DRC-2024-006281

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 File C-2024-25
THROUGH: Adam Wingate, Uranium Recovery Manager
Ryan Johnson, P.G., Health Physicist, Uranium Recovery Section
FROM: Heather Mickelson, P.E., P.G., Uranium Recovery Section
DATE: July 17, 2024
SUBJECT:DWMRC Review of the 2024 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
White Mesa Uranium Mill 2024 Land Use Survey Report (Survey) (DRC-2024-006072) submitted
by Energy Fuels Resources (USA) INC. (EFRI) for the five-kilometer radius surrounding the
White Mesa Mill (Mill). The Survey, dated June 24, 2024, was received by the DWMRC on June
27, 2024. The Survey was submitted to comply with Condition 12.3 of the Radioactive Materials
License No. UT1900479, Amendment 10 (“License”) (DRC-2021-005164).
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]
Energy Fuels Resources (USA) Inc. 2024 Land Use Survey Report
Page 2
Survey Contents
The 2024 Survey reviews the current land use and then compares the land use from the 2022
Survey (DRC-2022-015987). 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 between the 2022 and 2024 Survey;
3. Water rights information, including maps with lists of owners, land use information,
including oil and gas details, ownership and land use type;
4. Population and industry information; and
5. References and methods for data collection.

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 2022 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 2024 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. 2024 Land Use Survey Report
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References
Energy Fuels Resources (USA) Inc., June 24, 2023, White Mesa Uranium Mill 2024 Land Use
Survey Report (DRC-2024-006072)
Utah Dept. of Environmental Quality, Radioactive Material License Number UT 1900479,
Amendment 10 (DRC-2021-005164)
Energy Fuels Resources (USA) Inc. 2024 Land Use Survey Report
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Appendix 1 – Energy Fuels Resources (USA) Inc, Module 32 Inspection Form
Energy Fuels Resources (USA) Inc. 2024 Land Use Survey Report
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Regulatory Requirements Inspected Against: Radioactive Materials License # UT 1900479, Amendment 10
Condition 12.3 dated July 27, 2021
Last Previous Inspection Date: 2022
Date of Current Inspection: 2024
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, 2024?
Yes No
Notes:
The survey (report, tables, lists, and electronic copy) was received on June 27, 2024 and was dated June 24,
2024.

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 (all abandoned) and a past producing
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.
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. 2024 Land Use Survey Report
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 March to April 2024 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
and Water Well Owner List. Potential water use types are: domestic, irrigation, municipal, stock watering.
Energy Fuels Resources (USA) Inc. 2024 Land Use Survey Report
Page 7
The DWR no longer includes non-production application use in their search results. However, it is still
possible to find them by selecting test wells as a search criterion. The 2022 Survey does not include these
wells on the 2022 Water Well Owner list.
The current water rights are listed on Table 1a. List of Additions and Subtractions from 2022 Water Well
Owner List to Table 1a 2024 Well Owner List.

8. Are differences in land use from the previous survey discussed in the survey?
Yes No
Notes:
Differences between the 2022 and the 2024 Survey’s were identified. There were no changes in oil and gas
production, land use, pr grazing allotments. 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:
Eight new non-Energy Fuels Resources (USA) Inc. wells have been installed since 2022. Three of these
wells are producing wells and five are non-producing wells. These wells are located north and east of the
Mill’s boundaries. One Energy Fuels Resources (USA) Inc. monitoring well has been installed within the
Mill’s boundaries.

10. Additional Records Requested/Inspected:

Between the April decennial surveys, the Census Bureau's Population Estimates Program produces and
disseminates the official estimates of the population for the nation, states, counties, cities, and towns and
estimates of housing units for states and counties. The most recently available population estimates are
from 2022, which were released on December 7, 2023. Population estimates for the 2023 calendar year are
expected to be released December 12, 2024.
Location Population Estimates
(2022)2
Population
Estimates (2021) 2
Population Estimates
(2020) 2
San Juan County 14,358 14,610 15,295
Blanding City 3,345 3,343 3,594
White Mesa CDP1 60 104 138
Bluff 123 124 150
Montezuma Creek CDP1 272 303 324
Tselakai Dezza CDP1 95 75 51
1 A census designated place (CDP) is a statistical geography representing closely settled, unincorporated communities that are
locally recognized and identified by name. (https://www.census.gov/programs-surveys/bas/information/cdp.html, accessed July 15,
2024)
2Data from the United States Census Bureau (https://data.census.gov/table, accessed July 15, 2024)
San Juan County and Blanding City economies employs approximately 5,946 and 1,297, respectively
(https://data.census.gov/table, accessed July 15, 2024). The industries with the greatest number of
employees for San Juan County and Blanding City are educational services, and health care and social
assistance; arts, entertainment, and recreation and accommodation and food services; and retail trade.
Energy Fuels Resources (USA) Inc. 2024 Land Use Survey Report
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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
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