DRC-2012-003301 - 0901a068804f9105

Department of
Quaiity fjRrj. 2Q12-3
Amanda Smith
Executive Director
State of Utah DIVISION OF RADIATION CONTROL
Rust Lundberg
Director
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
DRC-2012-003301
June 12, 2012
David Frydenlund
Vice President Regulatory Affairs and Counsel
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, Colorado 80265
RE: Radioactive Material License (RML) Number UT1900479: Health Physics Inspection
RADMOD-Training-01
Dear Mr. Frydenlund:
On May 30, 2012, an inspection was conducted at your facility by Ryan Johnson and Kevin
Carney, representatives of the Division of Radiation Control (DRC) of the Utah Department of
Environmental Quality. Observations from the inspection were discussed with David Turk and
Dan Hillsten at the closeout meeting. The inspection was an examination of the activities
conducted in your facility as they relate to compliance with the Utah Radiation Control Rules, the
license conditions of the RML UT1900479 and Federal Regulations. The inspection consisted of
an examination of representative records, interviews of personnel, and observations by the
inspector.
Enclosed is the inspection report regarding this inspection for your review. The DRC considers
this inspection closed. The DRC would like to thank the Mill staff for their cooperation regarding
this inspection. If you have any questions concerning this letter contact Mr. Ryan Johnson
[phone].
Sincerely,
RL/RJ:rj
Cc: David Turk, Site Radiation Safety Officer
Enclosures
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T D D. (801) 536^414
www.deq.utah.gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module: RADMOD-AFIL-01: Alternate Feed and Insitu-Leach
Inspection Location: Denison Mines- White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Alternate Feed Acceptance and Circuit and Insitu Leach Recovery (ISL)
(a.k.a. 1 le(2)) Material Acceptance and Disposal)
Inspection Dates: May 30,2012
Inspectors: Ryan Johnson, Utah Division of Radiation Control (DRC)
Personnel Contacted: Dave Turk (Radiation Safety Officer (RSO)),
Ronnie Nieves (Radiological Coordinator)
Terry Slade (Chief Chemist)
Instrumentation: Bicron Microrem S/N: 09048 Cal. Due: 10/27/2012
Ludlum 2360 S/N: 237303 Cal. Due: 06/15/2012
Note: Instruments were source checked prior to inspection.
Governing Documents:
• UACR313-15
• Radioactive Materials License (RML) UT 1900479
Opening Meeting
Denison Mines:
Dave Turk (Radiation Safety Officer)
Utah DRC:
Ryan Johnson (Inspector)
Kevin Carney (Inspector)
During the opening meeting, the inspector discussed the inspection items and documentation to be
reviewed during the inspection. Only the Alternate Feed Circuit of the Mill was in operation
during this inspection, the remainder of the Mill was in shut down for maintenance. The Mill staff
reminded the inspector of the safety requirements for the Mill.
Inspection Summary
The inspection consisted of employee interviews, review of documentation and a mill tour. The
following discussion provides more detail of the specific items.
Item 1. Mill Tour: The inspector walked through the restricted area on a general site tour. The
tour included the ore pad, the new decontamination pad, the mill, the alternate feed circuit, and the
tailings ponds.
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While touring the ore pad the inspector observed that large numbers of drummed alternate feed
material have been processed since the last inspection. In addition to alternate feed material being
processed at the Alternate feed circuit, Comeco Calcine drums were being emptied at the Mill's
drum station just north of the grizzly. The Mill was emptying approximately 500 drums per day at
this location.
The inspector observed Comeco Phospate drums were also being emptied at the south drum station
next to the Alternate feed circuit. The Mill was processing approximately 20 drums per day at this
location. The inspector observed that there was a new concrete pad next to both drum stations that
are next to the Alternate feed circuit and that drums being staged were being stored on the concrete
pads. Drums waiting processing were being stored in overpacks behind the dry chemical storage
area.
While touring the tailing cells the inspector was able to observe ISL material being disposed in a
trench on tailing cell #3. The inspector observed:
• The metal debris being crushed by a CAT 9 Bulldozer;
• The metal and other debris being pushed into the trench;
• The CAT 9 bulldozer compacting the material once it was placed in the trench; and
• The trench was not covered because more material was to be placed into the trench when the
next shipment arrived.
