July 10, 2002

MEMORANDUM TO: Luis A. Reyes, Regional Administrator

Region II

FROM: Carl J. Paperiello /RA/

Deputy Executive Director for

Materials, Research and State Programs

SUBJECT: INTEGRATED MATERIALS PERFORMANCE EVALUATION

PROGRAM FOR REGION II

On June 5, 2002, the Management Review Board (MRB) met to consider the proposed final

Integrated Materials Performance Evaluation Program (IMPEP) report for Region II (RII). The

MRB found the RII program adequate to protect public health and safety.

Based on the results of the current IMPEP review, the next full review will be in approximately

four years.

I appreciate the courtesy and cooperation extended to the IMPEP team during the review and

your support of the program. 

Attachment: Final IMPEP Report 

cc: B. Mallett, RII

D. Collins, RII

CONTACT: Charles Cox, NMSS/IMNS

 (301) 415 -6755
MEMORANDUM TO: Luis A. Reyes, Regional Administrator July 10, 2002

Region II

FROM: Carl J. Paperiello /RA/

Deputy Executive Director for

Materials, Research and State Programs

SUBJECT: INTEGRATED MATERIALS PERFORMANCE EVALUATION

PROGRAM FOR REGION II

On June 5, 2002, the Management Review Board (MRB) met to consider the proposed final

Integrated Materials Performance Evaluation Program (IMPEP) report for Region II (RII). The

MRB found the RII program adequate to protect public health and safety.

Based on the results of the current IMPEP review, the next full review will be in approximately

four years.

I appreciate the courtesy and cooperation extended to the IMPEP team during the review and

your support of the program. 

Attachment: Final IMPEP Report

cc: B. Mallett, RII

D. Collins, RII

CONTACT: Charles Cox, NMSS/IMNS

 (301) 415-6755

 DISTRIBUTION :

IMNS r/f NMSS r/f PDR YES X NO 

IMPEP Master File LRakovan, STP KSchneider, STP GDeegan

Mvirgilio,NMSS JGreeves, DWM CReamer, DWM LCamper, DWM

RPierson, FCSS ELeeds, FCSS FBrown YChen, FCSS

GPurdy, DWM AHenry, DWMJ Thompson, Arkansas

 ADAMS-ML021690576

OFC MSIB MSIB IMNS NMSS DEDMRS

NAME CCox JHickey DCool MVirgilio CPaperiello

DATE 6/14/02 6/17/02 6/ /02 6/25/02 07/10/02

* see previous concurrence

OFFICIAL RECORD COPY
INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM

REVIEW OF NRC REGION II PROGRAM

March 18-22, 2002

FINAL REPORT

U.S. Nuclear Regulatory Commission
Region II Final Report Page 1

Attachment 1

1.0 INTRODUCTION

This report presents the results of the review of the Region II (RII) nuclear materials program. 

The review was conducted during the period of March 18-22, 2002, by a review team comprised

of technical staff members from the U.S. Nuclear Regulatory Commission (NRC) and the State 

of Arkansas. Team members are identified in Appendix A. The review was conducted in

accordance with the "Implementation of the Integrated Materials Performance Evaluation

Program and Rescission of a Final General Statement of Policy," published in the Federal

Register on October 16, 1997, and the November 5, 1999, revision to NRC Management

Directive (MD) 5.6, "Integrated Materials Performance Evaluation Program (IMPEP)." 

Preliminary results of the review, which covered the period February 1998 to March 2002, were

discussed with RII management on March 22, 2002.

A draft of this report was issued to RII for factual comment on April 18, 2002. RII responded in

a memorandum dated May 20, 2002. The Management Review Board (MRB) met on June 5,

2002, to consider the proposed final report. The MRB found the RII radiation control program

was adequate to protect public health and safety.

The RII nuclear materials program is administered by the Director, Division of Nuclear Materials

Safety (DNMS), who reports directly to the Regional Administrator. The DNMS organization

chart is included as Appendix B. At the time of the review, the RII nuclear materials program

regulated more than 800 specific material licenses.

In preparation for the review, a questionnaire addressing the common and non-common

indicators was sent to RII on January 17, 2002. RII provided a response to the questionnaire

on February 28, 2002. A copy of the completed questionnaire response can be found on

NRC’s Agency-wide Document Access and Management System (ADAMS) using Accession

Number ML02101006.

The review team's general approach for conduct of this review consisted of: (1) examination of

RII’s response to the questionnaire; (2) analysis of quantitative information from the licensing,

inspection, resource utilization, and allegation databases; (3) technical review of selected

licensing, inspection, incident response, allegation, and decommissioning actions or files; (4)

field accompaniments of two RII inspectors; and (5) interviews with staff and management to

answer questions or clarify issues. The team evaluated the information that it gathered against

the IMPEP performance criteria for each common and non-common indicator and made a

preliminary assessment of RII’s performance.

Section 2 below discusses RII’s actions in response to recommendations made following the

previous review. Results of the current review for the IMPEP common performance indicators

are presented in Section 3. Section 4 discusses results of the applicable non-common

indicators, and Section 5 summarizes the review team's findings and recommendations. 

Recommendations made by the review team are comments that relate directly to program

performance by RII. A response is requested from RII to all recommendations in the final

report.
Region II Final Report Page 2

2.0 STATUS OF ITEMS IDENTIFIED IN PREVIOUS REVIEWS

During the previous routine IMPEP review, which concluded on February 13, 1998, four

recommendations were made (some directed to RII: others to NRC Headquarters) and the

results transmitted to Luis A. Reyes, Regional Administrator, RII in the final IMPEP report on

May 7, 1998. The team’s review of the current status of these recommendations is as follows:

(1) RII should assure its inspectors make use of survey instruments calibrated at

proper frequencies.

Current Status: In response to this recommendation, RII reminded staff of the

requirement to used calibrated survey instruments and developed a calibration

and inventory program. A notice was posted in the instrument storage area to

remind inspectors to check the calibration of their instrument to ensure it remains

in calibration during the inspection. No further cases of inspectors using survey

instruments that were out of calibration were found by reviewers during the

IMPEP review of inspection files and inspection accompaniments. This

recommendation is closed.

(2) RII should develop and implement an effective periodic, in-depth peer review

type of quality assurance program for licensing actions. 

Current Status: In response to this recommendation, RII established a periodic

peer review through a Regional Office Instruction (ROI) in 1998. The peer

review is a semi-annual review of completed licensing actions by license

reviewers and DNMS managers. These reviews are intended to be a quality

check to determine the appropriateness of license conditions and documents

references, identify any grammatical or clerical errors, deficiencies in the license

application, and completeness of licensing files. In addition, RII now requires

licensing actions to undergo an independent review by a senior license reviewer

prior to issuance of the license action. The 2000 IMPEP self assessment

identified further inconsistencies and errors. However, the periodic peer review

reduced the magnitude of the problem and the additional senior license reviewer

check prior to issuing the action is an aggressive corrective action and

recognized as a good practice during this IMPEP review. This recommendation

is closed.

(3) RII should ensure that the fuel cycle inspection program is not adversely affected

when the current Inspection Follow-up System (IFS) program for tracking

inspections results is terminated.

Current Status: RII is using the Plant Issues Matrix System (PIMS) to effectively

track inspection findings, and the inspection program has not been adversely

affected. This recommendation is closed. 

(4) Office of Analysis and Operational Data provide supplementary training to Office

of Nuclear Material Safety and Safeguards (NMSS), Office of State Programs,

the regions, and Agreement States, to make the Nuclear Material Event
Region II Final Report Page 3

Database (NMED) system more accessible and usable for NRC and Agreement

State staff.

Current Status: Significant improvements were made in the NMED system

which is web based and the regions have been trained on the system. Review of

inspection records, observations during the inspector accompaniments, and

interviews with inspectors indicate that the NMED system is being used by the

inspection staff. This recommendation is closed. 

3.0 COMMON PERFORMANCE INDICATORS

IMPEP identifies five common performance indicators to be used in reviewing both NRC

Regional and Agreement State programs. These indicators are: (1) Status of Materials

Inspection Program; (2) Technical Quality of Inspections; (3) Technical Staffing and Training;

(4) Technical Quality of Licensing Actions; and (5) Response to Incidents and Allegations. 

3.1 Status of Materials Inspection Program

The team focused on four factors in reviewing this indicator: inspection frequency, overdue

inspections, initial inspection of new licenses, and timely dispatch of inspection findings to

licensees. The review team’s evaluation is based on the RII questionnaire responses relative to

this indicator, data gathered independently from NRC’s Licensing Tracking System (LTS) and

other NMSS and RII statistical databases, the examination of completed licensing and

inspection casework, and interviews with RII managers and staff.

Review of RII’s inspection priorities shows that, as with the 1998 review, the RII inspection

frequencies for various types or groups of licenses are consistent with program office guidance,

as provided in Inspection Manual Chapter (IMC) 2800. This was verified by cross-checking the

actual inspection frequencies entered in the LTS with the IMC 2800 frequencies. In all cases

reviewed, the inspection frequencies in the database match the IMC 2800 frequencies. RII is

also actively implementing a provision in IMC 2800 to reduce or extend individual licensee

inspection schedules, based on the licensee’s inspection findings and previous performance.

At the time of this IMPEP review, RII had no core inspections overdue, in comparison with the

IMC 2800 guidance. The team noted that during the 1998 IMPEP review, RII had no core

inspections overdue. Review of monthly NMSS statistical reports rarely showed any RII core

inspections overdue over the past four years.

While onsite, the team obtained a listing of all new licenses issued by RII during the review

period. The review team checked inspection dates for a sample of 16 of 165 new licenses

issued from February 1998 through February 2002. Of the 16 sampled, two were not inspected

within the first six months following licensees beginning licensed activity or having received

licensed material. However, both were inspected within eight months of beginning licensed

activities and within a year of license issuance. The remaining 14 licensees were inspected

within the appropriate six month or one year requirement as specified in IMC 2800. 
Region II Final Report Page 4

Review of RII’s reciprocity records indicate that RII failed to meet the previous criteria of 30

percent for Priority 3 inspections in 2000 (2 fewer than required) and 50 percent for Priority 1

inspections in 1998 (2 fewer than required). However, RII met the new criteria last year.

