HomeMy WebLinkAboutDRC-2011-007626 - 0901a0688028f87cState of Utah
GARY R. HERBERT
Govemor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rust Liindberg
i)irector m
September 26, 2011
David Frydenlund, Vice President Regulatory Affairs and Counsel
Denison Mines (USA) Corp.
1050 17**'Street, Suite 950
Denver-Colorado 80265
RE: Radioactive Material License (RML) Number UTI900479: Health Physics Inspection
RADMOD-AFIL-01
Dear Mr. Frydenlund:
On September 20 and 21, 2011, an inspection was conducted at your facility by Ryan Johnson, a
representative of the Division of Radiation Control (DRC) of the Utah Department of
Enviromnental Quality. Observations fi'om the inspection were discussed with David Turk and
Ronnie Nieves at the closeout meeting. The inspection was an examination of the activities
conducted in your facility as they relate to compliance with the Utah Radiation Control Rules, the
license conditions of the RML UTI 900479 and Federal Regulations. The inspection consisted of
an examination of representative records, interviews of personnel, and observations by the
inspector. During the closeout meeting the DRC inspector made recommendations regarding
items for improvement. These recommendations can be found at the end of the inspection report
under recommendations.
Enclosed is the inspection report regarding this inspection for your review. The DRC considers
this inspection closed. The DRC would like to thank the Mill staff for their cooperation regarding
this inspection. If you have any questions conceming this letter contact Mr. Ryan Johnson
(801)536-4250.
UTAH RADIATION CONTROL BOARD
Rusty Lundbel^, Executive Secretary
RL/RJ:rj
Cc: David Turk, Site Radiation Officer
Enclosures
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone (801) 536-4250 • Fax (801-533-4097 • T.D.D. (801) 536-4414
www.deq.utah.gov
. Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module: RADMOD-AFIL-01: Altemate Feed and Insitu-Leach
Inspection Location: Denison Mines- White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Altemate Feed Acceptance and Circuit and Insitu Leach Recovery (ISL)
(a.k.a. 1 le(2)) Material Acceptance and Disposal
InspectionDates: September 20 and 21, 2011
Inspectors: Ryan Johnson, Utah Division of Radiation Control (DRC)
Personnel Contacted: Dave Turk (Radiation Safety Officer (RSO)), Ronnie Nieves (Radiological
Coordinator)
Goveming Documents:
• UACR313-15
• Radioactive Materials License (RML) UTI 900479
Opening Meeting
Denison Mines:
Dave Turk (Radiation Safety Officer)
Ronnie Nieves (Radiological Coordinator)
Utah DRC:
Ryan Johnson (Inspector)
Kevin Camey (Inspector)
During the opening meeting, the inspector discussed the inspection items and documentation to be
reviewed during the inspection. Only the Altemate Feed Circuit of the Mill was in operation
during this inspection the remainder of the Mill was in armual shut down and maintenance. The
Mill staff reminded the inspector of the safety requirements for the Mill.
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• The generators shipping papers.
Deficiencies: ISL documentation is incomplete it does not completely document disposal activities
and steps taken to minimize void spaces.
In discussing this observation with the Mills RSO, the Inspector was provided a new form that will
be filled out for ISL (11 e(2)) material disposal. This form is Attachment 2 lie.(2) Byproduct
Material Disposal Documentation Form and it part of SOP PBL-10 R-3 lie. (2) Byproduct ^
Disposal. This revision of the procedure is currently be reviewed by the DRC and won't be
implemented until the DRC approves the procedure.
Closeout Meeting
Denison Mines:
Dave Turk (RSO)
Ronnie Nieves (Radiological Coordinator)
Utah DRC:
Ryan Johnson (Inspector)
Kevin Camey (Inspector)
During the closeout meeting the inspector discussed with RSO the number of air particulate
monitoring stations around the Mill. The inspector questioned, due to the size of the Mill property,
if there were enough BHV stations around the Mill to properly document the effluents fi'om the
Mill's ore pad, stacks and tailings cells.
Findings
The following fmdings were observed during this inspection:
1. Large cracks were observed in the concrete floor of the Altemate Feed Circuit area;
2. Dmms being staged to be put into the Altemate Feed Circuit were being placed on soil; and
3. Incomplete documentation ofthe 1 le.(2) material disposal process.
The Inspector also observed that the White Mesa Mill was in the process of correcting all ofthe
findings observed at the time of the inspection. Therefore, no enforcement actions will be taken
and these findings will be followed up by the DRC during the next inspection.
