DATED: AUGUST 12, 1996 SIGNED BY: HUGH L. THOMPSON, JR.

Mr. John H. Morse, Secretary

Cabinet for Health Services

275 East Main Street

Frankfort, KY 40621-001

Dear Mr. Morse:

On July 17, 1996, the Management Review Board (MRB) met to consider the proposed

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

Kentucky Agreement State Program. The MRB considered and concurred with the

review team's recommendation that the Kentucky program be found adequate to protect

public health and safety and compatible with NRC's regulatory program. Based on State

performance, the next IMPEP review will be scheduled in four years, unless program

concerns develop that require an earlier evaluation.

NRC recognizes the efforts of Kentucky and the other Agreement States to maintain an

adequate and compatible program. During the MRB meeting, the MRB discussed with

the review team the extent of the heavy workload handled by the program, not only in the

Agreement Materials area, but also in other radiation control program areas as well. 

One example relates to the programs' response to non-Atomic Energy Act material

incidents. Kentucky's efforts to maintain an adequate and compatible program while at

the same time devoting significant effort in other programs, such as in response to these

incidents, is commendable. Nevertheless, this is an area that appears to need a

resource evaluation review to ensure that sufficient staffing is available to respond to all

program areas, while maintaining the ability to adequately protect public health and

safety. 

Section 5 page 20 of the enclosed final report presents the IMPEP team's

recommendations. We request your evaluation and response to those recommendations

within 30 days from receipt of this letter.
John H. Morse 2

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

review.

Sincerely, /RA/

Hugh L. Thompson, Jr. 

Deputy Executive Director for

 Nuclear Materials Safety, Safeguards,

 and Operations Support

Enclosure: 

As stated

cc: Rice C. Leach, M.D., Commissioner, Department of Public Health

John Volpe, Ph.D., Manager, Radiation & Toxic Agents Control Section
John H. Morse 3

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

review.

Sincerely,

Hugh L. Thompson, Jr. 

Deputy Executive Director for

 Nuclear Materials Safety, Safeguards,

 and Operations Support

Enclosure: 

As stated

cc: Rice C. Leach, M.D., Commissioner, Department of Public Health

John Volpe, Ph.D., Manager, Radiation & Toxic Agents Control Section

bcc: Chairman Jackson

Commissioner Rogers

Commissioner Dicus

 

Distribution: 

DIR RF EDO RF HLThompson, DEDS

DCD (SP01) RLBangart PLohaus

SDroggitis KSchneider CPaperiello, NMSS

ELJordan, AEOD KCyr, OGC JHornor, RIV/WC

RWoodruff, RII DCollins, RI JMcNees, AL

JPiccone, NMSS CHaney, NMSS DCool, NMSS

GPangburn, NMSS FCameron, OGC HNewsome, OGC

TCombs, OCA

DOCUMENT NAME: G:\KXS\96FINLTR.KY, G:\KXS\KYIMPEP.FIN

*See previous concurrence.

To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy

OFFICE WCFO/RIV* E OSP* E OSP:DD* OSP:D DEDS

NAME JHorner KSchneider PLohaus RLBangart HLThompson

DATE 07/30/96 07/30/96 07/31/96 08/ /96 08/ /96

 OSP FILE CODE: SP-AG-11
INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM

REVIEW OF KENTUCKY AGREEMENT STATE PROGRAM

April 15-19, 1996

FINAL REPORT

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

1.0 INTRODUCTION

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

review was conducted during the period April 15-19, 1996, by a review team comprised of

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

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

accordance with the "Interim Implementation of the Integrated Materials Performance Evaluation

Program Pending Final Commission Approval of the Statement of Principles and Policy for the

Agreement State Program and the Policy Statement on Adequacy and Compatibility of Agreement

State Programs," published in the Federal Register on October 25, 1995, and the September 12,

1995, NRC Management Directive 5.6, "Integrated Materials Performance Evaluation Program

(IMPEP)." Preliminary results of the review, which covered the period May 13, 1994, to April 19,

1996, were discussed with Kentucky management on April 18 and 19, 1996. 

A draft of this report was issued to Kentucky for factual comment on June 13, 1996. The

Commonwealth of Kentucky responded in a letter dated June 21, 1996 (Attachment 1), and the

comments were incorporated into the proposed final report. The Management Review Board

(MRB) met on July 17, 1996, to consider the proposed final report. The MRB concurred in the

teams's overall recommendations and found that the Kentucky radiation control program was

adequate to protect public health and safety and was compatible with the NRC's regulatory

program.

The Cabinet for Health Services (CHS), which recently replaced the Cabinet for Human

Resources, is the radiation control agency within the Commonwealth of Kentucky. The Secretary

is appointed by and reports to the Governor. Within CHS, the Kentucky radiation control program

is administered by the Radiation Control Branch (RCB) under the direction of the Department of

Health Services through the Division of Environmental Health and Community Safety (DEHCS). 

The Department of Health Services will become the Department of Public Health in the near

future. The RCB organization chart is included as Appendix B. The Kentucky program regulated

403 specific licensees, including the specific license for the Maxey Flats radioactive waste

disposal site, at the time of the review. The review focused on the materials 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 Commonwealth of Kentucky.

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

was sent to the RCB on February 14, 1996. Kentucky provided its response to the questionnaire

on March 26, 1996. A copy of that response is included as Appendix C to this report. 

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

Kentucky's response to the questionnaire, (2) review of applicable Kentucky statutes and

regulations, (3) analysis of quantitative information from the RCB licensing and inspection data

base, (4) technical review of selected files, (5) field accompaniments of one Kentucky inspector,

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 non-common indicator and made a preliminary assessment of RCB's performance. 

As noted above, that preliminary assessment was discussed with program management before the

team's departure.
Kentucky Draft IMPEP Report Page 2

Section 2 below discusses the Commonwealth's actions in response to recommendations made

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

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

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

2.0 STATUS OF ITEMS IDENTIFIED IN PREVIOUS REVIEWS

The previous routine review concluded on May 13, 1994, and the results were transmitted to

Masten Childers II, Secretary, Cabinet for Human Resources, on January 27, 1995. 

