Technical Report, Bullfrog Project, Garfield County, Utah, USA

SLR Project No.: 123.V02544.00008

Prepared by

SLR International Corporation

1658 Cole Blvd, Suite 100

Lakewood, CO 80401

for

Energy Fuels Inc.

225 Union Blvd., Suite 600

Lakewood, CO 80229

USA

Effective Date - December 31, 2024

Signature Date - May 9, 2025

Table of Contents

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ii

iii

iv

Tables

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Figures

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vii

Appendix Tables

viii

1.0 Summary

1.1 Executive Summary

SLR International Corporation (SLR) was retained by Energy Fuels Inc. (Energy Fuels) to prepare an independent Technical Report on the Bullfrog Project (Bullfrog or the Project), located in Garfield County, Utah, USA.  Energy Fuels is the parent company of Energy Fuels Resources (USA) Inc. (EFR), which owns 100% of the Project. EFR is a US-based uranium and vanadium exploration and mine development company. Energy Fuels is listed on the NYSE American Stock Exchange (symbol: UUUU) and the Toronto Stock Exchange (symbol: EFR).

This Technical Report satisfies the requirements of Canadian National Instrument 43-101 Standards of Disclosure for Mineral Projects (NI 43-101) and United States Securities and Exchange Commission's (SEC) Modernized Property Disclosure Requirements for Mining Registrants as described in Subpart 229.1300 of Regulation S-K, Disclosure by Registrants Engaged in Mining Operations (S-K 1300) and Item 601 (b)(96) Technical Report Summary.

The purpose of this report is to disclose the results of a Preliminary Economic Assessment (PEA). The term PEA is used throughout this Technical Report and is consistent with an Initial Assessment (IA) under S-K 1300.

This report was prepared by Stuart Collins, P.E., Jeffrey L. Woods, MMSA QP, Lee (Pat) Gochnour, MMSA QP, Mark B. Mathisen, C.P.G., Grant A. Malensek, M.Eng., P.Eng., and Tedros Tesfay, SME (RM), all of whom are Qualified Persons (QP) within the meaning of both S-K 1300 and NI 43-101 (SLR QP). Messrs. Mathisen, Miranda, and Collins visited the Project on July 15 to 18, 2024.

Bullfrog consists of two contiguous sandstone-type uranium deposits, Copper Bench and Indian Bench, within the Colorado Plateau physiographic province in southwestern Utah. The Colorado Plateau has been a relatively stable structural province since the end of the Precambrian. During the Paleozoic and Mesozoic eras, the Colorado Plateau was a stable shelf without major geosynclinal areas of deposition, except during the Pennsylvanian when several thousand feet of black shales and evaporates accumulated in the Paradox Basin of southwestern Colorado and adjacent Utah.

The Project is situated in the southeastern flank of the Henry Mountains Basin, a subprovince of the Colorado Plateau physiographic province. The Henry Mountains Basin is an elongate north-south trending doubly plunging syncline in the form of a closed basin. It is surrounded by the Monument Uplift to the southeast, Circle Cliffs Uplift to the southwest, and the San Rafael Swell to the north.

The Project is currently being developed in preparation for production as an underground operation, from which the mineralized material will be processed based on a toll milling agreement at Energy Fuels' White Mesa Mill, located near Blanding, Utah, approximately 127 road miles (mi) south of the Project. Environmental permitting and compliance activities are being developed to start mining operations.

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1.1.1 Conclusions

The SLR QPs offer the following conclusions by area:

1.1.1.1 Geology and Mineral Resources

• The Bullfrog deposit is considered a tabular sandstone hosted uranium deposit.

• The Project is an advanced exploration stage property, 100% owned by EFR. The Project is in a region with a well-developed mining industry and is close to necessary infrastructure and resources.

• As of the effective date of this Technical Report, historical records of EFR predecessors indicate that approximately 1,694 drill holes have been completed on the Bullfrog deposit. Of the 1,694 drill holes, 949 drill holes totaling 910,780 ft of drilling were used in this Mineral Resource estimate Historical surface holes missing collar information, lithology information, or corresponding radiometric logs, i.e., assay data, were excluded.

• In the SLR QP's opinion, the drill hole logging and sampling procedures meet industry standards and are adequate for Mineral Resource estimation. The SLR QP is not aware of any drilling, sampling, or recovery factors that could materially impact the accuracy and reliability of the results.

• Mineral Resources have been classified in accordance with the definitions for Mineral Resources in S-K 1300, which are consistent with Canadian Institute of Mining, Metallurgy and Petroleum (CIM) Definition Standards for Mineral Resources and Mineral Reserves dated May 10, 2014 (CIM, 2014) definitions which are incorporated by reference in NI 43-101.

• In the SLR QP's opinion, the assumptions, parameters, and methodology used for the Bullfrog Mineral Resource estimate is appropriate for the style of mineralization and mining methods.

• The SLR QP considers the estimation procedures employed at Bullfrog, including compositing, top-cutting, variography, block model construction, and interpolation to be reasonable and in line with industry standard practice.

• The SLR QP is of the opinion the block models are adequate for public disclosure and to support mining activities. The effective date of the Mineral Resource estimate is December 31, 2024.

• The SLR QP considers that the knowledge of the deposit setting, lithologies, structural controls on mineralization, and the mineralization style and setting, is sufficient to support the MRE to the level of classification assigned.

• The SLR QP considers that the resource cut-off grade and mining shapes used to identify those portions of the Mineral Resource that meet the requirement for the reasonable prospects for economic extraction to be appropriate for this style of uranium deposit and mineralization.

1.1.1.2 Mining and Mineral Reserves

• There are no current Mineral Reserves at the Project.

• Mineralization is hosted in the relatively flat laying Salt Wash Member of the Westwater formation at depths below the surface of 500 ft to 1,200 ft. 

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• The Bullfrog Project is composed of the Copper Bench (southeast) and the Indian Bench (northwest) mining areas. 

• The mining areas will be accessed by a 13,520-ft long adit decline to the underground mine.

• The mine life comprises a four-year pre-production period and a 15-year active mine life (Base Case) across eight intertwined mining zones (zone 1 through zone 8). The Alternative Case active mine life is 12 years.

• The primary mining methods to employed at Bullfrog will be room and pillar, drift and fill, and split-shot.  EFR is acutely aware of the need to keep dilution low given the high cost of transportation and treatment.  EFR has many mines with similar geological and mining attributes to Bullfrog.  EFR has employed the above-mentioned mining methods at their other underground operations.

• A minimum mining thickness of four feet was applied to two-foot-thick mining blocks.

• Stope dilution was calculated to be 28%.

• An 85% mining recovery was applied to the Mineral Resource mining stopes.

• Groundwater inflow to the mine workings is expected to be between 20 gallons per minute (gpm) to 50 gpm; further hydrogeological modelling and analysis is required to confirm this. The SLR QP has accounted for dewatering wells for depressurization of the mine workings in the capital and operating costs.

• The Base Case mine plan includes 1.8 million tons (Mton) at an average grade of 0.28% eU₃O₈, containing 9.7 million pounds (Mlb) of eU₃O₈. Approximately 20% of the tonnage included in the Base Case is categorized as Inferred Resources. The Alternative Case, which comprises Indicated Resources only, includes 1.5 Mton at an average grade of 0.27 eU₃O₈, containing 7.7 Mlb of eU₃O₈.

• It is envisioned that Bullfrog will supply approximately 10,000 tons of mineralized material a month (120,000 tons per year (tpa)) to EFR's White Mesa Mill located six miles south of Blanding, Utah, approximately 127 miles south of the Bullfrog mine. The White Mesa Mill is the only active, operating uranium mill in the United States.

1.1.1.3 Mineral Processing

• The Bullfrog mineralized material will be toll milled at the existing White Mesa Mill in Utah. Mineralized material will be transported by haul trucks to the White Mesa Mill.

• The Mill has been in operation since 1981 and is equipped with the required equipment using a proven process for the production of uranium oxide (U₃O₈) product, called "yellowcake".  In addition, although it is not part of the production schedule in this Technical Report, the Mill also has the capacity to produce vanadium pentoxide (V₂O₅).

• Mill operations can receive run-of-mine (ROM) material from the Bullfrog Project and various other EFR mines. Material will be dumped from trucks onto a mineralized material pad at the Mill and stockpiled by type to be blended as needed. Material will be weighed, sampled, and probed for uranium grade.  The mineralized material pad area has an approximate capacity of 450,000 tons.

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• The Mill utilizes agitated hot acid leach and solvent extraction to recover uranium. Historical metallurgical tests and Mill production records on similar mineralized material confirm this processing method will recover 95% of the contained uranium.

• The Mill has historically run on a campaign basis and processes uranium bearing materials as they become available. 

1.1.1.4 Infrastructure

• The Project will have diesel-generated electric power for the underground operation, ventilation fans, surface infrastructure, and dewatering wells.

• Water for the Project will be supplied from dewatering wells, which are needed to depressurize the underground mine.

• The primary surface infrastructure buildings and areas that are required to efficiently operate the Bullfrog mine include the following:

o Underground mine equipment maintenance shop

o Equipment wash bay

o Warehouse facilities

o Mine dry for the workers,

o Offices

o Emergency Medical Services (EMS) facilities

o Guard shack and parking

o Water treatment plant and evaporation ponds

o Fuel depot

o Waste storage facilities

o Ore stockpile area

o Explosive storage facilities

o Underground communications

o Dewatering wells

o Ventilation shafts and fans

o Electrical generators, substation, and site distribution powerlines

o Project access road and site roads

o Fencing

1.1.1.5 Environment

• EFR has a comprehensive understanding of regulatory requirements, permits, authorizations, and the applicable agencies for each. They have initiated select environmental baseline gathering for select disciplines to comply with these requirements.

• The environmental baseline studies that have been performed for the Project area were established between 2014 and 2016 to support permitting. This baseline serves as an excellent benchmark for documenting existing site conditions (and changes that have occurred since) and can be used to assess success of proposed reclamation practices.

• The Project is in a regulatory jurisdiction that has recent experience in permitting similar project activities.

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1.1.1.6 Capital and Operating Costs

• The initial direct capital cost estimate is estimated to be US$36 million.  Indirect costs and Owner's costs are estimated to total 20% of direct costs. The contingency has been estimated at 25% of direct, indirect, and Owner's costs.  Total initial capital costs over the four year pre-production period are estimated to be US$55 million. 

• The initial capital cost estimate has an accuracy of +50% / -50%.

• Sustaining capital costs are estimated to be US$38 million.  Permitting and closure costs are estimated to be US$4 million.

• The average life of mine operating costs is estimated to be US$307.63 per ton milled.

1.1.2 Recommendations

SLR has proposed a two-phase exploration program with a total budget of approximately US$2,203,000 to advance the Project, beginning in 2025 (Table 1-1).  Phase 2 is contingent on the successful completion of Phase 1.

Table 1-1: Proposed Energy Fuels 2025 Budget - Bullfrog Project

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The objectives of the exploration program are summarized below.

1.1.2.1 Geology and Mineral Resources

The SLR QP offers the following recommendations related to the geology and Mineral Resources aspects of the Project:

Phase 1: Development Drilling Program

1 Conduct a 20 to 30 drill hole development drilling program aiming to upgrade Inferred Resources to Indicated Resource and verify historical reported equilibrium values. Average depth per hole is projected to be approximately 930 ft.

2 Utilize Prompt Fission Neutron (PFN) drill hole geophysical logging as an alternative to collecting core to save costs on equilibrium analysis. PFN logging has proven to be a reliable methodology for equilibrium analysis and has a strong performance record on similar uranium deposits in the USA.

3 Update the Mineral Resource estimate for the Project using Deswik Stope Optimizer (Deswik.SO) shape optimization.

The SLR QP estimated costs per drill foot is US$25/ft, which includes the equilibrium analysis costs using the PFN tool.

Phase 2: Updated Resource Estimate and Pre-Feasibility Study

1 Following the Phase 1 drilling and Mineral Resource update, complete a Prefeasibility Study (PFS) of the Project.

1.1.2.2 Mining and Mineral Reserves

1 As part of a PFS, conduct the necessary work to estimate Mineral Reserves. The following tasks, included in the work program budget, will need to be part of the PFS.

o Conduct development drilling of the first mining zones to be encountered.

o Conduct drilling and analysis of geotechnical holes in the first mining zones to be encountered and along the decline route to support ground control design.

o Conduct a hydrology study to quantify the amount of mine depressurization and dewatering needed for the Project.

o Update the mine plan designs and schedule, including equipment and site service requirements to support the target production rates.

2 Investigate the alternative mining methods, like the use of roadheaders in soft ground.

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1.1.2.3 Mineral Processing

1 Continue the White Mesa Mill intermittent operations with maintenance program.

2 Evaluate historical operating data to determine possible flowsheet improvements or modifications to improve the mill production rate/economics and make these changes before commencing production.

3 Conduct bench tests on the Bullfrog mineralized material to define process parameters.

1.1.2.4 Infrastructure

1 Design and estimate costs for a surface infrastructure to support future mining activities, including Project access road, surface facilities, water treatment plant, settling ponds, and evaporation ponds.

1.1.2.5 Environment

Hydrology

1 Given the absence of site-specific boring logs, monitoring wells, and data on transmissivity and storage, install wells to improve understanding of the groundwater system beneath the proposed Project site. Pumping tests should also be conducted to determine extraction rates, as well as the transmissivity and storage coefficient of the Navajo Sandstone aquifer near the production wells.

2 Using site-specific boring logs and permeability data, develop 3D geologic models, followed by numerical models, to verify the water budget of the Navajo Sandstone and assess its hydraulic connectivity, both laterally and vertically, with adjacent formations. Mine inflow estimates for the underground workings should be confirmed through the groundwater monitoring program, incorporating seepage water collection and the numerical modeling process for the Project.

Baseline Studies, Permits, Reclamation.

1 Review and document the previous environmental baseline studies, supplement or update these studies as required for current and anticipated permitting efforts, and document changes in the baseline since initial permitting efforts.

2 Complete additional studies for the socio-economic impacts, air quality, and meteorology.

3 Track (and where appropriate participate in) new legislation that may have impact(s) on permitting and environmental requirements for the Project.

4 As Permits are applied for and secured, begin development of an environmental management system that captures and describes environmental plans and requirements.

5 Even though opportunity may be limited, look for opportunities for concurrent reclamation to minimize financial obligation(s) during mining and at closure.

6 Once construction is complete, stabilize new disturbances with mulch, surface armoring and/or and vegetation to minimize erosion.