Recommendations
The following are DRC recommendations regarding items for improvement:
1. The DRC recommends that the 11 e.(2) Byproduct Material Disposal Documentation Form in
Attachment 2 of SOP PBL-10 R-3 1 le.(2) Byproduct Disposal is used immediately and not to
wait for DRC approval of the SOP.
2. The DRC recommends that the concrete for the Dmm Dumping Node is completed.
3. The DRC recommends that the cracks in the concrete floor of the Altemate Feed Circuit are
repaired.
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UTAH DIVISION OF RADIATION CONTROL
Inspecdon Module RADMOD-AFIL
WHITE MESA MILL
RML LICENSE UTI900479
OPENING MEETING
INSPECTOR(S) /C
DATE f-^<^-//^
MEETESIG MEMBERS
NAME COMPANY CONTACT
ESIFORMATION
UTAH DIVISION OF RADIATION CONTROL
DISCUSSION
//^ . SITE STAFF COMMENTS
ft] UTAIWIVISION OF RADIATION COmROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-AFIL-01
ALTERNATE FEED/INSITU LEACH FACILITY MATERIALS
DENISON MINES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UTI900479
References: Radioactive Material License UT1900479, License Renewal Application dated Febmary 28, 2007,
Radiation Protection Manual, Section 5, 10CFR20, Utah Administrative Code R313-15.
Alternate Feed Material (License Conditions 10.1,10.6 through 10.19)
1) Review the altemate feed manifests fi-om the last two years. (License Condition 10.6 through 10.19)
Date Generator Name Amount Received Storage Location/Processed
t / ( i
7^ ATA-
r 2-^3
7^
/
L
/
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2^ Have any altemate feeds been
Comrnents:
;epted that were not approved through' License Amendment?
Yes_ . NoX:^'.
How much tailings cell disposal capacity does the mill have left: at the time of the inspection?
How much altemate feed/ore/ISL material does the mill have onsite?
3)
Does the amount of altemate feed/ore/ ISL material exceed the tailing cell capacity? Yes No
Is the current surety amount adequate for the amount of altemate feed/ore/ ISL material currently stored at
the mill? (License Condition 10.1) Yes No
Comments:
Observe the new Alternate Feed Circuit being used.
4) Which Altemate Feed is being processed?(Name and Associated License Condition)
Comments:
r^f^ .
5) What PPE is being used?
Alternate Feed Circuit
Drum Dumping Node
PPE Observed Y/N
PPE Requiremen ts (check applicable) Alternate Feed Circuit
Drum Dumping Node
PPE Observed Y/N
Hard Hats i Tyvek Disp. Gloves
Alternate Feed Circuit
Drum Dumping Node
PPE Observed Y/N Safety Glasses Hearing Face Shields r
Alternate Feed Circuit
Drum Dumping Node
PPE Observed Y/N
Safety Boots Respirators Rubber Suits
Alternate Feed Circuit
Drum Dumping Node
PPE Observed Y/N
Rubber Boots Lab Coats Other
Alternate Feed Circuit
Drum Dumping Node
PPE Observed Y/N
Coveralls Gloves
Alternate Feed Circuit
UF4 Carbonate
Digestion Node
PPE Observed Y/N
PPE Requiremem ts (check applicable) Alternate Feed Circuit
UF4 Carbonate
Digestion Node
PPE Observed Y/N
Hard Hats f Tyvek Disp. Gloves
Alternate Feed Circuit
UF4 Carbonate
Digestion Node
PPE Observed Y/N Safety Glasses f Hearing Face Shields
Alternate Feed Circuit
UF4 Carbonate
Digestion Node
PPE Observed Y/N
Safety Boots Respirators Rubber Suits
Alternate Feed Circuit
UF4 Carbonate
Digestion Node
PPE Observed Y/N
Rubber Boots Lab Coats Other
Alternate Feed Circuit
UF4 Carbonate
Digestion Node
PPE Observed Y/N
Coveralls P Gloves
Alternate Feed Circuit
NaOH Precipitation
Node
PPE Observed Y/N
PPE Requirement ts (check applicable) Alternate Feed Circuit
NaOH Precipitation
Node
PPE Observed Y/N
Hard Hats F Tyvek Disp. Gloves
Alternate Feed Circuit
NaOH Precipitation
Node
PPE Observed Y/N Safety Glasses Hearing Face Shields
Alternate Feed Circuit
