DATED: DECEMBER 2, 1997 SIGNED BY: HUGH L. THOMPSON, JR.

Ms. Yvonne Sylva, Administrator

State Health Division

Nevada Department of Human Resources

505 East King Street, Room 201

Carson City, NV 89701-4797

Dear Ms. Sylva:

On November 18, 1997 the Management Review Board (MRB) met to consider the

proposed final Integrated Materials Performance Evaluation Program (IMPEP)

report on the Nevada Agreement State Program. The MRB found the Nevada

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

program. 

Section 5.0, page 19, of the enclosed final report presents the IMPEP team's

suggestions and recommendations. We request your evaluation and response to

recommendations 1, 2, and 4 within 30 days from receipt of this letter.

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

scheduled in four years, unless program concerns develop that require an

earlier evaluation.

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

the review and your support of the Radiation Control Program. I look forward

to our agencies continuing to work cooperatively in the future.

Sincerely, /RA/

Hugh L. Thompson, Jr.

Deputy Executive Director

 for Regulatory Programs

Enclosure:

As stated

cc: Sharon Ezell, Deputy Administrator

State Health Division

Stanley R. Marshall, Supervisor

Radiological Health Section

Robert R. Loux, Director

Nuclear Waste Project Office
Ms. Yvonne Sylva, Administrator December 2, 1997

State Health Division

Nevada Department of Human Resources

505 East King Street, Room 201

Carson City, NV 89701-4797

Dear Ms. Sylva:

On November 18, 1997 the Management Review Board (MRB) met to consider the

proposed final Integrated Materials Performance Evaluation Program (IMPEP)

report on the Nevada Agreement State Program. The MRB found the Nevada

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

program. 

Section 5.0, page 19, of the enclosed final report presents the IMPEP team's

suggestions and recommendations. We request your evaluation and response to

recommendations 1, 2, and 4 within 30 days from receipt of this letter.

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

scheduled in four years, unless program concerns develop that require an

earlier evaluation.

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

the review and your support of the Radiation Control Program. I look forward

to our agencies continuing to work cooperatively in the future.

Sincerely,

Hugh L. Thompson, Jr.

Deputy Executive Director

 for Regulatory Programs

Enclosure:

As stated

cc: Sharon Ezell, Deputy Administrator bcc: Chairman Jackson

State Health Division Commissioner Dicus

Commissioner Diaz

Stanley R. Marshall, Supervisor Commissioner

McGaffigan

Radiological Health Section

Robert R. Loux, Director

Nuclear Waste Project Office

Distribution:

DIR RF KSchneider DCD (SP01) KCyr, OGC

SDroggitis GDeegan, NMSS PDR (YES%) CPaperiello, NMSS

JHornor, RIV SMoore, NMSS KSchneider TMartin, AEOD

CHackney, RIV FCameron, OGC DBunn, CA SCollins, IL

HNewsome, OGC LRakovan Nevada File

DOCUMENT NAME: G:\KXS\97FINLTR.NV; G:\RLB\NVIMP97.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 OSP OSP:DD OSP:D DEDR

NAME RBlanton:gd/nb PHLohaus RLBangart HLThompson

DATE 11/20/97 * 11/20/97 * 12/ /97 11/ /97

OSP FILE CODE: SP-AG-17
INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM

REVIEW OF NEVADA AGREEMENT STATE PROGRAM

August 25 - 29, 1997

FINAL REPORT

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

1.0 INTRODUCTION

This report presents the results of the review of the Nevada radiation control

program. The review was conducted during the period August 25-29, 1997, 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

"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 March 6, 1993 to

August 24, 1997 were discussed with Nevada management on August 29, 1997.

A draft of this report was issued to Nevada for factual comment on September

30, 1997. The State of Nevada responded in a letter dated October 27, 1997

(Attachment 1). The State's factual comments were incorporated in the final

report. The Management Review Board (MRB) met on November 18, 1997 to

consider the proposed final report. The MRB found the Nevada radiation

control program was adequate to protect public health and safety and

compatible with NRC's program.

The Nevada Agreement State program is administered by the Radiological Health

Section (RHS) of the Bureau of Health Protection Services (BHPS), State Health

Division, Nevada Department of Human Resources. Nevada’s statute designates

the State Health Division as the radiation control agency. Organization

charts for the Division, the BHPS, and RHS are included as Appendix B.

At the time of the review, the Nevada program regulated 196 specific licenses,

including a major decontamination service, broad academic programs, medical

programs, radiopharmacies, radiographers, a small self-contained irradiator,

and a non-operating low-level radioactive waste burial site. The program grew

during the review period at a rate of about 6 percent per year, as evidenced

by the increase in the number of licenses. 

The review focused on the material’s program as it is carried out under the

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

the NRC and the State of Nevada.

In preparation for the review, a questionnaire addressing the common and noncommon indicators was sent to the State on March 28, 1997. The State provided

a response to the questionnaire on July 30, 1997. During the review,

discussions with the State staff resulted in the responses being further

developed. A copy of the final response is included in Appendix C to this

report. 

The review team's general approach for conduct of this review consisted of: 

(1) examination of Nevada's response to the questionnaire; (2) review of

applicable Nevada statutes and regulations; (3) analysis of quantitative

information from the radiation control program licensing and inspection data

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

field accompaniments of two Nevada 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 non-common indicator and made a preliminary assessment of the

radiation control program's performance.
Nevada Final Report Page 2

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 non-common indicators, and Section 5

summarizes the review team's findings and recommendations. Suggestions made

by the review team are comments that the review team believes could enhance

the State’s program. The State is requested to consider suggestions, but no

response is requested. Recommendations 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 March 5, 1993, eight

comments and recommendations were made in five program indicators. Because of

the significance of some of the review findings, a follow-up review was

conducted in April 1994 and the results transmitted to Ms. Yvonne Sylva,

Administrator, Nevada State Health Division, on September 21, 1994. The

follow-up review resulted in the closure of six of the eight recommendations

and the addition of two new recommendations. The team’s review of the current

status of these recommendations is as follows:

(1) Although the State's written enforcement procedures prescribed

escalated actions in general terms, they did not directly address

serious first-time violations and lacked specific action levels

for violations of varying degrees of severity. The NRC

recommended that the enforcement procedures be strengthened by

requiring escalated enforcement if the licensee has one or more

serious violations directly relating to occupational or public

health or safety, and by adding specific actions to be taken for

violations of various levels of severity.