The May 1994 review findings resulted in recommendations in six program indicators: Status and

Compatibility of Regulations, Adequacy of Product Evaluations, Staffing Level, Staff Continuity,

Budget, and Licensing Procedures. The Commonwealth's corrective actions in response to the

recommendations were evaluated during a review visit which concluded on April 18, 1995, and

with one exception, all comments and recommendations were satisfactorily resolved and closed at

that time. Results of the review visit were transmitted to the present Secretary, Cabinet for Health

Services, John H. Morse, on March 15, 1996.

The April 1995 review visit findings resulted in recommendations in one indicator. We

recommended the RCB take the following steps to improve the sealed source and device (SS&D)

evaluation program: (a) obtain engineering technical expertise for SS&D reviews, such as through

contractual agreements or through State agencies or universities, that could be called upon as

needed for resolution of specific engineering issues that may be encountered during SS&D

reviews; (b) develop an action plan for the review of all device sheets to assure that the files

contain all current background information and drawings applicable to the device safety review;

(c) establish documentation in the files which show that the generally licensed (GL) devices will

meet the dose requirements; and (d) amend the Commonwealth's regulations to adopt

requirements equivalent to those in 10 CFR 30.32(g) and 32.210(c), or amend the SS&D licenses

with conditions that specifically tie the respective devices, drawings, and background information

to the license. 

The current status of the above SS&D evaluation program is as follows: 

(a) The RCB Manager explained that if engineering expertise beyond the Commonwealth's

capability was needed, that he had an informal arrangement with the School of Chemical

Engineering, University of Kentucky, to assist the program with engineering evaluations of

sealed sources and/or devices evaluations as needed. The RCB Manager also related

that after receiving the SS&D Workshop training in 1995, he was confident that the

Kentucky could perform the reviews in accordance with the NRC guidance received at the

workshop. The review team feels that this action is sufficient and considers the issue

closed.

(b) The Commonwealth developed an action plan for the reassessment of all previously

issued device sheets by reviewing one device sheet every month. Although RCB

evaluated new devices during the period, workload demands prevented the reassessment

of the previously approved devices. The RCB has not been able to maintain this
Kentucky Draft IMPEP Report Page 3

schedule; workload demands prevented the reassessment of the previously approved

devices. RCB did review and register one new device and another device was reviewed;

RCB is awaiting a response from the applicant. In Section 4.2 of this report, the team

recommends that the work continue on the review of previous device sheets that remain

under Kentucky jurisdiction, as planned. This recommendation is considered closed and

will be tracked as a new recommendation (see Section 5.0).

(c) One element of the Commonwealth's action plan called for documentation to be added to

the files showing that the generally licensed (GL) devices meet the current dose

requirements. This task was to have been completed at the time the old device sheets

were reevaluated. However, since none of the previously issued device sheets were

reviewed, the GL dose documentation has not been added to the files. In Section 4.2, the

team also recommends that work on this portion of the action plan be continued to

completion. (It should be noted that Ohmart Corporation notified Kentucky that the

Kentucky facility would be closed prior to June 1996 and regulatory jurisdiction for these

products will be transferred to the NRC.) This recommendation is considered closed and

will be tracked as a new recommendation (see Section 5.0).

(d) The Commonwealth amended the licenses of Ohmart (License Number 

201-491-95) and Ronan (License Number 202-260-95) by incorporating the equivalent

requirements of 10 CFR Part 32.210(c) into the license through the use of a binding

commitment from the licensee and as incorporated into the license by license condition. 

The RCB manager verbally committed during the exit meetings to adopting the equivalent

provisions of 10 CFR Parts 30.32(g) and 32.210(c) as regulations during the next

regulation revision scheduled for FY 97. The license conditions were verified during the

casework review, and the review team considers this issue 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 include: (1) Status of Materials Inspection

Program; (2) Technical Staffing and Training, (3) Technical Quality of Licensing Actions, (4)

Technical Quality of Inspections, and (5) Response to Incidents and Allegations. 
Kentucky Draft IMPEP Report Page 4

3.1 Status of Materials Inspection Program

The team focused on four factors in reviewing this indicator: (1) inspection frequency, (2) overdue

inspections, (3) initial inspection of new licenses, and (4) timely dispatch of inspection findings to

licensees. This evaluation is based on the Kentucky's questionnaire responses regarding this

indicator, data gathered independently from the Commonwealth's licensing and inspection data

tracking system, the examination of licensing and inspection casework files, and interviews with

managers and staff.

The team's review of the Commonwealth's inspection priorities verified that the Commonwealth's

inspection frequencies for various types or groups of licenses are at least as frequent as similar

license types or groups listed in the frequency schedule in the NRC Inspection Manual Chapter

2800 (IMC 2800). In reviewing the Commonwealth's priority schedule, the review team noted that

the Commonwealth requires more frequent inspections in some license categories as follows: 

Portable gauges are scheduled to be inspected on a four year frequency vs. NRC's five year

frequency, and medical private practice licenses not required to have a quality management (QM)

program have a four year frequency schedule vs. NRC's frequency of five years.

The inspection frequencies of licenses selected for inspection file review were compared with the

frequencies listed in the Commonwealth's data system and verified to be consistent with the

Commonwealth's system and as frequent as similar license types under the IMC 2800 system.

In their response to the questionnaire, Kentucky indicated that as of April 19, 1995, only two

licenses identified as core inspections in IMC 2401 or IMC 2800, as appropriate, were overdue by

more than 25 percent of the NRC's frequency. This number is well within the 10 percent criterion

for overdue inspections of Management Directive 5.6. In fact, one of the overdue inspections had

been inspected by the time of the review. The other overdue inspection was for the Maxey Flats

Low-Level Waste Project and is discussed in Section 4.3.2 of this report.

With respect to initial inspections of new licensees, the team reviewed the inspection tracking data

system and verified that the initial inspections had been entered into the tracking system. 

Discussions with staff members were conducted to determine how initial inspections are assigned

and how data are entered into the system. The administrative staff sends the data generated by

the technical staff to a contractor to update the data base. This is done on a monthly basis and

then a quality check is performed by supervision based upon a computer printout provided by the

contractor and used for inspection planning. All initial inspections were completed within 6 months

of issuance.

