DRC-2014-005281 - 0901a0688048e6d7

ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energytuels.com
September 8, 2014
Sent VIA OVERNIGHT DELIVERY DRC-2014-005281
Mr. Rusty Lundberg
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Re: Response to Utah Division of Radiation Control ("DRC") July 10, 2014 Radioactive Materials
License ("RML") UT 1900479, Amendment 7, Request for an update Environmental Protection
Manual ("EPM") for the White Mesa Mill
Dear Mr. Lundberg:
This letter responds to the above-named RML Amendment dated July 10, 2014, Section 11.9, which
required that Energy Fuels Resources (USA) Inc. ("EFRI") submit a revised EPM for the White
Mesa Mill within 60 days of RML approval.
For ease of review, this letter provides each of the requirements specified in Section 11.9 of the
revised RML verbatim, in italics, below, followed by EFRI's response.
The White Mesa Mill EPM is comprised of fifteen separate Standard Operating Procedures
("SOPs") or Plans, housed in one binder. Only those SOPs which require revision are attached to
this response letter. It is important to note that additional changes to correct typographical errors or
to update procedures are also included for completeness purposes only, and were not made to
respond to the RML Amendment. The changes are in redline text for your convenience.
RML Section 11.9 Requirements
11.9 The licensee shall submit a revised Environmental Protection Manual for the White Mesa Mill
within 60 days of license approval. The revised Environmental Protection Manual shall include 2
additional air monitoring stations and a revised soil sampling program. The licensee shall also
analyze whether a revised vegetation sampling program is appropriate. In addition, air particulate
sample analysis will include Thorium 232, and every air monitoring station will also monitor for
radon (Rn222) and gamma detection devices on a quarterly basis. Implementation of the revised
environmental monitoring program shall be completed 90 days after Director approval of the revised
Environmental Protection Manual unless another deadline is approved by the Director.
[Applicable UDRC Amendment: 7]
Letter to Rusty Lundberg
September 8, 2014
Page 2 of 4
RML Requirement
The licensee shall submit a revised Environmental Protection Manual for the White Mesa Mill within
60 days of license approval.
EFRI Response:
The attached, revised sections of the EPM have been submitted on or before September 8, 2014, which
is 60 days after July 10, 2014 RML approval.
RML Requirement
The revised Environmental Protection Manual shall include 2 additional air monitoring stations...
EFRI Response:
EPM Section 1.1 has been revised to include the addition of two additional air monitoring stations as
required (BHV-7 and BHV-8). The locations for these two stations were specified by DRC in
correspondence dated June 12, 2014. EFRI placed the stations as close to the DRC-specified locations
as possible. Attachment A in Section 1.1 shows the approximate locations of the two new monitoring
stations. The monitoring stations will be placed into service within 90 days after approval of the
attached EPM. A survey of the locations will be completed after the final placement of the monitoring
stations.
RML Requirement
The revised Environmental Protection Manual shall include ....a revised soil sampling program.
EFRI Response:
EPM Section 4.1 has been revised to include the collection of an additional 67 soil samples for the
analysis of radium-226 and uranium ("UNat"). The additional samples will be collected at a
frequency of every 500 feet along the northern Mill boundary and the north half of the eastern
boundary (in/adjacent to Sections 22, 27 and 34) and at a frequency of every 2500 feet for the
remainder of the perimeter boundary.
As reported in the SAERs, previous soil results from the BHV-1, BHV-5, and BHV-6 indicate no
impacts from Mill activities and the historic results are within expected analytical variation. The
current program is appropriate for assessing impacts from Mill activities because BHV-1, BHV-5, and
BHV-6 are on or within the property boundaries which represent the areas of potential impact from
Mill activities. Because the current sample locations are on or within the Mill boundaries, they will
indicate whether any contamination has left the property boundary.
2
Letter to Rusty Lundberg
September 8, 2014
Page 3 of 4
RML Requirement
The licensee shall also analyze whether a revised vegetation sampling program is appropriate.
EFRI Response:
EFRI has been collecting vegetation samples, northeast, (near BHV-1) northwest (1/2 mile west of
BHV-1) and southwest (west of BHV-4 and south of the tailings cells) of the Mill operations since
1981. The northeast sample is on the Mill northern boundary, the northwest sample is on the Mill
property line and the southwest sample is collected west of BHV-4 and south of the tailings cells,
outside of the plant process area. The vegetation samples are collected three times per year; early
spring, late spring and late fall and are analyzed for radium-226 and lead-210.
As reported in the Semi-Annual Effluent Reports ("SAERs"), previous vegetation results indicate no
impacts from Mill activities, and the historic results are within expected analytical variation. The
current program is appropriate for assessing impacts from Mill activities because the locations
currently sampled are on the property boundaries or just outside of the property boundaries which
represent the areas of potential impact from Mill activities. Because the current sample locations are
on or within the Mill boundaries, they will indicate whether any contamination has left the property
boundary.
As previously stated the current vegetation sampling program is appropriate for the assessment of Mill
activities.
RML Requirement
In addition, air particulate sample analysis will include Thorium 232
EFRI Response:
EPM Section 1.1 has been revised to include the analysis of Thorium 232 on the particulate filters.
The Thorium 232 analyses will be reported starting with the third quarter 2014 samples.
RML Requirement
and every air monitoring station will also monitor for radon (Rn222).... on a quarterly basis.
EFRI Response:
EPM section 1.2 has been revised to include radon monitoring at the two new particulate monitoring
stations specified in the RML amendment. The data will be reported in the SAER. The data will be
included in the first regularly scheduled SAER following Director approval of the revised EPM.
3
Letter to Rusty Lundberg
September 8, 2014
Page 4 of 4
RML Requirement
and every air monitoring station will also monitor for gamma detection devices on a quarterly
basis.
EFRI Response:
Gamma monitoring has been conducted at the particulate air monitoring stations BHV-1 through
BHV-5 since 1981. Gamma monitoring has been conducted at BHV-6 since the placement of the
station in 2002. The gamma monitoring data are included in the routine SAERs.
EPM Section 4.3 has been revised to include gamma monitoring at the two new particulate monitoring
stations specified in the RML amendment.
Please contact me if you have any questions or require any further information.
