June 29, 2005

Mr. Alex Haartz, Administrator

State Health Division

Department of Human Resources

505 East King Street

Carson City, NV 89701

Dear Mr. Haartz:

On June 20, 2005, the Management Review Board (MRB) met to consider the proposed final

Integrated Materials Performance Evaluation Program (IMPEP) report on the Nevada

Agreement State Program. The MRB found the Nevada program adequate to protect public

health and safety and compatible with the U.S. Nuclear Regulatory Commission’s program.

Section 5.0, page 15, of the enclosed final report presents the IMPEP team’s recommendations

for the State of Nevada. We request your evaluation and response to the recommendations

within 30 days from receipt of this letter.

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. 

I also wish to acknowledge your continued support for the Radiation Control Program and the

excellence in program administration demonstrated by your staff, as reflected in the team’s

findings. I look forward to our agencies continuing to work cooperatively in the future.

Sincerely,

/RA/

Martin J. Virgilio

Deputy Executive Director for Materials, Research, 

 State and Compliance Programs

Office of the Executive Director for Operations

Enclosure:

As stated

cc: Stanley Marshall, Chief

Bureau of Health Protection Services

Robert Loux, Executive Director

Agency for Nuclear Projects

State Liaison Officer

Steve Collins, IL

OAS Liaison to the MRB
June 29, 2005

Mr. Alex Haartz, Administrator

State Health Division

Department of Human Resources

505 East King Street

Carson City, NV 89701

Dear Mr. Haartz:

On June 20, 2005, the Management Review Board (MRB) met to consider the proposed final

Integrated Materials Performance Evaluation Program (IMPEP) report on the Nevada

Agreement State Program. The MRB found the Nevada program adequate to protect public

health and safety and compatible with the U.S. Nuclear Regulatory Commission’s program.

Section 5.0, page 13, of the enclosed final report presents the IMPEP team’s recommendations

for the State of Nevada. We request your evaluation and response to the recommendations

within 30 days from receipt of this letter.

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. 

I also wish to acknowledge your continued support for the Radiation Control Program and the

excellence in program administration demonstrated by your staff, as reflected in the team’s

findings. I look forward to our agencies continuing to work cooperatively in the future.

Sincerely,

/RA/

Martin J. Virgilio

Deputy Executive Director for Materials, Research, 

 State and Compliance Programs

Office of the Executive Director for Operations

Enclosure:

As stated

cc: Stanley Marshall, Chief,

Bureau of Health Protection Services bcc: Chairman Diaz

Commissioner McGaffigan

Robert Loux, Executive Director Commissioner Merrifield

Agency for Nuclear Projects Commissioner Jaczko

State Liaison Officer Commissioner Lyons

Steve Collins, IL

OAS Liaison to the MRB

Distribution: See next page.

DOCUMENT NAME: E:\Filenet\ML051790203.wpd

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INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM

REVIEW OF NEVADA AGREEMENT STATE PROGRAM

March 15 - 18, 2005

FINAL REPORT

U.S. Nuclear Regulatory Commission
Nevada Final Report Page 1 

1.0 INTRODUCTION

This report presents the results of the review of the Nevada Agreement State program. The

review was conducted during the period of March 15-18, 2005, by a review team comprised of

technical staff members from the Nuclear Regulatory Commission (NRC) and the Agreement

State of Massachusetts. 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 February 26, 2004, NRC Management Directive

5.6, "Integrated Materials Performance Evaluation Program (IMPEP)." Preliminary results of

the review, which covered the period September 15, 2001 to March 18, 2005 for the indicators

Technical Quality of Inspections and Technical Quality of Licensing and April 11, 2003 to 

March 18, 2005 for the remaining five performance indicators reviewed were discussed with

Nevada management on March 18, 2005.

A draft of this report was issued to Nevada for factual comment on April 12, 2005. The State

responded by E-mail from Stanley Marshall on May 31, 2005. The Management Review Board

(MRB) met on June 20, 2005 to consider the proposed final report. The MRB found the Nevada

radiation control program adequate to protect public health and safety and compatible with

NRC's program.

The Nevada Agreement State program is administered by the Radiological Health Section (the

Section). The Section is located within the Bureau of Health Protection Services, which is part

of the State Health Division. The State Health Division reports to the Department of Human

Resources. Within the Section, there are two offices (Carson City and Las Vegas) that are

each headed by a supervisor. Both offices have the responsibility for the inspection of

radioactive materials licenses and response to radioactive materials incidents. In addition, both

offices are responsible for machine produced radiation and mammography. Program

management and radioactive material licensing is based in the Carson City office.

Organization charts for the State of Nevada and the Bureau of Health Protection Services are

included as Appendix B. The Nevada Agreement program regulates approximately 265 specific

licenses authorizing Agreement materials. The review focused on the program as it is carried

out under the Section 274b. (of the Atomic Energy Act of 1954, as amended) Agreement

between the NRC and the State of Nevada.

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

performance indicators was sent to the State on November 3, 2004. A copy of the official letter

and questionnaire can be found on NRC’s Agencywide Document Access and Management

System (ADAMS) using the Accession Number ML043080251. The State provided a partial

response to the questionnaire on March 7, 2004 and a complete response on March 18, 2005 

A copy of the State’s questionnaire response can be found in ADAMS using the Accession

Number ML050810487.

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

Nevada's response to the questionnaire; (2) review of applicable Nevada’s statutes and

regulations; (3) analysis of quantitative information from the Section’s licensing and inspection

database; (4) technical evaluation of selected licensing and inspection actions; (5) field

accompaniments of three Nevada inspectors; and (6) interviews with staff and management to
Nevada Final Report Page 2 

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

the IMPEP performance criteria for each common and applicable non-common performance

indicator and made a preliminary assessment of the Nevada Agreement State program’s

performance.

Section 2 discusses the State’s actions in response to previous IMPEP review

recommendations and the team’s conclusions regarding the closure of those recommendations. 

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 performance 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 the State. A response is requested from the State to all recommendations in

the final report.

2.0 STATUS OF ITEMS IDENTIFIED IN THE PREVIOUS REVIEW

During the previous IMPEP review which concluded on September 14, 2001, seven

recommendations were made and the results transmitted to Ms. Yvonne Sylva, Administrator,

Nevada Health Division on February 26, 2002. During the follow-up IMPEP review, which

concluded on April 10, 2003, six of the recommendations from the September 2001 review

were closed and two new recommendations were made. The results of the follow-up IMPEP

review were transmitted to Ms. Sylva on July 22, 2003. The review team’s evaluation of the

current status of the recommendations is as follows:

1. The review team recommends that the State, in accordance with the Department of

Administration audit report, increase the radioactive materials program staff to meet

program needs. (Section 2.1 of the 2003 follow-up report)

Current Status: The Program has been unable to fill four vacancies to increase the

radioactive materials program staff in accordance with the Department of Administration

audit report. Since some of the circumstances related to the unfilled vacancies and long

term staff stability has changed since the last review, the review team is closing this

recommendation and will make another recommendation. This matter is discussed in

more detail in Section 3.1.