Current Status: The enforcement procedures were revised and

further strengthened by new procedures dated August 7, 1997. The

new procedures address the problem of a single, serious violation. 

Escalated enforcement actions prescribed by various severity

levels include management-level meetings with the licensee,

follow-up inspections, license restrictions, and temporary

suspension or revocation of the license. This recommendation is

closed.

(2) During the March 1993 review, three inspections were identified in

which appropriate escalated enforcement actions were not taken in

response to numerous violations, including several repeats. At

the time of the April 1994 follow-up review, the State had

verified that the two licensees had taken corrective actions;

however, the third case remained open.

Current Status: The State followed through with the enforcement

on this medical private practice licensee by terminating the

license and replacing it with a more restrictive medical facility

license with requirements for a quality management plan program, a

radiation safety committee with quarterly meetings, and an outside

expert to serve as radiation safety officer. This recommendation

is closed.

(3) Nevada hospitals are required by regulation to provide dose

calculations when reporting misadministration to the State so that

each event may be analyzed and reported as necessary. However, in
Nevada Final Report Page 3

three misadministration cases calculations were not provided;

thus, the events could not be evaluated against the reporting

criteria. We recommended that the State's administrative

procedures be revised to improve instructions for evaluating,

following and reporting misadministration and that letters be sent

to all Nevada hospitals reminding them of the misadministration

reporting criteria, including the requirement for dose

calculation.

Current Status: The review team verified that the State revised

and improved the instructions for handling misadministration. All

medical licensees, including hospitals, were sent letters

reminding them of the reporting requirements in the regulations. 

This recommendation is closed.

(4) Several inadequacies were found in the State's system for tracking

incidents and misadministration: (a) the incident log was

incomplete; (b) some incidents shown as closed in the incident log

lacked documentation in the files justifying closure; and (c) in

some cases, copies of correspondence were found in the Las Vegas

regional Office on events handled by that office that was not in

the headquarters office files in Carson City. We recommended that

the State improve their events tracking system to ensure complete

incident logs, to ensure that all open items are properly

documented before closure and to ensure proper dissemination of

regional event correspondence to headquarters files.

Current Status: The team reviewed the incident files for the

review period and found that all incidents were included in their

tracking system, that all open items were properly documented

before closure, and that all regional office event documentation

is duplicated in headquarters files. This recommendation is

closed. 

3.0 COMMON PERFORMANCE INDICATORS

IMPEP identifies five common performance indicators to be used in reviewing

both NRC Regional and Agreement State programs. These indicators are: 

(1) Status of Materials Inspection Program; (2) Technical Staffing and

Training; (3) Technical Quality of Licensing Actions; (4) Technical Quality of

Inspections; and (5) Response to Incidents and Allegations. 

3.1 Status of Materials Inspection Program

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

frequency, overdue inspections, initial inspection of new licenses, and timely

dispatch of inspection findings to licensees. This evaluation is based on the

Nevada questionnaire responses relative to this indicator, data gathered

independently from the State's licensing and inspection data tracking system,

the examination of completed licensing and inspection casework, and interviews

with managers and staff.

The State maintains a licensee data base that can sort by a variety of data. 

During the review the team was provided various lists including: a priority

listing for all licenses, licenses due for inspection during a given period in

the future, inspections completed over a given time period, and reciprocity

licensee inspections completed for a given period. The data base does not,

however, retain historical data. As a result, the team was only able to

obtain detailed inspection statistics from the data base for the current year. 
Nevada Final Report Page 4

According to the program manager, prior year statistics could be developed

only by a manual search of the files. Biyearly statistics for budgeting

purposes are generated prior to legislative sessions, however, the program

does not retain the information in a readily available form due to infrequent

demand. Based on the inspection program performance during the past year and

the performance of the radiation control program generally during the review

period, the team did not request or conduct a manual search.

The printout of the current year inspections showed 89 completed. This

printout shows the inspection date, the date of the violation notice, the date

of the licensee's response, and the date of the State’s acknowledgment letter

or inspection closing date.

The State’s inspection frequencies were compared to IMC 2800 and verified to

be of equal, or in most cases more frequent than, IMC 2800. The State

requires more frequent inspection in some license categories as follows: 

hospitals and nuclear medicine private practice licenses are inspected on a

two-year frequency as compared to NRC three-year frequency; portable gauge

licenses are inspected at a three-year frequency as compared to NRC five-year

frequency; and teletherapy licensees are inspected on a one-year frequency as

compared to NRC's three-year frequency.

Two teletherapy license files were reviewed. One license was inspected at 1-

11⁄2 year intervals nominally; one inspection of the same license was conducted

approximately three years after the previous inspection. The State priority

was 1 for both licenses. The NRC inspection priority for a teletherapy

program is 3. The RHS Supervisor indicated that the State will consider

changing the inspection priority for teletherapy licenses to a 3.

The radioactive material’s low-level waste (RAM/LLW) program manager provided

the following information on reciprocity, which is maintained separately from

the licensee database. The State issued 187 reciprocity authorizations to 23

out-of-state industrial radiography licensees for the period March 3, 1993,

through June 9, 1997. During that period, six inspections were completed and

one was attempted. All six completed inspections were of radiography

licensees operating in the Las Vegas or Reno/Sparks areas. One licensee from

Utah was granted authorization to enter the State 68 times, however, it was

not inspected during the period because of the difficulty of travel to the

remote areas of the State in which the licensee was working. 

