July 24, 2006

Ronald F. Hammerschmidt, Ph.D.

Director, Division of Environment

Kansas Department of Health and Environment

1000 SW Jackson, Suite 400

Topeka, KS 66612-1367

Dear Dr. Hammerschmidt:

On July 11, 2006, the Management Review Board (MRB) met to consider the proposed final

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

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

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

The review team noted vast improvement in the performance of the Kansas Agreement State

Program. The Kansas program was placed on heightened oversight in June 2005 because of a

programmatic weakness in adopting compatible regulations in the required time frame. While

on site, the review team found that the Kansas Agreement State Program had successfully

adopted all overdue regulations. In addition, the review team noted that the Kansas program

became funded through a dedicated fee fund rather than a general fund as they had been

funded in the past. The dedicated fee fund will promote the timely training of newer staff by

having additional funds available to the program. Based on the review team’s findings for this

review, the MRB directed that the period of heightened oversight of the Kansas Agreement

State Program be discontinued.

The MRB noted that the Kansas Agreement State Program has made commendable efforts in

ensuring that initial and routine inspections of radioactive materials licensees in the State of

Kansas are completed in a timely manner. Given the ratio of the number of licensees to the

number of fully qualified inspectors, the MRB attributed a superior data management system as

an important factor in this achievement. Although all Agreement State programs utilize

inspection data management systems, the Kansas system is finely tailored to the radioactive

materials program and enhances the efficient and effective use of inspection resources.

Section 5.0, page 13, of the enclosed final report contains a summary of the IMPEP team’s

findings and recommendations. We request your evaluation and response to the

recommendations within 30 days from receipt of this letter. Based on the results of the current

IMPEP review, the next full review of the Kansas Agreement State Program will take place in

approximately four years, with a periodic meeting tentatively scheduled for April 2008.
R. Hammerschmidt - 2 -

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

I also wish to acknowledge your continued support for the Agreement State program and the

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

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

Sincerely,

/RA/

Martin J. Virgilio 

Deputy Executive Director for Materials, Research, 

 State and Compliance Programs

Office of the Executive Director for Operations

Enclosure: 

As stated

cc: Thomas A. Conley, Chief

Radiation and Asbestos Control Section

Kansas Bureau of Air and Radiation

Robert Greger, California

Organization of Agreement States

Liaison to the MRB
R. Hammerschmidt - 2 -

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

I also wish to acknowledge your continued support for the Agreement State program and the

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

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

Sincerely,

/RA/

Martin J. Virgilio 

Deputy Executive Director for Materials, Research, 

 State and Compliance Programs

Office of the Executive Director for Operations

Enclosure: 

As stated

cc: Thomas A. Conley, Chief

Radiation and Asbestos Control Section

Kansas Bureau of Air and Radiation

Robert Greger, California

Organization of Agreement States

Liaison to the MRB

Distribution: DCD (SP01) PDR (YEST)

DIR RF KCyr, OGC Chairman Klein

EDO RF JStrosnider, NMSS Commissioner McGaffigan

JLynch, RIII TCombs, OCA (2 copies) Commissioner Merrifield

VCampbell, RIV AKock, OEDO Commissioner Jaczko

JTobin, STP Commissioner Lyons

BParker, RI

EFordham, WA SUNSI Review Complete

MOrendi, ASPO : Publicly Available G Non-Publicly Available

CMiller, NMSS/IMNS : Non-Sensitive G Sensitive

RStruckmeyer, NMSS/IMNS

STreby, OGC

JGray, OGC

TCombs, CA (2)

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OFFICE STP STP:DD STP:D DEDMRS

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(DKRathbun for)

MJVirgilio

DATE 7/17/06 7/17/06 7/17/06 7/24/06

OFFICIAL RECORD COPY
INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM

REVIEW OF KANSAS AGREEMENT STATE PROGRAM

April 18-21, 2006

FINAL REPORT

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

1.0 INTRODUCTION

This report presents the results of the review of the Kansas Agreement State Program. The

review was conducted during the period of April 18-21, 2006, by a review team comprised of

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

Washington. 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 Final General Statement of Policy,” published in the Federal

Register on October 16, 1997, and the February 26, 2004, NRC Management Directive 5.6,

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

review, which covered the period of April 27, 2002, to April 21, 2006, were discussed with

Kansas management on the last day of the review.

A draft of this report was issued to Kansas for factual comment on May 18, 2006. The State

responded by letter on June 15, 2006, from Thomas A. Conley, Chief, Radiation, Asbestos &

Right-To-Know Section (the Section). The Management Review Board (MRB) met on July 11,

2006, to consider the proposed final report. The MRB found the Kansas Agreement State

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

Based on the results of the review, the review team recommended and the MRB agreed that

the period of heightened oversight be discontinued.

The Agreement State program is administered by the Section. The Section is part of the

Bureau of Air and Radiation (the Bureau) in the Division of Environment (the Division). The

Division is located within the Department of Health and Environment (the Department). 