Yours very/truly,
Kathy Weinel
Quality Assurance Manager
cc: Scott Bakken
Frank Filas
David C. Frydenlund
Dan Hillsten
Harold R. Roberts
David E. Turk
4
REDLINE
White Mesa Mill - Standard Operating Procedures
Book#l 1, Environmental Protection Manual, Section El
Date: 03^08/14 Revision: EFR-45
Page 1 of 67
AIR MONITORING - PARTICULATE RADIONUCLIDES
PART I AIR MONITORING PLAN
1.0 PARTICULATE RADIONUCLIDE AIR MONITORING
Air samples for monitoring particulate radionuclides are taken at the following four
locations: (See Attachment A)
BHV-1 Northeast of the Mill at the meteorological station.
BHV-2 Approximately 2.5 miles north of the Mill.
BHV-4 Approximately 400 yards south of Cell No. 4.
BHV-5 Approximately 100 yards south of the intersection of Highway 191 and the
Mill access road.
BHV-6 Approximately 0.5 miles south of BHV-5 along Highway 191.
BHV-7 Approximately 0.8 miles south of BHV-1 along Highway 191.
BHV-8 Approximately 0.6 miles west of BHV-1.
Air samples are collected on a weekly basis. A composite of 13 weekly samples from
each of the above locations is prepared to form a quarterly sample for each location.
2.0 QUALITY ASSURANCE
Quality assurance of the samples is met by collecting samples in accordance with the
conditions and guidelines set forth in this SOP (Section 6.0).
Quality assurance of the analytical results is based on the contract laboratory's quality
controls such as blanks, duplicates, and standard percent recovery. The laboratory will
also follow U.S. EPA Guide SW-846 and U.S. NRC Regulatory Guides 4.14 and 4.15
when analyzing the air filter samples. The laboratory is committed to meet the LLD
values for radionuclides listed in these guidance documents, and will perform re-runs on
all samples not meeting these limits.
3.0 ANALYTICAL REQUIREMENTS
Each quarterly sample will be analyzed for U-natNat, Ra-226, Th-230, afrd-Pb-210 and
Th-232. Results will be expressed in picocuries per milliliter (pCi/mL).
PART II STANDARD OPERATING PROCEDURES
1.0 EQUIPMENT
The equipment used in monitoring levels of particulate radionuclides consists of high
volume air samplers equipped with mass flow controllers and vacuum switch controlled
timers. The samplers are capable of collecting air through the sample filter at a
White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 1.1
Date: 03/4408/14 Revision: EFR-45
Page 2 of 67
volumetric flow rate of approximately 40 standard cubic feet per minute (scfm). The
mass flow controller varies the actual air flow rate as dictated by changing temperature,
filter loading, and barometric pressure to maintain a constant standard air flow rate. The
actual rate is read directly from the analog gauge located on the front panel. The timer is
turned off when no vacuum exists in the system, i.e., when the motor/blower assembly is
disconnected or otherwise malfunctions.
Particulates are trapped on an 8 x 10-inch glass micro fiber filter such as one of the
following, or equivalent:
1. Whatman EPM 1000
2. Whatman EPM 2000
3. Schliecher & Schuell #1 HV.
2.0 MONITORING METHODOLOGY
The air samplers are mounted on towers approximately 2 meters above ground plane.
The samplers run continuously except for calibration, mechanical or electrical failure, and
maintenance down time. Target flow rate will be 36 scfm.
Air filters are replaced weekly due to particulate loadings. Maximum filter use duration
will be weekly unless weather conditions prohibit safe access to one or more of the air
monitoring station locations.
Each filter is stamped by the manufacturer with a unique number. The blank filters are
weighed to the nearest 0.0001 gram using a Sartorius Model 2432 analytical balance or
equivalent. The filters are kept in manila folders inside resealable plastic bags for support
during transportation to the site. The tare weight is then recorded on each filter folder
along with the location, filter number, start date, and start time. This information is then
input into an analytical data file on the computer. When the sampled filters are collected
in the field, the stop dates and times are entered on the folder. On return from the field,
the filters are again weighed and the gross weights are recorded on the folders. The
weights, stop dates, and stop times are then recorded into the analytical data file that is
printed off and sent to the contract laboratory.
Samples are collected continuously for approximately one week. The "loaded" filters are
removed from the shut down samplers, folded, and placed in the folders in the plastic
bags. If any part of the filter remains on the seal gasket, it is removed and added to the
folder. The new filters are removed from their folders and placed on the vacuum head
with the filter holder frame tightened enough to seal, but not tight enough to rupture the
filters. The samplers are then turned on.
Each station's filters are composited on a quarterly basis (13 weeks) by the environmental
staff. The samples are forwarded, along with an analytical sheet and Chain of Custody
(COC) form (provided by the contract laboratory), to the contract laboratory in sealed
plastic bags.
White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 1.1
Date: 03/4408/14 Revision: EFR-45
Page 3 of 67
3.0 CALIBRATION
3.1 Orifice Plate
The orifice plates shall be calibrated every year as recommended by the EPA. A certified
calibration laboratory that will use the EPA or an EPA-approved method will do the
calibration. Calibration records are kept in the environmental files.
3.2 Sampler
Calibration of the equipment occurs during the first Monday of each month. If a non-
scheduled motor replacement is necessary, the sampler is re-calibrated.
An orifice plate assembly and U-tube manometer are used for monthly calibrations.
The sampler flow rate is regulated to a standard air volume that is recorded on the field
calibration sheet using 20°C. (298 K) and 29.2 inches (760 mm) of mercury as standard
conditions. The top portion of the Monthly Calibration and Weekly Flow Check
Worksheet (Attachment C) is completed for each air sampling station and retained in the
files.
The monthly calibration task involves the following:
1. Before visiting each monitoring location, the air temperature and barometric
pressure are recorded.
2. The motors are replaced as required. The replacement motors are prepared at the
Mill office.
3. A filter is placed within the orifice plate, and the orifice plate is secured on top of
the vacuum head.
4. The orifice plate is connected to the U-tube manometer and the initial inches H20
is recorded and a flow rate calculated using the current field temperature and
pressure.
