June 18, 2002

Mr. Aubrey V. Godwin, Director

Arizona Radiation Regulatory Agency

4814 South 40th Street

Phoenix, AZ 85040

Dear Mr.Godwin:

On June 6, 2002, the Management Review Board (MRB) met to consider the proposed final

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

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

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

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

and compatible program. During the meeting, the MRB discussed the recent reductions in

funding for the Arizona Agreement Program and its impact on funding travel for training. The

review team also discussed with you their concerns with an aging workforce. The MRB

recognized that Program performance can be affected by the reductions in funding and by the

potential loss of qualified staff to retirement. 

Section 5.0, page 17, of the enclosed final report presents the IMPEP team’s recommendations

for the State of Arizona. We received your April 25, 2002 letter which described your staff’s

actions taken in response to the recommendations in the draft report. We request no additional

information.

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

four years.

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

your support of the Radiation Control Program. I look forward to our agencies continuing to

work cooperatively in the future.

Sincerely,

/RA/

Carl J. Paperiello 

Deputy Executive Director 

 for Materials, Research and State Programs

Enclosure: 

As stated

cc: William Wright, AZ

Steve Collins, IL

OAS Liaison to MRB

Don Hughes

 Regulatory Agencies Executive Assistant

Office of the Governor
Mr. Aubrey V. Godwin, Director June 18, 2002

Arizona Radiation Regulatory Agency

4814 South 40th Street

Phoenix, AZ 85040

Dear Mr.Godwin:

On June 6, 2002, the Management Review Board (MRB) met to consider the proposed final

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

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

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

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

and compatible program. During the meeting, the MRB discussed the recent reductions in

funding for the Arizona Agreement Program and its impact on funding travel for training. The

review team also discussed with you their concerns with an aging workforce. The MRB

recognized that Program performance can be affected by the reductions in funding and by the

potential loss of qualified staff to retirement. 

Section 5.0, page 17, of the enclosed final report presents the IMPEP team’s recommendations

for the State of Arizona. We received your April 25, 2002 letter which described your staff’s

actions taken in response to the recommendations in the draft report. We request no additional

information.

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

four years.

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

your support of the Radiation Control Program. I look forward to our agencies continuing to

work cooperatively in the future.

Sincerely,

/RA/

Carl J. Paperiello 

Deputy Executive Director 

 for Materials, Research and State Programs

Enclosure: 

As stated

cc: William Wright, AZ bcc: Chairman Meserve

Commissioner Dicus

Steve Collins, IL Commissioner Diaz

OAS Liaison to MRB Commissioner McGaffigan

Commissioner Merrifield

 Don Hughes

Regulatory Agencies Executive Assistant 

Office of the Governor

Distribution: See next page.

DOCUMENT NAME: G:\IMPEP\ML021630511.wpd

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 STP STP:DD STP:D DEDMRS

NAME CHMaupin:kk JMPiccone PHLohaus CJPaperiello

DATE 06/12/02 06/12/02 06/12/02 06/18/02

OFFICIAL RECORD COPY

Distribution:

DIR RF VCampbell, RIV DCD (SP01) PDR (YES)
KSchneider, STP LCox, NC FCameron, OGC

LRakovan, STP JJankovich, NMSS KCyr, OGC

JMyers, STP/ASPO STreby, OGC MVirgilio, NMSS

DCool, NMSS/IMNS JLieberman, OGC Arizona File

LPsyk, NMSS/IMNS TCombs, OGC
INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM

REVIEW OF ARIZONA AGREEMENT STATE PROGRAM

February 25 - March 1, 2002

 FINAL REPORT

U.S. Nuclear Regulatory Commission

1.0 INTRODUCTION
Arizona Final Report Page 1

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

review was conducted during the period February 25 - March 1, 2002, by a review team

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

Agreement State of North Carolina. Team members are identified in Appendix A. The review

was conducted in accordance with the "Implementation of the Integrated Materials Performance

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

Federal Register on October 16, 1997, and the November 5, 1999, NRC Management Directive

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

the review, which covered the period of February 14, 1998 to March 1, 2002, were discussed

with Arizona management and a representative of the Governor’s office on March 1, 2002.

A draft of this report was issued to Arizona for factual comment on March 29, 2002. The State

responded in a letter dated April 25, 2002. The Management Review Board (MRB) met on 

June 6, 2002 to consider the proposed final report. The MRB found the Arizona radiation

control program was adequate to protect public health and safety and compatible with NRC’s

program.

The Arizona Agreement State program is administered by the Arizona Radiation Regulatory

Agency (the Agency). The Director of the Agency reports directly to the Governor of Arizona. 

The day-to-day operations of the Arizona Agreement State program are managed by the

Radioactive Materials & Nonionizing Radiation Compliance Program (the Program). The

Program Manager spends approximately one half of his time on the radioactive materials

program. An organization chart for the Agency is included as Appendix B. At the time of the

review, the Arizona Agreement State program regulated 292 specific licenses authorizing

Agreement materials. 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 State of Arizona.

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

indicators was sent to the Agency on December 19, 2001. The Agency provided its response

to the questionnaire on February 11, 2002. A copy of the completed questionnaire response

can be found on NRC’s Agencywide Document Access and Management System using the

Accession Number ML020860719. 

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

Arizona’ responses to the questionnaire; (2) review of applicable Arizona statutes and

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

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

accompaniments of two Agency inspectors; and (6) interviews with staff and management to

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

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

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

performance. 
Arizona Final Report Page 2

Section 2 below discusses the Agency’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 performance indicators, and Section 5 summarizes the review team’s

findings and recommendations. Recommendations made by the review team are comments

that relate directly to 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 IMPEP review, which concluded on February 13, 1998, seven

recommendations were made and transmitted to Mr. Aubrey Godwin, Agency Director on 

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

1. The review team recommends that industrial radiography inspections need to be

conducted at temporary job sites in addition to office inspections, to verify compliance to

operating procedures and regulations. (Section 3.2)

Current Status: The review team found that the Agency has conducted industrial

radiography inspections at temporary job sites. The Agency has experienced difficulty

in locating industrial radiography job sites and plans to institute additional measures to

increase the number of job site inspections. The Agency is planning to institute a policy

which would require licensees to notify the Agency of field work prior to conducting

industrial radiography operations. This recommendation is closed.

2. The review team recommends that staff include more detailed documentation related to

telephone deficiency calls, describing the issues and noting the applicant’s response. 

Additionally, the staff should ensure that all requests within license applications are

addressed, either in the amended license or by letter, if certain aspects of the

amendment request are denied. (Section 3.4)

Current Status: The Administrative Procedures Act of December 1998 eliminated

deficiency phone calls as a means of official communication with applicants. During this

review, the team noted that the Agency uses letters to officially communicate

deficiencies with licensees, and uses telephone discussions, as appropriate, to direct

licensees to submit additional information. In the files reviewed, the team noted

licensees’ written responses to Agency requests for additional information. The

Agency’s licensing actions were appropriately documented. This recommendation is

closed.

3. During the 1998 review, the team noted that an Arizona law, referred to as the

deficiency rule, required the Agency to complete licensing actions within a

predetermined period of time and prevented the Agency from obtaining additional

information from a license applicant once an initial deficiency letter had been sent. The

1998 IMPEP team noted that the deficiency rule could potentially adversely impact

public health and safety if the technical quality of the Agency’s licensing actions was

compromised due to the inability to obtain additional information from the applicant or

due to the need to meet a prescribed time line. The review team recommends that the

State closely monitor the impact of this deficiency rule and provide NRC with information
Arizona Final Report Page 3

about the Agency’s experience with this law. (Section 3.4)

Current Status: The team interviewed staff, reviewed licensing files and concluded that

the Agency has effectively and efficiently implemented the deficiency rule without

compromising public health and safety. This recommendation is closed.

4. The review team recommends that all incident reports be recorded and closed out as

directed in the Agency’s operating procedures, and that written procedures be

developed to ensure that the reports are consistently maintained, distributed, and crossreferenced between the incident and licensee files. (Section 3.5)

Current Status: The Agency has developed detailed written procedures for handling

incidents. Agency management meets with staff on a weekly basis to discuss the status

of any incidents along with other program related issues. The Program Manager

periodically performs checks to ensure that the procedures are being followed as

directed. This recommendation is closed.

5. The team also recommends that the State follow the new reporting procedures for all

incidents as described in the latest NMED manual. (Section 3.5)

Current Status: The Agency is following the new incident reporting procedures and is 

reporting Agreement materials events to the NRC. This recommendation is closed.

6. The review team recommends the certificate AZ 244 D 102S, for TLS Systems model

40111 be amended to include the maximum amount of radioactive material used in the

device and to remove the authorization for exempt license distribution. (Section 4.2.1)

Current Status: The Agency corrected the registration certificate and submitted it to the

NRC National Sealed Source and Device Registry on April 16, 1998. The NRC

distributed the corrected certificate to all Agreement States and placed the document

into the electronic data base in accordance with the applicable NRC procedure. This

recommendation is closed.

