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   Energy Fuels Inc. - SEC Correspondence - Filed by newsfilecorp.com

August 23, 2017

Mr. John Reynolds
Assistant Director
Offices of
Beverages, Apparel and Mining
Division of Corporation Finance
Securities
and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

    Re:
    Responses to the Securities
      and Exchange Commission

    Staff Comments dated July 26,
      2017 regarding

    Energy Fuels Inc.’s Annual
      Report on Form 10-K for the fiscal year ended

    December 31, 2016, Filed March
      10, 2017.

    File No. 001-36204

Dear Mr. Reynolds:

This letter responds to the comments of the staff of the United
States Securities and Exchange Commission (the “Staff”) set forth in the
July 26, 2017 letter (the “Comment Letter”) regarding the
above-referenced Annual Report on Form 10-K for the fiscal year ended December
31, 2016 (the “10-K”) of Energy Fuels Inc. (the “Company”).
For your convenience, the Staff’s comments are included below, and we have
numbered our responses accordingly.

Our response is as follows:

Staff Comment No. 1.

Please tell us the mineral price assumptions used in the
calculation of each of your 43-101 mineral resources and reserves. Please tell
us if you intend to revise your disclosures prospectively to include this
information or explain the basis for your presentation.

The Company’s Response No. 1:

In response to Staff Comment No. 1, the following table sets
out each property with respect to which Canadian National Instrument 43-101
(“43-101”) resources and/or reserves were disclosed in the 10-K, and the
mineral price assumptions used in the calculation of such mineral resources and
reserves. Unless otherwise specified below, all price assumptions were either
expressly set out in, or calculated from cost assumptions expressly set out in,
the respective 43-101 Technical Reports. In each case where the price assumption
was not expressly set out in, or calculated from cost assumptions expressly set
out in, the relevant 43-101 Technical Report, we have confirmed the applicable
price assumption with the author of the Technical Report.

John Reynolds
August 23, 2017
Page 2

    Material Properties
    Price Assumption

    Nichols Ranch, Jane Dough and Hank*
    $65.00/lb U3O8

    Alta Mesa**
    $65.00/lb U3O8

    Canyon, Arizona 1 and Pinenut**
    $50.00/lb U3O8

    Roca Honda*
    $65.00/lb U3O8

    Sheep Mountain
    $65.00/lb U3O8

    Henry Mountains, Tony M
    $60.00/lb U3O8

    Henry Mountains, Bull Frog**
    $40.00/lb U3O8

    La Sal Complex
    $65.00/lb U3O8 and
      $6.50/lb V2O5

    Daneros
    $60.00/lb U3O8

    Non-Material Properties

    Reno Creek**
    $65/lb U3O8

    West North Butte**
    $65/lb U3O8

    North Rolling Pin**
    $65/lb U3O8

    Arkose Joint Venture**
    $65.00/lb U3O8

    Wate
    $38.00/lb U3O8

    EZ1/EZ2
    $53.00/lb U3O8

    Whirlwind***
    $77.50/lb U3O8 and
      $7.50/lb V2O5

    Sage Plain
    $63.00/lb U3O8 and
      $6.75/lb V2O5

    *

      Based on the price assumption used for the economic
      analysis in the Preliminary Economic Assessment contained in the Technical
      Report.

    **

      Confirmed by subsequent correspondence from the author of
      the Technical Report.

    ***

      Based on reference in the Technical Report to the
      Company’s internal tentative mine plan, which contained price assumptions
      used to determine the cutoff grade for the resource calculations, as
      confirmed by subsequent correspondence from the author of the Technical
      Report.

The 10-K discloses the price assumptions used for the Roca
Honda Project Resource calculation (see page 72, note 3 of the 10-K) and Sheep
Mountain Project resource/reserve estimates (see page 79 of the 10-K), but does
not disclose the price assumptions for any other resource calculations. We will
revise our disclosures prospectively in future Annual Reports on Form 10-K,
commencing with the Form 10-K for the fiscal year ending December 31, 2017 to
include the price assumptions used to calculate the cut-off grade for all
resource or reserve estimates and for any economic analyses disclosed in future
Annual Reports on Form 10-K. Such disclosure will be set out in a footnote or
footnotes to each table that includes a resource or reserve estimate or economic
analyses or elsewhere in the text of the Form 10-K as may be appropriate.

* * * * *

If you should have any questions regarding the response letter,
please do not hesitate to contact the undersigned at (303) 389-4130 or Richard
Raymer of Dorsey & Whitney LLP at (416) 367-7388.

John Reynolds
August 23, 2017
Page 3

    Sincerely,

    Energy Fuels Inc.

    /s/ David C. Frydenlund

    David C. Frydenlund

    Senior Vice President, General Counsel and

    Corporate Secretary

cc: Richard Raymer, Dorsey & Whitney LLP