During the last 14 months, 18 radiography licensees were granted reciprocity. 

Ten conducted operations in urban areas and eight in rural areas of the State. 

There were four inspections of the licensees who operated in urban areas of

the State and none of the licensees who operated in rural areas of the State.

The review team finds that the State has not met the frequency of IMC 1220 for

the inspection of reciprocity licensees. The review team recommends that the

State inspect a higher percentage of reciprocity licensees, including high

priority industrial radiography licensees operating in rural areas.

New licenses are usually inspected six months after they are issued, provided

radioactive material has been received by the licensee. The State telephones

the licensee to determine if material has been received. If it has not, they

defer the inspection until material has been received. Only one Nevada

licensee experienced a delay of greater than one year in receiving material. 

This licensee was inspected within one year after the license was issued, but

before radioactive material was received, which is sooner than required by the

State's procedure.
Nevada Final Report Page 5

The University of Nevada, Reno, was the only licensee identified by the team

as overdue for inspection by the program's standards. Review of the file

indicated that the last complete inspection was in September 1991. The

University is an Academic Type B Broad licensee, assigned inspection priority

2, and it should have been inspected no later than April 1994. The State made

a number of partial inspections at the University since 1991, but none of

these inspections were brought to closure, or combined to form a complete

inspection by State standards.

A review of the inspections completed printout showed that the State has

inspected other licenses within their assigned frequency. The team finds that

only one license was overdue for inspection during the review period. Overdue

inspections thus do not exceed the evaluation criteria.

The State, by policy, does not extend the inspection interval for good

licensee performance. Licensees may be inspected at more frequent intervals

as the result of escalated enforcement action. Inspection intervals are

returned to normal after the licensee shows improvement.

In 4 of the 26 files evaluated, a letter to the licensee informing of

violations was mailed more than 30 days following the inspection. In one

case, the letter was mailed 70 days after the inspection, the other three

letters were mailed between 30 and 60 days after the inspection. Licensees

are usually given 20 days to respond, and if their response is satisfactory,

an acknowledgment letter is sent by the State and the inspection is closed.

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

Nevada's performance with respect to the indicator, Status of the Materials

Inspection Program, be found satisfactory.

3.2 Technical Staffing and Training

Issues central to the evaluation of this indicator include the radioactive

materials program staffing level, technical qualifications of the staff,

training and staff turnover. To evaluate these issues, the review team

examined the State's questionnaire responses relative to this indicator,

interviewed program management and staff, and considered any possible workload

backlogs. 

The RHS organization chart shows that the section has a total of 14 positions,

including the secretarial positions and the Las Vegas Regional Office. The

Radioactive Materials/Low-Level Radioactive Waste (RAM/LLW) program manager

and the Mammography/X-ray program manager in Carson City are classified as

Radiological Staff Specialist, while the Las Vegas office manager is

classified as a Supervising Radiation Physicist. These positions report to

the RHS Supervisor. The five technical staff members are classified as

Radiation Control Specialists.

Four of the technical staff members are cross-trained between the x-ray and

RAM/LLW programs. All technical staff members participate in event response

activities. The RAM/LLW Radiological Staff Specialist and one Radiation

Control Specialist in Las Vegas are primarily devoted to license reviews and

inspection of radioactive material licensees, including the low-level waste

disposal site and licensees authorized to possess and use materials not

subject to the Atomic Energy Act. The remaining technical staff members are

assigned primarily to other programs, and devote less than 50 percent of their

time each to the agreement program. The distribution of effort results in

2.95 technical staff FTE dedicated to the RAM/LLW program. The RHS also has

3.5 FTE of secretarial staff. The FTE distribution between licensing and

inspection effort appears balanced, as evidenced by the lack of significant
Nevada Final Report Page 6

backlogs. At the time of the review, there were no vacant positions. The

team notes that the RHS technical staff has been stable during the review

period, with only one departure (due to retirement) and two new hires. Based

on the program’s lack of significant backlogs, the staffing level is

sufficient to assure public health and safety.

The review team found that the technical staff positions require a bachelor’s

degree in the sciences, or an equivalent combination of training and

experience. New staff members are assigned basic responsibilities until the

training and experience necessary to handle more advanced responsibilities are

obtained. They are provided training in the core NRC courses. They are also

assigned to work with senior staff members to gain experience. Progression

through the training and experience warrants their assignment to more complex

responsibilities, however, they must demonstrate satisfactory performance in a

formal assessment prior to being authorized to conduct independent inspections

or license reviews. This general procedure is not, however, delineated in

written form. The RHS Supervisor does develop an individual training and

qualification plan, usually in memo form, for each new staff member. The

individual plan considers the past training and experience of the new staff

member, and the performance requirements of the specific position. Senior

staff members have completed their training and qualification plans.

The two new staff members hired during the review period hold associate

degrees and have considerable experience in a radiation field. One staff

member has 14 years experience in a non-Agreement State radiation control

program, including nine years as the program director; the other has 15 years

experience in medical x-ray. The team finds that the qualifications of

the new hires are adequate. The team also finds that the lack of a written

general training and qualification procedure has not adversely affected the

development of the new staff members during the review period. The review

team recommends that the general training and qualification procedure be

adopted in writing. During the onsite review, the team suggested that the

State wait until the NRC-OAS joint working group on training issues their

final recommendations. The working group recommendations should be considered

when developing the written plan. It was noted at the MRB meeting that the

working group report was issued October, 1997 and was provided to all States

at the October 1977 Agreement State Meeting.

The RHS, with the support of the BHPS and the State Health Division, has

received for the first time a budgetary allotment for training. The State

plans to use this funding to complete the training of the new staff members,

and to provide continuing training for experienced staff members.

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

recommends that Nevada's performance with respect to this indicator, Technical

Staffing and Training, be found satisfactory.