7. The review team recommends that the TLS license for distribution (10-135) be amended

to include model 40111. (Section 4.2.1)

Current Status: The Agency appropriately amended the license. This recommendation

is closed.

During the 1998 review, four suggestions were made for the Agency to consider. The team

determined that the Agency considered the suggestions and took appropriate actions. 
Arizona Final Report Page 4

3.0 COMMON PERFORMANCE INDICATORS

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

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

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

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

3.1 Status of Materials Inspection Program

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

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

licensees. The review team’s evaluation is based on the Agency’s questionnaire responses

relative to this indicator, data gathered independently from the Agency’s licensing and

inspection data tracking system, the examination of complete licensing and inspection

casework, and interviews with managers and staff.

The team's review of the Agency’s inspection priorities verified that inspection frequencies for

various types of Arizona material licenses are generally the same as those listed in the NRC

Inspection Manual Chapter (IMC) 2800. However, there are three categories of licenses that

have been assigned an inspection frequency less than those currently prescribed in the IMC

2800, yet the Agency currently has no licensees in these categories. These three categories of

licensees are “Byproduct Material Possession Only,” “Source Material Possession Only,” and

”SNM Possession Only-Other than Reactor Fuel.” These categories are currently assigned an

inspection priority of “3" by the Agency, while they are assigned a Priority of “2" by the NRC.

The Agency indicated that when their inspection procedures were written, they incorporated the

NRC priority codes that were in effect at that time and have not updated the procedure to reflect

the current priorities. Agency management stated that if the Agency received license

applications in these categories, they would revise their inspection priorities to be consistent

with those of the NRC. In addition, the team noted that a High Dose Remote Afterloader

(HDR) license was assigned a Priority 2 as opposed to a Priority 1, yet the Agency was

inspecting the license annually. The team discussed the issue with the Program Manager. The

Program Manager indicated that the priority for HDR licenses would be changed to a Priority 1

to be consistent with IMC 2800.

In their response to the questionnaire, the Agency indicated that there were currently no

overdue inspections of core licensees. This information was verified during the inspection

casework reviews and the review of the monthly generated “inspections due” list provided to the

team. The review team noted that out of 10 inspection files examined, only one inspection was

conducted overdue during the review period; a Priority 1 license was inspected 5 months past

its inspection due date. During the review period, there were no other overdue inspections. 

The review team also evaluated the Agency’s initial inspections. The team noted that the

Agency conducted initial inspections in accordance with the IMC 2800 guidelines.

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

review. The Agency has an effective and efficient process which ensures that inspection

findings are communicated to licensees in a timely manner. During each inspection, Agency

staff presents a Notice of Inspection to the licensee for signature. The Notice of Inspection

informs the licensee that within 30 working days of completing the inspection, the Agency will

mail a letter indicating that there were no potential violations identified or a letter detailing the
Arizona Final Report Page 5

potential violations and requesting the licensee’s response by a certain date. The Notice also

includes the licensee’s rights and the Agency’s responsibilities. For the 20 inspection files

examined, all inspection findings were sent to the licensees within 30 days.

During the review period, the Agency granted 170 reciprocity permits, of which, 82 permits were

core licensees based upon IMC 1220. The 82 core licensees consisted of 33 Priority 1 and 49

Priority 3 licensees. The Agency met the IMC 1220 inspection frequencies for Priority 1

licensees by conducting 16 inspections. At the time of the review, the Agency did not meet the

IMC 1220 inspection guidance for Priority 3 licenses. The Agency completed four Priority 3

inspections, while the IMC 1220 guidance provided that 14 inspections be conducted. New

NRC guidance requires totaling all of the Priority 1, 2, and 3 reciprocity (core) licensees, and

conducting inspections of 20% of this total. Thus, the Agency met the revised NRC guidance

by completing 19 inspections of the 82 permits issued for core licensees.

The Agency indicated that a lower priority is given to reciprocity inspections because of the

limited resources provided to the Program. The Agency indicated that they rely upon the

regulatory program which issued the license to conduct routine inspections for Priorities 2

through 7 licensees operating under reciprocity in Arizona. The Agency further indicated that it

concentrates its reciprocity inspection efforts on Priority 1 licenses and tries to comply with the

50% inspection requirement for these licenses. The review team concluded that this approach

is acceptable, especially in light of the revised IMC 1220 guidance.

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

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

satisfactory.

3.2 Technical Quality of Inspections

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

notes and interviewed inspectors for 10 radioactive materials inspections conducted during the

review period. The casework included all of the Agency’s fully trained materials inspectors, and

covered inspections of various types as follows: industrial radiography, medical broad scope,

limited industrial, nuclear pharmacy, limited medical, and health physics consultants. Appendix

C lists the inspection casework files reviewed for completeness and adequacy with casespecific comments. 

Based on the casework file reviews, the review team found that routine inspections covered all

aspects of the licensee’s radiation protection program. The inspection reports were thorough,

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

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

supported the cited violations, and recommendations made to the licensee, unresolved safety

issues, and discussions held with the licensee during exit interviews. Team inspections were

performed when appropriate and for training purposes.
Arizona Final Report Page 6

The review team found that routine inspections adequately cover the licensee’s radiation

protection program. Inspection reports include a written summary of the scope of the licensed

activities and categorize violations into severity levels which can be used for escalated

enforcement, if necessary. The review team noted that the majority of violations cited are

recordkeeping infractions. The review team discussed the current performance-based, riskinformed inspection philosophy with the accompanied inspectors. As discussed below, the

review team also found that the inspectors observed licensed operations, interviewed

personnel, and performed excellent performance-based inspections during both

accompaniments. 

The Program Manager conducts supervisory accompaniments of each material inspector once

a year. During the year 2000, the Program Manager did not formally document

accompaniments but confirmed that supervisory accompaniments are performed annually. The

team noted that the Agency has two experienced materials inspectors and one newly hired

inspector, who is currently in training status. 

The team accompanied two materials inspectors during the period of February 25 to 

February 26, 2002. The accompaniments included inspections of an industrial radiography

home office and a medical institution. The facilities inspected are identified in Appendix C. 

During the accompaniments, each inspector demonstrated appropriate inspection techniques

and knowledge of the regulations. The inspectors were trained, well prepared for the inspection,

and thorough in their audits of the licensees’ radiation safety programs. Each inspector

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

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

The Agency has an adequate number and types of survey meters to support the current

inspection program as well as for responding to incidents and emergency conditions. The

Agency has a contractor calibrate their survey instruments quarterly to meet the requirement

placed upon industrial radiographers. Appropriate, calibrated survey instruments such as GM

meters, scintillation detectors, ion chambers and micro-R meters were observed. Air monitoring

equipment is also available for emergency use. Contamination wipes are evaluated at the

Agency’s onsite laboratory. The Agency also maintains a mobile laboratory van for use in

emergencies and emergency exercises. 

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

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

satisfactory.

3.3 Technical Staffing and Training

Issues central to the evaluation of this indicator include the Agency’s staffing level and staff

turnover, as well as the technical qualifications and training histories of the staff. To evaluate

these issues, the review team examined the Agency's questionnaire responses relative to this

indicator, interviewed Agency management and staff, reviewed job descriptions, training

records, and considered any possible workload backlogs.

The Program is authorized for four State Health Physicist positions, and one half of the

Program Manager’s effort. In addition, the Agency Director also provides managerial support to

the Program. Since Arizona is a small program, the licensing and inspection functions are

supported by three materials inspectors and one materials licensing specialist. Licensing
Arizona Final Report Page 7

support is augmented by the Program Manager and Agency Director. The Program Manager

reviews all licensing actions and the Agency Director signs all licenses. At the time of the

onsite review, there were no backlogs in inspections or licensing actions. The team determined

that there was proper balance between the licensing and inspection functions. 

The materials licensing specialist also has lead responsibility for rulemaking development. Of

the four staff, three are experienced (2 inspectors and the licensing specialist). One inspector

retired during the review period and the Program hired an inspector who was previously from

the Agency’s X-ray Program. At the time of the review, no vacancies existed in the Program. 

In addition, the Program Manager and Agency Director support the Sealed Source and Device

Program. 

Program staff are required to have a bachelor’s degree in science or equivalent experience for

a State Health Physicist entry position, and a master’s degree and/or additional radiationrelated work experience for positions beyond entry level. The team noted that the Program has

been able to recruit and retain qualified staff.

The Agency has a documented training plan that is consistent with the requirements in the

NRC/Organization of Agreement States Training Working Group Report and IMC 1246. The

Agency also has on-the-job training to supplement the course work so that individuals may

broaden their work areas. A new hire is expected to complete “core” courses, or their

equivalent, to be fully qualified according to the Agency’s training guidelines. In the past, the

Agency staff has received “core” course training by attending NRC sponsored training. The

NRC training combined with on-the-job training allowed new personnel to be fully trained within

approximately two years. However, with the severe cuts in the Arizona budget it is very unlikely

that the newly hired inspector will be fully trained within the two-year period. 