2. The review team recommends that the State provide training to current and future

technical personnel, either by formal course work or equivalent, as prescribed by the

Division’s training policy. (Section 2.1 of the 2003 follow-up report)

Current Status: As a result of the Section increasing their fees and having this revenue

retained in a dedicated fund, the Section has adequate revenue to schedule training

needed for technical staff. The Section has requested training for one inspector to

attend two courses during 2005. In addition, the Bureau has scheduled a transportation

course in Las Vegas for all staff in April 2005. The Section has also revised their

training procedures to identify additional courses required by staff on an Annual Training

Needs Forecast Worksheet. This recommendation is closed.

3. The review team recommends that the Section take appropriate measures to conduct

core inspections (including initial inspections) in accordance with the NRC’s inspection
Nevada Final Report Page 3 

priority system. (Recommendation 1 from the 2001 report)

Current Status: During the review period, the Section reassigned staff from the x-ray

program to aid in addressing the backlog of overdue materials inspections and to

complete materials inspections in a timely manner. The review team determined that 6

of the 81 “core” (Priority 1, 2, and 3) and initial inspections conducted by the Section

were performed overdue. This represents a significant improvement in performance. 

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) Technical Staffing and

Training (2) Status of Materials Inspection Program; (3) Technical Quality of Inspections; 

(4) Technical Quality of Licensing Actions; and (5) Technical Quality of Incident and Allegation

Activities.

3.1 Technical Staffing and Training

Issues central to the evaluation of this indicator include the Section’s turnover, as well as the

technical qualifications and training histories of the staff. To evaluate these issues, the review

team examined the Section's questionnaire response relative to this indicator, interviewed

Section management and staff, and considered any possible workload backlogs.

The Section, headed by the Section Chief, regulates approximately 265 specific licenses with

4.0 full time equivalents (FTE) currently assigned to implement the radioactive materials

licensing and inspection programs. During the review period, the Section reassigned staff from

the x-ray program to aid in addressing the backlog of overdue materials inspections and to

complete materials inspections in a timely manner.

As a result of the performance issues identified during the 2001 IMPEP review and a significant

budgetary crisis in the State, the Department of Human Resources queried the Governor’s

office whether the State should continue to administer the radioactive materials program or

transfer the responsibility back to the NRC. The Department of Administration performed an

audit of the program to answer this question and on March 19, 2003, the audit report was

presented to the Executive Branch Audit Committee, chaired by the Governor. Two specific

recommendations were made: (1) Raise licensing fees to cover the State’s cost and continue

administering the program; and (2) Evaluate staffing levels to ensure the program is operating

effectively and complies with State and Federal requirements. The Health Division responded

to the audit report indicating that proposed regulations to increase fees are expected to be

presented for adoption by the Nevada State Board of Health on August 15, 2003. The fee

increase for the Section’s radioactive materials program was approved in March 2004 and went

into effect in Nevada’s Fiscal Year (FY) 2005 which started July 1, 2004.

During the 2003 Nevada Legislative session, the legislature approved a biannual budget for FY

2004 and 2005. For FY 2004, the budget for the Section included funds from the general fund

and approval to increase fees. Since approximately 25% of the Section’s budget in FY 2004

involved general funds (in addition to fee revenue), any funds not used by the Section in the FY

were returned to the general fund. For FY 2005, the budget included approval for a dedicated
Nevada Final Report Page 4 

fund that the fees would be deposited for the Section’s operations. Since the Section’s FY

2005 budget included no general funds, any fee revenue collected by the Section and not used

is retained in the Section’s dedicated fund and available in the next fiscal year. This change in

the Section’s funding is significant since it provides funding stability and allows the Section to

retain revenue for use at a later time for training and other program expenditures needed to

improve the program. For this fiscal year, this was of particular significance since the revenue

that was to be used for the salaries of vacant positions can be retained by the Section.

In January 2004, the Nevada Interim Finance Committee approved six new positions for the

Section (for radioactive materials, mammography and x-ray programs) and the associated

funding support. As a result of these new positions and since the follow-up review, one staff

member left the Section and three staff members were hired. Two of new staff members were

experienced individuals from other Agreement State programs and are currently in the Las

Vegas office. Another experienced individual from Nevada’s Department of Environmental

Protection was hired as the supervisor of the Carson City office. Four vacancies exist from the

new positions created in 2004 and in-house promotions: two vacancies in the Carson City

office, and two vacancies in the Las Vegas office.

The Section has not been able to produce successful candidates for the four vacancies due to

the current pay structure. The State’s pay structure is not competitive to attract qualified

individuals due to other employment opportunities available from the US Department of Energy

and its contractors and the high cost of living in the Carson City area. The team discussed with

Section management a number of different short- and long-term strategies to hire qualified

candidates. These include the use of contractors, tuition reimbursement in return for State

service, reclassifying current positions to a higher pay scale and use of fee revenue in the

dedicated fund to increase salaries. Section management indicates that they have been

unsuccessful with some of these strategies in the past, but indicated that recent changes in

upper management and the availability of the dedicated fund as possible opportunities for

success in the future.

The team also noted that there are a number of current staff in the Section who will be eligible

for retirement within the next five years. Without qualified staff entering the program, the team

concluded that the experienced staff that retire or leave the Section will likely have a negative

impact on the future performance of the radioactive materials program. Section management

acknowledged that this is a real concern and that these circumstances emphasize the need to

promptly fill the current vacancies. The review team recommends that the State develop and

implement a staffing plan to fill current vacancies, meet growing program needs and maintain

long-term program stability.

The qualifications of the staff were determined from the questionnaire, training records, and

interviews of personnel. The staff is well qualified from an education and experience

standpoint. All staff have at least a Bachelor’s degree in the sciences, or equivalent training

and experience. 
Nevada Final Report Page 5 

Due to budget limitations in FY 2004, training for Section staff virtually halted at the beginning

of the review period. The limited amount of the training budget, along with out-of-State travel

restrictions, has severely limited the ability of the program to maintain a technically trained staff

in accordance with its training policy. With increased fees and a dedicated fund, the Section

now has sufficient resources to send individuals out-of-state for training. In response to 

STP-05-003 “Training Needs Survey,” the Section has requested that one of the individuals

hired since the last review be registered for two training courses (industrial radiography and

inspection procedures). The Section will also address a training issue from the previous review

where it was identified that only one staff member had taken the transportation training course. 