3.3 Technical Quality of Licensing Actions

The review team examined completed licensing casework and interviewed the

reviewers for 24 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 accuracy, appropriateness of the license and of its

conditions and tie-down conditions, and overall technical quality. 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
Nevada Final Report Page 7

review as indicated, and proper signature authorities. The files were checked

for retention of necessary documents and supporting data.

The licensing casework was selected to provide a representative sample of

licensing actions which had been completed in the review period and to include

work by all reviewers. The cross-section sampling included all of the State's

major licenses as defined by the State in the questionnaire and included the

following types: broad academic; decontamination services; in vitro

laboratory; industrial radiography; small irradiator; medical (private

practice, teletherapy, and high dose remote afterloader); nuclear pharmacy;

well logging; ordnance testing; and low-level radioactive waste disposal. 

Licensing actions included 10 new licenses, 4 renewals, 5 amendments, and 5

terminations. A list of these licenses with case-specific comments can be

found in Appendix D.

The review team found that the quality of the State's licensing actions is

excellent. No discrepancies were found in the 24 files reviewed. The

licensing actions were also timely, with uncomplicated actions completed

within 60 days, including the exchange of correspondence. Unusual or complex

license actions required longer completion times.

The State’s license termination procedures are based on the NRC’s Site

Decommissioning Management Plan (SDMP) cleanup criteria, the tables in NRC

Regulatory Guide 1.86 on acceptable surface contamination levels and other

guidance such as NUREG/CR-5849 on Conducting Radiological Surveys in Support

of License Termination and NRC PGD FC 83-23, “Termination of Byproduct,

Source, and SNM Material Licensees.” One major facility was decommissioned

and the license terminated during the review period when Aerojet-General

closed the ordnance testing site at Nellis Air Force Base. In reviewing the

casework, the team found that the State had required an extensive

decommissioning plan and had carefully monitored the work performed by the

licensee and the contractor. All records of transfer of material were on

file, as well as the State’s confirmatory measurements taken during several

on-site inspections during the decommissioning activities.

From discussions with the reviewers and from casework reviews, the team found

that the State makes pre-licensing visits for complex licensing actions. It

was also noted that complex new licenses or renewals are personally delivered

so that licensees have the opportunity to discuss the license and their

obligations with a State representative.

Licenses are issued for five years and State policy requires a complete new

application each time the license is renewed. The team noted during the

evaluation of the casework that supporting documentation for new and renewed

licenses was current and complete. It was noted that every new or renewed

license is tied through license condition to an attached cover letter which

clearly explains the licensee’s responsibilities when the licensee receives

the license. The MRB noted that this cover letter is a good practice.

The review team found that the State uses the latest NRC standard license

conditions as the basis for their own standard conditions. The review team

also noted that the reviewers use licensing checklists based on the NRC's

current checklists. The State has copies of the current licensing guidance,

including NRC Regulatory Guides, NUREGS, and information notices, supplemented

with other professionally recognized health physics reference documents. The

team noted from reviewing the licensing checklists that the licensee's

compliance history is reviewed before license amendments or renewals are

approved.
Nevada Final Report Page 8

The team found that the deficiency letters, cover letters, and other types of

licensing correspondence were complete and well-written with proper regulatory

language and were issued promptly. 

All staff, including those in the Las Vegas office have licensing

responsibilities. After the license is written, the license and copies of the

application and all background documents are forwarded to the lead reviewer in

Carson City for peer and supervisory review. Major actions are also reviewed

by the Supervising Radiation Physicist in the Las Vegas office. After the

peer and supervisory reviews, the license is again reviewed and signed by the

RHS Supervisor. In his absence, the lead reviewer has signature authority.

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

Nevada's 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

inspection field notes and interviewed inspectors for 26 materials inspections

conducted during the review period. The casework included all six of the

State's materials license inspectors, and covered inspections of various types

including radiography, medical, academic, portable gauge, nuclear pharmacy,

and teletherapy. Appendix E lists the inspection files reviewed in depth with

case-specific comments. During the week of August 11-18, 1997, a review team

member performed accompaniments of two State inspectors on separate

inspections of licensed facilities. 

The State’s inspection forms are tailored to the type of license inspected. 

The forms were complete except for a section to remind the inspector to review

previous incidents by the licensee. The forms contain questionnaires for use

by the inspector to test the knowledge and understanding of the users. The

questionnaires assure that the inspector asks questions appropriate to the

type of licensee. The reports evaluated demonstrated that the inspectors

complete the inspection forms. The team finds that the inspectors followed

established State inspection procedures.

Of the 26 inspection reports evaluated, only four inspections were announced. 

The State's policy is to count any inspection in which the licensee was given

less than 24 hours notice, as an unannounced inspection. The State notes that

some licensees do not perform licensed operations daily, and believes that it

is a more efficient use of inspection effort to assure that licensed

operations will be in progress during an inspection. The State believes that

significant problems in a licensed program would be difficult to conceal from

inspectors when the licensee is given less than 24 hours notice of an

inspection. Although this practice differs from NRC guidance, it is a

reasonable approach. The review team found this policy acceptable.

Inspection reports were very high quality and the files were complete with all

documents including letters, telephone call logs, license documents and

amendment requests. Each report has the signature of the Radiological Staff

Specialist or the Supervising Radiation Physicist indicating it was reviewed,

and all correspondence is signed by the RHS Supervisor.

When violations are uncovered during an inspection, the inspector drafts a

violation notice for the RHS Supervisor's signature. A standard letter,

addressed to the licensee with the violation notice appended, is mailed to the

licensee. The violation notice may also identify items of concern which are

not violations (but for which a response from the licensee is expected), or

contain recommendations, (for which a response is not expected).
Nevada Final Report Page 9

Depending of the nature of the violations, the licensee's response, and the

inspector's recommendation, the State may take additional measures to bring

the licensee into compliance. For serious or repeated violations, a meeting

with licensee management may be scheduled in the State office. For less

serious violations, a repeat inspection at a reduced interval may be

scheduled. If these methods fail, the State enforcement policy provides for

an administrative hearing to revoke the license. There were no administrative

hearings during the review period. The RCP does not have authority to levy

and collect civil penalties (administrative fines) for violations of the

radiation control regulations. Monetary penalties must be collected through

action of the civil court.

