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HomeMy WebLinkAboutDRC-2011-006619 - 0901a068802462f0June 21, 2011 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: 303 628-7798 Fax: 303 389-4125 www.denisonmines.com Re: state of Utah Groundwater Discharge Permit ("GWDP") No. UGW370004 Transmittal of Revised Standard Operating Procedures ("SOPs") and Response to Division of Radiation Control ("DRC") request for Information of June 2, 2011 Regarding Settlement Monitoring Dear Mr. Lundberg: This letter transmits Denison Mines (USA) Corp's proposed revisions to the Settlement Monitoring SOP. This letter also responds to DRC's letter of June 2, 2011, which we received on June 6, 2011 providing DRC's proposed redlines and comments on the subject SOP. We have attached an edited redline copy of the SOP in which DRC's proposed changes remain in violet-red and Denison's modifications or additional language are indicated in other colors. We have provided, below, specific responses to each request in UDEQ's June 2, 2011 letter. The sections and numbering of the remainder of this letter follow the DRC June 2, 2011 letter. Each DRC request is shown in italics, below, followed by Denison's response. DRC Comments and Responses 1. No further comment. Denison Response: No response required. 2. No furttier comment. Denison Response: No response required. 3. No furttier comment. Denison Response: No response required. 4. Figure 1, a drawing titled Settlement Monitor Fabrication originally dated 09-14-96 and last revised 05- 11, was provided by DUSA to support ttie description of ttie design of ttie Settlement Monitors found in Section 1.3 of the subject SOPs. Denison Response: No response required. N:\SOPs and Procedures\Settlement Monitor SOP and comments\Response to RFI and Settlement SOP to DRC 06.21.11\06.21.11 Response to DEQ 06.02.11 RFI SettlementSOP.doc Letter to Mr. Rusty Lundberg June 21, 2011 Page 2 5. No further comment. Denison Response: No response required. 6. No further comment. Denison Response: No response required. 7. No further comment. Denison Response: No response required. 8. As previously stated and requested in our letter of April 4, 2011, Section 1.5.2 in the subject SOPs is vague in its intent and needed clarifying. After some revision by DUSA, this section still seems rather complex and unclear To help clarify the apparent intent of this section, some additional red-line strike- out verbiage attached, is suggested for Section 1.5.2. Denison Response: The change has been accepted as proposed. 9. No further comment. Denison Response: No response required. 10. Per License Condition 11.7K, we requested that the subject SOPs, "Include a list of records that will be prepared for documenting settlement data for each settlement monitoring device and related site observations and activities..." In this regard, we request that the annual review of the Settlement Monitors by a Utah Licensed Professional Engineer be added to the list of records of documents shown in Section 1.5.1 of the subject SOPs. Denison Response: The change has been made as requested. The review by the Utah-Licensed Professional Engineer has been added to the list of documents in Section 1.5.1. 11. Per License Condition 11.7L, in our letter of April 4, 2011, we suggested verbiage for the subject SOPs to provide that results and records of settlement monitoring be submitted annually as part ofthe ATER. It appears the addition of the word "submit" to Section 1.6 is appropriate in this regard. This addition is suggested as attached, in the red-line strike-out verbiage for Section 1.6, in the second to last paragraph of that section. Denison Response: The change has been accepted as proposed. 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 OENISO MSNES Letter to Mr. Rusty Lundberg June 21, 2011 Page 3 cc: David C. Frydenlund Harold R. Roberts David E. Turk K. Weinel Central files Attachment DENISO MINES White Mesa Mill - Standard Operating Procedures Date: 04644/20110 Revision: DUSA-2-1- Book #11: Environmentai Protection Manual, SOP Section 5.0 Page 1 of 5 SETTLEMENT MONITORING STANDARD OPERATING PROCEDURES \. SETTLEMENT MONITORING 1.1 Purpose This Standard Operating Procedure (SOP) describes the vertical monitoring of the Settlement Monitors that are placed within the tailings management cell areas. This SOP will also indicate how and where to document the findings. All data collected for these purposes, as described below, will be included in an Annual Technical Evaluation Report (ATER) to be submitted to the Executive Secretary of the Utah Division of Radiation Control (the Executive Secretary) pursuant to License Condition 12.3 of the Radioactive Materials License (RML). 