Mr. John M. Leonard November 27, 2000

Assistant Commissioner for Environment

Tennessee Department of Environment 

 and Conservation

401 Church Street, 21st Floor, L&C Tower

Nashville, TN 37243-1530

Dear Mr. Leonard:

On November 7, 2000, the Management Review Board (MRB) met to consider the proposed

final Integrated Materials Performance Evaluation Program (IMPEP) report on the Tennessee

Agreement State program. The IMPEP review was conducted August 21-25, 2000. The MRB

had received for consideration the comments in Mr. Nanney’s letter dated October 23, 2000. 

The MRB found the Tennessee program adequate but needs improvement, and not compatible

with NRC’s program. Because of the significance of the concerns, the MRB recommends

heightened oversight of the Tennessee program. I request that bi-monthly conference calls

take place with the appropriate Tennessee and NRC staffs to discuss the status of the

program. The Office of State and Tribal Programs will coordinate the bi-monthly conference

calls. I request that, two weeks prior to the calls, you submit a brief status report on the

activities conducted since the last report and the necessary statistical data. 

I also request that you prepare and submit a program improvement plan that addresses the

recommendations in Section 5 of the enclosed final report. I request that this report be

submitted within 30 days of this letter. Upon review of the program improvement plan, the staff

will schedule the first conference call and a more detailed outline for the status reports. I

request the initial conference call be scheduled and conducted no later than February 1, 2001.

Based on the results of the current IMPEP review, a follow-up review will be scheduled during

the period August - October 2001. The follow-up review will cover the State’s action on the

recommendations from the August 2000 review. 

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

your continuing support of the Division of Radiological Health. I look forward to our agencies

continuing to work cooperatively in the future. 

Sincerely,

/RA/

Carl Paperiello

Deputy Executive Director

 for Materials, Research and 

 State and Tribal Programs

Enclosure:

As stated

cc: See next page
John M. Leonard - 2 -

cc: Milton H. Hamilton, Commissioner

Department of Environment and Conservation

Lawrence E. Nanney, Director

Division of Radiological Health

Edgar D. Bailey, CA

Agreement State Liaison to

 The Management Review Board
INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM

REVIEW OF TENNESSEE AGREEMENT STATE PROGRAM

August 21-25, 2000

FINAL REPORT

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

1.0 INTRODUCTION

This report presents the results of the review of the Tennessee radiation control program. The

review was conducted during the period August 21-25, 2000, by a review team comprised of

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

State of California. 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 25, 1998, NRC Management Directive 5.6,

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

review, which covered the period December 7, 1996 to August 25, 2000 were discussed with

Tennessee management on August 25, 2000.

A draft of this report was issued to Tennessee for factual comment on September 22, 2000. 

The State responded in a letter dated October 23, 2000. At the time of the review, the review

team found Tennessee’s performance to be satisfactory for the common performance

indicators Technical Staffing and Training, Technical Quality of Licensing Actions and Sealed

Source and Device Evaluation Program; satisfactory with recommendations for improvement for

the indicator, Response to Incidents and Allegations; and unsatisfactory for the indicators, Status

of Materials Inspection Program, Technical Quality of Inspections, and Legislation and Program

Elements Required for Compatibility. Because of the significance of the concerns, the team

recommended that a program of heightened oversight be implemented to assess the progress

of the State in implementing corrective actions. 

On September 13, 2000, Mr. Carl Paperiello, NRC, and other NRC staff discussed by telephone

with Mr. John Leonard, Assistant Commissioner for Environment, and his staff, the significance

of the teams findings and NRC’s understanding of the State’s commitments made during the

team’s exit meeting on August 25, 2000. This conversation was documented in a October 2,

2000 letter to Mr. Leonard from Mr. Paperiello.

The Management Review Board (MRB) met on November 7, 2000 to consider the proposed final

report. The MRB concurred in the individual findings by the review team for each indicator.

Based on the Tennessee actions to date and the commitments by the Division Director, the

MRB concurred in the review team’s recommendation for a program of heightened oversight to

assess the progress of the State in implementing corrective actions. The MRB found the

Tennessee radiation control program was adequate, but needs improvement, and not

compatible with NRC’s program.

The MRB directed that a program improvement plan be submitted in addition to the responses to

the recommendations found in Section 5, that a follow-up review be conducted during the period

August - October 2001, that bimonthly conference calls take place with Tennessee staff, and

that written progress reports be submitted two weeks prior to each call.

The Tennessee Agreement State program is administered by the Division of Radiological Health

(the Division) within the Department of Environment and Conservation (DEC). Organization

charts for the DEC and the Division are included as Appendix B. At the time of the review, the

Tennessee program regulated 559 specific licenses, including gauges, medical, academic,

industrial, manufacturing, and waste broker/processor. The review focused on the materials

program as it is carried out under the Section 274b (of the Atomic Energy Act of 1954, (AEA) as

amended) Agreement between the NRC and the State of Tennessee.

In preparation for the review, a questionnaire addressing the common and non-common
Tennessee Final Report Page 2

indicators was sent to the State on June 16, 2000. The State provided a response to the

questionnaire on July 31, 2000. During the review, discussions with the State staff resulted in

the responses being further developed. A copy of the questionnaire responses is included as

Appendix G to the proposed final report.

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

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

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

data base; (4) technical review of selected licensing and inspection actions; (5) field

accompaniments of five Tennessee inspectors; and (6) 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 applicable non-common indicator and

made a preliminary assessment of the radiation control program's performance.

Section 2 below discusses the State'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 noncommon 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 PREVIOUS REVIEWS

During the previous routine review, which concluded on December 6, 1996, three

recommendations and four suggestions were made and the results transmitted to Mr. Wayne K.

Scharber, Deputy Commissioner, Tennessee Department of Environment and Conservation on

May 21, 1997. The periodic meeting resulted in recommendation for the closure of all three of

the recommendations. The team’s review of the current status of these recommendations is as

follows:

1. It is recommended that the State review the process for report issuance with the goal of

increasing the timeliness of inspection report issuance. (Section 3.1). 

