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HomeMy WebLinkAboutDRC-2016-004698 - 0901a0688061526fr Div of Waste Management and Radiation Control Energ\ Fuels Resources (ll.SA) 1 ne. / MAR 11 2016 225 l nion l}l\d. Suite 6(10 Lakewood. CO. LS, S022S ENERGYFUELS 303 074 2 140 March 7,2016 Sent VIA E-MAIL AND OVERNIGHT DELIVERY Mr. Scott Anderson, Director Division of Waste Management and Radiation Control State of Utah Department of Environmental Quality 195 North 1950 West P.O. Box 144880 Salt Lake City, UT 84114-4880 Re: Follow-up to DWMRC’s Letter dated November 4, 2015, Regarding Licensee-to-Licensee Transfer of Source Material at Energy Fuels Resources (USA) Inc.’s (“EFRI’s”) White Mesa Mill, State of Utah Radioactive Materials License No. UT1900479 (the “License”) Dear Mr. Anderson: This letter is a follow-up to a letter dated November 4, 2015, from the Division of Waste Management and Radiation Control (“DWMRC”) regarding EFRTs intent to receive yellowcake slurry from Energy Fuels’ Nichols Ranch In-Situ Recovery Project (“Nichols Ranch”) located in Wyoming (U.S. Nuclear Regulatory Commission (“NRC”) License No. SUA-1597 held by EFRTs affiliate Uranerz Energy Corporation) for final processing at the White Mesa Mill (the “Mill”). In the November 4, 2015, letter, the DWMRC provided concurrence that transfer of yellowcake slurry from Nichols Ranch to the Mill did not require a License amendment and requested documentation that the uranium slurry hauling system is an NRC-approved package as defined in 10 CFR 71, 49 CFR 173.427 and Table 6 found in 49 CFR 173. As such, EFRI is herein providing a description of how the uranium slurry hauling system meets the requirements of 49 CFR 173.427, which is incorporated by reference in 10 CFR 71. §173.427 Transport requirements for low specific activity (LSA) Class 7 (radioactive) material and surface contaminated objects (SCO). (a) In addition to other applicable requirements specified in this subchapter, LSA material and SCO must be transported in accordance with the following conditions: (1) The external dose rate may not exceed an external radiation level of 10 mSv/h (1 rem/h) at 3 m (10 feet) from the unshielded material; Letter to S. Anderson March 7,2016 Page 2 of 7 Shipments of yellowcake slurry from Nichols Ranch will be released for transport through the facility’s Health Physics Department, as approved by the Radiation Safety Officer. The facility’s Radiation Protection Program and procedures detail the contamination and dose rate surveys required to meet U.S. Department of Transportation (DOT) standards for the shipment of radioactive materials. The same surveys will be performed on the incoming (returning) shipment to ensure the empty conveyance meets DOT standards for radioactive packages. The results of the surveys will be maintained with a proper Bill of Lading for the shipment and maintained on site (i.e., at Nichols Ranch and the Mill) for review or inspection. (2) The quantity of LSA material and SCO transported in any single conveyance may not exceed the limits specified in Table 5; Pursuant to 10 CFR 71.4, yellowcake slurry (i.e., concentrates of uranium ore) is considered LSA-1 material. As shown in Table 5 below, there is no limit for LSA-1 material. (3) LSA material and SCO that are or contain fissile material must conform to the applicable requirements of §173.453; Not applicable. (4) Packaged and unpackaged Class 7 (radioactive) materials must conform to the contamination control limits specified in §173.443; TABLE 9-NON-FIXED EXTERNAL RADIOACTIVE CONTAMINATION LIMITS FOR PACKAGES Contaminant Maximum permissible limits Bq/crn uCi/cm2 dpm/cm 1. Beta and gamma emitters and low toxicity alpha emitters 10-4 240 2. All other alpha emitting radionuclides 0.4 10-24 The uranium slurry hauling system (i.e., conveyance) is the package and will be surveyed to ensure the non-fixed (i.e., removable) contamination