The team also evaluated the timeliness of RII’s issuance of inspection findings. Based on data

from RII’s tracking system, 96 percent of the routine inspection findings are issued to licensees

within 30 days. For all inspection findings, the average time to issue inspection findings during

the review period was 21 days from completion of the inspections. The review team reviewed

casework for 24 different inspection reports for the review period, and found that 22 had

inspection findings transmitted to the licensee within 30 days. The remaining two were issued

between 34 and 63 days. The review team determined that RII continues to perform

appropriately with respect to the timeliness of inspection report issuance to licensees.

The team reviewed an LTS generated data set comparing the number of licensees in each

State with the number of inspections conducted by RII since the last IMPEP review. There was

no geographic bias on the part of RII in scheduling inspections, as required by IMC 2800.

During the review, the team discussed with RII the requirement in IMC 2800 to inspect at least

50 percent of the permanent field offices specified on a license over the course of the licensee’s

inspection cycle. The team determined that RII was aware of the requirement and had a

system in place to identify the need for field office inspections. The review team verified that at

least 50 percent of permanent field offices were being inspected for the inspection records

reviewed.

Based on the IMPEP evaluation criteria, the review team recommends that RII’s performance

with respect to the indicator, Status of Materials Inspection Program, be found satisfactory.

3.2 Technical Quality of Inspections

The team evaluated the inspection reports, enforcement documentation, and inspection field

notes and interviewed inspectors for 24 materials inspections conducted during the review

period. The casework included 14 of RII’s materials license inspectors, and covered

inspections of various license types, including: source material medical institution, academic

broadscope, medical private practice, nuclear medicine, fixed gauges, radiography, well

logging, medical institution broad, research and development broad, and irradiator licensees. 

Appendix C lists the inspection casework files reviewed for completeness and adequacy with

specific comments. 

Based on the casework, the team noted that routine inspections are covering all aspects of the

licensees’ radiation programs. The review team found that inspection reports were thorough,

complete, consistent, and of high quality, with sufficient documentation to ensure that licensee’s

performance with respect to health and safety was acceptable. The documentation supported

violations, recommendations made to the licensee, unresolved safety issues, and discussions

held with the licensee during exit interviews. Team inspections were performed when

appropriate and for training purposes.

During the onsite review, the team determined that RII is performing inspections of materials

licensees in accordance with IMC 2800. Inspectors used the appropriate inspection field note

forms on all the files reviewed, with a single, non-consequential, exception. The review team
Region II Final Report Page 5

observed that inspectors were reviewing previous open items and past violations during the

inspections. For the cases reviewed, the correct inspection documentation was used. 

Specifically, NRC Form 591s were used unless the findings warranted a written letter or

escalated enforcement actions were involved. 

During this review period, the team determined that DNMS Branch Chiefs are accompanying all

inspectors at least once each year. Inspectors receive verbal feedback at the time of the

inspection accompaniments, and a portion of the inspectors’ annual performance appraisals

address their inspection skills. 

The team found that RII maintains a sufficient number of various models of survey instruments

to perform radiological surveys of materials licensees. The review team examined RII’s

instrumentation and observed that the survey instruments in RII’s office at the time of the onsite

review were calibrated and operable. RII contracts with a commercial radiological service

company to provide calibrations, and staggers the calibration dates. The calibration frequency

for all instruments is one year which is consistent with the current NMSS policy.

Two RII inspectors were accompanied during inspections by a review team member during the

periods of February 19 -21, 2002, and February 25-27, 2002. Inspection accompaniments were

conducted as follows: a mobile nuclear medicine license, a fixed gauge user, a university with a

special nuclear material license, and a medical broadscope license who was also authorized to

conduct intervascular brachytherapy. These accompaniments are identified in Appendix C. All

inspectors performed in-depth examinations of the licensees’ facilities; interacted with licensee

personnel; observed licensees’ activities; and reviewed pertinent records. In all cases, the

inspectors demonstrated a performance based inspection approach with appropriate technical

skills and professional inspection techniques. The inspectors’ performance were adequate to

assess the radiological health and safety of the licensees’ programs.

Based on the IMPEP evaluation criteria, the review team recommends that RII’s performance

with respect to the indicator, Technical Quality of Inspections, be found satisfactory.

3.3 Technical Staffing and Training

Issues central to the evaluation of this indicator include the radioactive materials program

staffing level, technical qualifications of the staff, training, and staff turnover. To evaluate these

issues, the review team examined RII’s questionnaire responses relative to this indicator,

interviewed DNMS management and staff, interviewed members of the RII Division of Resource

Management, and considered any possible workload backlogs.

RII’s DNMS staffing has fluctuated during the review period. As RII noted in its response to the

questionnaire, ten new technical staff members have been hired into DNMS since the last

IMPEP review. Two individuals were qualified Reactor Resident Inspectors and one individual

had partial Licensing Reviewer Authority from Region I. Four of the new staff participate in the

Nuclear Safety Intern Program. During the review period, ten DNMS staff members left the

program. Three staff retired, one staff expired, two staff transferred within the Commission,

one staff left the Commission for a utility, and three fuel facility staff moved to the Department

of Energy. DNMS had two Health Physicists, one Fuel Facility Inspector, and one Fuel Facility

Branch Chief vacancies at the time of the onsite review. Entry-level staff are recruited through

the Nuclear Safety Intern Program. The Health Physicists positions were announced in July
Region II Final Report Page 6

2001 and have been subsequently posted in two additional employment announcements. The

Fuel Facility Inspector position was announced June 2001 and has been subsequently posted

in two additional employment announcements. DNMS continues to interview qualified entrylevel applicants in anticipation of staffing needs through the Nuclear Safety Intern Program. 

DNMS includes two Material Licensing/Inspection Branches (MLIB), 1 & MLIB 2,and the Fuel

Facilities Branch. The Branches are currently staffed with 21 direct full time equivalents

(FTEs), supported by 3.5 clerical FTEs, and led by three Branch Chiefs. Including nontechnical overhead positions, DNMS has 33 staff members on-board at the time of the review. 

Funding for direct technical positions comes from NMSS, the Office of State and Tribal

Programs, and the Office of Human Resources.

The review team found a good balance of personnel between licensing and inspection. With

RII’s organization, most technical staff in MLIB 1 and MLIB 2 complete both licensing and

inspection actions, rather than having separate license reviewers and inspectors. The MLIBs

hired four new technical staff since the last IMPEP review and five staff left the program. With

just one exception, all the technical staff in RII were fully qualified or interim qualified inspectors

at the time of the onsite review. The staff member not yet qualified, recently joined RII in July

2001, and has prepared a schedule outlining progress toward earning his qualifications. Of the

11 technical staff members who work on materials issues, six have full signature authority for

licensing actions and one has limited signature authority. The remaining four have no signature

authority for licensing actions, so any licensing work they perform is reviewed and signed by a

supervisor or qualified reviewer. DNMS management tracks the qualifications of their staff in

the DNMS Training Matrix. The Training Matrix tracks all the courses taken, courses needed,

and dates that certain courses are needed for the Division staff. The Matrix is a spreadsheet

version of the qualifications journals. The review team determined that the number of license

reviewers with full or limited signature authority is sufficient to complete RII’s materials licensing

work, and allows for readjustments in the workload between materials licensing and inspection,

as necessary.

The review team examined the training spreadsheet, spot-checked individual inspector’s

qualifications, interviewed human resource staff, reviewed staff training records, and

interviewed managers concerning technical training in accordance with IMC 1246 requirements. 

The technical expertise of the RII staff continues to be a strength of the program. 

Based on the IMPEP evaluation criteria, the review team recommends that RII’s performance

with respect to the indicator, Technical Staffing and Training, be found satisfactory.

3.4 Technical Quality of Licensing Actions

The team examined completed licensing casework and interviewed the staff for 32 specific

licenses involving 40 licensing actions. Licensing actions were evaluated for completeness,

consistency, proper isotopes and quantities used, qualifications of authorized users, adequate

facilities and equipment, and operating and emergency procedures sufficient to establish the

basis for licensing actions. Licenses were evaluated for overall technical quality including

accuracy, appropriateness, license conditions and tie-down conditions. Casework was

evaluated for timeliness, adherence to good health physics practices, reference to appropriate

regulations, documentation of safety evaluation reports, product certifications, or other
Region II Final Report Page 7

supporting documents, consideration of enforcement history on renewals, pre-licensing visits,

peer or supervisory review as indicated, and proper signature authorities. The files were

checked for retention of necessary documents and supporting data.

The licensing casework was selected to provide a representative sample of licensing actions

which were completed during the review period. The sampling included the following types:

broad academic; broad medical; fixed and portable gauges; general license manufacturing and

distribution; industrial radiography; irradiator; master materials license, medical; nuclear

pharmacy; research and development; service providers; and teletherapy. Types of licensing

actions selected for evaluation included seven new licenses, ten renewals, eighteen

amendments, and five terminations. A list of the licenses evaluated with case-specific

comments can be found in Appendix D.

As discussed in Section 2.0, RII initiated a periodic peer review of completed licensing actions

and a quality control review by a senior reviewer using a checklist prior to issuing the license

action. Overall, the team found the licensing actions were thorough, complete, consistent, of

good quality, and properly addressed health and safety issues. The files generally contained

appropriate deficiency letters, and documentation of telephone communications with the

licensee. The license reviewers generally signed all new or renewed licenses or amendments. 

For those licensing actions for which the license reviewer did not have signature authority, the

licenses were signed by a senior reviewer with full authority, or by the Branch Chief. Licensing

files were found to be adequately maintained.

The review team recommends the RII’s management approach of identification of an issue,

establishment of the expectations to address the issue and the successful resolution of issue by

management be identified as a good practice. This approach was used to resolve licensing

inconsistencies identified during IMPEP self assessments. RII management initiated a process

which used a senior license reviewer to do a quality control review on all licensing actions prior

to issuing the action. As one of the empowerment initiatives being pursued in the Materials

Arena and since expectations have been established for license reviewers, RII management is

changing the practice from reviewing all actions to a more statistical sampling of outgoing

actions.