The timeliness of the issuance of inspection findings was also evaluated during the inspection file

review. Out of the files examined, all of the inspection correspondence had been sent to the

licensee within 30 days after completion of the inspection. 

Kentucky reported in their response to the questionnaire that 80 different licensees had submitted

requests for reciprocity during the review period, of which 18 were from licensees with inspection

intervals of 3 years or less. The Commonwealth reported that one of these was inspected and

five other licenses having longer inspection frequencies were inspected. 
Kentucky Draft IMPEP Report Page 5

Based on the IMPEP evaluation criteria, the review team recommends that Kentucky's

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

satisfactory.

3.2 Technical Staffing and Training

In reviewing this indicator, the review team considered the radioactive materials program staffing

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

issues, the review team examined the Commonwealth's questionnaire responses regarding this

indicator, interviewed RCB management and staff, and considered any possible backlogs in

licensing or compliance actions. Technical staffing and training for the low-level radioactive waste

disposal program are addressed in Section 4.3.3.

At the time of the review, Kentucky’s radiation control program was staffed by the Radioactive

Materials Section (RMS) Supervisor and three other health physicists under the supervision of the

Radiation Control Branch Manager. The RCB Manager is also indirectly responsible for all

radiation safety matters administered by other DEHCS branches, such as machine radiation and

laboratory services. The review team found that the current staffing level is adequate to

administer the basic regulatory program, as evidenced by the lack of backlogs in licensing and

inspections. However, according to program management and team observation, complex

licensing and compliance cases, complicated investigations, specialized training needs, and

frequent revisions to regulations often require use of overtime and delayed personal and annual

leave by the supervisors and other technical staff.

The licensing and inspection functions of the program are integrated; therefore, all health

physicists perform duties in licensing, inspection, and event response. Because of the need for

continuity and specialized training, however, SS&D evaluations are assigned to one of two trained

individuals. Balance between the licensing and inspection functions is achieved by basing staff

assignments on program needs. Personnel information provided by the RCB showed that there

had been no staff turnover and no vacancies in the radioactive materials program during the

review period. 

From program manager interviews and review of the job descriptions, the review team determined

that successful candidates for technical positions are required to have a Bachelor’s degree in

science for the first level and a Master’s degree and/or additional radiation-related work

experience for steps beyond the entry level. From review of the technical qualifications of the

current radioactive materials staff, the team concluded that the Commonwealth has been able to

recruit qualified individuals. All of the health physicists and the Section Supervisor have

Bachelor’s degrees in science; and the Branch Manager is a Ph.D.

According to the information provided in the questionnaire and the RCB training procedures, all

newly hired health physicists are required to attend the NRC core training courses outlined in the

now suspended May 28, 1992, Policy Statement (57 FR 224950), as well as the five-week health

physics course. The records show that all radioactive materials staff members have taken the

five-week health physics course and the four NRC core courses. Most other NRC courses

applicable to the materials program have also been taken by all professional staff. Two
Kentucky Draft IMPEP Report Page 6

individuals have not taken the Health Physics Engineering and Safety Aspects of Well Logging

courses, but management explained they expect to schedule them soon.

Program management also explained their in-house and on-job training processes in their

response and during interviews. Briefly, new staff are assigned increasingly complex licensing

duties under the direction of senior staff and accompany experienced inspectors during

increasingly complicated inspections. New staff are assigned independent inspections after

demonstrating competence during accompaniment evaluations by the RMS Supervisor. In

addition, the supervisor evaluates the level of radiation protection knowledge by use of written and

oral examinations during the training period. The written examinations and training

accompaniment evaluations were reviewed by the team and found to be excellent. The use of

written examinations is a strength in the Kentucky program. The team noted that program

management exhibited a strong commitment to training during the review.

As discussed above, the staff has used overtime and delayed personal and annual leave to avoid

licensing and inspection backlogs. In order to free technical staff from excessive administrative

and record keeping duties, the RCB is in the process of building an in-house local area network

(LAN) with a licensing and inspection data base. Program management explained that they feel

that their technical staff could operate more efficiently by having access to a system to collectively

store, retrieve, manipulate, and transmit data and information. The review team agrees that, once

installed and operating, a LAN system should enable staff to devote more of their efforts to the

technical aspects of their responsibilities, thus enhancing the overall quality of the regulatory

program.

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

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

3.3 Technical Quality of Licensing Actions

The review team examined casework and interviewed the reviewers for 25 specific licenses. 

Licensing actions were reviewed 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. Casework was

reviewed 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 authorities. Licenses were reviewed for

accuracy, appropriateness of the license and of its conditions and tie-down conditions, and overall

technical quality. The files were checked for retention of necessary documents and supporting

data.

Kentucky policy requires each licensee to review its program at five-year intervals and submit a

complete program for review by the staff as part of the license renewal. The RCB renews each

license annually, and amends licenses as needed. The staff makes extensive use of checklists

and standard review plans. 
Kentucky Draft IMPEP Report Page 7

The cases were selected to provide a representative sample of licensing actions which had been

completed in the review period and to include work by all reviewers. The cross-section sampling

included two of Kentucky's major licenses and included the following types: medical broad scope

(with a HDR afterloader), academic broad scope, nuclear pharmacy, research and development,

mobile nuclear medicine, nuclear medicine, teletherapy, portable and fixed gauges, and industrial

fixed radiography. Licensing actions included 6 new licenses, 3 five-year interval renewals, 10

amendments, and 6 terminations. A list of these licenses with case-specific comments can be

found in Appendix D.

The review team found that, overall, the licensing actions were generally thorough, complete,

consistent, and of acceptable quality with health and safety issues properly addressed. Special

license tie-down conditions were almost always stated clearly, backed by information contained in

the file, and inspectable. The licensee's compliance history was taken into account when

reviewing renewal applications. The Commonwealth's licensing guides and license policy

procedures were revised and updated during the review period, and reviewers were observed to

have good research skills in using these and other licensing documents. With few exceptions,

reviewers appropriately used the new licensing guides and accompanying check sheets. 