The Agency receives funding from the State’s General fund and does not receive funds

specifically for training. The State is currently experiencing a billion-dollar or more shortfall over

the next 16 months (March 2002 to September 2003) and has directed State Agencies to

develop plans and strategies to incorporate funding reductions to their programs. The Agency’s

FY 2002 budget was cut by 6%, which is equivalent to $86,200.00 and an additional 0.25% cut,

$3,000.00, is proposed. Currently, the Agency’s expenses are exceeding their funding. This

has resulted in the Agency suspending all travel which will require State reimbursement, except

for the use of State vehicles.

In addition, the review team discussed with Agency management their concerns about the

effect of an aging workforce. In light of the budget restraints and the potential loss of qualified

staff to retirement, the Agency may experience difficulty in maintaining a qualified staff in the

near future. 

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

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

satisfactory.
Arizona Final Report Page 8

3.4 Technical Quality of Licensing Actions

The review team examined completed licensing casework and interviewed the staff for 15

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 evaluated for overall technical quality including accuracy,

appropriateness of the license, its conditions, and tie-down conditions. Casework was

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

regulations; documentation of safety evaluation reports, product certifications or other

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

peer or supervisory review as indicated; and proper signature authority. The files were checked

for retention of necessary documents and supporting data.

Licensing casework was selected to provide a representative sample of licensing actions that

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

licenses: research and development, well logging, industrial radiography, medical (institution,

private practice, and broad scope), portable gauge, nuclear pharmacy, veterinary medicine, and

broad scope academic. Licensing actions selected for evaluation included three new licenses,

three renewals, eight amendments, and one termination. A list of the licenses evaluated with

case-specific comments can be found in Appendix D.

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

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

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

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

and amendments. The materials licensing specialist appropriately used the Agency’s licensing

guides and standard license conditions, in most cases. However, the team determined that

some modifications need to be made with the Program with regard to financial assurance.

The review team determined that the Program had not fully implemented the decommissioning

financial assurance requirements adopted by the State in May 1999. The team examined

licenses issued by the Program. The team noted that Arizona licenses contained materials,

including unsealed materials, meeting the financial assurance limits, yet no decommissioning

funding plan was submitted and the licenses were not conditioned to limit possession to

quantities not requiring financial assurance. The review team recommends that the Agency

review all Arizona licenses to ascertain if they require financial assurance, and take appropriate

action on each affected license to ensure that all licenses meet the State’s financial assurance

requirements.

All licensing actions are reviewed by the materials license reviewer who closely monitors the

timeliness of licensing actions. All completed licensing actions are then reviewed by the

Program Manager. The Agency Director conducts a secondary management review on

selected actions and signs all licensing documents. The team also found that licensing

checklists are not used routinely by the Program due to the experience of the Program staff. 
Arizona Final Report Page 9

The team also found that terminated licensing actions were adequately documented. In

general, the files included the appropriate material transfer records and survey records. No

potentially significant health and safety issues were identified.

In 1977, the NRC initiated a review of terminated NRC licenses to determine whether sites had

been adequately decontaminated prior to termination and release of the site. As a result of this

effort, a number of sites were identified as lacking proper documentation of termination

activities, including disposition of materials. Some of these NRC formerly licensed sites were

determined to be located in Agreement States and to be the regulatory responsibility of the

State. In an effort to reduce the resource impacts on Agreement States, the NRC established a

grant program for Agreement States to conduct file reviews and initial surveys of the NRC

formerly licensed sites. Five sites were determined to be located in Arizona. The State of

Arizona submitted a grant proposal to the NRC and was awarded a grant of $33,970.00 to

review the five sites within the State. The Agency is also requested to report the resolution of

each case to the NRC for tracking. 

During the Arizona IMPEP, the team examined the Agency’s activities with regard to the five

NRC formerly licensed sites. The review team interviewed staff, and reviewed the five license

files for the sites, which included radiological survey and analysis results. The team determined

that the Agency was applying good health physics practices in conducting radiological surveys

and sample collections. The team determined that the Agency’s laboratory facilities and

equipment were sufficient to provide appropriate analysis of samples. At the time of the onsite

review, the team was informed that the Agency had gathered sufficient information to close the

termination files of four sites. One site remains open because the Agency has not yet been

able to locate it. The specifics of each case are found in Appendix D. 

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

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

satisfactory.

3.5 Response to Incidents and Allegations

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

team examined the Agency’s response to the questionnaire relative to this indicator, evaluated

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

against those contained in the Agency files, and evaluated the casework and supporting

documentation for 15 material incidents. A list of the incident casework examined with casespecific comments is included in Appendix E. The team also reviewed the Agency’s response

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

The review team discussed the Agency’s incident and allegation procedures, tracking system,

file documentation, the State’s equivalent to the Freedom of Information Act, NMED, and

notification of incidents to the NRC Operations Center with Agency’s management and staff.

The primary responsibility for coordination of all emergency responses rests with the

Emergency Response Program Manager. However, the initial response and follow up to

incidents and allegations involving radioactive materials are coordinated with the Program

Manager for radioactive materials. Separate written procedures exist for handling incidents and

allegations (referred to as “complaints” by the Agency). The Agency conducts onsite
Arizona Final Report Page 10

investigations for all incidents that present an actual or potential hazard to public health and

safety. The Agency Director is advised of all incidents reported and the planned response prior

to dispatching responders to the site. Review of casework indicates that this approach provides

effective and appropriate response actions and does not delay the response time. The

procedures and report forms are available to the staff when responding to any incident,

accident or emergency involving radioactive materials. All records of reported incidents are

maintained by the Emergency Response Program Manager in a master file and a duplicate

copy is maintained in the license file. 

The incidents selected for review included the following categories: overexposure, damage to

equipment, lost and stolen gauges, loss of radioactive material, release of radioactive material,

and loss of administrative control. The review team found that the Agency’s response to

incidents was generally complete and comprehensive. Initial responses were prompt and wellcoordinated, and the level of effort was commensurate with the health and safety significance.

The Agency dispatched inspectors for onsite investigations when appropriate, and took suitable

enforcement and follow-up actions.

The Agency listed 31 radioactive material incidents involving Agreement material in their

response to the questionnaire. The team found 21 of the events in the NMED database. The

team reviewed 15 incidents, including the 10 events not included in NMED. The team found

that three of the event files indicated that reports or follow-up information had been provided to

the NRC yet the information was not in the NMED database. The team provided these

discrepancies to the NRC NMED Project Manager for follow up.

The 15 incidents reviewed included seven significant events, three 30-60 day notification

events, and five events not requiring reports as defined in the Office of State and Tribal

Programs (STP) Procedure SA-300, “Reporting Material Events.” Of the seven significant

incidents, the review team noted that two events which met the reporting criteria were not

reported to NRC. In addition, the team identified one event where follow-up information was

available in the file, but was not reported to NRC. The team discussed the procedure for

reporting incidents with the Agency management. The Agency management indicated that they

would update the NMED data to include this additional information. 

During the review period, the NRC referred four allegations to the Agency. The review team

noted that the Agency promptly responded with appropriate investigations, follow up, and close

out actions for all the allegations referred by the NRC. However, the team noted that no

allegations were received directly by the Agency for the current or the prior review period. 

It is not clear whether the Agency has a written procedure in place for managing allegations

received directly from members of the public. The team noted that the 1998 IMPEP report

provided that the Agency’s written allegation procedure required prompt evaluation of the

allegations, an initial written response to the alleger and indicated that the procedure was

revised on February 12, 1998, to include the requirement to furnish the alleger with a copy of

the final investigative report. However, when the team requested a copy of the Agency’s

procedures for managing allegations, the Agency management was unable to locate the 1998

document. Rather, the Agency provided a one page procedure dated January 1, 1995, which

focused on the State’s implementation of 10 CFR 19.16, “Requests by workers for inspections.”

The 1995 procedure also indicated that all official complaints must be filed in writing, unless
Arizona Final Report Page 11

circumstances prohibit such action and that anonymous complaints are not subject to action by

the Program unless they have another independent reason to believe that some violations are

occurring. In addition, the procedure was unclear on whether the State could protect the

alleger’s identity. The procedures implied that workers’ identities may be protected from 

disclosure; however, they were silent about the Agency’s policy on protecting the identity of

members of the public. 

In discussions with the review team, Agency management indicated that once an allegation was

identified, the staff would use the Agency’s procedure for response to incidents to investigate

the allegation. The Agency management also provided copies of a complaint log and a report

form that is used to document the receipt and resolution of allegations. Consequently, the team

concluded that the Agency takes appropriate action in response to allegations but procedures

for handling allegations received from members of the public are not clearly documented. The

team discussed NRC Management Directive 8.8, Management of Allegations, with the Program

Manager, and the team noted that the Program had a copy of the document. The team

recommends that the Agency reexamine their procedure for handling allegations, consider the

key elements of procedures outlined in NRC’s Management Directive 8.8, and incorporate the

elements that are appropriate for their program.