 

Current Status: The Division has developed and implemented a revised policy for

issuance of inspection reports and correspondence. This recommendation is closed.

This issue is evaluated further in Section 3.1 and a new recommendation is made.

2. It is recommended that the State review the number of reciprocity inspections it is

performing against the inspection goals established in Manual Chapter 1220. 

(Section 3.1)

 

Current Status: The Division has issued revised guidance to the technical staff regarding

increased reciprocity inspections by priority of inspection, and has started tracking the

inspections. This recommendation is closed. 

3. “Quality Management Program and Misadministrations,” 10 CFR Part 35 amendment (56

FR 34104) which became effective on January 27, 1992. The team recommended that

the DRH continue to closely follow the development of NRC’s compatibility policy and the

revision of 10 CFR Part 35 and, depending on the outcome, take appropriate action on
Tennessee Final Report Page 3

this rule (Section 4.1.2). 

Current Status: The Division is monitoring the development and status of the 10 CFR

Part 35 revision. The Commission has approved the final rule which is expected to be

published in Spring 2001. We believe that the Division conserving rulemaking resources

to address the new Part 35 is appropriate. The recommendation is closed. This issue is

addressed in Section 4.1.2. 

During the 1996 review, four suggestions were made concerning: (1) periodic reminder for outof-State licensees of the requirement to notify the Division before performing work within

Tennessee; (2) conducting accompaniments of field office supervisors that routinely perform

inspections; (3) revising Tennessee’s definition of “significant event” to provide national

consistency; and (4) revisit procedures for notification of the concerned individual of actions

taken and results of the State’s investigation. The team determined that the State considered

the suggestions and took appropriate actions. 

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

licensees. The review team’s evaluation is based on the Tennessee questionnaire response

relative to this indicator, data gathered independently from the Division’s inspection data tracking

system, the examination of completed inspection casework, and interviews with managers and

staff. 

A review of the Division’s inspection priorities revealed that the inspection frequencies for the

various types of licenses are the same or more frequent than similar license types listed in NRC

Inspection Manual Chapter (IMC) 2800. The Division does not extend or compress inspection

frequencies based on compliance history. The Division does attempt to inspect certain types of

licensees at a greater frequency than listed in NRC IMC 2800. These licensees are all waste

processing licensees, and the Division’s goal is to inspect them once every six months. 

In response to the questionnaire, the Division indicated that 31 core inspections were overdue by

more than 25% of the NRC frequency. By the time of the IMPEP review, this number had been

reduced to 21 core inspections. A review of the Division’s data indicated that during this review

period, 68 of 257 core inspections (26%) were overdue by more than 25% of the NRC frequency

when they were performed. At the time of the review, there were six licensees requiring

inspection on an annual basis that were overdue by more than 25% of the NRC frequency. Of

these six, four were nuclear pharmacies, and were overdue by 17 to 42 months.

With respect to new licensees, the team evaluated the Division’s inspection data tracking

system and determined that 73 initial inspections of new licensees were performed during the

IMPEP review period. Of these 73, there were 41 (56%) that were performed more than six
Tennessee Final Report Page 4

months after the license had been issued. In addition, at the time of the IMPEP review there

were 10 initial inspections that had not yet been performed, although the licenses had been

issued more than six months prior to the review. The team identified a tracking problem for

Priority 7 licensees. The inspection data tracking system calculates when the initial inspection is

due by looking at the expiration date of the license, and back-calculating to the date of issuance,

then calculating six months from that date, and assigning it as overdue when that date is

passed. Priority 7 licensees in Tennessee are not assigned an expiration date. Therefore, the

date when the initial inspection is overdue is not properly entered into the inspection data

tracking system. However, of the 41 initial inspections that were performed more than six

months after the issuance of the license, only 11 were Priority 7 licensees.

Regionally, there were substantial differences with respect to the number of inspections, routine

and initial, that were performed on an overdue basis. In the Memphis office, 21 out of 28 (75%)

of the core inspections performed were overdue, while in the Chattanooga office, no core

inspections were overdue when performed during this IMPEP review period.

The timeliness of the issuance of inspection findings was evaluated by randomly selecting from

each of the regional offices approximately seven inspection reports spanning the IMPEP review

period. Of the 29 reports reviewed, there were 12 where the inspection letter and Notice of

Non-compliance, if applicable, were dispatched to the licensee more than 30 days after the

inspection. Of these 12, six were dispatched more than 60 days after the inspection, including

one being up to 12 months late at the time of the review, but still not issued. 

The Division requires that the inspection findings be delivered to the Nashville office for

maintenance in the central files. However, this policy is not consistently followed by the regional

offices, as there were numerous cases where file documentation was missing. Some of the

reports from regional offices outside of Nashville were sent to Nashville at the Deputy Director’s

request for the IMPEP team’s review. In one case, the team requested a copy of the inspection

report for an inspection performed June 18, 1997, as entered in the inspection data tracking

system, but the Deputy Director stated that no inspection had actually been performed during

that period. The data in the tracking system was in error. That licensee is currently overdue for

inspection. 

In another eight cases, there were inspections performed in the Memphis region during March

1998, but no reports could be located, either in the central files or in the regional offices. The

Deputy Director stated that she believed the inspections were completed, but never approved by

the supervisor, and Division staff would continue to look for them. Several other reports could

not be located during the on-site IMPEP review. One report (February 1998) was missing for a

Priority 1 licensee. A second report (May 2000) for this licensee was still in the process of being

prepared while the review was being conducted, although the inspection had been performed

three months earlier. A report for an inspection (August 1999) in response to an allegation for a

Priority 1 licensee and the Notice of Non-compliance were never reviewed and released to the

licensee or the alleger. The Division should ensure that all completed inspection records are

properly filed in the central office. This would reduce the number of missing inspection reports. 

The Division has developed a plan for completing those inspections that are currently overdue

and was searching for the missing records at the time of the review. The staff turnover in the

inspection program has contributed to problems in performance of the inspection program.