is within DOT limits. (5) External radiation levels may not exceed those specified in §173.441; and The dose limit at any point on the surface of the exclusive use transport vehicle is 200 mrem/hr. This limit will be verified prior to release of the conveyance. (6) For LSA material and SCO consigned as exclusive use: 2 (i) Shipments must be loaded by the consignor and unloaded by the consignee from the conveyance or freight container in which originally loaded; Shipments will be consigned as exclusive use and will be loaded and unloaded only by consignor and consignee, respectively. (ii) There may be no loose radioactive material in the conveyance; however, when the conveyance is the packaging, there may not be any leakage of radioactive material from the conveyance; The uranium slurry hauling system (i.e., conveyance) is the package and will be inspected during the contamination survey for leakage prior to release. (Hi) Packaged and unpackaged Class 7 (radioactive) material must be braced so as to prevent shifting of lading under conditions normally incident to transportation; The uranium slurry hauling system consists of two tanks attached to a lowboy trailer that allows for vibration movement while not comprising the security of the load. (iv) Specific instructions for maintenance of exclusive use shipment controls shall be provided by the offeror to the carrier. Such instructions must be included with the shipping paper information; Exclusive use shipping papers will contain Bill of Lading, instructions to the carrier, emergency information, and radiation/contamination surveys. (v) The shipment must be placarded in accordance with subpart F of part 172 of this subchapter; The uranium slurry hauling system will be placarded “Radioactive 7” with a “Radioactive LSA, RQ” label. (vi) For domestic transportation only, packaged and unpackaged Class 7 (radioactive) material containing less than an A2 quantity are excepted from the marking and labeling requirements of this subchapter, other than the subsidiary hazard labeling required in §172.402(d). However, the exterior of each package or unpackaged Class 7 (radioactive) material must be stenciled or otherwise marked “RADIOACTIVE—LSA” or “RADIOACTIVE—SCO”, as appropriate, and packages or unpackaged Class 7 (radioactive) material that contain a hazardous substance must be stenciled or otherwise marked with the letters “RQ ” in association with the description in this paragraph (a)(6)(vi); and The uranium slurry hauling system will be placarded “Radioactive 7” with a “Radioactive LSA, RQ” label. (vii) Transportation by aircraft is prohibited except when transported in an industrial package in accordance with Table 6 of this section, or in an authorized Type A or Type B package. Letter-to S. Anderson March 7, 2016 Page 3 of 7 3 Letter to S. Anderson March 7, 2016 Page 4 of 7 Not applicable. (b) Except as provided in paragraph (c) or (d) of this section, LSA material and SCO must be packaged as follows: (1) In an industrial package (Type IP-1, Type IP-2 or Type IP-3; §173.411), subject to the limitations of Table 6; The uranium slurry hauling system is an Industrial Package Type IP-1 for LSA-1 materials. (2) In a DOT Specification 7A (§178.350 of this subchapter) Type A package; Not applicable. (3) In any Type B(U) or B(M) packaging authorized pursuant to §173.416; Not applicable. (4) For domestic transportation of an exclusive use shipment that is less than an A2 quantity, in a packaging which meets the requirements of §173.410; or The uranium slurry hauling system meets the requirements of a Type IP-1 package as prescribed in 49 CFR 173.410. The tanks will be securely attached to a lowboy trailer and can be easily decontaminated with surfaces free of protrusions, pockets and crevices. The cargo tanks are capable of withstanding the effects of acceleration and vibration during normal transport. The materials of construction