Based on the IMPEP evaluation criteria, the review team recommends that Arizona’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 Program Elements Required for Compatibility; (2) Sealed

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

and (4) Uranium Recovery Program. Arizona's Agreement State program does not cover

uranium recovery operations, so only the first three non-common performance indicators were

applicable to this review.

4.1 Legislation and Program Elements Required for Compatibility

4.1.1 Legislation 

The authority under which the Agency administers the State’s Radiation Control Program is

Title 30, Chapter 4 of the Arizona Revised Statutes, “Control of Ionizing Radiation.” This statute

gives the Agency specific powers and duties among which are authorities to allow the State to

enter into an agreement with the NRC, promulgate regulations, issue licenses, perform

inspections, collect fees, and issue civil penalties. The Arizona Revised Statutes also require

the Agency to review all regulations every five years. 
Arizona Final Report Page 12

Other statutes that affect the Agency are contained in Title 30, Chapter 5, “Interstate

Cooperation in Atomic Energy Matters,” and Title 41, Chapter 6, “State Government.” These

statutes describe the State’s administrative procedures for rulemaking, adjudicative

proceedings, licensing time frame, and hearing procedures. There has been no legislation

passed since the last IMPEP review that affected the radiation control program.

4.1.2 Program Elements Required for Compatibility 

The Agency’s regulations are contained in the Arizona Administrative Code under Title 12,

Chapter 1, “Radiation Regulatory Agency,” Articles 1 through 17. The Arizona Regulations

pertaining to radiation control apply to all ionizing radiation, whether emitted from radionuclides

or devices. Arizona requires a license for possession and use of all radioactive material

including naturally occurring materials, such as radium. To the extent possible, the Arizona

regulations follow the Suggested State Regulations (SSRs) of the Conference of Radiation

Control Program Directors, Inc. 

The Program has assigned a materials license specialist the responsibility of rulemaking

development, including schedule maintenance, to assure continued compatibility of State

regulations with those of the NRC. The review team conducted several interviews with the staff

member to determine the effectiveness of the Agency’s regulatory process. Team members

also witnessed two public hearings held at the Agency’s main office during the onsite IMPEP

review, and found that the public and other interested parties are offered an opportunity to

comment on proposed regulations.

The Agency’s regulations are reviewed every 5 years. For each regulation, the Agency must

describe the effectiveness of the regulation and provide the statutory authority under which the

regulation is issued. The Agency must also demonstrate that the regulation is consistent with

other Agency regulations, and that the regulation is clear and understandable. In addition, in

developing regulations, the Agency is to consider the economic impact on small businesses

and consumers. The review team found that draft regulations are sent to NRC for approval,

although not in the format required by the Office of State and Tribal Programs Procedure SA201, “Review of State Regulations.” The Agency’s regulation submittals to NRC were

discussed with management and the Agency was provided information on the format and

content for rule

submittals.

The information provided in the questionnaire reflects that the Agency initially adopts changes

to the NRC regulations by incorporating them into license conditions, then by adopting the NRC

regulations through rulemaking. After preparation of a package of draft regulations and

incorporation of comments, the Agency obtains approval from the Governor’s Regulatory

Review Council (the Council). The Council allows opportunity for members of the public to

comment on proposed regulations, and evaluate the regulations to avoid duplication and

unnecessary burdens. Typically, rule promulgation requires 1 to 11⁄2 years due to scheduling of

the Hearing Board and Council. This rulemaking process appears to be functioning for the

Agency, although in several cases it did not meet the 3-year time frame for adoption as

required by the Commission’s Policy Statement on Adequacy and Compatibility of Agreement

State Programs (Policy Statement). 

The team reviewed the status of the regulations required for adoption by the State under the
Arizona Final Report Page 13

Policy Statement. The team compared the adoption of regulations by the State with data

obtained from the STP Regulation Assessment Tracking System, and NRC Chronology tables. 

A spot check review of the Arizona Administrative Code was also done to verify adoption of

previously issued NRC regulations. Interviews were conducted with the Program staff

confirming that the Program uses license conditions when regulations were not adopted within

the 3-year time frame. The team noted that license conditions or other legally binding

requirements were being used for the following rules. 

 “Frequency of Medical Examinations for Use of Respiratory Protection Equipment,” 

10 CFR Part 20 amendment (60 FR 7900) that became effective March 13, 1995. A

proposed regulation has been drafted and submitted for NRC review.

 “Licenses for Industrial Radiography and Radiation Safety Requirements for Industrial

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

28948) that became effective June 27, 1997. A proposed regulation has been drafted

and submitted for NRC review.

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

amendments (62 FR 39057) that became effective August 20, 1997. A proposed

regulation has been drafted and submitted for NRC review.

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

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

The Program indicated that other legal mechanisms are in place in Arizona

Administrative Code §30-673, “Unlawful Acts” and in the Agency’s “Civil Penalties

Procedures” R12-1-1213 to address this requirement.

 “Licenses for Industrial Radiography and Radiation Safety Requirements for Industrial

Radiography Operations, Clarifying Amendments and Corrections,” 10 CFR Part 34

amendment (63 FR 37059) that became effective on July 9, 1998.

These legally binding requirements have not been submitted for NRC review. The team

recommends that the Program submit legally binding requirements to NRC for review.

During the onsite review, the review team found the following five regulations had not been

adopted, are overdue, and are not incorporated in license conditions or other legally binding

 requirements.

 “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,

and 60 FR 322) that became effective on January 1, 1995. The Agency has not drafted

this regulation.

 “10 CFR Part 7: Compatibility with the International Atomic Energy Agency,” 10 CFR

Part 71 amendments (60 FR 50248; 61 FR 28723) that became effective April 1, 1996.

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

Parts 20, 30, 40, 61, and 70 amendments (61 FR 24669) that became effective on 
Arizona Final Report Page 14

June 17, 1996. The Agency has drafted this regulation. The Agency anticipates

submitting a proposed regulation within 6-9 months for NRC review.

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

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

1997. The Agency has drafted this regulation. The Agency anticipates submitting a

proposed regulation within 6-9 months for NRC review.

 “Requirements for Certain Generally Licensed Industrial Devices Containing Byproduct

Material,” 10 CFR 32.52(a) and 32.52(b) amendments (65 FR 79162) that became

effective February 16, 2001 and was to be implemented by States within 6 months,

August 16, 2001. This regulation has not been addressed by the State.

In addition, the following two regulations were submitted to the NRC for review.

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

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

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

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

due date for the Agency to adopt this rule is May 17, 2003.

The Agency will need to address the following two regulations in upcoming rulemakings or by

adopting alternate legally binding requirements:

 “New Dosimetry Technology,” 10 CFR Parts 34, 36, and 39 amendments (65 FR 63749)

that became effective January 8, 2001. The due date for the Agency to adopt this rule is

January 8, 2004.

 “Requirements for Certain Generally Licensed Industrial Devices Containing Byproduct

Material,” entire amendment except 10 CFR 32.52(a) and 32.52(b), (65 FR 79162) that

became effective February 16, 2001. Although the State will need to address a portion

of this rule immediately, as discussed above, the remaining portion of this amendment is

due by February 16, 2004.

In evaluating the Agency’s program, the team determined that the Agency consolidates several

amendments into a rulemaking package in order to lower the expense of promulgation of its

regulations. The team recognizes the benefits of this practice in managing the cost of rule

development; however, this practice will need to be balanced against timeliness in incorporating

new rule changes to meet NRC compatibility requirements. The team recommends that the

Agency review its procedures to improve the timeliness in incorporating new rule changes into

their regulatory program, including immediately addressing the reporting requirements for

generally licensed device distributors which was due by August 16, 2001.

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

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

Compatibility, be found satisfactory with recommendations for improvement. 

4.2 Sealed Source and Device (SS&D) Evaluation Program
Arizona Final Report Page 15

In conducting this review, three sub-indicators were used to evaluate the Agency’s performance

regarding their SS&D Evaluation Program. These sub-indicators include: (1) Technical Quality

of the Product Evaluation; (2) Technical Staffing and Training; and (3) Evaluation of Defects

and Incidents Regarding SS&Ds.

In assessing the Agency's SS&D Evaluation Program, the review team examined information

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

selected SS&D evaluations and supporting documents covering the review period was

conducted. The team observed the staff's use of guidance documents and procedures, and

interviewed the staff and Program Manager involved in SS&D evaluations.

4.2.1 Technical Quality of the Product Evaluation Program

The Agency did not process any new SS&D applications since the last review in February 1998. 