The inspector also observed that the Alternate feed drums that were being stored on tailing cell #2
were being stored according to approved procedure.
The DRC inspector also observed:
• Proper PPE was being worn by Mill employees within the Alternate Feed Circuit and other
areas of the Mill;
• Proper Radiological Posting were being used at the Alternate Feed Circuit;
• TLDs were appropriately being used for general area Gamma radiation monitoring within the
Alternate Feed Circuit; and
• Appropriate air monitoring, both general area and quarterly breathing zone, was being done
within the Alternate feed circuit.
The inspector was also able to confirm that the recommendations listed below from the last
alternate feed/ISL disposal inspection were implemented.
1. The 11 e.(2) Byproduct Material Disposal Documentation Form in Attachment 2 of SOP PBL-
10 R-3 1 le.(2) Byproduct Disposal was used immediately. Now the DRC has approved of the
SOP.
2. The concrete for the Drum Dumping Node is completed.
3. The cracks in the concrete floor of the Alternate Feed Circuit are repaired.
Deficiencies:
None
Item 2. Documentation:
Alternate Feed Documentation: The Inspector reviewed the documentation for alternate feed
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acceptance to determine when the last shipment was received. The Inspector also discussed and
confirmed information with David Turk and Terry Slade.
Generator Name Approximate Year of Last
Shipment
Corresponding License
Condition
Linde 2003 10.14
Ashland 1 2004 10.12
Ashland 2 2004 10.10
St. Louis Never received 10.13
Maywood Never received 10.18
NTS Cotter 1997 10.8
Honeywell 2012 10.6
Cabot 2012 10.9
Allied Signal 1997 10.7
Rhone-Poulenc 1997 Not Specified
Cameco K.F 2012 10.11
Cameco UF4 2012 10.11
Cameco Calcine 2012 10.11
Cameco Phosphate 2012 10.11
WR Grace Never received 10.15
Heritage 2003 10.16
Molycorp 2004 10.17
FMRI 2007 10.19
Note: List of approved alternate feeds and corresponding License Conditions comes from the 2007
RML renewal and interrogatory responses.
During discussions with David Turk (Mill RSO), he informed the inspector that prior to the Mill
processing alternate feed material, the Mill samples the alternate feed material. This is done so the
RSO can calculate the derived air concentration (DAC) values and implement the appropriate air
sampling and assign the appropriate personal protective equipment (PPE) requirements.
The inspector also confirmed that there was enough room in the tailing cells for the amount of
alternate feed that is currently at the Mill.
ISL Disposal Documentation: The Inspector reviewed the documentation for ISL acceptance and
disposal.
Observations: The ISL material shipment was documented with:
• 11 e.(2) Byproduct Material Disposal Documentation Form
• A Bill of Lading;
• Photographs of the load of material when it arrived;
• PID (VOC) readings;
• Radiological Survey Information from the load when it arrived; and
• The generators shipping papers.
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Deficiencies:
None
Closeout Meeting
Denison Mines:
Dave Turk (RSO)
Dan Hillsten (Mill Manager)
Utah DRC:
Ryan Johnson (Inspector)
Kevin Carney (Inspector)
During the closeout meeting the inspector discussed the observations that the inspector had during
the inspection.
Findings
None
Recommendations
None
Recommendation for Next Inspection
1. Spills (yellowcake and other materials) being cleaned up in the mill immediately, and
2. Personnel Exit Monitoring
Prepared By: Ryan Johnson
(Print Name)
Reviewed By: Phil Goble
(Print Name)
(Signature (Date)
(Signature) (Date)
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t
UTAU JI VISION OF RADIATION CO.. xROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-AFIL-01
ALTERNATE FEED/INSITU LEACH FACILITY MATERIALS
DENISON MINES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT 1900479
References: Radioactive Material License UT1900479, License Renewal Application dated February 28, 2007,
Radiation Protection Manual, Section 5, 10CFR20, Utah Administrative Code R313-15.
