Appendix B ALARA Independent Audit Report

CALENDAR YEAR 2006
APPENDIX B
INDEPENDENT ALARA AUDIT
OF THE RADIOLOGICAL AND ENVIRONMENTAL PROGRAMS
AT THE
COTTER CORPORATION URANIUM MILL,
CANON CITY, COLORADO
CANON CITY MILLING FACILITY
Canon City, Colorado
June 29, 2007FINAL REPORT
Independent “As Low As is Reasonably
Achievable” (ALARA) Audit of the Radiological
and Environmental Programs

Cotter Corporation
Cañon City Milling Facility
Cañon City, Colorado

Prepared for
Cotter Corporation
Cañon City Milling Facility
Cañon City, Colorado
April 30, 2007

URS
8181 East Tufts Avenue
Denver, Colorado 80237



Project Number 22239445

Table of Contents


Executive Summary........................................................................................................................ 1
Introduction..................................................................................................................................... 2
Scope............................................................................................................................................... 2
Audit Schedule and Participants ..................................................................................................... 4
Audit Method and Nomenclature.................................................................................................... 4
Findings........................................................................................................................................... 6
Finding 1: Lack of Documentation of Prompt, Appropriate Correction of Known Deficiencies
(LC 8.7, LC 33.2, Repeat Finding) ............................................................................................. 6
Finding 2: Response Plan Out-of-Date, Missing Elements (LC 9.1) ........................................ 7
Finding 3: Out-of-Date Quality Assurance/Quality Control Program (LC 25.2.1)................... 7
Finding 4: Quality Assurance/Quality Control Program Lacking Laboratory Components (LC
25.2.2, LC 27.2) .......................................................................................................................... 9
Deficiencies................................................................................................................................... 10
Deficiency 1: Lack of Documentation of Written Recommendations to the Mill Manager (LC
10.3.1) ....................................................................................................................................... 10
Deficiency 2: Written Procedures RH-50 and RH-210 Not Updated (LC 13.1) ..................... 10
Deficiency 3: Missing Signatures on RSO Documentation of Employee Training (LC 16.2) 10
Observations ................................................................................................................................. 11
Observation 1: Inconsistencies in Documented Inspections.................................................... 11
Observation 2: Potential for Loss of Annual Dose Data Maintenance.................................... 12
Observation 3: Lack of Daily Calibration of Breathing Zone Air Sampling Pumps............... 12
General Observations and Recommendations .............................................................................. 13
License Modification Recommendations ..................................................................................... 14
Conclusions................................................................................................................................... 15
Attachment A – Audit Checklist................................................................................................... 16


Cotter Corporation Cañon City Milling Facility i June 15, 2007
2007 Independent ALARA Audit Executive Summary

In accordance with the provisions of the Cotter Corporation's State of Colorado Department of
Public Health and the Environment (CDPHE) Radioactive Material License (RML), URS
Corporation conducted an independent “as low as reasonably achievable” (ALARA) audit of the
facilities and operations of the Cotter Corporation's milling facility located in Cañon City,
Colorado. The audit was conducted to evaluate the radiation safety and environmental effluent
programs implemented at the facility that provide site employees and the public in the vicinity
with assurances that radiological exposures and releases to the environment are minimized.
After a comprehensive review of the Cotter Corporation radiation safety and environmental
program documentation, the on-site portion of the ALARA audit of the Mill was performed on
April 9 through 11, 2007, by the URS Audit Team with the support of the Cotter Corporation
radiation, environmental, safety and management representatives at the facility.

At the time of the audit, the Mill was not receiving or processing ore. General plant activities
were limited to facility maintenance and measures to sustain compliance with the license
requirements.

Several findings, deficiencies, and observations were noted during the audit. These are described
in detail in the audit report. “Findings” are considered to be significant deviations from
established requirements, and are summarized below:

• The Cotter management and Radiation Safety Officer (RSO) failed to take prompt,
appropriate actions to correct known deficiencies. (LC 8.7, LC 33.2 repeat finding)
• The Response Plan is out-of-date and missing required elements. (LC 9.1)
• The Quality Assurance/Quality Control Program (QAPP), as documented in the QAPP, is
out-of-date and non-functional (LC 25.2.1).
• The QAPP is not updated to reflect or provide review and oversight of new methods and
revised analytical procedures for the laboratory, including those for lower limit of
detection (LLD) and minimal detectable activity (MDA) (LC 25.2.2, LC 27.2).

The opportunities to examine personnel exposures to external radiation and internal intakes for
trends in specific areas were limited by the variations in activities and production rates and
materials processed. Although the average and maximum committed effective dose equivalent
(CEDE) and total effective dose equivalent (TEDE) values represent a decrease in 2006
compared to 2005, the variability of operations may be responsible for these decreases. Many
factors influence the decrease in these dose values, and thus, these numbers could not be
normalized based on production rates or inventory.
Cotter Corporation Cañon City Milling Facility 1 June 15, 2007
2007 Independent ALARA Audit Introduction

Cotter Corporation is a nuclear fuel cycle supply company that is authorized by the United States
Atomic Energy Act and licensed by the state of Colorado to engage in activities for the
commercial processing and recovery of uranium, zirconium and vanadium at their Cañon City
Milling Facility (CCMF), located in Cañon City, Colorado. Cotter Corporation is a General
Atomics (GA) affiliate headquartered in Denver, Colorado. Uranium milling is a highly
regulated industry governed by the conditions and requirements specified in the radioactive
material license. In the State of Colorado, the Nuclear Regulatory Commission (NRC) has
discontinued licensing responsibilities, and the Colorado Department of Public Health and
Environmental (CDPHE) has assumed these responsibilities. The CDPHE has the responsibility
for the licensing and use of radioactive materials in Colorado under the Radiation Control Act
(Title 25, Article 11) and the State of Colorado Rules and Regulations pertaining to Radiation
Control (6 CCR 1007-1).

As a condition of the Cotter Radioactive Materials License issued by the CDPHE (License
Number COLO.396-01, Amendment Number 41, Order on Consent 05 08-24-01 and Addendum
No. 1 to Order on Consent 05 08-24-01), License Condition 10.3.2 states, “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:

• the radiation, hazardous materials, and safety programs related to radioactive materials
and byproduct materials (including chemicals used in the milling process) are adequate,
• the quality assurance program is adequate,
• any upward trend is developing in personnel exposure for an identifiable category of
worker or type of operation or effluent release,
• any exposure or effluent might be lowered under the concept of ‘as low as reasonably
achievable’ (ALARA), and
• equipment for effluent and exposure control is being properly used, maintained, and
inspected.”
Scope

Cotter Corporation contracted URS Corporation (URS) to conduct this independent audit in
accordance with the license provisions and provide a detailed report to be included in the Cotter
Corporation Annual Report to be submitted to the CDPHE by June 30, 2007. The scope of the
audit was focused on elements of licensed operations that have potential radiological aspects to
its workers and the environment. After a review of the Cotter Corpora