NaOH Precipitation
Node
PPE Observed Y/N
Safety Boots Respirators Rubber Suits
Alternate Feed Circuit
NaOH Precipitation
Node
PPE Observed Y/N
Rubber Boots Lab Coats Other
Alternate Feed Circuit
NaOH Precipitation
Node
PPE Observed Y/N
Coveralls Gloves
U:\rad\COMMON\Uranium millsM le(2)UTl900479 Denison Mines - White Mesa UMill\HP hispection modules\201 l\hispection Modules\RADMOD-AFIL-01.doc
AlterBiate Feed Circuit
NaOH Precipitate
Filtration Node
PPE Observed Y/N
PPE R^uiremen ts (check applicable) AlterBiate Feed Circuit
NaOH Precipitate
Filtration Node
PPE Observed Y/N
Hard Hats P Tyvek Disp. Gloves
AlterBiate Feed Circuit
NaOH Precipitate
Filtration Node
PPE Observed Y/N Safety Glasses P Hearing Face Shields
AlterBiate Feed Circuit
NaOH Precipitate
Filtration Node
PPE Observed Y/N
Safety Boots Respirators Rubber Suits
AlterBiate Feed Circuit
NaOH Precipitate
Filtration Node
PPE Observed Y/N
Rubber Boots P Lab Coats Other
AlterBiate Feed Circuit
NaOH Precipitate
Filtration Node
PPE Observed Y/N
Coveralls Gloves c> 1
Alternate Feed Circuit
Filter Cake Acid
Re-Dissolution Node
PPE Observed Y/N
PPE Requirements (check applicable) Alternate Feed Circuit
Filter Cake Acid
Re-Dissolution Node
PPE Observed Y/N
Hard Hats f Tyvek Disp. Gloves
Alternate Feed Circuit
Filter Cake Acid
Re-Dissolution Node
PPE Observed Y/N Safety Glasses F Hearing Face Shields
Alternate Feed Circuit
Filter Cake Acid
Re-Dissolution Node
PPE Observed Y/N
Safety Boots Respirators Rubber Suits
Alternate Feed Circuit
Filter Cake Acid
Re-Dissolution Node
PPE Observed Y/N
Rubber Boots f Lab Coats Other
Alternate Feed Circuit
Filter Cake Acid
Re-Dissolution Node
PPE Observed Y/N
Coveralls r Gloves V
Alternate Feed Circuit
Filtration After Acid
Digestion of Filter
Cake Node
PPE Observed Y/N
PPE Requirements (check applicable) Alternate Feed Circuit
Filtration After Acid
Digestion of Filter
Cake Node
PPE Observed Y/N
Hard Hats p Tyvek Disp. Gloves
Alternate Feed Circuit
Filtration After Acid
Digestion of Filter
Cake Node
PPE Observed Y/N
Safety Glasses Hearing Face Shields
Alternate Feed Circuit
Filtration After Acid
Digestion of Filter
Cake Node
PPE Observed Y/N Safety Boots Respirators Rubber Suits
Alternate Feed Circuit
Filtration After Acid
Digestion of Filter
Cake Node
PPE Observed Y/N
Rubber Boots Lab Coats Other
Alternate Feed Circuit
Filtration After Acid
Digestion of Filter
Cake Node
PPE Observed Y/N
Coveralls Gloves
Alternate Feed Circuit
Impurity Removal
Node
PPE Observed Y/N
PPE Requirements (check applicable) Alternate Feed Circuit
Impurity Removal
Node
PPE Observed Y/N
Hard Hats p Tyvek Disp. Gloves
Alternate Feed Circuit
Impurity Removal
Node
PPE Observed Y/N Safety Glasses P Hearing Face Shields
Alternate Feed Circuit
Impurity Removal
Node
PPE Observed Y/N
Safety Boots Respirators Rubber Suits
Alternate Feed Circuit
Impurity Removal
Node
PPE Observed Y/N
Rubber Boots f Lab Coats Other
Alternate Feed Circuit
Impurity Removal
Node
PPE Observed Y/N
Coveralls e Gloves /
Comments:
6) Is the New Circuit operated under an RWP or an SOP?
Comments:
RWP SOP^
7) Where are the air monitoring Stations located for the Altemate feed Circuit?
Comments:
/^^/? M ^ /it (A I 2^
U:\rad\COMMON\Uranium millsM le(2)UT 1900479 Denison Mines - White Mesa UMill\HP hispection modules\20H\hispection Modules\RADMOD-AFIL-01 .doc
^ 8) What type of air Monitoring a^liey doing for the Altemate feed Circu^l^
Comments: /
is
9) Is the Air Monitoring in the Altemate Feed Circuit adequate? Yes )C No
Comments: . ,^
10) Is the Altemate feed Circuit posted? Yes ^ No
Is each area within the Altemate feed Circuit posted differentiy? Yes y No
How is the Altemate feed Circuit area(s) posted?
Comments:/ .
