Independent Audit License Condition Cotter Corporation by liaoqinmei

VIEWS: 8 PAGES: 35

									F I N A L   R E P O R T




2009
Independent Audit
License Condition 10.3.2


Cotter Corporation
Cañon City Milling Facility
Cañon City, Colorado




26 May 2009


Reid, Miller, & Associates, LLC
P.O. Box 1290
Muskogee, OK 74402


Audit Number CC0409-01
                                                    Table of Contents
Table of Contents................................................................................................................. i

Introduction......................................................................................................................... 1

Purpose................................................................................................................................ 1

Scope................................................................................................................................... 1

Participants and Schedule ................................................................................................... 2

Method ................................................................................................................................ 3

Terms .................................................................................................................................. 4

Findings............................................................................................................................... 5

Observations ....................................................................................................................... 5

Comments and Recommendations...................................................................................... 7

Conclusion .......................................................................................................................... 9

Attachment – Audit Plans ................................................................................................. 11




Cotter Corporation Canon City Milling Facility
2009 Independent Audit                                              i                                                    26 May 2009
Introduction
        The Cotter Corporation Cañon City Milling Facility (CCMF) is a uranium mill
        located approximately 1.5 miles south of Cañon City, CO. The CCMF was
        originally licensed to operate in 1958 by the Atomic Energy Commission. The
        State of Colorado assumed the licensing responsibilities in 1968. The CCMF
        conducts activities in accordance with State of Colorado, Department of Public
        Health and Environment, Radioactive Materials License Number 369-01
        (License). The License addresses management of the site with regard to worker
        safety, impacts to the environment, and decommissioning and reclamation.

        The predominant activity at the mill has been processing uranium ore to create a
        purified uranium ore concentrate (e.g. yellowcake). The mill operated
        continuously from 1958 until 1979, and then intermittently until 2006.
        Subsequently, activities at the site include those related to stand-down,
        stabilization, decommissioning, and remediation. Cotter is currently evaluating
        the feasibility of starting a reengineered mill.

Purpose
        The License includes several conditions (i.e. requirements) for periodic inspection
        or audit of activities. This report describes the conduct and results of an audit of
        activities at the CCMF with respect to requirements of the License.

Scope
        The subject audit was completed pursuant to the License as Amendment 50,
        Condition 10.3.2:
        10.3.2 Independent Audit
                The licensee shall annually commission an independent audit, including
                conclusions and recommendations from review of all audits, inspections,
                employee exposure data, effluent release data, and environmental data to
                determine if:
        10.3.2.1 the radiation, hazardous materials, and safety programs related to
                 radioactive materials and byproduct materials (including chemicals used
                 in the milling process) are adequate,
        10.3.2.2 the quality assurance program is adequate,
        10.3.2.3 any upward trend is developing in personnel exposure for an identifiable
                 category of worker or type of operation or effluent release,
        10.3.2.4 any exposure or effluent might be lowered under the concept of
                 ALARA, and
        10.3.2.5 equipment for effluent and exposure control is being properly used,
                 maintained, and inspected.




Cotter Corporation Canon City Milling Facility
2009 Independent Audit                           1                              26 May 2009
Participants and Schedule
        Cotter Corporation contracted Reid, Miller, and Associates, LLC (RMA) to
        complete an audit with respect to the previously described purpose and scope.

        The key personnel participating in the audit were:

        Auditor:          RMA
                          Robert Miller, Principal, Health Physicist

        Auditees:         CCMF
                          John Hamrick, Vice President, Milling
                          Jim Cain, Environmental Coordinator/Radiation Safety Officer (EC/RSO)
                          Mark Currey, Alternate (aka Assistant) Radiation Safety Officer
                          Kristy Usnick, Radiation Safety Clerk (RSC)
                          Frank W. Adamic, Quality Assurance Coordinator
                          Richard Wooten, Health and Safety Supervisor
                          Richard Ortega, Senior Environmental Technician

        The schedule of the audit was as follows:
        1. Entrance meeting conducted by auditor, including auditees and others, 08:00,
           27 April 2009. Mr. Miller briefly described the purpose, scope, plan, and
           schedule for conduct of the audit.
        2. Interviews and record review 27 through 30 April 2009.
        3. Observe collection of a soil sample, 08:00, 28 April 2009.
        4. Site tour with ALARA Review Committee, 08:10 – 10:30, 29 April 2009.
        5. Exit meeting conducted by auditor, including auditees and others, 09:00, 01
           May 2009. Mr. Miller briefly reviewed the purpose, scope, plan and
           associated summary of results, and the schedule for report of the audit.




Cotter Corporation Canon City Milling Facility
2009 Independent Audit                           2                            26 May 2009
Method
        The audit was conducted as a documented activity performed pursuant to written
        plans to verify, by examination and evaluation, that condition and/or activities at
        CCMF satisfy applicable requirements (i.e. see above Scope). The audit also
        included observing real-time actions to verify whether an activity conformed to
        specified requirements.

        The audit was completed in three phases: preparation, performance, and report.
        Preparation for the audit began with verbal communication between the auditor
        and Mr. Cain, EC/RSO for CCMF. This communication established basic
        coordination of the audit process, particularly the scope and pace. Mr. Cain also
        established initial notification of the audit scope and schedule with CCMF
        personnel prior to the auditor’s arrival. Ms. Usnick, RSC for CCMF, upon
        direction from Mr. Cain and request from the auditor, provided electronic copy of
        the License, reports, and procedures for the auditor’s use in preparation of audit
        plans. The auditor prepared audit plans based on communication with Mr. Cain
        and the electronic copy received from Ms. Usnick. The audit plans were
        developed consistent and commensurate with the previously described Scope.

        Performance of the audit was with respect to the audit plans. The audit plans
        were revised to varying degree during the performance of the audit depending on
        available evidence and/or observation. The audit performance included review of
        additional reports, examination of records, observation of activities, and interview
        of CCMF personnel. The results of the audit performance were recorded with
        varying degrees of specificity on the audit plans. The completed audit plans are
        included as an attachment to this report.

        Report of the audit is provided herein. This report includes description of
        preparation and performance of the audit. This report also provides the auditor’s
        assessment of status of CCMF with respect to the previously described Scope.

        Follow-up on any findings, observations, or other remark from the subject audit is
        out side the scope of this report.




Cotter Corporation Canon City Milling Facility
2009 Independent Audit                           3                               26 May 2009
Terms
        Conditions identified during performance of the audit were assigned to one of two
        classifications as follows:

        Finding           A Finding is the result of identifying a condition in which there is a
                          failure to comply with specific requirements of a CCMF program,
                          regulation, the License, or other sub-tier item (e.g., operating
                          procedure).