Organization charts for the Division, Bureau and Section are included as Appendix B. At the

time of the review, the Kansas program regulated approximately 306 specific licenses, including

naturally occurring or accelerator-produced radioactive material (NARM). 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 Kansas.

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

performance indicators was sent to the Section on February 2, 2006. The Section provided its

response to the questionnaire on April 3, 2006. A copy of the questionnaire response may be

found on the NRC’s Agencywide Documents Access and Management System (ADAMS) using

the Accession Number ML061020369.

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

the Section’s response to the questionnaire; (2) review of applicable Kansas statutes and

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

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

accompaniments of three Kansas inspectors; and (6) interviews with staff and management to

answer questions or clarify issues. The review team evaluated the information gathered

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

and made a preliminary assessment of the Agreement State program’s performance.

Section 2 below discusses the State’s actions in response to recommendations made following

the previous IMPEP 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-
Kansas Final Report Page 2

common performance indicators, and Section 5 summarizes the review team's findings and

recommendations. The recommendations made by the review team are comments that relate

directly to program performance by the State. A response is requested from the State to all

recommendations in the final report.

2.0 STATUS OF ITEMS IDENTIFIED IN PREVIOUS REVIEWS

During the previous IMPEP review, which concluded on April 26, 2002, four recommendations

were made and the results were transmitted to Clyde D. Graeber, Secretary of the Department,

on December 13, 2002. In June 2005, the Management Review Board (MRB) concluded that

the Kansas Agreement State Program should undergo a period of heightened oversight

because of a programmatic weakness in adopting compatible regulations in the required

timeframe. The MRB based its decision on the results of the 2002 IMPEP review, the

November 2003 periodic meeting with the State, and the results of quarterly monitoring calls

held between Kansas and NRC staff. The MRB concluded that heightened oversight would

provide a process for NRC to monitor the State’s completion of the adoption of final compatible

regulations.

The review team’s evaluation of the current status of the recommendations is as follows:

1. The team recommends the State ensure that the Agreement Materials Program has

adequate resources and an adequate complement of qualified staff. (Section 3.3 of the

2002 report)

Current Status: The State adopted a radiation control fee fund in 2004 which provides

adequate resources to the Agreement State program. After suffering significant staff

losses during the review period, the Section is now fully staffed, in part due to revenue

from the fee fund. Although the newer staff members are well educated and capable to

contribute to the Agreement State program, additional training and experience is

necessary before the Section has an adequate complement of fully qualified staff. The

review team recommends that this recommendation remain open, pending further staff

training and experience.

2. The review team recommends that the Program review all Kansas’ 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 of the 2002 report)

Current Status: The Section completed a review of all Kansas licenses with regard to

the need for financial assurance and now appropriately requires certain licensees to

maintain financial assurance for decommissioning. The Section should ensure that

those licensees with financial assurance in place appropriately increased the amounts in

accordance with the revised Kansas regulations that were implemented in December

2005, which included revised financial assurance amounts compatible with NRC

regulations. This recommendation is closed.
Kansas Final Report Page 3

3. The team recommends that, when the Bureau uses legally binding requirements as

alternates to rules, it submit the text of the requirements to NRC for review. (Section

4.1.1 of the 2002 report)

Current Status: The review team confirmed that current legally binding requirements,

such as the increased controls license conditions, were submitted to NRC for approval,

as required. Section management is aware that, in the future, if requirements are used

in lieu of regulations, the text of those requirements needs to be reviewed by the NRC. 

This recommendation is closed.

4. The review team recommends the Bureau adopt the regulations “Timeliness in

Decommissioning of Materials Facilities,” and “Preparation, Transfer for Commercial

Distribution, and Use of Byproduct Material for Medical Use,” or adopt generally

applicable legally binding alternatives to the regulations. (Section 4.1.1 of the 2002

report)

Current Status: The referenced regulations were adopted. 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 include: (1) Technical Staffing and

Training, (2) Status of Materials Inspection Program, (3) Technical Quality of Inspections, (4)

Technical Quality of Licensing Actions, and (5) Technical Quality of Incident and Allegation

Activities.

3.1 Technical Staffing and Training

Issues central to the evaluation of this indicator include the Section’s 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 Section’s questionnaire response relative to this

indicator; interviewed Division management and staff; and reviewed job descriptions, training

plans, and training records. The review team also considered any possible workload backlogs

in evaluating this indicator; however, no licensing or inspection casework backlogs were

identified.