The Division reported that 180 requests for reciprocity were received between January 1, 1997

and August 18, 2000. The team did not determine how many of these reciprocity requests were
Tennessee Final Report Page 5

received from the same licensee. The Division performed 67 reciprocity inspections during the

review period. This is a significant improvement over the 33 inspections performed out of 139

requests made during the previous review cycle. The Division's goal is to perform reciprocity

inspections at the same frequency as that prescribed by NRC IMC 1220. This goal was not met

in all cases (i.e., for all categories of licensees, for each year in the review period), however on

average, over the review period, the Division did meet this goal. 

The review team recommends that the Division take actions to ensure that: (1) inspections are

conducted in accordance with their assigned inspection frequencies; (2) inspection reports are

issued in a timely manner; (3) inspection reports and associated information are filed in a

manner that the information can be retrieved; and (4) deficiencies in the inspection tracking

system are corrected. 

During the MRB meeting, the Division Director noted that the Priority 1 overdue inspections had

been performed since the onsite review. In addition, the Division had selected a new Inspection

and Enforcement (I&E) supervisor to oversee the management of the inspection program. 

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

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

unsatisfactory. 

3.2 Technical Quality of Inspections

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

notes and interviewed some of the inspection staff. The evaluation included reviewing 21

radioactive materials inspections (for 17 licensees) conducted during the review period. The

casework included fourteen inspectors, representing each of the State’s four regional offices,

and covered inspections of nine types of licensees (hospitals, mobile nuclear medicine, gamma

knife, industrial radiography, well logging, radiopharmacy, waste processors, decontamination

services providers, and portable gauges). Appendix C lists the inspection casework files

reviewed for completeness and adequacy with case-specific comments.

The Division’s inspection procedures are consistent with the inspection guidance outlined in

NRC IMC 2800. Inspection reports are in checklist format with space for limited narrative input

that would adequately cover all inspection areas. The Division has specific inspection forms for

the various types of licensees. Full narrative reports (instead of the checklist format) are

normally completed for large, complex licensees, such as waste processors. All inspection

reports receive supervisory review. Central Office Management only reviews inspection reports

from Priority 1 licensees requiring financial assurance, notices of non-compliance involving

licenses-for-delivery, and any inspections performed by Field Office Managers.

During the review period, inspector accompaniments were performed by supervisory staff and

central office management. The review team determined that only two inspectors had not been

accompanied in calendar year 1999, one of whom was a field office manager who also

conducted inspections and performed accompaniments of inspection staff in his region. This

did not appear to affect the overall performance of the inspection program.

Based on casework and interviews of selected inspection staff, the review team determined that

most routine inspections do not adequately assess licensees’ radiation protection programs. 

The inspection reports document a compliance-based inspection technique that focuses heavily,
Tennessee Final Report Page 6

and in many cases exclusively, on record reviews. Of the 21 inspection reports reviewed, 13 did

not include any documentation of observation of licensed activities or interviews of licensee

personnel who performed those activities. The review team found that inspection reports were

of low quality, with insufficient documentation to ensure that licensee performance with respect

to health and safety was acceptable. The documentation in the inspection reports typically did

not support the violations transmitted to licensees. Of the 55 violations identified in the casework

reviewed, 35 were not supported, and in some cases were contradicted, by information in the

inspection reports. None of the inspection reports discussed the relative safety significance or

root causes of the violations identified to licensees. In many cases, the notices of noncompliance did not establish that a violation occurred, i.e., the “requirement” statement

addresses performance of a task and the “contrary to” statement indicates that records of the

results of the tasks were not available.

Five Division inspectors were accompanied during inspections by a review team member during

the week of July 31, 2000. The accompaniments included two medical licensees and three

radiography licensees. These accompaniments are also identified in Appendix C.

During four of the accompaniments, the inspectors did not demonstrate appropriate inspection

techniques. The inspectors focused exclusively on record reviews and did not observe any

activities in progress or conduct any substantive interviews of licensee personnel regarding their

knowledge of routine operating and emergency procedures. In one instance, the inspector did

not tour the licensee’s facilities until after the normal licensed activities for the day had ended,

approximately five hours after initially arriving onsite. Two inspectors did not interview any

licensee personnel who actively performed licensed operations. 

Except for the one industrial radiography inspection where the inspector observed activities at a

temporary job site, none of the inspectors assessed the radiological health and safety

performance of the licensees inspected. These inspectors did not demonstrate through their

inspection activities knowledge of the State’s Inspection and Enforcement Policy and Procedure

which directs inspectors to obtain information through “...selective direct observation of work in

progress, interviews of workers and management personnel, confirmatory measurements, and

examination of selective records and procedures to..” determine whether licensed activities are

conducted safely. In addition, under Section 1000.08 of the policy and procedure, inspection

staff are advised that inspection effort expended against various portions of regulatory

requirements should be commensurate with their relative importance to safety. During four of

the five accompaniments, the inspectors’ expenditure of resources was on activities that were of

little importance to safety (i.e., record retention).

Due to the inspection program not fully addressing the health and safety aspects of licensee’s

operations, the review team has the following recommendations: 

The review team recommends that the Division follow the Tennessee inspection policy and

procedures. 

The review team recommends that the Division ensure that inspection findings are fully

supported in documentation of the inspection and that cited violations are fully supported in the

inspection report. 

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

performance with respect to the indicator, Technical Quality of Inspections, be found
Tennessee Final Report Page 7

unsatisfactory. 

3.3 Technical Staffing and Training

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

staffing level and staff turnover, as well as the technical qualifications and training histories of the

staff. To evaluate these issues, the review team examined the State's questionnaire responses

relative to this indicator, interviewed program management and staff, and considered any

possible workload backlogs. 