In April 2005, the Section held a transportation training course (equivalent to the NRC’s

transportation course) for all technical staff in Las Vegas.

The Section’s training policy is similar to the NRC/Organization of Agreement States Training

Working Group Report. The policy requires that technical staff complete seven core training

courses or equivalent alternatives such as on-the-job training or computer-based training. Five

additional training courses are identified in the policy for advanced staff training. Since the last

review, the Section has initiated a revision of its training policy and improved documentation of

completed training. During the review, the team discussed the revisions with the Carson City

and Las Vegas office supervisors including the proposed changes to NRC’s Office of State and

Tribal Programs (STP) Procedure SA-103 “Reviewing the Common Performance Indicator,

Technical Staffing and Training.” This project is scheduled to be completed by June 2005.

The team also noted that revision of the training program is part of a larger effort by the Section

to revise their policy and procedure manual used for all aspects of the Section’s licensing and

inspection programs. The team agrees with the Section’s assertion that the large number of

changes in regulations, particularly for medical licensees, requires a number of procedures be

updated. Section management indicated that this project should be finished this year.

The State does not have an advisory board for radiological issues.

Based on the IMPEP evaluation criteria, the review team recommended, and the MRB

concurred that Nevada's performance with respect to the indicator, Technical Staffing and

Training, be found satisfactory.

3.2 Status of Materials Inspection Program

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

inspections, initial inspections of new licensees, the timely dispatch of inspection findings to

licensees, and the performance of reciprocity inspections. The review team’s evaluation is

based on the Section’s response to the questionnaire relative to this indicator, data gathered

independently from the Section’s licensing and inspection data tracking system, the

examination of completed licensing and inspection casework, and interviews with staff.

The team found that the Section’s inspection priorities require inspections as frequent as those

specified in NRC Manual Chapter (MC) 2800 for similar license types, with the exception of

intravenous brachytherapy (IVB). MC 2800 specifies a Priority 2 inspection frequency for

medical therapy - other emerging technologies, such as IVB, while the Section specifies a

Priority 3 inspection frequency. All other licensees are inspected at the frequency specified in

MC 2800. Since IVB has been replaced by other medical procedures, the review team
Nevada Final Report Page 6 

concluded that no specific recommendation was needed. Section management inquired if other

State programs have used inspection intervals less frequent than the NRC. The review team

indicated that a few States do use less frequent inspection frequencies for specific medical

modalities, and that these changes were agreed to by the MRB. Section management agreed

to consult with STP in the future if they decided to inspect a class of licensees at an inspection

interval less frequent than NRC.

In their response to the questionnaire, the Section indicated that no routine inspections were

overdue by more than 25 percent of the NRC frequency. The team reviewed lists of information

for all inspections conducted and all new licenses issued during the period. The review team

found it difficult to review the Section’s reports from their database because of the lack of

historical data and its reliability. The Section maintains a licensee database that does not retain

historical data and thus provides current year data only. At the time of the review, the database

was experiencing reliability problems and could not be accessed by the Section in Carson City. 

The Section management also acknowledged that the Las Vegas office was not linked to the

database at this time, but was in the process of having it linked. Due to the database’s

limitations and reliability problems, the Section had to provide the review team with a

handwritten list of current and historical inspection data to evaluate this indicator. The review

team also verified the information by conducting a similar file review.

Based on data provided by the Section, the review team determined that the Section has 68

Priority 1, 2 and 3 licensees according to NRC inspection priorities, and that 81 Priority 1, 2 and

3 and initial inspections were due during the review period. Six Priority 1, 2 and 3 inspections

were conducted overdue according to MC 2800, four of which were inspections of medical

facilities using IVB. This represents a significant improvement in performance for this indicator

compared to the two previous reviews.

The review team noted that 49 of the 81 due inspections were initial inspections, all of which

were conducted within one year of license issuance. The Section’s practice with respect to new

licenses is to conduct the initial inspection within six months of license issuance.

The review team identified three inspections of gauge licensees that were overdue at the time

of the review and have been open for several years. The Section had attempted to perform

these inspections but was now unable to locate the licensees after several attempts. The

review team determined that the failure to track these licensees was due to the lack of a policy

to handle licensees who have not used licensed material for long periods of time and the

limitations in the inspection tracking database, as discussed above. These issues are

discussed further in Sections 3.3 and 3.4, respectively.

During the review of selected inspection casework, the team evaluated the Section’s timeliness

in providing inspection findings to the licensees. The team determined that the Section issued

all inspection findings to the licensees within 30 days of the inspection.

To evaluate the reciprocity inspection program, the review team evaluated the inspection files

and the Section’s response to the IMPEP questionnaire. The review team determined that the

Section met and exceeded NRC’s criteria of inspecting 20 percent of candidate licensees

operating under reciprocity for the review period. The Section conducted 11 inspections of the

39 Priority 1, 2 and 3 reciprocity licensees (28%) who worked in the State during the review

period. 
Nevada Final Report Page 7 

Based on the IMPEP evaluation criteria, the review team recommended, and the MRB

concurred that Nevada’s performance with respect to the indicator, Status of the Materials

Inspection Program, be found satisfactory. 

3.3 Technical Quality of Inspections

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

notes for 16 radioactive materials inspections conducted during the review period. The

casework reviewed included inspections conducted by five current and one former Section

inspectors, and covered inspections of various types including medical (diagnostic, therapy,

teletherapy, and brachytherapy), fixed and portable gauges, industrial radiography, gamma

knife, HDR, academic broad scope, and nuclear pharmacy. Appendix C lists the inspection

casework files reviewed for completeness and adequacy with case-specific comments, and the

results of the inspector accompaniments

Based on casework reviewed, the review team noted that routine inspections covered all

aspects of licensed radiation programs. The review team found that inspection reports were

thorough, complete, consistent, and of high quality, with sufficient documentation to ensure that

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

supported violations, recommendations made to licensees, unresolved safety issues, and

discussions held with licensees during exit interviews. Team inspections were frequently

performed for larger and complex licenses and for training purposes.

The inspection procedures utilized by the Section are generally consistent with the inspection

guidance outlined in MC 2800. A Radioactive Materials Inspection Report is completed by the

inspector which is then reviewed and signed by a supervisor, generally within a few days of the

inspection. Supervisory accompaniments are being conducted annually for all inspectors.