                          Criteria for a Finding
                          A condition is classified as a Finding if that condition had not been
                          detected, it could:
                              1. Create a hazard to public safety, have a negative impact to
                                 the environment, or defeat/degrade a safety function in the
                                 facility.
                              2. Cause serious facility damage or a personnel safety hazard.
                              3. Create a loss of confidence in the integrity or effectiveness
                                 of a required program control.

        Observation       An Observation is the result of identifying a condition which does
                          not meet the criteria to be a Finding.

                          Criteria for an Observation
                          A condition is classified as an Observation if the condition is:
                              1. A departure from a specified requirement, which is an
                                 isolated case, and is not indicative of significant problems
                                 (e.g., a missing date on a document, or a missing signature,
                                 etc.).
                              2. A condition that is adequate at the time of the audit, but
                                 could possibly be inadequate if the condition should
                                 degrade.
                              3. A practice (system, procedure, or equipment condition) that
                                 could be considered to be questionable.
                              4. During conduct of an audit if a suggested improvement to
                                 existing procedures or practices can be made.

        Comments and recommendations are included to provide generally descriptive
        information and opinion.




Cotter Corporation Canon City Milling Facility
2009 Independent Audit                           4                                  26 May 2009
Findings
        There were no findings identified as a result of this audit.

Observations
        The following observations were identified as a result of this audit:

        Observation 1: Stored radioactive materials and chemicals should be
                       dispositioned in context of hazard reduction.
                       (Audit Plan CC0409-01-1)

        Condition: There are several radioactive and/or hazardous materials in varying
        conditions of storage at the site. Particularly, chemicals in the Zirconium
        Production Building, off-spec vanadium in drums on the dock of the Uranium
        Product Building, and sealed radioactive sources at several locations on site.
        These materials are not currently managed for long-term storage and/or there is no
        future need or plan for their use.

        Remark: CCMF has previously successfully implemented a program of hazard
        reduction. The scope and effort of this program were apparently consistent with
        responding to conditions similar in context to the observation and basis. CCMF
        should continue hazard reduction in concept with respect to remaining hazardous
        materials on site. Removal of the sealed radioactive sources should also be
        pursued in the context of reducing potential exposure of personnel to radiation;
        i.e., a classic application of the ALARA principal.




Cotter Corporation Canon City Milling Facility
2009 Independent Audit                           5                              26 May 2009
        Observation 2: The Quality Assurance Program Plan is not current.
                       (Audit Plan CC0409-01-2, Item 1; CC0409-01-4, items 2 and
                       4; CC0409-01-5)

        Condition: This condition was recognized as a finding in the report of the 2008
        independent audit. Since that time significant effort and progress has been made
        toward revision and State approval of the Quality Assurance Program Plan
        (QAPP).

        Remark: A final QAPP is due submittal to the State in May 2009.

        The revised QAPP will add requirements and/or influence activities within and
        across all functional areas at CCMF. As such, CCMF should consider the revised
        QAPP as the primary administrative control. Planning should begin now toward
        implementation of the concepts and requirements provided in the revised QAPP.

        For example, the revised QAPP includes specific requirements for document
        control and corrective action. Document control at CCMF is weak and
        inconsistently applied between functional areas. Corrective action is currently
        controlled by at least partially redundant systems with quality assurance and
        environmental control/radiation safety. Application of the revised QAPP as the
        overarching administrative control requirement would resolve these conditions.

        Observation 3: Response to Deficiencies of 2008 Independent Audit are not
                       complete.
                       (Audit Plan CC0409-01-2)

        Condition: The 2008 Independent Audit included one finding and two
        deficiencies. The Finding 1 and Deficiency 2 are repeated from the 2007
        Independent Audit. The Finding 1 and Deficiency 2 appear to be tracked within
        the corrective action systems of Quality Assurance and Environmental/Radiation
        Safety, respectively. Effort has been expended such that inspectable progress has
        occurred toward closure yet Finding 1 and Deficiency 2 are still open.

        Remark: Finding 1 identified that the QAPP was out of date. The status of this
        condition is described above in Observation 2.

        Deficiency 2 described that two written procedures were not updated. The subject
        procedures have been revised by the Alternate (aka Assistant) Radiation Safety
        Officer. They are currently in review by the Environmental
        Coordinator/Radiation Safety Officer. Upon approval of the EC/RSO, the
        procedures will be submitted to the State for approval. The EC/RSO did not
        indicate a specific schedule for either approval.




Cotter Corporation Canon City Milling Facility
2009 Independent Audit                           6                            26 May 2009
Comments and Recommendations
        Current licensed activities and current conditions
        Audit Plan CC0409-01-1 examined current licensed activities and current
        conditions. The examination was completed primarily from a site tour with the
        ALARA Review Committee. During the audit, no decommissioning or
        reclamation activities were occurring. Licensed activities were limited to routine
        monitoring and maintenance. The site tour indicated housekeeping to be
        adequate. Further outcome of this audit plan are provided above for Observation
        1.

        2008 Independent Audit
        Audit Plan CC0409-01-2 identifies the results of the 2008 Independent Audit and
        provides a brief description of status. The 2008 Independent Audit1 described one
        finding, two deficiencies, two observations, and three general recommendations.
        Generally, the response is not complete and thus considered untimely.
        Observations 2 and 3 above provide further discussion on this matter. The auditor
        recognizes, that in the case of observations and recommendations of the 2008
        Independent Audit, a formal response is not required. However, it is
        recommended that CCMF apply attention to the remaining open items and pursue
        them to a timely, documented closure.

        A particular measure toward timely and effective compliance management should
        be removing reference to procedures by title and revision from the License. This
        condition, including State approval of procedures has not demonstrated any real
        positive effect and in fact causes undue administrative burden with coordinating
        reviews and approvals. CCMF should negotiate with the State to remove these
        type prescriptive requirements from the License in favor of performance-based
        conditions. At a minimum, at the procedure level, CCMF should negotiate a
        threshold below which changes to procedure could occur without State approval,
        but may include periodic notification.

        License Condition 10. Safety Inspections and Audits
        The subject license condition includes requirements for shift and weekly
        inspections, and a quarterly and independent audit. Audit Plan CC0409-01-3
        examined Licensee’s status with respect to these requirements. The auditor found
        the Licensee to be responsive to the requirements for conduct of the required
        inspections and audits. The records examined indicate a thorough and broad
        application, in terms of both scope and participants, to the ALARA Program.




