Jim Cain RSO address:

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Ellen Anthony
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Name: Cotter Corporation License Number: CO

Box 1750, Cañon City, CO 81215 Radiation Safety Officer: Inspection Report Number: 3690116 License Expiration Date: Valid until terminated License Category: 14A RSO phone number: (719) 275-7413 Ext.

com Management Contact: Steve Cohen Location phone number: (719) 275-7413 Address/Location of Inspection: Cotter Cañon City Milling Facility, Cañon City, CO 81215 Inspectors: L = lead, A =

1 Name: Cotter Corporation License Number: CO , Amendment: 54 Doing business as: Inspection ID: Address: Cotter Cañon City Milling Facility, P.O. Box 1750, Cañon City, CO Radiation Safety Officer: Inspection Report Number: License Expiration Date: Valid until terminated License Category: 14A RSO phone number: (719) Ext. 212 Jim Cain RSO address: Management Contact: Steve Cohen Location phone number: (719) Address/Location of Inspection: Cotter Cañon City Milling Facility, Cañon City, CO Inspectors: L = lead, A = accompanying 1. Shiya Wang, L Inspection Type: Routine Complete Inspection: ( x ) Yes ( ) No Date of Inspection: September 22-23, 2016 Date of Closeout: September 23, 2016 Inspection: ( x ) Announced ( ) Unannounced Inspection Results: Apparent Violations: 1 Repeat Violations: 0 Items of Concern: 1 Recommendations: 0 ( ) No violations cited, clear form 59 issued at inspection closeout ( ) Apparent violations, form 59-1 Compliance Inspection Report issued at inspection closeout ( ) Form 59-3 Compliance Inspection Report Supplemental Information issued at inspection closeout ( x ) Apparent violations, ice of Apparent Violation letter issued ( x ) Written response required from licensee Last inspection date: 10/6-7/2015 By: Shiya Wang Number of Violations: 0 This Report Consists of Page 1 through Page ( 11 ) with ( 0 ) attachments Inspector s Signature(s) Date Reviewer's Signature Date /26/ /01/2016 : Page 1 of 11 FILE SECTION 5

2 Inspection Report: Cotter Corporation Page 2 of 11 Apparent Violations 1. License Conditions 10.E and 10.F authorize Cotter to possess and use liquid and solid standard sources for laboratory calibrations. License Condition 12.C requires using and storing these materials in a manner that will preclude access or use by unauthorized personnel. Contrary to these requirements, the liquid standard sources are placed on the laboratory bench top and the solid sources are stored in an unlocked open shelf in the counting room of the laboratory. Cotter shall secure these materials when they are not in use or when there is no authorized user present. REPEAT ITEM Items of Concern: Items of Concern / Recommendations 1. Active erosion was identified downstream and adjacent to the long silt fence on the Cotter property east of the restricted area. Cotter should mitigate this feature before the next inspection by the Department or before it is impacting the silt fence, whichever is earlier. Persons Interviewed: Name, position, type of interview ("O" Opening interview; "I" Interview; "C" Closeout) 1. Stephen Cohen, Mill Manager, OIC 5. JoAnne Ary, Document Control Coordinator, OIC 2. Jim Cain, RSO, OIC 6. Mark Currey, ARSO, O 3. Issac Gonzalez, ARSO in training, OIC 7. Mitch Abbate, Lab Manager, I 4. Will DeSpain, Security, I 8. Nathaniel Lambert, Quality Assurance Manager, I Pre-inspection Items Date 1. Reviewed license 9/15/16 2. Reviewed license application, amendments since last application 9/15/16 3. Reviewed SS&D sheet for device / sealed sources (if applicable) N/A 4. Reviewed last inspection report 9/15/16 5. Reviewed any incidents or Orders (if applicable) 9/15/16 6. Reviewed financial assurance correspondence (see Parts and ) 9/15/16 7. Contacted program assistant for past due fees N/A 8. Contacted program assistant for any general licensed items 9/15/16