Enforcement letters are written in appropriate regulatory language and are

dispatched in a timely manner. The date the letter is sent is entered into

the data base so that response due dates can be easily tracked.

If no violations are found during an inspection, the inspection is closed at

the exit and the State does not notify the licensee of the findings in

writing. The review team suggests that the State provide a letter, or a short

form similar to the NRC Form 591, to the licensee indicating that no

violations were found as the result of the inspection, when appropriate.

According to program staff, there is an ample supply of radiation survey

instruments at both the Carson City and Las Vegas offices. At Carson City

there are 3 Victoreen 450P ion chambers, 4 Ludlum micro/R meters, 3 Ludlum

model 12 or 14c meters with 6 pancake probes for contamination surveys, 2

Eberline emergency kits with alpha, pancake, and end window probes. In

addition, each office has an Apter Odyssey 6 portable multi-channel analyzer

for isotope identification.

All survey meters are calibrated annually and are rotated so that they are

calibrated at least at the frequency of the licensee inspected. The meters

are calibrated by a private firm that uses NIST traceable standards.

All six inspectors have had supervisor accompaniments at least annually. The

Compliance Inspection Fieldwork Inspector Evaluation form is maintained in the

inspector’s file. 

A member of the review team conducted accompaniments of two Nevada inspectors

prior to the team review. On August 13, 1997, one inspector was accompanied

during an inspection of a portable gauge licensee in Carson City. The second

inspector was accompanied on August 18, 1997, during an inspection of a

portable gauge licensee in Reno. Both inspectors have extensive experience in

x-ray programs, and at the time of the review, were being trained in

inspecting radioactive materials licensees. Both inspectors had qualified to

independently perform inspections of the gauge licensees, but had not yet

qualified to inspect more complex licensees. 

Both inspectors prepared well and performed thorough inspections of the

licensees’ radiation safety programs. The inspectors demonstrated appropriate

inspection techniques including observations, interviews, review of records,

and knowledge of regulations, although one inspector was reminded to cite the

regulation or license condition for each item of non-compliance. The

technical performance of the inspectors was satisfactory, and their

inspections were adequate to assess the radiological health and safety program

of the licensee. The results of the accompaniments were discussed with the

inspectors and their supervisors. The accompaniments are identified in

Appendix E.
Nevada Final Report Page 10

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

Nevada'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 State's actions in responding to

incidents and allegations, the review team examined the State's response to

the questionnaire relative to this indicator and reviewed the incidents

reported for Nevada in the "Nuclear Material Events Database (NMED)" against

those contained in the Nevada casework and license files, and supporting

documentation, as appropriate for ten incidents. The team reviewed the

State's response to six allegations, of which NRC referred two allegations. A

list of the incident casework with comments is included in Appendix F.

State procedures require an on-site investigation for significant incidents. 

The procedures do not distinguish between incidents and allegations. The RHS

Supervisor coordinates with the Las Vegas field office Supervising Radiation

Physicist on incident response. All incident reports and summaries are

reviewed by the RHS Supervisor for close-out. 

The review team found that, with the exception of reporting incidents to NRC

the State responses were within the performance criteria. Notification to the

NRC was provided in 1993 through the first half of 1995, for incidents that

require reporting under State regulations. Although the State incident report

log contains an entry space for recording notification to NRC, notifications

were not made for incidents occurring in the second half of 1995 through the

end of the review period. The reporting of incident information was discussed

with the program management, who indicated that a combination of problems with

the NMED computer software and altered priorities related to the office

relocation resulted in a decision to delay the reporting to NRC of events the

State considered to be of low significance. The State did not consider any of

the events that occurred during this period to be of high significance,

however, the team reviewed reports of one damaged and five lost or stolen

moisture/density gauges. The team recommended that the State review the

incident files back to the last event reported to NRC in 1995, and submit

reports to NMED as appropriate. At the MRB meeting, the State commented that

they had completed their review and had submitted the appropriate reports. No

additional action is necessary and the State does not need to address this

recommendation further.

Responses were prompt and well-coordinated, and the level of effort was

commensurate with health and safety significance. Inspectors were dispatched

for on-site inspections when appropriate. In general, the State took suitable

corrective and enforcement actions and followed the progress of the inspection

until close out. 

The team reviewed the files of six allegations. Two of the allegations were

referred to the State by NRC Region IV. The records indicated a response to

the Region when requested. All six allegations were responded to promptly

with appropriate inspections, follow-up, and close-out actions. The quality

of the State’s response was adequate. Persons making allegations are advised

that their identity can be protected under State law, but the alleger must

request the identity protection in writing.

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

Nevada's performance with respect to the indicator, Response to Incidents and

Allegations, be found satisfactory.
Nevada Final Report Page 11

4.0 NON-COMMON PERFORMANCE INDICATORS

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

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. Nevada's agreement does not cover

uranium recovery, so only the first three non-common 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, the State 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 Nevada Revised Statute

Section 459. The Nevada State Health Division is designated as the State's

radiation control agency. The review team noted that the legislation had not

changed since being found adequate during the previous review, and found that

the State legislation is adequate.

4.1.2 Status and Compatibility of Regulations

The Nevada Regulations for Control of Radiation, found in Chapter 459 of the

Nevada Administrative Code (NAC), apply to all ionizing radiation, whether

emitted from radionuclides or devices. Nevada requires a license for

possession, and use, of all radioactive material including naturally occurring

materials, such as radium, and accelerator-produced radionuclides. Nevada

also requires registration of all equipment designed to produce x-rays or

other ionizing radiations.

The review team examined the procedures used in the State's regulatory process

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

regulations and participate in public hearings before the Board of Health. 