5. The control screw is adjusted as necessary to advance or slow the vacuum motor
to reach the desired flow rate. The final flow rate must be at least 32 scfm on the
analog meter and reach 75% onstream time for the quarter to meet the required
LLD for the radionuclide parameters.
4.0 CALCULATIONS
Using inches of water from the U-tube, refer to the following subsections to perform the
calculation of flow rate. Section 4.1 provides the equation used to compute the flow rate
at field conditions, and (the "actual" flow rate [Qa]), in cubic meters per minute. Actual
flow rate must be corrected to standard flow rate (Qs) using the flow rate equation in
Section 4.2. The standard flow rate is then converted to standard cubic feet with the
conversion equation in Section 4.3.
4.1 Orifice Equation
Using the inches of water
White Mesa Mill - Standard Operating Procedures
Book#l 1, Environmental Protection Manual, Section 1.1
Date: 03^408/14 Revision: EFR-45
Page 4 of 67
measurement, determined from the U-tube, the following equation is used to calculate the
flow rate at field conditions:
Qa = \lm< AH i.
Where:
Qa = Actual flow rate at field conditions (nrVmin)
m = Slope value from Qa portion of orifice calibration
AH = Manometer reading (in. H20)
Ta = Actual temperature (273 + °C = K) [from the meteorological station data
(temperature readings) that are downloaded weekly]
Pa = Actual atmospheric pressure (mrnHg) [from the meteorological station data
(barometric pressure readings) that are downloaded weekly]
b = Intercept value from Qa portion of orifice calibration
The constants m and b in the above equation are provided by the calibration laboratory
for each specific calibrated orifice (Attachment D). Each orifice will have unique
performance properties that relate to design; those measured performance properties are
incorporated into the flow equation as specific constants. The flow equation
demonstrates the relationship between measured vacuum pressure in inches of water to
actual flow rate utilizing this device.
4.2 Standard Conditions Flow Rate Equation
The flow rate at standard conditions is calculated by adjusting the field condition flow
rate, calculated above, by the following equation:
f r, \
\ sJ\ aJ
Where:
Qs = Standard flow rate at standard conditions (m3/min)
Qa = Actual flow rate at field conditions (m3/min)
Ta = Actual temperature (273 + °C = K)
Pa = Actual atmospheric pressure (mrnHg)
Ts = Standard temperature = 298 K
Ps = Standard atmospheric pressure = 760 mrnHg
White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 1.1
Date: 03/4408/14 Revision: EFR-45
Page 5 of 67
4.3 Correction Equation
To convert the standard flowrate, from cubic meters per minute to standard cubic feet per
minute, use the following equation:
The records are kept on the filter folders and the field worksheets, which are retained in
the environmental files in the environmental office and are also entered into the analytical
data file on the computer after the data have been reviewed. The following information
will be entered into the computer data file (see Attachment E):
• Filter number
. Start date
• Stop date
• Start time
• Stop time
• Starting manometer reading (AH) (in. H2O)
• Stopping manometer reading (AH) (in. H20)
• Weekly average temperature (Ta) (°C)
• Weekly average pressure (Pa) (mrnHg)
• Tare filter weight (g)
• Gross filter weight (g)
The following information will be calculated by the computer file (see Attachment E):
• Total time (min)
• Average manometer reading (AH) (in. H2O)
• Weekly average temperature (K)
• Actual flow rate (Qa) (m3/min)
• Standard flow rate (Qs) (m3/min)
• Standard flow rate (Qs) (ftVmin)
• Total standard volume (m )
• Net weight (mg)
• Loading (mg/m3)
• Percent onstream
6.0 QUALITY ASSURANCE
6.1 Installation and Removal of Filters
Field methods to assure quality of air sample collection include the following:
1. Inspection of all new filters for aberrations and discarding damaged ones.
2. Maintaining seals on equipment connections.
3. Careful installation and removal of filters, retaining all abraded filter media.
a(/'%J=35.315xG.!fen)
5.0 RECORD KEEPING
White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 1.1
Date: 02/4408/14 Revision: EFR-45
Page 6 of 67
4. Proper sequential handling of all filters.
5. Filters are inspected for fingerprint contamination by visual observation.
6.2 Sample Duration
Maintenance of sample duration is assured by:
1. Installation of a vacuum-actuated timer which operates the timer only when
the motor is running and pulling the minimum allowable vacuum.
2. Weekly monitoring of stations and inspecting wear on the motors and proper
change-out at appropriate intervals (monthly).
6.3 Sample Flow Rate
Quality assurance of each sampler's flow rate is accomplished by weekly readings of the
sampler's flow characteristics using a manometer. Sampler pressure drop readings are
measured on a weekly basis using a manometer and going through the monthly
calibration steps. This value, along with average weekly temperature and pressure values
from the site meteorological station, are used to determine weekly flow rate values.
Monthly checks of flow controller operation and documentation thereof also provide
quality assurance. Samplers are calibrated and checked at motor rotation intervals
(monthly).
6.4 Calculations
Calculations are checked on a random basis for inconsistencies, and such checks are
documented.
Upon retrieval of the data analytical sheet from the contract laboratory, the date of receipt
is noted, along with the date of transcription is noted on the sample station log sheet with
the transcriber's initials. The transcription of data is reviewed by another person in the
Environmental Department to minimize transposition of numerical values. Calculation
and data storage is by computer program.
6.5 Sampler Performance
A record of sampler operation time versus total possible duration time is maintained as a
flag against excessive equipment downtime. Sampler performance is reviewed monthly.
6.6 Quality Control Methodology
Blanks are weighed each week and submitted alongside the actual filters. The filters and
blanks are recorded on an analytical sheet which is sent to the vendor, and this sheet is
returned with the results.
BHV-2
— 1 i
V? BHV-8 BHV-1
6 — L
I
BHV-7
; >
BHV-5
BHV-6 ' BHV-4
Actual Location of BHV-3
is 34,500'Feet Due Wes
Energy Fuels Resources (USA) Inc. r
*v
c1 J 91
Tentative location based on DRC
correspondence dated June 12, 2014.
Final locatons will be surveyed after
installation. Installation will be performed
after DRC approval of The Environmenta
Protection Manual.