Normal peer review is accomplished as the RMS Supervisor reviews all new or renewed licenses

and amendments prior to issuance. All licensing actions are signed by the RCB Manager. 

Complex reviews are performed by the RMS Supervisor and reviewed by the RCB Manager. 

Just prior to the review, the RMS Supervisor had identified the need for revising and improving the

procedures for terminating licenses. Although the Supervisor was using the guidance recently

issued by the Office of Nuclear Material Safety and Safeguards (NMSS) to develop new

procedures to ensure proper closeout of terminated licenses, the terminated files still showed

some missing documentation as to the ultimate disposition of the radioactive material. The review

team found the work to be progressing satisfactorily.

Kentucky's other licensing guides and license conditions were adopted directly from the NRC’s. 

No potentially significant health and safety issue were identified.

Based on the IMPEP evaluation criteria, the review team recommends that performance with

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

3.4 Technical Quality of Inspections

The team reviewed the inspection reports, enforcement documentation, and the data base

information for 20 materials inspections conducted during the review period. The casework

included all of the Commonwealth's materials inspectors and covered a sampling of the higher

priority categories of license types as follows: two institutional medical for diagnostic, four

institutional medical with brachytherapy and isotope therapy, one institutional medical with an

HDR unit, one teletherapy, two nuclear pharmacies, one broad medical, one veterinary, one

industrial radiography, one distribution, and three portable gauges. Appendix E provides a list of

the inspection cases reviewed in depth with case-specific comments.
Kentucky Draft IMPEP Report Page 8

The inspection procedures and techniques utilized by Kentucky were reviewed and determined to

be consistent with the inspection guidance provided in IMC 2800. All inspections are conducted

on an unannounced basis except those instances where notification is necessary because of the

geographical location or to obtain a meeting with specific licensee management or individuals. 

 

The inspection report forms were reviewed and found to be consistent with the types of

information and data collected under IMC 2800 and 87100 documents. The Commonwealth uses

separate supplements to the inspection report form for various classes of license types, such as

medical, brachytherapy, pharmaceutical therapy, teletherapy, portable gauges, fixed gauges, field

radiography, fixed-facility radiography, well logging, and laboratory type inspections. The reports

were reviewed to determine if the reports adequately documented the scope of the licensed

program, licensee organization, personnel protection, posting and labeling, control of materials,

equipment, use of materials, transfer, and disposal. The reports were also checked to determine

if the reports adequately documented operations observed, interview of workers, independent

measurements, status of previous noncompliance items, substantiation of all items of

noncompliance, and the substance of discussions during exit interviews with management.

For the most part, the review team found that the inspection reports contained only minor

discrepancies when compared to Commonwealth internal guidance or standard practice. Two

reports needed additional information to fully document the details of the independent

measurements and associated results developed during the respective inspections. One report

needed additional information to describe the circumstances and details under which a licensee

survey meter was determined to be inoperable. 

The Section Supervisor reviews and initials all inspection reports and signs all routine

enforcement correspondence which enhances the quality of the correspondence to the licensee. 

Kentucky uses a manual logging system to track inspections performed, status of reports, letters

to licensees, responses from licensees, and acknowledgment letters. Inspection data are also

placed on computer change forms and sent to a contractor for updating the inspection and

licensing data base. No discrepancies were found in the manual system. The desirability,

convenience, flexibility, and efficiency of maintaining the data base on the Commonwealth's

computers was discussed with the RMS Supervisor. 

The files were found to be well organized, orderly, and easily accessed for information. The files

were also found to be complete with all license and enforcement documents and correspondence. 

The enforcement letters and correspondence were determined to be written in appropriate

regulatory language and timely in all cases.

The Commonwealth bases their enforcement program primarily upon onsite inspections, informal

enforcement conferences and increased inspection frequencies as a means to obtain compliance. 

When the licensee responds to the notice of violation (NOV), the response is given to the

inspector to evaluate the licensee's response, and to draft a reply for the supervisor's review or

signature. The use of informal enforcement conferences (verbally requested meeting with

licensee to discuss inspection findings and potential enforcement actions) has been an effective

tool for the Commonwealth. These conferences are followed by another unannounced inspection

to confirm and evaluate the licensee's corrective actions. The review team concluded that the
Kentucky Draft IMPEP Report Page 9

enforcement policies were effective, and this supervisory review enhanced the quality of the

inspection and enforcement documents. Kentucky does not have civil penalty authority. The

review team suggests that Kentucky consider obtaining necessary statutory authority to apply civil

penalties as an additional enforcement option to supplement their enforcement efforts. The

inspectors are also cross trained as license reviewers, which also strengthens the continuity of the

regulatory program. 

One inspector accompaniment was performed by a review team member during the visit on August

16, 1995. This accompaniment is identified in Appendix E. All of the other inspectors have been

accompanied during previous reviews. On the accompaniment, the Commonwealth inspector

demonstrated appropriate inspection techniques and knowledge of the regulations. The inspector

was well prepared and thorough in the review of the licensees' radiation safety program. Overall,

the technical performance of the inspector was satisfactory, and the inspection was adequate to

assess radiological health and safety at the licensed facility.

In response to the questionnaire, Kentucky reported that no supervisory inspector

accompaniments were performed during 1994; however, three inspectors were accompanied by

the RMS Supervisor during 1995. Kentucky further reported that supervisory accompaniments

are required for junior staff before they are allowed to perform independent inspections. Kentucky

has a policy of annual supervisory accompaniments of all inspectors. The review team

considered the high demands placed on supervisory staff during this review period because of the

efforts necessary to update regulations, the need to evaluate new devices, issue and amend

SS&D registrations and the efforts needed to prevent the development of licensing and inspection

backlogs. However, supervisory accompaniments provide management with important insight into

the quality of the inspection program. The review team recommends that the Commonwealth

maintain its policy of annual supervisory accompaniments of all inspectors.