Procedures also require the proposed regulations, and proposed hearing date,

be publicized. Written response to all written public comments must be part

of the staff presentation to the Board. 

Regulations must be reviewed by the State Legislative Council Bureau before

they become final. Regulations may be submitted at any time to the Nevada

State Board of Health for adoption; however, adoption during certain periods

of the biennium requires a second adoption hearing to create permanent

regulations, making it difficult for the State to adopt all NRC amendments

within the 3-year time period during which Agreement States are generally

expected to adopt compatible rules. The team noted that while some of the

regulations adopted during the review period were adopted after the 3-year

period had expired, Nevada has other legally binding methods of applying

regulatory requirements on a temporary basis as needed.

The team evaluated Nevada’s responses to the questionnaire and reviewed the

regulations adopted by the State since the 1993 review to determine the status

of the Nevada regulations under the Commission’s new adequacy and

compatibility policy. The team found that the State addressed the following

NRC regulation amendments:

! "Quality Management Program and Misadministration," 10 CFR Part 35

amendment (56 FR 34104) which became effective on January 27, 1992. The

State adopted equivalent regulations for the quality management and

misadministration rules prior to the current NRC decision to defer
Nevada Final Report Page 12

consideration of these rules in making compatibility findings for

Agreement States. Nevada intends to revisit the matter when NRC issues

a revised Part 35 rule, compatibility designations for the new rule are

established, and an effective date for Agreement State implementation

has been set. 

! “Licensing and Radiation Safety Requirements for Irradiators,” 10 CFR

Part 36 amendment (58 FR 7715) which became effective on July 1, 1993. 

There are no current Nevada licensees that are affected by this rule. 

The State plans to apply the requirements by license condition and adopt

an equivalent rule if an application for an irradiator is received. NRC

has previously found this approach to be compatible.

! “Definition of Land Disposal and Waste Site Quality Assurance Programs,”

10 CFR Part 61 amendment (58 FR 33886) which became effective on July

22, 1993. In consideration of the closed status of the Beatty site, the

State does not plan to adopt an equivalent regulation.

! “Decommissioning Record Keeping Documentation of Restricted Areas and

Spill Sites," 10 CFR Parts 30 and 40 (58 FR 39628) that became effective

on October 25, 1993. It should be noted that this rule applies to all

licensees, rather than just those licensees required to file a

decommissioning plan. 

! "Self-Guarantee as an Additional Financial Mechanism," 10 CFR Parts 30,

40, and 70 amendments (58 FR 68726 and 59 FR 1618) that became effective

on January 28, 1994. Note, this rule is designated as a Division 2

matter of compatibility. Division 2 compatibility allows the Agreement

States flexibility to be more stringent (i.e., the State could choose

not to adopt self-guarantee as a method of financial assurance.) If a

State chooses not to adopt this regulation, the State’s regulation,

however, must contain provisions for financial assurance that include at

least a subset of those provided in NRC’s regulations; e.g., prepayment,

surety method (letter of credit or line of credit), insurance or other

guarantee method (e.g., a parent company guarantee). This rule has been

redesignated as category D under the Commission’s new adequacy and

compatibility policy. The rule affects only one Nevada licensee and is

being adopted by license condition. 

! “Uranium Mill Tailings Regulations: Conforming NRC Requirements to EPA

Standards,” 10 CFR Part 40 amendment (59 FR 36026) that became effective

on July 1, 1994. This rule is not applicable as Nevada does not

regulate section 11(e).2 material under the Agreement.

! "Timeliness in Decommissioning of Materials Facilities," 10 CFR Parts

30, 40, and 70 amendments (59 FR 36026) that became effective on August

15, 1994. It should be noted that this rule applies to all licensees,

rather than just those licensees required to file a decommissioning

plan. 

The State has expressed the intent to adopt the following regulations on or

about March 1, 1998:

! "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. 

The State will temporarily adopt the rule by license condition as

necessary.
Nevada Final Report Page 13

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

Parts 20 and 61 amendments (60 FR 15649, 60 FR 25983) that will become

effective March 1, 1998. Agreement States are expected to have an

effective rule on the same date. 

! “Frequency of Medical Examinations for Use of Respiratory Protection

Equipment,” 10 CFR Part 20 amendments (60 FR7900) that became effective

on March 13, 1995. Note, this rule is designated as a Division 2 matter

of compatibility. Division 2 compatibility allows the Agreement States

flexibility to be more stringent (i.e., the State could choose to

continue to require annual medical examinations).

Nevada has not started to address the following RULEMAKINGS, but indicated the

intent to adopt the rules prior to the due date (three years after the

effective date given):

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

(60 FR 28323) that became effective on June 30, 1995.

! "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. 

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

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

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

Part 20.35 amendment (60 FR 48623) that became effective on October 20,

1995.

! “Termination or Transfer of Licensed Activities: Record Keeping

Requirements,” 10 CFR Parts 20, 30, 40, 61, 70 (61 FR 24669) that became

effective on May 19, 1996. This requirement need not be in effect until

May 19, 1999. 

! “Resolution of Dual Regulation of Airborne Effluents of Radioactive

Materials; Clean Air Act,” 10 CFR Part 20 amendment (61 FR 65119) that

became effective January 9, 1997.

! “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 on January 13, 1997.

! “Criteria for the Release of Individuals Administered Radioactive

Material,” 10 CFR Part 20.35 amendment (62 FR 4120) that became

effective on January 29, 1997.

As noted above, the rules “Decommissioning Record Keeping Documentation of

Restricted Areas and Spill Sites," and "Timeliness in Decommissioning of

Materials Facilities," apply to all licensees, rather than only to those

licensees required to file a decommissioning plan. The State has applied the

regulatory requirements of the rules as license conditions on the one Nevada

licensee required to file a decommissioning plan, but has not addressed the

requirements for the other licensees. The inconsistency was not identified

until after the on-site review was completed and therefore was not discussed

during the exit meeting. The issue was discussed during follow-up telephone
Nevada Final Report Page 14

conversations with the State. On this basis, the team finds that the State

needs to adopt both rules, or other generic legally binding requirements, in

order to assure consistency with the compatibility designations of the new

adequacy and compatibility policy. 