7 Develop revegetation test plots to finalize reclamation seed mix(es).

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1.1.2.6 Capital and Operating Costs

1 For the next phase of study, complete detailed capital cost estimates based on PFS-level designs.

1.2 Economic Analysis

1.2.1 Base Case - Indicated and Inferred Resources

The economic analysis contained in this Technical Report is based, in part, on Inferred Mineral Resources, and is preliminary in nature. Inferred Mineral Resources are considered too geologically speculative to have the economic considerations applied to them that would enable them to be categorized as Mineral Reserves. There is no certainty that economic forecasts on which this PEA is based will be realized.  Inferred Mineral Resource tonnage represents approximately 20% of the Mineral Resources used in this Base Case economic analysis. It is important to note that, unlike Mineral Reserves, Mineral Resources do not have demonstrated economic viability.

An after-tax Cash Flow Projection has been generated from the Life of Mine production schedule and capital and operating cost estimates. A summary of the key criteria is provided below.

1.2.1.1 Economic Criteria

Revenue

• Total mill feed processed: 1,765 kt

• Percent of Inferred Mineral Resource tonnage in LOM: 20%

• Average head grade: 0.28% eU₃O₈

• Average mining rate: 10,000 tons per month mining from underground (120,000 tons per year).

• Cut-off grade of 0.15% applied to diluted stope shapes.

• eU₃O₈ is sold at 100% payable.

• All prices are in US dollars, the Project is located in Utah, and all products produced are sold domestically.

• Metal Price: US$90/lb eU₃O₈.

• Net Smelter Return includes refining, transport, and insurance costs.

• Revenue is recognized at the time of production.

• Average mill recovery: 95%

• Total Recovered U₃O₈: 9,226 llb

Costs

• Pre-production period: four years (Year -4 through Year -1).

• Mine life: 15 years.

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• Mine life capital totals $97 million, initial capital totals $55 million, permitting and closure totals $4 million, and sustaining capital totals $38 million.

• Average operating cost over the mine life is $307.63 per ton milled.

Taxation and Royalties

There are no royalties on the Bullfrog production other than the state of Utah has a 2.6% Severance mineral tax. Income tax assumptions include a 21% Federal Income tax rate and a Utah Income tax rate of 4.50%.  Unit of Production (UoP) depreciation was used along with percentage depletion of 22% versus cost depletion.

1.2.1.2 Cash Flow Analysis

Considering the Project on a stand-alone basis, the undiscounted after-tax cash flow totals $147 million over the mine life, and simple payback occurs approximately 5.8 years from start of production. The after-tax Net Present Value (NPV) at an 8% discount rate is $31 million, and the after-tax Internal Rate of Return (IRR) is 14%.

The amount of Inferred Mineral Resources included in this study represents approximately 20% of the total Mineral Resources tons. Inferred Mineral Resources are geologically speculative, and there is no certainty that economic forecasts on which this PEA is based will be realized.

A summary of the after-tax cash flow is provided in Table 1-2. Figure 1-1 presents the payable metal by year.

Table 1-2: Base Case After-Tax Cash Flow Summary

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Figure 1-1: Base Case Payable U₃O₈

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1.2.1.3 Sensitivity Analysis

Project risks can be identified in both economic and non-economic terms. Key economic risks were examined by running cash flow sensitivities:

• eU₃O₈ price

• Mill Recovery

• Head grade

• Operating costs

• Pre-production capital costs

• Mine life

The sensitivity analysis reveals the variations in key economic factors-such as metal prices, operating costs, and recovery rates-that can significantly impact the Project's net present value (NPV) and internal rate of return (IRR). Understanding these sensitivities is crucial for effective risk management and strategic decision-making.

1.2.2 Alternative Case - Indicated Only

The SLR QP also undertook an analysis of an alternative case that considers only Indicated Mineral Resources, which account for approximately 1.42 million tons, or 80%, of the 1.76 million tons in the base case production schedule.  The Project has no estimated Measured Resource. The SLR QP has determined that a stand-alone alternative case with only Indicated Mineral Resource tonnage is economic using the assumptions and inputs outlined in the Base Case at an Internal Rate of Return of approximately 12%. The SLR QP notes that while the alternative case does not contain Inferred Mineral Resources, Indicated Mineral Resources are not Reserves and do not have demonstrated economic viability. There is no certainty that economic forecasts included in this PEA will be realized. 

EFR plans to conduct additional definition drilling of the known mineralized material to convert the Inferred Mineral Resources to Indicated Mineral Resources.

1.2.2.1 Economic Criteria

Revenue

• Total mill feed processed: 1,419 kt

• Average head grade: 0.27% eU₃O₈

• Average mining rate: 10,000 tons per month mining from underground (120,000 tons per year).

• Cut-off grade of 0.15% applied to diluted stope shapes.

• eU₃O₈ is sold at 100% payable.

• All prices are in US dollars, the Project is located in Utah, and all products produced are sold domestically.

• Metal Price: US$90/lb eU₃O₈.

• Net Smelter Return includes refining, transport, and insurance costs.

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• Revenue is recognized at the time of production.

• Average mill recovery: 95%

• Total Recovered U₃O₈: 7,324 llb

Costs

• Pre-production period: four years (Year -4 through Year -1).

• Mine life: 12 years.

• Mine life capital totals $97 million, initial capital totals $55 million, permitting and closure totals $4 million, and sustaining capital totals $38 million.

• Average operating cost over the mine life is $307.63 per ton milled.

Taxation and Royalties

There are no royalties on the Bullfrog production other than the state of Utah has a 2.6% Severance mineral tax. Income tax assumptions include a 21% Federal Income tax rate and a Utah Income tax rate of 4.50%.  Unit of Production (UoP) depreciation was used along with percentage depletion of 22% versus cost depletion.

1.2.2.2 Cash Flow Analysis

Considering the Project on a stand-alone basis, the undiscounted after-tax cash flow totals $97.6 million over the mine life, and simple payback occurs approximately 5.7 years from start of production. The after-tax Net Present Value (NPV) at an 8% discount rate is $18.7 million, and the after-tax Internal Rate of Return (IRR) is 12.4%.

The cash flow analysis for the Alternative Case is summarized in Table 1-3. Figure 1-2 presents the payable metal by year.

Table 1-3: Alternative Case After-Tax Cash Flow Summary

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Figure 1-2: Alternative Case Payable U₃O₈

1.2.2.3 Sensitivity Analysis

Project risks can be identified in both economic and non-economic terms. Key economic risks were examined by running cash flow sensitivities:

• eU₃O₈ price

• Mill Recovery

• Head grade

• Operating costs

• Pre-production capital costs

• Mine life

The sensitivity analysis reveals the variations in key economic factors-such as metal prices, operating costs, and recovery rates—that can significantly impact the Project's net present value (NPV) and internal rate of return (IRR). Understanding these sensitivities is crucial for effective risk management and strategic decision-making.

1.3 Technical Summary

1.3.1 Property Description and Location

The Bullfrog Project consists of two separate contiguous deposits, also known as Copper Bench and Indian Bench. The Project is located in eastern Garfield County, Utah, 17 mi north of Bullfrog Basin Marina on Lake Powell and approximately 40 mi south of the town of Hanksville, Utah. It is situated three miles west of Utah State Highway 276 and approximately five miles north of Ticaboo, Utah.

The approximate center of the of the Project has the following coordinates:

• Universal Transverse Mercato (UTM): 526,649.08 mE, 4,184861.5m N zone 12S

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• Geographic: 37°48'38.71"N latitude and110°41'50.09"W longitude (decimal degrees 37.810753, -110.697247)

• State Plane 1983 Utah South FIPS 4303 (US feet) system: 1,872,319.926 E, 10,260,078.280 N

1.3.2 Land Tenure

EFR's property position at the Project consists of 168 unpatented mining claims located on U.S. Bureau of Land Management (BLM) land, encompassing approximately 2,344 acres. Surface access to conduct exploration, development and mining activities on unpatented mining claims is granted by the BLM if National Environmental Protection Act (NEPA) regulations are met. The Project is 100% owned by EFR and all claims are in good standing.

1.3.3 History

During World War I, vanadium was mined from small deposits outcropping in Salt Wash exposures on the eastern and southern flanks of the Henry Mountains. In the 1940s and 1950s, interest increased in both vanadium and uranium, and numerous small mines developed along the exposed Salt Wash outcrops.

In the late 1960s, Gulf Minerals (Gulf) acquired a significant land position southwest of the Henry Mountains Complex property and drilled approximately 70 holes with little apparent success. In 1970 and 1971, Rioamex Corporation conducted a 40-hole drilling program in an east-west zone extending across the southerly end of the Bullfrog property and the northerly end of the Tony M-Frank M property. Some of these holes intercepted significant uranium mineralization. 

The ownership history of the Bullfrog and Southwest deposits and the Tony M deposit evolved independently from the mid-1970s until early 2005. The Bullfrog and Southwest deposits were initially explored by Exxon Minerals Company (Exxon), while the Tony M deposit was explored and developed by Plateau, a subsidiary of Consumers Power Company (Consumers) of Michigan. In 2005, International Uranium Corporation (IUC) combined the three deposits into a larger land package. In 2021, EFR divested of the Tony M property and Southwest deposit, retaining the mineral claims associated with the Bullfrog deposits (Copper Bench and Indian Bench).

Exxon conducted reconnaissance in the area in 1974 and 1975, resulting in staking of the first "Bullfrog" claims in 1975 and 1976. The first drilling program in 1977 resulted in the discovery of what became the Southwest deposit. Additional claims were subsequently staked, and drilling continued, first by Exxon's Exploration Group, and then by its Pre-Development Group. Several uranium and vanadium zones were discovered in the Southwest and Copper Bench areas, and mineralization exhibiting potential economic grade was also discovered in the Indian Bench area. With the declining uranium markets of the early 1980s, Exxon prepared a prefeasibility report and then discontinued development of the property. Subsequently, Exxon offered the property to Atlas Minerals Corporation (Atlas) in January 1982.

Atlas entered into an agreement to purchase the Bullfrog property from Exxon in July 1982. From July 1982 to July 1983, Atlas completed 112 drill holes delineating the Southwest and Copper Bench deposits on approximately 100 ft centers. In August 1983, Atlas commissioned Pincock, Allen and Holt, Inc. (PAH), to conduct a feasibility study for development of the Southwest and Copper Bench deposits. From July 1983 to March 1984, Atlas completed a core drilling program throughout the Bullfrog property, as well as a rotary drill hole program to delineate the Indian Bench deposit. In November 1983, Atlas renamed the Bullfrog deposits as the "Edward R. Farley Jr. Deposit", but that name is no longer used.

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Atlas continued to hold the Bullfrog property until 1990 when a corporate decision was made to consider its sale. During that year, Mine Reserves Associates, Inc. (MRA) of Tucson, Arizona, was retained to prepare mineral inventory and mineable reserve estimates for the Indian Bench deposit and incorporate the results into a project-wide reserve base. Steve Milne of Milne and Associates (Milne), a principal engineer for the PAH study, was engaged in November 1990 to update the PAH feasibility study and to complete an optimization study on selected mining/milling scenarios. The completed Milne study was submitted to Atlas in December 1990.

Atlas did not sell the Bullfrog property, and in 1991 returned it to Exxon. In late 1992, Energy Fuels Nuclear Inc. (EFNI), no relation to EFR, acting through its subsidiary Energy Fuels Exploration Company, purchased the property from Exxon. EFNI conducted a geologic review and internal economic analysis of the Bullfrog property. In 1997, IUC became the owner of the Bullfrog property as part of an acquisition in which IUC acquired all of EFNI's assets. IUC performed no exploration activities on the properties.

On December 1, 2006, IUC combined its operations with those of Denison Mines Inc. (DMI) and DMI became a subsidiary of IUC. IUC was then renamed Denison. 

In June 2012, Energy Fuels acquired 100% of the Henry Mountains Complex through the acquisition of Denison and its affiliates' U.S. Mining Division.

In October 2021, EFR divested of the Tony M property and Southwest deposit to Consolidated Uranium, Inc. (CUR), retaining the mineral claims associated with the Bullfrog (Copper Bench and Indian Bench) Deposits.

1.3.4 Geology and Mineralization

The Copper Bench and Indian Bench Deposits are classified as sandstone hosted uranium deposits. Sandstone-type uranium deposits typically occur in fine to coarse grained sediments deposited in a continental fluvial environment. The uranium may be derived from a weathered rock containing anomalously high concentrations of uranium, leached from the sandstone itself or an adjacent stratigraphic unit. It is then transported in oxygenated groundwater until it is precipitated from solution under reducing conditions at an oxidation-reduction interface. The reducing conditions may be caused by such reducing agents in the sandstone as carbonaceous material, sulfides, hydrocarbons, hydrogen sulfide, or brines.

Uranium mineralization on the Bullfrog property is hosted by favorable sandstone horizons in the lowermost portion of the Salt Wash Member of the Jurassic age Morrison Formation, where detrital organic debris is present. Mineralization primarily consists of coffinite, with minor uraninite, which usually occurs in close association with vanadium mineralization. Uranium mineralization occurs as intergranular disseminations, as well as coatings and/or cement on and between sand grains and organic debris. Vanadium occurs as montroseite (hydrous vanadium oxide) and vanadium chlorite in primary mineralized zones located below the water table.

The vanadium content of the Henry Mountains Basin deposits is relatively low compared to many other Salt Wash hosted deposits on the Colorado Plateau. Furthermore, the Henry Mountains Basin deposits occur in broad alluvial sand accumulations, rather than in major sandstone channels as is typical of the Uravan Mineral Belt deposits of western Colorado. The Henry Mountains Basin deposits do, however, have the same general characteristic geochemistry of the Uravan deposits, and are therefore classified as Salt Wash type deposits.

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1.3.5 Exploration Status

Energy Fuels has carried out no exploration work on the Project since acquiring the Bullfrog property in 2012.

1.3.6 Mineral Resources

Mineral Resources have been classified in accordance with SEC S-K 1300 definitions, which are consistent with the Canadian Institute of Mining, Metallurgy and Petroleum (CIM) Definition Standards for Mineral Resources and Mineral Reserves dated May 10, 2014 (CIM (2014) definitions), which are incorporated by reference in NI 43-101.

The Mineral Resource estimate was completed using a conventional block modeling approach. The general workflow used by SLR included the construction of a geological or stratigraphic model representing the Jurassic Morrison Formation (Jm) in Seequent's Leapfrog Geo (Leapfrog Geo) from mapping, drill hole logging, and sampling data, which was used to define discrete domain and surfaces representing the upper and lower zones uranium mineralization contacts of the middle portion of the lower Salt Wash Sandstone Member (Jms). The geologic models were then used to constrain resource estimation completed using Seequent's Leapfrog Edge (Leapfrog Edge) software. The resource estimate used a regularized, unrotated whole block approach, inverse distance cubed (ID³) methodology, and 1.0 ft, uncapped composites to estimate the equivalent uranium (eU₃O₈) grade in a three-pass search approach. Hard boundaries were used with ellipsoidal search ranges, and search ellipse orientation was informed by geology and mineralization wireframing. Density values were assigned based on historical bulk density records.

