SEC Comment Letter 0000000000-23-002980 to ENERGY FUELS INC (UUUU)
ENERGY FUELS INC
Date: March 24, 2023 · CIK: 0001385849 · Accession: 0000000000-23-002980
AI Filing Summary & Sentiment
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File numbers found in text: 001-36204
Letter
United States securities and exchange commission logo March 24, 2023 Tom Brock Chief Financial Officer Energy Fuels Inc. 225 Union Blvd. Suite 600 Lakewood, CO 80228 Re:Energy Fuels Inc. Form 10-K for the Fiscal Year ended December 31, 2021 Filed March 15, 2022 File No. 001-36204 Dear Tom Brock: We have reviewed your March 16, 2023 response to our comment letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our February 16, 2023 letter. Form 10-K for the Fiscal Year ended December 31, 2021 Exhibits and Financial Schedules, page 189 1.We note your response to prior comment 2 regarding the cut-off grade used for the Nichols Ranch property, and the pricing, recovery, and operating cost numbers that are disclosed on pages 14-15 of the revised technical report summary.
Please provide us with the equation that was used to calculate the cut-off grade for the Nichols Ranch project based on the information referenced above, to clarify and demonstrate how the minimum geologic cut-off grade of 0.02% was determined.
Also provide us with the equation that was used to calculate the cut-off grade for the Alta Mesa project based on information in the corresponding technical report summary, to show how the minimum geologic cut-off grade of 0.02% was determined.
FirstName LastNameTom Brock Comapany NameEnergy Fuels Inc. March 24, 2023 Page 2 FirstName LastName Tom Brock Energy Fuels Inc. March 24, 2023 Page 2
Please identify all elements of each equation, reconciled as necessary to the corresponding details in the associated reports, identifying the specific locations within the reports where such details are disclosed, and including clear explanations of rationale for any adjustments or modifications to the inputs or within the equations.
Identify and describe any differences in the assumptions utilized or the approach taken in determining the cut-off grades for each project.
You may contact John Coleman, Mining Engineer, at (202) 551-3610, or Karl Hiller, Branch Chief, at 202-551-3686 if you have any questions regarding the comments. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: James Guttman - External Counsel
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United States securities and exchange commission logo
March 24, 2023
Tom Brock
Chief Financial Officer
Energy Fuels Inc.
225 Union Blvd. Suite 600
Lakewood, CO 80228
Re:Energy Fuels Inc.
Form 10-K for the Fiscal Year ended December 31, 2021
Filed March 15, 2022
File No. 001-36204
Dear Tom Brock:
We have reviewed your March 16, 2023 response to our comment letter and have the
following comments. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
February 16, 2023 letter.
Form 10-K for the Fiscal Year ended December 31, 2021
Exhibits and Financial Schedules, page 189
1.We note your response to prior comment 2 regarding the cut-off grade used for the
Nichols Ranch property, and the pricing, recovery, and operating cost numbers that are
disclosed on pages 14-15 of the revised technical report summary.
Please provide us with the equation that was used to calculate the cut-off grade for the
Nichols Ranch project based on the information referenced above, to clarify and
demonstrate how the minimum geologic cut-off grade of 0.02% was determined.
Also provide us with the equation that was used to calculate the cut-off grade for the Alta
Mesa project based on information in the corresponding technical report summary, to
show how the minimum geologic cut-off grade of 0.02% was determined.
FirstName LastNameTom Brock
Comapany NameEnergy Fuels Inc.
March 24, 2023 Page 2
FirstName LastName
Tom Brock
Energy Fuels Inc.
March 24, 2023
Page 2
Please identify all elements of each equation, reconciled as necessary to the corresponding
details in the associated reports, identifying the specific locations within the reports where
such details are disclosed, and including clear explanations of rationale for any
adjustments or modifications to the inputs or within the equations.
Identify and describe any differences in the assumptions utilized or the approach taken in
determining the cut-off grades for each project.
You may contact John Coleman, Mining Engineer, at (202) 551-3610, or Karl
Hiller, Branch Chief, at 202-551-3686 if you have any questions regarding the comments.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: James Guttman - External Counsel