black range minerals and tallahassee uranium , page-2

I pointed this out to "Grant" that BLR would need a material Radioactive Material License, months ago.

Grant was of the opinoin that BLR wouldn't need the License, so what your opinoin now.


2. Black Range insists that this process is "mining" and not source material processing ("uranium milling"). It bases its belief on peculiar wording in the definition of "ore" found in the Colorado Radiation Regulations, and thereby expecting to avoid the necessity of obtaining a source material Radioactive Material License. Federal regulations contradict this position and includes the "crushing" or "grinding", separation, screening, and concentration of uranium ore as beneficiation processes which are identified as source material processing activities. TAC pointed out the contradiction between Colorado and Federal regulations to the manager of the Radiation Management Unit of CDPHE. After reviewing our documentation, he stated (in correspondence to TAC in October and November 2012) that "the process, if implemented as we now understand it, would result in the possession of source material and would, therefore, require a source material radioactive material license at a minimum".