The review team recommends the RII’s biennial IMPEP self assessment be identified as a good

practice. On following-up on identified issues, the review team found that the recent IMPEP self

assessment had identified the same or similar issues in all the common and non-common

performance indicators, and RII had already initiated corrective measures.

Based on the IMPEP evaluation criteria, the review team recommends that RII’s performance

with respect to the indicator, Technical Quality of Licensing Actions, be found satisfactory.

3.5 Response to Incidents and Allegations

In evaluating the effectiveness of RII’s actions in responding to incidents, the team examined

RII’s response to the questionnaire relative to this indicator, evaluated selected incidents

reported for RII in NMED against those contained in RII’s files, and evaluated the casework and

supporting documentation for 10 material incidents. A list of the incident casework examined

with case-specific comments is included in Appendix E. The team also reviewed RII’s response

to ten allegations involving radioactive materials.
Region II Final Report Page 8

The team discussed RII’s incident and allegation procedures, file documentation, NMED, and

notification of incidents to the NRC Operations Center with DNMS staff and management. The

responsibility for initial response and follow-up actions to materials incidents rests with DNMS. 

All incidents are promptly evaluated for the need for onsite investigations. The review team

determined that DNMS took prompt, appropriate action in response to incidents. Of the ten

incidents reviewed, the review team observed that RIl consistently addressed health and safety

issues in incident follow-up. The review team found that DNMS’ level of effort expended on

incidents was appropriate and commensurate with the potential health and safety significance

of the incidents. DNMS staff adequately and clearly identified licensees' noncompliance issues

and, as appropriate, initiated enforcement actions to ensure prompt compliance. In addition,

DNMS coordinated materials incident responses with other NRC offices and, when appropriate,

with other regulatory jurisdictions (i.e., States) in a timely and effective manner. The review of

license files and discussions with staff revealed that Preliminary Notifications (PNs) in response

to incidents were documented, and were issued in accordance with regional instructions and

IMC 1120, "Preliminary Notifications." PNs received supervisory review and approval before

issuance. The review team found good correlation between the PNs issued by RIl, the incident

information in the licensing files, and the incident information on the NMED system.

The team discussed the recent revisions to the various IMC’s requiring the use of NMED by

Regional inspection staff in the preparation for inspections. The inspection staff was familiar

with NMED and review of inspection records and observations during the inspector

accompaniments indicated that the NMED system was being used by the inspection staff. The

team found that most NMED records for event files reviewed were accurate and complete,

although some of the records were not classified as “complete.” Based upon a review of the

existing guidance in IMC 2800 and IMC 2600, the team concluded that RII is in conformance

with the existing expectations. The review team recommends that NMSS revise the guidance in

IMC 2800 and IMC 2600 to clarify the regions responsibility for NMED item updates.

In evaluating the effectiveness of RIl's actions in responding to allegations, the review team

examined RIl's response to the questionnaire relative to this indicator and reviewed the

allegations reported for RIl in the Allegations Management System against those contained in

RIl’s allegations files, and supporting documentation, for ten allegations. The review team

considered RIl's actions in the materials area in response to the July 9, 2001, memorandum,

"Results of Audit of Allegation Program," from Mr. Edward T. Baker III, Agency Allegation

Advisor. In addition, the review team held interviews with the Regional Senior Allegations

Coordinator, DNMS managers, and DNMS technical staff on allegation handling. 

Responsibility for initial response and follow-up actions to material allegations rests with the

Regional Allegations Coordinator, in conjunction with DNMS staff and management. The

team’s review of casework, associated documents, and interviews with staff revealed that RlI

has an aggressive, effective, and an efficient program for managing materials allegations. The

average time for closing materials allegations containing technical concerns is 110 days. MD

8.8, "Management of Allegations," sets the goal of 180 days. In addition, all Allegation Review

Board meetings were held within the MD 8.8 goal of 30 days. Acknowledgment letters,

responding to allegers, were issued within the performance goal of 30 days. 

The review team found that proper procedures were being followed for control and maintenance

of allegation materials, in accordance with MD 8.8. DNMS staff received annual allegation
Region II Final Report Page 9

training. Moreover, the review team interviews indicated that the RII staff had a clear

understanding of the applications of MD 8.8.

The review team noted that internal and external coordination of allegations was appropriate

and performed in a timely manner. The results of file reviews showed that DNMS routinely

referred cases involving potential wrongdoing to the Office of Investigations for resolution. In

addition, the review team noted that allegations involving Agreement States were appropriately

managed.

Based on the IMPEP evaluation criteria, the review team recommends that RIl’s performance

with respect to the indicator, Response to Incidents and Allegations, be found satisfactory.

4.0 NON-COMMON PERFORMANCE INDICATORS

IMPEP identifies three non-common performance indicators to be used in reviewing RII’s

nuclear materials program: (1) Performance with Respect to Operating Plans and Resource

Utilization; (2); Regional Fuel Cycle Inspection Program and (3) Site Decommissioning

Management Plan and Decommissioning Activities. 

4.1 Performance with Respect to Operating Plans and Resource Utilization

4.1.1 Operating Plan Performance

Note: This indicator has been reviewed independently from the IMPEP review, on an ongoing

basis, since the time of the last Region II IMPEP in 1998. NMSS reviews each region’s

Operating Plan performance on a quarterly basis, and includes key licensing and inspection

statistics as part of the Agency’s Green Book output measures. As such, the IMPEP Working

Group has recommended that this indicator no longer be included in subsequent regional

IMPEP reports. 

RII typically receives and completes action on approximately 500 new applications and

amendments each year, and in recent years, has received approximately 100 license renewal

applications. Throughout this review period, RII has consistently exceeded expectations for the 

licensing timeliness metrics. FY 2001 was a typical year, in which RII completed all 47 new

applications within 90 days, and 95% of its 453 amendments within 90 days. The region also

completed 98% of its renewals within the 180 day standard. In each case, the metric for

acceptable performance was 80% (in FY 2002, this was increased to 85%). RII performed in a

similar fashion in FY 1998-1999-2000, and is again exceeding the metric in FY 2002.

As discussed in Section 3.1 of this report, RII met the Operating Plan standards for completing

inspection reports in accordance with IMC 2600 and 2800 schedules, had virtually no overdue

core inspections in this IMPEP review period, and issued its inspection reports in a timely

fashion in accordance with IMC 0610 guidance (within 30 days). Each year, the region

completed approximately 250 materials program inspections. In FY 2001, 96% of the written

inspection reports were issued on time (versus an NRC goal of 90%). 

RII’s good operating plan performance is especially noteworthy for early FY02 in light of the

resource strains imposed by the NRC’s response to the terrorist acts on September 11, 2001.
Region II Final Report Page 10

4.1.2 Resource Utilization

Note: This indicator was reviewed independently from the IMPEP review, on an ongoing basis,

since the time of the last Region II IMPEP in 1998. NMSS reviews each region’s resource

utilization on a quarterly basis. As such, the IMPEP Working Group has recommended that this

indicator no longer be included in subsequent regional IMPEP reports. 

Other Sections of this report (3.3, 4.2.3, and 4.3.4) include separate detailed discussions of

RII’s staffing and resource utilization. With respect to the materials program, RII was budgeted

12.4 FTE in FY 2001, but expended only 11.3 FTE. Based on first quarter data for FY 2002, RII

is again under-expending. However, this aligns with the staff attrition discussed in Sections 3.3

and 4.2.3, and, as noted in Section 3 of this report, there have been no performance issues

identified, and RII has moved quickly to fill its vacancies and train its new staffers.

Based on the IMPEP evaluation criteria, the review team recommends that RII’s performance

with respect to the indicator, “Performance with Respect to Operating Plans and Resource

Utilization,” be found satisfactory.

4.2 Regional Fuel Cycle Inspection Program

In conducting this review, four sub-indicators were reviewed to evaluate RII’s performance

regarding their Fuel Cycle Inspection Program. These sub-indicators include: (1) Status of the

Fuel Cycle Inspection Program; (2) Technical Quality of Inspections; (3) Technical Staffing and

Training; and (4) Response to Incidents and Allegations. In performing this review, the team

interviewed DNMS management and staff, examined fuel cycle inspection reports, reviewed the

PIMS, NMED, and allegation files.

4.2.1 Status of Fuel Cycle Inspection Program

The team focused on three factors in reviewing this sub-indicator: inspection frequency,

overdue inspections, and timely dispatch of inspection findings to licensees. 

Inspections at fuel facilities are coordinated with NMSS and the Regions through an integrated

Fuel Cycle Master Inspection Plan, based on considerations of risks, licensee performance, and

recent occurrences. In meeting the general guidelines for frequency of inspections in

Temporary Instruction 2600/007, RII has prepared detailed written guidance targeting specific

plant operations and functional areas for emphasis during inspections. This provides specific

guidance based on lessons learned from previous inspections, Licensee Performance Reviews

(LPRs), licensing actions, and recent occurrences. Changes to the guidance were well

documented and communicated with NMSS and the inspection staff.

RII is using the PIMS to effectively track inspection findings and event information. ADAMS,

which provides online access to inspection reports, has improved the coordination of

inspections and tracking licensee performance between Regions and Headquarters. RII

inspectors have been using PIMS information to identify areas of emphasis and prepare

inspection plans.
Region II Final Report Page 11

RII is facing a challenge in inspection resource management. RII, after consulting with NMSS, 

suspended all physical security inspections at fuel cycle facilities in order to perform security

reviews at nuclear power reactors and fuel cycle facilities (post September 11 activities) due to

a shortage of qualified inspectors as noted in Section 4.2.3 . RII has restarted routine

inspections. The team did not observe any other delayed inspections or inspection reports

during the IMPEP review period. 

4.2.2. Technical Quality of Inspections

The team evaluated the inspection reports and enforcement documentation for eight fuel cycle

inspections. In general, inspection findings were well founded, well documented, and in

accordance with IMC 610, “Inspection Reports.” These reports received proper peer and

management review. The review noted that some inspection findings were not characterized in

terms of safety and safeguards significance. This has been identified in RII’s Self-Assessment

for First Quarter FY 2001. Appendix C lists the inspection casework files reviewed for

completeness and adequacy with specific comments.