1
 Final Report, Independent “As Low As is Reasonably Acheivable” (ALARA) Audit of the Radiological
and Environmental Programs, prepared for Cotter Corporation Canon City Milling Facility, prepared by
URS Corporation, June 11, 2008.

Cotter Corporation Canon City Milling Facility
2009 Independent Audit                            7                                      26 May 2009
        License Condition 10.3.2.1 the radiation, hazardous materials, and safety
        programs …
        Audit Plan CC0409-01-4 broadly reviewed status of the subject license condition.
        The review was completed primarily from examination of records and interview
        of personnel. The condition of document control could be improved; this issue is
        included above within the scope of Observation 2. Otherwise, the scope and
        content of the safety programs appear adequate.

        License Condition 10.3.2.2 the quality assurance program is adequate
        Audit Plan CC0409-01-5 reviewed status of the subject license condition. The
        review was completed primarily from examination of records and interview of
        personnel. The result of this review is included within the scope of Observation
        2. Otherwise, implementation of the revised QAPP will require development of
        new and revision of existing procedures. This implementation will involve all
        functional areas at CCMF. It is recommended that the implementation be
        managed as a project and assigned a manager.

        License Condition 10.3.2.3 any upward trend is developing in personnel exposure
        for an identifiable category of worker or type of operation or effluent release,
         &
        License Condition 10.3.2.4 any exposure or effluent might be lowered under the
        concept of ALARA
        Audit plans CC0409-01-6 and -7 reviewed status of the subject license conditions.
        The reviews were completed primarily from examination of reports. The reports
        reviewed were the semi-annual effluent reports for 2008, the semi-annual
        performance objective reports for 2008, and the Environmental and Occupational
        Performance Report ALARA Review & Annual report on Remedial Action Plan
        Activities, 2007. The review included brief discussion with Mr. Cain, EC/RSO.

        No significant decommissioning or reclamation activities (i.e. operation) were
        conducted by Cotter Corporation Mill Facility staff during 2008. Contractors
        removed approximately 230,000 cubic yards of soil from the Old Pond Area
        (OPA) and demolished and decommissioned the zirconium kiln. This work was
        performed under the contractor’s radioactive materials license. Cotter personnel
        performed work in and adjacent to these work areas. There was no apparent trend
        in personnel exposure or effluent release. The semi-annual performance objective
        report does not appear to serve a unique purpose; i.e., it seems unnecessarily
        redundant with the semi-annual effluent report and the annual environmental and
        ALARA report. It is recommended that CCMF examine current practices to
        identify redundancy and superfluity in reporting and take measures to streamline
        or eliminate efforts to minimize such.

        Implementation of the ALARA program appeared to be comprehensive with
        respect to consideration of activities and involvement of personnel.


Cotter Corporation Canon City Milling Facility
2009 Independent Audit                           8                             26 May 2009
        License Condition 10.3.2.5 equipment for effluent and exposure control is being
        properly used, maintained, and inspected

        Audit Plan CC0409-01-8 reviewed status of the subject license condition. The
        review was completed from review of reports, examination of records, and
        interview of personnel. No equipment for airborne effluent control was in
        operation during the first half of 2008 or during the audit. The Laboratory
        baghouse was operated sporadically during the second half of 2008. Records
        were reviewed of maintenance, sampling, and visual monitoring of the baghouse
        and effluent. The records appeared complete and were readily accessible. The
        records indicated proper maintenance, use, and monitoring of the Laboratory
        baghouse.

        Regarding exposure control, a cursory review was made of records and equipment
        used for respiratory protection and contamination surveys. In each case, the
        equipment appeared properly stored and maintained. Also, records appeared
        completed and were readily accessible. The respective programs were inspectable
        and verifiable.

        Procedure EV-110 Soil Sampling, Rev. 4, 04/14/04

        Audit Plan CC0409-01-9 recorded surveillance of a soil sampling exercise in
        support of annual sampling requirements. The surveillance included direct
        observation of the sampling event, a cursory review of records, and interview of
        personnel. The auditor was accompanied on the surveillance by the CCMF
        Quality Assurance Coordinator (QAC). Documentation of training for the Senior
        Environmental Technician and the General Mill Foreman (GMF) appeared to be
        incomplete. This condition with respect to the GMF was explained by the SET to
        be a reflection of ongoing task training of the GMF by the SET. The QAC
        subsequently communicated to the SET the need to maintain record of training in
        accordance with the QAPP.

        The SET and the GMF were familiar with the requirements of the procedure.
        They were properly prepared for conduct of the sampling exercise. The sampling
        exercise appeared to be completed in conformance with subject procedure.




Cotter Corporation Canon City Milling Facility
2009 Independent Audit                           9                           26 May 2009
Conclusion
        CCMF personnel were cooperative, informative, and timely in response to
        requests of the auditor. The reports, records, and interviews reflected
        management commitment to the ALARA philosophy with respect to protection of
        workers, public, and the environment.

        The management of radiation safety and environmental records was very good.
        The management system was comprehensive in application; it included
        consideration of generation, circulation, receipt, and storage. The records were
        consistently organized, available, complete, and accurate. The Radiation Safety
        Clerk (RSC) demonstrated a comprehensive understanding of the nature and type
        of records generated, necessity of completeness and retrievability. The auditor
        noted the RSCs plans to yet improve accessibility to records and reports. The
        RSC exhibited a valuable sense of ownership of the records management
        program. Thus the radiation safety and environmental records provided for the
        respective programs to be inspectable and verifiable.

        The quality and comprehensiveness of the monthly, quarterly, and semi-annual
        reports might be considered “beyond the call of duty”. They appear to include
        redundancy and reflect collection of data that is either no longer reflective and/or
        not commensurate current and near term activities. The effort to create and
        compile the information for these reports is not inconsequential. CCMF should
        review these periodic reports with respect to content, application, and
        precipitating requirement for opportunities of efficiency and utility. Such review
        should involve the State, particularly with regard to establishing requirements
        more in terms of performance than prescription. (This conclusion is made with
        emphasis regarding operating procedures; i.e., License Condition 34. S. and
        34.T.)

        This audit found the radiation, hazardous materials, and safety programs related to
        licensed material to be established at least commensurate with activities and
        conditions at the site. The programs appeared to be inspectable and verifiable.
        The programs are thus considered adequate.

        This audit found the quality assurance program to be lacking. However,
        considering state and progress of revision, and the activities and conditions at the
        site, the quality assurance program should not be considered inadequate.