The team determined that the inspection findings were appropriate and prompt regulatory

actions were taken, as necessary. The Section normally issues Compliance letters or Notices

of Violation (NOV) as it deems appropriate. Violations of minor safety or environmental

concerns, which are at or below the level of significance equivalent to NRC’s Severity Level IV

violation, are documented in the inspection report and generally issued to the licensee as Items

of Concern (IOC). The licensee is required to respond to the noted IOC within 30 days. NOVs

are routinely issued for licensees with repeat violations and IOC, which are elevated above the

IOC level. All inspection findings are clearly stated and documented in the report, and reviewed

by the appropriate supervisor and the appropriate Section administrator, before being sent to

the licensee with the appropriate letter detailing the results of the inspection.

Three inspectors were accompanied during inspections by a review team member from 

January 31 to February 2, 2005. The inspectors were accompanied during inspections of

nuclear medicine facilities. The accompaniments are identified in Appendix C. During the

accompaniments, each inspector demonstrated appropriate performance-based inspection

techniques and knowledge of the regulations. The inspectors were well-trained, prepared and

thorough in their reviews of the licensees’ radiation safety programs. Overall, each inspector

conducted effective interviews with appropriate licensee personnel, observed licensed

operations, conducted confirmatory measurements, and utilized good health physics practices. 

Their inspections were adequate to assess radiological health and safety at the licensed

facilities.
Nevada Final Report Page 8 

As discussed in Section 3.2, the team identified three gauge licensees which the Section was

tracking as overdue since the Section has been unable to locate the licensees. During the

review of inspection casework, the review team identified another gauge licensee inspected by

the Section that had not used their licensed material for more than eight years and failed to

maintain inventory records during the most recent inspection. The similarities among the three

licensees that the Section was unable to locate and the licensee recently inspected that is not

using their material was bought to the attention of the Section. Based on discussions with

Section staff and management, the review team concluded that the Section has adequate

regulations to enforce timely notification and license termination and ensure proper transfer and

disposal of licensed materials, but had not used them in either of the situations. Different

strategies were discussed with Section staff to use in these circumstances including

enforcement action based on their decommissioning timeliness rule, increased inspection

frequencies and higher fees. In addition, the review team indicated that any licensed materials

not accounted for in these circumstances should be reported as lost, stolen or abandoned. The

review team recommends that the Section revise their inspection procedures and provide

training to implement a policy for timely and orderly license termination of licensed materials not

in use.

It was noted that the Section has an adequate supply of survey instruments to support the

current inspection program. Appropriate, calibrated survey instrumentation such as Geiger

Mueller (GM) meters, scintillation detectors, ion chambers, and micro-R meters were observed

to be available. The instruments are calibrated at least annually by a commercial calibration

service. The Section has portable analytical instruments and has access to a commercial

contract laboratory.

Based on the IMPEP evaluation criteria, the review team recommended, and the MRB

concurred that Nevada’s performance with respect to the indicator, Technical Quality of

Inspections, be found satisfactory.

3.4 Technical Quality of Licensing Actions

The review team interviewed license reviewers, evaluated the licensing process, and examined

licensing casework for 16 specific licenses. Licensing actions were reviewed for completeness,

consistency, proper radioisotopes and quantities, qualifications of authorized users, adequate

facilities and equipment, adherence to good health physics practices, financial assurance,

operating and emergency procedures, appropriateness of the license conditions, and overall

technical quality. The casework files were also reviewed for timeliness, use of appropriate

deficiency letters and cover letters, reference to appropriate regulations, product certifications,

supporting documentation, consideration of enforcement history, pre-licensing visits,

supervisory review as indicated, and proper signatures. The files were checked for retention of

necessary documents and supporting data. 
Nevada Final Report Page 9 

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

which were completed during the review period by four different reviewers. The sample

included the following types: academic broad scope, gamma knife, research and development,

nuclear medicine, high dose afterloaders, and portable gauges. Licensing actions reviewed

included five new license applications, three renewals, six amendments, and two terminations. 

A list of the casework evaluated with case-specific comments can be found in Appendix D.

Overall, the review team found that the licensing actions were thorough, complete, consistent,

and of high quality with health and safety issues properly addressed. License tie-down

conditions were stated clearly, backed by information contained in the file, and enforceable. 

The licensee’s compliance history was taken into account when reviewing renewal applications

and amendments. Deficiency letters clearly state regulatory positions, are used at the proper

time, and identify deficiencies in the licensees' documents. Terminated licensing actions are

well-documented, showing appropriate transfer and survey records.

The administrative staff receives and routes all licensing actions primarily to one senior reviewer

who assigns actions to the other reviewers. There are no due dates or goals for the completion

of licensing actions, however, the review team found that most of the licensing actions were

completed within three months after receipt by the Section. New applications and amendments

are given priority over renewals. The senior reviewer conducts a cursory review of the renewal

applications for the purpose of identifying any program changes that need to be addressed in a

more timely manner.

The review team found that the Section’s current database system for handling licensing

actions consists of a spreadsheet maintained by the senior reviewer. Since the database is not

accessible electronically by Section management, it has limitations in terms of a management

tool to monitor the status of licensing actions. These limitations were exemplified during the

review when the review team found an unprocessed and untracked amendment request dated

December 2004 in the license file. Coupled with the difficulties and limitations discussed in

Section 3.2 regarding the Section’s inspection database, the review team concluded that the

existing databases used for inspection and licensing do not provide an effective planning,

tracking or management tool for the Section’s Carson City and Las Vegas offices. During

discussions with Section staff and management, the review team noted that the Section

management was working to correct the database problems. Section staff was knowledgeable

of successful licensing and inspection databases employed by other States. The review team

recommends that the Section develop, implement and maintain a reliable and comprehensive

licensing and inspection database that serves as an effective and efficient planning, tracking

and management tool.

Based on the IMPEP evaluation criteria, the review team recommended, and the MRB

concurred that Nevada's performance with respect to the indicator, Technical Quality of

Licensing Actions, be found satisfactory.

3.5 Technical Quality of Incident and Allegation Activities

In evaluating the effectiveness of the Section’s actions in responding to incidents, the review

team examined the Section’s response to the questionnaire relative to this indicator, reviewed

the incident reports for Nevada in the Nuclear Material Events Database (NMED) against those

contained in the Section’s files, and evaluated reports and supporting documentation for eight
Nevada Final Report Page 10 

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

included in Appendix E. The team also reviewed the Section’s response to one allegation

involving radioactive materials referred to the State by the NRC during the review period.

The incidents selected for review included the event categories of damaged equipment and lost

and stolen radioactive material. The review team found that the Section’s response to incidents

was complete and comprehensive. Initial responses were prompt and well-coordinated, and the

level of effort was commensurate with the health and safety significance. The Section

dispatched inspectors for on-site investigations when appropriate, and took suitable

enforcement and follow-up actions.