However, the Agency issued one amendment correcting deficiencies identified during the

previous IMPEP review. The review team noted that in 1993, preceding the previous IMPEP

review period, the Agency issued two SS&D registration certificates for self-luminous light

sources. During the review of the Agency’s casework supporting the revision of the certificate

issued April 16, 1998, the review team noted deficiencies in the supporting information for the

amendment. Although a final certificate had been transmitted to NRC for inclusion into the

NRC national registry, the review team found only a draft, marked-up copy of the certificate

which showed that the recommended corrections had been made. There were no Agency

records documenting the amendment and issuance of the certificate or the transmittal of the

document to the NRC for national distribution. The review team identified additional concerns

with this certificate during casework review. Due to the limited experience of the Agency with

SS&D evaluations, the other certificate issued during the previous review period was examined

and similar deficiencies were identified. The specific comments are listed in Appendix F. The

scope of these corrections involve technical issues, including the accuracy of the description of

the sources. The team found no safety issues relative to the corrections needed to the

certificates. The team discussed the corrections with the Agency staff. They agreed to revise

the certificates to correct the deficiencies identified in Appendix F. The review team

recommends that the Agency make corrections to the SS&D registration certificates Nos. AZ244-D-101-S and 

AZ-244-D-102-S.

As noted in Appendix F, the review team also reviewed the Honeywell, Inc. license files. A

description to manufacture and distribute a fuel gauge for various aircraft containing 2.5 mCi

(9.25 MBq) of Am-241 was imbedded in a 1987 license application from Honeywell. The

Agency issued a materials license to Honeywell in response to the application. At the time of

the review, the team was unable to determine whether a safety evaluation of the device had

been conducted. Following the review, the team confirmed through NRC records that prior to

moving to Arizona from Minnesota in 1987, NRC conducted a safety evaluation of the

Honeywell fuel gauge and approved the manufacture and distribution of the generally licensed

device. The Agency indicated that they reviewed the information that had been submitted to

the NRC and concluded that the device was acceptable for distribution. At present, there is no

certificate on the device because there is no regulatory requirement to issue registration

certificates. However, the issuance of registration certificates is a common practice and the

Agency has indicated that they will provide the NRC an information certificate on the current

status of the device.
Arizona Final Report Page 16

The team also reviewed all other Arizona licensees to determine whether there is a need to

issue other registration certificates to those who may be manufacturing or distributing sealed

sources and devices. The team found that there are no other licensees requiring action.

4.2.2 Technical Staffing and Training

The Program Manager and a health physicist from the Radiation Measurement Program,

another program within the Agency, are the reviewers qualified to conduct safety evaluations of

SS&D applications. Both of the Agency staff members have academic degrees in engineering

and have completed the NRC workshop for SS&D reviewers. The team interviewed these

individuals and found that both are familiar with the SS&D evaluation process and are familiar

with and have access to the applicable reference documents. According to Agency procedures,

both of these reviewers are to conduct the safety evaluation, and the Program Manager and the

Agency Director sign the certificate. The team determined that the reviewers meet the

technical training required for SS&D reviews as described under the guidance. Similarly, the

team determined that the staffing level of qualified reviewers is sufficient in view of the relatively

low number of Arizona licensees who need registration certificates.

The review team noted that the qualified staff has not conducted a full safety evaluation for nine

years. Given the deficiencies identified in the Technical Quality of the Product Evaluation

Program sub-indicator, the review team discussed that rotational assignment of the Agency

staff to NRC or other Agreement States, where a large number of SS&D safety reviews are

conducted on a continual basis, would be most beneficial for maintaining the skills obtained in

their initial training. Such rotational opportunities, which usually last for a two week period, are

routinely available. For example, NRC usually hosts two SS&D reviewers from Agreement

States each year. If a new SS&D application was submitted to the Agency, the review team

concludes that some type of refresher training would be crucial for the current staff. 

The training requirements for Agency staff are delineated in Procedure No. ARRA-PROG-1245,

“Inspector Qualifications.” However, the team noted that the training and qualification

requirements for SS&D reviewers is not addressed. The qualification requirements usually

include the basic SS&D related courses or workshop, the number of casework reviews

necessary to qualify as a reviewer, and refresher training needed. The Agency has not

developed formalized, written training requirements for SS&D reviewers. Formal training

requirements would facilitate qualification of other staff in case replacement of the currently

available persons would be needed and address the necessity of refresher training and current

experience. The review team recommends that the Agency establish qualification requirements

for SS&D reviewers and develop a formalized, written training program.

4.2.3 Evaluation of Defects and Incidents Regarding SS&Ds

Two incidents related to SS&D defects were noted by the State of Arizona during the review

period. The team found that Agency staff addressed the issues in the incidents in a

comprehensive manner. Specifically, the staff responded to the incidents with inspections, in

one of the cases within an hour, prepared inspection reports, and followed up the cases with

the licensee, the equipment manufacturer, and other Agreement States. Incidents were

reported to the NRC. The incidents that the team reviewed regarding SS&D issues are listed in

Appendix E.
Arizona Final Report Page 17

The team conducted a search of the NMED system to determine whether other incidents might

have taken place that were not registered by the Agency staff. No incidents were identified that

could have been related to malfunctioning devices or products considered during the review.

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

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

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

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

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

disposal authority without the need of an amendment. Although the Arizona Agreement State

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

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

State for a LLRW disposal facility. When an Agreement State has been notified or becomes

aware of the need to regulate a LLRW disposal facility, they are expected to put in place a

regulatory program which will meet the criteria for an adequate and compatible LLRW disposal

program. There are no plans for a LLRW disposal facility in Arizona. Accordingly, the review

team did not review this indicator.

5.0 SUMMARY

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

satisfactory for the five common performance indicators and the non-common performance

indicator, Sealed Source and Device Evaluation Program, and satisfactory with

recommendations for improvement for the non-common performance indicator, Legislation and

Program Elements Required for Compatibility. Accordingly, the review team recommended and

the MRB concurred in finding the Arizona Agreement State program to be adequate and

compatible with NRC's program. Based on the results of the current IMPEP review, the next full

review will be in approximately four years.

Below are the recommendations, as mentioned earlier in the report, for evaluation and

implementation, as appropriate, by the State.
Arizona Final Report Page 18

RECOMMENDATIONS:

1. The review team recommends that the Agency review all Arizona licenses to ascertain if

they require financial assurance, and take appropriate action on each affected license to

ensure that all licenses meet the State’s financial assurance requirements. (Section

3.4)

2. The team recommends that the Agency reexamine their procedure for handling

allegations, consider the key elements of procedures outlined in NRC’s Management

Directive 8.8, and incorporate the elements that are appropriate for their program. 

(Section 3.5)

3. The team recommends that the Program submit legally binding requirements to NRC for 

review. (Section 4.1.2)

4. The team recommends that the Agency review its procedures to improve the timeliness

in incorporating new rule changes into their regulatory program, including immediately

addressing the reporting requirements for generally licensed device distributors which

was due by August 16, 2001. (Section 4.1.2)

5. The review team recommends that the Agency make corrections to the SS&D

registration certificates Nos. AZ-244-D-101-S and AZ-244-D-102-S. (Section 4.2.1)

6. The review team recommends that the Agency establish qualification requirements for

SS&D reviewers and develop a formalized, written training program. (Section 4.2.2). 
LIST OF APPENDICES AND ATTACHMENTS