are compatible with the contents. All valves through which the package contents could escape are protected against unauthorized operation. The tanks are certified to meet ASME Boiler and Pressure Vessel Code and DOT 407/412 requirements (see attached certifications in Attachment A). Copies of these certifications will be maintained at both Nichols Ranch and the White Mesa Mill. (5) In portable tanks, cargo tanks and tank cars, as provided in §173.411(b)(4) and (5), respectively. Not applicable. (c) LSA-I material and SCO-I may be transported unpackaged under the following conditions: (1) All unpackaged material, other than ores containing only naturally occurring radionuclides, must be transported in such a manner that under routine conditions of transport there will be no escape of the radioactive contents from the conveyance nor will there be any loss of shielding; Not applicable. 4 Letter*to S. Anderson March 7,2016 Page 5 of 7 (2) Each conveyance must be under exclusive use, except when only transporting SCO-l on which the contamination on the accessible and the inaccessible surfaces is not greater than 4.0 Bq/cm2 for beta and gamma emitters and low toxicity alpha emitters and 0.4 Bq/cm" for all other alpha emitters; Not applicable. (3) For SCO-I where it is reasonable to suspect that non-fixed contamination may exist on inaccessible surfaces in excess of the values specified in paragraph (c)(2) of this section, measures shall be taken to ensure that the radioactive material is not released into the conveyance or to the environment; and Not applicable. (4) The highway or rail conveyance must be placarded in accordance with subpart F of part 172 of this subchapte. Not applicable. Also, see (a)(6)(v) above. (d) FSA material and SCO that exceed the packaging limits in this section must be packaged in accordance with 10 CFR part 71. Not applicable. (e) Tables 5 and 6 are as follows. TABFE 5-CONVEYANCE ACTIVITY LIMITS FOR LSA MATERIAL AND SCO Nature of material Activity limit for conveyances other than by inland waterway Activity limit for hold or compartment of an inland waterway conveyance 1. LSA-I No limit No limit 2. LSA-11 and LSA-III; Non-combustible solids No limit 100 A2 3. LSA-II and LSA-III; Combustible solids and all liquids and gases 100 A2 10 a2 4. SCO 100 A,10 A2 5 Letterto S. Anderson March 7,2016 Page 6 of 7 TABLE 6-INDUSTRIAL PACKAGE INTEGRITY REQUIREMENTS FOR LSA MATERIAL AND SCO Contents Industrial packaging type Exclusive use shipment Non exclusive use shipment 1. LSA-I: Solid Type IP-1 Type IP-1 Liquid Type IP-1 Type IP-2 2. LSA-1I: Solid Type IP-2 Type IP-2 Liquid and gas Type IP-2 Type IP-3 3. LSA-III Type IP-2 Type IP-3 4. SCO-I Type IP-1 Type IP-1 5. SCO-11 Type IP-2 Type IP-2 [79 FR 40613, July 11, 2014] Please let me know if you have any questions or require any further information regarding the foregoing. You can reach me at 303-389-4132 or Kathy Weinel at 303-389-4134. Sincerely, _____ Energy Fuels Resources (USA) Inc. Scott A Bakken Sr. Director, Regulatory Affairs Att ASME and DOT Certifications ec: David C. Frydenlund Harold R. Roberts William Paul Goranson Kathy Weinel David E. Turk 6 Attachment A ASME and DOT Certifications FORM U-1A MANUFACTURER'S DATA REPORT FOR PRESSURE VESSELS (Alternate Form for Single Chamber, Completely Shop or Field Fabricated Vessels Only) As Required by the Provisions of the ASME Boiler and Pressure Vessel Code Rules, Section VIII, Division 1 1. Manufactured and certified by Proco Inc. 700 Proco Trail, Kingsville, Texas 78363 (Name and address of Manufacturer) 2. Manufactured for Uranerz Energy Corportaion 1701 East "E" Street (Name and address of Purchaser) 3. Location of installation Unknown 4. Type Horizontal____________1335 N/A (Name and address) 70050 ________ N/A 2016 (Horizontal or vertical, tank) (Manufacturer's serial number) (CRN) (Drawing number) (National Board number) (Year built) 5. ASME Code, Section VIII, Division 1 2013 EditionN/A N/A 6. Shell SA-240 304L [Edition and Addenda, if applicable (date)] (Code Case numbers) 25" NONE 75" [Special service per UG-120(d)] 8'_________________________________ (Material spec number, grade) (Nominal thickness) (Corr allow.)