In general, the inspection program appears to focus on the high-risk functional areas. Based

on interviews with inspectors, the inspectors have good understanding of risk-informed

performance-based inspection philosophy and try to apply it during inspections and in

documentation. RII is using PIMS to track past issues at each facility, which include past

inspection findings, events, and routine activities at each site. This information is kept current

by project inspectors and is used by the inspectors in the planning phase of the inspection to

focus on areas that may need more attention. The inspection effort addresses past inspection

findings and event follow-up.

During the review period, supervisors performed accompaniments of all inspectors annually. In

some cases, some inspectors were accompanied more than once per year. During the review

period, RII hired six new inspectors. RII management has performed appropriate inspection

observations and accompaniments, focusing on these new inspectors.

One newly qualified inspector was accompanied during an inspection by a review team member

on March 4-8, 2002. This accompaniment is identified in Appendix C. The inspector

performed in-depth examinations of the licensee’s facility; interacted with licensee personnel;

observed licensee’s activities; and reviewed pertinent records. During the inspection, the

inspector demonstrated a performance based inspection approach with appropriate technical

skills and professional inspection techniques. The inspector’s performance was adequate to

assess the radiological health and safety of the licensee’s program.

4.2.3 Technical Staffing and Training

Issues central to the evaluation of this indicator include the fuel cycle inspection program

staffing level, technical qualifications of the staff, training, and staff turnover. To evaluate these

issues, the review team examined RII’s questionnaire responses relative to this indicator,

interviewed DNMS management and staff, interviewed members of the RII Division of Resource

Management, and considered any possible workload backlogs.

The Fuel Facilities Branch has seen a large influx of new entry-level staff and a departure of

five experienced staff. Six of the ten branch technical staff are new to the branch. Of the new
Region II Final Report Page 12

staff, three staff are members of the Nuclear Safety Intern Program, two are hired as Senior

Resident Inspectors, and one is hired as a Physical Security Inspector. All the new staff are on

a rigorous schedule to complete their qualifications. DNMS uses their Training Matrix to

coordinate training activities. One new staff member has been qualified as a Fuel Cycle Safety

Inspector. The new Physical Security Inspector comes to RII with twenty-one years of

experience in the field. The two Senior Resident Inspectors are qualified reactor Resident

Inspectors.

The Senior Resident Inspectors are in the process of completing the Fuel Facility Inspector

qualifications and each inspector will become the backup inspector for the other inspector’s

facility. The Senior Resident Inspectors are highly qualified and there are no foreseeable

impediments to them receiving full qualifications. The three Nuclear Safety Interns in the

Branch participate in the “Big Brother/Big Sister” mentor program. Senior branch staff teach

the Interns all about Fuel Cycle Inspection duties, such as conducting an inspection, completing

forms, and writing reports to advising the Interns on completing their qualifications for Fuel

Cycle Safety Inspector. There are no foreseeable impediments to the Interns receiving full

qualifications with the “Big Brother/Big Sister” mentor program and oversight from DNMS

management and the DNMS Training Matrix. 

DNMS acknowledges there is a staffing and performance challenge with the high staff attrition

and large number of entry-level staff. All unqualified staff have schedules to complete their

training requirements and one staff member is close to interim qualification. DNMS

management conducts a vigilant watch over the qualifications of their staff via the DNMS

Training Matrix. The Training Matrix tracks all the courses taken, courses needed, and dates

that certain courses are needed for the Division staff. The team did not observe any

performance deficiency during the IMPEP review period. 

4.2.4. Response to Incidents and Allegations

In evaluating the effectiveness of RII’s actions in responding to fuel cycle incidents, the team

examined RII’s response to the questionnaire relative to this indicator, evaluated selected

incidents reported for RII in the Nuclear Material Events Database (NMED) against those

contained in RII’s files, and evaluated the casework and supporting documentation for two fuel

cycle incidents. A list of the incident casework examined with case-specific comments is

included in Appendix E. The team also reviewed RII’s response to two allegations involving fuel

cycle facilities.

Responses to events appeared to be appropriate. The inspectors receive and evaluate the

event information, coordinating with NMSS, to determine RII’s action based on the safety and

safeguards significance of the events. The description of the event, initial evaluation, causes,

precursors, and event follow-up are well documented and reviewed by management.

Based on the IMPEP evaluation criteria, the review team recommends that RII’s performance

with respect to the indicator, “Regional Fuel Cycle Inspection Program,” be found satisfactory.
Region II Final Report Page 13

4.3 Site Decommissioning Management Plan (SDMP)

In conducting this review, six sub-indicators were reviewed to evaluate RII’s performance

regarding their Site Decommissioning Management Plan (SDMP). These sub-indicators

include: (1) Quality of SDMP Decommission Reviews; (2) Financial Assurance for

Decommissioning; (3) Termination Radiological Surveys; (4) Inspections; (5) Staff

Qualifications; and (6) SDMP Milestones. In performing this review, the review team

interviewed DNMS management and staff, examined non-SDMP licensing files, and reviewed

financial assurance documents. 

Decommissioning and license termination is the responsibility of the MLIB1, MLIB2, and the

Fuel Facilities Branch. The types of sites reviewed included sites that required substantial

decommissioning actions, such as remediation or final radiological surveys, non-complex

decommissioning license terminations, such as Page D.13 for Type I and Type II sites involving

sealed sources or limited onsite decontamination and termination radiological surveys.

4.3.1 Quality of SDMP Decommission Reviews

To assess RII’s performance on reviews for license terminations, the review team interviewed

RII staff and examined docket files for five non-SDMP licenses that were terminated during the

review period. Appendix F lists the termination casework files reviewed for completeness and

adequacy with specific comments. Note: RII has no SDMP facilities for this review.

Through interviews with RII staff and managers and from examination of files, the review team

found that, for most decommissioning sites managed by RII, an individual staff member serves

as both the license reviewer and the inspector. Decommissioning licensing review actions

undertaken by RII staff include: reviewing the status of sites in accordance with timeliness

requirements; reviewing/approving radiological criteria for release of sites; reviewing licensees’

decommissioning plans; ensuring adequate financial assurance; reviewing licensees’ final

status survey plans and reports; and conducting confirmatory surveys.

Licensee decommissioning plans, where required, were reviewed and documented by DNMS in

accordance with NRC guidance. For license terminations, RII included closeout documentation

in docket files examined by the review team. The “Materials License Termination/Retirement

Form,” from the “NMSS Handbook for Decommissioning Fuel Cycle and Materials Licensees,”

and Form 314, “Certificate of Disposition of Materials,” were included in the files. 

4.3.2 Financial Assurance for Decommissioning

The review team evaluated RII’s financial assurance program for conformance with

requirements of MD 8.12, “Decommissioning Financial Assurance Instrument Security

Program.” 

To assess the performance of RII for financial assurance, the review team examined the

License Tracking System (LTS); reviewed RII’s “FY2001 Inventory List of Original Financial

Assurance Instruments;” reviewed ten financial assurance instruments in the file, including a

comparison with the inventory list information, reviewed RII’s annual self-evaluations, security of

decommissioning financial assurance instruments, and interviewed licensing staff.
Region II Final Report Page 14

The review team confirmed that RII has staff assigned as a Decommissioning Financial

Assurance Instrument Custodian (FAIC), Alternate Custodian (AFAIC), and FAIC manager, in

accordance with MD 8.12. The FAIC Manager is the Chief of the MLIB 1. The review team

confirmed that the FAIC, AFAIC, and FAIC manager have been designated in writing, and that

no one has access to the financial assurance records other than through these individuals, as

required by MD 8.12. The review team confirmed that the decommissioning financial

assurance instruments are stored in a fire-rated safe, having a fire rating in accordance with

MD 8.12. The review team also confirmed that the FAIC maintains an inventory list of the

financial assurance instruments held in the safe, and this inventory contains the information

required by MD 8.12.

The team reviewed the security of the financial assurance instruments. RII has established

check out/in procedures. Instruments that are taken from the safe are noted on a log sheet and

returned to the safe before the end of the business day. The safe is checked at the end of

each day to ensure that it is locked. This check is noted on a log sheet. Finally, the

combination to the safe has recently been changed and only the FAIC, AFAIC, and FAIC

manager have the combination. 

The team reviewed the self assessment required by MD 8.12 for 1999, 2000, 2001, and 2002. 

MD 8.12 requires the annual self assessments review of 100% of the files on the inventory list

against the guidelines in the Handbook. Additionally, MD 8.12 requires that two evaluations of

financial assurance instruments be conducted annually, one by the FAIC or AFAIC and one by

the FAIC manager. In 1999, the evaluations by the FAIC and the FAIC manager were

performed. In 2000, and 2001 the evaluation by the FAIC was performed. The 2001 FAIC

manager was done late, in early 2002, and the FAIC manager evaluation was not done in 2000. 

The most recent FAIC manager review also noted these discrepancies.

The team compared the inventory list of the financial assurance instruments with the LTS. The

team found discrepancies between the inventory list and LTS. However, RII had identified

these issues in their self assessment and were in the process of addressing them during the

review. 

The team reviewed ten financial instruments and found several discrepancies. One of the

stand-by trust agreements listed the name of the bank that was providing the letter of credit. 

However, the bank providing the credit had changed. The FAIC was aware of the issue and

had already followed-up with the institution that provided the stand-by trust. The institution

indicated that the change in bank providing the line of credit did not affect the trust agreement. 

One escrow account had the correct licensee name but the wrong license number. Three

Statements of Intent did not include documentation that the individual signing the statement

was authorized to provide funding for decommissioning. After consultation with HQ FAIC, it

was determined that these issues may delay but will not prevent the execution of these

instruments. The HQ FAIC stated that these issues could be resolved at license renewal. 