Appendix A IMPEP Review Team Members

Appendix B Arizona Organization Chart

Appendix C Inspection Casework Reviews

Appendix D License Casework Reviews

Appendix E Incident Casework Reviews

Appendix F Sealed Source & Device Casework Reviews

Attachment April 25, 2002 Letter from Aubrey V. Godwin

Arizona’s Response to Draft IMPEP Report
APPENDIX A

IMPEP REVIEW TEAM MEMBERS

Name Area of Responsibility

Cardelia Maupin, STP Team Leader

Technical Staffing and Training

Vivian Campbell, RIV Technical Quality of Licensing Actions

Response to Incidents and Allegations

Roberto J. Torres, STP Legislation and Program Elements Required for

Compatibility

John Jankovich, NMSS Sealed Source and Device Evaluation Program

Lee Cox, NC Status of Materials Inspection Program

Technical Quality of Inspections

Inspector Accompaniments
APPENDIX B

ARIZONA ORGANIZATION CHART

ML020860628
APPENDIX C

INSPECTION CASEWORK REVIEWS

NOTE: CASEWORK LISTED WITHOUT COMMENT ARE INCLUDED FOR COMPLETENESS

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

File No.: 1

Licensee: St. Luke’s Medical Center License No.: 07-76

Location: Phoenix, AZ Inspection Type: Routine, Unannounced

License Type: Medical Institution Priority: 1

Inspection Date: 9/22 & 25/00 Inspector: JW

File No.: 2

Licensee: Phoenix National Laboratories, Inc. License No.: 07-415

Location: Phoenix, AZ Inspection Type: Routine, Unannounced

License Type: Industrial Radiography Priority: 1

Inspection Date: 4/10/01 Inspector: JN

File No.: 3

Licensee: Mayo Clinic Arizona License No.: 07-448

Location: Scottsdale, AZ Inspection Type: Routine, Unannounced

License Type: Broad Medical Priority: 1

Inspection Date: 10/30/01 Inspector: JN, GS, WY

File No.: 4

Licensee: Syncor International Corporation License No.: 10-84

Location: Tucson, AZ Inspection Type: Routine, Unannounced 

License Type: Nuclear Pharmacy Priority: 1

Inspection Date: 3/29/01 Inspector: JN, GS

File No.: 5

Licensee: University of Arizona License No.: 10-44

Location: Tucson, AZ Inspection Type: Routine, Unannounced

License Type: Broad Medical Priority: 1

Inspection Date: 2/26/01 Inspector: JN, GS, JW, WW

File No.: 6

Licensee: Good Samaritan Regional Medical Center License No.: 07-478

Location: Phoenix, AZ Inspection Type: Routine, Announced

License Type: Broad Medical Priority: 1

Inspection Date: 5/1/01 Inspector: JN, GS, JW

File No.: 7

Licensee: Radiation Safety Engineering, Inc. License No.: 07-192

Location: Chandler, AZ Inspection Type: Routine, Unannounced

License Type: Health Physics Priority: 3

Inspection Date: 3/30/99 Inspector: JW

File No.: 8
Arizona Final Report Page C.2

Inspection Casework Reviews

Licensee: Valley Lutheran Medical Center License No.: 07-251

Location: Mesa, AZ Inspection Type: Routine, Unannounced

License Type: Medical Priority: 2

Inspection Date: 1/24/00 Inspector: JN

File No.: 9

Licensee: Mesa Lutheran Hospital License No.: 07-127

Location: Mesa, AZ Inspection Type: Routine, Announced

License Type: Medical Priority: 2

Inspection Date: 11/30/99 Inspector: JN

File No.: 10

Licensee: Honeywell, Inc. License No.: 07-316

Location: Phoenix, AZ Inspection Type: Routine, Unannounced 

License Type: Limited Industrial Priority: 3

Inspection Date: 11/4/99 Inspector: GS, JW

INSPECTOR ACCOMPANIMENTS

In addition, the following inspection accompaniments were performed as part of the IMPEP

review.

Accompaniment No.: 1

Licensee: AMEC Earth and Environmental License No.: 07-369

Location: Phoenix, AZ Inspection Type: Unannounced, Routine

Type: Industrial Radiography Priority: 1

Inspection Date: 2/25/02 Inspector: JN

Accompaniment No.: 2

Licensee: Arrowhead Community Hospital License No.: 07-328

Location: Glendale, AZ Inspection Type: Unannounced, Routine 

License Type: Medical Institution-HDR Priority: 1

Inspection Date: 7/25/01 Inspector: GS
APPENDIX D

LICENSE CASEWORK REVIEWS

NOTE: CASEWORK LISTED WITHOUT COMMENT ARE INCLUDED FOR COMPLETENESS

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

File No.: 1

Licensee: Phoenix Regional Medical Center License No.: 07-120

Location: Phoenix, AZ Amendment No.: 61

License Type: Medical Institution Type of Action: Termination

Date Issued: 3/10/00 License Reviewer: DK

File No.: 2

Licensee: AMMTEC Consulting, Inc. License No.: 07-473

Location: Tempe, AZ Amendment No.: 0

License Type: Portable Gauge Type of Action: New

Date Issued: 5/2/00 License Reviewer: DK

Comment:

a) License authorizes Am-241 sealed sources with no total possession limit. The license

does not contain a condition limiting possession to quantities not requiring financial

assurance.

File No.: 3

Licensee: Sonora Veterinary Specialists License No.: 07-498]

Location: Phoenix, AZ Amendment No.: 0

License Type: Veterinary Medicine Type of Action: New

Date Issued: 1/28/02 License Reviewer: DK

File No.: 4

Licensee: Scottsdale Cardiovascular Center, P.C. License No.: 07-479

Location: Scottsdale, AZ Amendment No.: 0

License Type: Medical Private Practice Type of Action: New

Date Issued: 9/8/00 License Reviewer: DK

File No.: 5

Licensee: Welenco, Incorporated License No.: 07-300

Location: Bakersfield, CA Amendment No.: 18

License Type: Well Logging (temporary job site only) Type of Action: Amendment

Date Issued: Pending License Reviewer: DK

File No.: 6

Licensee: Radiocat, L.L.C. License No.: 07-455

Location: Phoenix, AZ Amendment No.: 4

License Type: Veterinary Medicine Type of Action: Amendment

Date Issued: 5/29/01 License Reviewer: DK
Arizona Final Report Page D.2

License Casework Reviews

File No.: 7

Licensee: Regenesis Biomedical, Inc. License No.: 07-439

Location: Scottsdale, AZ Amendment No.: 2

License Type: Research and Development, Limited Type of Action: Amendment

Date Issued: 2/5/01 License Reviewer: DK

File No.: 8

Licensee: University Medical Center Corporation License No.: 10–44

 University Medical Center Board of Regents

 University of Arizona

Location: Tucson, AZ Amendment No.: 49

License Type: Broad Scope, Medical Type of Action: Amendment

Date Issued: 2/11/02 License Reviewer: DK

Comment:

a) The license authorizes quantities of radioactive material that require financial assurance

but does not contain a condition limiting possession to amounts below that requiring

financial assurance. 

File No.: 9

Licensee: Catholic Healthcare West II License No.: 07-24

 St. Joseph’s Hospital and Medical Center

Location: Phoenix, AZ Amendment No.: 99

License Type: Broad Scope, Medical Type of Action: Amendment

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

Comment:

a) The license authorizes quantities of radioactive material that require financial assurance

but does not contain a condition limiting possession to amounts below that requiring

financial assurance.

File No.: 10

Licensee: Board of Regents, University of Arizona License No.: 10-24

Location: Tucson, AZ Amendment No.: 59

License Type: Broad Scope, Academic Type of Action: Amendment

Date Issued: 1/18/01 License Reviewer: DK
Arizona Final Report Page D.3

License Casework Reviews

File No.: 11

Licensee: Board of Regents, Arizona State University License No.: 07-37

Location: Tempe, AZ Amendment No.: 71

License Type: Broad Scope, Academic Type of Action: Amendment

Date Issued: 4/13/01 License Reviewer: DK

Comment:

a) The license authorizes quantities of unsealed radioactive material that require financial

assurance. However, during the renewal, the licensee’s statement of intent addressed

only the cobalt-60 sealed sources. The license does not contain a condition limiting

possession of unsealed radioactive material to amounts below that requiring financial

assurance.

File No.: 12

Licensee: Midwestern University - Glendale Campus License No.: 07-466

Location: Glendale, AZ Amendment No.: 3

License Type: Limited Academic, Research and Development Type of Action: Amendment

Date Issued: 2/13/02 License Reviewer: DK

Comment:

a) The license authorizes quantities of radioactive material that require financial assurance

but does not contain a condition limiting possession to amounts below that requiring 

financial assurance.

File No.: 13

Licensee: Short/Dolan Investments, Canyon State Inspection License No.: 10-101

Location: Tucson, AZ Amendment No.: 23

License Type: Industrial Radiography Type of Action: Renewal

Date Issued: 2/16/00 License Reviewer: DK

File No.: 14

Licensee: Medi-Physics, Incorporated, Amersham Health License No.: 07-346

Location: Phoenix, AZ Amendment No.: 25

License Type: Nuclear Pharmacy Type of Action: Renewal

Date Issued: 9/24/99 License Reviewer: DK

File No.: 15

Licensee: Catholic Health Care West II License No.: 07-424

 Saint Joseph’s Medical Center

Location: Phoenix, AZ Amendment No.: 3

License Type: Gamma Stereotactic Radiosurgery Type of Action: Renewal

Date Issued: 10/2/01 License Reviewer: DK
Arizona Final Report Page D.4

License Casework Reviews

FORMERLY LICENSED SITES

In addition, these sites formally licensed by the NRC were reviewed:

File No.: 16

Licensee: Western Technologies License No.: 02-21033-01

Location: Phoenix, AZ Docket No.: 30-19684

License Type: Moisture Density Gauge Type of Action: Termination

Date Issued: 06/87

Comment: 

a) The license only listed sealed sources and provided no final disposition. This project

was never activated. The Troxler Model 3411 moisture/density gauges for measurement

of properties of construction materials were never possessed by the licensee in Arizona.

The site will be closed with no further action. 

File No.: 17

Licensee: International Harvester, Co. License No.: 12-920-01

Location: Phoenix, AZ Docket No.: Unknown

License Type: Tracer and Material Wear Type of Action: Termination

Date Issued: 07/64

Comment: 

a) The license authorized the use of isotopes P-32, La-140, Cr-51, Mn-56, Fe-59, Au-198

and various irradiated hardware for oil and parts wear analyses and provided no final

disposition. Ten soil samples were taken at the site. No tracer materials were detected

according to results from the Agency Laboratory dated February 5, 2002. The site will

be closed in the near future.