        This audit did not find any upward trend in personnel exposure or effluent release.
        This audit did not find that any exposure or effluent should be lowered under the
        concept of ALARA. This audit found that equipment for effluent and exposure
        control is being properly used, maintained, and inspected.




Cotter Corporation Canon City Milling Facility
2009 Independent Audit                           10                              26 May 2009
Attachment – Audit Plans




Cotter Corporation Canon City Milling Facility
2009 Independent Audit                           11   26 May 2009
                                                                   AUDIT PLA
                                                                         For
                                                                 Cotter Corporation

Purpose: Independent Audit: State of Colorado, Department of Public Health and Environment, Radioactive                Audit No.
         Materials License No. 369-01, Amendment No. 50, License Condition 10.3.2                                     CC0409-01-1
Scope: Current licensed activities and current conditions

Location: Mill facility, Canon City, CO                     Prepared By: Robert Miller   Evaluator: Robert Miller   Date: 27 April 2009

No.   Requirement/Characteristic                            Evidence / Remark                                       By     Date
      Site tour – current licensed activities               Evidence:                                               rhm    29 Apr 08
 1              – current site conditions                   Tour of site by ALARA Review Committee.
                                                            Quarterly ALARA Inspection.
                                                            Wednesday 20 April 2009, 08:10 – 10:30.
                                                            Personnel:
                                                                • EC/RSO – Jim Cain
                                                                • ARSO – Mark Currey
                                                                • H&S Supervisor – Richard Wooten
                                                                • Operations – Roy Hockett
                                                                • Maintenance – Jerry Jones




                                                                                                                            Page 1 of 3
                                                      AUDIT PLA
                                                            For
                                                    Cotter Corporation

No.   Requirement/Characteristic               Evidence / Remark                                       By    Date
     (continued)                               (continued)                                             rhm   29 Apr 08
 1   Site tour – current licensed activities   Evidence:
cont           – current site conditions       Walking tour:
                                                   • Guard Shack – chairs need cleaned
                                                   • Survey Trailer
                                                   • Womens Change Room
                                                   • Respirator Room
                                                   • Mens Change Rooms
                                                   • Office
                                                   • Engineering Trailer – wash carpets
                                                   • Old lab
                                                   • Radiation Technician trailer
                                                   • “breezeway” (storage)
                                                   • Old prep building
                                                   • Old metalurgical lab
                                                   • Former ore storage (W of entrance) (empty,not
                                                       remediated)
                                                   • Zirconium production – various stored chemicals
                                                   • Secondary Crusher
                                                   • Analytical Laboratory – active
                                                   • Maintenance
                                                   • Solvent Extraction
                                                   • Product
                                                       o dock – off spec drummed V as RAM
                                                   • Fine Ore Bins
                                                   • Thickeners (CCDs)
                                                   • Grind Leach

Audit No. CC0409-01-1                                                                                         Page 2 of 3
                                                      AUDIT PLA
                                                            For
                                                    Cotter Corporation

No.   Requirement/Characteristic               Evidence / Remark                                         By    Date
     (continued)                               (continued)                                               rhm   29 Apr 08
 1   Site tour – current site conditions       Evidence:
cont           – current licensed activities   Walking tour:
                                                   • Zirconium ore pile
                                                   • Former kiln (storage)
                                                   • Catalyst Plant
                                                   • Lime Neutralization
                                                   • Quonset (storage)
                                                   • Warehouse
                                                   • Former molybdenum solvent extraction (storage)
                                                          o Used oil
                                                          o Euxenite ore
                                                   • Impoundments
                                               Remarks:
                                               Currently no decommissioning or reclamation activities.
                                               Licensed activities limited to routine monitoring and
                                               maintenance.
                                               Sealed sources are in various places on site. There are
                                               none in operation. There are no plans for use.
                                               Recommend remove from site.
                                               Housekeeping good, certainly adequate in context.
                                               Stored radioactive materials and chemicals should be
                                               dispositioned in context of hazard reduction.




Audit No. CC0409-01-1                                                                                           Page 3 of 3
                                                                 AUDIT PLA
                                                                       For
                                                               Cotter Corporation

Purpose: Independent Audit: State of Colorado, Department of Public Health and Environment, Radioactive            Audit No.
         Materials License No. 369-01, Amendment No. 50, License Condition 10.3.2 Independent Audit              CC0409-01-2
Scope: Final Report, Independent … (ALARA) Audit of Radiological and Environmental Programs, Cotter Corporation, Canon City
       Milling Facility, … June 11, 2008
Location: Mill facility, Canon City, CO                   Prepared By: Robert Miller     Evaluator: Robert Miller       Date: 27 April 2009

No.   Requirement/Characteristic                          Evidence / Remark                                             By     Date
      Finding 1: Out-of-Date, Inadequate Quality          Evidence:                                                     rhm    27 Apr 09
 1    Assurance/Quality Control Program                   QA Coordinator (Frank Adamic): correspondence trail:
      The Quality Assurance/Quality Control Program,      Cotter submitted revision to State Jul 2008, State required
      as documented in the QAPP is out-of-date.           additional revision Nov 2008, Cotter submitted additional
      (LC 10.3.2.2; LC 25.2.1)                            information Jan 2009, State concurred Feb 2009, final
                                                          copy due to State May 2009.
      Recommendation: This is a repeat finding. …
      {refer to Corrective Action Improvement Request     Remark:
      250}                                                None.

      Deficiency 1: Response Plan Missing Elements        Evidence:                                                     rhm    27 Apr 09
 2    … The “Notifications” section of the plan did not   The recommendation is included in ER-010, Section 6.3.
      include all the license requirements for            The recommendation is included in ER-010, Section 10.1.
      emergency notification of CDPHE.                    The current copies in Conference Room and H&S
                                                          Supervisors Office include updated pages of phone
      Recommendation: Provide for management to           numbers.
      annually review and update the Response Plan
      content and train all facility personnel to the     Remark:
      current Plan                                        This procedure indicates a weakness in document control.
                                                          The copies in Conference Room and H&S Supervisors
                                                          Office do not include the same updated pages. The copy
                                                          in the H&S Supervisors Office retains the superseded
                                                          pages.
                                                                                                                                Page 1 of 4
                                                                 AUDIT PLA
                                                                       For
                                                               Cotter Corporation

No.   Requirement/Characteristic                          Evidence / Remark                                          By    Date
      Deficiency 2: Written Procedures RH-50 and          Evidence:                                                  rhm   27 Apr 09
 3    RH-210 ot Updated                                   A revision has not been drafted for procedure RH-50.
      Written Procedures RH-50 (“Uranium Bioassay”)       Procedure RH-210 has been revised by ARSO (Mark
      and RH-210 (“Personal Radiation Monitors” were      Currey). RH-210 is waiting approval by the EC/RSO
      not updated. This is a repeat deficiency.           (Jim Cain). Subsequently they will be submitted to the
                                                          State for approval.
      Recommendation: … Revise RH-50 and RH-
      210, and submit them for review by State. …         Remark:
                                                          This is not a timely response.
                                                          The review/approval by State is also not reasonable with
                                                          respect to timely management of site activities.