Alternate Feed Material (License Conditions 10.L 10.6 through 10.19)
1) Review the alternate feed manifests from the last two years. Determine the last time a shipment was
received, How much material has been accepted over the course of the project.(License Condition 10.6
through 10.19)
Generator Name Corresponding
License
Condition
Date of Last
Shipment
Amount Received Storage
Location/Processed
Lindc 10.14
Ashland 1 10.12
Ashland 2 10.10
St. Louis 10.13 •Ac • - -
Maywood 10.18
NTS Cotter 10.8
Honeywell 10.6
Cabot 10.9
Allied Signal 10.7 (JM) A? 4 1-
Rhone-Poufenc 979 7 T<
4 /2J Cameco KF 10.11 3 t<T^ 'Je-' C
Cameco UF4 10.11 Ceil ^
Cameco Calcine 10.11 A
Cameco
Phosphate
10.11 7A
WR Grace 10.15
Heritage 10.16 7 CP
Molycorp 10.17 /0i 5
—7
Y* c FMRI 10.19 >7 ^ <
Note* L.Cs. 10.8, 10.10 & 10.12 are being removed from the RML when RML is renewed.
2) Have any alternate feeds been accepted that were not approved through a License Amendment?
Cornments: ,y A A Yes No
U:\rad\COMMON\Uranium millsU le(2)UT 1900479 Denison Mines - White Mesa UMillNHP Inspection modules\2012\Inspection Modules\RADMOD-AFlL-02.doc
p.™ 1 «f in
^7
T 1
/
<7 3,
3) How much tailings cell dispose capacity does the mill have left at the U. „ of the inspection? % &/( z ^
How much alternate feed/ore/ISL material does the mill have onsite? ^— // 7~&^
Does the amount of alternate feed/ore/ ISL material exceed the tailing cell capacity? Yes No >C
' Is the current surety amount adequate for the amount of alternate feed/ore/ ISL material currently stored at
the mill? (License Condition 10.1) Yes X No
Comments:
Observe the Alternate Feed Circuit being used.
4) Which Alternate Feed is being processed?(Name and Associated License Condition)
Comments: y
22 4a.
v^-. ""L 2 7 A^-^t
5) What PPE is being used?
Alternate Feed Circuit
Drum Dumping Node
PPE Observed Y/N
Alternate Feed Circuit
UF4 Carbonate
Digestion Node
PPE Observed Y/N
PPE Requirements (check applicable)
Hard Hats
Safety Glasses
Safety Boots
Rubber Boots
Coveralls
S Tyvek
Hearing
Respirators
Lab Coats
Gloves
Disp. Gloves
Face Shields
Rubber Suits
Other
PPE Requirements (check applicable)
Hard Hats • Tyvek
Safety Glasses
Safety Boots
Rubber Boots
Coveralls
Hearing
^^Respirators
Lab Coats
• "Gloves
Disp. Gloves
Face Shields
Rubber Suits
Other
Alternate Feed Circuit
NaOH Precipitation
Node
PPE Observed Y/N
PPE Requirements (check applicable)
Hard Hats
Safety Glasses
Safety Boots
Rubber Boots
Coveralls
•"Tyvek
•
Hearing
Respirators
Lab Coats
Gloves
Disp. Gloves
Face Shields
Rubber Suits
Other
Alternate Feed Circuit
NaOH Precipitate
Filtration Node
PPE Observed Y/N
PPE Requirements (check applicable)
Hard Hats
Safety Glasses
Safety Boots
Rubber Boots
Coveralls
y Tyvek
Hearing
S Respirators
Lab Coats
Gloves
Alternate Feed Circuit PPE Requirements (check applicable)
Disp. Gloves
Face Shields
Rubber Suits
Other
U:\rad\COMMON\Uranium millsU le(2)UTl900479 Denison Mines - White Mesa UMill\HP Inspection modu!es\2012\Inspection Modules\RADMOD-AFIL-02.doc
Filter Cake Acid
Re-Dissolution Node
PPE Observed Y/N
Hard txats
Safety Glasses
Safety Boots
Rubber Boots
Coveralls
/
Tyvek
Hearing
Respirators
Lab Coats
oves
Disp. Glovfcj
Face Shields
Rubber Suits
Other
Alternate Feed Circuit
Filtration After Acid
Digestion of Filter
Cake Node
PPE Observed Y/N
PPE Requirements (check applicable)
Hard Hats
Safety Glasses
Safety Boots
Rubber Boots
Coveralls
• "Tyvek
Hearing
Respirators
Lab Coats
;/ Gloves
Disp. Gloves
Face Shields
Rubber Suits
Other
Alternate Feed Circuit
Impurity Removal
Node
PPE Observed Y/N
PPE Requirements (check applicable)
Hard Hats
Safety Glasses
Safety Boots
Rubber Boots
Coveralls
Tyvek
Hearing
Respirators
Lab Coats
Gloves
Disp. Gloves
Face Shields
Rubber Suits
Other
Comments:
6) Is the New Circuit operated under an RWP or an SOP? RWP SOP ><^
Comments:
7) Where are the air monitoring Stations located for the Alternate feed Circuit?