N
1 IN = 6 000 F r
0.5 1.5
Miles
Legend
* Existing Air Monitoring Station
<D> Tentative Air Monitoring Station
Canyon Rim
Drainage
Road
|m|Property Boundary
I iTailinas Cell
C^Township gncj Range
I I Section
Pond
Coordinate System: NAD
1983 StatePlane Utah
South FIPS 4303 Feet
er ENERGYFUELS
REVISIONS
By
Project: WHITE MESA MILL
County: San Juan State Utah
Location
ATTACHMENT A
PARTICULATE MONITORING STATIONS
Author mhenington Date 8/22/2014 Drafted By mhenington
IJ\BORATORILS
iiiWWj Mi IU r-yt
PLEASE PRINT (Provide as much information as possible.)
Page. of
Company Name: Project Name, PWS, Permit, Etc. Sample Origin
State:
EPA/State Compliance:
Yes • No •
Report Mail Address: Contact Name: Phone/Fax: Email: Sampler: (Please Print)
Invoice Address: Invoice Contact & Phone: Purchase Order: Quote/Bottle Order:
Special Report/Formats:
• DW
• POTW/WWTP
• State:
• Other:
• EDD/EDT(Electronic Data)
Format:
• LEVEL IV
• NELAC
Q >-OJ
CO cn^
{ycogSifc
o><8 s?|
4» CL oj O Q •
co
CD
H Z at S x o
<
SAMPLE IDENTIFICATION
(Name, Location, Interval, etc.)
Collection
Date
Collection
Time MATRIX
R
U
S
H
Contact ELI prior to
RUSH sample submittal
for charges and
scheduling - See
Instruction Page
Comments:
Shipped by:
Cooler tO(%):
Receipt Tamp
On lc«: Y N
Custody Seal
On Bottle
On Cooler
Intact
Signature
Match
Custody
Record
MUST be
Signed
"Relinquished by (print). Date/Time: Signature:
Relinquished by (print): Date/Time. Signature:
jample Disposal: Return to Client: Lab Disposal:.
Received by (pnnt)' Datefilme: Signature:
Received by (pnnt)' Date/Time:
TJeceTve^ByTaTOraToTyT^^^^^^^aleTTlmQT
Signature:
Signature:
In certain circumstances, samples submitted to Energy Laboratories, Inc. may be subcontracted to other certified laboratories in order to complete the analysis requested.
This serves as notice of this possibility. All sub-co t data will be clearly notated on your analytical report.
Visit our web site at www.eneravlab.com for additloi, ,ormation, downloadable fee schedule, forms, and links.
ATTACHMENT C
MONTHLY CALIBRATION AND WEEKLY FLOW CHECK WORKSHEET
Site:
Date of Calibration:
Temperature (Ta):_ °C/ K
Orifice Plate No.: _
Calibrator's Name:
Pressure (Pa): .mrnHg (25.4 x inches)
Monthly Calibration for the Month of:
(i)
Initial
Manometer
(AH) (in. H2Q)
Qa^
Actual Flow
(m3/min)
Standard Flow
(m3/min)
QS
W | Adjusted
Standard Flow Manometer(5)
(ftVmin) (in. H2Q)
Adjusted
Qs ^
(ft3/min)
Weekly Flow Check
Start Start
Time Week Filter Number Date
Starting "T
Manometer Stop
(in. H2Q) Date
Stop
Time
Stopping
Manometer
(in. H20)
Orifice Information
Orifice S/N
Qa Slope (m)
Qa Intercept (b)
Calibration Date
Orifice Notes: Information to left found on the
latest certification worksheet delivered with a
newly certified orifice. Orifice should be
calibrated annually. Slope and intercept values
should come from Qa portion of the calibration.
Monthly Calculations:
1) Connect the U-tube manometer to the orifice plate then read and record the initial pressure drop.
2) Use the manometer reading to calculate the actual flow rate using the Qa equation below, which
uses actual temperature and pressure as well as specific orifice values filled out above.
3) Convert actual flow rate to standard flow rate using the Qs equation below.
4) Convert the standard flow rate from (m3/min) to (ft3/min).
5) If necessary, adjust the control screw so that the final flow rate is between 32-40 ft /min.
(2) Qa =\lm-AH
( O V T \
(3) Qs = Qa
-b
(4) a(*/4)=35.315x0>%,n)
Where:
Qa = Actual flow rate at field conditions (m3/min)
Qs = Standard flow rate at standard conditions (m3/min)
m = Slope value from Qa portion of orifice calibration
b = Intercept value from Qa portion of orifice calibration
AH = Manometer reading (in. H20)
Ta = Actual temperature (273 + °C = K)
Pa = Actual atmospheric pressure (mrnHg)
Ts = Standard temperature = 298 K
Ps = Standard atmospheric pressure = 760 mrnHg
Environmenta
ATTACHMENT D
TISCH {k
TISCH ENVIRONMENTAL, INC.
145 SOUTH MIAMI AVE
VILLAGE OF CLEVES, OH
45002
513.467.9000
877.263.7610 TOLL FREE
513.467.9009 FAX
ORIFICE TRANSFER STANDARD CERTIFICATION WORKSHEET TE-5025A
Date - Jul 10, 2014 Rootsmeter S/N 0438320 Ta (K) - 296
Operator Tisch Orifice I.D. - 8091779 Pa (mm) - 754.38
PLATE
OR
Run #
VOLUME
START
(m3)
VOLUME
STOP
(m3)
DIFF
VOLUME
(m3)
DIFF
TIME
(min)
METER
DIFF
Hg
(mm)
ORFICE
DIFF
H20
(in.)