1.2 Locations and Frequency of Monitoring Settlement Monitors are located on covered tailings cells and shall be surveyed on a monthly basis by the Environmental Department staff and annually by a Utah Licensed Professional Land Surveyor. For any new Settlement Monitor installed (after June, 2010)-, within 30 days of the installation, a Utah Licensed Land Surveyor will survey the monument. The locations of new Settlement Monitors will be pre-designated by the Mill Engineer on the latest DUSA Settlement Monitor Points map (originallv dated 09/15/08). Settlement Monitors will be placed on the tailings cells as the intermediate cover is advanced over tailings. New Settlement Monitors will be installed within XX60 calendar days of completion of the intermediate cover at the designated locations. The Settlement Monitor Points map will be updated as part of the installation of new monitors. As stated above. Settlement Monitors will be placed on the tailing cells when temporary cover is being advanced on the placed tailings. Settlement Monitors are also required on In-situ leach (ISL) source disposal areas that have been closed to further disposal pursuant to RML condition I0.5.A. Settlement monitors will be installed and surveyed by a Utah Licensed Land Surveyor within 30 days of the completion of each ISL disposal area, and then annually after that point. One Settlement Monitor will be required for approximately every 22,500 square feet or 5,000 cubic yards of ISL material. These monuments will be uniquely labeled to identify the specific ISL material. F:\WP\Division ofRadiation ControlVDenison Mines. DUSA\ATER Annual Tech Eval Reports\Movement & Setttemert Monitors\Settlement Monitors\Prop Settlement Monit SOP Markup 03 2010.docC:\Users\itischler\Desktop\Section 5 0 Settlement Monitoring SOP.doc White Mesa Mill - Standard Operating Procedures Date: 046-14/20UO Revision: DUSA-2+ Book #11: Environmental Protection Manual, SOP Section 5.0 Page 2 of 5 For ISL source disposal areas or trenches completed before April 1, 20110, the required settlement stands will be placed and the initial elevation survey completed prior to June 1, 20110. 1.3 Design of Settlement Monitors Each Settlement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing animals and other environmental factors. The design is a 2'x2' steel plate with a 1" steel pipe welded to the center of the plate. This steel plate will be positioned by digging straight down in the desired location until tailing sands are contacted. Upon contacting the sands, the steel plate and pipe are lowered and placed on top of the sands. The hole will then be backfilled to within two feet of the ground surface. At this point, a 3" steel outer casing will be placed over the 1" inner pipe. After this has been completed, the last two feet of material will be backfilled. The top of the 3" casing will be threaded to allow for a cap to be installed. The settlement monitors will have the threaded caps, lubricated on an as needed basis, to allow the cap to be removed during the survey process. See the attached Figure 1 detailing the construction of the Settlement Monitors. In order to protect the settlement monitors from man-caused damage, each settlement will be bounded on three sides. This bounding will prevent equipment from accidentally coming in contact with the settlement monitor. These devices will consist of three 3" steel pipes that will be cemented into the ground. The interior of the pipe will also be filled with concrete. The barriers will then be painted red as a visual reminder. If damage, by any source, has occurred, the informafion will be documented and immediately tumed in to the RSO, or designee. The RSO, or designee, will make same dav notificafion to the Corporate Compliance Director^ and a corrective action plan will be created for rReplacement and/or repairs to the damaged Settlement Monitor and the surveying and documentation of those changes due to the Settlement Monitor damage will be completed within within 30XX calendar davs of the discovery of the damage to the Settlement Monitor. L4 Monthly Surveying (i) The monthly survey will be performed by the Mill's Radiation Safety Officer or designee (the "Surveyor") with the assistance of another Mill worker (the "Assistanf); (ii) The survey will be performed using a survey instrument accurate to 0.1 feet, such as a Sokkai No. B21, or equivalent, together with a survey rod having a visible scale in 0.1 foot increments; (iii) The reference points are known points established by a professional survey. (iv) The surveyor will set up the survey instrument in a location where both the applicable reference point and settlement monitor are visible. F:\WP\Division ofRadiation ControlVDenison Mines. DUSAVATER Annual Tech Eval ReportoVMovement & Settlement Monitors\Settlement MonitorsVProp Settlement Monit SOP Markup 03 2010.docC:\Users\itischler\Desktop\Section 5 0 Settlement Monitoring SOP.doc White Mesa Mill - Standard Operating Procedures Date: 0464I-/2011Q Revision: DUSA-24- Book #11: Environmental Protection Manual, SOP Section 5.0 Page 3 of 5 (v) Once in location, the surveyor will ensure that the survey instrument is level by centering the bubble in the level gauge on the survey instrument; (vi) The assistant will place the survey rod vertically