3 Inspection Report: Cotter Corporation Page 3 of Radiation Safety Officer A. Named on license X No change since the last inspection B. Refresher training X C. Level of involvement in program X D. Knowledge and experience X E. Management support X 2. Radioactive Material Users A. Authorized users on license X As of September 2016, 15 on-site employees. All employees are authorized users on the license. B. Supervised Users X 4 new employees: Steve Cohen (Mill Manager), 1. Training and experience X Nate Lambert (QA Manger), 2. Documentation of Training X Issac Gonzalez (ARSO in training), and 3. Supervisor Level of Involvement X Lori Simpson (Document control) 3. Other Persons On-site A. Administrative Personnel X 1. training X 2. dose limits / dose assessments X B. Security Personnel X 1. training X 2. dose limits / dose assessments X C. Contracted Labor X 1. training X 2. escorts / supervision X 3. dose limits / dose assessments X 4. site entry / exit logs X 5. contamination surveys X D. Site Visitors X 1. training X 2. escorts / supervision X 3. dose limits / dose assessments X 4. site entry / exit logs X 5. contamination surveys X 4. Incidents / Unsafe Conditions A. Non-reportable events / conditions X 1. Cause Investigation X 2. Timely Resolution X 3. Measures to prevent reoccurrence X B. Reportable events / conditions X Spills: 08/01/2016, 11/25/2015, 12/3/ Documentation / Records X Spill locations were inspected. 2. Reported to CDPHE X 3. Timeliness of reporting X 4. Investigation / Resolution X 5. Measures to prevent reoccurrence X Pipeline replacement proposal submitted. 5. Radioactive Materials Inventory A. Authorized Radionuclides / Form X Tailings, Zirconium ore, check/lab std sources B. Within Licensed Possession Limit X C. Receipt Records X D. Process Records X E. Placement into Repository Cell X F. Transfer Records X G. Disposal Records X

4 Inspection Report: Cotter Corporation Page 4 of Radioactive Sealed Sources A. Current Inventory Documented X Remaining sources are check, calibration, lab B. Authorized Radionuclide X standard, and generally licensed sources. C. Authorized Manufacturer / model X D. How Used X Apparent Violation #1 E. Gauge Relocation X No gauges. 1. surveys at new location X F. Receipt Records X G. Transfer Records X H. Disposal Records X I. Leak Tests X 1. Personnel taking wipe sample X 2. Procedure X 3. Proper Analysis X 4. Frequency X 5. Leak Test Records X 7. Posting A. ice to Employees X Posted in the exit survey trailer B. License (or location) X C. Regulations (or location) X D. Radiation Signs X 1. Fence and Gate Areas X 2. Use Area X 3. Storage Area X 8. Training Content and Duration A. Production Workers X Training for the new ARSO in training adequate. B. Administrative Staff X C. Janitorial X D. Security Personnel X E. Contracted Service Providers X F. Site Visitors X G. Refresher Training X H. Course Instructor X 9. ALARA Program A. Program Implementation X B. Annual Program Review X In annual reports C. RSO Facility Audits / Reports X D. Correcting Program Deficiencies X E. Records X 10. Transportation of RAM A. Shipping Papers X No RAM transfer B. Appropriate Packaging X C. Package Labeling X D. Package Placement in Vehicle X E. Package Surveys and Wipe Tests X F. Security X G. Placards X H. Vehicle Survey X I. Emergency Response X