1
2
3
4
5
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1
1
1
1
1
00
00
00
00
00
1.3890
0.9870
8770
8370
6900
0
0
0
3 . 3
6.4
8 .1
9.0
12 . 9
2 .00
4 .00
5 .00
5.50
8 .00
DATA TABULATION
Vstd
(x axis)
Qstd
(y axis)
Va
(x axis)
Qa
(y axis)
0.9949
0.9907
0,9885
0.9874
0.9822
0. 7163
1. 0038
1.1271
1.1797
1.4235
1
1
2
2
2
4137
9993
2353
3444
8275
0.9956
0.9914
0.9892
0.9881
0.9829
0.7168
1.0045
1.1279
1.1805
1.4245
8859
2528
4007
4690
7717
Qstd slope (m) = 1.99700
intercept (b) = -0.01294
coefficient (r) = 0.99992
Qa slope (m) = 1.25049
intercept (b) = -0.00811
coefficient (r) = 0.99992
y axis = SQRT[H20(Pa/760) (298/Ta)] y axis = SQRT[H20(Ta/Pa)]
CALCULATIONS
Vstd = Diff. Vol[(Pa-Diff, Hg)/760](298/Ta)
Qstd = Vstd/Time
Va = Diff Vol [(Pa-Diff Hg)/Pa]
Qa = Va/Time
For subsequent flow rate calculations:
Qstd = l/m{[SQRT(H20(Pa/760)(298/Ta))]- b}
Qa - l/m{[SQRT H20(Ta/Pa)]- b}
ATTACHMENT D
TISCH i O
Environmenta
TISCH ENVIRONMENTAL, INC.
145 SOUTH MIAMI AVE
VILLAGE OF CLEVES, OH
45002
513.467.9000
877.263.7610 TOLL FREE
513.467.9009 FAX
ORIFICE TRANSFER STANDARD CERTIFICATION WORKSHEET TE-5025A
Date - Jul 21, 2014 Rootsmeter S/N 0438320 Ta (K) - 299
Operator Tisch Orifice I.D. - 5-76-02 Pa (mm) - 754.38
PLATE
OR
Run #
VOLUME
START
(m3)
VOLUME
STOP
(m3)
DIFF
VOLUME
(m3)
DIFF
TIME
(min)
METER
DIFF
Hg
(mm)
ORFICE
DIFF
H20
(in.)
1
2
3
4
5
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1
1
1
1
1
00
00
00
00
00
1.3950
0.9800
0.8780
0.8370
0.6860
3 . 2
6 . 4
8 .1
8 . 9
12 . 9
2 . 00
4 . 00
5 . 00
5 . 50
8.00
DATA TABULATION
Vstd
(x axis)
Qstd
(y axis)
Va
(x axis)
Qa
(y axis)
0.9851
0 . 9808
0.9786
0.9776
0.9723
0. 7061
1.0008
1.1146
1. 1680
1.4174
1.4066
1.9893
2.2241
2.3326
2.8132
0
0
0
0
0
9957
9914
9892
9882
9829
0.7138
1.0116
1.1266
1.1806
1.4328
0.8903
1.2591
1.4077
1.4765
1.7807
Qstd slope (m) = 1.98285
intercept (b) = 0.00883
coefficient (r) = 0.99986
Qa slope (m) = 1.24163
intercept (b) = 0.00559
coefficient (r) = 0.99986
y axis = SQRT[H20(Pa/760)(298/Ta)] y axis = SQRT[H20(Ta/Pa) ]
CALCULATIONS
Vstd = Diff. Vol[(Pa-Diff. Hg)/760](298/Ta)
Qstd = Vstd/Time
Va = Diff Vol [(Pa-Diff Hg)/Pa]
Qa = Va/Time
For subsequent flow rate calculations:
Qstd = l/m{[SQRT(H20(Pa/760)(298/Ta))]- b)
Qa = l/m{[SQRT H20(Ta/Pa)]- b}
-———•
BHV-1
Energey Fuels Resources - White Mesa Mill
Period: July 1, 2014 - September 30, 2014
Calibration Date: 7/10/2014
Calibration Slope & Intercept:
Orifice S/N: 8091779
m= 1.25049 b= -0.0081 Updated: 8/22/14
Week
#
Filter
Number
Start
Date
Stop
Date
Start
Time
Stop
Time
Total
rime
(min)
AH
Starting
Manometer
(in. HjO)
AH
Stopping
Manometer
(in. H20)
AH
Average
Manometer
(in. H,0)
Ta
WMy. Avj
Temp.
<°C)
Ta
WWty. Avg.
Temp.
(K)
Pa
WMy. Avg
Pressure
(mrnHg)
Qa
Act. Plow
(mVmin)
Qs
Std. Flow
(mVmin)
Qs
Std. Flow
(SCFM)
(ItVinin)
Total
Std.
Volume
(nr')
Tare
Weight
Gross
Weight
<g)
Net
Weight
Loading
(mg/m')
Percent
On stream
(%)
7130505 7/7/2014 7/14/2014 7278.3 17366.2 10087.9 4.0 4.0 4.0 19.0 292.2 621.03 1.10 32.48 9278.3
7123199 17366.2 27408.8 10042.6 3.5 3.6 3.6 20.0 293.2 621.03 1.04 0.87 30.56 8689.7 4.5221
44905_
4.5319
46.3 0.0050
9.8 0.0011
100.1
99.6
7129193 27408.8 37640.7 10231.9 4.0 3.5 3.8 20.0 293.2 621.03 1.07 0.89 31.40 9098.0 4.5172 4.5218 4.6 0.0005 101.5
7129187 37640.7 47869.5 10228.8 3.0 3.9 3.5 20.0 293.2 621.03 1.03 0.85 30.13 8726.1 4.5303 4.5360 5.7 0.0007 101.5
47869.5 57734 9864.5 3.5 4.0 3.8 20.0 293.2 621.03 1.07 0.89 8771.3 4.5295 4.5380 8.5 0.0010
57734 67754.2 10020.2 4.0 3.9 20.0 293.2 621.03 1.09 0.91 32.02 9085.1 4.5402 4.5464 6.2 0.0007
67754.2 77803.4 10049.2 3.6 3.9 20.0 293.2 621.03 1.07 0.89 31.40 8935.5 4.5359 4.5435 7.6 0.0009
99.4
99.7
77803.4 83387.6 5584.2 3.7 3.7 293.2 621.03 1.06 0.88 30.98 4.5536 4.5610 7.4 0.0015 55.4
83387.6 93412.4 10024.8 3.8 4.0 3.9 20.0 293.2 621.03 1.09 0.91 32.02 9089.3 4.5542 4.5605 6.3 0.0007 99.5
10 93412.4 103434.8 10022.4 4.0 4.0 4.0 20.0 293.2 621.03 0.92 9202.2 4.5613 4.6928 0.0143
11 103434.8 113555.1 10120.3 3.5 3.6 3.6 20.0 293.2 621.03 1.04 0.87 30.56 8757.0 4.5489 4.5543 5.4 0.0006 100.4
12 17921.6 27945.8 10024.2 3.6 3.7 20.0 293.2 621.03 1.06 0.88 31.19 8854.0 4.5355 4.5454 9.9 0.0011 99.4
13 27945.6 38066.3 10120.7 3.7 4 0 3.9 20.0 293.2 621.03 0.90 31.81 9117.6 4.5355 4.5454 9.9 0.001 I 100.4
Totals 126421.7 11.56 408.38 112503.2 59.168 0.0291
Averages 9724.7 19.9 621.03 1.07 0.89 8654.1 4.531 4.551 19.9 0.0022 96.5
Comments:
Insert weekly flow check values in yellow columns.