During the conference call with the HQ FAIC, regional staff took the opportunity to discuss

additional financial assurance scenarios. Regional staff and the reviewer felt that discussion of

financial assurance issues would be better handled through refresher training for the entire

staff. Therefore, the team recommends that the HQ FAIC provide refresher training and update

Regional and HQ staff on changes made to financial assurance guidance. 
Region II Final Report Page 15

4.3.3 Termination Radiological Surveys

The review team discussed termination surveys with RII staff and managers and evaluated

casework for adequacy of licensee and RII surveys to support license termination. The review

team observed that licensee final status survey plans and reports have been prepared in

accordance with NUREG/CR-5849, “Manual for Conducting Radiological Surveys in Support of

License Termination;” NUREG-1575, “Multi-Agency Radiation Survey and Site Investigation

Manual (MARSSIM);” or other appropriate methods, and are reviewed by RII staff. The review

team concluded that RII’s reviews are adequate to ensure that residual radioactivity levels

comply with release criteria. Confirmatory or closeout surveys are performed, as necessary, for

each licensee’s site, by RII or NRC’s contractor to validate licensee survey data, as outlined in

IMC 2605, Inspection Procedure (IP) 87104, “Decommissioning Inspection Procedure for

Materials Licensees,” and IP 88104, “Decommissioning Inspection Procedure for Fuel Cycle

Facilities.”

4.3.4 Inspections

Note: RII has no SDMP facilities to evaluate this sub-indicator for this review.

4.3.5 Staff Qualifications

The review team found that the decommissioning staff is very experienced and highly qualified

to perform licensing and inspection functions on decommissioning sites. The staff is

knowledgeable about the process and procedures for decommissioning, and the staff follows

the process and procedures, as applicable, to each decommissioning site and license

termination action. Two staff members from MLIB 1 have completed the additional training

required for decommissioning technical reviewers and decommissioning inspectors in IMC

1246. Additional staff have met the old requirements for decommissioning technical reviewers

and decommissioning inspectors and are in the process of completing the requirements added

by the latest revision of IMC 1246.

4.3.6 SDMP Milestones

Note: RII has no SDMP facilities to evaluate this sub-indicator for this review.

Based on the IMPEP evaluation criteria, the review team recommends that RII’s performance

with respect to the indicator, Site Decommissioning Management Plan, be found satisfactory.

5.0 SUMMARY

As noted in Sections 3 and 4 above, the review team found RII’s performance with respect to

each of the performance indicators to be satisfactory. According, the review team

recommended and the MRB concurred in finding the RII nuclear material program to be

adequate to protect public health and safety. Based on the results of the current IMPEP review,

the next full review will be in approximately four years.

.
Region II Final Report Page 16

Below is a summary list of recommendations, as mentioned in earlier sections of the report, for

evaluation and implementation, as appropriate, by RII. 

RECOMMENDATIONS:

1. The review team recommends that NMSS revise the guidance in IMC 2800 and IMC

2600 to clarify regional responsibility for NMED item updates (Section 3.5).

2. The review team recommends that the HQ FAIC provide refresher training and update

Regional and HQ staff on changes made to financial assurance guidance (Section 4.3).

GOOD PRACTICES:

1. The review team recommends the RII’s management approach of identification of an

issue, establishment of the expectations to address the issue and the successful

resolution of issue by management be identified as a good practice. This approach was

used to resolve licensing inconsistencies identified during IMPEP self assessments. RII

management initiated a process which used a senior license reviewer to do a quality

control review on all licensing actions prior to issuing the action. As one of the

empowerment initiatives being pursued in the Materials Arena and since expectations

have been established for license reviewers, RII management is changing the practice

from reviewing all actions to a more statistical sampling of outgoing actions (Section

3.4).

2. The review team recommends RII’s annual IMPEP self assessment be identified as a

good practice. In all the common and non-common performance indicators, the review

team found issues which in following-up on the issues, the team would determine that

the recent IMPEP self assessment had identified the same or similar issues and RII had

already initiated corrective measures (Section 3.4). 
LIST OF APPENDICES AND ATTACHMENTS

Appendix A IMPEP Review Team Members

Appendix B Region II Organization Charts

Appendix C Inspection Casework Reviews and Accompaniments

Appendix D License Casework Reviews

Appendix E Incident Casework Reviews

Appendix F Decommissioning Casework Reviews
APPENDIX A

IMPEP REVIEW TEAM MEMBERS

Name Area of Responsibility

Charles R. Cox, NMSS/IMNS Team Leader

Technical Quality of Inspections

Inspection Accompaniments

Response to Incidents and Allegations

Yen-Ju Chen, NMSS/FCSS Fuel Cycle

Frederick Brown, NMSS/IMNS Technical Quality of Inspections

Status of Materials Inspection Program

Gary Purdy, NMSS/DWM Site Decommissioning Management Plan

Response to Incidents and Allegations

Jared Thompson, Arkansas Technical Quality of Licensing Actions

Alvin Henry, NMSS/DWM Technical Staffing and Training

Response to Incidents and Allegations
APPENDIX B

REGION II

DIVISION OF NUCLEAR MATERIAL SAFETY

ORGANIZATION CHART
APPENDIX C

INSPECTION CASEWORK REVIEWS

NOTE: ALL INSPECTIONS LISTED WITHOUT COMMENT ARE INCLUDED FOR

COMPLETENESS ONLY; NO SIGNIFICANT COMMENTS WERE IDENTIFIED BY THE IMPEP

TEAM.

File No.: 1 

Licensee: University of Puerto Rico License No.: 52-01946-07

Location: San Juan, PR Inspection Type: Routine

License Type: Medical Institution, Broad Priority: 1

Inspection Date: 5/16/01 - 5/18/01 Inspector: HB

Comment:

a) Wrong inspection record used (87110 vs 87119). Very minor issue given scope of

inspection.

File No.: 2 

Licensee: Reviss Services Inc. License No.: IL-02058-01

Location: Steris Corp., Vega Alta, PR Inspection Type: Reciprocity

License Type: Other Services - includes teletherapy, irradiator Priority: 1 

Inspection Date: 10/1/01 - 10/2/01 Inspector: OB

Comment:

c) Report issued in 34 days

File No.: 3 

Licensee: J.L. Sheperd License No.: CA 1777-19

Location: FEMA, Mt. Weather, VA Inspection Type: Reciprocity

License Type: Other Services - includes teletherapy, irradiator Priority: 3 

Inspection Date: 7/9/01 - 7/10/01 Inspector: RG

File No.: 4 

Licensee: Sabia Services Inc. License No.: CA 6663-37

Location: Leewood, WV Inspection Type: Reciprocity

License Type: Other Services - includes teletherapy, irradiator Priority: 3 

Inspection Date: 11/1/01 Inspector: DC

File No.: 5

Licensee: Layne Christensen Co License No.: CO-971-01

Location: Warner Robbins AFB, Warren Robbins, GA Inspection Type: Reciprocity

License Type: Well Logging Byproduct and/or SNM Sealed Source Priority: 3 

Inspection Date: 11/6/01 Inspector: JD
Region II Proposed Final Report Page C.2

Inspection Casework Reviews

File No.: 6

Licensee: Mick /Radio-Nuclear Instruments License No.: NY 2252-3034

Location: DePaul Med. Center, Norfolk VA Inspection Type: Reciprocity

License Type: Other Services - includes teletherapy, irradiator Priority: 1

Inspection Date: 3/16/01 Inspector: DC

File No.: 7

Licensee: Alpha-Omega Services License No.: CA 2641-19

Location: University of Virginia, Charlottesville, VA Inspection Type: Reciprocity

License Type: Other Services - includes teletherapy, irradiator Priority: 1 

Inspection Date: 6/7/01 - 6/9/01 Inspector: WL

Comment:

a) Wrong 591/Inspection Record attached to letter in ADAMS 

File No.: 8

Licensee: Berthold Technologies License No.: TN R-01082-D02

Location: Dillwyn, VA Inspection Type: Reciprocity

License Type: Other Services - includes teletherapy, irradiator Priority: 3 

Inspection Date: 7/12/01 Inspector: RG

File No.: 9

Licensee: Space Science Services License No.: AL 217

Location: Mayport Naval Shipyard, Mayport, FL Inspection Type: Reciprocity

License Type: Industrial Radiography - Temporary job sites Priority: 1

Inspection Date: 4/2/01 Inspector: BAP

File No.: 10

Licensee: S. K. McBryde License No.: NC 041-0766-1

Location: Bristle, VA Inspection Type: Reciprocity

License Type: Industrial Radiography - Temp job sites Priority: 1 

Inspection Date: 1/20/01 Inspector: DJC

File No.: 11

Licensee: Neutron Products License No.: SUB-1551

Location: Ransom, WV Inspection Type: Routine

License Type: Source Material - Shielding Priority: 7 

Inspection Date: 3/27/01 Inspector: JP

File No.: 12

Licensee: Northern Virginia Community Hospital License No.: 45-16222-01

Location: Arlington, VA Inspection Type: Routine

License Type: Medical Institution, QMP required Priority: 3 

Inspection Date: 1/22/02 Inspector: CT
Region II Proposed Final Report Page C.3

Inspection Casework Reviews

File No.: 13

Licensee: Marshall University License No.: 47-05972-02

Location: Huntington, WV Inspection Type: Routine

License Type: Academic Type B Broadscope Priority: 3 

Inspection Date: 9/29/98 Inspector: LF

File No.: 14

Licensee: Alleghany Wireline Services License No.: 47-11976-01

Location: Titusville & Elderton, PA Inspection Type: Routine

License Type: Well Logging Priority: 3 

Inspection Date: 2/6/01 - 2//9/01 Inspector: R-I

Comment:

a) Report issued over 60 days after inspection performed, report included updated

information from licensee.

File No.: 15

Licensee: Alleghany Wireline Services License No.: 47-11976-01

Location: Salem, WV Inspection Type: Routine

License Type: Well Logging Priority: 3 

Inspection Date: 12/6/00 - 12/7/00 Inspector: JP 

File No.: 16

Licensee: West Virginia University Hospital License No.: 47-23066-02

Location: Morgantown, WV Inspection Type: Routine

License Type: HDR, Medical Institution - QMP Priority: 1 

Inspection Date: 6/25/01 - 6/26/01 Inspector: JP

File No.: 17

Licensee: West Virginia University License No.: 47-23035-01

Location: Morgantown, WV Inspection Type: Routine

License Type: Academic Type A Broad Priority: 2 

Inspection Date: 6/12/01 - 6/14/01 Inspector: JP

File No.: 18

Licensee: Northern Virginia Radiology and Nuc Med License No.: 45-08482-01

Location: Falls Church, VA Inspection Type: Routine

License Type: Medical Private Practice - QMP required Priority: 3 

Inspection Date: 8/20, 8/23, & 8/31/99 Inspector: JH
Region II Proposed Final Report Page C.4

Inspection Casework Reviews

File No.: 19 

Licensee: Danville Regional Medical Center License No.: 45-15154-03

Location: Danville, VA Inspection Type: Routine

License Type: Nuclear Medicine HDR Priority: 1

Inspection Date: 8/01/01 Inspector: CT 

Comment:

a) Duration of a violation for failure to perform surveys not identified.