(Inner diameter)[Length (overall)] Body Flanges on Shells No.Type ID OD Flange Thk Min Hub Thk Material How Attached Location Bolting Num & Size Bolting Material Washer (OD, ID, thk)Washer Material 7 Seams 1 None 70% N/A N/A N/A None N/A 0 [Long (welded, dbl., sngl, lap, butt)) [R. T (spol or full)) (Etf.%) (HT(emp) (Time.hr) [Girth (welded, dbJ, sngJ, lap, butt)) [R T (spol (EH,%) (No of courses) or full)] 8 Heads: (a) Material SA-240 304L 1/4" Tvp.4 Conn. 55% (Spec no., grade) (b) Material SA-240 304L 1/4" Typ.4 Conn. 55% (Spec no., grade) Location (Top, Bottom, Ends) Minimum Thickness Corrosion Allowance Crown Radius Knuckle Radius Elliptical Ratio Conical Apex Angle Hemispherical Radius Flat Diameter Side To Pressure (Convex or Concave) (a)End .148”NONE 75"4.5"CONCAVE (b)End .148" NONE 75"4.5"CONCAVE Body Flanges on Heads Location Type ID OD Flange Thk Min Hub Thk Material How Attached Bolting Num & Size Bolting Material Washer (OD, ID, thk)Washer Material (a) (b) 9. MAWP 15 at max. temp. 200F 200F (Internal) Min. design metal temp. -20 F (External) (Internal) (External) at 15 . Hydro., pnethr of Gombr test pressure 20 PS I Proof test NONE 10. Nozzles, inspection, and safety valve openings: Purpose (Inlet, Outlet, Drain, etc.)No Diameter or Size Type Material Nozzle Flange Nozzle Thickness Nom. Corr. Reinforcement Material Attachment Details Nozzle Flange Location (Insp. Open.) Manway/Cvr 18 PIPE SA-240 304L 150#0.562 0"INTEGRAL 16.1 I N/A Shell inlet/outlet 3.5 PIPE SA-240 304L 150#0.216 0"INTEGRAL 16.1 I N/A Shell Vent 2"RFWN SA-105 150#B16.11 0"INTEGRAL 16.1 C N/A Shell Relief 4"RFWN SA-105 150#B16.11 0"INTEGRAL 16.1 C N/A Shell Sump 8.625 PIPE SA-240 304L N/A 0.322 0"INTEGRAL 16.1 I N/A Shell 11. Supports: Skirt N/A Lugs N/A (Yes or no)(Number) Legs N/A Other FRAME (Number)(Describe) Attached SHELL PAD WELDED (Where and how) 12 Remarks: Manufacturer's Partial Data Reports properly identified and signed by Commissioned Inspectors have been furnished for the following items of the report. (Name of part, item number, Manufacturer's name and identifying stamp) Inner Girth Seams Double Butt Welded, Impact Test Exempt Per UG-20 (F). UCS-66 (b), not for corrosive service CEI® DesignDocs 2014 - U1A Rev. 4 FORM U-'IA (Back) CERTIFICATE OF SHOP / FIELD COMPLIANCE We certify that the statements made in this report are correct and that all details of design, material, construction, and workmanship of this vessel conform to the ASME BOILER AND PRESSURE VESSEL CODE, Section VIII, Division 1. "U" Certificate of Authorization Number 28981______ expires 6/5/2017 Date 2/23/2016 Co. name Proco. Inc. (Manufacturer) Signed ative)(Repr CERTIFICATE OF SHOP / FIELD INSPECTION Vessel constructed by Proco. Inc. at 700 Proco Trail, Kingsville, Texas 78363 I, the undersigned, holding a valid commission issued by the National Board of Boiler and Pressure Vessel Inspectors and employed by One CIS Insurance Co., of Lvnn MA have Inspected the component described in this Manufacturer's Data Report on 2/23/2016 , and state that, to the best of my knowledge and belief, the Manufacturer has constructed this pressure vessel in accordance with ASME BOILER AND PRESSURE VESSEL CODE, Section VIII, Division 1. By signing this certificate neither the Inspector nor his/her employer makes any warranty, expressed or implied, concerning the pressure vessel described in this Manufacturer's Data Report. Furthermore, neither the Inspector nor his/her employer shall be liable in any manner for any personal injury or property damage or a loss of any kind arising from or connected with this inspection. Date 2/23/2016 Sianed ___ Commissions (Authorized Inspector) [National Board (inch endorsements)) FORM U-1A MANUFACTURER'S DATA REPORT FOR PRESSURE VESSELS {Alternate Form for Single Chamber, Completely Shop or Field Fabricated Vessels Only) As Required by the Provisions of the ASME Boiler and Pressure Vessel Code Rules, Section VIII, Division 1 1 Manufactured and certified by Proco Inc 700 Proco Trail, Kingsville, Texas 78363 (Name and address of Manufacturer) 2 Manufactured for Uranerz Energy Corportaion 1701 East "E" Street (Name and address of Purchaser) 3. Location of installation Unknown 4. Type Horizontal 1336 N/A (Name and address) 70050 _______ N/A 2016 (Horizontal or vertical, tank) (Manufacturer’s serial number) (CRN) (Drawing number) (National Board number) (Year built) 5. ASME Code, Section VIII, Division 1 2013 Edition N/AN/A 6. Shell SA-240 304L [Edition and Addenda, it applicable (date)] (Code Case numbers) .25" NONE 75" __________ [Special service per UG-120(d)] 8' (Material spec number, grade) (Nominal thickness) (Corr. allow.)(Inner diameter)[Length (overall)] Body Flanges on Shells No.Type ID OD Flange Thk Min Hub Thk Material How Attached Location Num & Size Bolting Bolting Material Washer (OD, ID, thk)Washer Material 7. Seams 1 None 70% N/A N/A N/A None N/A 0 (Long (welded, dbl, sngl, lap, bull)] (R T (spot or full)] (Eff,%) (H. T temp ) (Time, hr} [Girth (welded, dbt, sngL, tap, butt)] |R T. (spot (Eff,%) (No. of courses) or full}] 8. Heads: (a) Material SA-240 304L 1/4” Typ.4 Conn. 55% (Spec no, grade) (b) Material SA-240 304L 1/4" Typ.4 Conn. 55% (Spec, no., grade) Location (Top, Bottom, Ends) Minimum Thickness Corrosion Allowance Crown Radius Knuckle Radius Elliptical Ratio Conical Apex Angle Hemispherical Radius Flat Diameter Side To Pressure (Convex or Concave) (a)End .148“NONE 75"4.5"CONCAVE (b)End 148"NONE 75"4.5"CONCAVE Body Flanges on Heads Location Type ID OD Flange Thk Min Hub Thk Material How Attached Bolting Num & Size Bolting Material Washer (OD, ID, thk)Washer Material (a) (b) 9 MAWP 15 at max. temp. 200F 200F (Internal) Min. design metal temp. -20 F (External) (Internal) (External) at 15 . Hydro., pneu- gf Gemb- test pressure 20 PSI Proof test NONE 10. Nozzles, inspection, and safety valve openings: Purpose (Inlet, Outlet, Drain, etc.)No.Diameter or Size Type Material Nozzle Flange Nozzle Thickness Norn Corr Reinforcement Material Attachment Details Nozzle Flange Location (Insp Open) Manway/Cvr 18 PIPE SA-240 304L 150# 0 562 0"INTEGRAL 16.1 I N/A Shell inlet/outlet 3.5 PIPE SA-240 304L 150#0 216 0”INTEGRAL 16.1 I N/A Shell Vent 2"RFWN SA-105 150#B16.11 0"INTEGRAL 16.1 C N/A Shell Relief 4"RFWN SA-105 150#B16.11 0”INTEGRAL 16.1 C N/A Shell Sump 8.625 PIPE SA-240 304 L N/A 0.322 0"INTEGRAL 16.1 I N/A Shell 11. Supports: Skirt N/A Lugs N/A (Yes or no)(Number) Legs N/A (Number) Other FRAME Attached SHELL PAD WELDED (Describe)(Where and how) 12. Remarks: Manufacturer's Partial Data Reports properly identified and signed by Commissioned Inspectors have been furnished for the following items of the report: (Name of part, item number, Manufacturer's name and identifying stamp) Inner Girth Seams Double Butt Welded. Impact Test Exempt Per UG-20 (F), UCS-66 (b), not for corrosive service CEI® DesignDocs 2014 - U1A Rev. 4 FORM U-1A (Back) CERTIFICATE OF SHOP / FIELD COMPLIANCE We certify that the statements made in this report are correct and that all details of design, material, construction, and workmanship of this vessel conform to the ASWIE BOILER AND PRESSURE VESSEL CODE, Section VIII, Division 1. "U" Certificate of Authorization Number 28981 expires 6/5/2017 . Date 2/23/2016________Co. name Proco, Inc.Signed (Manufacturer) cate or Autnorizatio Ou& (Represi;e^taw^) Vessel constructed by Proco, Inc. CERTIFICATE OF SHOP / FIELD INSPECTION at 700 Proco Trail, Kingsville. Texas 78363 l, the undersigned, holding a valid commission issued by the National Board of Boiler and Pressure Vessel