It was noted that Kentucky has a variety of portable instruments for routine confirmatory surveys

and use during incidents and emergency conditions. The instruments were a good mix of low

range GM tubes and pancake probes, micro R meters, high range instruments, instrumentation

with calibration standards for alpha detection, a neutron rem ball, and a portable multichannel

analyzer. Air monitoring equipment is also available. The portable instrument used during the

inspector accompaniment was observed to be operational and calibrated. The portable

instruments maintained in the office were also observed to be calibrated. Program staff explained

that instruments are calibrated at least on an annual basis, and staggered so as to always have

instruments calibrated within the calendar quarter for use during industrial radiography

inspections. 

Based on the IMPEP evaluation criteria, the review team recommends that Kentucky's

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

3.5 Response to Incidents and Allegations

In evaluating the effectiveness of the Commonwealth's actions in responding to incidents and

allegations, the review team examined the Commonwealth's response to the questionnaire

regarding this indicator, reviewed the incidents reported for Kentucky in the "Nuclear Material
Kentucky Draft IMPEP Report Page 10

Events Database" (NMED) against those contained in the Kentucky files and reviewed the

casework of 15 reportable incidents and 6 allegations identified as involving byproduct material. 

In addition, the review team interviewed the RCB Manager, the RMS Supervisor, and the health

physicists assigned to incident response.

Responsibility for initial response and follow up actions to radioactive materials incidents and

allegations rests with the RCB. Written procedures require that notifications of incidents be

referred to the RMS Supervisor, who will determine the extent of the investigation and/or

response. Complex events or those with potential for impacting public safety or likely to involve

media attention are referred to the RCB Manager. Review of the files indicated that this approach

provided effective response actions and did not delay the response time.

All incident files of reportable incidents involving byproduct material that occurred during the

review period were reviewed. The information in NMED agreed with the information in the

Kentucky files. These included three misadministrations, three loss of control of material, three

damaged devices, two leaking sources, one possible overexposure, one equipment failure, one

contamination event, and one byproduct sealed source found in scrap. A list of the incident

response case work with comments is included as Appendix F.

For the most part, the correct procedures were followed. In most instances actions were

appropriate and timely. The level of effort was typically commensurate with the hazard to the

public. Suitable enforcement actions were taken, and almost all items were followed to resolution. 

There were, however, instances in which improvement was needed.

C In 2 of 15 cases, the incident report did not document supervisory oversight.

C In four cases, the report did not document that the incident was closed. In two others, the

report did not indicate that the incident was not closed nor did it contain an indication of

the reason why it was not closed.

C In one case, the licensee was not cited for loss of control of the radioactive source or for

failure to provide timely notification.

C After the Owens Illinois Labels incident, the Commonwealth waited 43 days before making

an onsite response to a possible leaking source at a general licensee. The

Commonwealth indicated that the delay was due to the reorganization of the program and

lack of immediate availability of staff to respond to the incident. Without having good

reason to believe the general licensee was capable of managing a leaking source, the

Commonwealth should have responded sooner to this potentially serious problem. 

Furthermore, the issue of the license authorization for and approval of procedures utilized

by the individual who apparently made an improper leak test at this facility was not

adequately resolved.

C On 11 occasions during the review period the Commonwealth responded to incidents of

unidentified unlicensed radioactivity, presuming the source to be naturally occurring and

accelerator-produced radioactive material (NARM). The review team believes that
Kentucky Draft IMPEP Report Page 11

identification of the radioactive isotope involved could lead to a better resolution of these

incidents because the source may not always be NARM. The review team recommends

that the Commonwealth determine the specific isotope in all incidents rather than

assuming the source to be NARM.

In spite of the number of incidents involving NARM radioactive material in Kentucky, especially an

increasing number of incidents involving NARM radioactivity in scrap metal, Kentucky has been

able to maintain its program for Atomic Energy Act material. In 1995, Kentucky issued 13

Department of Transportation (DOT) exemptions for the return of shipments that were turned

away from Kentucky scrap mills due to NARM radioactivity in the scrap. Also, in 1995, four DOT

exemptions were issued by other states for return to Kentucky of scrap containing NARM

radioactivity. Seventeen potential incidents in 1995 due to NARM radioactivity in scrap metal

amounted to approximately twice the number that occurred in 1994.

The response to six of the seven allegations received by the Commonwealth during the review

period that involved byproduct radioactive materials were examined in detail. Allegations were

responded to promptly with appropriate investigations and follow up actions. Proper procedures

were used for the control of information, and the results of the investigation were promptly related

to the alleger. No significant problems were observed.

Based on the IMPEP evaluation criteria, the review team recommends that Kentucky's

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

satisfactory.

4.0 NON-COMMON PERFORMANCE INDICATORS

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

State programs: (1) Legislation and Regulations, (2) Sealed Source and Device Evaluation

Program, (3) Low-Level Radioactive Waste Disposal Program, and (4) Uranium Recovery

Operations. Because Kentucky has no agreement to regulate uranium recovery operations, only

the first three performance indicators were applicable to this review.

4.1 Legislation and Regulations

4.1.1 Legislative and Legal Authority

Along with their response to the questionnaire, Kentucky provided the review team with copies of

legislation that affects the radiation control program. Kentucky Revised Statutes (KRS) Title XVIII,

Chapter 211, names the Cabinet for Human Resources as the radiation control agency of the

Commonwealth of Kentucky. (At the time of the review, the Governor was in the process of

changing the title of the Cabinet of Human Resources to the Cabinet for Health Services, and it is

so designated on the organization charts for this report.) Chapter 211 also authorizes the Cabinet

to regulate the registration and licensing of the possession or use of any sources of ionizing or

electronic product radiation and the handling and disposal of radioactive waste and to fix fees and

charges. 
Kentucky Draft IMPEP Report Page 12

4.1.2 Status and Compatibility of Regulations

All regulations that are required for compatibility that were identified as due or overdue for

adoption at the time of the 1994 routine review had been adopted at the time of the April 1994

review visit and had received final NRC review and approval as of August 18, 1995. The

Commonwealth regulations were acknowledged to be compatible in correspondence dated March

15, 1996, from Richard L. Bangart, Director, Office of State Programs, to John H. Morse,

Secretary, Cabinet for Human Resources.