Blue column vnlues are calculated.
Green columns are calculated averages from the met station.
columns.
I White Mesa Mill - Standard Operating Procedures Date: 0408/14 Revision: EFR-32
Book #11, Environmental Protection Manual, Section 1.2 Page 1 of 3
AIR MONITORING -- RADON
1. RADON MONITORING PLAN
1.1 Locations and Frequency of Samples
Radon samples are taken at the following locations:
BHV-1
BHV-2
BHV-2A (Duplicate of BHV-2)
BHV-3 (Background location for use in assessment of background concentrations)
BHV-4
BHV-5
BHV-6
BHV-7
BHV-8
BHV-70 (Blank sample for use in assessment of effects due to sample shipment.
Previously numbered as BHV-7)
See Attachment A to Section 1.1 of this Environmental Protection Manual for the
locations of these monitoring stations.
Samples are collected on a quarterly basis using Radtrak® (Trac-Etch) Outdoor Air
Radon Detector, (Landauer Part Number DRNM) or equivalent. One or more than 1
Radtrak® (Trac-Etch) Outdoor Air Radon Detector will be placed at each of the locations
noted above (except BHV-70). The number of detectors to be placed at each location
shall be as determined by the Radiation Aafety Officer ("RSO"). If multiple Radtrak®
detectors are placed at one location, the numeric average of the results for that location
will be calculated and reported as the radon value for quarter.
1.2 Quality Assurance
Quality assurance of the samples is met by collecting samples in accordance with the
conditions and guidelines set forth in Section 2 of this procedure. In addition, the
following steps will be followed:
a) One duplicate sample or set of duplicate samples will be collected each
quarter by placing twe-samples at the same location as the routine sample(s), at
the same height as the routine sample(s), and as close together to the routine
sample(s) as reasonably achievable;
b) A field blank sample will be collected each quarter to assess any
concentrations resulting from shipment of the detectors;
White Mesa Mill - Standard Operating Procedures Date: 0408/14 Revision: EFR-32
Book #11, Environmental Protection Manual, Section 1.2 Page 2 of 3
c) Detector locations will be monitored periodically to ensure the detectors have
not been lost;
d) Detector shipments will be inspected to ensure that all detectors are present
when receiving or shipping detectors; and
e) Monitoring data will be reviewed for consistency and data transportation
issues/detections.
1.3 Analytical Requirements
Each quarterly sample will be analyzed for Radon-222. Results will be expressed in
pCi/L.
2. STANDARD OPERATING PROCEDURES
2.1 Equipment
Samples will be collected using the Radtrak® (Trac-Etch) Outdoor Air Radon Detector
(Landauer Part Number DRNM) or equivalent. The detectors will be returned to the
supplier/manufacturer for processing and analysis. Detectors are analyzed using the
"high sensitivity" methodology, which provides a lower limit of detection of 6.0 pCi/L-
days.
2.2 Monitoring Methodology
The following monitoring procedures will be followed:
a) Remove detector from package - The Radtrak® radon detectors are supplied
in aluminum bags which prevent radon exposure. Open the aluminum bag and
remove the clear plastic cup which has a Radtrak® detector fastened to the
bottom. Detectors, before, during or after exposure should not be in locations
which exceed a temperature of 160°F (70°C). There is no low temperature.
b) Fill in the enclosed Detector Log Sheet with the serial number on the detector
label. Also fill in the date installed and the location information in the
location/comments area.
c) Attach a field canister to a post or other location using the metal bracket with
the open mouth of the canister facing down. The canister may be placed at any
desired height (typically 3-6 feet) and preferably in a location minimizing animal
damage or tampering. Remove the clear acrylic retaining ring from the canister
White Mesa Mill - Standard Operating Procedures Date: 0408/14 Revision: EFR-33
Book #11, Environmental Protection Manual, Section 1.2 Page 3 of 3
by removing the wing nuts. Install the assembled cup inside the canister and
replace the retaining ring and wing nuts in order to hold the cup in place.
d) Leave the detectors undisturbed for the duration of the three month
monitoring period.
e) At the end of the monitoring period, remove the Radtrak® detector from the
plastic cup. Peel off the gold seal provided with the shipment and cover all the
holes on the top of the detector. This stops the monitoring period. Record the
ending date on the Detector Log Sheet.
f) After all of the detectors have been collected and sealed, but prior to final
packaging and shipment, open a new detector and immediately cover all the holes
on the top of the detector with one of the gold seals provided with the shipment.
Label this detector as BHV-^-TO on the Detector Log Sheet. Use the same
exposure time/days for BHV-T70 as the seven-eight sample detectors when listing
BHV-7-70 on the Detector Log Sheet.
g) Return the seven detectors (six sample detectors and one blank detector) along
with a copy of the Detector Log Sheet using the laboratory provided label for
shipment back to the supplying organization.
3. RECORD KEEPING
Data maintained in record form for environmental radon is:
a) Sample period;
b) Sample location; and
c) Radon levels.
White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 4.1
Date: 0408/14 Revision: EFR-34
Page 1 of 4
SURFACE SOIL MONITORING
PART I SOIL MONITORING PLAN
1.0 SOIL MONITORING
Surface soils are sampled at the fi-ve-eight air monitoring sites and at spaced intervals around
the perimeter boundary of the Mill property. The sampling locations^ are shown in Figure 1-,
are as follows: BHV 1, BHV 2, BHV 3, BHV 1, BHV 5 and BHV 6. Soil samples from the
northern Mill boundary and the north half of the eastern boundary (adjacent to Sections 22,
27 and 34) are collected approximately every 1000 feet. The remainder of the perimeter
boundary soil samples are collected every 2500 feet. Soil samples are taken once per year
during August or as soon as possible thereafter, but no later than September 30 of the year.
