DRC-2024-005583

Uranium Watch
P.O. Box 1112
Moab, Utah 84532
435-26O-8384
May 6, 2024
Doug Hansen, Director
Utah Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, Utah 84114-4880
[e-mail]
RE: Request for Meeting regarding White Mesa Mill Rare Earth Processing.
License No. UT1900479
Dear Mr. Hansen:
Uranium Watch requests a virtual meeting with Division of Waste Management and
Radiation Control (DWMRC, of Division) Staff to get clarification regarding the
processing of rare earth element concentrates to separate individual rare earth elements or
oxides at the White Mesa Uranium Mill (Radioactive Materials License No.
UT1900479). Below is background information and some questions that I have.
INTRODUCTION
Proposed Meeting with staff of the Division to discuss the developments at the White
Mesa Uranium Mill related to the processing of monazite ore to recover uranium and rare
earth elements.
Energy Fuels Resources (USA) Inc. (EFRI), a United States subsidiary of the Canadian
company Energy Fuels Inc. (EFI), has been processing monazite ore from the State of
Georgia to recover uranium and to produce a rare earth element (REE) concentrate. EFRI
is also developing the capabilities for further separation of individual rare earth elements
or oxides from the concentrate. This processing and recent Mill construction is
documented in EFRI Safety and Environmental Review Panel (SERP) Annual Reports
for 2021 and 2022, submitted to the Division. EFRI did not have any construction to
report in their SERP Report for 2023. Additional information about this processing is
found in EFI News Releases and Interim and Annual U.S. Securities Exchange 1
https://www.energyfuels.com/news-releases1
Doug Hansen/DWMRC
May 6, 2024
2
Commission (SEC) 10-K Reports and Management’s Discussion and Analysis (MD&A
Reports) submitted to the Canadian Securities Administrators.2
There are some factual, legal, and regulatory issues related to the construction of new
processing circuits to separate individual rare earth elements and oxides that need to be
clarified.
RECENT EFI STATEMENTS
• LAKEWOOD, Colo., May 3, 2024. Energy Fuels Announces Q1-2024 Results,
Including Continued Net Income, Continued Successful Uranium Ramp-Up,
Commissioning Rare Earth Oxides Production, and Steps to Secure World-Scale Sources
of Heavy Mineral Sands and Monazite3

Rare Earth Element Ramp-Up:
•The Mill's REE production is complementary to its uranium production and does
not diminish the Mill's uranium capacity or production profile in any way.
•The development of the "Phase 1" REE Separation circuit at the Mill was
completed on-schedule at the end of Q1-2024, at a cost that is expected to be $7
million to $9 million below the $25 million budget.
•During Q2-2024, the Company expects to produce about 25 – 35 tonnes of
separated neodymium praseodymium ("NdPr") oxide and 10 to 20 tonnes of a
"heavy" samarium plus ("SM+") mixed rare earth carbonate as it commissions
the Phase 1 REE Separation circuit, after which time the Company expects to
begin processing uranium ore and alternate feed materials for the large-scale
production of uranium at the Mill for the remainder of the year and through
mid-2026.
•The Mill's Phase 1 REE separation circuit is expected to have the capacity to
produce approximately 800 to 1,000 tonnes of separated NdPr oxide per year. For
reference, 1,000 tonnes of NdPr can be used in enough permanent REE magnets
to power up to 1 million electric vehicles  ("EVs") per year. Subject to securing
sufficient monazite feed, "Phase 1" capacity is expected to position Energy Fuels
in the coming years as one of the world's leading producers of separated NdPr
outside of China.
•Due to the significant opportunity in REEs, Energy Fuels is engineering further
enhancements at the Mill to increase NdPr oxide production capacity to
approximately 4,000 tonnes – 6,000 tonnes per year by 2027 ("Phase 2"), and to
https://www.sedarplus.ca/landingpage/2
https://www.energyfuels.com/news-releases3
Doug Hansen/DWMRC
May 6, 2024
3
add a separate crack and leach circuit to allow for the simultaneous operation of
the Mill's conventional ore and REE processing circuits. The Company also
intends to produce separated dysprosium ("Dy"), terbium ("Tb") and potentially
other advanced REE materials in the future from monazite and potentially other
REE process streams by 2028 ("Phase 3"). Phase 2 and Phase 3 are subject to
permitting, financing and receipt of sufficient monazite feed.
