were also evaluated. The 2022 population, based on the 2020 census, in
Blanding is 4,036, White Mesa is 380, and Montezuma Creek is 386.

The economy of San Juan County employs approximately 5,694. The largest industries are health care and
social assistance, educational services, and construction. The highest paying industries in San Juan County
are mining, quarrying, and oil and gas extraction; utilities; and transportation and warehousing.

The economy of Blanding employs approximately 1,590. The largest industries are educational services,
health care and social assistance, and retail trade. The highest paying industries in Blanding are mining,
quarrying, and oil and gas extraction; agriculture, forestry, fishing, and hunting; and manufacturing.

Inspection Staff: Heather Mickelson
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Signature:
Email:[e-mail]