At the time of the review, the Division had a total of 72 staff positions. Approximately 36 of these

staff contribute to the Agreement State portion of the program for a total of 1.1 full time

employees (FTE) in administration, 7.8 FTE in licensing, 9.8 FTE in inspection, and 2.4 FTE in

emergency response. The Division is managed by a Director and Deputy Director (with 2

administrative and 1 technical staff in the Director’s office) with three technical sections

(Technical Services, Inspection and Enforcement, and Licensing, Registration, and Planning) as

well as an Administrative Services Section (7 staff) which provides general office services and

management of accounts receivable. The Technical Services Section (13 staff) provides

personnel and environmental monitoring, low-level waste monitoring, standards development

and processing, and emergency preparedness and training. 

The I&E Section (32 staff) is divided into four regional offices (Memphis (6), Nashville (9),

Chattanooga (3), and Knoxville (13)) and a program manager in Nashville. The I&E Section

conducts all inspections for materials and radiation machines. 

The Licensing, Registration and Planning Section (14 staff) conducts the licensing of radioactive

materials and registration of radiation producing devices used within the State. Eleven staff are

involved, in part, in conducting the review of license applications and issuance of licenses for

radioactive materials covered under the Agreement. Two staff, other than the managers in the

Section, review Sealed Source and Device applications. This activity will be discussed further in

Section 4.2.2. 

All health physics staff are required to have a bachelors degree in physical, engineering, or life

sciences. They are usually assigned basic responsibilities in the program until sufficient training

and experience is obtained. The Division has established a tracking system for all training for

the staff. They receive training in health physics, nuclear medicine uses, materials licensing,

inspection procedures for materials or radiation producing machines, industrial radiography,

emergency response, and regulations and office procedures. Although not all staff have

attended every course, the program has sufficient expertise to execute the program. The

Division has limited funding ($14K) for out-of-State travel. This limits their participation in certain

out-of-State training courses which over time degrades the technical quality of the program. 

They have used on-the-job training to supplement the course work so that individuals may

broaden their work areas. The Division does not have a documented training program or plan

which specifies minimum training requirement as well as supervisory sign off on completion of

that training. The review team recommends that the Division develop and document a training

and qualification program which address the training requirements in the NRC/Organization of

Agreement States Training Working Group Report or NRC Inspection Manual Chapter 1246.

The Division has experienced significant staff turnover. During the review period, they hired 24

new staff and 23 staff have left the program. About half of the staff that left the program worked
Tennessee Final Report Page 8

in the radioactive materials program. Several of the staff working in the x-ray portion of the

program were being trained to become materials inspectors. The majority of the staff that left

the Division had about 3 years or less with the Division. Therefore, several of the positions have

been filled more than once during the evaluation period. This has required significant training

resources as well as on the job training effort to get the new staff prepared to contribute to the

Division. The new staff are typically trained to begin in the x-ray program. As their training

progresses they may be moved to a position in the materials program. 

The Director of the Division retired in November 1999 and the Deputy Director was selected to

succeed him in January 2000. The Technical Services manager was selected to be the new

Deputy Director in July 2000. The Inspection and Enforcement manager was moved to a staff

technical position in July 2000 and at the time of the review these two management positions

were in the process of being filled. At the time of the review, there were seven vacancies (4.1

FTE) in the inspection program and two vacancies (1.3 FTE) in the licensing program. The

current vacancies in the inspection program account for about 40% of the staff assigned to the

materials inspection program. The Division has requested hiring freeze waivers for their vacant

positions and has attempted to hire qualified individuals. This has not always been successful

since several times there were no qualified individuals on the register when it was accessed. 

The low salary ($21K) for an initial hire is not a sufficient salary to attract qualified individuals. 

Without a significant salary increase, which is not likely given the current financial condition of

the State of Tennessee that was discussed during the exit meeting, the current staffing issues

will persist. At the exit meeting, upper management indicated that some salary incentives may

be available for some entry level positions and the Division management expressed an interest

in pursuing this as an option. The high turnover and training workload on existing staff has

adversely impacted the program, specifically the “Status of Materials Inspections,” “Technical

Quality of Inspections,” and “Incident and Allegations” indicators. The review team recommends

that the inspection staff be trained in the Division’s policies and procedures on the conduct of

inspections.

Based on the team's finding and the IMPEP evaluation criteria, the review team recommends

that Tennessee's performance with respect to the indicator, Technical Staffing and Training, be

found satisfactory.

3.4 Technical Quality of Licensing Actions

The review team examined completed licensing casework and interviewed the staff for 25

specific licenses. 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 reviewed for overall technical quality including accuracy,

appropriateness of the license, its 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 supporting

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

supervisory review as indicated, and proper signature authority. The files were checked for

retention of necessary documents and supporting data. A separate review evaluated one

licensing action in detail, including an onsite visit to the State offices and licensed facility. Based

on the results of this specific case review, the team looked at the programmatic process for

documentation of telephone calls and meetings with licensees. In addition, particular attention

was given to review of the State’s process for review and approval of sampling and monitoring
Tennessee Final Report Page 9

programs, release criteria, and detection limits. The evaluation conducted of this licensing

action will be issued as a separate report.

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

which were completed during the review period. The cross-section sampling included the

following types: waste processing; broad scope licenses; decontamination services; industrial

radiography; medical (institutions and private practices performing diagnostic and/or therapeutic

nuclear medicine, brachytherapy, strontium-90 eye applicator, gamma stereotactic surgery);

nuclear pharmacy; nuclear laundry; laboratory research and development; portable gauges; leak

test, calibration and other services; source material; and sealed neutron PuBe source. A list of

the licenses evaluated with case-specific comments can be found in Appendix D.

The following licensing actions that were completed during the review period were reviewed: 

8 new licenses, 3 renewals, 33 amendments, and 3 terminations, for a total of 47 licensing

actions. During the review period, extensions of the license expiration date were issued to

nearly all licensees, so few renewals were done. Two sets of amendments were generated by

the State to certain classes of licenses: 1) to add a license condition to all radiography licenses

for approval to use the optically-stimulated luminescent dosimeters; and 2) to add a license

condition to all medical facilities authorized to perform therapeutic nuclear medicine describing

the new patient release criteria. In discussions with State management representatives, it was

noted that one licensee has filed for bankruptcy and was unable to sell or re-organize. For this

facility, the State has drawn on the funds provided by the facility’s financial assurance in order to

decommission the facility. 