• ENERGY FUELS INC. United States Securities and Exchange Commission,
Washington, 20549. FORM 10-Q. Quarterly Report Pursuant to Section 13 OR 15(d) of
The Securities Exchange Act of 1934. For the quarterly period ended March 31, 2024.4
Mill Activities
During the three months ended March 31, 2024, the Mill focused on development
of its Phase 1 REE separation circuit, which upon successful commissioning will
be capable of producing separated NdPr and a “heavies” samarium plus
(“Sm+”) RE Carbonate. The Company purchased an additional 480 tonnes of
monazite from Chemours in late 2023 that it received in early 2024, which the
Company expects to process for the recovery of 25 – 35 tonnes of separated NdPr
oxide and 10 – 20 tonnes of Sm+ RE Carbonate, along with uranium, in 2024
upon commissioning of the Mill’s Phase 1 REE separation circuit, which is
expected to be completed in Q2-2024 (see “Rare Earth Element Initiatives”
below). After completion of this REE production, which is expected to be in
Q2-2024, the Mill will turn to uranium production for the remainder of 2024. No
vanadium production is currently planned during 2024, though the Company
continually monitors its inventory and vanadium markets to guide future potential
vanadium production. (Page 30)
• An April 22 Investor Presentation and the May 6, 2024, Investor Call and Presentation5
provided additional information on the current status of the production of separated rare
earth oxides at the Mill. EFRI has completed Phase I SX Plant for the separation of
neodymium praseodymium (“NdPr”).
REGULATION OF REE PROCESSING
EFRI has never submitted a license amendment application related to the construction of
a processing circuit to separate individual rare earth elements from a rare earth
concentrate. There is no technical information related to the processing circuit. The
November 7, 2023, letter from the Division in response to my October 13, 2023, letter
regarding the processing of a rare earth concentrate for individual rare earth elements
states: “Rare earth minerals are not radioactive and using a solvent extraction process to
https://www.energyfuels.com/sec-filings4
https://filecache.investorroom.com/mr5ircnw_energyfuels/1214/5
Project%20Latte%20Investor%20Presentation%20-%204.22.2024%20v19_FINAL.pdf
Doug Hansen/DWMRC
May 6, 2024
4
recover individual minerals does not fall under the uranium recovery radioactive material
license. Therefore, a license amendment is not required for this activity.”
In Utah, mineral processing, other than the processing of uranium and/or thorium ore in a
licensed uranium mill, is regulated by the Utah Division of Oil, Gas & Mining (DOGM),
if the processing occurs at the same site as the mineral extraction. The monazite ore and
other monazite ores that EFRI expects to process at the Mill for uranium and rare earth
elements are not mined at the White Mesa Mill site. So, it appears that the processing of
a rare earth concentrate for its individual rare earth elements, would not fall under the
Utah DOGM regulations and regulatory program.
Although EFRI has mentioned possible license amendment requests associated with rare
earth processing, as far as I know, no related license amendments have been submitted to
the DWMRC. As a result, there is little technical information about the processes used to
produce rare earth element oxides from a rare earth concentrate. There are questions—
but no answers— about rare earth processing and the wastes produced from such
processing at the White Mesa Mill.
QUESTIONS
•What exactly is going on at the White Mesa Mill with respect the processing of rare
earth element concentrates to separate out individual rare earth elements or rare earth
oxides?
•What original materials and chemicals are used in the Phase 1 Rare Earth Element
separation circuit to produce a separated neodymium praseodymium (NdPr) and a
“heavies” samarium plus (“Sm+”) Rare Earth Carbonate?
•What are the wastes produced in the Phase 1 Rare Earth Element separation circuit to
produce a separated neodymium praseodymium (NdPr) and a “heavies” samarium plus
(“Sm+”) Rare Earth Carbonate? Where are these wastes stored and disposed of?
•What chemicals and other materials will be used to process a rare earth concentrate into
other individual rare earth oxides or rare earth products?
•What wastes will be produced by this rare earth concentrate separation processing to
produce individual rare earth oxides. Where will these wastes be stored and disposed
of?
•Which Utah State and federal regulations apply to the processing of a rare earth
concentrate to produce individual rare earth oxides at the White Mesa Mill?
•How is the recently completed "Phase 1" REE Separation circuit different from the
Circuit it replaced?
Doug Hansen/DWMRC
May 6, 2024
5
Thank you for your response to this request. Please let me know if you have any
questions.
Sincerely,
/s/
Sarah Fields
cc: Stevie Norcross, DWMRC
Adam Wingate, DWMRC