Inspectors and employed by One CIS Insurance Co., of Lynn MA have inspected the component described in this Manufacturer's Data Report on 2/23/2016 , and state that, to the best of my knowledge and belief, the Manufacturer has constructed this pressure vessel in accordance:with ASME BOILER AND PRESSURE VESSEL CODE, Section VIII, Division 1. By signing this certificate neither the Inspector nor his/her employer makes any warranty, expressed or implied, concerning the pressure vessel described in this Manufacturer's Data Report. Furthermore, neither the Inspector nor his/her employer shall be liable in any manner for any personal injury or property damage or a loss of any kind arising from or connected with this inspection. Date 2/23/2016 Signed <-///^ _______________ Commissions1X (Authorized Inspector)[National'Board (incl. endorsements)] CERTIFICATE OF COMPLIANCE ISSUED BY PROCO INC. TO: Uranerz Energy Corportaion PURCHASER This certifies that the new PROCO tank identified below was designed, constructed ,tested and completed accordance with the Department of Transportation Motor Vehicle Cargo Tank Specifications No. 407/412 for cargo tankused for the transportaion of classified liquids. Vehicle TypePVT_______________ Capacity 2100_______________ Date Shipped 3/4/2016 Year Fabricated 2016 Proco Serial Number 1 3 3 5 _______ Manufactured by PROCO, Inc. at Kingsville Texas DEPARTMENT OF TRANSPORTATION ___________________DOT 407__________________ EQUIPMENT REQUIRED REQUIRED RATING PRESSURE RELIEF DEVICES PRESSURE ACTUATED TYPE NC FRANGIBLE TYPE NONE LADING DISCHARGE DEVICES TOP NONE BOTTOM NC PRESSURE UNLOADING FITTINGS NONE CLOSURES MANHOLES NC FILL OPENINGS NC DISCCHARGE OPENINGS NONE __________________DOT 412___________________ EQUIPMENT REQUIRED REQUIRED RATING PRESSURE RELIEF DEVICES PRESSURE ACTUATED TYPE NC FRANGIBLE TYPE NONE LADING DISCHARGE DEVICES TOP NONE BOTTOM NC PRESSURE UN LOADING FITTINGS NONE CLOSURES MANHOLES NC FILL OPENINGS NC DISCCHARGE OPENINGS NONE CERTIFICATION 0 Cargo Tank Complies to Specifications No 407/412 as shipped Certification Date 2/23/2012 Q Cargo tank Complies to Specifications No except items listed Certification Date _________Design Cerfitiiigifrigineer ITEMS NOT INSTALLED AT THE TIME OF SHIPMENT Above items installed Date By ______________________________________ From Authorized Signature Authorizechlnspector DOT REGISTRATION NO CT0083 CERTIFICATE OF COMPLIANCE ISSUED BY PROCO INC. TO: Uranerz Energy Corportaion PURCHASER This certifies that the new PROCO tank identified below was designed, constructed ,tested and completed accordance with the Department of Transportation Motor Vehicle Cargo Tank Specifications No. 407/412 for cargo tankused for the transportaion of classified liquids. DEPARTMENT OF TRANSPORTATION Vehicle TypePVT_______________ Capacity 2100_______________ Date Shipped 3/4/2016 Year Fabricated ^__2016___ Proco Serial Number 1 3 3 6 _______ Manufactured by PROCO, Inc. at Kingsville Texas ___________________DOT 407__________________ EQUIPMENT REQUIRED REQUIRED RATING PRESSURE RELIEF DEVICES PRESSURE ACTUATED TYPE NC FRANGIBLE TYPE NONE LADING DISCHARGE DEVICES TOP NONE BOTTOM NC PRESSURE UNLOADING FITTINGS NONE CLOSURES MANHOLES NC FILL OPENINGS NC DISCCHARGE OPENINGS NONE DOT 412 EQUIPMENT REQUIRED REQUIRED RATING PRESSURE RELIEF DEVICES PRESSURE ACTUATED TYPE NC FRANGIBLE TYPE NONE LADING DISCHARGE DEVICES TOP NONE BOTTOM NC PRESSURE UNLOADING FITTINGS NONE CLOSURES MANHOLES NC FILL OPENINGS NC DISCCHARGE OPENINGS NONE CERTIFICATION [xj Cargo Tank Complies to Specifications No 407/412 as shipped Certification Date 2/23/2012 Q Cargo tank Complies to Specifications No except items listed Certification Date Design Certifing Engineer cAuthorized Inspector ITEMS NOT INSTALLED AT THE TIME OF SHIPMENT Above items installed Date By ______________________________________ From Authorized Signature DOT REGISTRATION NO CT0083