The casework evaluation indicated that the Division staff follows appropriate licensing guides

during the review process. Generally, deficiencies were addressed by letters containing

appropriate regulatory language. Each license reviewer has proper signature authority to sign

their own licensing actions. Overall, the review team found that the licensing actions were

thorough, complete, consistent, of high quality and properly addressed health and safety issues. 

Based on the IMPEP evaluation criteria, the review team recommends that Tennessee'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 the Division’s actions in responding to incidents, the review

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

the Division’s “Complaint/Allegation/Incident (CAI) Event Investigation Procedure,” and evaluated

selected incidents reported for Tennessee in the Nuclear Material Events Database (NMED)

against those contained in the Tennessee files. A list of the incident casework examined with

the case-specific comments is included in Appendix E. The team also reviewed the State’s

response to 14 allegations involving radioactive materials including 10 allegations referred to the

State by the NRC during the review period.

The Division had 64 reportable radioactive materials incidents during the review period and 14

were selected for review. The incidents included: leaking sources; a misadministration;

contamination events; fires; and an occupational overexposure. All incidents in the Division files

were in the NMED records. The NMED records reflected the information in the Division files.
Tennessee Final Report Page 10

The review team found that the Division has an incident response and allegation procedure in

place, but that it is not routinely practiced in a detailed fashion. The resolution of potential health

and safety issues was marginal. The Division made notifications to the NRC, and other

Agreement State programs as required.

The Division’s CAI procedure requires that each “staff member involved in an event . . . prepare

a written report documenting the activities in which (s)he was involved,” including, “all relevant

information,” and that these reports be “forwarded to the CAI coordinator, where they will be

made part of the file for each event.” In four of the fourteen cases reviewed, there was no written

report by the inspector(s) involved. All four of these cases appeared to have had the potential for

serious consequences. In all four cases, the incident file did not contain any indication that the

Division had evaluated the licensee’s response or corrective actions. Two of these four

incidents occurred at the same licensed facility, within three months of one another, and both

involved fires in the ventilation system sparked by cutting torches. In three additional incident

files, significant information was missing, including laboratory sample analysis results,

documentation of the decontamination of an unlicensed facility, information necessary to assess

the public dose consequences of a release, and assessments of individual doses resulting from

the incidents. 

In the remaining seven incident files that were reviewed, the written reports and supplementary

documentation appeared to support the conclusions reached by Division staff and the actions

taken were appropriate and timely. In two of these cases, the Division pursued escalated

enforcement actions, including the imposition of fines. 

The missing information was discussed with the Deputy Director, who also functions as the CAI

coordinator, and she stated that the Division does not have a formal procedure for closing

incident files. This appears to have contributed to the missing information identified in half of the

incident files reviewed during the on-site IMPEP review. The CAI coordinator felt that the

activities had been conducted but that the information had not been assembled in the incident

files.

The review team recommends that the Division ensure that independent, documented

evaluations of the licensee’s actions and root cause analyses are completed as part of an

incident investigation.

The review team recommends that the Division formally close incident files, including a review

to ensure that all the necessary documentation is included in the file.

The Division’s procedure for responding to incidents includes a section specifically related to

allegations. The State law currently does not provide anonymity to persons bringing complaints

forward to the Division. Information in the Division’s files is open to the public, and anonymity

can only be preserved if the complainant’s name does not become a part of any record. The

procedure also requires that when a complainant is known to the Division, a response to that

person be made providing the results of the investigation. If the complaint was made in writing,

the response is to be made in writing. If the complaint was made verbally, the response may be

verbal or in writing, but should be documented in the file.

The team reviewed 10 of the 12 allegations referred to the State by the NRC, and four allegations

delivered directly to the State. With respect to the two referred by NRC that were not reviewed,

both were referred within the two months prior to the on-site IMPEP review. One was still with
Tennessee Final Report Page 11

the field office, and the investigation had not been completed, and the other did not involve AEA

material.

The review team found that the Division’s response to the allegations referred by the NRC were

handled in a timely and appropriate manner, with two exceptions. In one case, the investigation

was performed during the course of a full inspection, approximately three months after the

referral. In addition, the results of this inspection, including a Notice of Non-compliance was

written, but never delivered to the licensee. The Deputy Director said this report had been

submitted for supervisory approval, but was apparently misplaced and never approved for

release. In the second case, the allegation was investigated approximately one and one half

months after the referral, and the results of the investigation were not transmitted to the

complainant until another two and one half months after that because, according to the

investigation, the “report was misplaced in [the] Central Office.” 

The review team found that with respect to those allegations received directly by the Division, the

responses appeared timely and appropriate. However, in three out of the four cases, there was

no documentation of responses providing the results of the investigation to the complainants. 

The review team recommends that supervisory reviews be conducted to ensure thoroughness

of investigations of allegations, including that allegations are closed out with the alleger.

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

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

satisfactory with recommendations for improvement.

4.0 NON-COMMON PERFORMANCE INDICATORS

IMPEP identifies four non-common performance indicators to be used in reviewing 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. Tennessee's Agreement does not cover uranium

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

review.
Tennessee Final Report Page 12

4.1 Legislation and Program Elements Required for Compatibility

4.1.1 Legislation

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

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

authority to create an agency and enter into an agreement with the NRC is granted in Title 68,

Chapter 202-101 through 202-704 of the Tennessee Code Annotated. The Division is

designated as the State’s radiation control agency. The review team noted that no legislation

affecting the radiation control program was passed since being found adequate during the

previous review, and found that the State legislation is adequate. 