      Observation 1: Inspection Form ot                   Evidence:                                                  rhm   27 Apr 09
 4    Consistently Completed                              Reviewed to 2008 ALARA file.
      Inconsistencies were noted in a section of the      No change in form noted after June 2008.
      ALARA Committee inspection checklists of
      active work areas. …                                Remark:
                                                          The form was not changed, however the inspectors now
      Recommendation: … Modify the inspection             consistently document posted areas.
      checklists to allow for other inspection options,   (An observation does not require action or response by
      such as “not required” (state reason), …            licensee.)




Audit No. CC0409-01-2                                                                                                       Page 2 of 4
                                                                AUDIT PLA
                                                                      For
                                                              Cotter Corporation

No.   Requirement/Characteristic                         Evidence / Remark                                       By    Date
      Observation 2: Potential for Loss of Annual        Evidence:                                               rhm   28 Apr 09
 5    Dose Data Maintenance                              The ARSO (Mark Currey) described that he continues to
      In the event of an unplanned absence of the …      conduct related cross-training with HR Clerk (Linda
      (ARSO), the system employed for determining        Gehring).
      annual occupational doses may be difficult to
      maintain without specific instruction and/or       Remark:
      training.                                          The EC/RSO (Jim Cain) is aware of the recommendation
                                                         and status of response.
      Recommendation: … Continue to cross-train
      other employees and allow them to gain
      experience with the system through frequent,
      hands-on involvement and coordination with the
      ARSO.
      General Recommendation (page 10):                  Evidence:                                               rhm   28 Apr 09
 6    Adding an updated status summary to the sealed     The ARSO (Mark Currey) completed an inventory of
      source log book is recommended to eliminate        sealed sources Jan/Feb 2009. The inventory record
      confusion about which sources are in storage and   describes two sources as in “storage”.
      which are in use.
                                                         Remark:
                                                         None.




Audit No. CC0409-01-2                                                                                                   Page 3 of 4
                                                              AUDIT PLA
                                                                    For
                                                            Cotter Corporation

No.   Requirement/Characteristic                       Evidence / Remark                                          By    Date
      General Recommendation (page 10):                Evidence:                                                  rhm   27 Apr 09
 7    … consider developing a written procedure for    The ARSO (Mark Currey) has drafted a procedure with
      surveying of inbound radioactive materials, in   respect to this recommendation. He has yet to provide it
      compliance with the requirements of DOT.         to the EC/RSO (Jim Cain) for review and submittal to
                                                       State.

                                                       Remark:
                                                       The EC/RSO is aware of the status of response.


      General Recommendation (page 11):                Evidence:                                                  rhm   27 Apr 09
 8    … consider removing revision dates and numbers   The EC/RSO (Jim Cain) described that no specific
      [of procedures] from the license conditions      activity has occurred on this matter.
      during a future amendment.

                                                       Remark:
                                                       None.




Audit No. CC0409-01-2                                                                                                    Page 4 of 4
                                                                AUDIT PLA
                                                                      For
                                                              Cotter Corporation

Purpose: Independent Audit: State of Colorado, Department of Public Health and Environment, Radioactive                Audit No.
         Materials License No. 369-01, Amendment No. 50, License Condition 10.3.2 Independent Audit                   CC0409-01-3
Scope: License Condition 10. Safety Inspections and Audits

Location: Mill facility, Canon City, CO                 Prepared By: Robert Miller    Evaluator: Robert Miller      Date: 27 April 2009

No.   Requirement/Characteristic                        Evidence / Remark                                           By     Date
      10.1 Shift Inspections:                            Evidence:                                                  rhm     29 Apr 09
 1    The shift supervisor shall conduct and document    Currently two shifts: day and night.
      per the licensee’s Security Manual visual          The following shift reports were reviewed:
      surveillance of each active mill area during each    • Daily Shift Report
      shift to evaluate site conditions, and to ensure     • Safety/Security Technician Duties (Day and Night)
      proper implementation of the radiation protection,   • Shift Dust/Watering Report
      safety, and security programs.                       • Daily Tailings Impoundment Inspection
                                                           • Chemical Containment System Shift inspection
      Management shall provide a mechanism for           The following relevant reports were also reviewed:
      management review of the inspection program.         • Silt fence inspection
                                                           • Weather station inspection
                                                           • Inspection of Water Distribution Pond and Hypalon
                                                               Liner
                                                           • Inspection of #3 Pond Hypalon Liner
                                                           • Weekly Reconnaissance of Tailings Impoundment
                                                               Area
                                                         These reports are compiled by the Radiation Safety Clerk
                                                         (Kristy Usnick) into ALARA reports to management.
                                                         Remark:
                                                         The scope and application of these reports are
                                                         comprehensive with regard to the requirement.


                                                                                                                            Page 1 of 3
                                                                   AUDIT PLA
                                                                         For
                                                                 Cotter Corporation

No.   Requirement/Characteristic                            Evidence / Remark                                             By    Date
      10.2 Weekly Inspections:                              Evidence:                                                     rhm    28 Apr 09
 2    During any period … the RSO or … designee             This requirement is implemented by Radiation Safety
      shall conduct a weekly documented inspection of       Procedure AD-080 ALARA Program.
      each active work area to evaluate site conditions
      and to ensure proper implementation of the            ALARA Committee Inspection Form is completed by
      radiation protection program and safety program.      routine weekly, and supplementally by judgment or
                                                            calendar quarter.
      Any deviation from a standard operating
      procedure, license requirement, or safety practice,   The completed form is circulated to management.
      including housekeeping practice, affecting
      radiological safety shall be reviewed by              Followup is provided by workorder and/or tracking as
      management with the employee(s), documented,          corrective action in the monthly ALARA meeting (see
      and corrected.                                        Item 3 below).

                                                            Remark:
                                                            The weekly inspection forms indicate a thorough and
                                                            broad application, in terms of both scope and participants,
                                                            to the ALARA Program.