Estimates were validated using standard industry techniques including statistical comparisons with composite samples and parallel inverse distance squared (ID²), ordinary kriging (OK) and nearest neighbor (NN) estimates, swath plots, and visual reviews in cross section and plan. A visual review comparing blocks to drill holes was completed after the block modeling work was performed to ensure general lithologic and analytical conformance and was peer reviewed prior to finalization.

Table 1-4 summarizes the Mineral Resource estimate based on a $90/lb uranium price using a cut-off grade of 0.150% eU₃O₈, with an effective date of December 31, 2024.

Table 1-4: Summary of Mineral Resources - Bullfrog Project - December 31, 2024

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The SLR QP is of the opinion that with consideration of the recommendations summarized in Sections 1 and 26 of this report, any issues relating to all relevant technical and economic factors likely to influence the prospect of economic extraction can be resolved with further work. There are no other known environmental, permitting, legal, social, or other factors that would affect the development of the Mineral Resources.

Based on the similarity of the Bullfrog deposit to other past producing uranium deposits in the Colorado Plateau and the Henry Mountain Mining District, the proposed mining methods at Bullfrog will include a combination of random room and pillar operation with pillar extraction by a retreat system, split shot, and drift and fill.

While the estimate of Mineral Resources is based on the SLR QP's judgment that there are reasonable prospects for eventual economic extraction, no assurance can be given that Mineral Resources will eventually convert to Mineral Reserves.

1.3.7 Mineral Reserves

There are no current Mineral Reserves at the Project.

1.3.8 Mining Method

The Salt Wash Member, which hosts the mineralized horizons, is comprised primarily of sandstones with interbedded shales and mudstones. The Copper Bench and Indian Bench horizons are located in the Upper area of the Salt Wash Member.

It is proposed that the deposit will be developed and mined by two methods: 1) modified room-and-pillar methods using ground support during development to ensure roof stability, especially in weak ground conditions, and 2) drift and fill (DF) for areas of poor rock quality.

Room-and-pillar mining is a simple, low-capital cost mining method in which mining recoveries of 70% to 90% can be expected, dependent upon the rock strengths and geological structures encountered.  Although pillars are anticipated to remain unmined, even with tight backfilling and artificial support, the method is sufficiently flexible to achieve required production rates, control cut-off grades, and maintain safe working conditions.  The operational sequence must be modified when mining heights are high (>12 ft) since multi-cuts and stacked pillars (low width-to-height ratios) are required and backfilling must be used to ensure pillar stability.  This method becomes a hybrid of the cut-and-fill method in areas where the mineralization is thick (12 ft to 16 ft high), because slender pillars are ineffective for roof support and strong global backfill support must enhance local roof support.

With the wide range of mineralized zone stope thicknesses (from 4 ft to 16 ft) and dips/plunges (from flat to 15°), one of the mining methods selected for the Project for this study is step room and pillar (SRP).  Permanent pillars will be left in a pre-designed pattern and cemented rockfill (CRF) will be placed in mined-out areas as backfill.  This method, recommended for the lower grade mineralized lenses, allows for mobile equipment to be used effectively in the range of dips/plunges encountered at Bullfrog.

Drift and Fill (DF) mining methods are well suited for selective precision mining in variable-grade areas and are quite flexible, resulting in high extraction ratios. The volume of open ground at any one time is small since drifts are mined and immediately backfilled before adjacent drifts are mined. The development can be placed in the mineralized areas, minimizing waste rock. This method is not well suited for high production rates, unless many stopes are simultaneously opened, which requires a laterally extensive mineralized zone. The cost of local support (roof cabling through multi-cuts) is high because all cuts must be fully supported. DF mining is recommended for the higher-grade mineralized lenses at Bullfrog, where maximum recovery is desired. This method is widely used in other mines with similar ground conditions and will result in higher mining recoveries as the need to leave permanent pillars will be significantly reduced. This method, however, requires a high quality, high strength engineered backfill in order to be successful.  For the DF method, a high-strength CRF will be placed in the mined-out areas. 

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Bulk mining methods were investigated, particularly for the thick (up to 20 ft) zones. One method considered involved mining of the thick zones in staggered primary and secondary panels using engineered cemented backfill. After the evaluation, this method was considered inapplicable due to the weak rock conditions. The low rock strengths and limited stand-up time made this method impractical given the relatively high stope walls, which would be exposed during the benching process.

The minimum thickness used in the development of the Mineral Resource estimate was three feet. The mineralized zones range exceeding thickness of 3 ft to 16 ft, the Deswik.SO used conservative 4 ft height stopes.  Mineralized zones with thicknesses from 3 ft to 8 ft will be mined in one pass. Mineralized zones exceeding 12 ft in thickness will be mined in two sequential overhand cuts with each cut being approximately one-half of the overall zone thickness.   

In both the Copper Bench and Indian Bench, the mineralized horizons will be further defined using longhole drills from a dedicated drilling horizon located below the mineralized zones. 

The proposed Life of Mine (LOM) schedule was developed based on initiating development from the production decline located adjacent to the mineralized mining zones. The mining areas in Copper Bench and Indian Bench will be connected by means of a 5,400 ft twin decline haulage way.  The last section of the decline will become a single haulage way.

Secondary development connecting the shaft to the various mineralized zones (including the twin decline) will be driven 10 ft wide by 12 ft high with 10 ft rounds.  Production development connecting the primary development to the mining areas will be individual stopes and will be driven 10 ft wide by 8 ft high with 10 ft rounds.

The mining sequence in each of the eight mining zones is dependent upon the development schedule.  Generally, the extraction schedule is sequenced to prioritize the mining of the largest and highest-grade zones in each section of the mine.  Where mineralized zones are stacked, they will be mined in a top-down sequence.

Stope mining begins approximately four years after the start of construction and the operating mine life spans 15 years. The production rate averages approximately 10,000 short tons per month over the life of the mine, assuming 350 operating days per year.

Depressurization of the three main aquifers in the mine area will be accomplished using 11 depressurization wells and underground longholes that will supply water to a couple of underground pumping stations that will ultimately feed water to the Copper Bench sump pumps located in one of the declines. It has been estimated that the mine will discharge a nominal 20 gpm of water at temperatures between 70°F and 80°F. An additional 100 gpm will be produced by surface wells, resulting in a total discharge rate as high as 150 gpm.

The deposit will be developed and mined based on single-pass ventilation using a series of separate and independent intake and exhaust networks. The design requires a total of 10 ventilation raises and the twin declines.  Intake air will be sourced from the two declines and two of the seven ventilation raises; the fresh air intake raise in Indian Bench will be equipped with emergency evacuation hoisting equipment.  The decline to and along the mineralization is approximately 13,500-ft long.

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The LOM statistics for the Project are summarized in Table 1-5.

Table 1-5: Key Bullfrog Life of Mine Production Statistics

1.3.9 Mineral Processing

The White Mesa Mill is currently on a reduced operating schedule processing materials as they become available. 

The Mill uses a Semi Autogenous (SAG) mill operating in closed circuit with vibratory screens for comminution.  Mill feed is fed to the comminution circuit via front end loader. The nameplate production rate for the circuit is 150 short tons per hour (stph).

The Mill uses an atmospheric hot acid leach followed by counter current decantation (CCD) and a clarifier stage to remove suspended solids.  Clarified pregnant leach solution (PLS) reports to the solvent extraction (SX) circuit where uranium and vanadium are extracted from the aqueous solution to an organic phase.  Salt and sulfuric acid are then used to strip the uranium from the organic phase.

After stripping of the uranium from the organic in SX, uranium is precipitated with anhydrous ammonia, dissolved, and re-precipitated to improve product quality.  The resulting precipitate is then washed and dewatered using centrifuges to produce a final U₃O₈ product called "yellowcake". The yellowcake is dried in a multiple hearth dryer and packaged in drums weighing approximately 800 lb to 1,000 lb for shipping to uranium converters.

Tailings from the acid leach plant are stored in permitted 40 acre tailing cells located in the southwest and southern portion of the mill site.  Spent process solutions are stored in the evaporation cells for reuse with excess solutions allowed to evaporate.

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1.3.10 Project Infrastructure

The Project is currently a 'Greenfield' site, i.e., there currently exists no mine infrastructure. Required infrastructure for the site will include surface facilities to support mining operations, such as warehouses, fuel depot, explosive storage facilities, and offices; ventilation shafts and fans; a water treatment plant and evaporation ponds; dewatering wells; mineralized material stockpiles; and waste rock storage facilities. It is planned that electricity will be supplied by an on-site diesel generator, and a substation will be required. Water for the site will be supplied from on site dewatering wells.

Cellular telephone coverage and Starlink satellite services are currently available at the Project.

A 3-mi long access road from Utah Highway 76 west to the Project will be required.

1.3.11 Market Studies

Uranium does not trade on the open market, and many of the private sales contracts are not publicly disclosed since buyers and sellers negotiate contracts privately.  Spot prices are generally driven by current inventories and speculative short-term buying. Monthly long-term industry average uranium prices based on the month-end prices are published by Ux Consulting, LLC, and Trade Tech, LLC. An accepted mining industry practice is to use Consensus Forecast Prices obtained by collating commodity price forecasts from credible sources.

Consensus forecasts collected by SLR show long-term averages of approximately $80.00/lb. General industry practice is to use a consensus long-term forecast price for estimating Mineral Reserves, and 10% to 20% higher prices for estimating Mineral Resources.

For Mineral Resource estimation and cash flow projections, the SLR QP selected a U₃O₈ price of $90.00/lb, on a Cost, Insurance, and Freight (CIF) basis to customer facility, based on independent forecasts. The SLR QP considers this price to be reasonable and consistent with industry practice based on independent long-term forecasts and a mark-up for use with Mineral Resource estimation.

Currently, EFR has not entered into any long-term agreements for the provision of materials, supplies, or labor for the Project. The construction and operations will require negotiation and execution of a few contracts for the supply of materials, services, and supplies.

1.3.12 Environmental, Permitting and Social Considerations

EFR has performed select environmental studies of the Project area, starting in 2014 and supplemented in 2015 and 2016.  The methods and scope of work for these efforts were defined by EFR in coordination with the U.S. Bureau of Land Management (BLM) and the Utah Department of Natural Resources, Division of Oil, Gas and Mining (DOGM). The baseline studies serve as an excellent benchmark for documenting existing site conditions.

Permitting of the proposed Project will require approvals from federal, state and local (county) agencies. These approvals include:

• Plan of Operation and reclamation bond from the BLM

• Notice of Intention and reclamation bond from the Utah DOGM

• Conditional Use Permit from Garfield County

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• Various other approvals from state agencies including an air quality permit, ground water and surface water discharge permits, pond construction and operating permits, a septic permit and water right(s).

A Memorandum of Understanding (MOU) has been developed between the BLM and the DOGM to facilitate a coordinated review and approval process where responsibilities overlap. EFR has a comprehensive understanding of regulatory requirements, permits, authorizations, and the applicable agencies for each.

The land encompassing the Project area is currently designated as multiple use and is used mostly for livestock grazing, wildlife habitat, and recreation (primarily off-road vehicles). Reclamation will return disturbed areas of the Project to the same pre-mining land use(s). Reclamation plans and performance bonds will be required and in place prior to the startup of mining in accordance with state and federal requirements.

1.3.13 Capital and Operating Cost Estimates

The life of mine (LOM) capital cost estimate is summarized in Table 1-6.

Table 1-6: LOM Capital Cost Summary

The LOM average operating cost, summarized in Table 1-7, includes mining, general and administration, freight of the product to a point of sale (White Mesa Mill), toll milling costs at White Mesa Mill, and various royalties and severance taxes.  The Project operating costs were estimated in 2023 US dollars basis. 

Table 1-7: LOM Operating Unit Costs Summary

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2.0 Introduction

SLR International Corporation (SLR) was retained by Energy Fuels Inc. (Energy Fuels) to prepare an independent Technical Report on the Bullfrog Project (Bullfrog or the Project), located in Garfield County, Utah, USA. Energy Fuels is the parent company of Energy Fuels Resources (USA) Inc. (EFR), which owns 100% of the Project. EFR is a US-based uranium and vanadium exploration and mine development company. Energy Fuels is listed on the NYSE American Stock Exchange (symbol: UUUU) and the Toronto Stock Exchange (symbol: EFR).

This Technical Report satisfies the requirements of Canadian National Instrument 43-101 Standards of Disclosure for Mineral Projects (NI 43-101) and United States Securities and Exchange Commission's (SEC) Modernized Property Disclosure Requirements for Mining Registrants as described in Subpart 229.1300 of Regulation S-K, Disclosure by Registrants Engaged in Mining Operations (S-K 1300) and Item 601 (b)(96) Technical Report Summary.

The purpose of this report is to disclose the results of a Preliminary Economic Assessment (PEA). The term PEA is used throughout this Technical Report and is consistent with an Initial Assessment (IA) under S-K 1300.

This report was prepared by Stuart Collins, P.E., Jeffrey L. Woods, MMSA QP, Lee (Pat) Gochnour, MMSA QP, Mark B. Mathisen, C.P.G., Grant A. Malensek, M.Eng., P.Eng., and Tedros Tesfay, SME (RM), all of whom are Qualified Person (QP) within the meaning of both S-K 1300 and NI 43-101 (SLR QP). Messrs. Mathisen, Miranda, and Collins visited the Project on July 15 to 18, 2024.

Bullfrog consists of two contiguous sandstone-type uranium deposits, Copper Bench and Indian Bench, within the Colorado Plateau physiographic province in southwestern Utah. The Colorado Plateau has been a relatively stable structural province since the end of the Precambrian. During the Paleozoic and Mesozoic, the Colorado Plateau was a stable shelf without major geosynclinal areas of deposition, except during the Pennsylvanian when several thousand feet of black shales and evaporates accumulated in the Paradox Basin of southwestern Colorado and adjacent Utah.

The Project is situated in the southeastern flank of the Henry Mountains Basin, a sub province of the Colorado Plateau physiographic province. The Henry Mountains Basin is an elongate north-south trending doubly plunging syncline in the form of a closed basin. It is surrounded by the Monument Uplift to the southeast, Circle Cliffs Uplift to the southwest, and the San Rafael Swell to the north.