The Commonwealth regulates a low-level radioactive waste disposal facility licensed prior to

NRC's 10 CFR Part 61. This is the only licensed low-level waste disposal facility in Kentucky and

is not an operating facility. The Commonwealth requires the licensee to carry out a

comprehensive quality assurance program for the licensed activities presently through license

tiedown condition. Previously, the Commonwealth had promulgated a rule equivalent to NRC's 10

CFR Part 61. The Commonwealth, however, does not expect to be designated as a host State for

a new low-level radioactive waste disposal facility. If Kentucky, in the future, becomes aware of

the need to regulate a new low-level radioactive waste disposal facility, the Commonwealth would

be expected to put in place all regulations necessary for compatibility. In the interim, however,

given the legally binding license condition requirement to conduct a comprehensive quality

assurance program, the review team concluded Kentucky does not need to adopt any change to

their Part 61 equivalent regulations to maintain compatibility. Therefore, Kentucky will not adopt

the following amendment to their regulations equivalent to the following NRC rules:

! "Definition of Land Disposal and Waste Site QA Program," 10 CFR Part 61 amendments

that became effective on July 22, 1993.

With the following exceptions, Kentucky has adopted all compatibility regulations which will

become due through June 1998:

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

amendments (59 FR 36026) that became effective on August 15, 1994, is under review

and is expected to become effective by the due date of August 15, 1997.

! "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, is under review and is expected to

become effective by the due date of January 1, 1998.

Kentucky has the following rules under consideration, but has no estimated date for the adoption:

! "Radiation Protection Requirements: Amended Definitions and Criteria," 10 CFR Parts 19

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

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

amendments (60 FR 38235) that became effective November 24, 1995.
Kentucky Draft IMPEP Report Page 13

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

(60 FR 50248) that became effective April 1, 1996.

During this review period, the only two regulations that were required for compatibility which were

not adopted within the three-year time frame became effective within six months after the due

date. Kentucky strives to meet the three-year compatibility requirement, and has enacted

emergency regulations to implement rules sooner if requested to do so by the NRC. The quality

management rule (QM), which was enacted as an emergency regulation in January 1994, was

one recent example of Kentucky's willingness to cooperate with the NRC. 

The review team examined the procedures used in the Kentucky's promulgation process and

found the public is offered several opportunities to comment on proposed regulations throughout

the process. According to program management, the NRC is provided with drafts of the proposed

regulations for comment during the process and any changes suggested by the NRC are

incorporated into the final rules.

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

performance with respect to the indicator, Legislation and 

Regulations, be found satisfactory.

4.2 Sealed Source and Device Evaluation Program

In evaluating the Commonwealth's SS&D evaluation program, the review team studied the

information provided by the questionnaire, reviewed the casework and background information of

all certificates of registration issued since the May 13, 1994, review, reviewed new procedures

and guidance, and interviewed RCB staff and managers responsible for SS&D evaluations.

At the time of the 1994 review, Kentucky had two major device manufacturers, Ohmart

Corporation and Ronan Engineering Company. On March 28, 1996, Ohmart Corporation notified

Kentucky that the Kentucky facility would be closed prior to June 1996. Ohmart also stated that

all sources had been moved, provided a survey protocol to the Commonwealth, and stated that

the final survey was planned for the week of April 29, 1996. Kentucky has scheduled an

inspection of the Ohmart facility during the time Ohmart's final survey will be performed. Only one

Ohmart device was registered by Kentucky since the 1994 review. Ronan is currently the only

device manufacturer in Kentucky and has nine registered devices. 

4.2.1 Technical Quality of the Product Evaluation Program

The April 1995 review visit resulted in recommendations for improvement in the Commonwealth’s

SS&D evaluation program. In response, Kentucky developed an action plan calling for the

reassessment of all previously issued device sheets to assure that the files contain all current

background information and drawings applicable to the device safety review, including

documentation that generally licensed (GL) devices meet the current dose requirements. 

Although the Commonwealth evaluated new devices during the period, workload demands

prevented the reassessment of the previously approved devices. The review team recommends

that the RCB continue with their plan to reassess all previously issued SS&D sheets, under their
Kentucky Draft IMPEP Report Page 14

regulatory jurisdiction to assure that the files contain all current background information and

drawings applicable to the device safety review and to verify and document that GL devices meet

the current dose requirements.

As noted in the questionnaire, since the previous review, Kentucky has completed one device

evaluation and registration for Ohmart (KY-512-D-112-S) and one device evaluation for Ronan.

Following Kentucky's initial evaluation of the Ronan device, the application package, including the

Commonwealth's review and proposed deficiency letter, was sent to the NRC Office of State

Programs as a technical assistance request (TAR). This TAR was referred to the NRC Division of

Industrial and Medical Nuclear Safety (IMNS) on April 12, 1995, and a response from IMNS was

provided to Kentucky on May 17, 1995. The comments from IMNS and Kentucky have been

provided to Ronan and a response is pending. During the Commonwealth's evaluation of the

application, the Commonwealth utilized the guidance obtained during the SS&D Workshop

sponsored by NRC in September 1995. Documents in the file confirm that the Commonwealth

followed the NRC guidance during their evaluation of the Ronan device. Also, the RCB notified

Ronan on March 15, 1995, that Condition 19 of Ronan's license would require the devices to be

manufactured in accordance with their quality control program and provided Ronan a copy of the

NRC Regulatory Guide 6.9. Ronan provided a Quality Control Manual dated September 28,

1995, to Kentucky. The review of this manual is still pending and the completed registration of the

device cannot be completed until the additional information is received from Ronan. 

The Ohmart device evaluation was completed and the registration KY-512-D-112-S was issued on

January 19, 1996. A review of the file confirms that the Commonwealth utilized the information

obtained during the SS&D Workshop and followed the recommended guidance. The registration

file contained all correspondence, photographs, engineering drawings, radiation profiles, and

results of tests conducted by the applicant.

4.2.2 Technical Staffing and Training

Kentucky has two persons that have the experience and training needed to perform SS&D

reviews. Both the RCB Manager and the RMS Supervisor attended the September 1995 SS&D

Workshop for training on device reviews and registrations. During interviews, the RCB Manager

stated that based upon the Commonwealth's successful review of the Ronan device, which was

subsequently reviewed by IMNS under a TAR, and the training received at the workshop, he was

confident that Kentucky could perform the needed device reviews. The RCB Manager said that if

engineering expertise beyond the Commonwealth's capability was needed, that he had an informal

arrangement with the School of Chemical Engineering, University of Kentucky, to assist the

program with engineering evaluations of sealed sources and/or devices evaluations as needed. 