4.1.2 Program Elements Required for Compatibility

The Tennessee radiation control program’s regulations are found in the “Rules of the

Department of Environment and Conservation,” Chapters 1200-2-4 through 1200-2-12, and

applies to all ionizing radiation from agreement materials, machine produced radiation, and

accelerators. Tennessee requires a license for possession, and use, of all radioactive material

including naturally occurring materials, such as radium, and accelerator-produced radionuclides.

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

that the public and other interested parties are offered an opportunity to comment on proposed

rules. Under the Rulemaking Hearing Rules procedures, all proposed rules are reviewed

internally by the Department’s Office of General Council (OGC) and by outside interested parties

before a rulemaking hearing is established. The proposed rules are published in the Tennessee

Administrative Register during the month prior to the public hearing. Comments are accepted at

the hearing and for a two week period following the hearing. Any changes are made to the rules

as needed and reviewed by the OGC, signed by the Department’s Commissioner, filed with the

Secretary of State, and become effective after a waiting period of 75 days. After the rule

becomes effective, representatives of the Division and the OGC will be scheduled to appear

before the Government Operations Committee of the legislature for the Committee’s approval. 

Rules adopted during the year are subject to sunset on June 30 of the 

following calendar year, unless approved by the legislature. Historically, all rules approved buy

the OGC have been approved by the legislature with the passage of appropriate legislation.

The team evaluated Tennessee’s responses to the questionnaire, reviewed the status of

regulations required to be adopted by the State under the Commission’s Adequacy and

Compatibility Policy, and verified the information concerning the adoption of regulations with data

obtained from the Office of State and Tribal Programs (STP) Regulation Assessment Tracking

System.

The Division has not adopted any regulations needed for compatibility since the 1996 review.

The Division drafted some of the rules needed for compatibility, but the rules were never adopted

and the rules were not provided to STP for review. The team identified rules needed for

compatibility as follows:

! "Quality Management Program and Misadministrations," 10 CFR Part 35 amendment (56

FR 34104) which became effective on January 27, 1992. The Division is monitoring the

development and status of the 10 CFR Part 35 revision. The Commission has approved
Tennessee Final Report Page 13

the final rule which is expected to be published in Spring 2001. We believe that the

Division conserving rulemaking resources to address the new Part 35 is appropriate.

! “Decommissioning Recordkeeping and License Termination,” 10 CFR Parts 30 and 40

amendment (58 FR 39628) that became effective October 25, 1996. This rule was

drafted in February 1998 then removed from consideration by the Division.

! "Timeliness in Decommissioning of Materials Facilities," 10 CFR Parts 30, 40, and 70

amendments (59 FR 36026) that became effective on August 15, 1994. This rule was

drafted in December of 1996 then removed from consideration by Division.

! "Preparation, Transfer for Commercial Distribution and Use of Byproduct Material for

Medical Use," 10 CFR Parts 30, 32 and 35 amendments (59 FR 61767, 59 FR 65243, 60

FR 322) that became effective on January 1, 1995.

! "Frequency of Medical Examinations for Use of Respiratory Protection Equipment," 10

CFR Part 20 amendments (60 FR 7900) that became effective on March 13, 1995. This

rule was drafted in April of 1998.

! "Low-Level Waste Shipment Manifest Information and Reporting," 10 CFR Parts 20 and

61 amendments (60 FR 15649, 60 FR 25983) that became effective March 1, 1998. 

Agreement States were expected to have an effective rule on the same date and this rule

is designated as category B for compatibility.

! “Performance Requirements for Radiography Equipment,” 10 CFR Part 34 amendment

(60 FR 28323) that became effective June 30, 1995. This rule is designated as category

B for compatibility. The Division incorporated 60 FR 28323 in all radiography licenses by

license condition in January 1997. The team did not verify during the review that the

license condition covered all of the regulatory requirements.

! "Radiation Protection Requirements: Amended Definitions and Criteria," 10 CFR Parts

19 and 20 amendments (60 FR 36038) that became effective August 14, 1995. Certain

definitions in this rule are designated as category A for compatibility.

! “Clarification of Decommissioning Funding Requirements,” 10 CFR Parts 30, 40, and 70

amendments (60 FR 28323) that became effective November 24, 1995.

! “Medical Administration of Radiation and Radioactive Materials,” 10 CFR Part 35

amendment (60 FR 48623) that became effective November 24, 1995.

! "10 CFR Part 71: Compatibility with the International Atomic Energy Agency," 10 CFR

Part 71 amendments (60 FR 50248 and 61 FR 28724) that became effective April 1,

1996. This rule is designated as category B for compatibility.

! “Termination or Transfer of Licensed Activities: Recordkeeping Requirements,” 10 CFR

Parts 20, 30, 40, 61, and 70 amendments (61 FR 24669) that became effective June 17,

1996.

! “Resolution of Dual Regulation of Airborne Effluents of Radioactive Materials; Clean

Air Act,” 10 CFR Part 20 amendment (61 FR 65120) that became effective January 9,
Tennessee Final Report Page 14

1997. This rule was drafted in October of 1998.

! “Recognition of Agreement State Licenses in Areas Under Exclusive Federal Jurisdiction

Within an Agreement State,” 10 CFR Part 150 amendment (62 FR 1662) that became

effective February 27, 1997. The Division incorporated this jurisdictional requirement in

temporary jobsite licenses by license condition in April, 1996. The team did not verify

during the review that the license condition covered all of the regulatory requirements.

! “Criteria for the Release of Individuals Administered Radioactive Material,” 10 CFR Parts

20 and 35 amendments (62 FR 4120) that became effective May 29, 1997. The Part 20

amendment is designated as category A compatibility. The Division put a license

condition on medical licenses that authorized therapeutic dosages of

radiopharmaceuticals that allowed the use of the new patient release criteria. The

license condition was not reviewed for completeness. The Division is proceeding to

adopt the rule in the next revision.

! “Licenses for Industrial Radiography and Radiation Safety - Requirements for Industrial

Radiography Operations,” 10 CFR Parts 30, 34, 71, and 150 amendments (62 FR

28947) that became effective June 27, 1997. Parts of this rule are designated as

category B for compatibility.