The Project originally formed part of the Henry Mountains Complex, which consisted of the Tony M mine and deposit, collectively known as the Tony M property, and the Southwest, Copper Bench, and Indian Bench deposits, collectively known as the Bullfrog property. In October 2021, IsoEnegy Ltd. (formerly Consolidated Uranium Inc. (CUR)) acquired the Tony M property and Southwest deposit from EFR. The remaining deposits (Copper Bench and Indian Bench) that occur to the north as part of the historical Bullfrog property remain under EFR ownership.

The Project is currently being developed in preparation for production. Environmental permitting and compliance activities are being developed to start operations. EFR envisages an underground operation in which the mineralized material will be processed based on a toll milling agreement at Energy Fuels' White Mesa Mill, 127 road miles (mi) away in Blanding, Utah. The Mill has historically run on a campaign basis and processes uranium bearing materials as they become available.

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2.1 Sources of Information

Sources of information and data contained in this Technical Report or used in its preparation are from publicly available sources in addition to private information owned by EFR, including that of past property owners.

This Technical Report was prepared by the SLR QPs with assistance from Yenlai Chee, M.Sc., SLR Senior Resource Geologist, and Hugo M. Miranda, M.Eng., MBA, SME(RM), SLR Principal Mining Engineer. The independent SLR QPs Mathisen and Collins, accompanied by Mr. Miranda, visited the Project under care and maintenance on July 15 to 18, 2024. The SLR QPs toured various parts of the Project, drill hole locations, and infrastructure, and conducted discussions with EFR Project personnel on current and future operations.

Table 2-1 presents a summary of the QP responsibilities for this Technical Report.

Table 2-1: Summary of QP Responsibilities

During the preparation of this Technical Report, discussions were held with personnel from EFR:

• Daniel Kapostasy, P.G., Vice President, Technical Services, Energy Fuels Resources (USA) Inc.

• Race Fisher, Director of Conventional Mining, Energy Fuels Resources (USA) Inc.

• Scott Bakken, P.G., Vice President Regulatory Affairs, Energy Fuels Resources (USA) Inc.

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This Technical Report supersedes the previous Technical Report completed by SLR, dated February 22, 2022 (the 2022 Technical Report).

The documentation reviewed, and other sources of information, are listed at the end of this Technical Report in Section 27 References.

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2.2 List of Abbreviations

The U.S. System for weights and units has been used throughout this Technical Report. Tons are reported in short tons (ton) of 2,000 lb unless otherwise noted. All currency in this Technical Report is US dollars (US$) unless otherwise noted.

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3.0 Reliance on Other Experts

This Technical Report has been prepared by the SLR QP for EFR's parent company, Energy Fuels. The information, conclusions, opinions, and estimates contained herein are based on:

• Information available to the SLR QP at the time of preparation of this Technical Report.

• Assumptions, conditions, and qualifications as set forth in this Technical Report.

3.1 Reliance on Information Provided by the Registrant

For the purpose of this Technical Report, the SLR QP has relied on ownership information provided by Energy Fuels in a legal opinion by Parsons Behle & Latimer dated February 7, 2022, entitled Mining Claim Status Report - Bullfrog Mine, Garfield County, Utah.  The opinion was relied on in Section 4 Property Description and Location and the Summary of this Technical Report. The SLR QP has not researched property title or mineral rights for the Bullfrog Project as we consider it reasonable to rely on Energy Fuels' legal counsel who is responsible for maintaining this information.

The SLQ QP has relied on Energy Fuels for the legal aspects of royalties and other encumbrances for the Project, as described in Section 4 Property Description and Location and the relevant sections of the Summary, as confirmed by Daniel Kapostasy P.G., EFR, Vice President, Technical Services, in an email dated October 10, 2024. The reliance is considered reasonable because the information was supplied by a senior technical officer of the registrant with direct knowledge of the property rights and agreements. Mr. Kapostasy is a licensed professional geologist, and Energy Fuels is the project operator with access to and responsibility for legal and financial records. The SLR QP has reviewed the correspondence and supporting context and finds no reason to question the accuracy or completeness of the information relied upon.

The SLR QP has relied on Energy Fuels for guidance on applicable taxes and other government levies or interests, applicable to revenue or income, to evaluate the viability of the Mineral Reserves stated in Section 22 Economic Analysis, and the relevant sections of the Summary of this Technical Report. This information was confirmed by Kara Beck, Tax Manager for EFR, in an email dated May 7, 2025. The SLR QP is unaware of any changes to the US tax code since the date of confirmation.  This reliance is considered reasonable as Ms. Beck is a qualified tax professional employed by Energy Fuels, with direct responsibility for tax matters relevant to the Project. Energy Fuels, as the project operator and registrant, maintains current knowledge of corporate tax liabilities applicable to its operations. The SLR QP has reviewed the correspondence and context provided and is satisfied that the information is reliable and appropriate for use in the economic evaluation of the Mineral Reserves.

The SLR QP has taken all appropriate steps, in their professional opinion, to ensure that the above information from Energy Fuels is sound.

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4.0 Property Description and Location

4.1 Location

The Bullfrog Project consists of two separate contiguous deposits, also known as Copper Bench and Indian Bench. The Project is located in eastern Garfield County, Utah, 17 mi north of Bullfrog Basin Marina on Lake Powell and approximately 40 mi south of the town of Hanksville, Utah. It is situated three miles west of Utah State Highway 276, and approximately five miles north of Ticaboo, Utah (Figure 4-1).

The approximate center of the Project has the following coordinates:

• Universal Transverse Mercator (UTM): 526,649.08 mE, 4,184861.5m N zone 12S

• Geographic: 37°48'38.71"N latitude and110°41'50.09"W longitude (decimal degrees 37.810753, -110.697247)

• State Plane 1983 Utah South FIPS 4303 (US feet) system: 1,872,319.926 E, 10,260,078.280 N

4.2 Land Tenure

EFR's property position at the Project consists of 128 unpatented mining claims located on U.S. Bureau of Land Management (BLM) land, encompassing approximately 2,344 acres (Figure 4-2). Surface access to conduct exploration, development and mining activities on unpatented mining claims is granted by the BLM if the National Environmental Protection Act (NEPA) regulations are met. The Project is 100% owned by EFR and was acquired from Denison Mines Corp. and its affiliates in June 2012.

All claims, which are renewed annually in September of each year, are in good standing until September 1, 2025 (at which time they will be renewed for the following year as a matter of course). All unpatented mining claims are subject to an annual federal mining claim maintenance fee of $200 per claim to the BLM. Table 4-1 lists the mineral claims covering the Project.

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Table 4-1: List of Claims held by Energy Fuels

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4-4

4-5

4-6

4-7

4-8

Notes:

1. Section - Township - Range

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Figure 4-1: Location Map

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Figure 4-2: Land Tenure Map

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4.3 Required Permits and Status

The annual mining claim holding costs for the Project for 2024 was $25,600.

Environmental baseline studies have been completed. Permitting and compliance-related activities are currently ongoing in preparation for submittal of the appropriate permit applications to start operations, as further discussed in Section 20.

4.4 Royalties

There is no royalty burden for the 168 claims that comprise the Project.

4.5 Other Significant Risks

The SLR QP is not aware of any environmental liabilities on the Project. EFR has all required permits to conduct the proposed work on the Project. The SLR QP is not aware of any other significant factors and risks that may affect access, title, or the right or ability to perform the proposed work program on the Project.

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5.0 Accessibility, Climate, Local Resources, Infrastructure and Physiography

5.1 Accessibility

Road access to the Project is by paved Utah State Highway 276, running between Hanksville, Utah, and Bullfrog Basin Marina, Utah. An unimproved gravel road maintained by Garfield County extends west from Highway 276 (just north of mile marker 19) to the Project. The northern end of the Project can be accessed by the Eggnog Star Spring County Road, approximately 10.4 mi north (near mile marker 17) of Ticaboo, Utah, along Highway 276. A network of unimproved, dirt exploration roads provide access over the Project except in the areas of rugged terrain.

5.2 Vegetation

The vegetation consists primarily of small plants including some of the major varieties of blackbrush, sagebrush, and rabbitbrush. A few small junipers are also present.

5.3 Climate

The climate is distinctly arid with an average annual precipitation of approximately eight inches, in addition to approximately 12 in. of snow. Local records indicate the temperature ranges from a minimum of -10°F to a maximum of 110°F. These conditions allow year-round exploration to occur.

5.4 Local Resources

Skilled labor can be recruited from the region, which has a tradition of uranium mining. Materials and supplies are transported to the site by truck approximately 275 mi from Salt Lake City, Utah, and approximately 190 mi from Grand Junction, Colorado. The distance to Energy Fuels' White Mesa Mill near Blanding, Utah, is 127 mi.

5.5 Infrastructure

The Project is in a relatively remote area of Utah with limited supporting infrastructure in the general vicinity. If the Project is developed, it is anticipated that power will be supplied by diesel generators and water will be supplied by a well. The town of Ticaboo, Utah, is located approximately five miles south of the Project. The next closest community is Hanksville, Utah, a small town of a few hundred people, located approximately 40 mi north of the Project. The Bullfrog Basin Marina airstrip is located approximately 15 mi south of the Project area.

5.6 Physiography 

The Project is located on the lower southern flank of Mt. Hillers (10,723 ft elevation), and to the west and northwest of Mount Ellsworth and Mt. Holmes (7,930 ft elevation). The land surface slopes south-southwesterly from these mountains to Lake Powell, which has an average elevation of approximately 3,700 ft.

Relief over the area is approximately 400 ft. The elevation in the Project area ranges from 5,000 ft above sea level (ft ASL) to 5,400 ft ASL over the northern end of the Project. The terrain is typical canyon lands topography, with some areas deeply dissected by gullies and headwalls of canyons and the rest consisting of gently undulating gravel benches covering the northern part of the project area. The terrain in several parts of the Project is particularly rugged and inaccessible and is the primary reason for the irregular pattern of surface drill holes in parts of the Project.

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There are no perennial streams in the vicinity of the Henry Mountains Complex area, but there are ephemeral streams all of which flow in response to snow melt and rainfall. In the western part of the property area, primary surface waters flow from a series of seeps and springs at the base of the Tununk shale, which is located above the Morrison Formation. The major regional water source is provided by wells developed in the Jurassic-Triassic Navajo sandstone aquifer. The Navajo Sandstone is located at a depth of about 1,800 ft in the Bullfrog property area, placing it about 1,000 ft below the Salt Wash (Jms) uraniferous zones.

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6.0 History

During World War I, vanadium was mined from small deposits outcropping in Salt Wash exposures on the eastern and southern flanks of the Henry Mountains. In the 1940s and 1950s, interest increased in both vanadium and uranium, and numerous small mines developed along the exposed Salt Wash outcrops.

Prior to 2005, all exploration, mine development, and related activities for the two historical properties (Tony M and Bullfrog) were conducted independently. Many historical activities on the Bullfrog and Tony M properties are therefore discussed separately, except where correlations and comparisons are made.

In the late 1960s, Gulf Minerals (Gulf) acquired a significant land position southwest of the Henry Mountains Complex Property and drilled approximately 70 holes with little apparent success. In 1970 and 1971, Rioamex Corporation conducted a 40-hole drilling program in an east-west zone extending across the southerly end of the Bullfrog property and the northerly end of the Tony M-Frank M property. Some of these holes intercepted significant uranium mineralization. 

The history of exploration and development of the Bullfrog property and former Tony M property evolved independently from the mid-1970s until early 2005. The Bullfrog property was initially explored by Exxon, while the former Tony M property was explored and developed by Plateau, a subsidiary of Consumers Power Company (Consumers) of Michigan.

6.1 Prior Ownership

In 1982, Atlas Minerals Corporation (Atlas) acquired the Bullfrog property from Exxon, subsequently returning it to Exxon in 1991. The Bullfrog property was then sold by Exxon to EFNI in 1992. In 1997, IUC became the owner of the Bullfrog property as part of an acquisition in which IUC acquired all of EFNI's assets.

Plateau commenced exploration east of Shootaring Canyon in 1974, and drilled the first holes west of the canyon on the former Tony M property in early 1977. Development of the Tony M decline and mine began on September 1, 1978. Under Plateau, the Shootaring Canyon Uranium Processing Facility (Ticaboo Mill) was developed approximately four miles south of the Tony M mine portals. Operational testing commenced at the Ticaboo Mill on April 13, 1982, with the mill declared ready for operation on June 1, 1982. Following extensive underground development, the Tony M mine was put on care and maintenance in mid-1984 as a result of the cancellation of construction of Consumers' dual-purpose nuclear plants in Midland, Michigan. Plateau's Tony M mine uranium production had been committed to the Midland plants.

Ownership of the former Tony M property was transferred from Plateau to Nuclear Fuels Services, Inc. (NFS) in mid-1990. During its tenure, NFS conducted various investigations including delineation drilling and geologic analysis of the former Tony M property. The report documenting "Geologic analysis of the uranium and vanadium ore reserves in the Tony M Orebody" was prepared for NFS by Nuclear Assurance Corporation (NAC, 1989). Drilling by NFS on the former Tony M property, consisting of 39 rotary holes, was targeted to delineate zones of high-grade uranium mineralization. In addition, with the cooperation of NFS, BP Exploration Inc. drilled one stratigraphic core hole (91-8-14c) on the northern former Tony M property in 1991 (Robinson & McCabe 1997).

In 1994, U.S. Energy Corporation (USEC) of Riverton, Wyoming, then owner of the Ticaboo Mill (which it had acquired from Plateau) entered into an agreement to acquire the Tony M mine and Frank M deposit from NFS. USEC held the mineral properties until the late 1990s when it abandoned them because of the continued low uranium market prices. During this period USEC also conducted a program to close the Tony M mine and reclaim disturbed surface areas, which included backfilling the portals and capping the mine ventilation holes. The buildings and structures were removed, and the terrain was reclaimed and recultivated.

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In February 2005, the State of Utah offered the Utah State Mineral Lease covering Section 16 Township 35 South (T35S) Range 11 East (R11E), Salt Lake Meridian, for auction. Both the portal of the Tony M mine and the southern portion of the Tony M deposit are located on this State section. IUC was the successful bidder, and the State of Utah leased Section 16 to IUC. Subsequently, IUC entered into an agreement to acquire the Utah State Mineral Lease and 17 unpatented Federal lode mining claims (TIC) located between Section 16 and the Bullfrog property claims.

On December 1, 2006, IUC combined its operations with those of Denison Mines Inc. (DMI), acquiring all issued and outstanding shares of DMI and subsequently amending its name to Denison Mines Corp. (Denison). In February 2007, Denison acquired the former Plateau Tony M property, bringing it under common ownership with the Bullfrog property and renaming the properties the Henry Mountain Complex.