In addition, a soil sample could be taken from Westwater Creek, in the place of a water
sample. However, a sediment (soil) sample would only be taken at Westwater Creek if water
was not available. In the event that a soil sample is collected in place of a water sample for
Westwater Creek, the sample should be analyzed for the same parameters as those called for
in this SOP (Radium-226 and U-nat). Refer to SOP No. PBL-EP-3 for details regarding
collection of a water sample from Westwater Creek.
2.0 SAMPLING AND ANALYTICAL QUALITY ASSURANCE
The sample bags are marked for location identification and are submitted to the analytical
laboratory accompanied by Chain-of-Custody forms. (Attachment A)
Analytical quality assurance for soil monitoring is based on the contract laboratory's quality
controls such as blanks, duplicates, and standard percentage recovery. The laboratory is
committed to meet the LLD values for radionuclides contained in U.S. NRC Regulatory
Guides 4.14 and 4.15 and will perform re-runs on all samples not meeting these limits, as per
EPA SW 846. Appropriate laboratory control and quality assurance data will be provided by
the contract laboratory, or equivalent, including LLD information.
3.0 ANALYTICAL REQUIREMENTS
All soil samples will be analyzed, on a dry basis for the following radionuclides: Ra-226 and
U-Nat. Analytical results will be reported in appropriate radiological units such as pico curies
per gram or micro curies per kilogram.
PART II SOIL MONITORING STANDARD OPERATING PROCEDURES
1.0 SURFACE SOIL SAMPLING
1.1 Equipment
I White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 4.1
Date: 0408/14 Revision: EFR-34
Page 2 of4
Equipment used for soil sampling is as follows:
1. Tape measure or measuring stick calibrated to 1 foot and to one centimeter.
2. Clean trowel or shovel.
3. Clean sample containers.
1.2 Soil Sampling Procedure
Soil samples are collected using a clean trowel or shovel to excavate a soil sample evenly
across a one square foot area at a depth of one centimeter. The one centimeter excavation
depth is maintained by using the tape measure or other suitable calibrated measuring stick.
As the soil is being collected, it is placed directly into the sample container. The sample
container is then identified with a label (see Section 2.1 below).
2.0 SAMPLING QUALITY ASSURANCE
2.1 Sample Duplicates
Soil sample duplicates will be collected at a frequency of 1 duplicate per 20 samples. The
duplicates will be submitted blind to the laboratory and will be named as follows:
N = Northern boundary
1 = Sequential number of the northern boundary sample
D = Duplicate of sample Nl
Duplicate precision will be discussed in the Semi-Annual Effluent Report. Duplicate
precision will be assessed as follows:
a) Relative Percent Difference.
RPDs will be calculated in comparisons of duplicate and original field sample results. Section
3.3 will apply when the RPD > 35%, unless the measured concentrations are less than 5 times the
required detection limit (Standard Methods, 1998) (EPA Contract Laboratory Program National
Functional Guidelines for Inorganic Data Review, February 1994. 9240.1-05-01. p. 25).
2.4 2 Sample Labeling
Each sample must be labeled and all sample labels must be filled out in ink and numbered.
The following information must be contained on the label:
NIP where:
I White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 4.1
Date: 0408/14 Revision: EFR-^4
Page 3 of 4
1. Project and facility.
2. Company name
3. Date and time of sample collection.
4. Sampler's initials.
5. Sample location.
6. Requested Analytical Parameters
2.2 Sample Chain-of-Custody
During sampling activities, traceability of the sample must be maintained upon sample
collection until the laboratory data is issued. Information on the custody, handling, transfer,
and shipment of the samples will be recorded on a Chain-of-Custody form (COC). The
sampler is responsible for filling out the COC form. The COC form will be signed by the
sampler when the sampler relinquishes the samples to anyone else. A COC form is to be
completed for each set of samples placed in a sample shipping container and is to include the
following:
1. Sampler's name.
2. Date and time of collection.
3. Sample location.
4. Sample type.
5. Analysis requested.
6. Signatures of persons releasing custody.
7. Signatures of persons accepting custody, dates, and times.
Copies of the COC forms and all custody documentation when received will be retained in
appropriate files at the Mill. The original COC form remains with the samples until disposal
of the samples.
2.3 Sample Handling and Shipping
Samples will be placed in shipping containers and transported to the contract laboratory.
COC forms will be placed inside a resealable bag and placed inside the sample shipping
White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 4.1
Date: 0408/14 Revision: EFR-34
Page 4 of 4
container.
2.4 Record Keeping
All soil sample data are retained in the files and when analytical results are available the
results are entered into a computer file and retained in the files. Laboratory analytical data
are stored in the soil files after the data has been entered on a computer file.
3.0 ANALYTICAL QUALITY ASSURANCE
3.1 Data Validation and Quality Control
Laboratory analyses will be reviewed by the technical staff and any identifiable anomalies in
results noted and investigated. Appropriate measures to confirm or disaffirm results will be
pursued, such as laboratory conversation, analytical sample rerun, or trend analysis.
3.2 Quality Assurance and Data Validation
The contract laboratory will prepare and retain a copy of all analytical and quality control
documentation. The laboratory will provide hard copy information in each data package
submitted in accordance with quality assurance objectives for the surface soil quality
assurance project plan that is: COC forms, cover sheets with comments, narratives, samples
analyzed, reporting limits and LLD values for analytes, and analytical results of quality
control samples. The data reduction and laboratory review will be documented, signed, and
dated by the analyst.
3.3 Corrective Action
Corrective action will be taken for any deficiencies or deviations noted in the procedures or
anomalous results, such as but not limited to additional sample collection, sample re-run,
laboratory inquires, or other actions as appropriate.
Corrective actions for duplicate deviations shall first determine if the deviation is indicative
of a systematic issue. If the deviation is limited in scope and nature, the QA Manager will:
1. Notify the laboratory,
a. Request the laboratory review all analytical results for transcription and calculation
errors, and
b. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.
l_AK(.)RA rc)Rll:S ,
Chain of Custody and Analytical Request Record Page of.