The team recommends that, as provided by the implementing procedures

(“Adequacy and Compatibility of Agreement State Programs,” draft NRC

Management Directive 5.9, Handbook Part V), State regulations or other generic

legally binding requirements equivalent to the NRC rules be adopted as

expeditiously as possible but not later than September 3, 2000 (three years

after the September 3, 1997, [62 FR 46517] publication of the final policy).

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

Nevada’s performance with respect to the indicator, Legislation and

Regulations, be found satisfactory. 

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

At the time of the review, Nevada had no sealed source or device manufacturers

nor were any applicants anticipated in the near future. The State, however,

does not wish to relinquish the authority to regulate SS&D manufacturers in

the future. The RHS Supervisor explained the State’s provisionary plan as

follows:

Upon receipt of an application for a sealed source or device

review by any licensee or after State licensure of a manufacturing

company in Nevada, BHPS will begin to take steps to develop

proposed regulations as appropriate, acquire additional staff

and/or train existing staff and develop procedures to conduct

timely sealed source/device review in accordance with NRC

criteria. Considerations to hire new staff or train existing BHPS

staff will address all technical disciplines such as mechanical

and/or civil engineering expertise, radiation physics, etc., as

necessary for this program.

Options for immediate implementation prior to full review program

development include: (a) informal or contractual arrangements

with other Agreement State(s) to conduct reviews or assist Nevada

as they develop various components of the minimum program; (b)

contract with an outside consultant to conduct the review; or (c)

contract with NRC to conduct the review.

Funding for any of these options would be from revenue collected

from the applicant.

The review team finds this approach acceptable and recommends that Nevada’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

The State has no separate LLRW program, but instead regulates the LLRW license

in the same manner as any other complex specific licensee. In the process of

evaluating this performance indicator, the review team studied the State's

responses to the questionnaire, evaluated the qualifications of the technical

staff, reviewed the State's written procedures and plans, examined parts of

the site closure plan and associated documents, reviewed surveillance and

inspection reports, and interviewed the principal staff and managers assigned

to the LLRW project.
Nevada Final Report Page 15

The US Ecology LLRW site, located 11 miles south of Beatty, stopped receiving

LLRW on January 1, 1993. This decision was formalized by a settlement

agreement signed by the Governor on September 24, 1993. The site license

expired December 31, 1992, but will remain in effect until the licensee

completes their obligations specified in their license and regulations, in the

“Beatty, Nevada, Low-Level Radioactive Waste Disposal Facility – Stabilization

and Closure Plan - Rev 1,” and in the lease agreement. Upon completion of the

licensee’s obligations, the US Ecology license will be transferred to the

State of Nevada which will assume all oversight responsibilities and become

custodian of the site. This transfer, according to State management, is

expected to take place later this year or some time in 1998. Meanwhile, it

was verified through file evaluations that the State continues to closely

monitor closure activities such as final trench capping, completion of

security fencing, and installation of trench markers. It is noted that this

LLRW site pre-dates the waste site standards adopted in 10 CFR 61.

The team verified by evaluation of State records and the settlement agreement

that the State has the funding (approximately nine million dollars) and plans

to continue surveillance and necessary repair through inspections and

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

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

Bureau of Land Management (BLM). The lease expires in 2007; however, the

State is currently in negotiation to buy, trade for, or extend the lease

before the expiration date. According to State management, upon transfer of

the license to a yet to be named State agency, that agency will assume the

responsibility for control of all activities on the site indefinitely.

4.3.1 Status of Low-Level Radioactive Waste Disposal Inspection

The State continues to inspect the facility periodically for trench slumping,

security, posting, environmental sampling, and other requirements imposed on

the licensee by the license, the regulations and the closure plan. The

State’s frequency of inspection for the Beatty site is one year, the same as

specified in IMC 2800 and IMC 2401. However, due to public and political

interests and the potential for changing conditions, the State often visits

the site on a more frequent basis, conducting additional inspections during

most visits. The annual inspection is considered complete when all elements

required for closure and/or long term surveillance are covered. The review

team examined the reports for nine inspections completed during the review

period. There were no inspections in 1993. There were five inspections in

1994 to observe important closure activities such as trench filling and

capping. Complete inspections were conducted in 1995, 1996, and 1997.

It is Nevada’s policy to send written confirmation of inspection findings to

the licensee within 30 days after the inspection, but only if items of noncompliance are found or if the licensee specifically requests the written

confirmation. If there are no findings or concerns, the State policy is to

present the results orally during the exit meeting. This was the case for the

nine inspections conducted during the review period. 

4.3.2 Technical Staffing and Training

In April 1995, the LLRW project manager retired and, because the site was no

longer accepting waste, he was not replaced. LLRW functions are now handled

by the RHS staff, under the direction of the RHS Supervisor. In addition to

his other technical qualifications, the RHS Supervisor has taken all the NRC

LLRW specialty courses and has 17 year’s experience in regulating the site,

both as a reviewer and inspector. The basic qualifications for the LLRW

program staff are the same as for the RAM program staff, as described in

Section 3.2, Technical Staffing and Training.
Nevada Final Report Page 16

Because of its proximity to the site, the Las Vegas office performs most of

the licensing and inspection activities, with their work reviewed by the RHS

Supervisor. The Las Vegas Supervising Radiation Physicist has been directly

involved in regulating the site since 1978. He was trained and accompanied on

many inspections by the retired LLRW project manager. He has taken all of the

pertinent courses and workshops given by the NRC and EPA. He, in turn, has

trained and assessed another Las Vegas technical staff member to conduct

inspection duties. This inspector now has five years of on-site inspection

experience. 