File No.: 20 

Licensee: E. I. DuPont de Nemours & Co. License No.: 45-14837-01

Location: Hopewell, VA Inspection Type: Routine

License Type: Measuring Systems, Fixed Gauges Priority: 5

Inspection Date: 7/31/01 - 8/1/01 Inspector: AJ

File No.: 21

Licensee: Dept. of the Army, Eisenhower Med. Center License No.: 10-12044-03

Location: Fort Gordon, GA Inspection Type: Routine

License Type: Research and Development, Type A Broad Priority: 2

Inspection Date: 12/8/98 Inspector: DC

File No.: 22

Licensee: Levenger Co. License No.: 09-25410-01E

Location: Delray Beach, FL Inspection Type: Routine

License Type: Exempt Distribution Priority: 5

Inspection Date: 9/15/98 Inspector: JH

Comment:

a) Inspection record for this E-license missing from file. Copy of 591 indicates a clean

inspection. Original may have been sent to Headquarters.

File No.: 23 

Licensee: Pine Ridge Coal Co. License No.: 45-25199-01

Location: Hopewell, VA Inspection Type: Routine

License Type: Measuring Systems, Fixed Gauges Priority: 5

Inspection Date: 2/11/99 Inspector: RG
Region II Proposed Final Report Page C.5

Inspection Casework Reviews

File No.: 24

Licensee: V. A. Medical Center License No.: 41-00104-04

Location: Nashville, TN Inspection Type: Routine

License Type: Research and Development, Type A Broad Priority: 2

Inspection Date: 12/20/01 Inspector: JV

Comment:

a) Form 591 and Inspection record missing from docket folder: Inspection record added,

will get a copy of 591.

Accompaniment No.: 1

Licensee: Alliance Imaging License No.:47-25570-01

Location: Bluefield, VA Inspection Type: Routine, unannounced

License Type: Mobile Nuclear Medicine Priority: 2

Inspection Date: 2/20/02 Inspector: AM

Accompaniment No.: 2

Licensee: Mingo Logan Coal Company. License No.: 47-25025-01

Location: Wharncliffe, WV Inspection Type: Routine, unannounced

License Type: Gauge Priority: 5

Inspection Date: 2/21/02 Inspector: AM

Accompaniment No.: 3

Licensee: University of Florida License No.: SNM-50 

Location: Gainesville, FL Inspection Type: Routine, unannounced

License Type: SNM Priority: 2

Inspection Date: 2/27/02 Inspector: CT

Accompaniment No.: 4

Licensee: Veterans Administration Medical Center License No.: 09-12467-02

Location: Gainesville, FL Inspection Type: Routine, unannounced

License Type: Medical Broadscope/Brachytherapy Priority: 1

Inspection Date: 2/27-28/02 Inspector: CT
Region II Proposed Final Report Page C.6

Inspection Casework Reviews

Fuel Cycle Inspection Casework Review

File No.: 1 

Licensee: Nuclear Fuel Services License No.: SNM-0124

Location: Erwin, TN Inspection Type: Routine

License Type: Fuel Cycle Facility Priority: 1

Inspection Date: 9/17-21/01 Inspector: AG

Comment:

a) The report did not clearly characterize the safety and safeguards significance of the

cited violation.

File No.: 2

Licensee: Nuclear Fuel Services License No.: SNM-0124

Location: Erwin, TN Inspection Type: Routine

License Type: Fuel Cycle Facility Priority: 1

Inspection Date: 1/ 2 – 2/12/00 Inspector: GH, WG

File No.: 3 

Licensee: BWX Technologies, Inc. License No.: SNM-0042

Location: Lynchburg, VA Inspection Type: Routine

License Type: Fuel Cycle Facility Priority: 1

Inspection Date: 8/26/01 – 10/6/01 Inspector: JR, AG, OM, DS, OS

Comment:

a) In the report, the inspector discussed the Severity Level IV violation as an “apparent”

violation. The report did not clearly identify the safety and safeguards significance of

the inspection followup items and the cited violation.

File No.: 4

Licensee: BWX Technologies, Inc. License No.: SNM-0042

Location: Lynchburg, VA Inspection Type: Routine

License Type: Fuel Cycle Facility Priority: 1

Inspection Date: 8/13/00 – 9/23/00 Inspector: CH, AG, RS, WT

File No.: 5

Licensee: Global Nuclear Fuel – Americas, LLC License No.: SNM-1097

Location: Wilmington, NC Inspection Type: Routine

License Type: Fuel Cycle Facility Priority: 1

Inspection Date: 7/23-27/01, 8/6-10/01 (2 parts) Inspector: DA, MC, WG, AG
Region II Proposed Final Report Page C.7

Inspection Casework Reviews

File No.: 6

Licensee: Global Nuclear Fuel – Americas, LLC License No.: SNM-1097

Location: Wilmington, NC Inspection Type: Routine

License Type: Fuel Cycle Facility Priority: 1

Inspection Date: 8/14-18/00 Inspector: WG

File No.: 7

Licensee: Westinghouse License No.: SNM-1107

Location: Columbia, SC Inspection Type: Routine

License Type: Fuel Cycle Facility Priority: 1

Inspection Date: 8/21-25/00 Inspector: DA, SB

File No.: 8

Licensee: Westinghouse License No.: SNM-1107

Location: Columbia, SC Inspection Type: Special

License Type: Fuel Cycle Facility Priority: 1

Inspection Date: 9/10-13/01 Inspector: WG, LH, OW

Accompaniment No.: 1

Licensee: Global Nuclear Fuel - Americas, LLC License No.: SNM-1097

Location: Wilmington, NC Inspection Type: Routine, unannounced

License Type: Fuel Cycle Priority: 1

Inspection Date: 3/ 4-8/02 Inspector: MC
APPENDIX D

LICENSE CASEWORK REVIEWS

NOTE: ALL LICENSES LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS

ONLY; NO SIGNIFICANT COMMENTS WERE IDENTIFIED BY THE IMPEP TEAM.

File No.: 1

Licensee: Roof Surveys & Consultants License No.: 45-23000-02

Location: Roanoke, VA Amendment No.: 01

License Type: By-Product Possession Only Type of Action: Termination

Date Issued: 11/16/99 License Reviewer: WL

Comment:

a) License had been suspended for non-payment of fees on 05/20/99. A completed

Certificate of Disposition of Materials dated 10/23/99 was in the file.

File No.: 2 

Licensee: Baxter Healthcare, Corporate License No.: 52-21175-01

Location: Aibonito, PR Amendment No.: 14

License Type: Irradiator Type of Action: Amendment

Date Issued: 08/20/01 License Reviewer: HB

Licensee: Baxter Healthcare, Corporate License No.: 52-21175-01

Location: Aibonito, PR Amendment No.: 13

License Type: Irradiator Type of Action: Amendment

Date Issued:09/03/99 License Reviewer: JP

Comment:

a) Amendment request dated 06/02/99 for several changes. It was noted on the Licensing

Tracking Form that there was complications. Received a fax dated 09/02/99 that

containing training certificates. There was no correspondence from RII on deficiencies. 

Amendment issued 09/03/99.

File No.: 3

Licensee: Old Dominion University License No.: 45-09599-03

Location: Norfolk, VA Amendment No.: 33

License Type: Academic-Board A Type of Action: Amendment

Date Issued: 12/18/00 License Reviewer: OMB

Licensee: Old Dominion University License No.: 45-09599-03

Location: Norfolk, VA Amendment No.: 29

License Type: Academic-Board A Type of Action: Amendment

Date Issued: 07/29/99 License Reviewer: WL
Region II Proposed Final Report Page D.2

License Casework Reviews

File No.: 4

Licensee: The San Juan Health Center License No.: 52-25505-01

Location: San Juan, PR Amendment No.: 01

License Type: Medical Private Practice Type of Action: Termination

Date Issued: 05/24/01 License Reviewer: DC

Comment:

a) A Material License Termination/Retirement form showed the disposition of the sealed

sources and that no waste had been generated. A documented close out inspection by

NRC inspector was conducted on 04/15/01.

File No.: 4

Licensee: The San Juan Health Center License No.: 52-25505-01

Location: San Juan, PR Amendment No.:

License Type: Medical Private Practice Type of Action: New

Date Issued: 04/23/00 License Reviewer: DC

File No.: 5

Licensee: Governor Juan F. Luis Hospital

 & Medical Center License No.: 55-25547-01

Location: St. Croix, VI Amendment No.:

License Type: Medical Private Practice Type of Action: New

Date Issued: 02/ 09/01 License Reviewer: JP

Comments:

a) There is a note on the checklist that a telephone conversation was held with licensee

regarding additional information. There is no documentation of the phone call in file

describing the requested information or whom it was discussed with.

b) The items identified on the reviewer’s checklists as needing additional information were

not all closed indicating that the information was complete.

File No.: 6

Licensee: United Hospital Center License No.: 47-01458-02

Location: Clarksburg, WV Amendment No.: 17

License Type: Teletherapy Type of Action: Termination

Date Issued: 06/05/01 License Reviewer: DC

Comment:

a) Documentation of close out survey dated 12/14/00 and of source removal on 12/13/00

was in file with the Materials License Termination/Retirement Form.

File No.: 7

Licensee: Interstate Construction Corp. License No.: 45-25517-01

Location: Richmond, VA Amendment No.: 01

License Type: Portable Gauge Type of Action: Amendment

Date Issued: 01/09/02 License Reviewer: WL
Region II Proposed Final Report Page D.3

License Casework Reviews

File No.: 7

Licensee: Interstate Construction Corp. License No.: 45-25517-01

Location: Richmond, VA Amendment No.:

License Type: Portable Gauge Type of Action: New

Date Issued: 07/17/00 License Reviewer: OMB

Comment:

a) No reviewer’s checklist was in the file that was used by reviewer for this new license

application.