The staff member who receives the initial notification has responsibility for initial response and

follow up to the incident. Each incident receives an unique tracking number. Incidents with

potential for impacting public safety are evaluated by the Section management in order to

determine the appropriate response. Documentation related to an incident is placed in the

Section’s incident files and includes a cover sheet that summarizes the event and documents

supervisory review 

The review team identified 16 radioactive materials incidents during the review period including

11 incidents that required reporting under the NRC criteria. The review team identified one

event that occurred in January 2005 that was not reported to the NRC. This event involved a

portable gauge damaged at a temporary job site that was subsequently returned to the

manufacturer for disposal. After this event was discussed with the Section, they agreed that

the event should be reported. The Section reported the event to the NRC on March 18, 2005. 

Nearly all reportable events involved lost, stolen or damaged portable gauges. Except as noted

above, the team found that reportable incidents were appropriately reported to the NRC

Operations Center in a timely manner. Appropriate and timely follow-up reports were provided

to the NRC contractor maintaining NMED.

During the review period, the Section received one allegation referred to the Section by the

NRC. A review of the casework and the file for this allegation indicated that the Section took

prompt and appropriate action in response to the concerns raised. The allegation was reviewed

and appropriately closed, and the alleger was informed of the results. The team noted that

allegations were treated and documented internally in the same manner as incidents. 

Allegation files are maintained separately. There were no performance issues identified from

the review of the casework documentation.

The Nevada public records statute found in Nevada Revised Statutes Section 239.010, requires

that records of a governmental entity, the contents of which are not otherwise declared by law

to be confidential and must be available for public review. These publicly available records

include alleger identities.

Based on the IMPEP evaluation criteria, the review team recommended, and the MRB

concurred that Nevada’s performance with respect to the indicator, Technical Quality of Incident

and Allegation Activities, be found satisfactory.
Nevada Final Report Page 11 

4.0 NON-COMMON PERFORMANCE INDICATORS

IMPEP identifies four non-common performance indicators to be used in evaluating Agreement

State programs: (1) Legislation and Program Elements Required for Compatibility; (2) Sealed

Source and Device Evaluation Program; (3) Low-Level Radioactive Waste Disposal Program;

and (4) Uranium Recovery Program. Nevada’s Agreement does not cover a uranium recovery

program, so only the first three non-common performance indicators were applicable to this

review.

4.1 Compatibility Requirements

4.1.1 Legislation

Along with their response to the questionnaire, the Section provided the review team with the

opportunity to review copies of legislation that affect the radiation control program. Legislative

authority to create an agency and enter into an Agreement with the NRC is granted in Nevada

Revised Statutes (NRS) Section 459. The Nevada State Health Division is designated as the

State’s radiation control agency. Other NRS sections that effect the Agreement State program

include NRS 439, “Public Heath Administrative Procedures,” and NRS 414, “Emergency

Response.” The review team noted that no legislation affecting the radiation control program

was passed since being found adequate during the previous review, and the team found that

the State legislation is adequate.

4.1.2 Program Elements Required for Compatibility

The Nevada Radiological Health Rules, found in Chapter 459 of the Nevada Administrative

Code (NAC), apply to all ionizing radiation, whether emitted from radionuclides or devices. 

Nevada requires a license for possession, and use, of all radioactive material including naturally

occurring materials, such as radium, and accelerator produced radionuclides. Nevada also

requires registration of all machines specifically designed to produce x-rays or other ionizing

radiation.

The review team examined the procedures used in the State’s regulatory process and found

that Nevada offers the public the opportunity to comment on proposed regulations and

participate in public hearings before the Board of Health. Procedures also require the proposed

regulations, and proposed hearing date, be publicized. A written response to all written public

comments must be part of the staff presentation to the Board.

The team evaluated Nevada’s response to the questionnaire relative to this indicator, reviewed

the status of the regulations required to be adopted by the State under the Commission’s

adequacy and compatibility policy, and verified the adoption of regulations with data obtained

from the State Regulation Status Data Sheet as maintained by STP.

Since the follow-up IMPEP review in April 2003, the Section has adopted three regulations by

legally binding requirements (i.e., license conditions). The Section provided the license

conditions to the NRC for review and there were no comments. The amendments covered by

license conditions are:

• “Transfer for Disposal and Manifests: Minor Technical Conforming Amendment,”
Nevada Final Report Page 12 

10 CFR Part 20 (63 FR 50127) that became effective November 20, 1998.

• “Respiratory Protection and Controls to Restrict Internal Exposures,” 10 CFR Part 20 

(64 FR 54543 and 64 FR 55524) that became effective on February 2, 2000.

• “Energy Compensation Sources for Well Logging and Other Regulatory Clarifications”

10 CFR Part 39 (65 FR 20337) that became effective on May 17, 2000.

Current NRC policy requires that Agreement States adopt certain equivalent regulations or

legally binding requirements no later than three years after they are effective. The following two

regulations are overdue:

• “Requirements for Certain Generally Licensed Industrial Devices Containing Byproduct

Material,” 10 CFR Parts 30, 31, 32 (65 FR 79162) that became effective on February 16,

2001

• “Revision of the Skin Dose Limit,” 10 CFR Part 20 (67 FR 16298) that became effective

on April 5, 2002.

The Section has drafted rule text to meet the requirements of these amendments and this

drafted rule is currently undergoing legal review in the Department. A preliminary review by the

team indicated that the proposed rule language is compatible with the requirements in STP

Procedure SA-200. The Section will be sending in the rule text for NRC review, in accordance

with STP Procedure SA-201, when their internal review process is complete.

The team also identified three amendments that the Section has incorporated into State

regulations, but the rule text has not yet been sent into the NRC for review. A preliminary

review by the team indicated that the rule language is compatible with the requirements in STP

Procedure SA-200. The Section committed to submit to the NRC the Nevada rule sections

covering the following NRC amendments:

• “Decommissioning Recordkeeping and License Termination: Documentation Additions

[Restricted areas and spill sites],” 10 CFR Parts 30, 40 (58 FR 39628) that became

effective on October 25, 1993

• “Timeliness in Decommissioning Material Facilities,” 10 CFR Parts 30, 40, 70 

(59 FR 36026) that became effective on August 15, 1994

• “Resolution of Dual Regulation of Airborne Effluents of Radioactive Materials; Clean Air

Act,” 10 CFR Part 20 (61 FR 65120) that became effective on January 9, 1997. 