PLEASE PRINT, provide as much information as possible. Refer to corresponding notes on reverse side.
I Project Name, PWS #, Permit #, Etc.: Company Name:
Report Mail Address: Contact Name, Phone, Fax, E-mail: Sampler Name If other than Contact:
Invoice Address: Invoice Contact & Phone #: Purchase Order #: ELI Quote #:
Report Required For: POTW/WWTP •
Other
DW •
Special Report Formats - ELI must be notified prior to
sample submittal for the following:
NELAC • A2LAU Level IV •
Other
EDD/EDT • Format
SAMPLE IDENTIFICATION
(Name, Location, Interval, etc.)
Collection
Date
Collection
Time
c
£ si
O CD O
s > $ ^
w > 5 c > s « Q > P Q
U < "S >,
MATRIX
ALYSIS REQUESTED f Notify ELI prior to RUSH
sample submittal for additional
charges and scheduling
Comments:
Shipped by:
Cooler ID(s)
Receipt Temp
° C
Custody Seal Y N
Intact Y N
Signature Y N
Match
Lab ID
ILL
to
2-
03
10
Custody
Record
MUST be
Signed
ReHnqurshed by (print)-DataAunr Signature:
Relinquished by (print): Oata/Trme: Signatura:
Sample Disposal: Return to client: Lab Disposal:
Recatvod by (pnnt). Signature:
Rncntvad by (print): DaWTbna: Signature:
Sample Type:.
LABORATORY USE ONLY
# of fractions
|r -»rtaln circumstances, samples submitted to Energy Laboratories, Inc. may be ""^contracted to other certified laboratories In order to complete the analysis
This serves as notice of this possibility. All sub-c :t data will be clearly notatad on your analytical report
Visit our web site at www.energytob.com for aotiittonarmformation, downloadable fee schedule, forms, & links.
reqi'--ted.
09
BHV-2
BHV-1
BHV-
BHV-7
_ L
BHV-5 D
33 U 34
T37S
T38S BHV-4 BHV-6 Actual location of BHV-3
is 34!.500 feet due west
05 UJ
' Energy Fuels Resources (USA) Inc. •
I A k ,t~ * ft
191
tt
1 N = 6 )00 FT
11,250 15,000
=W Feet
3,750 7,500
Legend
Program
-fc 1,000 Feet
* 2,500 Feet
• Existing Air Monitoring Station
# Tentative Air Monitoring Station
1 'Property Boundary
Road
|_JTownship and Range Coordinate System: NAD
j I Section 1983 StatePlane Utah
South FIPS 4303 Feet
CF
m ENE
ENERGYFUELS
By:
Project: WHITE MESA MILL
County: San Juan State: Utah
Location:
FIGURE 1
SOIL MONITORING LOCATIONS
Author: mhenington Date: 9/5/2014 Drafted By: mhenington
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 4.3
Date: 4-2A-2Q8/14 Revision: EFR-23
Page 1 of 2
EXTERNAL GAMMA MONITORING PLAN
AND STANDARD OPERATING PROCEDURES
1. EXTERNAL GAMMA MONITORING PLAN
1.1 Locations and Frequency of Monitoring
External gamma measurements are taken over a quarterly interval for the twelve months of the
year at all BHV locations and selected areas around the mill site (see Attachment #1 for those
locations).
Quality assurance for external gamma measurements consists of:
a) Monitoring the container locations to ensure the Optically Stimulated Luminescence
doMineicrs (OSLs) s have not been lost:
b) Ensuring that all containers are present when receiving or shipping to Landauer; and
c) Reviewing Landauer data for consistency and data transportation.
1.3 Analytical Requirements
Values reported are in millirems per week average for the monitor period (supplied by Landauer)
along with a counting error term. The counting error term is calculated by:
[(sample 2 sigma) - (control mrem/week)] / (#weeks)
1.2 Quality Assurance
1.4 STANDARD OPERATING PROCEDURES
1.5 Equipment
External gamma is monitored at the ambient air sampling sites and other selected areas around
the mill site, using the spherical container TLDOSL badges from Landauer, Inc., or the
equivalent.
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 4.3
Date: 43/4508/14 Revision: EFR-23
Page 2 of 2
1.6 Monitoring Methodology
a) The containers-? each containing five TLD chips, are mounted approximately one
meter above ground plane at each site with one container per site.
b) The containers loaded with TLDs OSLs are received the first of each quarter from
Landauer and exchanged with those in the field.
c) A background TLD OSL is stored in the Administration Vault as a transportation
control.
d) The TLDs OSLs are returned to Landauer for processing.
1.7 Record Keeping
Data maintained in record form for external gamma is:
a) Sample period;
b) Sample location; and
c) External gamma levels for total radiation.
ATTACHMENT 1
OSL GAMMA ENVIRONMENTAL MONITORING LOCATIONS
WHITE MESA MILL
Badge Number Location of Monitor
Control Administration Vault
1 V2CK Control Room
BHV-6
Ore Stor. - Barrel Area
Vanadium Precip.Area
Yellowcake Drying Area
Leach
SAG Mill Control Room
Yellowcake Precip.
Central Control Room
10 Trommel Screen (ore pad)
11 North East Corner Ore Pad
12 Met. Lab
13 Filter Press Room
14 BHV-1
15 BHV-2
16 BHV-3
17 BHV-4
18 BHV-5
19 SAG Mill
20 Tails
21 CCD
22 North SX
23 Administration Building
24 Admin Parking Lot
25 Yellowcake Packaging
26 Yellowcake Storage
27 Bucking Room
28 Mill Lunch Room
29 South SX
30 Mtce. Super.'s Office
31 Ore Feed Grizzly
32 Scalehouse
33 Sample Plant (OBS)
34 Front Gate
45 AF - Barrel Dump Station
I ATTACHMENT 1
OSL GAMMA ENVIRONMENTAL MONITORING LOCATIONS
WHITE MESA MILL
Badge Number Location of Monitor
46 AF Circuit - South
47 AF Circuit - North
51 North Control # 1
52 North Control # 2
53 CaF2 Barrel Dump Station - Operator Station
64
70
71
KF Barrel Dump Station
BHV-7
BHV-8