on the reference point. The assistant will ensure that the survey rod is vertical by genfiy rocking the rod back and forth until the surveyor has established a level reading; (vii) The surveyor will focus the cross hairs of the survey instrument on the scale on the survey rod, and record the number (the "reference point reading"), which represents the number of feet the survey instrument is reading above the reference point; (viii) The assistant will then move to a designated settlement monitor. Once at the monitor, the assistant will remove the steel cap and place the survey rod on top of the 1" inner pipe. A few of the original setfiement monitors do not have an inner pipe. For original settlement monitors without a 1" inner pipe, the assistant will place the survey rod on the lip of the settlement monitor; (ix) The assistant will hold the rod vertically and will ensure the survey rod is vertical by gently rocking the rod back and forth until the Surveyor has established a level reading; (x) The surveyor will focus the cross hairs of the survey instrument on the scale on the survey rod, and record the number (the "surface reading"), which represents the number of feet the survey instrument is reading above the settlement monitor. The surveyor will calculate the elevation of the settlement monitor by adding the reference point reading to the reference point elevation and then subtracting the surface reading for the settlement monitor, and will record the number accurate to O.I feet. The elevation information will be maintained within the Environmental Department records. The monthly documentation of the readings will be recorded on the Monthly Tailings Inspection Form. The form can be found in Section 3.1 ofthe Environmental Protecfion Manual. 1.5 Monitoring and Maintenance of Settlement Monitors 1.5.1 Monitoring and Documentation of Condition of Devices The Movement Settlement Monitors will be maintained so that the monuments remain in reliable, good working condition. Conditions at and in the vicinity of the monitoring devices will be inspected monthly by Environmental Department staff. Any observations will be recorded on the monthly tailings inspection report form. On an annual basis, each monument will be photographed to document conditions at the monitoring areas. Addifionally, photographs will be taken following any instances of unusually severe weather or incidents involving equipment if they result in physical damage or disturbance to any settlement monitoring device, or significant changes to the ground areas adjacent to or surrounding the settlement monitor. F:\WPVDivision ofRadiation ControlVDenison Mines. DUSAATER Annual Tech Eval ReportsVMovement & Settlement Monitors\Settlement MonitorsVProp Settlement Monit SOP Markup 03 2010.docC:\Users\itischler\Desktop\Section 5 0 Settlement Monitoring SOP.doc White Mesa Mill - Standard Operating Procedures Date: 04644-/20110 Revision: DUSA-24 Book #11: Environmental Protection Manual, SOP Section 5.0 Page 4 of 5 The following records and documents will be maintained bv the Environmental Department staff: a) Monthly tailings inspection forms h) Data files of monthly and annual survey information c) Records of initial installation and survey data d) Records of maintenance, damage, and/or replacement of settlement monitors e) Annual photographs documenting site conditions at each settlement monitor f) Annual Review of Settlement Monitors by Utah Licensed Professional Engineer 1.5.2 Maintenance of Monitors If any settlement monitoring device is irreparably damaged as a result of environmental stresses or man-caused contact, it will be promptly replaced with an identical or equivalent device. Based on the last monthly survey, prior to the damage, t¥he replacement device will be placed as near as practical at the same elevation and in the same location from which the damaged device was removed. Data from the new device will be correlated to data from the removed damaged device as follows: 1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the location of the new device as well as that of the two nearest (undamaged) devices adjacent to on either side of the new device. 2. Ifthe survey indicates there has been less than 0.1 foot of vertical change since the last monthly survev in the elevation location of the undamaged devices, no adjustment will be made to the survey data of the new device. 