The team identified the following NRC amendments that will be needed in the future. The

Section indicated that the regulations would be addressed in upcoming rulemaking or by

adopting alternate legally binding requirements:

• “Medical Use of Byproduct Material,” 10 CFR Parts 20, 32, 35 (67 FR 20249) that

became effective on November 24, 2002.

• “Financial Assurance for Materials Licensees,” 10 CFR Parts 30, 40, 70 that became
Nevada Final Report Page 13 

effective on December 3, 2003.

• “Compatibility with IAEA Transportation Safety Standards (TS-R-1) and Other Safety

Amendments,” 10 CFR Part 71 amendments (69 FR 3698), that became effective on

October 1, 2004.

Based on the IMPEP evaluation criteria, the review team recommended, and the MRB

concurred that Nevada’s performance with respect to the indicator, Compatibility Requirements,

be found satisfactory.

4.2 Sealed Source and Device (SS&D) Evaluation Program

There are currently three manufacturers/distributors licensed by the Section. Two of the

licensees assemble and distribute generally licensed devices in accordance with SS&D registry

sheets issued by other Agreement States. The third licensee manufactures gun and bow sights

in accordance with an NRC issued SS&D registry sheet and distributes them under an NRC

exempt distribution license.

During the review period, no SS&D certificates were issued by the program. The State has

indicated to the NRC that they plan to relinquish the authority to regulate SS&D manufacturers

to the NRC. The Section has prepared a memorandum for senior Department management

and a letter from the Governor to the NRC Chairman requesting the return of the SS&D

program to the NRC. These documents were provided in the State’s IMPEP questionnaire

response. The memorandum and letter are currently with senior Department management for

review. Accordingly, the review team did not review this indicator.

4.3 Low-Level Radioactive Waste (LLRW) Disposal Program

The review team focused on five factors in reviewing the LLRW Disposal Program performance

indicator: (1) Technical Staffing and Training; (2) Status of Inspection Program; (3) Technical

Quality of Inspections; (4) Technical Quality of Licensing Actions; and (5) Technical Quality of 

Incidents and Allegations Activities. In addition, the team evaluated the qualifications of the

technical staff, accompanied two inspectors during the performance of a routine quarterly

inspection of the site, reviewed the Section's written procedures and plans, reviewed

surveillance and inspection reports, and interviewed the principal inspector assigned to the

LLRW project.

The former U.S. Ecology LLRW facility, located in Nye County, opened in September 1962, and

received radioactive waste for burial until December 31, 1992. The site license expired

December 31, 1992, but remained in effect until the licensee completed their obligations

specified in their license and regulations.

The former licensee, U.S. Ecology, completed the State-approved closure plan to stabilize the

site and establish proper security measures on December 30, 1997. The plan was intended to

ensure that the LLRW disposed during the operational phase of the facility continued to remain

in a suitable, stable, and safe condition after site closure. Upon completion of the licensee’s

obligations, the license was transferred to the State of Nevada. The Nevada State Health

Division assumed all oversight responsibilities and became the custodian of the site. The site
Nevada Final Report Page 14 

has continuous security.

It is noted that this LLRW site predates the waste site standards adopted in 10 CFR 61. The

State has the funding and plans to continue surveillance and necessary repair through

inspections and environmental monitoring for 100 years. The State currently owns the 80 acre

LLRW site and leases a 400 acre buffer zone surrounding the site from the U.S. Bureau of

Land Management (BLM). The 80 acres are divided approximately in half, one-half was used

for LLRW disposal, and the other half for hazardous waste disposal, which is still in operation

today. The 400 acre buffer zone is leased by the State from the BLM to ensure no land use. 

The lease expires in 2007.

4.3.1 Technical Staffing and Training

LLRW activities are handled by the Section’s staff, under the direction of the Las Vegas office

supervisor. As required, the Carson City office provides additional review and program

management. The basic qualifications for the LLRW program staff are the same as for the

RAM program staff, as described in Section 3.1.

4.3.2 Status of Inspection Program

Based on the license issued to the State Health Division for this facility, the State is required to

perform quarterly visits. NRC guidance in MC 2800 and MC 2401 require an annual inspection

frequency. The team determined that the Section made at least quarterly visits to the facility

during the review period.

4.3.3 Technical Quality of Inspections

Site post-closure activities include collecting environmental water samples, taking radiation

measurements and inspecting the conditions at the site (e.g., the condition of the security fence

and the trench cap). In addition, the Section continues to monitor for radioactivity in

groundwater.

The review team evaluated documentation for the on-site inspections and site visits conducted

by the Section during the review period. The inspection reports were complete, thorough, and

reviewed by the supervisor in Carson City. Appropriate action was taken by the Section if

conditions warranted corrective actions. During the review period, this included the repair of a

portion of the trench cap with rip-rap that had experienced erosion and the repair of the security

fence damaged by construction equipment. Special inspections of the facility were conducted

as necessary. For example, after a severe weather event, the Section would inspect the trench

cap for erosion.

Supervisory accompaniments of staff that routinely inspects the site are performed on an

annual basis as discussed in Section 3.3.

The review team accompanied two inspectors on February 2, 2005 during a routine quarterly

inspection of the site. This accompaniment is identified in Appendix C. Inspection activities

include radiation surveys and surveys of the site perimeter to observe the condition of the site

fence and of the trench cap. The inspectors walked the trench cap to observe signs of erosion
Nevada Final Report Page 15 

and cracks in the cap and to take radiation surveys. Two State engineers also accompanied

the inspectors to examine the condition of the rip-rap and the trench cap. During the

accompaniments, each of the inspectors demonstrated appropriate inspection techniques and

knowledge of the regulations and the license. The inspectors were well-prepared and thorough

in their review of the site. The inspection was adequate to assess radiological health and safety

and the condition of the site.

4.3.4 Technical Quality of Licensing Actions

Pursuant to NAC 459.822, the license was transferred to the Nevada State Health Division on

December 30, 1997. The current license expires in December 2007. No licensing actions were

completed during the review period. 

The team found through observation and interviews with the Las Vegas staff that applicable

NRC guidance documents that support 10 CFR 61 activities, are available and used as needed.

4.3.5 Response to Incidents and Allegations

There were no incidents or allegations pertaining to the LLRW program during the review

period. 

Based on the IMPEP evaluation criteria, the review team recommended, and the MRB

concurred that Nevada’s performance with respect to the indicator, Low-Level Radioactive

Waste Disposal Program, be found satisfactory.

5.0 SUMMARY

As noted in Sections 3 and 4 above, the review team recommended, and the MRB concurred

that Nevada’s performance be found satisfactory for all eight performance indicators reviewed. 