11) Does the posting(s) reflect the radiological/health concems present? Yes No
Comments:
W ac^cA yiSJe /^^L^ (Ff^ c^/f <^
12) Are area gamma monitors in the Altemate Feed Circuit located appropriately? Yes X'' No
Comments:
13) What are the types of monitoring systems being used and are they appropriate?
Comments: ^
U:\rad\COMMON\Uranium millsM le(2)UT 1900479 Denison Mines - White Mesa UMill\HP hispection modules\201 l\hispection Modules\RADMOD-AFIL-01 .doc
Dar,o /I O
14) Briefly describe the dmm han^il^g and loading into the Altemate Feed^fcuit.
Comments: ,
£^ , ^^^^ /pc?.^ /-s ^7/^- ^
t^M/^ ^ ^^'-'^ /if?v^f^ "X> .p.^^^ /..J^-^
Note * Tom during a previous inspection documented that dmms were being staged off of the Altemate Feed
Circuit with possible staining in soils fi'om the dmms •
U:\rad\COMMON\Uranium millsM le(2)UT 1900479 Denison Mines - White Mesa UMill\HP hispection modules\201 l\hispection Modules\RADMOD-AFIL-01 .doc
Alternate Feed Material (ContalW-ized Alternate Feedstock Material Mirage Procedure)
15) Are all Altemate Feed materials stored on the Ore Pad? Yes No
If answer is no then go to questions 8 through 13. If yes skip to question 14.
Comments: y / / " /
16) Where is the Altemate Feed not on the Ore Pad being stored?
Comments: /I f ; y
17) Is the Altemate Feed Material being stored on a Hardened Surface? Yes_^ No
If No, Is the Altemate feed being stored in Over Pack containers? Yes No_
Comments: ^
18) Are Altemate Feed Containers stacked no more then 2 wide and 2 high? Yes No
Comments:
19) Are Altemate Feed Containers being stored on planks or pallets? Yes_ No ^
Comments:
20) Are Altemate Feed Storage areas bermed? Yes_ ^ No^^^
Comments: / ^ ^ /?
o s^^z/ /^-"^ - • —
21) Are weekly inspections of the Altemate Feed Storage Areas being done and documented? Yesy^ No
Comments:
U:\rad\COMMON\Uranium millsM le(2)UTl 900479 Denison Mines - White Mesa UMillVHP hispection modules\201 l\hispection Modules\RADMOD-AFIL-01.doc
Insitu Leach Facilitv Material (HRnse Condition 10.5)
22) According to License Condition 10.5 Part D "All disposal activities shall be documented". Review the
disposal records from the past two years (starting from the present year). Describe how the shipments are
documented and what is documented.
Comments:
U:\rad\C0MM0N\Uramum millsM le(2)UTl 900479 Denison Mines - White Mesa UMill\HP hispection modulesVZOl l\hispection Modules\RADMOD-AFIL-01.doc
, 23) Have any single source of ISL^fete material exceed the disposal limit ^11,000 cubic yards per source?
Comments: (License Condition 10.5.A) Yes No
24) Was all ISL waste material disposed in Cell #3? (License Condition 10.5.C) .
Comments: Yes No
25) Were all disposal activities properly documented? (License Condition 10.5.D) .
Comments: Yes No VN'
26) Did the documentation show that all steps were taken to minimize void spaces? (License Condition 10.5.B)
Comments: Yes No
^ ^ .
27) Discuss with the Lead/Forman of ISL disposal on how ISL material is disposed. If possible observe also.
Comments:
: ^ , , •
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Porro O of 0
UTAH DIVISION OF RADIATION CONTROL
Inspection Module RADMOD-AFIL
WHITE MESA MILL
RML LICENSE UTI 900479
CLOSEOUT MEETING
INSPECTOR(S) ^
DATEttiUzj/
MEETING MEMBERS
NAME COMPANY CONTACT
INFORMATION
/L/nf/ A/iP'^S
UTAH DIVISION OF RADIATION CONTROL
CLOSEOUT MEETING
DISCUSSION of FINDINGS
'i/o(^.u^^J&).^ y\&<^^. ^,7^ ^/J:?^ 6^..t.^J^
//\A^rZ^ 1^ % a^^^yZr^y^^^ .Mc^.^ ;^ \y41^/j/^
— j^^xSl ^•^Af /A^0€'Z/^ A-^l^y 1^ ^^/^.^
SITE STAFF COMMENTS
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 10 of 11
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:
Generator of the Byproduct Material: _
Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
Was the material placed on a taifings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
Was the material segregated from any Mill material or equipment disposed of in the cell?