Audit No. CC0409-01-3                                                                                                            Page 2 of 3
                                                                   AUDIT PLA
                                                                         For
                                                                 Cotter Corporation

No.   Requirement/Characteristic                            Evidence / Remark                                           By    Date
      10.3 RSO’s Quarterly Audit:                           Evidence:                                                   rhm    28 Apr 09
 3    10.3.1 During any period of active operation, the     This requirement is implemented by Radiation Safety
             RSO shall (1) audit quarterly … the logs       Procedure AD-080 ALARA Program.
             and reports of inspections, (2) evaluate the
             adequacy of implementation of license          The ALARA Review Committee provides monthly and
             requirements, and (3) recommend in             quarterly minutes of meeting. The reports include
             writing to the mill manager any necessary      summaries or results of various occupational and
             corrective actions.                            environmental monitoring, and corrective actions. The
                                                            corrective actions tracked in these reports are developed
                                                            from the ALARA inspections (Item 2 above) as well as
                                                            other inspections and audits. The EC/RSO provides a
                                                            quarterly report to the Mill Manager regarding license
                                                            implementation and necessary corrective actions.

                                                            Remark:
                                                            The monthly and quarterly meeting minutes indicate a
                                                            thorough and broad application, in terms of both scope
                                                            and participants, of the ALARA Program.

      10.3.2 Independent Audit                              Evidence:                                                   rhm    28 Apr 09
 4    The licensee shall annually commission an             The report Final Report, Independent … (ALARA) Audit
      independent audit, including conclusions and          of Radiological and Environmental Programs, Cotter
      recommendations from review of all audits,            Corporation, Canon City Milling Facility, … June 11,
      inspections, employee exposure data, effluent         2008, was reviewed (the scope of report was year 2007):
      release data, and environmental data to determine     see Audit Plan CC0409-01-2.
      if: [license conditions 10.3.2.1 – 10.3.2.5]
                                                            Also observed equivalent report for year 2006.

                                                            Remark:
                                                            None.
Audit No. CC0409-01-3                                                                                                          Page 3 of 3
                                                                 AUDIT PLA
                                                                       For
                                                               Cotter Corporation

Purpose: Independent Audit: State of Colorado, Department of Public Health and Environment, Radioactive                     Audit No.
         Materials License No. 369-01, Amendment No. 50, License Condition 10.3.2 Independent Audit                       CC0409-01-4
Scope: License Condition 10.3.2.1 the radiation, hazardous materials, and safety programs related to radioactive materials and byproduct
                                   materials (including chemicals used in the milling process) are adequate,
Location: Mill facility, Canon City, CO                   Prepared By: Robert Miller    Evaluator: Robert Miller      Date: 27 April 2009

No.   Requirement/Characteristic                          Evidence / Remark                                           By     Date
      29 CFR 1910.1200 Hazard Communication               Evidence:                                                   rhm    29 Apr 09
 1    Appendix E, … 5. Checklist for Compliance           Discussion with H&S Supervisor (Richard Wooten) and
                                                          observation of written procedure SP-0009 Hazard
      { use Appendix E checklist }                        Communication Program confirmed program
                                                          implementation.

                                                          This item was not otherwise specifically reviewed.

                                                          Remark:
                                                          None.




                                                                                                                               Page 1 of 3
                                                            AUDIT PLA
                                                                  For
                                                          Cotter Corporation

No.   Requirement/Characteristic                     Evidence / Remark                                             By    Date
      LC 13. Written Operational Procedures:         Evidence:                                                     rhm   29 Apr 09
 2    13.1 Written operational procedures shall be   Discussion with H&S Supervisor (Richard Wooten)
           maintained … These shall include at a     identified the written procedure series SPA and SP as
           minimum, … Site Safety Manual, …          comprising the Site Safety Manual. The H&S Supervisor
                                                     also identified the Mill Safety Manual as a formal
                                                     component of the written site safety program.
                                                     Reviewed records of training on topics of industrial health
                                                     and safety.

                                                     Remark:
                                                     There is no effective document control or distribution of
                                                     the written procedure series SPA and SP.
                                                     By discussion and review, the scope and content of the
                                                     safety program appear adequate.

      6 CCR 1007-1, … Radiation Control              Evidence:                                                     rhm   27 Apr 09
 3    Part 1 General Provisions                      License Condition 8.12 Radiation Safety Officer (RSO):
      Appendix 1A Qualified Expert …                 The designated RSO is Jim Cain.

                                                     License Condition 8.13 Designated Alternate Radiation
                                                     Safety Officer (ARSO):
                                                     The designated ARSO is Mark Currey.

                                                     Remark:
                                                     These individuals currently fill respective roles.




Audit No. CC0409-01-4                                                                                                     Page 2 of 3
                                                            AUDIT PLA
                                                                  For
                                                          Cotter Corporation

No.   Requirement/Characteristic                     Evidence / Remark                                           By    Date
      LC 13. Written Operational Procedures:         Evidence:                                                   rhm   27 Apr 09
 4    13.1 Written operational procedures shall be   Discussion with EC/RSO (Jim Cain) identified the written
           maintained … These shall include at a     procedure series AD, ER, EV, and RH as comprising the
           minimum, … Radiation Protection Program   Radiation Protection Program Procedures.
           Procedures, …
                                                     Review various records of environmental and radiation
                                                     safety programs.

                                                     Remark:
                                                     There is no effective document control or distribution of
                                                     the written procedure series AD, ER, EV, and RH.
                                                     By discussion and review, the scope and content of the
                                                     radiation safety program appear adequate.




Audit No. CC0409-01-4                                                                                                   Page 3 of 3
                                                                AUDIT PLA
                                                                      For
                                                              Cotter Corporation

Purpose: Independent Audit: State of Colorado, Department of Public Health and Environment, Radioactive                   Audit No.
         Materials License No. 369-01, Amendment No. 50, License Condition 10.3.2 Independent Audit                      CC0409-01-5
Scope: License Condition 10.3.2.2 the quality assurance program is adequate,

Location: Mill facility, Canon City, CO                  Prepared By: Robert Miller     Evaluator: Robert Miller       Date: 27 April 2009

No.   Requirement/Characteristic                         Evidence / Remark                                             By     Date
      13. Written Operational Procedures:                Evidence:                                                     rhm    28 Apr 09
 1    13.1 Written operational procedures shall be       QA Coordinator (Frank Adamic): correspondence trail:
           maintained … These shall include at a         Cotter submitted revision to State Jul 2008, State required
           minimum, … , and the Quality Assurance        additional revision Nov 2008, Cotter submitted additional
           Program Plan.                                 information Jan 2009, State concurred Feb 2009, final
                                                         copy due to State May 2009.