Accordingly, the review team recommended, and the MRB concurred that the Nevada

Agreement State program be found adequate to protect public health and safety and

compatible with NRC's program and that the next full review take place in approximately four

years. The review team also recommends that the period of monitoring of the State be

discontinued.

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

evaluation and implementation, as appropriate, by the State.

RECOMMENDATIONS

1. The review team recommends that the State develop and implement a staffing plan to

fill current vacancies, meet growing program needs and maintain long-term program

stability. (Section 3.1)

2. The review team recommends that the Section revise their inspection procedures and

provide training to implement a policy for timely and orderly license termination of

licensed materials not in use. (Section 3.3)
Nevada Final Report Page 16 

3. The review team recommends that the Section develop, implement and maintain a

reliable and comprehensive licensing and inspection database that serves as an

effective and efficient planning, tracking and management tool. (Section 3.4)
LIST OF APPENDICES

Appendix A IMPEP Review Team Members

Appendix B Nevada Organization Charts

Appendix C Inspection Casework Reviews

Appendix D License Casework Reviews

Appendix E Incident Casework Reviews

Attachment May 31, 2005 E-mail from Stanley Marshall

Nevada’s Response to Draft IMPEP Report
APPENDIX A

IMPEP REVIEW TEAM MEMBERS

Name Area of Responsibility

Duncan White, Region I Team Leader

Technical Staffing and Training

Technical Quality of Incident and Allegation Activities

Linda McLean, Region IV Low Level Radioactive Waste Disposal Program

Inspector Accompaniments

Toye Simmons, Region III Technical Quality of Licensing Actions

John Zabko, STP Compatibility Requirements

Robert Gallaghar, Massachusetts Status of Materials Inspection Program

Technical Quality of Inspections Program

Inspector Accompaniments
APPENDIX B

NEVADA ORGANIZATION CHARTS

ML050810515 and ML050810582
APPENDIX C

INSPECTION CASEWORK REVIEWS

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS

ONLY.

File No.: 1

Licensee: 21st Century Technology License No.: 03-12-0429-01

Inspection Type: Routine Priority: 2

Inspection Date: 4/13/04 Inspector: PS

File No.: 2

Licensee: Sunrise Diagnostic Center License No.: 03-12-0395-02

Inspection Type: Routine Priority: 2

Inspection Date: 4/13/04 Inspector: PS

Comment:

The inspector used HDR field notes rather than field notes specific to radiostereotactic

radiosurgery; however, all applicable safety issues were adequately addressed.

File No.: 3

Licensee: Bobcat Properties, Inc. License No.: 10-11-0275-01

Inspection Type: Routine Priority: 5

Inspection Date: 6/18/03 Inspector: MT

Comment:

Licensed material has been in storage for many years. Section has not pursued

enforcement of license termination requirements with the licensee.

File No.: 4

Licensee: Cardinal Health License No.: 03-11-0150-01

Inspection Type: Routine Priority: 2

Inspection Date: 2/25/04 Inspector: WY

File No.: 5

Licensee: Cardiovascular Consultants of NV License No.: 03-12-0412-01

Inspection Type: Routine Priority: 5

Inspection Date: 3/25/04 Inspector: AH

File No.: 6

Licensee: Davis Labs License No.: 00-11-0113-01

Inspection Type: Routine Priority: 1

Inspection Date: 2/10/05 Inspector: RV
Nevada Final Report Page C.2

Inspection Casework Reviews

File No.: 7

Licensee: Desert Springs Hospital License No.: 03-12-0040-01

Inspection Type: Routine Priority: 2

Inspection Date: 3/26/03 Inspector: LF

Comment:

State is performing inspections of medical therapy - other emerging technologies as

Priority 3, while Manual Chapter (MC) 2800 has established a priority of 2 for this

category of use.

File No.: 8

Licensee: University of Nevada Reno License No.: 16-13-0003-07

Inspection Type: Routine Priority 3

Inspection Date: 6/5/03 Inspector: PS

File No.: 9

Licensee: Mesquite Material Testing License No.: 00-11-0511-01

Inspection Type: Routine Priority: 5

Inspection Date: 6/4/03 Inspector: AH

File No.: 10

Licensee: North Vista Hospital License No.: 03-12-0291-01

Inspection Type: Routine Priority: 3

Inspection Date: 2/10/05 Inspector: WY

File No.: 11

Licensee: Nucletron Corporation License No.: MD-27-035-01

Inspection Type: Reciprocity Priority: NA

Inspection Date: 8/26/04 Inspector: WY

File No.: 12

Licensee: Southwest Geotechnical Consultants License No.: 00-11-0313-01

Inspection Type: Routine Priority: 5

Inspection Date: 8/26/03 (attemped) Inspector: AH

Comment:

Unable to locate licensee, no further follow-up inspection performed.

File No.: 13

Licensee: St. Mary’s Regional Medical Center License No.: 16-12-0244-01

Inspection Type: Routine Priority: 2

Inspection Date: 1/29/04 Inspectors: PS and LB

Comment:

State is performing inspections of medical therapy - other emerging technologies as

Priority 3, while MC 2800 has established a priority of 2 for this category of use.
Nevada Final Report Page C.3

Inspection Casework Reviews

File No.: 14

Licensee: Summerlin Medical Center License No.: 03-12-0388-01

Inspection Type: Routine Priority: 3

Inspection Date: 11/13/02 Inspectors: LF and LB

Comment:

Inspection Field Notes indicated personnel monitoring reports did not include the social

security number; however, Notice of Violation cited licensee for not including the date of

birth on personnel monitoring reports.

File No.: 15

Licensee: Sunrise Hospital Laboratory License No.: 03-12-1325-02

Inspection Type: Routine Priority: 5

Inspection Date: 3/12/03 Inspector: MT

File No.: 16

Licensee: Certified Testing and Consulting Services License No.: CA-3941-31

Inspection Type: Reciprocity Priority: N/A

Inspection Date: 2/24/04 Inspector: LB

INSPECTOR ACCOMPANIMENTS

The following inspection accompaniments were made as part of the IMPEP review:

Accompaniment No.: 1

Licensee: Desert Heart Specialists License No.: 03-12-0498-01

Inspection Type: Routine Priority: 5

Inspection Date: 1/31/05 Inspector: AH

File No.: 2

Licensee: Insight Mountain Diagnostics License No.: 03-12-0268-01

Inspection Type: Routine Priority: 3

Inspection Date: 2/1/05 Inspector: WY

File No.: 3

Licensee: Carson Valley Medical Center License No.: 04-12-0440-01

Inspection Type: Routine Priority: 3

Inspection Date: 2/2/05 Inspector: MT

Accompaniment No.: 4

Licensee: Nevada State Health Division (Beatty Site) License No.: 13-11-0043-02

Inspection Type: Routine Priority: N/A

Inspection Date: 2/1/05 Inspectors: RV and WY
APPENDIX D

LICENSE CASEWORK REVIEWS

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS

ONLY.