5 Inspection Report: Cotter Corporation Page 5 of Dose Monitoring A. NVLAP Supplier X United States Dosimetry Technology, Inc. B. Dosimeter Type & Exchange Freq. X TLD, quarterly C. Investigations / Action Levels X Highest quarterly TLD reading = 50 mrem D. Dosimeter Storage Location X E. Direct Reading Pocket Dosimeter X 1. calibration X F. Timely Processing X G. Lost Dosimeters X One (Nate Lambert) H. Bioassay X 1. Sample Collection X 2. Frequency of Tests / Sampling X Monthly 3. Timely Laboratory Analysis X All reading < the reporting limit of 5 ug/l 4. Adequate Level of Detection X 5. How Bioassay Results Are Used X 6. Problems / Corrective Actions X 7. Records X 8. Exceed Soluble U Intake Limits N I. Determining Worker s CEDE X List of air monitoring locations were reviewed 1. Methods and Assumptions X Using ICRP 60 s DCF; No BZ samples. 2. Identify Radionuclide and Class X Highest quarterly result=47mrem (record staff*) 3. Frequency of Determinations X Quarterly 4. Workers Exceeding Intake limits N * Record room Rn WL ~ 5% of DAC. Cotter is 5. Investigation / Corrective Action X looking into methods to reduce the radon level. 6. Records X J. Determining Worker s TEDE X 1. Methods and Assumptions X 2. Frequency of Determinations X Quarterly 3. Records X K. Declared Pregnant Workers X None L. Reports to Workers X Provided annually in one of the quarterly meetings M. Reports to CDPHE X In annual reports 12. Occupational Dose Records A. Prior Occupational Dose Records X B. Year End Dose Records X C. Over Exposures X None D. Embryo/fetus doses X None 13. Public Dose Determinations A. On-Site Public Access Areas X Cotter submitted amendment request to release 1. contamination levels X A few areas on site for unrestricted access. 2. exposure rates X 3. assumptions & dose calculations X 4. records X B. Off-Site Doses to Public X 1. Inhalation Pathway X a.) Identify radionuclides & class X b.) Air emission concentrations X c.) Wind-blown materials X d.) Air Sampling and Analysis X Cotter started new air radon sampler (Rapidos) e.) Public Exposure Scenarios X since 3 rd quarter of f.) CEDE Dose Calculations X g.) NESHAPS X The impoundments are not operational 2. Dose rates at site boundary X 3. TEDE dose calculations X Annually 4. records X In annual reports

6 Inspection Report: Cotter Corporation Page 6 of Operating / Handling Procedures A. Receipt of Materials X 1. Surveys X 2. Records X B. Storage of Materials X Apparent Violation #1 1. Materials Received for Processing X No processing and no products; the mill is no 2. Products X longer operating. 3. Waste Materials X 4. Access / Security for storage area X C. Use of Radioactive Materials X 1. Handling Precautions X 2. Use area set up X 3. Safety equipment X 4. Time, Distance, Shielding X 5. Radiation Work Permits (RWP) X One for contractors of sand box experiment D. Transfer of Materials X No transfer 1. Authorized recipient X 2. Recipient License on file X 3. Records X E. Disposal of Radioactive Materials X 1. Sewer Disposal/Effluent Levels X 2. Placement in the Impoundment X 3. Transfer for Disposal X 4. Authorized Recipient X 5. Disposal Records X F. Emergency Procedures X The emergency procedure is under revision 1. Contacts and Emergency No. X 2. Response Procedures X 3. Decontamination Methods X 4. Investigation / follow-up X 15. Radiation Detection Equipment A. Survey Instruments X 1. Appropriate Detection Capability X 2. Instruments Available X 3. Calibration X 4. Correction Charts or Graphs X 5. Check and Calibration Sources X 6. Survey Procedures X 7. Records X B. Liquid Scintillation Counters X C. Well Counters X D. Wipe Counters X E. Other X 16. Radiation Measurement Lab A. Analysis of Air Filters X 1. Procedures X 2. Equipment X 3. Limit of Detection X B. Bioassay Sampling Analysis X 1. Procedures X 2. Equipment X 3. Limit of Detection X C. QA / QC methods X Under revision through the AOC/SOW process D. Split-Sample Analysis at other lab X E. Contamination Control X

7 Inspection Report: Cotter Corporation Page 7 of Radiation Safety Precautions A. No food or tobacco in use areas X B. RSO Designated break areas X C. Routine Surveys of break areas X List of routine survey location was reviewed 1. survey methods and frequency X 2. action levels X 3. records X D. Surveys of Personnel X 1. entering break/eating areas X 2. departing the facility X 3. action levels X 4. records X E. Surveys of Equipment X 1. removed from contaminated area X 2. departing the facility X 3. action levels X 4. records X F. Contamination Control X 1. Labeling X 2. Movement of Materials X 3. Coverings, spill containers, etc. X 4. watering surfaces X Dust control using water trucks 5. action levels X Certified dust opacity observer available on site G. Personnel Apparel X H. Respiratory Protection Program X 1. Protective Equipment Used X No respirator was used since last inspection 2. Physical and Fit Test X PPE equipment available 3. Policies for Respirator Use X 4. Written Procedures X 5. Equipment Maintenance X 6. Equipment Storage X 7. Worker Training X 8. Records X I. Breathing Zone Sampling X No BZ samples were taken since last inspection 1. Equipment Type X Equipment available 2. Equipment Calibration X 3. Equipment Serviceability X 4. Written Procedures X 5. Sample Analysis X a.) Methods X b.) LLD X c.) Timeliness of Analysis X 6. Data collection and Use X J. Surveys of Public Access Areas X 1. contamination levels X 2. exposure rates X 3. action levels X 4. records X Daily perimeter was observed on 9/22/16 K. Security X Other security: locked/alarmed buildings 18. Ventilation A. Hood flow rates X B. Filter exchanges X C. Effluent Concentrations X 19. X-ray equipment Innova Model Alpha 400 backscatter X-ray Series No A. registered X Recertified in March 2016