In 2007, the Ticaboo Mill was purchased by Uranium One Inc. from USEC. In 2015, Anfield Energy Inc. acquired the mill from Uranium One Inc. The mill is currently in care and maintenance.

In June 2012, EFR acquired 100% of the Henry Mountains Complex through the acquisition of Denison and its affiliates' U.S. Mining Division.

In October 2021, EFR divested of the Tony M property and Southwest deposit to IsoEnergy Ltd. (formerly CUR), retaining the mineral claims associated with the Bullfrog (Copper Bench and Indian Bench) deposits.

6.2 Exploration and Development History

The primary method of exploration used for Salt Wash uranium/vanadium deposits and for the Project specifically is rotary drilling into the host sandstone followed by logging of the drill hole using a gamma probe. Typically, core is only collected from a few holes to determine vanadium content and to determine if there are any disequilibrium issues.

Denison, and its predecessor IUC, carried out no physical work on the properties, with the exception of review of available data and critical evaluation, until the end of 2005, when certain activities including underground reconnaissance and permitting were initiated. A Notice of Intent to Conduct Exploration E/017/044 was issued by the Utah Division of Oil, Gas and Mining, Department of Natural Resources on December 2, 2005. In addition, IUC filed a Notice of Intent to Conduct Mineral Exploration, UTU-80017, with the BLM, on March 6, 2006. A notice of exploration activities was sent to the Utah State Institutional and Trust Land Administration (SITLA), the owner of Section 16, on September 7, 2005.

6.2.1 Bullfrog and Southwest Deposits Property History

Exxon conducted reconnaissance in the area in 1974 and 1975, resulting in staking of the first "Bullfrog" claims in 1975 and 1976. The first drilling program in 1977 resulted in the discovery of what became the Southwest deposit. Additional claims were subsequently staked, and drilling was continued, first by Exxon's Exploration Group, and then by its Pre-Development Group. Several uranium and vanadium zones were discovered in the Southwest and Copper Bench areas, and mineralization exhibiting potential economic grade was also discovered in the Indian Bench area. With the declining uranium markets of the early 1980s, Exxon prepared a prefeasibility report and then discontinued development of the Bullfrog property. Subsequently, Exxon offered the Bullfrog property to Atlas Minerals Corporation (Atlas) in January 1982.

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Atlas entered into an agreement to purchase the Bullfrog property from Exxon in July 1982. From July 1982 to July 1983, Atlas completed 112 drill holes delineating the Southwest and Copper Bench deposits on approximately 100 ft centers. In August 1983, Atlas commissioned Pincock, Allen and Holt, Inc. (PAH), to conduct a feasibility study for development of the Southwest and Copper Bench deposits. From July 1983 to March 1984, Atlas completed a core drilling program throughout the Bullfrog property, as well as a rotary drill hole program to delineate the Indian Bench deposit. In November 1983, Atlas renamed the Bullfrog deposits as the "Edward R. Farley Jr. Deposit", but that name is no longer used.

Atlas continued to hold the Bullfrog property until 1990 when a corporate decision was made to consider its sale. During that year, Mine Reserves Associates, Inc. (MRA) of Tucson, Arizona, was retained to prepare mineral inventory and mineable reserve estimates for the Indian Bench deposit and incorporate the results into a project-wide reserve base. Steve Milne of Milne and Associates (Milne), a principal engineer for the PAH study, was engaged in November 1990 to update the PAH feasibility study and to complete an optimization study on selected mining/milling scenarios. The completed Milne study was submitted to Atlas in December 1990 (Milne & Associates, 1990).

Atlas did not sell the Bullfrog property, and in 1991 returned it to Exxon. In late 1992, EFNI, no relation to EFR, acting through its subsidiary Energy Fuels Exploration Company, purchased the Bullfrog property from Exxon. EFNI conducted a geologic review and internal economic analysis of the Bullfrog property. In 1997, International Uranium Corp. (IUC) became the owner of the Bullfrog property as part of an acquisition in which IUC acquired all of EFNI's assets. IUC performed no exploration activities on the properties.

On December 1, 2006, IUC combined its operations with those of DMI and DMI became a subsidiary of IUC. IUC was then renamed Denison.

EFR acquired all three deposits — Copper Bench, Indian Bench, and Southwest — through its acquisition of Denison's U.S. assets in June 2012. No mine development has been conducted on the Project and EFR has carried out no exploration work on the Project.

6.3 Past Production

No past production has occurred at the Project.

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7.0 Geological Setting and Mineralization

7.1 Regional Geology

The Project is part of the Colorado Plateau physiographic province in southwestern Utah. The Colorado Plateau has been a relatively stable structural province since the end of the Precambrian. During the Paleozoic and Mesozoic, the Colorado Plateau was a stable shelf without major geosynclinal areas of deposition, except during the Pennsylvanian when several thousand feet of black shales and evaporates accumulated in the Paradox Basin of southwestern Colorado and adjacent Utah.

Folding and faulting of basement rocks during the Laramide orogeny of Late Cretaceous and Early Tertiary time produced the major structural features of the Colorado Plateau. Compared to the adjacent areas, however, it affected the plateau only slightly. The nearly horizontal strata were gently flexed, producing the uplifts and basins.

Early Tertiary fluvial and lacustrine sedimentation within the deeper parts of local basins was followed in mid-Tertiary time by laccolithic intrusion and extensive volcanism. Intrusions of diorite and monazite porphyry penetrated the sediments at several sites to form the laccolithic mountains of the central Colorado Plateau. Dikes and sills of similar composition were intruded along the eastern edge of the plateau, probably in Miocene time. Faulting along the south and west margins of the plateau was followed Henry Mountains Basin by epeirogenic uplift and northeastward tilting of the plateau and by continuing erosion which has shaped the present landforms.

7.2 Local Geology

The Project is situated in the southeastern flank of the Henry Mountain basin, a subprovince of the Colorado Plateau physiographic province. The Henry Mountains Basin is an elongate north-south trending doubly plunging syncline in the form of a closed basin. It is surrounded by the Monument Uplift to the southeast, Circle Cliffs Uplift to the southwest, and the San Rafael Swell to the north.

The Project is located to the south of Mt. Hillers (10,723 ft) and to the northwest of Mount Ellsworth and Mt. Holmes (7,930 ft). Exposed rocks in the Project area are Jurassic and Cretaceous in age. Host rocks at the Project are Lower sandstones of the Salt Wash Member (Jms) of the Jurassic Morrison Formation (Jm). In addition, a minor portion (i.e., a few percent) of the Tony M uranium mineralization occurs in the uppermost section of the underlying Tidwell Member (PAH 1985).

Figure 7-1 presents a geologic map of the Bullfrog area.

7.2.1 Stratigraphy

Surface outcrops at the Project include the Tununk Shale Member of the Mancos Shale in the northern portions of the Project area and the Dakota Sandstone and Morrison Formations in the southern portions. Detailed geologic descriptions of the stratigraphic sequence are given below. The stratigraphic section for the Project area is shown in Figure 7-2 and Figure 7-3.

7.2.1.1 Mancos Shale (Tununk Shale Member)

The Tununk Shale Member of the Mancos Shale is a dark gray to blue gray, thinly laminated, calcareous, marine shale that is locally fossiliferous. It contains minor fine-grained quartz sandstone beds. In the Henry Mountains Basin area, it is 440 ft to 720 ft thick (Doelling and Willis 2018).

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7.2.1.2 Dakota Sandstone

The Dakota Sandstone is a grayish orange to light brown, locally fossiliferous sandstone interbedded with light-olive gray shale in the upper half of the formation. The Dakota contains mostly thin, but locally thick, coal beds in the middle of the formation and dark-brown to black carbonaceous claystone, gray shale, siltstone, and some beds of grayish orange to white coarse-grained sandstone in the lower have of the formation (Doelling and Willis 2018).

7.2.1.3 Morrison Formation

The Morrison Formation is a complex fluvial deposit of Late Jurassic age that occupies an area of approximately 600,000 square miles (mi²), including parts of 13 western states and small portions of three Canadian provinces, far to the north and east of the boundary of the Colorado Plateau.

In most areas of major Salt Wash uranium production in Colorado and Utah, the Morrison Formation consists of only the Salt Wash Member and the conformably overlying Brushy Basin Member. The Tidwell Member underlies the Salt Wash Member in some districts.

Morrison Formation (Brushy Basin Member - Jmb)

The Brushy Basin Member is comprised of variegated mudstone and claystone, minor sandstone, and conglomerate. In the Project area, the thickness of the Brushy Basin ranges between 0 ft and 300 ft (Doelling and Willis 2018).

Morrison Formation (Salt Wash Member - J)

The Salt Wash Member is subdivided into three major facies. Uranium-vanadium orebodies have been found in each of the three facies, but the great majority of ore has been mined from the interbedded sandstone and mudstone facies. In outcrop, the Salt Wash is exposed as one or more massive, ledge-forming sandstones, the number varying from one district to another. Closer to the source areas, as in Arizona, the Salt Wash is mainly a massive sandstone or conglomeratic sandstone broken only by a few, thin interbeds of siltstone or clay. Farther from the source areas, as in the area of the Uravan mineral belt, three or more discontinuous sandstone ledges are common, generally interbedded with approximately equal amounts of thick, laterally persistent siltstones or mudstones.

The sandstones of the Salt Wash have been classified as modified or impure quartzite, ranging from orthoquartzite to feldspathic or tuffaceous orthoquartzite. Carbonate cement is a relatively common component in the Salt Wash. The sandy strata of the Salt Wash Member contain many mineable concentrations of uranium throughout the Henry Basin, most of which are relatively small. The Henry Mountains deposits, together with adjoining deposits, constitute the largest Salt Wash-hosted uranium concentration on the Colorado Plateau.

In the southern Henry Mountains Basin, including the Project area, the Salt Wash Member ranges from 400 ft to 510 ft thick. In the northern part of the Tony M deposit, core hole 91-8-14c intersected 444 ft of the Salt Wash Member. The lower Salt Wash sandstones are finer grained, while the upper Salt Wash sandstones consist of more coarse-grained clastics. The lower Salt Wash is approximately 150 ft thick in the Project area, thinning and becoming less sandy northward from the Project area. Sandstones comprise 80% of the sequence, with siltstones and mudstones making up the remainder. Significant uranium mineralization occurs only in this lower unit.

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Tidwell and Summerville Formations (Jt and Js)

The Tidwell Member of the Morrison Formation interbeds with the upper Summerville Formation making the contact difficult to define. The Tidwell is composed of alternating thin beds of light-gray and greenish gray, fine-grained, calcareous sandstone and calcareous moderate red or green shale. The Summerville Formation is a reddish brown, ribbed or thinly bedded siltstone and mudstone and brown to white, fine-grained sandstone. Locally it includes pink and white gypsum near the top. Near the top of the formation, the Summerville contains interbedded red and gray mudstone, pink and white gypsum, gray limestone, and gray sandstone that are part of the overlying Tidwell Formation (Doelling and Willis 2018).

7.2.2 Structural Geology

The structural geology of the Project reflects a gentle westward dip off the Monument Uplift, toward the axis of the Henry Mountains Basin, except where the strata have been influenced by the adjacent Mount Hillers and Mount Ellsworth intrusive igneous bodies. As a result, strata at Bullfrog dips a few degrees to the west and southwest.

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Figure 7-1: Regional Geologic Map

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Figure 7-2: Regional Stratigraphic Column

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Figure 7-3: Detail of the Lower Portion of the Lower Rim of the Salt Wash Member

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7.3 Mineralization

7.3.1 Uranium Mineralization

The uranium-vanadium mineralization in the Henry Mountains Basin area is similar to the mineralization observed elsewhere in the Colorado Plateau.

It occurs as intragranular disseminations within the lower fluvial sand facies (Lower Rim) of the Salt Wash Member containing detrital organic debris. Mineralization primarily consists of coffinite, with minor uraninite, which usually occurs in close association with vanadium mineralization. Mineralization occurs as intergranular disseminations, as well as coatings and/or cement on and between sand grains and organic debris (Northrop and Goldhaber, 1990).

The Lower Rim of the Salt Wash Member has been subdivided into an upper, middle, and a lower unit designated as the Upper-Lower, Middle-Lower, and Lower-Lower. Each of these subunits, in turn, have been subdivided into upper, middle, and lower horizons. The Bullfrog deposit primarily occurs in upper and lower portions of the Middle-Lower unit (i.e., 60 ft to 100 ft above the base) with minor mineralization found in the upper portion of the Lower-Lower unit.  Minor mineralization is also seen in the underlying Tidwell formation.

Table 7-1 presents a summary of the naming conventions of the mineralized sands for the Henry Mountains Complex.

Table 7-1: Naming Convention of the Mineralized Sands for the Henry Mountains Complex

The framework minerals of the Salt Wash host beds for the Tony M deposit are predominantly quartz, (averaging 70% to 79% of the rock) with minor, variable amounts of feldspar (ranging from 1% to 14% and averaging 4%). Rock fragments average about 7% but range from 1% to 60%. Accessory minerals form about 2% or less of the rock. The sandstones are classified as modified or impure quartzite, ranging from orthoquartzite to feldspathic orthoquartzite.

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The Salt Wash sandstone is cemented by carbonate and silica and/or clay minerals that average about 17% of the total volume of the samples studied. Calcite is the most common carbonate. In the mineralized zones, the proportionate of clay minerals increases and the amount of carbonate decreases. The carbonate in the mineralized zone is also marked by the presence of dolomite. Organic carbon commonly occurs in the concentration of 0.1 to 0.2 weight percent (wt%) but ranges up to 1 wt% or higher in some zones. The predominant type of organic matter is coalified detrital plant debris together with a trace amount (<1%) of unstructured organic matter. This detrital debris occurs as individual elongate fragments a few tens of micrometers to about 5 mm in length. Silicified logs, carbonized organic debris, and pyrite are locally abundant in the uranium-vanadium bearing zone.

Quartz overgrowths in amounts ranging from 1% to 12% are present with the highest concentrations associated directly with the mineralized zone(s).

Other "ore-stage" minerals identified in the U.S. Geologic Survey (USGS) study include pyrite (0% to 3.3%), quartz overgrowths (0% to 17%), dolomite and calcite (Wanty et al., 1990). The quartz overgrowths are often visible to the naked eye within the Tony M mine. While dolomite is associated with the mineralized zones, the abundance of calcite decreases in highly mineralized zones. This is thought to occur because calcite postdates the deposition of vanadium bearing chlorite and other "ore-stage" minerals that preferentially plug the pores of the mineralized zone. 

The main uranium mineralized horizons appear as laterally discontinuous, horizontal bands of dark material separated vertically by lighter zones lacking uranium but enriched in vanadium. On a small scale (inches to feet), the dark material often exhibits lithologic control, following cross-bed laminae or closely associated with, though not concentrated directly within, pockets of detrital organic debris.