File No.: 18

Licensee: Southwest Metal Industries License No.: C-05180

Location: Phoenix, AZ Docket No.: 40-2113

License Type: Fabrication Type of Action: Termination

Date Issued: 07/61

Comment: 

a) The license authorized the use of up to 290 pounds of mag-thorium alloy and sands and

provided no disposition of material, final close-out survey or AEC inspection. Four soil

samples were taken at the site. It appears that there is no thorium/magnesium alloy

present at the site according to results from the Agency Laboratory dated February 4,

2002. The site will be closed in the near future.
Arizona Final Report Page D.5

License Casework Reviews

File No.: 19

Licensee: INFILCO License No.: C-03575

Location: Tucson, AZ Docket No.: 40-1479

License Type: Research and Development Type of Action: Termination

Date Issued: 09/58

Comment: 

a) The license authorized the use of uranium in pilot plant studies demonstrating acid

leaching and extraction using ion exchange and provided no disposition of material, final

close-out survey or AEC inspection. Sixteen soil samples were taken at the site and

evaluated for the presence of uranium oxide. No presence of uranium oxide was found

according to results from the Agency Laboratory dated February 13, 2002. The site will

be closed in the near future.

File No.: 20

Licensee: Airsearch Manufacturing, Co., License No.: 02-07592-01

Location: Phoenix, AZ Docket No.: Unknown

cense Type: Research and Development Type of Action: Termination

Date Issued: 08/63

Comment:

a) The license authorized the use of uranium in aircraft and missile systems and provided

no disposition of material, final close-out survey or AEC inspection. The Agency is

currently unable to locate the site. 
APPENDIX E

INCIDENT CASEWORK REVIEWS

NOTE: CASEWORK LISTED WITHOUT COMMENT ARE INCLUDED FOR COMPLETENESS

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

File No.: 1

Licensee: Superior Testing Inc. Licensee No.: 09-013

Site of Incident: Show Low, AZ Incident Log No.: None

Date of Incident: 8/8/98 Type of Incident: Stolen Portable Gauge

Investigation Date: 8/10/98 Type of Investigation: Telephone

Summary of Incident and Final Disposition: On August 8, 1998, the licensee advised the

Agency that their office had been vandalized and a portable gauge had been stolen. The

gauge was returned to the owner on August 24, 1998.

Comment:

a) The Agency’s records indicate that NRC was notified, however, the event is not

identified in NMED. The record will be provided to INEEL.

File No.: 2

Licensee: Ricker, Atkinson, McBee and Associates Licensee No.: 07-406

Site of Incident: Mesa, AZ Incident Log No.: NMED 010138

Date of Incident: 2/13/01 Type of Incident: Stolen Portable Gauge

Investigation Date: 2/13/01 Type of Investigation: Onsite

Summary of Incident and Final Disposition: The licensee reported the theft of a portable

Troxler moisture/density gauge. The gauge was stolen from the cab of a truck parked in Mesa,

Arizona. A licensee employee had secured the gauge within its transport container and chained

it in the cab of the vehicle for overnight storage. The gauge was recovered from a pawn shop

with locks intact. 

Comment:

a) The Agency’s records indicate that NRC was provided the supplemental information. 

However, the updated information is not in NMED. The record will be provided to

INEEL.
Arizona Final Report Page E.2

Incident Casework Reviews

File No.: 3

Licensee: Phelphs Dodge Licensee No.: 13-005

Site of Incident: Bagdad, AZ Incident Log No.: None

Date of Incident: 10/30/00 Type of Incident: Lost Radioactive Material

Investigation Date: 11/1/00 Type of Investigation: Phone

Summary of Incident and Final Disposition: On October 30, 2000, the licensee advised the

Agency that a cadmium-109 source was missing. The licensee was unsure of the date of the

incident. The source was last accounted during an inventory conducted January 1998. The

Agency planned to investigate at the next scheduled inspection.

Comment:

a) The Agency’s records indicate that NRC was provided the supplemental information. 

However, the updated information is not in NMED. The record will be provided to

INEEL.

File No.: 4

Licensee: Board of Regents, University of Arizona Licensee No.: 10-024

Site of Incident: Tucson, AZ Incident Log No.: NMED 000698

Date of Incident: 7/22/00 Type of Incident: Release of Radioactive Material

Investigation Date: 9/6/00 Type of Investigation: Telephone

Summary of Incident and Final Disposition: The licensee reported that approximately

3.7 megabequerel (100 microcuries) of hydrogen-3 had been removed from a laboratory by the

custodial staff. While investigating this event, the licensee discovered that a release of

1.15 gegabequerel (31 millicuries) of hydrogen-3 was released for a fume hood stack. The

Agency required the licensee to conduct an evaluation. The Agency reviewed the licensee’s

report and accepted the results.

Comment:

a) There is no record that the follow-up information has been reported to NMED.

File No.: 5

Licensee: Board of Regents, Arizona State University Licensee No.: 07-037

Site of Incident: Tempe, AZ Incident Log No.: NMED 990961

Date of Incident: 11/17/99 Type of Incident: Lost Radioactive Material

Investigation Date: 12/20/99 Type of Investigation: Onsite

Summary of Incident and Final Disposition: The licensee reported that a vial containing

4.6 megabequerel (0.123 millicuries) phosphorus-32 labeled ATP was missing from a

laboratory. The material was placed in storage on November 17, 1999. The loss was detected

on December 15, 1999. The licensee and the Agency conducted an investigation. The

material has not been recovered.
Arizona Final Report Page E.3

Incident Casework Reviews

File No.: 6

Licensee: Maxim Technologies, Inc Licensee No.: 07-168

Site of Incident: Chandler, AZ Incident Log No.: NMED 010285

Date of Incident: 3/20/01 Type of Incident: Stolen Portable Gauge

Investigation Date: 3/21/01 Type of Investigation: Onsite

Summary of Incident and Final Disposition: The licensee reported the theft of a Troxler

moisture/density gauge. The truck with the gauge secured in the bed were stolen from a

shopping area in Chandler, AZ. The local police were immediately notified and the licensee

offered a reward for the return of the gauge. The material has not been recovered.

File No.: 7

Licensee: Maxim Technologies Inc. Licensee No.: 07-168

Site of Incident: Phoenix, AZ Incident Log No.: NMED 981135

Date of Incident: 11/14/98 Type of Incident: Stolen Portable Gauge

Investigation Date: 11/16/98 Type of Investigation: Onsite

Summary of Incident and Final Disposition: On November 14, 1998, the licensee reported the

theft of a Troxler moisture/density gauge from an open bed truck while parked in front of an

employee’s home. The gauge was secured to the bed of the truck. On November 16, 1998,

the Agency reported that the gauge case was recovered. However, the gauge is still missing.

File No.: 8

Licensee: FNF Construction Inc. Licensee No.: 07-373

Site of Incident: Tempe, AZ Incident Log No.: NMED 980810

Date of Incident: 7/11/98 Type of Incident: Lost Portable Gauge

Investigation Date: 7/15/98 Type of Investigation: Onsite

Summary of Incident and Final Disposition: On July 11, 1998, the licensee reported the loss of

a Troxler density gauge. The gauge was reported missing from a temporary job site north of

Phoenix, AZ. On July 14, 1998, the gauge was recovered.

File No.: 9

Licensee: AllState Service Environmental Inc. Licensee No.: 07-458

Site of Incident: Phoenix, AZ Incident Log No.: None

Date of Incident: 7/10/00 Type of Incident: Loss of Radioactive Material

Investigation Date: 7/24/00 Type of Investigation: Onsite

Summary of Incident and Final Disposition: On July 24, 2000, the licensee notified the Agency

that a lead paint analyzer containing cobalt-57 was missing. A former employee had taken the

device to conduct work, but has not reported for work since. The licensee finally contacted the

former employee, who had been out-of-town on personal business, and recovered the gauge.
Arizona Final Report Page E.4

Incident Casework Reviews

File No.: 10

Licensee: Maxim Technologies, Inc. Licensee No.: 07-168

Site of Incident: Framonto jobsite Incident Log No.: None

Date of Incident: 5/15/01 Type of Incident: Damage to Equipment

Investigation Date: 5/15/01 Type of Investigation: Onsite

Summary of Incident and Final Disposition: On May 15, 2001, the licensee notified the Agency

that a portable gauge had been run over by a water tanker while at a temporary job site at

Highway 17 and Carefree Highway. The source was maintained in the shielded position. Only

the device was damaged. The device was leak tested and the results were negative. The

Agency conducted a special inspection.

File No.: 11

Licensee: Geotech and Environmental Licensee No.: 07-402

Site of Incident: Chandler, AZ Incident Log No.: None

Date of Incident: 11/3/00 Type of Incident: Damage to equipment

Investigation Date: 11/3/00 Type of Investigation: Onsite

Summary of Incident and Final Disposition: On November 3, 2000, the licensee notified the

Agency that a portable gauge had been run over by a front-end loader. The depth rod had

been bent and broken. However, there was no damage to the source. The Agency conducted

an onsite investigation and confirmed that the source was not damaged. The gauge was

repaired and put back in service.