File No.: 8

Licensee: Medicina Nuclear del Este License No.: 52-25333-01

Location: Fajardo, PR Amendment No.: 02

License Type: Medical Type of Action: Renewal

Date Issued: 08/22/01 License Reviewer: JD

Comment:

a) Renewal application was dated 04/30/01. First review was 07/13/01. File noted

deficiency telephone calls on 07/14/01, 08/01/01 and 08/15/01. No documentation in file

on 07/14/01 telephone call with the licensee.

File No.: 9

Licensee: Clendenin Environmental &

 Geotechnic Consultants License No.: 45-25348-02

Location: Leesburg, VA Amendment No.:

License Type: Portable Gauge Type of Action: New

Date Issued: 11/24/98 License Reviewer: DC

Comment:

a) Notes on reviewer’s checklist indicate a telephone call to licensee regarding application

but no documentation of call.

File No.: 10

Licensee: Geodax Technology, Inc. License No.: 45-25339-01MD

Location: Roanoke, VA Amendment No.: 06

License Type: Nuclear Pharmacy Type of Action: Amendment

Date Issued: 08/15/01 License Reviewer: RG

Comment:

a) Amendment request and Region cover letter incorrectly filed.

File No.: 10

Licensee: Geodax Technology, Inc. License No.: 45-25339-01MD

Location: Roanoke, VA Amendment No.: 05

License Type: Nuclear Pharmacy Type of Action: Renewal

Date Issued: 01/11/01 License Reviewer: OMB
Region II Proposed Final Report Page D.4

License Casework Reviews

File No.: 11

Licensee: Law Engineering & Environmental License No.: 52-25461-01

Location: Dorado, PR Amendment No.: 2

License Type: Industrial Radiography-Field Type of Action: Termination

Date Issued: 09/28/01 License Reviewer: HB

Comment:

a) Certificate of Disposition of Materials dated September 11, 2001 showed that radioactive

sources were transferred to Region III License Number 34-25898-02. Letter and license

from Region III indicated a use and storage location at the Puerto Rico field office.

File No.: 12

Licensee: Connex Pipe System, Inc. License No.: 45-26591-01

Location: Troutville, VA Amendment No.: 2

License Type: Industrial Radiography-Fixed Type of Action: Termination

Date Issued: 07/12/99 License Reviewer: OMB

File No.: 13

Licensee: SPIN-X License No.: 52-25577-01

Location: Dorado, PR Amendment No.:

License Type: Industrial Radiography-Field Type of Action: New

Date Issued: 11/30/01 License Reviewer: JP

File No.: 14

Licensee: Intermet Corporation License No.: 45-17464-01

Location: Lynchburg, VA Amendment No.: 8

License Type: Industrial Radiography-Fix Type of Action: Amendment

Date Issued: 08/25/00 License Reviewer: OMB

Comment:

a) There was no Use of Materials Licensing Milestone Form in the file for this amendment.

File No.: 15

Licensee: NuMed Imaging License No.: 47-25276-01

Location: Princeton, WV Amendment No.: 08

License Type: Medical Type of Action: Amendment

Date Issued: 10/21/99 License Reviewer: DC

File No.: 16

Licensee: S.K. McByrde, Inc. License No.: 32-25276-01

Location: Colfax, NC Amendment No.: 01

License Type: Industrial Radiography-Field Type of Action: Renewal

Date Issued: 12/14/01 License Reviewer: RG
Region II Proposed Final Report Page D.5

License Casework Reviews

File No.: 17

Licensee: Jeld Wen Fiber of West Virginia License No.: 47-25421-01

Location: Craigsville, WV Amendment No.:

License Type: Fixed Gauges Type of Action: New

Date Issued: 02/20/98 License Reviewer: OMB

File No.: 18

Licensee: Klug Brothers, Inc. License No.: 47-23079-01

Location: Moundsville, WV Amendment No.: 03

License Type: Portable Gauge Type of Action: Renewal

Date Issued: 08/30/00 License Reviewer: DC

File No.: 19

Licensee: VA Medical Center License No.: 09-00239-06

Location: Miami, FL Amendment No.: 91

License Type: Medical-HDR Type of Action: Renewal

Date Issued: 12/17/01 License Reviewer: OMB

Comment:

a) Letter received from licensee dated 11/27/01 containing supplement information. During

interview with reviewer, it was stated that a deficiency letter should be in this file. 

Reviewer had emailed letter requesting additional information to the licensee. A copy of

email document was not in file.

File No.: 20

Licensee: Henrico Doctors’ Hospital License No.: 45-16231-01

Location: Richmond, VA Amendment No.: 27

License Type: Medical-HDR Type of Action: Amendment

Date Issued: 08/28/01 License Reviewer: BP

Comment:

a) Region staff conducted a peer review of licensing actions (11/13 –20/01) and identified

that there was no authorized user identified for intravascular brachytherapy (IVB) listed

in Item 9.H. Corrective actions with this licensee are pending with an established due

date of 05/15/02.

File No.: 21

Licensee: PharmaLogic W.V., Ltd. License No.: 47-25375-01MD

Location: Bridgeport, WV Amendment No.:05

License Type: Nuclear Pharmacy Type of Action: Amendment

Date Issued: 08/31/01 License Reviewer: DC
Region II Proposed Final Report Page D.6

License Casework Reviews

File No.: 22 

Licensee: Preston Memorial Hospital License No.: 47-16720-01

Location: Kingwood, WV Amendment No.: 15

License Type: Medical - QMP Type of Action: Amendment

Date Issued: 12/31/01 License Reviewer: JP

File No.: 23 

Licensee: Cardiology Associates of Fredricksburg License No.: 45-25366-01

Location: Fredricksburg, VA Amendment No.:01

License Type: Medical – Private Practice Type of Action: Renewal

Date Issued: 12/19/01 License Reviewer: RG

File No.: 24

Licensee: Patrick Community Hospital License No.: 45-25474-01

Location: Stuart, VA Amendment No.:

License Type: Medical Type of Action: New

Date Issued: 07/06/99 License Reviewer: WL

Comments:

a) License was issued with out a specified physical location. A street address was

identified on the inspection of 07/30/01. No licensing actions taken.

b) Deficiency telephone conversations with licensee were noted on Materials Licensing

Milestone Form. There was no documentation in the file regarding the telephone

conversations. Licensee responded on 06/29/99 and 07/02/99.

c) There is a letter dated 01/14/01 from the RSO requesting removal from the license. 

There is no correspondence to the licensee regarding this matter. 

File No.: 25

Licensee: West Virginia School of

 Osteopathic Medicine License No.: 47-19315-01

Location: Lewisburg, WV Amendment No.:07

License Type: Other – R & D Type of Action: Renewal

Date Issued: 11/11/00 License Reviewer: RG

File No.: 26

Licensee: University of Richmond License No.: 45-08373-01

Location: Richmond, VA Amendment No.: 25

License Type: R & D Type of Action: Amendment

Date Issued: 08/28/00 License Reviewer: OMB

Comment:

a) No Materials Licensing Milestone Form for this amendment in file.
Region II Proposed Final Report Page D.7

License Casework Reviews

File No.: 26

Licensee: University of Richmond License No.: 45-08373-01

Location: Richmond, VA Amendment No.: 24

License Type: R & D Type of Action: Amendment

Date Issued: 07/22/99 License Reviewer: DC

File No.: 27

Licensee: INOVA Alexandria Hospital License No.: 45-09358-01

Location: Alexandria, VA Amendment No.: 38

License Type: Medical - HDR Type of Action: Renewal

Date Issued: 07/17/01 License Reviewer: OMB

File No.: 28

Licensee: University of Puerto Rico License No.: 52-01946-07

Location: San Juan, PR Amendment No.: 25

License Type: Medical -- Broad Type of Action: Renewal

Date Issued: 07/27/01 License Reviewer: HB

File No.: 28

Licensee: University of Puerto Rico License No.: 52-01946-07

Location: San Juan, PR Amendment No.: 23

License Type: Medical -- Broad Type of Action: Amendment

Date Issued: 04/26/99 License Reviewer: HB

File No.: 29

Licensee: Department of the Army License No.: 01-00126019

Location: Redstone Arsenal, AL Amendment No.: 07

License Type: Other-Service Provider Type of Action: Renewal

Date Issued: 04/20/01 License Reviewer: DC

File No.: 30

Licensee: Department of the Army License No.: 45-00953-01

Location: Ft. Belvoir, VA Amendment No.: 40

License Type: R&D – Broad, Type A Type of Action: Renewal

Date Issued: 06/09/00 License Reviewer: OMB

Comments:

a) No Materials Licensing Milestone Form for this renewal in the file.

b) Additional information from the licensee dated 08/22/00 indicated that there had been a

telephone conversation discussing licensing issues. There was no telephone deficiency

documentation in the file. 
Region II Proposed Final Report Page D.8

License Casework Reviews

File No.: 30

Licensee: Department of the Army License No.: 45-00953-01

Location: Ft. Belvoir, VA Amendment No.: 41

License Type: R&D – Broad, Type A Type of Action: Amendment

Date Issued: 12/17/01 License Reviewer: BP

File No.: 31

Licensee: Department of the Navy License No.: 45-23645-01NA

Location: Arlington, VA Amendment No.: 12

License Type: Master Materials License Type of Action: Amendment

Date Issued: 07/28/01 License Reviewer: JP

File No.: 32

Licensee: Sensor Services, Inc. License No.: 32-25568-02G

Location: Sherrills Ford, NC Amendment No.:

License Type: Distribution -- GL Type of Action: New

Date Issued: 07/06/01 License Reviewer: JP
 APPENDIX E

INCIDENT CASEWORK REVIEWED

NOTE: ALL INCIDENTS LISTED WITHOUT COMMENT IS INCLUDED FOR

COMPLETENESS ONLY; NO SIGNIFICANT COMMENTS WERE IDENTIFIED BY THE IMPEP

TEAM.

File No.: 1 

Licensee: Isomedix Operations, Inc. License No.: 52-24994-01

Site of Incident: Vega Alta, PR Incident ID No: NMED 980579

Date of Incident: 5/12/98 Type of Incident: Source rack cable damaged

Investigation Date: 5/13/98 Type of Investigation: Special inspection

Summary of Incident and Final Disposition: Licensee reported a source rack cable failure. 