8 Inspection Report: Cotter Corporation Page 8 of Waste Impoundment X Cotter conducted two impoundment inspections following NRC RG 3.11 on November 2015 and April Ground Water X 22. Engineering Controls A. Silt Fences X IOC #1, Also see attached picture below B. C. 23. Financial Assurance Parts , A. Annual Report X B. Annual published public notice X General Inventory Radionuclide Form of material Activity in inventory Status of materials See Annual Report Sealed Source Inventory Isotope Manufacturer Model Serial Number Assay Activity Assay Date See license

9 Inspection Report: Cotter Corporation Page 9 of 11 Location: Diagrams and / or monitoring notes Inspector s survey instrument: RADEYE, Serial No. 240, Calibration date: March 23, 2016 Ludlum Model 3, Serial No , Calibration date: July 19, 2016, with Model 44-9 GM pancake probe Gamma readings on-site are mostly background.

10 Inspection Report: Cotter Corporation Page 10 of 11 Additional Scope: 1. The license Amendment 54 was issued in Dec 2014 to change the license from milling to decommissioning. 2. The facility is in decommissioning; however, no decommissioning or remediation will be conducted until completion of all AOC/SOW tasks. 3. Routine activities since last inspection include routine occupational and environmental monitoring, dust control, operation of the SCS pumpback system, regular site maintenance, and site security inspections. Non-routine activities since last inspection include works associated with procedure updates and preparation of AOC/SOW deliverables, maintenance works associated with the spills, SCS pumpback system, and silt fences, preparation works associated with the proposed unrestricted areas, and sand box experiment. 4. The short silt fence has been filled up and damaged (see the attached pictures). The sediment buildup is at or above 1 foot. This was resulted in a precipitation event between August 12-14, 2016 (weekend) that resulted in 1.25 precipitation within a very short period of time. The buildup was discovered on August 15, The security staff who does the silt fence inspection was interviewed and he indicated that there was very little buildup before this rain event, verifying that this buildup was due to one single event. Cotter notified us after this was discovered. During this inspection, the sediment has not been removed and the fence has not been repaired, because Cotter thinks that the silt fence is not effective and is proposing to replace the silt fence with a check dam. Cotter submitted this proposal to us on 09/30/ Cotter has stopped seeking buyers for the Zirconium ore. The disposal of the ore will be determined through the RI/FS process in accordance with the AOC/SOW. 6. Cotter had two violations from the annual inspection in 2012; one was associated with the lab LIMS system and the other was associated with the emergency response procedure. The lab LIMS violation is being addressed through the revision of the QAPP under the AOC/SOW. The emergency response procedure is being incorporating into the health and safety plan required under the AOC/SOW. Therefore, since both violations are being addressed by AOC/SOW, they are not reviewed during this inspection.

11 Inspection Report: Cotter Corporation Page 11 of 11 Picture 1: The erosion feature at the long silt fence location: Picture 2 and 3: The sediment buildups at the short silt fence location:

TEMPLE UNIVERSITY ENVIRONMENTAL HEALTH AND RADIATION SAFETY

TEMPLE UNIVERSITY ENVIRONMENTAL HEALTH AND RADIATION SAFETY Page 1 of 9 ISSUED: 5/00 REVISED: 08/06 Introduction Purpose: In accordance with applicable regulations and Temple University, this policy was developed to minimize exposure to Ethylene Oxide. Applicability