The RCB Manager also stated that he had plans to train additional backup personnel for SS&D

reviews, and when this occurs, he would consider sending a person to train at NRC if the option is

still available.

The RCB Manager has a Ph.D. in Biochemistry and has teaching experience. He managed the

Radiochemistry Laboratory for the Commonwealth for several years. He is also the

Commonwealth's consultant on all radiation matters. The RMS Supervisor conducted the current
Kentucky Draft IMPEP Report Page 15

 

1Now U S Ecology

device evaluations. She is an experienced health physicist who has served several years as

supervisor of the materials section and is responsible for evaluating all major or complex license

applications. Based upon the previous device reviews performed by the Commonwealth and

interviews with the staff, the review team believes that the Commonwealth's SS&D reviewers are

qualified to understand and interpret appropriate prototype tests which ensure the integrity of the

products under normal, and likely accidental conditions of use; understand and interpret test

results; read and understand blueprints and drawings; understand how the devices work and how

the safety features operate; understand and apply the appropriate regulations; understand the

conditions of use; and understand external dose rates, source activities and nuclide chemical

form.

Based upon the additional technical training received by the device reviewers during the SS&D

workshop, the experience in performing complete device reviews since the previous review, a

reduction in the projected device workload (Ohmart moving to Ohio), and our interviews with the

device reviewers, the review team found that the Kentucky staff has adequate qualifications and

training for the current and anticipated device reviews. 

4.2.3 Evaluation of Defects and Incidents Regarding SS&Ds

The review team determined that there were no incidents or defects regarding SS&Ds as

determined from the evaluation of the incident files and responses to the questionnaire from

Kentucky. 

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

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

found satisfactory. 

4.3 Low-Level Radioactive Waste (LLRW) Disposal Program

Kentucky has no separate low-level radioactive waste (LLRW) disposal program. The

Commonwealth and RCB treat the closed radioactive waste burial site at Maxey Flats in the same

manner as any other complex specific licensee with all program requirements incorporated as

license conditions. The statutes and regulations, including Kentucky’s equivalent to 10 CFR 61,

apply to the site license. 

4.3.1 Introduction

In 1962, the Commonwealth of Kentucky became an Agreement State, and that same year, the

Kentucky General Assembly also passed legislation to enable the Commonwealth to purchase

lands for the disposal of radioactive waste, to be owned and controlled in perpetuity by the

Commonwealth. The Agreement vested in the Commonwealth the authority to license the

disposal of LLRW. Also in 1962, a commercial enterprise, Nuclear Engineering Company

(NECO)1, purchased 280 acres of land in Fleming County in an area known as Maxey Flats. 
Kentucky Draft IMPEP Report Page 16

NECO submitted an application to the Commonwealth and was issued a license to dispose of

radioactive waste at the Maxey Flats Disposal Site (MFDS) in January 1963. A condition of the

license was that title to the land be given to the Commonwealth and leased back to NECO for 25

years with conditions in the lease providing for a perpetual care fund. From May 1963 through

December 1977, NECO disposed of 4,750,000 cubic feet of LLRW at the site.

In 1977, due to water management problems, the Commonwealth ordered NECO to cease receipt

and burial of radioactive waste. Throughout the years since disposal activities ceased in 1977,

various stabilization and maintenance activities have been conducted in an effort to control

excessive water accumulation. On October 7, 1991, Kentucky was notified by the U.S,

Environmental Protection Agency (EPA) that the site has been approved for remedial action under

the Comprehensive Environmental Response, Compensation and Liability Act (Superfund). 

In a 1978 financial agreement with NECO, Kentucky purchased NECO’s license rights and other

assets and assumed responsibility for site-related liabilities, thus making the Commonwealth both

licensee and regulator, a situation that remains today. Responsibility for the MFDS operations

rests within the Natural Resources and Environmental Protection Cabinet (NREPC) while

regulatory responsibility for the project's radiation safety program rests with CHS. The review

team concluded that this separation of operational and regulatory functions is adequate to avoid

conflicts of interest. 

The license is still active and authorizes care, maintenance, stabilization and remedial operations

as well as onsite and offsite environmental monitoring. The closure plan and consent decree

statement of work developed jointly by the Commonwealth, the EPA, and the Potentially

Responsible Parties (PRP) were added to the license as Amendment 36 issued October 12, 1995. 

The site is now on standby awaiting a Federal court order for the use of Superfund monies. The

approval is expected to occur some time in 1996. 

Meanwhile, maintenance continues, including the placement of a new 10 year plastic cover over

the trenches to further inhibit infiltration of water. Environmental monitoring continues on a

monthly or more frequent basis by both CHS and NREPC. The sampling includes air, water, soil,

vegetation, and direct radiation. Annual monitoring reports are published by the Commonwealth. 

The latest report concluded that there is no significant off-site migration of radioactive

contaminants under present conditions. When the Superfund remediation project begins, it will

operate in compliance with the license. CHS will continue to conduct inspections to ensure that

the contractor meets the standards set in Kentucky equivalent regulations to 10 CFR Parts 19, 20,

30, 61, and other applicable Kentucky regulations.

4.3.2 Status of Low-Level Radioactive Waste Disposal Inspection

The Commonwealth's frequency of inspection for the MFDS is one year, the same as in IMC 2800

and IMC 2401. However, by a note to file, the inspection frequency has temporarily been

extended to two years. This decision was based on the lack of activity at the site and the fact that

the few previous items of non-compliance were administrative in nature and had been corrected. 

However, the last full inspection was conducted in April 1993, making the inspection overdue at
Kentucky Draft IMPEP Report Page 17

the time of the review. The Commonwealth has committed to conducting an inspection of this

license within 30 days of the IMPEP review. 