! “Radiological Criteria for License Termination,” 10 CFR Parts 20, 30, 40, and 70

amendments (62 FR 39057) that became effective August 20, 1997. Parts of this

amendment are designated as A and or B for compatibility.

Regulations needed in the future were identified as follows:

! “Exempt Distribution of a Radioactive Drug Containing One Microcurie of Carbon-14

Urea,” 10 CFR Part 30 amendment (62 FR 63634) that became effective January 2,

1998. This rule was reportedly drafted by the Division in February 1998 and is

designated as category B for compatibility. 

! “Minor Corrections, Clarifying Changes, and a Minor Policy Change,” 10 CFR Parts 20,

35, 36 amendments (63 FR 39347 and 63 FR 45393) that became effective October 26,

1998. Definitions changes in this rule are designated as category A for compatibility.

! “Transfer for Disposal and Manifests: Minor Technical Conforming Amendment,” 10 CFR

Part 20 amendment (63 FR 50127) that became effective November 20, 1998. This

amendment is designated as category B for compatibility.

! “Deliberate Misconduct by Unlicensed Persons,” 10 CFR Parts 30, 40, 61, 70, and 150

amendments (63 FR 1890 and 13773) that became effective February 12, 1998.

! “License for Industrial Radiography and Radiation Safety Requirements for Industrial

Radiographic Operations; Clarifying Amendments and Corrections,” 10 CFR Part 34

amendment (63 FR 37059) that became effective July 9, 1998. Portions of this rule are

designated as category B for compatibility.
Tennessee Final Report Page 15

! “Termination of Transfer of Licensed Activities: Recordkeeping Requirements,” 10 CFR

Parts 20, 30, 40, 61, and 70 amendments (61 FR 24669) that became effective June 17,

1999.

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

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

Portions of this amendment are designated as category B for compatibility.

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

10 CFR Part 39 amendment (65 FR20337) that became effective May 17, 2000. 

Portions of this amendment are designated as category B for compatibility.

It is noted that Management Directive 5.9, Handbook, Part V, (1)(C)(III) provides that regulations

issued prior to September 3, 1997 should be adopted by the State as expeditiously as possible,

but not later than three years after the September 3, 1997 effective date of the Commission

Policy Statement on Adequacy and Compatibility, i.e., September 3, 2000.

During the review, Division staff reported that the Tennessee regulations were being revised in

their entirety and estimated that at least six months would be needed for their adoption after they

were approved by Division management. The review team recommends that the Division adopt

the regulations needed for compatibility as expeditiously as possible and provide the proposed

regulations to the STP for compatibility review in accordance with the procedure SA-201

“Review of State Regulations.” 

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

performance with respect to the indicator, Legislation and Program Elements Required for

Compatibility, be found unsatisfactory.

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

In assessing the State's SS&D evaluation program, the review team examined information

provided by the State in response to the IMPEP questionnaire on this indicator. A review of

selected new and amended SS&D evaluations and supporting documents covering the review

period was conducted. The team observed the staff's use of guidance documents and

procedures, interviewed the two Managers and staff involved in SS&D evaluations, and verified

the use of regulations and license conditions to enforce commitments made in the applications.

4.2.1 Technical Quality of the Product Evaluation Program

The Division has processed two new registrations, and amended 19 other registrations since

the last review. The review team selected the two newly issued SS&D registry certificates and

nine other registrations for review. The review included all amendments, supporting

documentation, licenses, and inspections associated with each of the registrations selected. 

The certificates reviewed covered the period since the last program review in December of 1996

and represented cases completed by all reviewers. The SS&D certificates issued by the

Division and evaluated by the review team are listed with case-specific comments in

Appendix F.

Analysis of the files and interviews with the staff confirmed that the Division follows the

recommended guidance from the NRC SS&D training workshops and NUREG-1556, Volume 3,
Tennessee Final Report Page 16

issued July 1998. Appropriate review checklists were used to assure all relevant 

materials have been submitted and reviewed. Checklists were contained in the registration files. 

All pertinent American National Standards Institute standards, Regulatory Guides, and applicable

references were confirmed to be available and were used when performing SS&D reviews.

The registration files contained all correspondence, photographs, engineering drawings,

radiation profiles, and results of tests conducted by the applicant. The registrations clearly

summarized the product evaluation to provide license reviewers with adequate information to

license the possession and use of the product. Deficiency letters clearly stated regulatory

positions and all health and safety issues were properly addressed. The review team

determined that the product evaluations were thorough, complete, consistent, of acceptable

technical quality, and adequately addressed the integrity of the products during use and in the

event of an accident.

4.2.2 Technical Staffing and Training

The manager of the Radioactive Materials Specific Licensing Section is the principal reviewer

and signs all registration sheets. A concurrence review is performed by the manager of the 

Licensing/Registration/Planning Branch. The principal reviewer and the concurrence reviewer

both have Bachelor of Science degrees, many years of experience in health physics; licensing;

inspections; performing SS&D reviews; and both have attended the NRC/State SS&D

workshops. Two experienced license reviewers are being trained to perform SS&D reviews

under the direct supervision of the principal reviewer. These trainees were determined by the 

team during interviews to be fully trained license reviewers, adequate to perform limited SS&D

reviews under the direct supervision of the principal reviewer, and the case specific registration

reviews performed during this review period. However, the trainees have not attended the SS&D

workshops which would assist in qualifying them to sign the registration sheets as a reviewer. 

Signatures and reviewer qualifications were discussed with the principal reviewer. The principal

reviewer confirmed that the trainees had only performed work under his direct supervision and

that the trainees would be sent to the next SS&D workshop scheduled for FY 2001 providing

funds are available. The qualification of the trainees have not been fully documented as

discussed under Section 3.3 and the SS&D managers acknowledged the need for additional

authorization documentation for the reviewers. The managers are committed to maintaining a

high degree of quality in their SS&D reviews. The review team recommends that all persons

conducting principal and concurrent reviews for SS&D registrations be fully qualified and have

documented authorizations on file.