The Bullfrog deposit extends approximately 3.5 mi along a northwesterly trend to the northeast of the Tony M-Southwest deposit.  Mineralization of the Bullfrog deposits ranges in thicknesses of three feet to six feet but occasionally is shown on radiometric logs exceeding 12 ft in some portions of the Project area.

The age of the deposit is 115 million years, indicating that the mineralization formed shortly after deposition of the Brush Basin Member of the Morrison Formation (Ludwig 1986 from Wanty et al. 1990).

7.3.2 Vanadium Mineralization

Vanadium occurs as montroseite (hydrous vanadium oxide) and vanadium chlorite in primary mineralized zones located below the water table (i.e., the northern portion of the Tony M deposit). Montroseite is the only vanadium oxide mineral identified in this interval. An unusual vanadium-bearing chlorite or an interlayered vanadium-bearing chlorite-smectite is the only authigenic clay mineral(s) recognized. The grain size and sorting characteristics of detrital quartz grains vary within the host rocks; cross-bed laminae with coarser grains and better sorting are invariably more highly mineralized (Wanty et al. 1990).

Above the water table vanadium chlorite is absent, while montroseite and a suite of secondary uranium-vanadium minerals are present. These include tyuyamunite, metatyuyamunite, rauvite, and carnotite all of which have been identified in samples from the southern part of the Tony M deposit. Carnotite is a secondary hydrous potassium-vanadium-uranium mineral, while the other three are similar minerals with calcium replacing potassium. The later minerals occur above the water table in the zone that has been subjected to near surface secondary oxidation.

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The V₂O₅:U₃O₈ weight ratios in Salt Wash-type deposits range from about 1:1 to 20:1 with the V₂O₅:U₃O₈ routinely reported as 5:1 based on U.S. Atomic Energy Commission (AEC) production records of 18,300 tons for the period 1956 to 1965. Focusing only on the South Henry Mountains (also known as the Little Rockies) mining district, the V₂O₅:U₃O₈ ratio is markedly lower with ranges from approximately 1.3:1 to approximately 2.0:1. This value is also based on production records for the period 1956 to 1965, comprising about 6,900 tons produced from several small mines all located within a few miles of the Tony M mine (Doelling 1967).

Determining the concentration of vanadium in a deposit is much more costly and time-consuming than making the equivalent determination for uranium. While indirect determinations of the uranium content may be efficiently made at low cost using gamma logging, chemical analysis is the only way to determine the vanadium content.

Northrop and Goldhaber (1990) established that the relationship between the uranium and vanadium mineralization in the Henry Mountains Mining District is not a simple one. Vanadium enrichment in the mineralized intervals occurred over a thicker interval than uranium. Northrop and Goldhaber (1990) found that while uranium and vanadium often reached their maximum concentration at the top of each uranium-bearing horizon, the vertical distribution of vanadium was frequently distinct from uranium.

While there is a clear tendency for higher-grade uranium to be associated with higher-grade vanadium, the relationship is somewhat erratic and high-grade uranium samples frequently have low concentrations of vanadium.

7.3.3 Other Elements

Table 7-2 shows the concentration of several minor elements occurring with the uranium and vanadium.

Table 7-2: Minor Element Concentrations of Various Rock Composites

The average concentration of CaCO₃ is a consideration for processing cost and ranges from 5.4% to 11.1%. Northrop and Goldhaber (1990) observed that the character of the mineralized zones which contain significant concentrations of vanadium chlorite and other pore filling minerals effectively blocked the deposition of large amounts of carbonate and therefore the mineralized zones usually have a carbonate content that is less than the non-mineralized Salt Wash sandstone. 

Molybdenum concentrations above detection levels were found to occur only close to mineralized horizons, and generally each mineralized horizon has an associated zone of molybdenum enrichment. Vanadium and chromium enrichment in the mineralized intervals occur over a thicker interval than uranium and/or molybdenum.

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8.0 Deposit Types

Sandstone-type uranium deposits typically occur in fine- to coarse-grained sediments deposited in a continental fluvial environment. The uranium is either derived from a weathered rock containing anomalously high concentrations of uranium, leached from the sandstone itself, or leached from an adjacent stratigraphic unit. It is then transported in oxygenated water until it is precipitated from solution under reducing conditions at an oxidation-reduction front. The reducing conditions may be caused by such reducing agents in the sandstone as carbonaceous material, sulfides, hydrocarbons, hydrogen sulfide, or brines.

There are three major types of sandstone hosted uranium deposits: tabular vanadium-uranium Salt Wash type of the Colorado Plateau, uraniferous humate deposits of the Grants, New Mexico area, and the roll-type deposits of Wyoming. The differences between the Salt Wash deposits and other sandstone hosted uranium deposits are significant. Some of the distinctive differences are as follows:

• The deposits are dominantly vanadium, with accessory uranium.

• One of the mineralized phases is a vanadium-bearing clay mineral.

• The deposits are commonly associated with detrital plant trash, but not redistributed humic material.

• The deposits occur entirely within reduced sandstone, without adjacent tongues of oxidized sandstone.

The vanadium content of the Henry Mountains Basin deposits is relatively low compared to many Uravan deposits. Furthermore, the Henry Mountains Basin deposits occur in broad alluvial sand accumulations, rather than in major sandstone channels as is typical of the Uravan deposits of Colorado. The Henry Mountains Basin deposits do have the characteristic geochemistry of the Uravan deposits and are classified as Salt Wash type deposits.

Extensive research by Northrop and Goldhaber (1990) shows that the Henry Mountains Basin deposits were formed at the interface of an underlying brine with overlying oxygenated flowing waters carrying uranium and vanadium in solution. Reduction and deposition of the mineralization were enhanced where the interface occurred within sandstones containing carbonaceous debris. The multiple mineralized horizons developed at favourable intervals as the brine surface migrated upwards. Geochemical studies indicate the uranium and vanadium were leached either from the Salt Wash sandstone or the overlying Brushy Basin Member.

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9.0 Exploration

EFR has not conducted any exploration or geotechnical activities on the Project, since acquiring the properties in 2012.

9.1 Hydrogeology

9.1.1 Overview

The proposed Bullfrog underground mine consists of two adjacent sandstone-type uranium deposits, Copper Bench and Indian Bench. The exposed rocks in the Project area date to the Jurassic and Cretaceous periods. The uranium deposit is situated within sandstone of the lower Salt Wash member of the Jurassic Morrison Formation (Jm), primarily composed of coffinite, along with smaller quantities of uraninite and vanadium. The mineralized zone found 60 ft to 100 ft above the base of the Salt Wash member(Western Water & Land 2015).

The SLR QP is not aware of any site-specific hydrogeologic data for the groundwater system in the Project area. However, due to the uniformity of the subsurface water resources, it is reasonable to utilize data from nearby regions. Three hydrogeological reports and additional relevant documents were reviewed, forming the basis for this section (Mower 1980; Blanchard 1986; Western Water & Land 2015). A detailed description of the geological formations in the Lake Powell area, along with hydraulic conductivity information based on grain size analysis for some of these formations, can be found in Blanchard (1986) and its referenced works, including Stokes (1964), Hackman and Wyant (1973), and Peterson and Pipiringos (1979).

During development of the Tony M mine by Plateau, water inflows in the order of 100 gpm were pumped to surface for disposal in an evaporation pond. Estimates of inflow indicated that simultaneous maximum inflows to the proposed Bullfrog mine should not exceed 126 gpm (Plateau 1981).

A 2015 search, confirmed by a recent inquiry by SLR QP, identified one surface water right and four to six groundwater well rights within a one-mile radius of the Project area, as noted by Mower (1980). In line with previous studies by Mower (1980), LASR Geo Consulting (2008), and Energy Fuels (Western Water & Land 2015), no springs were found within this radius. Although there are no perennial streams nearby, ephemeral flows do occur due to rainstorms and snowmelt. The Project is currently in the advanced exploration stage, with environmental permitting and compliance activities underway to commence operations.

No site-specific data has been collected by EFR or other parties; however, this section reviews the available hydrogeological data from the area surrounding the project site.

9.1.2 Main Findings

9.1.2.1 Primary Aquifers

The primary aquifers in the area include the Navajo Sandstone, Wingate Sandstone, and Entrada Sandstone, with the Navajo and Entrada Sandstones being the most frequently used (Blanchard 1986). The Navajo Sandstone, the oldest formation with hydrologic data available for evaluating drinking water and mill water sources, is a thick aquifer that holds significant quantities of high-quality water, making it suitable for both uses (Mower 1980; Blanchard 1986).

While the geologic formations above the Navajo Sandstone in the Project area do contain groundwater, their low yield and poor water quality render them unsuitable for supplying the mill or the town site. Generally, aquifers within the Glen Canyon Group, including these formations, are recharged by precipitation infiltrating directly in exposed bedrock areas, particularly in the southeastern region or at the base of the Henry Mountains, as well as through seepage from nearby bedrock.

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In addition to the Navajo Sandstone, the following provides an overview of other aquifers within the alluvial and bedrock strata of the Henry Mountains area and the Project site (Western Water & Land, 2015).

9.1.2.2 Secondary Aquifers and Confining Layers

An overview of other aquifers within the alluvial and bedrock strata of the Henry Mountains area and the Project site (Western Water & Land, 2015) follows.

Alluvium and Pediment Gravels: - The uppermost water-bearing unit in the Henry Mountains area consists of unconsolidated Quaternary deposits. Water in these alluvial deposits is intermittent, originating from drainage flows, precipitation infiltration, and discharge from underlying bedrock. A spring and seep survey found several springs near the Bullfrog Project site, though none were within a one-mile radius of the proposed facilities.

Mancos Shale: Though typically a confining unit, the Manco Shale can yield small amounts of water from its sandstone layers, with springs and seeps found near the Bullfrog Project site.

Dakota Sandstone: Underlying the Mancos Shale, the Dakota Sandstone may yield small amounts of water but is not considered a significant aquifer.

Brushy Basin: A member of the Morrison Formation, the Brushy Basin is a confining unit beneath the Dakota Sandstone, generally does not yield water and forms the foundation of the Bullfrog Facilities Area.

Salt Wash Member: The shallowest groundwater at the Project area is found in the Salt Wash Member of the Morrison Formation, though it is not a major aquifer and yields poor-quality water in low amounts. Recharge likely occurs from precipitation infiltration or seepage from surrounding bedrock. Dewatering of the Tony M Mine, south of the Project, was required due to groundwater seepage from the Salt Wash Member, with pumping rates ranging from 15 gpm to 120 gpm.

Summerville Formation: Located beneath the Salt Wash Member, unlikely to yield water, and considered a confining layer.

Entrada Sandstone: It is a major aquifer in the area, likely recharged by precipitation where exposed bedrock and fractured strata exist, particularly near the Henry Mountains. Additional recharge may come from seepage through nearby bedrock and dune sands southwest of Mount Ellsworth. Wells that are screened in the Entrada Sandstone are detailed in the Western Water & Land (2015) report.

Carmel Formation: This formation provides limited water to springs and seeps east of Ticaboo; it primarily acts as a confining layer between the Entrada Sandstone and the Navajo Sandstone of the Glen Canyon Group.

9.1.3 Summary of Previous Permitting and Regulatory Documentation

The Project is currently in the advanced exploration stage, with environmental permitting and compliance activities in progress to begin operations. Western Water & Land (2015) produced a report to fulfill the Utah Department of Environmental Quality's requirements for a Groundwater Discharge Permit and to support EFR's mining and exploration permitting efforts. According to email correspondence (August 1, 2024) with EFR, no permits have been issued for the site at this time; however, a permitting matrix detailing the required permits has been completed.

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9.1.4 Summary of Hydrogeological Understanding

The Navajo Sandstone, though not exposed at the Project site, lies between 1,000 ft and 2,999 ft below the surface and is estimated to be approximately 797 ft thick (Mower 1980). The potentiometric surface of the aquifer is at least 164 ft above the base of the Carmel Formation, indicating that the Carmel acts as a confining bed (Figure 9-1).

The SLR QP is unaware of any specific hydrogeologic data available for this formation in the Project area; however, the uniformity of the formation permits the use of hydrogeologic data from nearby locations. A pumping test in the Navajo Sandstone aquifer near the Plateau Resources Ltd. mill showed a transmissivity of 234 m²/day and a storage coefficient of about 3 x 10⁻³ (Mower 1980). These values can be applied to the Project due to the typically uniform nature of the Navajo Sandstone and the lack of evidence for significant changes in the sandstone between the two areas. However, the transmissivity and storage coefficient at the Bullfrog project could be slightly higher if the formation of Mount Hillers caused increased fracturing in the sandstone.

Inflow into the mine, necessitating dewatering from the underground workings, is estimated to be approximately 22 gallons per minute (1.4 liters per second) per 0.6 miles of the mine. Dewatering of the Tony M Mine, located south of the Project, recorded pumping rates varying between 15 gpm and 120 gpm (Mower 1980). The reported dewatering results. of Tony M is likely an indicator of the potential for dewatering at the Project site, due to their proximity and similar geological conditions, but further fieldwork and analysis to achieve greater refinement is required per the SLR QP.

No site-specific water quality data is available; within a one-mile radius of the Project area, historical monitoring wells data shows sodium sulfate/sodium carbonate water types that may be classified as "saline" on a Piper diagram. Uranium concentrations in the water ranged from 2.6 µg/L to 22.2 µg/L across three sampling dates (Western Water & Land 2015).

The report by Western Water & Land (2015) includes water quality data from the Tony M Mine and several wells beyond the one-mile radius. The groundwater quality analysis indicates that total dissolved solids (TDS) in well samples ranged from 237 to 808 mg/L, which meets Utah Class II protection standards. In contrast, TDS levels from the Tony M Mine are considerably higher, ranging from 1,970 to 3,660 mg/L. The report by Western Water & Land (2015) includes water quality data from the Tony M Mine (located outside the Project's property boundary) and several wells beyond the one-mile radius. Water from the Tony M Mine, collected from an underground sump, consistently shows a magnesium sulfate to calcium sulfate type, classified near "permanent hardness" on the Piper diagram. This composition differs from groundwater in the Lower Salt Wash unit due to mineral dissolution in the mine's stratigraphic rock layers (Western Water & Land 2015).

9.1.5 Potential Mine Impacts

The SLR QP recommends that the potential impacts of the proposed underground mine on both groundwater and surface water in the Project area should be assessed by gathering site-specific hydrogeological data and conducting numerical modeling.

The need for water treatment during dewatering is uncertain, given the absence of chemical data for the Project site. Once the mine becomes fully operational, a groundwater monitoring program will be essential to assess data from existing underground workings and newly installed monitoring wells.