As noted previously, the site is awaiting Superfund remedial work, and there has been very little

work going on at the site except for radiation monitoring. Also, monthly site visits are being

conducted by the Radiation Environmental Laboratory staff and the RCB Manager. This monthly

environmental monitoring protects the worker, as well as the public, from the radioactive material

located at MFDS and can be considered partial inspections. The team agrees with the decision to

defer the inspection interval to two years. However, the team agrees that the Commonwealth

should conduct the routine inspection at the earliest possible time. 

In addition, CWS radiation laboratory staff is on-site at least monthly, and the RCB Manager visits

the site frequently. When the activities increase under Superfund clean-up, the Commonwealth

intends to resume inspections on an annual basis. Review of the files showed that past

inspections had been conducted as scheduled and the results transmitted to NREPC within 30

days. All previous inspection reports are on file, but were not reviewed by the team because they

were not performed during the review period.

4.3.3 Technical Staffing and Training

The RCB Manager and RMS Supervisor, whose training and experience are discussed in Section

3.2, also serve as the LLRW site reviewers and inspectors. They have many years’ experience

regulating the MFDS project. The review team believes they are both fully qualified for their

responsibilities. 

In addition, the CHS Radiation and Environmental Monitoring Laboratory (REML) provides

approximately 3.5 FTEs dedicated to MFDS environmental monitoring. Although not directly part

of the RMS, this lab is also directed by the RCB Manager. The REML technical staff are all

professional chemists who have been trained in radiochemistry, environmental sampling, and

analysis and evaluation. The review team examined the training records and educational

background of the five laboratory staff members, and found that the qualifications of the technical

staff are commensurate with expertise identified as necessary to regulate a low-level radioactive

waste disposal facility. Management has developed and implemented a training program for staff. 

Staff trends that could have an adverse impact on the quality of the program are tracked, analyzed

and addressed.

4.3.4 Technical Quality of Licensing Actions

The MFDS license was renewed in its entirety during the review period. In examining the license

and background information in the file, the review team found that the license:

C meets standard licensing practices (activity, location, RSO, regulations, tie-downs,

etc.);

C ties the license to Kentucky regulations, including the equivalent Part 61; 
Kentucky Draft IMPEP Report Page 18

C limits activity to remedial and monitoring activities;

C precludes receipt or disposal of waste;

C limits possession to existing material and addresses possible form changes due to

remediation efforts; and

C requires qualified personnel to be designated in writing before working on site.

The tiedown condition properly cites the renewal application; the radiological protection program

revised to meet the new Part 20; radiological procedures, Superfund consent decree Statement of

Work; and procurement, receipt, possession and use of laboratory standard sources for onsite

use. The license file was complete with all background documents.

Applicable guidance documents such as the NUREGs that support 10 CFR 61 are available and

used as needed. Review of certain technical and administrative aspects of the MFDS license and

background materials indicated to the team that the review was generally thorough, complete,

consistent, and of acceptable technical quality. Health and safety issues, as well as

environmental issues, are properly addressed. No potentially significant health and safety issues

can be linked to licensing practices.

4.3.5 Technical Quality of Inspections

Inspection and enforcement is handled in the same manner as any Commonwealth licensee. In

addition to the laboratory equipment, the RCB possesses a good mix of calibrated instrumentation

used at the site, including micro R meters. 

The review team examined the environmental monitoring log, and from checking a random

sampling of approximately ten of the reports concluded the Commonwealth is gathering sufficient

data necessary to evaluate the status of the possible contaminant migration.

Although no full, routine inspection occurred in the review period, past inspection reports show

that past inspections adequately covered the scope, completeness, and technical accuracy

necessary to determine compliance with regulations, license conditions, and available guidance.

4.3.6 Response to Incidents and Allegations

There were no incidents or allegations pertaining to the Commonwealth’s low-level radioactive

waste program activities during the review period. The Commonwealth explained to the review

team that incidents and allegations relating to the MFDS would be handled in the same manner as

those pertaining to any materials licensee.

Based on the IMPEP evaluation criteria for the above five performance areas, the review team

recommends that Kentucky's performance with respect to the indicator, Low-level Radioactive

Waste Disposal Program, be found satisfactory.

5.0 SUMMARY
Kentucky Draft IMPEP Report Page 19

As noted in Sections 3 and 4 above, the review team found the Commonwealth's performance with

respect to each of the performance indicators to be satisfactory. The MRB concurred in the

team's individual and overall recommendations and found that the Kentucky program was

adequate to protect public health and safety and was compatible with NRC's regulatory program.

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

action by the Commonwealth. 

1. The review team suggests that the Commonwealth consider obtaining necessary statutory

authority to apply civil penalties as an additional enforcement option to supplement their

enforcement efforts. (Section 3.4)

2. The review team recommends that the Commonwealth maintain its policy of annual

supervisory accompaniments of all inspectors. (Section 3.4)

3. The review team recommends that the Commonwealth determine the specific isotope in all

incidents rather than assuming the source to be NARM. (Section 3.5)

4. The review team recommends that the RCB continue with their plan to reassess all

previously issued SS&D sheets, under their regulatory jurisdiction to assure that the files

contain all current background information and drawings applicable to the device safety

review and to verify and document that GL devices meet the current dose requirements. 

This is a recommendation from the 1995 review visit. (Section 4.2)
LIST OF APPENDICES AND ATTACHMENTS

Appendix A IMPEP Review Team Members

Appendix B Kentucky Radiation Control Branch Organization Chart

Appendix C Kentucky's Questionnaire Response

Appendix D License File Reviews

Appendix E Inspection File Reviews

Appendix F Incident File Reviews

Attachment 1 Kentucky's Response to Review Findings
APPENDIX A

IMPEP REVIEW TEAM MEMBERS 

Name Area of Responsibility

Jack Hornor, RIV, WCFO Team Leader

Technical Staffing and Training

Legislation and Regulations

Low Level Radioactive Waste Program 

Richard Woodruff, RII Status of Materials Inspection Program

Technical Quality of Inspections

Sealed Source and Device Evaluation Program

David Collins, RII Technical Quality of Licensing Actions

James McNees, Alabama Response to Incidents and Allegations
APPENDIX B

KENTUCKY RADIATION CONTROL PROGRAM

ORGANIZATION CHART