DRC-2012-001698 - 0901a068802f7a6e

DENISO
MINES
DRC-20
August 2, 2012
Denison Mines (USA) Corp.
105017th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
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 Denlson'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 • Ashland 1 2004 10.12
Ashland 2 2004 10.10
St. Louis Never received 10.13 Remediation of
industrial/connmercial areas
undenway
Keep
Maywood Never received 10.18 Remediation of
industrial/commercial areas
underway
Keep
NTS Cotter 1997 10.8
Allied Signal/Honeywell
Corp.
2012 10.7 Shipments of same material
ongoing under new supplier name
Keep
Rhone-Poulenc 1997 Not Specified
WR Grace Never received 10.15 Material in inventory at WR Grace Keep
Heritage 2003 10.16
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:
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 of the 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.
DENISO
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
DENISO
MINES
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