Comments: / ^ . ,
7t~ C-<// c".
8) What type of air Monitoring are they doing for the Alternate feed Circuit?
Comments: , / //
9) Is the Air Monitoring in the Alternate Feed Circuit adequate? Yes^X^No
U:\rad\COMMON\Uranium millsU le(2)UTl900479 Denison Mines - White Mesa UMill\HP Inspection modules\2012\Inspection Modules\RADMOD-AFIL-02.doc
Comments:
10) Is the Alternate feed Circuit posted? Yes^^ No
Is each area within the Alternate feed Circuit posted differently? Yes )<j No
How is the Alternate feed Circuit area(s) posted?
Comments:
11) Does the posting(s) reflect the radiological/health concerns present? Yes3K/ No_
Comments:
12) Are area gamma monitors in the Alternate Feed Circuit located appropriately? Yes / No_
Comments: ,
13) What are the types of monitoring systems being used and are they appropriate?
Comments: ^
U:\rad\COMMON\Uranium millsU le(2)UTl900479 Denison Mines - White Mesa UMillVHP Inspection modules\2012\Inspection Modules\RADMOD-AFIL-02.doc
14) Briefly describe the drum hanu-.ig and loading into the Alternate Feed ^..cuit.
Comments: •;
Note * Tom during a previous inspection documented that drums were being staged off of the Alternate Feed
Circuit with possible staining in soils from the drums
Alternate Feed Material (Containerized Alternate Feedstock Material Storage Procedure)
U:\rad\COMMON\Uranium millsU le(2)UTl900479 Denison Mines - White Mesa UMillNHP Inspection modules\2012\Inspection Modules\RADMOD-AFlL-02.doc
• 15) Are all Alternate Feed materials stored on the Ore Pad? Yes No ^XT
If answer is no then go to questions 16 through 21. If yes skip to question 22.
N Comments:
16) Where is the Alternate Feed not on the Ore Pad being stored?
.Comments: ^
17) Is the Alternate Feed Material being stored on a Hardened Surface? Yes No^X.
If No, Is the Alternate feed being stored in Over Pack containers? Yes ^XTNo
Comments: , •
18) Are Alternate Feed Containers stacked no more then 2 wide and 2 high? Yes X^ No
Comments:
x 19) Are Alternate Feed Containers being stored on planks or pallets? Yes A- No
Comments:
7 X X ; ^ X^X
20) Are Alternate Feed Storage areas bermed? Yes No_
Comments:
X 21) Are weekly inspections of the Alternate Feed Storage Areas being done and documented? Yes ANo
Comments:
U:\rad\COMMON\Uranium millsM le(2)UTl900479 Denison Mines - White Mesa UMill\HP Inspection modules\2012\Inspection Modules\RADMOD-AFIL-02.doc
Dor,,, tnf IA
Insitu Leach Facility Material (ju^ense Condition 10.5)
22) According to License Condition 10.5 Part D "All disposal activities shall be documented". Review the
% disposal records from the past year. Describe how the shipments are documented and what is documented.