3; If the survey indicated 0.1 foot or greater of vertical change to either of the undamaged devices, the survey results for the new device will be adjusted by the average change observed in the two adjacent devices. This adjustment will be documented in the Utah- Licensed Land Surveyors report and in the annual ATER. 3T4J Also, based on the last monthly survey, prior to the damage, fif the elevafion of the new device is greater than +/- 0.1 foot from that of the damaged devicse, then the replacement devicse will be designated with a new number (such as "Cell 2W2-R". as the replacement for damaged devicse "Cell 2W2"). Elevafion data for the new devicse, and the date of installation of the new device, will be recorded in the data file adjacent to the information from the damaged devicse. with a notation that this devicse is a replacement for the damaged devicse. F:\WP\Division ofRadiation ControlVDenison Mines. DUSA\ATER Annual Tech Eval ReportsVMovement & Settlement Monitors\Settlement MonitorsVProp Settlement Monit SOP Markup 03 2010.docC:\Users\itischlor\Desktop\Section 5 0 Settlement Monitoring SOP.doc White Mesa Mill - Standard Operating Procedures Date: 04644/20110 Revision: DUSA-24- Book #11: Environmental Protection Manual, SOP Section 5.0 Page 5 of 5 1.6 Performance Criteria and Data Validation When the monthly data has been collected, the information will be reviewed for any errors and/or major changes in the vertical movement on the settlement monitors. If there is a difference of 0.1 foot between two consecutive months, then an investigation and possible the corrective acfions will be taken as follows: 1 Resurvey the settlement monitor that shows vertical movement of 0.1 foot or more, within 7XX days of discovery of the problem.T 2 Document site conditions. 3 Prepare a document to the Corporate Compliance Director stating possible causes (i.e. expected setfiement of the tailings sands, man-caused contact, environmental stresses, er burrowing animals, etc.). 4 Report this information to the Executive Secretary within 30XX calendar davs for approval a timely manner and include in that notification the investigation steps, movement evaluation, and corrective acfions-steps taken, if needed. This report will be also be maintained within the Environmental Department records and will be submitted annually as part of the ATER as required by RML Condition 12.3. On an annual basis, a Utah Licensed Professional Engineer shall review^ and-analyze. correct (as needed), submit the data and then certify the annual data in writing—, including an explanation of the methods and basis used for the review, analysis, and corrections including ongoing graphical updates for the Setfiement Monitors. For movements attributed to expected settlement ofthe tailings sands, the review will include comments on the graphical presentation of the data, and an evaluafion of the previous, current and expected rates of ongoing settlement. which This information will be maintained within the Environmental Department records and will be submitted annually as part of the ATER as required by RML Condition 12.3. F:VWPVDivision ofRadiation ControlVDenison Mines. DUSAATER Annual Tech Eval ReportsVMovement & Settlement MonitorsVSenlement MonitorsVProp Settlement Monit SOP Markup 03-2010.docC:VUsersVitischlerVDosktopVSection 5 0 Settlement Monitoring SOP.doc White Mesa Mill - Standard Operating Procedures Date: 06/2011 Revision: DUSA-2 Book #11: Environmental Protection Manual, SOP Section 5.0 Page 1 of 5 SETTLEMENT MONITORING STANDARD OPERATING PROCEDURES 1. SETTLEMENT MONITORING 1.1 Purpose This Standard Operating Procedure (SOP) describes the vertical monitoring of the Settlement Monitors that are placed within the tailings management cell areas. This SOP will also indicate how and where to document the findings. All data collected for these purposes, as described below, will be included in an Annual Technical Evaluation Report (ATER) to be submitted to the Executive Secretary of the Utah Division of Radiation Control (the Executive Secretary) pursuant to License Condition 12.3 of the Radioactive Materials License (RML). 1.2 Locations and Frequency of Monitoring Settlement Monitors are located on covered tailings cells and shall be surveyed on a monthly basis by the Environmental Department staff and annually by a Utah Licensed Professional Land Surveyor. For any new Settlement Monitor installed (after June, 2010), within 30 days of the installation, a Utah Licensed Land Surveyor will survey the monument. The locations of new Settlement Monitors will be pre-designated by the Mill Engineer on the latest DUSA Settlement Monitor Points map (originally dated 09/15/08). Settlement Monitors will be placed on the tailings cells as the intermediate cover is advanced over tailings. New Settlement Monitors will be installed within 60 calendar days of completion of the intermediate cover at the designated locations. The Settlement Monitor Points map will be updated as part of the installation of new monitors. Settlement Monitors are also required on In-situ leach (ISL) source disposal areas that have been closed to further disposal pursuant to RML condition 10.5.A. Settlement monitors will be installed and surveyed by a Utah Licensed Land Surveyor within 30 days of the completion of each ISL disposal area, and then annually after that point. One Settlement Monitor will be required for approximately every 22,500 square feet or 5,000 cubic yards of ISL material. These monuments will be uniquely labeled to identify the specific ISL material. For ISL source disposal areas or trenches completed before