4.2.3 Evaluation of Defects and Incidents Regarding SS&Ds

No significant incidents or defects related to SS&Ds were reported with these devices

(products) during the review period. The team also verified that there were no reported incidents

through discussions with the SS&D reviewers and a review of the incidents as discussed under

Section 3.5. An on-line search by manufacturer utilizing the NMED system was conducted by

the team prior to the review, and no incidents were identified that were related to any

malfunctioning devices or products considered during this review. 

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

performance with respect to the indicator, Sealed Source and Device Evaluation Program, be

found satisfactory.
Tennessee Final Report Page 17

4.3 Low-Level Radioactive Waste (LLRW) Disposal Program

In 1981, the NRC amended its Policy Statement, "Criteria for Guidance of States and NRC in

Discontinuance of NRC Authority and Assumption Thereof by States Through Agreement" to

allow a State to seek an amendment for the regulation of LLRW as a separate category. Those

States with existing Agreements prior to 1981 were determined to have continued LLRW

disposal authority without the need of an amendment. Although Tennessee has LLRW disposal

authority, NRC has not required States to have a program for licensing a LLRW disposal facility

until such time as the State has been designated as a host State for a LLRW disposal facility. 

When an Agreement State has been notified or becomes aware of the need to regulate a LLRW

disposal facility, they are expected to put in place a regulatory program which will meet the

criteria for an adequate and compatible LLRW disposal program. There are no plans for a

LLRW disposal facility in Tennessee. Accordingly, the review team did not review this indicator.

5.0 SUMMARY

As noted in Sections 3 and 4 above, the review team found that Tennessee’s performance to be

satisfactory for the indicators, Technical Staffing and Training, Technical Quality of Licensing

Actions, and Sealed Source and Device Evaluation Program. The review team found

Tennessee’s performance to be satisfactory with recommendations for improvement for the

indicator, Response to Incidents and Allegations. The review team found Tennessee’s

performance to be unsatisfactory for the indicators, Status of Materials Inspections, Technical

Quality of Inspections, and Legislation and Program Elements Required for Compatibility. 

Accordingly, the review team recommended and the MRB concurred in finding the Tennessee

Agreement State Program to be adequate, but needs improvement and not compatible with

NRC's program. The review team recommended and the MRB concurred that a program of

Heightened Oversight be implemented to assess the progress of the State in implementing

corrective actions discussed at the exit meeting and the MRB meeting. The MRB requested the

State prepare and submit a program improvement plan which addresses the recommendations

below. The MRB also requested that the State submitted bi-monthly status reports and

participate in bi-monthly conference calls to discuss the progress to date on the State’s action

plan. The initial conference call should be scheduled no later than February 1, 2001. 

Based on the results of the current IMPEP review, the review team recommended and the MRB

concurred that a follow-up review will be scheduled during the period August - October 2001.

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

evaluation and implementation, as appropriate, by the State. 
Tennessee Final Report Page 18

RECOMMENDATIONS:

1. The review team recommends that the Division take actions to ensure that: (1)

inspections are conducted in accordance with their assigned inspection frequencies;

(2) inspection reports are issued in a timely manner; (3) inspection reports and

associated information are filed in a manner that the information can be retrieved; and (4)

deficiencies in the inspection tracking system are corrected. (Section 3.1)

2. The review team recommends that the Division follow the Tennessee inspection policy

and procedures. (Section 3.2)

3. The review team recommends that the Division ensure that inspection findings are fully

supported in documentation of the inspection and that cited violations are fully supported

in the inspection report. (Section 3.2)

4. The review team recommends that the Division develop and document a training and

qualification program which address the training requirements in the NRC/Organization

of Agreement States Training Working Group Report or NRC Inspection Manual Chapter

1246. (Section 3.3)

5. The review team recommends that the inspection staff be trained in the Division’s

policies and procedures on the conduct of inspections. (Section 3.3)

6. The review team recommends that the Division ensure that independent, documented

evaluations of the licensee’s actions and root cause analyses are completed as part of

an incident investigation. (Section 3.5)

7. The review team recommends that the Division formally close incident files, including

a review to ensure that all the necessary documentation is included in the file. 

(Section 3.5)

8. The review team recommends that supervisory reviews be conducted to ensure

thoroughness of investigations of allegations, including that allegation are closed out with

the alleger. (Section 3.5)

9. The review team recommends that the Division adopt the regulations needed for

compatibility as expeditiously as possible and provide the proposed regulations to the

STP for compatibility review in accordance with the procedure SA-201 “Review of State

Regulations.” (Section 4.1.2)

10. The review team recommends that all persons conducting principal and concurrent

reviews for SS&D registrations be fully qualified and have documented authorizations on

file. (Section 4.2.2)
LIST OF APPENDICES AND ATTACHMENTS

Appendix A IMPEP Review Team Members

Appendix B Tennessee Organization Charts

Appendix C Inspection Casework Reviews

Appendix D License Casework Reviews

Appendix E Incident Casework Reviews

Appendix F Sealed Source & Device Casework Reviews

Attachment 1 Tennessee Comments on the Draft IMPEP Report dated 

October 23, 2000
APPENDIX A

IMPEP REVIEW TEAM MEMBERS

Name Area of Responsibility

Dennis Sollenberger, STP Team Leader

Technical Staffing and Training

Richard Woodruff, Region II Sealed Source and Device Evaluation Program

Legislation and Program Elements Needed for

Compatibility

Jamnes Cameron, Region III Technical Quality of Inspection

Inspection Accompaniments

Betsy Ullrich, Region I Technical Quality of Licensing Actions

Barbara Hamrick, California Response to Incidents and Allegations

Status of Materials Inspections Program
APPENDIX B

TENNESSEE

DEPARTMENT OF ENVIRONMENT AND CONSERVATION

ORGANIZATION CHART

and 

DIVISION OF RADIOLOGICAL HEALTH

ORGANIZATIONAL CHART

ML003752894