Comments:
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4
Table 4.2-1 •
Alternate Feed Materials Licensed to Date for Processing at the Mill
Alternate Feed Description Volume Average Uranium
Content
(Wt % U)
Linde Soils contaminated with uranium and
other radionuclides
100,000 tons 0.07%
Ashland Soils contaminated with uranium and
other radionuclides.
172,600 tons 0.06%
Ashland Soils contaminated with uranium and
other radionuclides.
43,980 tons
St. Louis 12
0.009%
Soils contaminated with uranium and
other radionuclides.
1,029,000 CY 0.09%
Maywood Soils contaminated with Th-232, uranium
and other radionuclides.
250,000 Tons 0.01%
Nevada Test Site
Cotter Concentrate4
Drummed slurry 363 tons 10.0%
Honeywell Calcium Fluoride waste stream
source material
licensed 5,443 tons 2.0%
Cabot0 Ore residues from tantalum production
Licensed source material
16,830 tons 0.343%
Allied Signal' Aqueous potassium hydroxide (KOH)
slurry and solids
Licensed source material
1,595 tons 17.0%
Rhone-Poulenc Uranyl nitrate
concentrate
hexahydrate liquid 17 tons 50.0%
Cameco Potassium fluoride product 1,966 tons 4.6%
Cameco Uranium tetrafluoride with filter ash
Powdered solid
10 tons 65%
Cameco Calcined raffinate 2,197 tons 5.5%
Cameco
XT
Mono- and dibutyl
regeneration product
phosphate 557 tons 8.0%
W.R. Grace Monazite sands and soils 203,000 tons .0.74%
Heritage Monazite sands 2,910 tons 0.05%
Molycorp Lead sulfide pond solids. Licensable
source material
11,500 tons 0.15%
FMRI Ore residues from tantalum production
Licensed source material
32,000 tons 0.15%
Source: Denison
1 These FUSRAP materials are derived from uranium mill tailings. Therefore, they contain the U-238 series in disequilibrium
2 Material that the Mill is licensed to process, but which the Mill has not received to date.
3 Contains U-238 series in equilibrium and Th-232 series in disequilibrium.
' Contains U-238, low levels of Ra-226 and high levels of Th-230
5 Contains U-238 series in disequilibrium
6 Contains U-238 series in equilibrium as well as Th-232 series in equilibrium.
7 Contains U-238 series in equilibrium with high levels of Th-232 and Th-228.
1 Contains U-238 series in equilibrium, as well as elevated levels of Th-232 series in equilibrium.
28
23) Have any single source of ISL .ste material exceed the disposal limit < >,000 cubic yards per source?
Comments: (License Condition 10.5.A) Yes No"">^
24) Was all ISL waste material disposed in Cell #3? (License Condition 10.5.C)
Comments: Yes No
25) Were all disposal activities properly documented? (License Condition 10.5.D) ,
Comments: Yes 77 No
26) Did the documentation show that all steps were taken to minimize void spaces? (License Condition 10.5.B)
Comments: . .g . . Yes ><• No
/Li^J<j *~i~7" r^*/<Z. 7 ' <,^.7
27) Discuss with the Lead/Forman of ISL disposal on how ISL material is disposed. If possible observe also.
Comments:
&7<J,'^ ,/ xisp ^y^jT^ 7r,>/.,:„. / 7- j:^^\ ^
—- 7~/4i-c - ^7^»y (QLJC^7 /,4..f 7^^- 7 y-t^f <^Z'',7c 7K /7yf<-^7
4^-.' 7 7' su,, < '7y : -;.,7 <^~~ 7s~ 7(- 'f<*>£7
U:\rad\COMMON\Uranium millsU le(2)UTl900479 Denison Mines - White Mesa UMilKHP Inspection modules\2012\Inspection Modules\RADMOD-AFIL-02.doc
Additional Items
28) Denison Request dated 3/20/12, to allow a ISL source to exceed the 5,000 cy limit. What did they decide to
do? ^ J / / > •"
29) Hard ore request, See if they are going to respond to our RFI. .
mAAarJ X- /Z4KCJ^ ^ //^^/a /P. A^/r ^K'J''
3U7-Sample AlterrMiji^W^irizSi^e.