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Engineer's
Initials
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thicknessof subsequent lifts less than 2 feet
thick?
Has 4 foot of tailings sands been maintained under each disposal area?
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell?
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 11 of 11
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
Were void spaces filled with tailings?
Was the shipment properly covered?
Are additional settlement monitors required to be placed for this generator?
If required, where were settlement markers were placed?
Radiological receipt survey measurements:
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or No
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? Yes or No
Inspection Summarv
The inspection consisted of employee interviews, review of documentation and a mill tour. The
following discussion provides more detail of the specific items.
Item 1. Mill Tour: The inspector walked through the restricted area on a general site tour. The
tour included the ore pad, the new decontamination pad, the mill, the altemate feed circuit, and the
tailings ponds. No ISL material was being disposed during the inspection and those activities were
not observed. ^
Observations: The DRC inspector observed:
• Proper PPE was being worn by Mill employees within the Altemate Feed Circuit and other
areas of the Mill;
• Proper Radiological Posting were being used at the Altemate Feed Circuit;
• TLDs were appropriately being used for general area Gamma radiation monitoring within
the Altemate Feed Circuit; and
• Appropriate air monitoring, both general area and quarterly breathing zone, was being done
within the Altemate feed circuit.
Deficiencies: The inspector observed the following deficiencies:
• Large cracks in the cement floor in the Altemate Feed Circuit area; and
• Dmms that were being "staged" next to the Dmm Dumping Node of the Altemate Feed
Circuit.
The Inspector did observe that repair activities were being done on the cracks in the floor and the
RSO said that concrete will be poured by October 15, 2011 in the area where the dmms are being
staged.
Item 2. Documentation:
Alternate Feed Documentation: The Inspector reviewed the documentation for altemate feed
acceptance.
Observations: The altemate feed documentation documented:
• The date of the shipment;
• The generators name;
• The amount of material that was in each shipment; and
• Where the altemate feed material was being stored.
ISL Disposal Documentation: The Inspector reviewed the documentation for ISL acceptance and
disposal.
Observations: The ISL material shipment was documented with:
• A Bill of Lading;
• Photographs of the load of material when it arrived;
• PID (VOC) readings;
• Radiological Survey Information fi'om the load when it arrived; and
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• The generators shipping papers.
Deficiencies: ISL documentation is incomplete it does not completely document disposal activities
and steps taken to minimize void spaces.
In discussing this observation with the Mills RSO, the Inspector was provided a new form that will
be filled out for ISL (11 e(2)) material disposal. This form is Attachment 2 lie. (2) Byproduct'
Material Disposal Documentation Form and it part of SOP PBL-10 R-3 lie. (2) Byproduct
Disposal. This revision of the procedure is currently be reviewed by the DRC and won't be
implemented until the DRC approves the procedure.
Closeout Meeting
Denison Mines:
Dave Turk (RSO)
Ronnie Nieves (Radiological Coordinator)
Utah DRC:
Ryan Johnson (Inspector)
Kevin Camey (Inspector)
During the closeout meeting the inspector discussed with RSO the number of air particulate
monitoring stations around the Mill. The inspector questioned, due to the size of the Mill property,
if there were enough BHV stations around the Mill to properly document the effluents fi^om the
Mill's ore pad, stacks and tailings cells.
Findings
The following findings were observed during this inspection:
1. Large cracks were observed in the concrete floor of the Altemate Feed Circuit area;
2. Dmms being staged to be put into the Altemate Feed Circuit were being placed on spil; and
3. Incomplete documentation of the 1 le.(2) material disposal process.
The Inspector also observed that the White Mesa Mill was in the process of correcting all of the
findings observed at the time of the inspection. Therefore, no enforcement actions will be taken
and these fmdings will be followed up by the DRC during the next inspection.
Recommendations
The following are DRC recommendations regarding items for improvement:
1. The DRC recommends that the 11 e.(2) Byproduct Material Disposal Documentation Form in
Attachment 2 of SOP PBL-10 R-3 1 le.(2) Byproduct Disposal is used immediately and not to
wait for DRC approval of the SOP.
2. The DRC recommends that the concrete for the Dmm Dumping Node is completed.
3. The DRC recommends that the cracks in the concrete floor of the Altemate Feed Circuit are
repaired.
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Recommendation for Next Inspectiori
1. Spills (yellowcake and other materials) being cleaned up in the mill immediately, and
2. Personnel Exit Monitoring
3 . Follow-up on the Findings of this inspection.
Prepared By: Ryan Johnson '
(Print Name) (Signature) (Date)
Reviewed By: Phil Goble
(Print Name) (Signature) (Date)
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