APPROVAL PAGE PROCUREMENT APPROVALS

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Page: 1 of 6 APPROVAL PAGE PROCUREMENT EC: Date: APPROVALS QA Manager: Date: Program Manager: Date:

Page: 2 of 6 1.0 PURPOSE PROCUREMENT The purpose of this procedure is to describe the documentation of process for procurement of goods and services. The objective of this procedure is to ensure that the goods and services procured meet the appropriate quality requirements and that the procurement process is documented. 2.0 SCOPE This procedure applies to procurement of goods and services for the Cotter Corporation, Canon City Milling Facility. 3.0 REFERENCES 3.1 Current Colorado Radioactive Materials License 3.2 Cotter Corporation, Canon City Milling Facility, Quality Management Plan (QMP), current version. 3.3 Cotter Corporation, Canon City Milling Facility, Quality Assurance Project Plan (QAPP), current version. 3.4 Purchase Requisition Form (Blue Sheet). 3.5 Typical Statement of Work Format. 3.6 Typical Contract Template. 4.0 DEFINITIONS 4.1 Requestor An individual or group with the Cotter organization requesting purchase of physical items or services. 4.2 Group A qualified individual who performs monitoring, collects samples, or otherwise performs functions prescribed in the QMP or QAPP. Key Individuals (a quality assurance designation) are also described in Section 4 of the QAPP. Designated Assistants to the Radiation Safety Officer (a license condition designation) are described in Radioactive Materials License Condition 14.5. 4.3 QA and QC Requirements Specific DQOs or other criteria identified in appropriate planning documents specifying performance criteria designed to assess and ensure that data quality or quality of services result in products that meet their intended purposes. 5.0 EQUIPMENT AND MATERIALS None

Page: 3 of 6 6.0 HEALTH AND SAFETY None 7.0 RESPONSIBILITY 7.1 The Requestor 7.1.1 Completing the Purchase Requisition Form (Blue Sheet) or Statement of Work (SOW), depending on the nature of the item(s) or service(s) requested. 7.1.2 Identifying the appropriate QA and QC requirements for the item(s) or service(s) requested from appropriate planning documents. 7.1.3 Documenting the source of the appropriate QA and QC requirements for the item(s) or service(s) requested in the description line of the Purchase Requisition Form (Blue Sheet) or within the SOW. If no specific criteria are identified then it should be noted that no specific criteria or requirements apply. 7.1.4 Verifying draft purchase agreement or contract is accurate, complete, and clearly describes the item or service needed. 7.1.5 Verifying that responses to solicitations satisfy all technical and quality requirements. 7.1.6 Verifying that purchased goods and services meet the technical and quality requirements. 7.1.7 Identifying technical and/or quality related deficiencies and engaging the QA Manger in the corrective action process. 7.2 The Purchasing Group 7.2.1 Verifying that QA and QC requirements are identified or noted that none apply in the Purchase Requisition or SOW. 7.2.2 Drafting contract or purchase agreement. 7.2.3 Soliciting suppliers or service provider for requested item(s) and/or service(s). 7.2.4 Ensuring that the purchased item(s) comply with the identified QA and QC requirements, or, in the case of purchased service(s), that reasonable and appropriate metrics for assessing compliance with identified QA and QC requirements are incorporated into the agreement/contract. 7.3 The QA Manager or designee 7.3.1 Performing periodic Technical system audits (TSA) of the procurement process.

Page: 4 of 6 7.0 S 7.3.2 Ensure that appropriate and timely corrective actions are identified, implemented and are effect. 7.1 REQUEST FOR PROCUREMENT 7.1.1 Staff prepares Purchase Requisition form (Blue Sheet) or Statement of Work (SOW). 7.1.2 Preparation includes identification of the quantity and description of each item or service, identification the specific technical and quality requirements and the planning document source (e.g., title and date of QAPP and/or specific DQO, if applicable) for each item or specifically notes for each item that there are no specified QA or QC requirements. 7.1.3 For requests for procurement of services, preparation includes performance periods, specific deliverables, deliverable schedule and cost guidance with requested schedule for procurement. 7.1.4 Purchase Requisition form or SOW is routed to the Group or their designee. 7.2 PROCUREMENT REQUEST REVIEW 7.2.1 Group staff or their designee review the Purchase Requisition or SOW for the following elements: documents are complete and accurate clearly describes the item or service needed technical and quality requirements are identified or explicitly noted that none apply. 7.2.2 Group drafts procurement agreement or contract based on the Purchase Requisition or SOW. 7.2.3 For routine supplies and services, procurement may proceed with no additional review. 7.2.4 For non-routine supplies and services, procurement Group routes the draft procurement agreement or contract to the originating group Project Manager or their designee. 7.3 VERFIICATION OF PROCUREMENT TECHNICAL AND QUALITY REQUIREMENTS 7.3.1 Originating group Project Manager reviews the draft procurement agreement or contract to ensure that it clearly describes the item or

Page: 5 of 6 service needed and describes the associated technical and quality requirements. 7.3.2 Originating group Project Manager corrects the draft as needed, documents approval of the revised agreement or contract with signature and date and routes approved agreement or contract to Group. 7.3.3 For all non-standard contracts, approved contracts are routed to corporate for contractual review. 7.4 VERIFICATION OF SOLICITATION CONFORMANCE TO TECHNICAL AND QUALITY REQUIREMENTS 7.4.1 Solicitations (bids) for items and/or services are received by the Group and routed to the request originating group. 7.4.2 The request originating group reviews the solicitations to ensure the supplier s conformance to the technical and quality requirements including supplier s quality-related documents (e.g., QAPP, QMPs, etc.). 7.5 VERIFICATION OF CONFORMANCE TO TECHNICAL AND QUALITY REQUIREMENTS 7.5.1 For physical items, the Requestor verifies the items received match the packing list and the agreement or contract, signs and dates the packing slip and routes it to the Group. 7.5.2 The Group verifies the invoice matches the packing slip and processes the invoice for payment. 7.5.3 For contracted services, the Group performs the contract management and verifies that unit rates and services in the invoices are consistent with the agreement/contract. 7.5.4 The Requestor performs as the project manager and verifies that services provided meet the specified technical and quality requirements as per the applicable planning documents (e.g., QMP, QAPP, FSP, etc.). 7.6 CORRECTVIE ACTIONS 7.6.1 Both the Group and the Requestor are authorized and responsible for identifying and documenting any technical or quality deficiencies in procured items or services. 7.6.2 The CAIR System is to be followed (QAPP, Section 4) for identifying deficiencies and requesting, implementing and verifying that corrective actions are implemented in a timely manner and are effective.

Page: 6 of 6 Exhibit 3.2.1 Purchase Requisition Form