DRC-2010-002227 - 0901a0688016ecee

State of Utah
GARY R. HERBERT
Govemor
GREG BELL
Lieutenant Governor
DRC-201U-0
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
March 1,2010
CERTIFIED MAIL
(Retum Receipt Requested)
David C. Frydenlund
Vice President and General Counsel
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Mr. Frydenlund:
SUBJECT: October 30, 2008 DUSA Request for Amendment to Update Existing License Conditions
Relating to Disposal of Byproduct Material for ISL Facilities and Mill-Generated Non-
Tailings Wastes in Tailings Cells; September 14, 2009 DRC Inspection Letter; Radioactive
Materials License No. UT1900479; Request for Information
Dear Mr. Frydenlund:
We have reviewed the subject October 30, 2008 letter from DUSA. In the letter, DUSA proposes an
amendment to the license. It appears the primary purpose for the amendment would be to allow disposal of
non-tailings mill waste and ISL byproduct material into any active tailings cells at the site. The DUSA letter
also proposes using similar requirements for mill waste and ISL byproduct material.
We need to collect additional information prior to completing the processing of your request. To safeguard
the liners of the newer cells we request: >
A. Proposed methods and procedures to fully protect the liner while accessing tailings cells for disposal
of ISL byproduct material and mill equipment must be submitted for approval. These methods and
procedures would apply to tailings Cell 4A and newer cells.
B. The Executive Secretary shall be notified in writing at least 7 calendar days prior to disposal of
byproduct material generated at in-situ leach facilities.
C. Proposed methods and procedures to assure that all disposal activities shall be documented. The
documentation shall include descriptions of the waste and the disposal locations, as well as all actions
required by this condition, including the following;
1). the disposal area is on a tailings beach area of the cell or on an area of the cell that is
underlain by tailings sands;
2). the elevation of the disposal area, once filled with such material and equipment, will not
exceed the elevation ofthe flexible membrane liner ofthe tailings cell; and
168 North 1930 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
Mr. David C. Frydenlund
March 1,2010
Page 2
3). such byproduct material will be segregated from any material and equipment disposed of
in the cell pursuant to license condition 10.4, and the byproduct materia] from each in-
situ leach source will be segregated from the byproduct material from all other in-situ
leach sources.
4). drawings which demonstrate:
a. there are at least 4 feet of tailings sands under the bottom of each ISL source
disposal area;
b. the bottom of each ISL source disposal area is located at least 12 feet from the sides
or dikes of the tailings cell;
With respect to the above, some provisions in the upcoming license amendment will be added for these items.
Please review the above comments, and respond in writing submitting the requested information. We will
continue our review of the subject request on receipt of the above information. If you have any questions on
the above, please contact me.
Sincerel
David A. Rupp, P.E.
Geotechnical Services Section
LBMiDAR-.dr
F:\DUSA\LRA&License MSL Amendment\Prelim LicAdjustments 3-2010 .doc