U:\rad\COMMON\Uranium millsU le(2)UT1900479 Denison Mines - White Mesa UMill\HP Inspection modules^" 12\Inspection Modules\RADMOD-AFIL-02.doc
.<•'-*?• ^ '•*"•'<'•*
J) J-iJ/^-y
Page 1 of 2
Ryan,
The information below should answer both of your emails I received from you today.
1. We have received two different alternate feeds from Allied Signal/Honeywell, hence the two
different license conditions. Condition 10.6 refers to a dry drummed solid material we call CaF2,
and which includes bed material, filter fines, and other approved components consistent with the
1993 license amendment request. We still receive that material, as indicated in my letter to DRC.
2. Condition 10.7 refers to a slurry material we call KOH, which was described in a 1996 license
amendment request. Although we have not received this material since the late 1990's,
Harold is scheduling a discussion with Rusty Lundberg and Phil Goble about Honeywell's
interest in resuming sending this material to us.
We would like to keep the license conditions for both of these feeds.
3. We no longer receive any material from Rhone Poulenc. The condition allowing this feed was
removed from the license on or after 2007 because it was a one-time situation and is done. There
is no need to add a condition for this feed.
Thanks,
Jo Ann Tischler
Jo Ann Tischler
Director, Compliance and Permitting
Energy Fuels Resources (USA) Inc.
t 303-389-4132 |f 303-389-4125
225 Union Blvd , Suite 600
Lakewood, CO, US, 80228
http: / /www. energy fuel s. com
This e-mail is intended for the exclusive use the of person(s) mentioned as the recipient(s) This message and any attached files with it are
confidential and may contain privileged or proprietary information If you are not the intended recipient(s) please delete this message and notify the
sender You may not use, distribute print or copy this message if you are not the intended recipient(s)
From: Ryan Johnson [mailto:[e-mail]]
Sent: Monday, August 20, 2012 11:25 AM
To: Jo Ann Tischler
Cc: David Frydenlund; John Hultquist
Subject: Clarification on Letter dated August 2, 2012
Hi Jo Ann,
file://C:\Documents and Settings\rmjohnson\Local Settings\Temp\XPgrpwise\503257C9E... 8/20/2012
Page 2 of 2
I have been reviewing the letter that you sent on August 2, 2012 regarding our RFI on the Alternate Feed
program. You stated that the alternate feed associated with License Condition 10.7 you are currently receiving
material. It is my understanding that material is associated with License Condition 10.6. Both License
Conditions are associated with Allied Signal Corp. Maybe that is where the confusion is. Will you please clarify
which License condition that the material from Allied/Honeywell is associated with and what is the status of the
Alternate material is from the other License Condition. If you have any questions please let me know.
Thanks,
Ryan Johnson, P.G.
Environmental Scientist/Health Physicist
Utah Division of Radiation Control
http //www eneravfuels com
This e-mail is intended for the exclusive use the of person(s) mentioned as the recipient(s) This message and any attached files with it are
confidential and may contain privileged or proprietary information If you are not the intended recipient(s) please delete this message and notify the
sender You may not use, distribute print or copy this message if you are not the intended recipient(s)
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Page 1 of 1
Jo Ann,
In the 2007 RML renewal application Rhone-Poulenc is identified as an alternate feed. Which License Condition
is it associated with because I can not find that name mentioned in the License.
Thanks
Ryan Johnson, P.G.
Environmental ScientistyHealth Physicist
Utah Division of Radiation Control
file://C:\Documents and Settings\rmjohnson\Local Settings\Temp\XPgrpwise\503242DBE... 8/20/2012
0RC-?0 12-30 1698
DENISON
MINES
www.denisonmines.com
Tel : [phone]
Fax : [phone]
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
August 2, 2012
VIA PDF AND FEDERAL EXPRESS
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
168 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Dear Mr. Lundberg:
Re: Radioactive Material License No. UT 1900479, June 7, 2012 Request for Information
Regarding Alternate Feed Program
This letter responds to the above-mentioned Request for Information ("RFI") from the Utah Division of
Radiation Control ("DRC") dated June 7, 2012 regarding Denison's radioactive Material License ("RML")
Number UT 1900479.