April 1, 2011, the required settlement stands will be placed and the initial elevation survey completed prior to June 1, 2011. White Mesa Mill - Standard Operating Procedures Date: 06/2011 Revision: DUSA-2 Book #11: Environmental Protection Manual, SOP Section 5.0 Page 2 of 5 1.3 Design of Settlement Monitors Each Settlement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing animals and other environmental factors. The design is a 2'x2' steel plate with a 1" steel pipe welded to the center of the plate. This steel plate will be positioned by digging straight down in the desired location until tailing sands are contacted. Upon contacting the sands, the steel plate and pipe are lowered and placed on top of the sands. The hole will then be backfilled to within two feet of the ground surface. At this point, a 3" steel outer casing will be placed over the 1" inner pipe. After this has been completed, the last two feet of material will be backfilled. The top of the 3" casing will be threaded to allow for a cap to be installed. The settlement monitors will have the threaded caps, lubricated on an as needed basis, to allow the cap to be removed during the survey process. See the attached Figure 1 detailing the construction of the Settlement Monitors. In order to protect the settlement monitors from man-caused damage, each settlement will be bounded on three sides. This bounding will prevent equipment from accidentally coming in contact with the settlement monitor. These devices will consist of three 3" steel pipes that will be cemented into the ground. The interior of the pipe will also be filled with concrete. The barriers will then be painted red as a visual reminder. If damage, by any source, has occurred, the information will be documented and immediately tumed in to the RSO, or designee. The RSO, or designee, will make same day notification to the Corporate Compliance Director. Replacement and/or repairs to the damaged Settlement Monitor and the surveying and documentation of changes due to the Settlement Monitor damage will be completed within within 30 calendar days of the discovery of the damage to the Settlement Monitor. 1.4 Monthly Surveying (i) The monthly survey will be performed by the Mill's Radiation Safety Officer or designee (the "Surveyor") with the assistance of another Mill worker (the "Assistanf); (ii) The survey will be performed using a survey instrument accurate to 0.1 feet, such as a Sokkai No. B21, or equivalent, together with a survey rod having a visible scale in 0.1 foot increments; (iii) The reference points are known points established by a professional survey. (iv) The surveyor will set up the survey instrument in a location where both the applicable reference point and settlement monitor are visible. (v) Once in location, the surveyor will ensure that the survey instrument is level by centering the bubble in the level gauge on the survey instrument; (vi) The assistant will place the survey rod vertically on the reference point. The assistant will ensure that the survey rod is vertical by gently rocking the rod back and forth until the surveyor has established a level reading; White Mesa Mill - Standard Operating Procedures Date: 06/2011 Revision: DUSA-2 Book #11: Environmental Protection Manual, SOP Section 5.0 Page 3 of 5 (vii) The surveyor will focus the cross hairs of the survey instrument on the scale on the survey rod, and record the number (the "reference point reading"), which represents the number of feet the survey instrument is reading above the reference point; (viii) The assistant will then move to a designated settlement monitor. Once at the monitor, the assistant will remove the steel cap and place the survey rod on top of the 1" inner pipe. A few of the original settlement monitors do not have an inner pipe. For original settlement monitors without a 1" inner pipe, the assistant will place the survey rod on the lip of the settlement monitor; (ix) The assistant will hold the rod vertically and will ensure the survey rod is vertical by gently rocking the rod back and forth until the Surveyor has established a level reading; (x) The surveyor will focus the cross hairs of the survey instrument on the scale on the survey rod, and record the number (the "surface reading"), which represents the number of feet the survey instrument is reading above the settlement monitor. The surveyor will calculate the elevation of the settlement monitor by adding the reference point reading to the reference point elevation and then subtracting the surface reading for the settlement monitor, and will record the number accurate to 0.1 feet. The elevation information will be maintained within the Environmental Department records. The monthly documentation of the readings will be recorded on the Monthly Tailings Inspection Form. The form can be found in Section 3.1 of the Environmental Protection Manual. 