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Figure 9-1: Potentiometric Surface of the Navajo Sandston

Source: adapted from Mower 1980.

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10.0 Drilling

Historically the basic tool for exploring on the Project was conducted by rotary drilling using a tricone bit with a nominal diameter of 5.1 in., supplemented by diamond drilling (DD or Core) down to depths of 1,200 ft. Exploration holes at Bullfrog are used to determine lithology and uranium content using radiometric probes.

Drill hole collar locations are recorded on the original drill logs and radiometric logs created at the time of drilling, including easting and northing coordinates in local grid or modified NAD 1983 Utah State Plane FIBPS 4303 (US feet) and elevation of collar in feet above sea level. Due to the horizontally stratified nature of mineralization, downhole deviation surveys are not typically conducted as all drill holes are vertical.

Energy Fuels has not conducted any drilling since acquiring the Project.

10.1 Historical Bullfrog Drilling

Exxon commenced drilling on the Bullfrog property in 1977. Before it sold the Bullfrog property to Atlas in July 1982, Exxon reportedly drilled 1,782 holes. From July 1982 to July 1983, Atlas completed 112 drill holes delineating the Southwest and Copper Bench deposits on approximately 100 ft centers. After July 1983, Atlas completed an additional 49 core hole drilling program throughout the Bullfrog deposit, as well as a 133 rotary drill hole program to delineate the Indian Bench deposit on approximately 200 ft centers. Drill hole spacing in some areas is irregular and more widely spaced where rugged terrain does not allow access. Analysis indicated the Indian Bench deposit is similar to the Copper Bench deposit, and it is a northwesterly continuation of the Copper Bench deposit. The Indian Bench mineralization occurs in the same stratigraphic interval of the Salt Wash Member as the Copper Bench mineralization. The depth of mineralization in the Project is nearly 1,100 ft, with base elevation of the deposit at approximately 4,500 ft ASL.

As of the effective date of this Technical Report, a total of 2,232 drill holes were reportedly completed on the Bullfrog property by both Exxon and Atlas (Schafer 1991). This drilling includes drilling completed over the Southwest deposit which was acquired by CUR in October of 2021.

10.2 Core Drilling

Records indicate that a total of 81 core holes were drilled in the Southwest, Copper Bench, and Indian Bench deposits by EFR's predecessors. These holes were most likely used for equilibrium analysis work, as discussed in Section 11.1.5. No core from any of the deposits is known to exist and was therefore not available to analyze for this Technical Report, but this is nonmaterial to the resource estimation work.

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Figure 10-1: Bullfrog Drill Hole Location Map

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11.0 Sample Preparation, Analyses, and Security

11.1 Sample Preparation, Analyses, and Security 

11.1.1 Gamma Logging

Exploration drilling for uranium is unique in that core does not need to be recovered from a hole to determine the metal content. Due to the radioactive nature of uranium, probes that measure the decay products or "daughters" can be measured with a downhole gamma probe; this process is referred to as gamma logging. While gamma probes do not measure the direct uranium content, the data collected (in counts per second or CPS) can be used along with probe calibration data to determine an equivalent U₃O₈ grade in percent (% eU₃O₈). These grades are very reliable if there is no disequilibrium problem in the area. Disequilibrium will be discussed below. Gamma logging is common in non-uranium drilling and is typically used to discern rock types.

The original downhole gamma logging of surface holes was done on the Bullfrog property by Century Geophysical Corp. (Century) and Professional Logging Services, Inc. (PLS) under contract to Exxon. Atlas also contracted Century for this service. Standard logging suites included radiometric gamma, resistivity, and self-potential measurements, supplemented by neutron-neutron surveys for dry holes. Deviation surveys were conducted for most of the holes. Century used its Compulog system consisting of truck-mounted radiometric logging equipment, including a digital computer. The natural gamma (counts per second, or cps), self potential (millivolts), and resistance (ohms) were recorded at 1/10th foot increments on magnetic tape and then processed by computer to graphically reproducible form. The data were transferred from the tape to computer for use in resource estimation.

Procedures followed by Exxon, Atlas, and Plateau, together with their contractors Century and PLS, were well documented and at the time followed best practices and standards of companies participating in uranium exploration and development. Onsite collection of the downhole gamma data and onsite data conversion limit the possibility of sample contamination or tampering.

11.1.1.1 Calibration

For the gamma probes to report accurate %eU₃O₈ values the gamma probes must be calibrated regularly. The probes are calibrated by running the probes in test pits maintained historically by the AEC and currently by the DOE. There are test pits in Grand Junction, Colorado, Grants, New Mexico, and Casper, Wyoming. The test pits have known %U₃O₈ values, which are measured by the probes. A dead time (DT) and K-factor can be calculated based on running the probes in the test pits. These values are necessary to convert CPS to %eU₃O₈. The dead time accounts for the size of the hole and the decay that occurs in the space between the probe and the wall rock. DT is measured in microseconds (μsec). The K-factor is simply a calibration coefficient used to convert the DT-corrected CPS to %eU₃O₈.

Quarterly or semi-annual calibration is usually sufficient. Calibration should be done more frequently if variations in data are observed, or the probe is damaged.

11.1.1.2 Method

Following the completion of a rotary hole, a geophysical logging truck will be positioned over the open hole and a probe will be lowered to the hole's total depth. Typically, these probes take multiple different readings. In uranium deposits, the holes are usually logged for gamma, resistivity, standard potential, and hole deviation. Only gamma is used in the grade calculation. Once the probe is at the bottom of the hole, the probe begins recording as the probe is raised. The quality of the data is impacted by the speed the probe is removed from the hole. Experience shows a speed of 20 feet per minute is adequate to obtain data for resource modeling. Data is recorded in CPS, which is a measurement of uranium decay of uranium daughter products, specifically Bismuth-24. That data is then processed using the calibration factors to calculate a eU₃O₈ grade. Historically, eU₃O₈ grades were calculated using the AEC half amplitude method, which gives a grade over a thickness. Currently, the eU₃O₈ grades tend to be calculated on 0.5-foot intervals by software. Depending on the manufacturer of the probe truck and instrumentation, different methods are used to calculate the eU₃O₈ grade, but all, including the AEC method, are based on the two equations given below.

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The first equation converts CPS to CPS corrected for the dead time (DT) determined as part of the calibration process

The second equation converts the Dead Time Corrected CPS (N) to %eU₃O₈ utilizing the K-factor (K)

Depending on the drilling and logging environment, additional multipliers can be added to correct for various environmental factors. Typically, these include a water factor for drill hole mud, a pipe factor if the logging is done in the drill steel, and a disequilibrium factor if the deposit is known to be in disequilibrium. Tables for water and pipe factors are readily available.

11.1.2 Core Sampling

11.1.2.1 Sample Preparation

The following information is extracted from the 2012 Technical Report (Roscoe et al., 2012) as reported by the 1983 Report on Disequilibrium Variability (Bhatt 1983) and 1983 Report on Bullfrog Laboratory Studies (Rajala, 1983) as reported by EFR. EFR has not conducted any drilling at the Project since EFR acquired the property in 2012, and therefore no additional samples have been prepared for analysis. No data was available to the SLR QP for review, and the information is included for reference only.

Atlas drilled a number of core holes, from which core was sampled and analyzed. Below is a description of the method used for preparing the composites as reported by Rajala (1983).

Each of the composites consisted of 0.5 ft drill core intervals combined in such a manner as to give a composite head analysis exceeding 0.2% U₃O₈. Only one-half of the full core was available for composite preparation. The Indian Bench, Southwest, and Copper Bench composite samples contained 45, 104, and 90 core intervals, respectively. When possible, the composites were prepared using equal weights from each interval but, since the sample weight were small (e.g., approximately 50 g), for some of the intervals, the total weight of the composites was limited. Each minus 10-mesh interval was blended on a rolling mat prior to splitting out the appropriate weight for the composite.

The composites were stored in cylindrical containers and then placed on a set of rolls for at least eight hours to achieve complete blending of the intervals. The blended samples were placed on a rolling mat and flattened with a spatula. A head sample, along with 500 g test samples, was split out by random cuts of the primary samples. The head samples were pulverized to minus 100-mesh for chemical analysis.

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11.1.2.2 Assaying and Analytical Procedure

Every interval was analyzed for U₃O₈, V₂O₅, and CaCO₃. The initial U₃O₈ analyses were performed fluorometrically, with samples greater than 0.02% U₃O₈ being rerun volumetrically. The Atlas Fluorometric Laboratory also performed the initial V₂O₅ analyses and the Atlas Ore Lots Laboratory repeated V₂O₅ assays on samples that assayed greater than 0.2% V₂O₅. Most CaCO₃ analyses were run only once in the Ore Lots Laboratory. Results of the analysis are presented in Section 10 Mineral Processing and Metallurgical Testing. Certification and accreditation of the Atlas Laboratory is unknown as the laboratory is no longer in existence. It was independent of EFR.

11.1.3 Radiometric Equilibrium

Disequilibrium in uranium deposits is the difference between equivalent eU₃O₈ grades and assayed U₃O₈ grades. Disequilibrium can be either positive, where the assayed grade is greater than the equivalent grades, or negative, where the assayed grade is less than the equivalent grade. A uranium deposit is in equilibrium when the daughter products of uranium decay accurately represent the uranium present. Equilibrium occurs after the uranium is deposited and has not been added to or removed by fluids after approximately one million years. Disequilibrium is determined during drilling when a piece of core is taken and measured by two different methods, a counting method (closed-can) and chemical assay. If a positive or negative disequilibrium is determined, a disequilibrium factor can be applied to eU₃O₈ grades to account for this issue.

Exxon conducted analyses of samples from core drilling in the Southwest and Copper Bench deposits, using results from Core Labs. Exxon found that the radioactive disequilibrium of potentially economic grade intercepts in cores, measured as the ratio of chemical % U₃O₈ to log radiometric equivalent (% eU₃O₈), varied from 0.80 to 1.35 and averaged 1.06, close to the equilibrium value of 1.0. Milne (1990) reported that, while the investigation by Atlas of samples from core from an additional 40 drill holes was incomplete at the time, Atlas had identified no significant disequilibrium problem.

The most comprehensive analysis of disequilibrium of uranium in the area was completed by Bhatt (1983) using the results from 2,354 composite samples collected from buggies coming from the Tony M mine over the period 1980 to 1982. Based on sampling records, Bhatt divided the analytical results according to various areas of origin in the mine. This provided the basis to estimate the relative state of disequilibrium for uranium in different areas of the deposit. A summary of Bhatt's results is given in Table 11-1.

Bhatt reports that the analyses of closed can uranium and chemical uranium were performed at the Plateau laboratory at the Ticaboo Mill. Certification and accreditation of the Plateau Laboratory is unknown as it is no longer operational, and it was independent of EFR. Bhatt also reports that many independent check analyses were sent to independent commercial laboratories as a Quality Assurance practice.

Table 11-1: Plateau Disequilibrium Study

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Based on the analysis, Bhatt concluded:

• The state of disequilibrium varies from location to location within the deposit.

• With the exception of one small area in the southern part of the deposit, the disequilibrium factor is positive.

• Low-grade material with less than 0.06% U₃O₈ is depleted in uranium.

• Higher-grade material containing more than 0.06% U₃O₈ is enriched in uranium.

Bhatt also concluded that the overall weighted disequilibrium factor of chemical to radiometric uranium grade (at a grade x thickness (GT) cut-off of 0.28%-ft) for the Tony M deposit is about 1.06. The disequilibrium factor for Tony M is similar to the factor of 1.06 determined by Exxon for the Southwest and Copper Bench deposits of the Bullfrog property.

Based on the information available, the original gamma log data and subsequent conversion to % eU₃O₈ values are reliable but slightly conservative estimates of the uranium U₃O₈ grade. Furthermore, there is no evidence that radiometric disequilibrium would negatively affect the uranium resource estimates of the Copper Bench-Indian Bench deposits.

11.2 Sample Security

EFR has conducted no core sampling since acquiring the properties. All reported core sampling was performed by previous operators Exxon and Atlas. The reported sample preparation, handling of the historical coring, and sample security cannot be confirmed.

11.3 Quality Assurance and Quality Control

EFR Geologists identified 25 twinned drill holes (drilled by Exxon and Atlas) in the Bullfrog deposit, of which 23 were reviewed by AMEC (now Wood) in 2016 to determine the reason there was a large discrepancy between the "original" hole, which typically contained high-grade uranium and the "twin", which typically contained lower-grade uranium. Table 11-2 presents the statistics for both the non-twinned drill holes in the database and the twinned drill holes.

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Table 11-2: Statistics for Project and Twin Database Holes

AMEC attributed the decrease in thickness and grade between the "Original" and the "Twin" due to selection bias, i.e., the selection of holes with higher grades and thicker mineralized zones to twin as opposed to issues with the method of logging the original holes. The data for the "twin" is much more in line with the larger project database than the "original". In its recommendations, AMEC suggested EFR twin 20 additional holes with the "originals" coming evenly from every 5^th percentile in the project database. As of the issuance of this Technical Report, EFR has not conducted any drilling at Bullfrog.

11.4 Conclusions

In the SLR QP's opinion, the historical radiometric logging, analysis, and security procedures at Bullfrog are adequate for use in the estimation of Mineral Resources. The SLR QP also opines that, based on the information available, the original gamma log data and subsequent conversion to % eU₃O₈ values are reliable. Furthermore, there is no evidence that radiometric disequilibrium would be expected to negatively affect the uranium resource estimates.

The SLR QP is of the opinion that the sample security, analytical procedures, and QA/QC procedures used by EFR meet industry best practices and are adequate to estimate Mineral Resources.

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12.0 Data Verification

Data verification is the process of confirming that data has been generated with proper procedures, is transcribed accurately from its original source into the project database and is suitable for use as described in this Technical Report.

As part of the resource estimation procedure, drill data is spot checked by EFR personnel and audited by the SLR QP for completeness and validity. Specifically, any data which appears higher or lower than the surrounding data is confirmed by reviewing the original geophysical log. This data review includes confirming that the drill depth was adequate to reflect the mineralized horizon, that the geologic interpretation of host sand is correct, and that the thickness and grade of mineralization is correct.

The primary assay data used to calculate the Mineral Resource estimate for the Bullfrog property is downhole geophysical log data. While the resource estimate methodology has changed since the last Mineral Resource estimate was completed in 2012 (Roscoe et al., 2012), EFR has conducted no additional drilling on the Project or completed any additional data analysis, and the downhole geophysical database remains unchanged since 2012.