In addition, RHS has ready access to geologists, civil engineers,

hydrologists, and environmentalists within various State agencies or by

contract. The review team believes that the technical staffing and training

is adequate to meet the criteria for this indicator. 

4.3.3 Technical Quality of Licensing Actions

As explained previously, the site license expired December 31, 1992, but will

remain in effect until the licensee completes their obligations set forth in

the closure plan incorporated as a license condition on December 21, 1989, the

regulations and the lease agreement. A licensee performance assessment was

performed at the time the plan was submitted.

Only two licensing amendments were completed during the review period, and

both were evaluated. The amendments were minor, involving a change of

address, deleting some operational procedures, and clarifying by tie-down

exactly what activities the licensee must complete prior to transfer of the

license to the State. These licensing actions were done by senior staff and

were fully acceptable to the review team. Details of the reviews are included

in Appendix D.

The team found through observation in Carson City and interviews with the Las

Vegas staff that applicable guidance documents such as the NUREGs that support

10 CFR 61 are available and used as needed. 

4.3.4 Technical Quality of Inspections

The review team evaluated all nine of the on-site inspections conducted by the

State during the review period. Two were evaluated in depth, and included in

Appendix E. The Supervising Radiation Physicist and the inspector were

evaluated during the two casework reviews. The inspection reports were

complete, thorough, and in accordance with NRC guidance. Both had been

reviewed by the supervisors in Las Vegas and Carson City.

No LLRW enforcement actions were needed during the review period because the

inspections revealed no items of non-compliance. However, the State does have

in place enforcement procedures with severity levels triggering specific

escalated actions. These have been used effectively in the past to maintain

licensee compliance, and the RHS Supervisor assured the review team that the

enforcement procedures would be used as necessary.

Because of site closure, reduced activity, and the use of only senior

inspectors, supervisory accompaniments specific to the LLRW program were no

longer justifiable. However, the same inspectors are accompanied annually by

policy for the radioactive material program. The review team finds this

policy acceptable.
Nevada Final Report Page 17

4.3.5 Response to Incidents and Allegations

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

this review period. There have been reports by the U.S. Geological Survey

that they have found tritium at a monitoring well they operate in the buffer

zone outside the fence. These reports, however, were never formally submitted

to the State, only to the media. According to program management, RHS, the

licensee, and a disinterested third party have continuously and independently

monitored for tritium and other isotope migration and have found no evidence

of release on or off-site. The review team evaluated records including the

August 14, 1997, “Site Environmental Data Summary,” which included more than

2,700 environmental sample results taken by several different parties,

including State inspectors and contractors, during the period 1962 to 1997,

and found no support for the USGS report. These environmental samples include

soil, water, air, vegetation, and direct radiation, both on and off site.

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

the review team recommends that Nevada’s performance with respect to the

indicator, Low-level Radioactive Waste Disposal Program, be found

satisfactory.

5.0 SUMMARY

As noted in Sections 3 and 4 above, the review team found that Nevada’s

performance with respect to each of the performance indicators to be

satisfactory. Accordingly, the review team recommended and the MRB

concurred, in finding the Nevada program to be adequate to protect public

health and safety, and compatible with NRC's program. 

Below is a summary list of suggestions and recommendations, as mentioned in

earlier sections of the report, for evaluation and implementation, as

appropriate, by the State. 

RECOMMENDATIONS:

1. The review team finds that the State has not met the frequency of IMC

1220 for the inspection of reciprocity licensees. The review team

recommends that the State inspect a higher percentage of reciprocity

licensees, including high priority industrial radiography licensees

operating in rural areas. (Section 3.1) 

2. The review team recommends that the general training and qualification

procedure be adopted in writing. (Section 3.2)

3. The team recommended that the State review the incident files back to

the last event reported to NRC in 1995, and submit reports to NMED as

appropriate. At the MRB meeting, the State commented that they had

completed their review and had submitted the appropriate reports. No

additional action is necessary and the State does not need to address

this recommendation further. (Section 3.5)

4. The team recommends that, as provided by the implementing procedures

(“Adequacy and Compatibility of Agreement State Programs,” draft NRC

Management Directive 5.9, Handbook Part V), State regulations or other

generic legally binding requirements equivalent to the NRC rules be

adopted as expeditiously as possible but not later than September 3,

2000 (three years after the September 3, 1997, [62 FR 46517] publication

of the final policy.) (Section 4.1.2)
Nevada Final Report Page 18

SUGGESTIONS:

1. The review team suggests that the State provide a letter, or a short

form similar to the NRC Form 591, to the licensee indicating that no

violations were found as the result of the inspection, when appropriate. 

(Section 3.4)

Good Practice:

It was noted that every new or renewed license is tied through license

condition to an attached cover letter which clearly explains the licensee’s

responsibilities when the licensee receives the license.
LIST OF APPENDICES AND ATTACHMENTS

Appendix A IMPEP Review Team Members

Appendix B Nevada Organization Charts

Appendix C Nevada's Questionnaire Response

Appendix D License File Reviews

Appendix E Inspection File Reviews

Appendix F Incident File Reviews

Attachment 1 Nevada's Response to Review Findings
APPENDIX A

IMPEP REVIEW TEAM MEMBERS

Name Area of Responsibility

Richard Blanton, OSP On-Site Team Leader

Technical Staffing and Training

Response to Incidents and Allegations

Legislation and Regulations 

Donald E. Bunn, California Status of Materials Inspection 

Technical Quality of Inspections

Jack Hornor, RIV, WCFO Technical Quality of Licensing Actions

Sealed Source and Device Evaluations

Low-level Radioactive Waste Disposal

Program
APPENDIX B

NEVADA

BUREAU OF HEALTH PROTECTION SERVICES

HEALTH DIVISION

RADIOLOGICAL HEALTH SECTION

ORGANIZATION CHARTS
APPENDIX C

INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM

(IMPEP) QUESTIONNAIRE