DRC-2025-002088

June 30, 2025
Dr. Chris Merritt
Deputy SHPO - Archaeology
Division of State History
300 Rio Grande
Salt Lake City, Utah 84101
RE: Request for Archaeological Assistance, Review and Concurrence for the Proposed Radioactive
Materials License Condition
Radioactive Material License Number UT1900481
Project Number 481-2025-005
Dear Dr. Merritt:
Rio AlgomMining Limited (Rio Algom) owns the former uranium mill site in Lisbon Valley located approximately four miles south-southwest of La Sal, Utah.The site is licensed and regulated
by the Utah Division of Waste Management and Radiation Control (Division) under State of Utah Radioactive Materials License No. UT 1900481 (RML). The Mill has been decommissionedand
currently is conducting groundwater and geotechnical work on and around the two remaining tailing impoundments. Prior to any drilling and other ground disturbing activities, Rio Algom
is required to conduct an archeological survey of any area that has not been previously disturbed. A report of the archeological survey is developed and the Division and/or the U.S.
Bureau of Land Management (BLM) works with the Utah State Historic Preservation Office (SHPO) to determine compliance with archeological regulatory requirements.
On March 14, 2025, Rio Algom submitted a request to amend their license.The amendment request included changes to License Condition 12, which outlines the requirements for Rio Algom
to follow for cultural resource surveys.The proposed, amended license condition is attached to this letter.
The Division is requesting that SHPO provide a written concurrence letter, stating that the language in License Condition 12 meets SHPOs requirements for cultural resource protection.

If you have any questions, please call Ryan Johnson at [phone].
Sincerely,
Adam Wingate, Uranium Recovery Section Manager
Division of Waste Management and Radiation Control
AJW/RMJ/wa
c:Dennis Shumway, San Juan Public Health Department
Mike Moulton, San Juan Public Health Department
Curtis Page, P.E., District Engineer, UDEQ
Attachment: Rio Algom Mining, Limited UT 1900481 License Condition 12 Language
The Licensee shall implement the following practices related to protection of cultural resources for any ground-disturbing activity1 proposed by the Licensee:
On Federal land: The Licensee shall comply with applicable federal requirements.
On Licensee-owned private land: Before engaging in any ground-disturbing activity in an area not previously surveyed, the Licensee shall:
Ensure that all disturbances associated with the proposed activity undertaken by the Licensee are completed in compliance with the following: Utah’s antiquities law in Utah Code Section
9-8a-3 et seq. and its implementing regulations; Utah’s historic sites law in Utah Code Section 9-8a-4 et seq. and its implementing regulations; and the Utah Native American Grave Protection
and Repatriation Act in Utah Code Section 9-9-4 et seq. and its implementing regulations.
Contract to complete a survey, as defined in Utah Code Section 9-8a-302(19), if a survey does not already exist for the given area, or if a previous inventory covering the area is over
15 years old. This work shall be carried out by a person holding a principal investigator survey or excavation permit from the State of Utah’s Public Lands Policy Coordinating Office
per Utah Code Section 9-8a-305(1).
Report in writing the discovery of any archaeological resources as defined in Utah Code Section 9-8a-302(4), which shall be deemed to include historical artifacts, ancient human remains
and historic properties, to the State Historic Preservation Officer within 60 days of completion of the survey for review and submittal to the Utah State Historic Preservation Office
(SHPO) in accordance with Utah Code Section 9-8a-404(1)(a)(ii).
In the event of the discovery of possible, previously unknown or unidentified archaeological specimens or sites as defined in Utah Code Section 9-8a-302(16-17), immediately cease any
activity in the area of the discovery, notify the Director and at which point the SHPO shall be consulted regarding next steps. No further disturbance shall occur until the Licensee
has received authorization from the Director to proceed.
In the event the Licensee knows or has reason to know that it has discovered ancient human remains, immediately cease any activity in the area of the discovery, make a reasonable effort
to protect the remains discovered, and notify local law enforcement per Utah Code Section 76-9-704(2) in addition to the Director and SHPO in accordance with Utah Code Section 9-9-403(4).
Activity in the area may not resume until the Licensee has fulfilled the requirements of Utah Code Sections 76-9-704 and 9-8a-309 or has otherwise received authorization from the Director
to proceed.
Where possible, design any proposed ground-disturbing activities to avoid and minimize potential adverse effects to any historic properties as defined by Utah Code Section 9-8a-402(1)(b)
and further defined in this License to include all archaeological sites designated as “eligible to the National Register of Historic Places” in any previous archeological survey conducted
should the historic integrity of the historic property remain unchanged from the original documentation.
Where it is not reasonably feasible to avoid or minimize adverse effects to a historic property, the Licensee shall institute mitigation efforts that consider current U.S. Advisory Council
on Historic Preservation’s Archaeology Guidance, such as a research design and data recovery or alternative mitigation developed in consultation with the Director, SHPO and entities
affected by the proposed impacts. It is understood and agreed that it is not feasible to avoid any historic properties located in or within 100 feet of current or reclaimed mill structures
and tailings impoundments. If onsite data recovery is selected, field work shall be completed prior to the start of any project-related disturbance in that location. Analysis and report
preparation need not be complete prior to the time of disturbance.
Private land owned by entities other than the Licensee: The Licensee shall comply with all DWMRC stipulations related to cultural resources stipulated in Condition 12.B. If the Licensee
is unable to obtain landowner approval to conduct activities required by Condition 12.B., the Licensee shall:
Engage with DWMRC and the SHPO to determine a mutually agreeable means to resolve the potential inability to gain access to complete surveys or minimize or mitigate adverse effects to
historic properties; and

Implement the appropriate action identified through the Licensee’s consultation with DWMRC and SHPO.
Note 1: For the purpose of assessment of activities under this condition, the following are not considered ground-disturbing activities: 1) walking; 2) driving a utility vehicle or light
vehicle with a tread width less than ten inches; 3) placement, use, and removal of stationary equipment on the ground surface; 4) use of wheeled tools and equipment mounted to a wagon
or cart; 5) vehicular traffic and maintenance on existing roads, pads, or laydown areas; and 6) marking locations or securing items with a pin or stake with a with a cross-sectional
area of less than one square inch.
Note 2: If a federal undertaking will occur on licensee-owned lands, the licensee shall follow the superseding conditions of the lead federal agency related to cultural resources (e.g.,
Section 106 of the National Historic Preservation Act) rather than the conditions listed herein.