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State of Utah
GARY R. HERBERT Governor
SPENCER J. COX Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
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MEMORANDUM
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Heather Mickelson, P.E., P.G. 1-5Dk I
July 30, 2018
DWMRC Review of the 2018 Biennial Land Use Survey, Energy Fuels Resources
(USA) INC., White Mesa Mill, Radioactive Materials License No. UT1900479,
Condition 12.3
TO:
THROUGH:
FROM:
DATE:
SUBJECT:
File
Phil Goble, Manager
Review Summary
The Utah Division of Waste Management and Radiation Control (DWMRC) has reviewed the
2018 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 25, 2018 and received by the DWMRC on June 28, 2018. Survey updates were
received on July 27, 2018. The Survey was submitted to comply with Condition 12.3 of the
Radioactive Materials License No. UT1900479, Amendment 8 ("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 industly 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: I) 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]
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Pnnted on 100% recycled paper
Energy Fuels Resources (USA) Inc. 2018 Land Use Survey
Page 2
Survey Contents
This Survey establishes a baseline for future surveys to discuss changes; this is the first one
conducted for the land surrounding the Mill. The cover letter, tables, and lists, and maps were
submitted via hard copy. Maps were large format maps with legible information. 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 Ute Mountain Ute Tribe letter with contact information for the sovereign nation of the
Ute Mountain Ute Tribe sent to David Frydenlund signed by Scott Clow on January 23,
2018.
3. The Water Well Owner List includes the owner's name, location, and phone number (if
available); water right number and location; and intended water use. An updated list was
received on July 27, 2018. This update includes a discussion of changes from the initial
list in Table 1A and 1B.
4. The Record of Oil and Gas Activity lists the API well number, well name, operator, field
name, geographical location and elevation, lease number and type, well status and type,
operator, and completion date, and regulatory jurisdiction.
5. The Land Parcel Owner List includes owner's name and mailing address, parcel ID, legal
description, and lot size.
6. The Water Rights Map shows the point of diversion for active water rights within 5 km of
the Mill. An updated map was received on July 27, 2018.
7. The Oil and Gas Wells Map shows many of the oil and gas wells types and the land
parcels within 5 km of the Mill.
8. The Land Ownership Map shows land ownership type within 5 km of the Mill (Bureau of
Land Management, Indian Reservation, State, and Private).
9. The Land Use Map shows the major building structures and grazing allotments within 5
km of the Mill.
10. A letter from Scott Clow of the Ute Mountain Ute Tribe, dated January 23, 2018, that lists
points of contact for the sovereign nation of the Ute Mountain Ute Tribe.
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.
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
Energy Fuels Resources (USA) Inc. 2018 Land Use Survey
Page 3
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/parcelsi).
Land Use Survey Submission Conclusions
The 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 (Annual Land Use Survey
Report Review).
References
Energy Fuels Resources (USA) Inc., June 25, 2018, Bi-annual Land Use Survey.
Energy Fuels Resources (USA) Inc., Jul 27, 2018, Bi-annual Land Use Survey Updates
Utah Dept. of Environmental Quality, Radioactive Material License Number UT 1900479,
Amendment 8
Energy Fuels Resources (USA) Inc. 2018 Land Use Survey
Page 4
Appendix 1 — Energy Fuels Resources (USA) Inc, Module 32 Inspection Form
tah DiviHon oi' WasManagerhent andAadiation Contronnspection:FW1
(; round Watee:Mciciule .32 (Ahnual lnd.4 fse StkOeiiReport Review)
Energffuels Resources (USA )
Lisbon Val (ey, Utih •
Regulatory Requirements Inspected Against: Radioactive Materials License # UT 1900479,
Amendment 8 Condition 12.3 dated February 21, 2018
Last Previous Inspection Date: Not applicable
Date of Current Inspection: 2018
Violations Recommended: 1-1 Yes El No Comments: NA
INSPECTION ITEM — Annual Land Use Survey (Ground Water Module 32):
ran4 -Use u rvey 41.equirements (Condition 21)
1. Report Submittal Date - Was the report submitted on or before June 30 2018?
IZ Yes 111No
Notes:
The survey (report, tables, lists, and electronic copy) were received on June 28, 2018 and was
dated June 25, 2018. Updates were requested on July 11, 2018 by UDWMRC and were received
on July 27, 2018. The Water Well Owner List and Water Rights Map were updated.
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?
IZ Yes No
Notes:
The survey included four maps titled: Water Rights Map, 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.
The Water Rights Map shows the point of water diversion for a water right for active water rights
and well logs.
The Oil and Gas Wells and Property Ownership map shows many of the oil and gas wells types
and land parcels.
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. Private and non-residential
structures are not differentiated.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www deq.utah.gov
Printed on 100% recycled paper
3. Were those items listed above appropriately plotted on the Annual Land Use Map?
El Yes CI 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?
El Yes E1No
Notes:
Parcel ownership was obtained from the 3rd party company Core Logic Spatial Solutions.
Water well ownership and well log information was obtained from the State of Utah Division of
Water Rights website and was accessed on April 10, 2018 and June 26, 2018. Surface water
diversions and EFRI wells were not included on the map or list. The water well owner's phone
numbers were obtained from the 2017-2018 Blanding City Phone book published by Frontier
Pages for residential and commercial owners and from governmental website for governmental
organizations.
Oil and gas well and uranium mines ownership was obtained from the Utah Division of Oil, Gas,
and Mining via Utah AGRC and was accessed on April 10, 2018.
Land ownership type information was obtained from Utah ARGC.
The location of buildings and structures are based on 2018 ESRI imagery. House and building-
sized structures were identified. Smaller sheds and storages buildings were not identified, if on
they were on the same property as a larger-sized structure.
5. Did all plotted items include contact information?
El Yes D No
Notes:
The plotted identification numbers 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 LI 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? [E] Yes El No
Notes:
Different types of oil and gas wells were differentiated on the Oil and Gas Wells and Property
Ownership map. Producing, approved permit, plugged and abandoned, location abandoned,
temporarily abandoned, and shut-in are types of listed oil and gas wells.
Water wells with active water rights and the intended water use were included on the Water Wells
and Property Ownership map and Water Well Owner List. Potential water use intent types are:
power, domestic, irrigation, municipal, stock watering, other, mining, non-production well
application.
8. Differences in land use from that described in the last report are discussed in the survey?
Yes No
Notes:
This is the first land use survey that established a baseline for future surveys. Future surveys will
include a discussion of the differences from the previous submittal.
9. Do any of these changes represent a concern with regard to ground water at the Mill
property? D Yes L1 No
Notes:
Not applicable — see response to question 8 above
10. Additional Records Requested/Inspected:
Not applicable
Inspection Staff: Heather Mickelson