                                                         Remark:
                                                         The QAPP requires development of new and revision of
                                                         existing procedures to support implementation.
                                                         There is no effective document control or distribution of
                                                         the QAPP.

      25.2 Quality Assurance / Quality Control:          Evidence:                                                     rhm    28 Apr 09
 2    25.2.1 The licensee shall maintain a quality       See above Item 1.
             assurance/quality control program for all   The scope of the revised QAPP particular to “ …
             analytical data collection, analysis, and   Environmental and Occupational Sampling and
             reporting activities approved by the        Monitoring Studies.”
             Division and specified in writing.
                                                         Remark:
                                                         Existing procedures will need revision to support
                                                         implementation of the QAPP.

                                                                                                                               Page 1 of 2
                                                                 AUDIT PLA
                                                                       For
                                                               Cotter Corporation

No.   Requirement/Characteristic                          Evidence / Remark                                            By    Date
      25.2 Quality Assurance / Quality Control:           Evidence:                                                    rhm   28 Apr 09
 3    25.2.1 The licensee shall follow the lower limits   Laboratory Procedure 3-5 “Counting and Analysis of
             of detection (LLDs) contained in USNRC       Radiochemistry Samples”, sections 6.6.5.6 and 6.6.5.9.
             Regulatory Guide 8.30, …, May 2002.
                                                          Remark:
                                                          The term used in the aforementioned procedure is MDA
                                                          (it should be MDC or LLD). The procedural MDA is
                                                          determined using a calculated k value or 2.71; the subject
                                                          Regulatory Guide uses a k factor of 3.




Audit No. CC0409-01-5                                                                                                         Page 2 of 2
                                                                 AUDIT PLA
                                                                       For
                                                               Cotter Corporation

Purpose: Independent Audit: State of Colorado, Department of Public Health and Environment, Radioactive                   Audit No.
         Materials License No. 369-01, Amendment No. 50, License Condition 10.3.2 Independent Audit                     CC0409-01-6
Scope: License Condition 10.3.2.3 any upward trend is developing in personnel exposure for an identifiable category of worker or type of
                                  operation or effluent release,
Location: Mill facility, Canon City, CO                   Prepared By: Robert Miller    Evaluator: Robert Miller      Date: 30 April 09

No.   Requirement/Characteristic                          Evidence / Remark                                           By     Date
      [See Scope.]                                        Evidence:                                                   rhm    30 Apr 09
 1                                                        The following reports were reviewed;
                                                            • Semiannual Effluent Report, August 29, 2008.
                                                            • Semiannual Performance Objective Report, August
                                                                29, 2008.
                                                            • Semiannual Effluent Report, February 27, 2009.
                                                            • Semiannual Performance Objective Report,
                                                                February 27, 2009.
                                                            • Environmental and Occupational Performance
                                                                Report ALARA Review & Annual report on
                                                                Remedial Action Plan Activities, 2007.

                                                          Remark:
                                                          No significant decommissioning or reclamation activities
                                                          (i.e. operation) were conducted by Cotter Corporation
                                                          Mill Facility staff during 2008.
                                                          There was no apparent trend in personnel exposure or
                                                          effluent release.




                                                                                                                               Page 1 of 1
                                                               AUDIT PLA
                                                                     For
                                                             Cotter Corporation

Purpose: Independent Audit: State of Colorado, Department of Public Health and Environment, Radioactive                Audit No.
         Materials License No. 369-01, Amendment No. 50, License Condition 10.3.2 Independent Audit                   CC0409-01-7
Scope: License Condition 10.3.2.4 any exposure or effluent might be lowered under the concept of ALARA,

Location: Mill facility, Canon City, CO                 Prepared By: Robert Miller    Evaluator: Robert Miller      Date: 30 April 09

No.   Requirement/Characteristic                        Evidence / Remark                                           By     Date
      [See Scope.]                                      Evidence:                                                   rhm    30 Apr 09
 1                                                      The following reports were reviewed;
                                                          • Semiannual Effluent Report, August 29, 2008.
                                                          • Semiannual Performance Objective Report, August
                                                              29, 2008.
                                                          • Semiannual Effluent Report, February 27, 2009.
                                                          • Semiannual Performance Objective Report,
                                                              February 27, 2009.
                                                          • Environmental and Occupational Performance
                                                              Report ALARA Review & Annual report on
                                                              Remedial Action Plan Activities, 2007.

                                                        Remark:
                                                        No significant decommissioning or reclamation activities
                                                        (i.e. operation) were conducted by Cotter Corporation
                                                        Mill Facility staff during 2008.
                                                        There was no apparent trend in personnel exposure or
                                                        effluent release.
                                                        Implementation of the ALARA program appeared to be
                                                        comprehensive with respect to consideration of activities
                                                        (breadth and depth) and involvement of personnel.


                                                                                                                            Page 1 of 1
                                                                   AUDIT PLA
                                                                         For
                                                                 Cotter Corporation

Purpose: Independent Audit: State of Colorado, Department of Public Health and Environment, Radioactive                 Audit No.
         Materials License No. 369-01, Amendment No. 50, License Condition 10.3.2                                      CC0409-01-8
Scope: License Condition 10.3.2.5 equipment for effluent and exposure control is being properly used, maintained, and inspected.

Location: Mill facility, Canon City, CO                     Prepared By: Robert Miller   Evaluator: Robert Miller    Date: 29 April 09

No.   Requirement/Characteristic                              Evidence / Remark                                      By     Date
      [See Scope: “equipment for effluent … control ...”]     Evidence:                                              rhm    30 Apr 09
 1                                                            Semiannual Effluent Report, August 29, 2008.
                                                                 • No stacks operating first half 2008
                                                              Semiannual Effluent Report, February 27, 2009.
                                                                 • Sporadic, minimal operation of Laboratory
                                                                    Baghouse second half 2008.
                                                              Radiation Safety files: 2008; Stacks
                                                                 • Maintenance Log Record Form
                                                                     o (five forms for Lab 2008)
                                                                 • Source Sampling, Lab Baghouse – Sample Prep
                                                                     o (13 pages describing stack sampler calib.)
                                                              Radiation Safety files: 2008; Opacity
                                                                 • EPA Visible Emission Observation Form 1
                                                                     o (32 forms for 2008)
                                                                     o (personnel training in Sep and Oct 2008)
                                                              Radiation Safety procedure EV-080 “Stack Sampling”
                                                                 • This procedure was not specifically audited.
                                                              Remark:
                                                              No stacks were operating during the audit.
                                                              Records are complete and accessible.
                                                              Records indicate proper use, maintenance, and
                                                              inspection of Laboratory baghouse.