1.5 Monitoring and Maintenance of Settlement Monitors 1.5.1 Monitoring and Documentation of Condition of Devices The Settlement Monitors will be maintained so that the monuments remain in reliable, good working condition. Conditions at and in the vicinity of the monitoring devices will be inspected monthly by Environmental Department staff Any observations will be recorded on the monthly tailings inspection report form. On an annual basis, each monument will be photographed to document conditions at the monitoring areas. Additionally, photographs will be taken following any instances of unusually severe weather or incidents involving equipment if they result in physical damage or disturbance to any settlement monitoring device, or significant changes to the ground areas adjacent to or surrounding the settlement monitor. The following records and documents will be maintained by the Environmental Department staff a) Monthly tailings inspection forms White Mesa Mill - Standard Operating Procedures Date: 06/2011 Revision: DUSA-2 Book #11: Environmental Protection Manual, SOP Section 5.0 Page 4 of 5 b) Data files of monthly and annual survey information c) Records of initial installation and survey data d) Records of maintenance, damage, and/or replacement of settlement monitors e) Annual photographs documenting site conditions at each settlement monitor f) Annual Review of Settlement Monitors by Utah Licensed Professional Engineer 1.5.2 Maintenance of Monitors If any settlement monitoring device is irreparably damaged as a result of environmental stresses or man-caused contact, it will be promptly replaced with an identical or equivalent device. Based on the last monthly survey, prior to the damage, the replacement device will be placed as near as practical at the same elevation and in the same location from which the damaged device was removed. Data from the new device will be correlated to data from the removed damaged device as follows: 1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the location of the new device as well as that of the two nearest (undamaged) devices adjacent to the new device. 2. If the survey indicates there has been less than 0.1 foot of vertical change since the last monthly survey in the elevation of the undamaged devices, no adjustment will be made to the survey data of the new device. 3. If the survey indicated 0.1 foot or greater of vertical change to either ofthe undamaged devices, the survey results for the new device will be adjusted by the average change observed in the two adjacent devices. This adjustment will be documented in the Utah- Licensed Land Surveyors report and in the annual ATER. 4. Also, based on the last monthly survey, prior to the damage, if the elevation ofthe new device is greater than +/- 0.1 foot from that of the damaged device, then the replacement device will be designated with a new number (such as "Cell 2W2-R", as the replacement for damaged device "Cell 2W2"). Elevation data for the new device, and the date of installation of the new device, will be recorded in the data file adjacent to the information from the damaged device, with a notation that this device is a replacement for the damaged device. 1.6 Performance Criteria and Data Validation When the monthly data has been collected, the information will be reviewed for any errors and/or major changes in the vertical movement on the settlement monitors. If there is a difference of O.l foot between two consecutive months, then an investigation and possible corrective actions will be taken as follows: White Mesa Mill - Standard Operating Procedures Date: 06/2011 Revision: DUSA-2 Book #11: Environmental Protection Manual, SOP Section 5.0 Page 5 of 5 1. Resurvey the settlement monitor that shows vertical movement of 0.1 foot or more, within 7 days of discovery of the problem. 2. Document site conditions. 3. Prepare a document to the Corporate Compliance Director stating possible causes (i.e. expected settlement of the tailings sands, man-caused contact, environmental stresses, burrowing animals, etc.). 4. Report this information to the Executive Secretary within 30 calendar days for approval and include in that notification the investigation steps, movement evaluation, and corrective actions taken, if needed. This report will also be maintained within the Environmental Department records and will be submitted annually as part of the ATER as required by RML Condition 12.3. On an annual basis, a Utah Licensed Professional Engineer shall review, analyze, correct (as needed), submit and certify the annual data in writing, including an explanation of the methods and basis used for the review, analysis, and corrections including ongoing graphical updates for the Settlement Monitors. For movements attributed to expected settlement of the tailings sands, the review will include comments on the graphical presentation of the data, and an evaluation of the previous, current and expected rates of ongoing settlement. This information will be maintained within the Environmental Department records and will be submitted annually as part of the ATER as required by RML Condition 12.3.