DRC-2011-006449 - 0901a0688023b664

OENISO
MINES
May 31, 2011
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Utah Department of Environnnental Quality
195 North 1950 West
P.O Box 144850
Salt Lake City, UT 84114-4850
Received
JUN 2011
Divisionof
Radiation Control
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tei: 303 628-7798
Fax:[phone]
www.denisonmines.com
2011-00 64
Re: Stateof Utah Groundwater Discharge Permit ("GWDP") No. UGW370004
Transmittal of Revised Standard Operating Procedures ("SOPs") and Response to Division of
Radiation Gontrol ("DRC") Request for Information of April 21, 2011 Regarding 11.e(2) Byproduct
Disposal SOP
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed revisions to the White Mesa Mill 11e.(2)
Byproduct Disposal SOP. This letter also responds to DRC's letter of April 21, 2011, which we received on
April 28, 2011 providing DRC's proposed redlines and comments on the subject SOP. We have attached an
edited redline copy of the SOP in which Denison's modifications or additional language in response to DRC
comments are indicated in a second color.
We have provided, below, specific responses to each request in DRC's April 21, 2011 letter. The sections
and numbering of the remainder of this letter follow the DRC April 21, 2011 letter. Each DRC request is
shown in italics, below, followed by Denison's response.
ORG Comments and Responses
1. General.
a. Some suggested red-line strike-out changes for the subject SOPs a The majority
of these suggestions were derived from our review of the Ucense Conditions. Please note
that some sections of the red-line strike-out copy of the subject SOPs may contain several
recommended changes. Also, please note that not all changes requested are captured in our
red-line strike-out notations.
Denison Response: So noted. Denison has also replied to the four additional DRC comments provided in
the margins of the SOP. Our responses are provided in the margins of the SOP directly below the
comments. As general background to our response to DRC's comment in the margin of Section 3.0
of the SOP, Denison feels it is important to clarify that trench disposal and tailings beach disposal are
not two different types of disposal.
The disposal location for material from each ISL source is pre-determined by the RSO as a
Designated Disposal Area for that source. Designated Disposal Areas were selected primarily to
C:\Users\jtischler\Desktop\SOP repsonse 11e2 monitor\05.27.11 Response to DEQ 04.20.11 RFI 11e2 SOP.doc