File No.: 1

Licensee: Insight Mountain Diagnostics License No.: 03-12-0268-01

Type of Action: Amendment Amendment No.: 23

Date Issued: 11/23/04 License Reviewer: MT

File No.: 2

Licensee: Desert Heart Specialist License No.: 00-12-0498-01

Type of Action: Amendment Amendment No.: 04

Date Issued: 7/1/04 License Reviewer: LB

File No.: 3

Licensee: Sunrise Diagnostic Center License No.: 00-12-0395-02

Type of Action: Amendment Amendment No.: 06

Date Issued: 4/7/03 License Reviewer: LB

File No.: 4

Licensee: Tahoe Carson Radiology License No.: 01-12-0524-01

Type of Action: Amendment Amendment No.: 02

Date Issued: 9/22/04 License Reviewer: MT

File No.: 5

Licensee: Nevada Department of Transportation License No.: 00-14-0012-01

Type of Action: Amendment Amendment No.: 29

Date Issued: 4/24/03 License Reviewer: PS

Comment: 

Documentation of letter dated 1/13/03 letter listed in license as 1/13/02.

File No.: 6

Licensee: Carson Valley Medial Center License No.: 04-12-0440-01

Type of Action: Renewal Amendment No.: 05

Date Issued: 9/7/04 License Reviewer: PS

File No.: 7

Licensee: University of Nevada-Las Vegas License No.: 03-13-0305-01

Type of Action: Renewal Amendment No.: 26

Date Issued: 9/29/03 License Reviewer: PS

Comment: 

Renewal took 13 months to complete.
Nevada Final Report Page D.2

Licensing Casework Reviews

File No.: 8

Licensee: Angle Engineering License No.: 00-11-0569-01

Type of Action: New Amendment No.: N/A

Date Issued: 3/14/05 License Reviewer: AH

File No.: 9

Licensee: ATC Associates, Inc. License No.: 00-11-0547-01

Type of Action: New Amendment No.: N/A

Date Issued: 4/12/04 License Reviewer: MT

File No.: 10

Licensee: Professional Services Industries, Inc. License No.:

Type of Action: New Amendment No.: N/A

Date Issued: 10/22/03 License Reviewer: PS

File No.: 11

Licensee: Nevada Cardiology Associates License No.: 03-12-0559-01

Type of Action: New Amendment No.: N/A

Date Issued: 10/22/04 License Reviewer: MT

File No.: 12

Licensee: Northwest Radiation Oncology Center License No.: 03-12-0538-01

Type of Action: New Amendment No.: N/A

Date Issued: 11/19/03 License Reviewer: LB

File No.: 13

Licensee: Lombardi Research Foundation License No.: 16-11-0448-01

Amendment No.: 01

Type of Action: Termination

Date Issued: 9/16/04 License Reviewer: LB

File No.: 14

Licensee: Northwest Radiation Oncology Center License No.: 03-12-0538-01

Type of Action: Termination Amendment No.: 01

Date Issued: 2/22/05 License Reviewer: LB

File No.: 15

Licensee: University of Nevada-Reno License No.: 16-13-0003-07

Type of Action: Amendment Amendment No.: 29

Date Issued: 9/30/04 License Reviewer: LB

Comments: 

a) An amendment request dated 12/13/04 was found in the docket file that was not

processed or entered into the licensing database.

b) Renewal submitted to Section in March 2004 and not assigned for review.
Nevada Final Report Page D.3

Licensing Casework Reviews

File No.: 16

Licensee: Barton Memorial Hospital License No.: 04-12-0440-01

Type of Action: Amendment Amendment No.: 04

Date Issued: 12/24/03 License Reviewer: LB
APPENDIX E

INCIDENT CASEWORK REVIEWS

Note: Casework Listed Without Comment Is Included for Completeness Only.

File No.: 1

Licensee: Landmark Testing & Engineering License No.: 00-11-0518-01

Date of Incident: 11/11/04 Incident Log No.: 04-008 (NMED 040816)

Investigation Date: 11/17/04 Type of Investigation: Site

Type of Incident: Stolen Radioactive Material

File No.: 2

Licensee: Geotek, Inc. License No.: 00-11-0384-01

Date of Incident: 6/10/04 Incident Log No.: 04-003 (NMED 040429)

Investigation Date: 6/10/04 Type of Investigation: Site and Phone

Type of Incident: Stolen Radioactive Material

File No.: 3

Licensee: Kazan and Associates California License No.: 4247-10

Date of Incident: 11/14/04 Incident Log No.: 04-009 (NMED 040818)

Investigation Date: 11/16/04 Type of Investigation: Phone

Type of Incident: Stolen Radioactive Material

File No.: 4

Licensee: Nevada Department of Transportation License No.: 00-14-0404-01

Date of Incident: 11/16/04 Incident Log No.: 03-006 (NMED 030942)

Investigation Dates: 11/26/03 - 12/1/03 Type of Investigation: Site and Phone

Type of Incident: Stolen Radioactive Material

File No.: 5

Licensee: Northern Geotech License No.: 00-11-0309-01

Date of Incident: 3/2/04 Incident Log No.: 04-001 (NMED 040168)

Investigation Date: 3/3/04 Type of Investigation: Phone

Type of Incident: Stolen Radioactive Material

File No.: 6

Licensee: Western Technologies License No.: 00-11-0019-02

Date of Incident: 9/10/04 Incident Log No.: 04-006 (NMED 040698)

Investigation Date: 9/10/04 Type of Investigation: Phone

Type of Incident: Damaged Equipment

File No.: 7

Licensee: Barrick Goldstrike License No.: General License

Date of Incident: 6/1/04 Incident Log No.: 04-004 (NMED 05006)

Investigation Date: 12/12/04 Type of Investigation: Site and Phone

Type of Incident: Lost Radioactive Material
Nevada Final Report Page E.2

Incident Casework Reviews

File No.: 8

Licensee: Davis Labs License No.: 00-11-0013-02

Date of Incident: 1/27/05 Incident Log No.: 05-003

Investigation Date: 1/27/05 Type of Investigation: Phone

Type of Incident: Damaged Equipment

Comment: Event was reported to the Nuclear Regulatory Commission 48 days late
ATTACHMENT

May 31, 2005 E-mail from Stanley Marshall

Nevada’s Response to Draft IMPEP Report

ADAMS: ML051640183