The RFI identified 12 alternate feed materials and asked that Denison:
"provide justification why the alternate feed materials where Denison has never received or
processed any feed material or feed material that has not been received for 5 years or more,
listed above, should remain in the White Mesa Mill RML, including:
• An estimated timeframe of when that material will be sent to the Mill; and
• Updated analytical results (including RCRA) demonstrating that it is the same material
that was originally approved, unless the process at that facility has not changed."
Denison is providing the following information to update the status of each of the alternate feed materials.
As discussed in table 1, below, Denison agrees to remove six of the alternate feed materials from the
RML. Denison has provided additional information, in the discussion following Table 1, regarding the
remaining six alternate feeds, for which license conditions allowing processing of the feed should be
retained in the RML.
Table 1, below, summarizes the status of each facility or remediation site from which the alternate feeds
have been or will be generated. For alternate feed materials which should be retained in the RML
conditions, additional narrative is provided below the table.
Letter to Mr. Rusty Lundberg,
August 2, 2012
Page 2
Table 1
Generator Name Approximate
Year of Last
Shipment
Corresponding
License
Condition
Status Proposal for
License
Condition
Linde 2003 10.14 Project Complete Remove
Ashland 1 2004 10.12 Project Complete Remove
Ashland 2 2004 10.10 Project Complete Remove
St. Louis Never received 10.13 Remediation of
industrial/commercial areas
underway
Keep
Maywood Never received 10.18 Remediation of
industrial/commercial areas
underway
Keep
NTS Cotter 1997 10.8 Project Complete Remove
Allied Signal/Honeywell
Corp.
2012 10.7 Shipments of same material
ongoing under new supplier name
Keep
Rhone-Poulenc 1997 Not Specified Project Complete Remove
WR Grace Never received 10.15 Material in inventory at WR Grace Keep
Heritage 2003 10.16 Project Complete Remove
Molycorp 2004 10.17 Future additional shipments
possible
Keep
Fansteel Metals
Resources, Inc. ("FMRI"
2007 10.19 Inventory on site at Mill to be
processed. Keep
St. Louis
Timeframe
Remedial excavation and construction at the St. Louis FUSRAP sites has been ongoing since 1998. The
U.S. Army Corps of Engineers is currently performing remedial excavation of the industrial and
commercial portions of several of the affected sites. Excavation may be expected to continue beyond
2013. Denison does not currently have a contract in place for receipt of the licensed materials.
Analytical Data
The materials remain in place in situ pending remedial excavation. The processes which generated the
materials were discontinued in the prior to 1966 as discussed in the license amendment request. No
additional analytical data is required.
Maywood
Timeframe
The St. Louis FUSRAP sites are currently undergoing remediation. The U.S. Army Corps of Engineers
("USACE") is currently performing remedial excavation of the industrial and commercial portions of
several of the affected sites. Denison does not currently have a contract in place for receipt of the
licensed materials. Per the U.S. Department of Energy and USACE, remedial excavation is expected to
continue through 2024 or later.
Analytical Data
The materials remain in place in-situ pending remedial excavation. The processes which generated the
materials were discontinued prior to 1983, as discussed in the license amendment request. No additional
analytical data are required.
Allied Signal/Honeywell
Timeframe
DRC's June 7, 2012 letter erroneously stated that the last shipments of the Allied Signal alternate feed
material occurred in 1997. Allied Signal Corp. purchased Honeywell International, Inc. in 1999 and
adopted the Honeywell International, Inc. name at that time. The material from Allied Signal's Metropolis,
Illinois facility, described in Denison's 1993 license amendment request, has been shipped to the Mill
periodically from the inception of the project through 2012. The material currently being received at the
Mill, and identified as Honeywell, Inc. alternate feed, is:
2
DENISON
MINES
Letter to Mr. Rusty Lundberg
August 2, 2012
Page 3
• the same type of material described in the 1993 license amendment request, and
• the same type of material which was formerly received as Allied Signal alternate feed when Allied
Signal owned the Metropolis facility.