The drilling and radiometric logging data associated with the Bullfrog deposit was audited by RPA (now SLR) in 2012, and EFR staff and AMEC (now Wood) consultants in 2016. In all reviews of the Bullfrog data, audits of historical records were completed to assure that the grade, thickness, elevation, and location of uranium mineralization used in preparing the current Mineral Resource estimate corresponded to mineralization indicated by the original gamma logs of drill holes on the Project. EFR and its predecessors reviewed the available information to verify the reliability of the eU₃O₈ grade as determined by downhole gamma logging. The findings of those studies are provided below.

12.1 RPA Henry Mountain Complex Data Review (2012)

In 2012, RPA conducted audits of historical records to assure that the grade, thickness, elevation, and location of uranium mineralization correspond to mineralization indicated by the original gamma logs of drill holes on the Henry Mountains Complex. RPA reviewed the available information to verify the reliability of the eU₃O₈ grade as determined by downhole gamma logging.

Exxon and Plateau both conducted programs previously to investigate the state of chemical equilibrium of uranium in their respective deposits, and to verify the reliability of the eU₃O₈ grade as determined by downhole gamma logging. This was done by comparing the results of chemical analysis of drill core, closed can radiometric analysis of the core samples, and downhole gamma logs for the core intervals in question. Plateau also conducted a much more extensive sampling program from 189,332 tons of mine production, equal to about 80% of total mine production, of mineralized material extracted from the Tony M mine. Analyses of these samples were used to establish the relationship between chemical and radiometric uranium grade within most areas of the deposit (Bhatt, 1983).

While RPA reviewed the detailed results of this verification program as described in Bhatt's 1983 report, RPA did not have access to the original analyses for this investigation. The results of both the core analysis program for the Southwest deposit and Plateau's mine production sampling program indicate that, while the state of chemical equilibrium does vary from zone to zone in the deposits, taken overall, the gamma log estimates of grade are slightly conservative and underestimate the average U₃O₈ grade by up to 6%. RPA also concurred with Bhatt's conclusion that mineralized material with a grade of <0.06% U₃O₈ has a chemical uranium content that is lower than the radiometric uranium content and is in a negative state of disequilibrium. Atlas reportedly conducted a program of analysis of core samples, with similar results. RPA did not have access to any of the data from Atlas's investigation.

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RPA did not verify any chemical analyses for Copper Bench or Indian Bench deposits because no core samples were available.

12.2 EFR-AMEC Bullfrog Deposit Data Review (2016)

In 2016, EFR contracted AMEC (now Wood) to conduct a review of a newly compiled drill hole database for the Copper Bench and Indian Bench portions of the Bullfrog deposit. The compilation of the database was completed as the first step in calculating an updated resource for the Copper Bench and Indian Bench portions of the Bullfrog deposit. That updated resource is provided in Section 11 of this Technical Report.

EFR geologists reviewed all the original drill logs for the Bullfrog deposit and the downhole gamma data was entered. The Upper-Lower, Middle-Lower, and Lower-Lower sands of the Salt Wash Member of the Morrison Formation were interpreted from the geophysical logs. AMEC geologists reviewed this work and provided a report detailing their report and findings. Recommendations included:

1 Thoroughly checking collar elevations for holes with respect to the surface topography wireframe

2 Thoroughly checking the x, y, z coordinates of desurveyed stratigraphic contacts versus coordinates on the wireframe surfaces where holes pierce the wireframes

3 Interpreting mineralized zones on fences as opposed to cross sections, snapping wireframe contacts to drill holes

4 Using the GAMLOGBF2 version to convert natural gamma to eU₃O₈ for PD series holes. Using Compulog eU₃O₈ values supplied by Century for the BF series holes.

Item 1 regarded survey busts in the z direction or errors in converting z elevations to the current coordinate system. All collars were tied to z values from an aerial survey conducted at the Project area in 2005 and have since been corrected. Items 2 and 3 refer to the generation of wireframes used to constrain a block model. As the new resource was completed using GT contours and not a block model, these two recommendations do not apply to the current Mineral Resource estimation. Item 4 refers to how counts per second (CPS) values from the gamma log are converted into % eU₃O₈ values. Century Geophysical has a proprietary software called COMPULOG that automatically converts CPS to % eU₃O₈ and Item 4 recommends using that data as is for those holes. For those holes not logged by Century (the later PD series holes were drilled by Professional Logging Services), AMEC recommended using an updated version of the GAMLOG algorithm developed by Scott (1962) to convert the CPS to % eU₃O₈. That conversion was done by AMEC and those values are what are used in the current Bullfrog deposit drill hole database.

Regarding the geologic picks from the geophysical logs done by EFR geologists, AMEC concluded that the picks were accurate and that it was not practical or necessary to subdivide the geologic units.

Based on these reviews of the grade and thickness of uranium mineralization indicated in the original gamma logs for the Bullfrog deposits and comparisons with the computer-generated GT composites, the SLR QP is of the opinion that the original gamma log data and subsequent conversion to eU₃O₈ values are reliable and suitable for a mineral resource estimate.

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12.3 SLR Data Verification (2021)

The SLR QP visited the Project and the adjacent Tony M-Southwest property in July 2021 in support of CUR's acquisition of the Tony M and Southwest deposits from EFR in 2021. Discussions were held with the EFR technical team and found them to have a strong understanding of the mineralization types and their processing characteristics, and how the analytical results are tied to the results. The SLR QP received the project data from EFR for independent review as a series of MS Excel spreadsheets and ArcGIS digital files. The SLR QP used the information provided to validate the Mineral Resource interpolation, tons, grade, and classification.

12.3.1 Audit of Drill Hole Database

In preparing the 2022 Technical Report, the SLR QP revisited the work completed in 2012, conducted audits of historical records and a series of verification tests on the drill hole database to assure that the grade, thickness, elevation, and location of uranium mineralization used in preparing the current Mineral Resource estimate correspond to mineralization indicated by the original gamma logs of drill holes on the Project.

The SLR QP's tests included a search for unique, missing, and overlapping intervals, a total depth comparison, duplicate holes, property boundary limits, and verifying the reliability of the % eU₃O₈ grade conversion as determined by downhole gamma logging. No errors were encountered, and no significant issues were identified.

12.3.2 Audit of GT Contours

Based on its review of the grade and thickness of uranium mineralization indicated in the original gamma logs for the deposits, and comparisons with the computer-generated GT composites, the SLR QP is of the opinion that the original gamma log data and subsequent conversion to eU₃O₈ values are reliable for use in preparing a Mineral Resource estimate.

The SLR QP carried out check estimates of the historical polygonal models using the GT drill intercept contour method. The contour method has been described by Agnerian and Roscoe (2002) and has been used for many decades for estimation of uranium resources, particularly in the western U.S.

Total GT values for each drill hole intercept within the Middle-Upper (MU), Middle-Lower (ML), and Lower (L) horizon sandstones (zones) were plotted on plans and contoured. Results indicated that although continuity of mineralization is variable, local continuity exists within each sandstone unit in both plan and section as elongate tabular or irregular shapes. Mineralization also occurs in various horizons within the sandstone domains. The contained pounds of U₃O₈ estimated by the contour method are in the same general range as the historical polygon estimate.

12.4 SLR Data Verification (2024)

12.4.1 Audit of Drill hole Database

SLR audited and validated the drill hole database used for the previous resource estimation (2022) to assure that the grade, thickness, elevation, and location of uranium mineralization are reliable for use in preparing a Mineral Resource estimate. As no additional exploration or drilling activities have occurred since the previous Mineral Resource Estimate which could impact the integrity of the database, the SLR QP continues to accept the database as being accurate and appropriate for Mineral Resource estimates.

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12.4.2 Audit of GT Contours

Using the validated drill hole database, a trend analysis was conducted in Leapfrog Geo to validate the zones identified by the polygonal models of the GT drill intercept contour method.

The trend analysis model yielded similar results to the GT contour method identifying zones of U₃O₈ like those defined previously as Middle-Upper (MU), Middle-Lower (ML), and Lower (L).

12.5 Limitations

There were no limitations in place restricting the ability to perform an independent verification of the Project drill hole database. There has been adequate drilling to develop the Mineral Resource models.

12.5.1 Conclusion

The SLR QP is of the opinion that the database contains valid data, the verification procedures for the Bullfrog property comply with industry standards, and the data is suitable for the purposes of Mineral Resource estimation.

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13.0 Mineral Processing and Metallurgical Testing

The White Mesa Mill is located six miles south of Blanding in southeastern Utah. Construction commenced in June 1979 and was completed in May 1980. Its construction by EFNI was based on the anticipated reopening of many small low-grade mines on the Colorado Plateau, and the mill was designed to treat 2,000 tons of mineralized material per day. The mill has operated at rates in excess of the 2,000 tons per day design rate. The mill has been modified to treat higher grade ores from the Arizona Strip, as well as the common Colorado Plateau ores. Processing of Arizona Strip ores is typically at a lower rate of throughput than for the Colorado Plateau ores. The basic mill process is a sulfuric acid leach with solvent extraction recovery of uranium and vanadium.

Since 1980, the mill has operated intermittently in a series of campaigns to process ores from the Arizona Strip as well as from a few higher-grade mines of the Colorado Plateau. Overall, the mill has produced approximately 30 Mlb U₃O₈ and 33 Mlb V₂O₅.

13.1 Metallurgical Testing 

The following information is extracted from the 2012 Technical Report (Roscoe et al. 2012) and 1983 Report on Bullfrog Laboratory Studies (Rajala 1983) as reported by EFR. No additional metallurgical testing has been completed on the Project since EFR acquired the Project in 2012 and no data was available to SLR for review.

Drill core from the Bullfrog deposits was tested by Atlas in 1983 to determine metallurgical parameters (Rajala, 1983). Amenability results for a strong acid leach indicated overall recoveries of 99% U₃O₈ and 90% V₂O₅. Additional testing of a mild acid leach and an alkaline leach gave recoveries of 97% U₃O₈ and 40% V₂O₅ for both. Acid consumption for the strong acid leach was 350 pounds per ton.

Samples from each deposit were combined to give representative composites. Each composite consisted of 0.5 ft drill core intervals combined in such a manner as to give a composite head analysis exceeding 0.2% U₃O₈. The Southwest, Copper Bench, and Indian Bench composite samples contained, respectively, 104 core intervals from 16 drill holes core intervals, 90 core intervals from seven drill holes, and 45 core intervals from four drill holes. The results of the analyses for uranium, vanadium, and calcium carbonate are compared with the values calculated based on the weighted value of each of the individual core samples included in the composite. Results of the analysis are given in Table 13-1.

Table 13-1: Comparison of Composite Head Analyses with Calculated Head Grade Analyses

In 1982, the Shootaring Canyon mill processed some 27,000 tons of mineralized material from the Tony M mine; however, details were not available to SLR.

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From November 2007 to December 2008, a total of 162,384 tons at 0.131% eU₃O₈, containing 429,112 lb U₃O₈, were trucked to the White Mesa Mill at Blanding, Utah, for processing. Of this material, 90,025 tons at 0.165% eU₃O₈ (297,465 lb) were extracted by Denison from the Tony M mine and 72,359 tons at 0.091% eU₃O₈ (131,647 lb) came from stockpiled material mined by previous operators. Based on this, the recovery for the Tony M material was estimated to be 95%. As the Copper Bench and Indian Bench deposits are similar to the Tony M deposit, similar recoveries should be expected for the Project.

13.2 Opinion of Adequacy

The QP supports the conclusions of the expected performance of the metallurgical processes based on historical test work.

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14.0 Mineral Resource Estimates

14.1 Summary

Mineral Resources have been classified in accordance with SEC S-K 1300 definitions, which are consistent with the Canadian Institute of Mining, Metallurgy and Petroleum (CIM) Definition Standards for Mineral Resources and Mineral Reserves dated May 10, 2014 (CIM (2014) definitions), which are incorporated by reference in NI 43-101.

The Mineral Resource estimate was completed using a conventional block modeling approach. The general workflow used by SLR included the construction of a geological or stratigraphic model representing the Morrison Formation (Jm) in Seequent's Leapfrog Geo (Leapfrog Geo) from mapping, drill hole logging, and sampling data, which was then used to define discrete domain and surfaces representing the Lower Zone and the Upper Zone (which is the combination of the ML and MU zones as identified in Table 7-1) of the lower Salt Wash Sandstone Member (Jms). The geologic model was then used to constrain resource estimation completed using Seequent's Leapfrog Edge (Leapfrog Edge) software. The resource estimate used a regularized, unrotated whole block approach, inverse distance cubed (ID³) methodology, and 1.0 ft, uncapped composites to estimate the uranium (eU₃O₈) in a three-pass search approach. Hard boundaries were used with ellipsoidal search ranges, and search ellipse orientation was informed by geology and mineralization wireframing. Density values were assigned based on historical bulk density records.

Estimates were validated using standard industry techniques including statistical comparisons with composite samples and parallel inverse distance squared (ID²), ordinary kriging (OK), and nearest neighbor (NN) estimates, swath plots, and visual reviews in cross section and plan. A visual review comparing blocks to drill holes was completed after the block modeling work was performed to ensure general lithologic and analytical conformance and was peer reviewed prior to finalization.

Table 14-1 summarizes the Mineral Resource estimate based on a $90/lb uranium price using a cut-off grade of 0.150% eU₃O₈, with an effective date of December 31, 2024.

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Table 14-1: Summary of Mineral Resources as at December 31, 2024

The SLR QP is of the opinion that with consideration of the recommendations summarized in Sections 1 and 26 of this report, any issues relating to all relevant technical and economic factors likely to influence the prospect of economic extraction can be resolved with further work.  The SLR QP is not aware of any environmental, permitting, legal, social, or other factors that would affect the development of the Mineral Resources.

Based on the similarity of the Bullfrog deposit to other past producing uranium deposits in the Colorado Plateau and the Henry Mountain Mining District, the proposed mining methods at Bullfrog will include a combination of long-hole stoping, and a random room and pillar operation with pillar extraction by a retreat system.

While the estimate of Mineral Resources is based on the SLR QP's judgment that there are reasonable prospects for eventual economic extraction, no assurance can be given that Mineral Resources will eventually convert to Mineral Reserves.

14.2 Resource Database

As of the effective date of this Technical Report, historical records of EFR predecessors indicate that approximately 1,694 drill holes have been completed on the Bullfrog deposit. Of the 1,694 drill holes, 949 drill holes totaling 910,780 ft of drilling were used in this Mineral Resource estimate. Historical surface holes missing collar information, lithology information, or corresponding radiometric logs, i.e., assay data, were excluded. A summary of the available data used in the modeling of mineralization is presented in Table 14-2. Figure 10-1 shows the location of the drill holes.

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Table 14-2: Summary of Drill Hole Data used in Mineral Resource Estimation