DRC-2011-006570 - 0901a068802415e0

June 9, 2011
-2011-0G657
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Denison Mines (USA) Corp.
1050 17th street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax : [phone]
www.denisonmines.com
Re: May 24, 2011 Request for Information No. 2 Regarding the November 15, 2010 Annual Technical
Evaluation of the White Mesa Mill Tailings Management System [ATER]
Dear Mr. Lundberg:
This letter responds to the Utah Division of Radiation Controls ("DRC's") May 24, 2011 Request for
Information No. 2 regarding the 2010 ATER. DRC's Request for Information ("RFI") No. 2 referred to
Denison's letter of April 19, 2011 in which Denison stated that "the tree-like plants on the Cell 2 interim cover
have been removed."
Denison had, in fact, performed a removal and treatment action on the tamarisk (identified in DRC's
memoranda and emails as "greasewood") on the Cell 2 interim cover as identified in Denison's April 19 letter.
Denison followed the recommended practices (as used by USPS and BLM) for the management of tamarisk.
Tamarisk is extremely resilient if it has been cut down with its tap root fully or partially intact. Standard
practice for eradication requires cutting by hand tool to the level where the emergent surface of the tap root
can be identified, and soaking with sufficient herbicide to saturate the taproot. If bulk cutting is to be used, it
is applied after evidence of taproot death. Bulk cutting by dozer or heavy equipment without pre-treatment
with herbicide is not recommended due to the risk of leaving live taproots which result in rapid and dense re-
growth. Specifically, on April 8, 2011 Mill staff used pruning shears to cut the growth close to ground level to
expose and identify the taproot. They also initiated on the same day a weekly application of herbicide,
repeatedly soaking the stump of every cut plant, to destroy the remaining visible growth via the taproot.
Based on past experience, the herbicide typically requires a month or longer to poison the taproot of larger
woody growth. Based on Mill staff's weekly observations, the recommended management practice was
working. Smaller growth had died right after the first application on April 8, 2011, and some of the larger
growth has responded over the past several weeks. The eradication program was at this stage at the time
that DRC's inspector visited the Mill on May 17, 2011.
Denison was not sufficiently clear in our response to DRC's March 17, 2011 RFI, that is, we did not explain
that the response to chemical application typically takes over a month and some stumps would be visible until
the chemical application took effect. In response to the requirement in DRC's RFI No. 2, we believe that this
information is sufficient to "Explain and justify why the April 19, 2011 statement that the trees had been
removed, was not a false statement." Nonetheless Denison has performed a second removal action on the
treated stumps as demonstrated in the photographs supplied in Attachment 1. On June 9, 2011, Denison
N:\Required Reports\ATER\2010 ATER RFI and response\06.09.11 response to DRC 05.11 Itr ATER Cell 2 tree growth.doc
Letter to Mr. Rusty Lundberg
June 9, 2011
Page 2
used the Mill's dozer to cut or uproot the visible remaining growth. Attachment 2 contains photographs of
this operation and the condition of the Cell 2 cover after its completion.
Denison acknowledges DRC's concern in the May 24, 2011 RFI that the "photos supplied by DUSA to
document the removal process and results are illegible." Denison has provided the attached photos
electronically in their original jpeg format in addition to printed hard copies. It is our hope that jpegs provide
the maximum clarity possible within the conditions that the photographs were taken. Please understand that,
due to the environment in which the photographs were taken, perfect image resolution is not possible. It is
our hope that these photos will be sufficiently clear for DRC's purposes.
DRC's May 24, 2011 RFI requested that the attached "evidence be submitted as an amendment to the
subject ATER." Based on our phone conversation with David Rupp today, June 9, 2011, we will document
the above removal activity in the upcoming 2011 ATER to be submitted on or before November 15, 2011.
Please contact me if you have any questions or require any further information.
Yours very truly,
DENISON MINES (USA) CORP.
\Jo Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Harold R. Roberts
David Rupp
David E. Turk
K. Weinel
Central files
DENISON
MINES
Letter to Mr. Rusty Lundberg
June 1, 2011
Page 3
ATTACHMENT 1
DENISOi
MINES
Letter to Mr. Rusty Lundberg
June 1, 2011
Page 4
DESCRIPTIONS OF ATTACHED TREE REMOVAL PHOTOS
Imaae # Time Location DescriDtion
01 0719 Cell 2 Stump before removal
02 0722 Cell 2 Stump during removal
03 0722 Cell 2 Stump removed - showing roots
04 0725 Cell 2 Stump removal
05 0726 Cell 2 Stump before removal
06 0727 Cell 2 Stump before removal
07 0729 Cell 2 Stump before removal
08 0732 Cell 2 Removed stumps
09 0733 Cell 2 Area after stumps removed
10 0733 Cell 2 Removed stumps
11 0733 Cell 2 Stump before removal
12 0736 Cell 2 Stump during removal
13 0750 Cell 2 Area after all stumps removed
14 0751 Cell 2 Area after all stumps removed
15 0751 Cell 2 Area after all stumps removed
16 0752 Cell 2 Area after all stumps removed
17 0753 Cell 2 Area after all stumps removed
18 0755 Cell 2 Loader bucket full of removed stumps
DENISOI
MINES
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