                                                                                                                              Page 1 of 3
                                                                AUDIT PLA
                                                                      For
                                                              Cotter Corporation

No.   Requirement/Characteristic                            Evidence / Remark                                   By    Date
      [See Scope: “equipment for exposure … control ...”]   Evidence:                                           rhm   29 Apr 09
 2                                                          Respiratory Protection
                                                              • Cursory review of records
                                                                  o Inspection, Maintenance, Cleaning, and
                                                                      Storage
                                                                  o Inventory
                                                                  o Medical evaluation
                                                                  o Fit Test
                                                                  o Training
                                                              • Cursory review of equipment
                                                                  o Inventory and storage
                                                                  o Fit test equipment

                                                            Remarks:
                                                            Records appear complete and accessible.
                                                            Equipment appears properly stored and maintained.
                                                            Program is inspectable and verifiable.




Audit No. CC0409-01-8                                                                                                  Page 2 of 3
                                                                AUDIT PLA
                                                                      For
                                                              Cotter Corporation

No.   Requirement/Characteristic                            Evidence / Remark                                        By    Date
      [See Scope: “equipment for exposure … control ...”]   Evidence:                                                rhm   29 Apr 09
 3                                                          Radiation and contamination surveys
                                                              • Review of records for 2008
                                                                  o Alpha Surveys - #1
                                                                  o Alpha/Beta Surveys – Mill Locations #1
                                                                  o Calibration (very limited review)
                                                                  o Equipment Survey #1
                                                                  o Miscellaneous Surveys
                                                                  o Personnel Survey #1
                                                              • Cursory review of equipment in service
                                                                  o Type
                                                                  o Availability
                                                                  o Condition
                                                                  o Use

                                                            Remarks:
                                                            Records are complete and accessible.
                                                            Equipment appears properly stored and maintained.
                                                            Program is comprehensive, inspectable, and verifiable.




Audit No. CC0409-01-8                                                                                                       Page 3 of 3
                                                               AUDIT PLA
                                                                     For
                                                             Cotter Corporation

Purpose: Independent Audit: State of Colorado, Department of Public Health and Environment, Radioactive             Audit No.
         Materials License No. 369-01, Amendment No. 50, License Condition 10.3.2                                  CC0409-01-9
Scope: Procedure EV-110 Soil Sampling, Rev. 4, 04/14/04

Location: Mill facility, Canon City, CO                 Prepared By: Robert Miller   Evaluator: Robert Miller    Date: 27 April 09

No.   Requirement/Characteristic                        Evidence / Remark                                        By     Date
       5.1 The Environmental Coordinator/Radiation Evidence:                                                     rhm    28 Apr 09
 1       Safety Officer (EC/RSO) or the Assistant RSO 5.1.1 SSTF: Sample Submittal Tracking Form (SSTF).
         is responsible for:                                            General Mill Foreman (GMF)(Bob
           5.1.1 Insuring      that    the    technicians               Tennant) trained Sep 07.
                   obtaining soil samples are properly                  Senior Environmental Technician
                   trained in soil sampling and sample                  (SET)(Richard Ortega) no training
                   chain of custody.                                    documentation.
           5.1.2 Assigning schedule of sampling                  EV-110: Bob Tennant no training documentation
                   events to the Senior Environmental                    Richard Ortega read procedure Jan 05
                   Technician or Radiation Safety 5.1.2 The EC/RSO does not directly assign. The SET
                   Technicians.                                  schedules directly.
                                                          Remark:
                                                          See Item 2.
       5.3     The Quality Assurance Coordinator or Evidence:                                                    rhm    28 Apr 09
 2             designee is responsible for                5.3.1 See Item 1 above at 5.1.1.
           5.3.1 Assuring that personnel considered as
                   key individuals relevant to this 5.3.2 The QA Coordinator (Frank Adamic)
                   procedure are documented as                    accompanied sampling event for AS204.
                   properly trained and/or qualified to
                   perform the required duties.           Remark:
           5.3.2 Assuring that the quality principles of The SET is in process of training the GMF on EV-110.
                   this procedure are followed and        The QA Coordinator communicated to SET need for
                   maintained.                            documentation of training in accordance with QAPP.
                                                                                                                         Page 1 of 2
                                                                    AUDIT PLA
                                                                          For
                                                                  Cotter Corporation

No.   Requirement/Characteristic                            Evidence / Remark                                           By    Date
       7.3 The SET or RSTs will take the soil sample at     Evidence:                                                   rhm   28 Apr 09
 3         locations listed in Appendix 3.2.1 and as        7.3   Observed sample event at AS204. GPS location
           shown on the map in Appendix 3.2.2 …                   and soil sample collected on west side of sampler.
           Designate the GPS coordinates on form
           SSTF or attach a map upon which is marked        7.5    The GMF used a stainless steel shovel with 5cm
           the sampling location.                                  mark.

       7.5 Remove the top 5 cm of soil from a 10 cm x       7.6    The soil sample was placed directly in the Nalgene
           10 cm area using the stainless steel shovel or          sample bag from the sample shovel.
           take a 5 cm diameter plug 5 cm deep if using
           the soil sampler. Remove any large rocks or      7.7    The sample bag was labeled as required and placed
           debris from the sample.                                 in a plastic chest.
       7.6 Place the soil in a 23 cm x 33 cm Nalgene® 7.8          The SET had previously initiated the SSTF. The
           sample bag or equivalent.                               SSTF indicated required information to be
                                                                   included on an attached sheet.
       7.7 Label the Nalgene® sample bag or
           equivalent using an indelible marker or
                                                                   The SSTF referred to procedure RHS-3-5 for
           prepared a label with the location, date, and
                                                                   sample preparation.
           time the sample was taken and the SSTF #.

       7.8 Fill out the necessary information on the 7.9           The GMF completed the field logbook as required.
           SSTF.                                                   The GMF cleaned the sampling equipment as
                                                                   required.
       7.9 Note pertinent information in the field
                                                            Remark:
           logbook form including the location, date
                                                            The reference to procedure RHS-3-5 seems inappropriate
           and time of sample, description of sample
                                                            as it is apparently superseded by EV-110.
           location, site conditions, GPS coordinates,
                                                            The sampling exercise was conducted in conformance
           and any unusual circumstances …
                                                            with Radiation Safety Procedure EV-110.


Audit No. CC0409-01-9                                                                                                          Page 2 of 2

								
To top