Shipments have been received at the Mill as recently as July 2012.
Analytical Data
The materials have been periodically shipped to the Mill from inception of the project through 2012. The
process which generated the materials has not changed since the initiation of shipments to the Mill. No
additional analytical data are required.
WR Grace
Timeframe
Denison does not yet have a contract in place for receipt of this material. The materials remain in
inventory at the WR Grace Chattanooga facility. Material may be shipped any time from 2013 onward
depending upon contract negotiations and uranium market price.
Analytical Data
The process which generated the materials has not changed over the life of the facility. No additional
analytical data are required.
Molycorp
Timeframe
The material shipped to date, and any future shipments of material, result from a remediation of on-site
clarifier/thickener sludges discharged to on-site evaporation ponds. Cleanup operations at the Molycorp
facility may continue to generate additional volume of the material approved in the license condition.
Denison is involved n ongoing negotiations with the generator regarding additional future volumes of the
material.
Analytical Data
As mentioned above, the material resulted from a remediation of on-site clarifier/thickener sludges
discharged to on-site evaporation ponds. The process which generated the ponded material was
discontinued prior to 1984 and therefore will not change. No additional analytical data are required.
FMRI
Timeframe
The materials received from FMRI through 2007 remain in the on-site inventory at the Mill on site to be
processed in a future campaign. Cleanup operations at the Fansteel facility site may continue to
generate additional volume of the material approved in the license condition. Denison is involved n
ongoing negotiations with the generator regarding additional future volumes ofthe material.
Analytical Data
The materials, and any future shipments of material, result from a remediation of onsite ponds, for which
the generating process is complete and will not change. No additional analytical data are required.
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DENISON
MINES
Letter to Mr. Rusty Lundberg
August 2, 2012
Page 4
Please contact me If you have any additional questions or require any further information.
Yours very truly,
DENISON MINES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Dan Hillsten
Harold R. Roberts
David E. Turk
Katherine A. Weinel
DENISON
MINES
4
m
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
HLt
June 7, 2012
David Frydenlund
Vice President Regulatory Affairs and Counsel
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, Colorado 80265
RE: Radioactive Material License (RML) Number UT 1900479: Request for Information regarding
Alternate Feed Program.
Dear Mr. Frydenlund:
On May 30, 2012, an inspection was conducted at the White Mesa Uranium Mill Facility by Ryan
Johnson representing the Utah Division of Radiation Control. During this inspection, Mr. Johnson
gathered information regarding when the last shipment of each of the alternate feed materials that the
White Mesa Mill is currently approved to accept. Based on Mr. Johnson's observation, there are
several approved alternate feed materials that have never been received at the Mill or have been
inactive for 5 years or more. Please see list below.
Generator Name Approximate Year of Last
Shipment
Corresponding License
Condition
Linde 2003 10.14
Ashland 1 2004 10.12
Ashland 2 2004 10.10
St. Louis Never received 10.13
Maywood Never received 10.18
NTS Cotter 1997 10.8
Allied Signal 1997 10.7
Rhone-Poulenc 1997 Not Specified
WR Grace Never received 10.15
Heritage 2003 10.16
Molycorp 2004 10.17
FMRI 2007 10.19
During the RML renewal, the Licensee indicated that Ashland 1 (License Condition 10.12), Ashland
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Page 2
2 (License Condition 10.10) and NTS Cotter (License Condition 10.8) will no longer be sent to the
Mill and that they should be removed from the RML.
Please provide justification why the alternate feed materials where Denison Mines has never received
or processed any feed material or feed material that has not been received for 5 years or more, listed
above, should remain in the White Mesa Mill RML, including:
• An estimated timeframe of when that feed material will be sent to the Mill; and
• Updated analytical results (including RCRA) demonstrating that it is the same material that
was originally approved, unless the process at that facility has not changed.
If you have any questions please contact Ryan Johnson at 801-536-4250.
Sincerely,
Rusty Lundberg, Director
Cc: Dave Turk, Denison Mines, White Mesa Mill Facility