Special inspection was held while vendor personnel replaced cable. No apparent reason was

found for cable failure..

File No.: 2

Licensee: V. A. Medical Center License No.: 01-00643-02 

Site of Incident: Birmingham, AL Incident ID No: NMED 020217 

Date of Incident: 2/25/02 Type of Incident: Receipt of contaminated package 

Investigation Date: 2/26/02 Type of Investigation: Telephone inquiry

Summary of Incident and Final Disposition: Licensee received radiopharmaceutical package

containing 1 millicurie of thallium 201 with removal contamination. While the thallium was not

NRC licensed material, the contamination was identified as technetium-99m which is licensed

material. Contamination levels were 969 dpm/cm2 (greater than four times the allowable limit). 

Package was from an agreement state licensee. Telephone inquiry was conducted and the

agreement state contacted. 

File No.: 3

Licensee: Pharmalogic of West Virginia License No.: 47-25375-01MD

Site of Incident: Bridgeport, WV Incident ID No: NMED 010826

Date of Incident: 9/09/01 Type of Incident: Transportation

Investigation Date: Next Routine Inspection Type of Investigation: Routine Inspection

Summary of Incident and Final Disposition: Licensee vehicle transporting a container with 0.5 Ci

of Tc-99m was involved in a single car accident. Local volunteer fire department personnel 

responded to the accident and found the container intact. Radiological surveys confirmed no

detectable contamination or elevated dose rates. Follow-up will be at next routine inspection. 

Licensee is a Priority 1 licensee and last routine inspection was in July 2001. 

Comment:

a) NMED record not complete pending next inspection.
Region II Proposed Final Report Page E.2

Incident Casework Reviews

File No.: 4

Licensee: I. Gonzalez Martinez Oncological Hospital License No.: 52-13471-01 

Site of Incident: Hato Rey, PR Incident ID No: NMED 010421

Date of Incident: 3/14/01 Type of Incident: Loss of licensed material 

Investigation Date: 3/29/01 Type of Investigation: Special Inspection

Summary of Incident and Final Disposition: Four 24.4 mCi Cs-137 capsules were misplaced

and later found in a trash compactor resulting in unnecessary exposure to employees. A

special inspection was conducted promptly in March 2001, the Office of Investigation reviewed

the event and no willfulness was determined. Escalated enforcement was issued in March

2002. 

File No.: 5

Licensee: West Virginia University License No.: 47-23035-01 

Site of Incident: Morgantown, WV Incident ID No: NMED 990395

Date of Incident: 6/25/99 Type of Incident: Loss of licensed material 

Investigation Date: None Type of Investigation: None

Summary of Incident and Final Disposition: Licensee received a shipment of S-35 and radiation

specialist initially indicated package was inspected and material was in the package. Written

report and telephone conversation with Licensee later indicated that shipper sent an empty

package. No further investigation was done.

Comment:

a) Next routine inspection report did not document closure of the event and NMED was

not updated to reflect final findings. NMED item not complete. Self identified but not

corrected.

File No.: 6

Licensee: Fairfax County Government License No.: 45-19479-01 

Site of Incident: Lorton, VA Incident ID No: NMED 000003

Date of Incident: 12/22/99 Type of Incident: Fire involving equipment 

Investigation Date: None Type of Investigation: None

Summary of Incident and Final Disposition: Fire in Sludge Processing Building melted lead

shielding in fixed gauge. Vender repaired gauge. Follow-up will be with next regular inspection. 

Comment: 

a) No copy of PN in docket file. NMED not complete, contained only the Event Notification.
Region II Proposed Final Report Page E.3

Incident Casework Reviews

File No.: 7

Licensee: Turabo Corportation License No.: 52-25133-01 

Site of Incident: Ciales, PR Incident ID No: NMED 000313

Date of Incident: 3/02/00 Type of Incident: Lost or Stolen Gauge

Investigation Date: 3/23/00 Type of Investigation: Special Inspection

Summary of Incident and Final Disposition: Licensee portable gauge operator used a private

home electrical outlet to recharge gauge and left it unattended. Homeowner moved gauge and

refused to return it until police filled out report. Special inspection was conducted and escalated

enforcement held. No civil penalty was imposed. 

File No.: 8

Licensee: Law Engineering License No.: 52-25461-01 

Site of Incident: Dorado, PR Incident ID No: NMED 000890

Date of Incident: 11/24/00 Type of Incident: Potential Overexposure

Investigation Date: 11/28/00 Type of Investigation: Special Inspection

Summary of Incident and Final Disposition: Improper radiography source change resulted in

potential extremity overexposure. Special Inspection performed. Licensee and NRC concluded

that exposures less than limits. Failure to perform adequate surveys and failure to implement

emergency response procedures identified. Escalated enforcement taken, no civil penalty was

imposed.

Comment:

a) Docket file missing the Event Notification/Preliminary Notification, 30 day report, special

inspection report, and Enforcement Number/Notice of Violation. All documents were

found in ADAMS. The NMED record did not include a reference for the licensee 30 day

report, but met completeness criteria.

File No.: 9

Licensee: Nuclear Fuel Services, Inc. License No.: SNM-0124

Site of Incident: Erwin, TN Incident ID No: NMED 010314

Date of Incident: 04/01/01 Type of Incident: Safeguards

Investigation Date: 04/10-12/01 Type of Investigation: Special

Summary of Incident and Final Disposition: A loss of the offsite power supply along with the

failure of the licensee’s onsite uninterruptible power supply (UPS) system caused a loss of

power to certain safety and safeguards equipment. After the initial event, the UPS failed

several times while the licensee performed system testing and preventive maintenance. The

age of the UPS batteries and the deficiencies in the maintenance program may have caused

the failure. 

Comment:

a) NMED records not complete.
Region II Proposed Final Report Page E.4

Incident Casework Reviews

File No.: 10

Licensee: Westinghouse License No.: SNM-1107

Site of Incident: Columbia, SC Incident ID No: NMED 020285

Date of Incident: 03/13/02 Type of Incident: Bulletin 91-01 event

Investigation Date: N/A Type of Investigation: Routine

Summary of Incident and Final Disposition: An operator did not obtain the proper approval prior

to bringing moderator (oil) into the moderator-restricted area. In addition, an equipment failure

caused the oil to splash onto the bulk-blending tank. This is a loss of double contingency for

criticality safety controls. However, there was not sufficient moderator to cause a criticality, and

there was not a path for the moderator to reach to material in the container. The licensee has

cleaned up and removed the moderator from the area, and initiated a casual analysis to

determine corrective actions to prevent recurrence.
APPENDIX F

DECOMMISSIONING CASEWORK REVIEWS

NOTE: ALL LICENSES LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS

ONLY; NO SIGNIFICANT COMMENTS WERE IDENTIFIED BY THE IMPEP TEAM.

Terminated license review

File No.: 1

Licensee: Waco Oil and Gas License No: 47-18152-02

Location: Glenville, WV License Type: Portable gauge

File No.: 2

Licensee: Mid-Atlantic Resources License No: 47-25070-01

Location: Crab Orchard, WV License Type: Portable gauge

File No.: 3

Licensee: Ft. McClellan License No: 01-02861-04

Location: Ft. McClellan, AL License Type: Contaminated hot cell

File No.: 4

Licensee: Philip Morris License No: 45-00385-04

Location: Richmond, VA License Type: R & D

File No.: 5

Licensee: The Applied Radiant Corporation License No: 45-11496-01

Location: Forest, VA License Type: irradiator category III

Inspections 

File No.: 1

Licensee: Philip Morris License No: 45-00385-04

Location: Richmond, VA License Type: R & D

File No.: 2

Licensee: The Applied Radiant Corporation License No: 45-11496-01

Location: Forest, VA License Type: irradiator category III

File No.: 3

Licensee: Global Nuclear Fuels License No.: SNM-1097

Location: Wilmington, NC License Type: Fuel Facility
Region II Proposed Final Report Page F.2

Decommissioning Casework Reviews

File No.: 4 (two inspections reviewed)

Licensee: Nuclear Fuel Services

Location: Erwin, TN License Type: Fuel facility

FINANCIAL ASSURANCE INSTRUMENT FILES REVIEWED

File No.: 1

Licensee: National Aeronautics and Space Administration (NASA)

Location: Kennedy Space Center, Florida

License No: 09-11149-03

Comment:

a) No copy of authority document included in financial assurance package.

File No.: 2

Licensee: Grammapar

Location: Lynchburg, Virginia

License No: 45-11496-01

File No.: 3

Licensee: Medical College of Hampton Roads

Location: Norfolk, Virginia

License No: 45-15877-01

File No.: 4

Licensee: Isomedix Operations, Inc.

Location: Vega Alta, Puerto Rico

License No: 52-24994-01

Comment:

a) No Schedule C in Standby Trust

File No.: 5

Licensee: Department of the Army

Location: Waterways Experiment Station

License No: 23-01544-10

Comment:

a) No copy of authority document included in financial assurance package. Incorrect title

of Licensee on Inventory.
Region II Proposed Final Report Page F.3

Decommissioning Casework Reviews

File No.: 6

Licensee: Tennessee Valley Authority

Location: TN

License No: 01-06113-04

Comment:

a) No copy of authority document in financial assurance package.

File No.: 7

Licensee: Covance

Location: Princeton, New Jersey

License No: 45-03253-02

Comment:

a) Standby trust agreement lists an old bank which extended a line of credit. 

File No.: 8

Licensee: Union Carbide Chemical and Plastics Company

Location:

License No: 47-00260-02

Comment: 

a) No Schedule C, no Certificate of Resolution. Licensee name incorrect on both License

Tracking System and Inventory List (Union Carbide Corporation listed v UC Chemical

and Plastics)

File No.: 9

Licensee: Allegheny Wireline Services

Location: Weston, West Virginia

License No: 47-11976-011

File No.: 10

Licensee: Belair Quartz

Location: Virgin Islands

License No: 55-23732-02

Comment: 

a) Three License Numbers: 55-23732-01 on the folder in safe, 55-23732-02 on Inventory,

LTS, and NRC RII documents, and 55-23832-02 on Escrow documentation and

Licensee documents. Escrow was still executed.