File No.: 12

Licensee: Foree and Vann Inc. Licensee No.: 07-263

Site of Incident: Horizon, AZ Incident Log No.: None

Date of Incident: 3/9/00 Type of Incident: Damage to the equipment

Investigation Date: 3/9/00 Type of Investigation: Onsite

Summary of Incident and Final Disposition: On March 9, 2000, the licensee notified the Agency

that a vehicle carrying a portable gauge had been involved in a traffic accident. The Agency

conducted a site investigation and determined that only the licensee’s vehicle was damaged. 

The incident was closed.

File No.: 13

Licensee: Northwest Surveying Licensee No.: 08-24

Site of Incident: Lake Havasu City, AZ Incident Log No.: None

Date of Incident: 9/18/00 Type of Incident: Loss of Control

Investigation Date: 9/18/00 Type of Investigation: Telephone

Summary of Incident and Final Disposition: On September 18, 2000, the licensee notified the

Agency that a portable gauge had been taken by the wife (co-owner) of the owner because of a

domestic dispute. The gauge was returned to the permanent storage facility on the same day. 

Although the police were notified, no charges could be filed. The incident was closed. 

File No.: 14
Arizona Final Report Page E.5

Incident Casework Reviews

Licensee: Speedie & Associates Licensee No.: 07-209

Site of Incident: Tucson, AZ Incident Log No.: None

Date of Incident: 11/11/00 Type of Incident: Stolen Portable Gauge

Investigation Date: 11/13/00 Type of Investigation: Telephone

Summary of Incident and Final Disposition: On November 11, 2000, the licensee notified the

Agency that a portable gauge and truck had been stolen. The local police were notified. The

truck and the gauge were recovered the same day. The gauge found undisturbed in the bed of

the truck. 

Comment:

a) No record reporting the loss and recovery of the gauge could be found by the team.

File No.: 15

Licensee: Navapache Hospital Licensee No.: 09-011

Site of Incident: Show Low, AZ Incident Log No.: None

Date of Incident: 2/25/99 Type of Incident: Overexposure

Investigation Date: 3/23/99 Type of Investigation: Telephone

Summary of Incident and Final Disposition: On March 23, 1999, the Agency received written

notification from the licensee informing them of a possible overexposure. However, the

licensee expressed doubt regarding the validity of this overexposure. The licensee had

received film badge results on February 25, 1999, indicating that a whole body exposure of

21,375 millirem and extremity exposure of 9223 millirem for one of their nuclear medicine

personnel. On April 21, 1999, the Agency requested additional information by letter. On 

April 27, 1999, the technologist provided a statement describing his activities during that period

and acknowledging his belief that the exposure was not real. The licensee obtained the

services of a consultant to evaluate the exposure. In a letter dated June 23, 1999, the

consultant provided his evaluation of the exposure and demonstrated that the exposure was not

possible. In a letter dated August 11, 1999, the Agency acknowledged that they accepted the

licensee’s evaluation.

Comments:

a) No record reporting the potential overexposure could be found by the team.
Arizona Final Report Page E.6

Incident Casework Reviews

File No.: 16

Licensee: Scottsdale Memorial Hospital Licensee No.: 07-265

Site of Incident: Scottsdale, AZ Incident Log No.: 99-17

Date of Incident: 11/18/99 Type of Incident: I-125 seed rapture

Investigation Date: 11/22-29/99 Type of Investigation: Onsite Inspections

Summary of Incident and Final Disposition: The licensee reported that they identified an I-125

seed source during brachytherapy procedure which contained only three seeds instead of five. 

The Agency conducted site inspections after the incident, and notified NRC and the Agreement

State who licensed the seed manufacturer. The Agency also compiled quality assurance

reports from the manufacturer, distributor, and the user (licensee) showing no defective units in 

the product lot of the seed source. The Agency compiled technical reports from the attending

physician and the radiology staff. The Agency analyzed the information and concluded that the

cause was indeterminable, but requested that the licensee provide training for the hospital staff. 

The analysis as well as the training records for the hospital staff are well documented.

Comments:

a) The inspection report was not generated shortly after the inspection. The inspection

report, dated February 29, 2000, was generated in response to the “Information

Request for NMED Item 000074," e-mail to the Agency from INEEL/Hunstman, dated

February 17, 2000.

b) The Agency’s RAD report properly documented the disposition. The person who made

the disposition dated his resolution only, but did not sign or initialize the decision,

making traceability of this one record incomplete. The team found the rest of the file

complete. 

File No.: 17

Licensee: Good Samaritan Regional Medical Center Licensee No.: 07-478

Site of Incident: Phoenix, AZ Incident Log No.: 01-11

Date of Incident: 11/30/01 Type of Incident: Beta-Cath Source Train Failure

Investigation Date: 11/30/01 Type of Investigation: Onsite

Summary of Incident and Final Disposition: The licensee reported that, during a test run of a

Novoste Beta-Cath system before commencing the procedure for the patient, a catheter failed

and five seeds were found on the floor, and one seed was trapped in the device. The Agency

responded to the incident with a site response within an hour, and determined with the licensee

that all seeds were accounted for. The device was sent back to the manufacturer to determine

the cause of the failure. The Agency prepared a comprehensive inspection report, dated

December 3, 2001, in a timely manner shortly after the incident. The Agency notified the NRC

and the Agreement State who licensed the manufacturer. The file contained complete records

about the Agency’s contacts with the manufacturer. The case was still open at the time of the

review. The team noted that the Agency was properly tracking the incident. Specifically, the

Agency requested a final report on the incident and reminded the licensee that such an incident

should be concluded in a timely manner (letter to the licensee dated February 13, 2002). 
APPENDIX F

SEALED SOURCE AND DEVICE (SS&D) CASEWORK REVIEWS

File No.: 1

Registry No.: AZ-244-D-101-S SS&D Type: Reference Light Source

Manufacturer: TLS Systems, Inc. Model No.: 40108A

Date Issued: 3/5/93

Comments:

a) Assignment of the registration number is incorrect. The product is a source which is

distributed to both general and specific licensees. The registration number that

expresses these conditions is: AZ-244-S-101-B.

b) Typographic error: Section entitled “DETAILS OF CONSTRUCTION” refers to

Attachment 1. It should read Attachment 2.

File No.: 2

Registry No.: AZ-244-D-102-S SS&D Type: Reference Light Source

Manufacturer: TLS Systems, Inc. Model No.: 40111

Date Issued: 1/24/98

Comments:

a) File did not contain the final certificate as transmitted to NRC, only a draft, marked-up

copy of the certificate. In addition, the review team was unable to locate Agency

records documenting the amendment and issuance of the certificate or the transmittal of

the document to the NRC for national distribution.

b) Assignment of the registration number is incorrect. The product is a source which is

distributed to both general and specific licensees. The registration number that

expresses these conditions is: AZ-244-S-102-B.

c) The certificate did not include the section entitled “External Radiation Level.”

d) The illustrations that are referenced in Section “DETAILS OF CONSTRUCTION” as

Attachments 1 and 2 were not part of the registration and were not marked as the

attachments. These attachments need to be added to complete the registration

certificate.
Arizona Final Report Page F.2

Sealed Source and Device Casework Reviews

File No.: 3

Registry No.: None SS&D Type: Fuel Gauge 

Manufacturer: Honeywell, Inc. Model No.: Model WG1136AA01

License No.: 07-316, 7-320, 7-395

Date Issued: Not applicable (see comments)

Comment:

a) During the review of Honeywell licensing files, the team noted that Honeywell applied for

a materials license in a letter dated September 17, 1987. The enclosure to the letter

contained an imbedded application for a device in one of the sections which was entitled

“Manufacturing License Application” (Appendix D) to manufacture and distribute the

Model WG1136AA01, Fuel Quantity Indicating System (FQIS). The FQIS is a fuel

gauge for various aircraft. The device contains a source with 2.5 mCi (9.25 MBq) of

Am-241. The Agency issued a materials license to Honeywell in response to the

application. Following the review, the team confirmed through NRC records that prior to

moving to Arizona from Minnesota in 1987, NRC conducted a safety evaluation of the

Honeywell fuel gauge and approved the manufacture and distribution of the generally

licensed device. The Agency indicated that they reviewed the information that had been

submitted to the NRC and concluded that the device was acceptable for distribution. At

the time of the review, there was no certificate on the device because there is no

regulatory requirement to issue registration certificates. However, the issuance of

registration certificates is a common practice and the Agency has indicated that they will

provide the NRC a information certificate on the current status of the device. 
ATTACHMENT

April 25, 2002 Letter from Aubrey V. Godwin

Arizona’s Response to Draft IMPEP Report

ML021330507