The Section Chief supervises three administrative staff and three unit supervisors. The

Materials Supervisor is responsible for the radioactive materials program which employs five

Environmental Scientists, who perform both licensing and inspection duties. The Section

devotes approximately 4.7 full time equivalent (FTE) to the radioactive materials program, of

which approximately 3.0 FTE are allotted for licensing and inspection. The remaining 1.7 FTE

includes program management and administrative support. The FTE support for the

radioactive materials program is expected to increase to approximately 6.5 FTE as the x-ray

program staffing increases and the majority of x-ray duties that are now being performed by

radioactive materials staff are transferred to the new x-ray staff members.
Kansas Final Report Page 4

On January 1, 2006, the radiation control inspector classification was changed to Environmental

Scientist. The reclassification resulted in a five percent raise for the staff, and gives employees

better career progression potential. The reclassification also gives the Section a larger pool of

applicants to fill vacancies.

The 2002 IMPEP review team noted that the program had only two staff members fully qualified

to perform license reviews and inspections. The review team concluded that the lack of

adequate staff was a root cause of weaknesses observed in the radioactive materials program. 

Since the last review, the program lost several staff members. Four radiation control inspectors

left the program for other employment opportunities in December 2002, November 2003,

January 2004, and November 2004. A temporary employee, involved primarily with a large

decommissioning project, was not rehired after his contract was completed in June 2004.

By May 2005, all of the vacated positions, other than the temporary position, had been re-filled. 

In April 2006, the remaining vacant radioactive materials Environmental Scientist position was

filled and a new support position, reporting to the Section Chief, was also hired. 

Responsibilities of the support position include maintaining regulations up-to-date, providing

training for technical staff and providing outreach to Kansas licensees. At the time of the

review, the Kansas Agreement State Program was fully staffed.

Two of the Environmental Scientists are fully qualified to perform both licensing and inspection

activities. The other three Environmental Scientists have bachelor’s degrees and have limited

experience in the radioactive materials area. Those staff members have attended the two-week

NRC-sponsored Basic Health Physics Course, as well as the NRC’s Inspection Procedures

Course and the NRC’s Licensing Practices and Procedures Course. These three staff

members also attended the Safety Aspects of Industrial Radiography course, the week after

this IMPEP review. The Section Chief stated that additional training, such as medical and well

logging courses, is being scheduled as work schedules, funding and training dates allow. In

addition to the core technical training, two of the Environmental Scientists have attended the

NRC Security training course. Two others are scheduled to attend the Security training courses

scheduled for May and June 2006, respectively.

The Section has a documented qualification and training plan that is consistent with the

guidance in the NRC/Organization of Agreement States Training Working Group Report and

the NRC’s Inspection Manual Chapter (MC) 1246. The Section also uses on-the-job training to

supplement the course work so that individuals may broaden their work areas. Emphasis is

placed on cross-training so that staff develop skills applicable to other areas, such as x-ray. 

Newer staff members are assigned increasingly complex licensing duties under the direction of

the Materials Supervisor and accompany more experienced inspectors during increasingly

complex inspections. Inspectors are assigned independent inspections after demonstrating

competence during accompaniment evaluations by the Materials Supervisor.

The review team noted that the Section had stable funding during the review period. The

Section collects 100 percent of the budget from materials fees, which goes into a dedicated

fund. This radiation control fee fund became effective in October 2004 and allowed funding of

training, additional staff and new equipment.
Kansas Final Report Page 5

The State of Kansas does not have an oversight board or committee to provide direction to the

Agreement State program.

During the last IMPEP review, the review team made the following recommendation: “The team

recommends the State ensure that the Agreement Materials Program has adequate resources

and an adequate complement of qualified staff.” The Section has made significant progress

since the last IMPEP review in providing resources through a dedicated fee fund and obtaining

a fully staffed radioactive materials program. Due to staff retention issues, however, the

program still has only two fully qualified staff members to perform licensing and inspection

activities. As evidenced by inspector accompaniments performed as part of the review, Section

staff are progressing in their development, but need additional training and experience. For

that reason, the review team recommends that the recommendation mentioned above, remain

open until additional staff members are fully qualified to perform licensing and inspection

activities.

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

that Kansas’ performance with respect to the indicator, Technical Staffing and Training, be

found satisfactory, but needs improvement.

3.2 Status of Materials Inspection Program

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

inspections of Priority 1, 2, and 3 licensees; initial inspection of new licenses; timely dispatch of

inspection findings to licensees; and the performance of reciprocity inspections. The review

team’s evaluation is based on the Section’s response to the questionnaire relative to this

indicator, data gathered from the Section’s licensing and inspection database, the examination

of completed inspection casework, and interviews with managers and staff.

The review team’s evaluation of the Section’s inspection priorities verified that inspection

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

license types listed in MC 2800. During a 2005 self-assessment, Kansas staff discovered that

four storage-only licensees were being inspected less frequently than MC 2800 requirements. 

Staff increased the inspection frequency and achieved compatibility in March 2005. The

Section requires more frequent inspections for a number of license categories. Medical broad

scope programs, gamma knives, and nuclear pharmacies are inspected annually whereas MC

2800 allows a two year periodicity. Academic broad scope programs and research &

development licenses are inspected annually compared to the NRC’s three-year frequency. 

Small private nuclear medicine licenses are inspected on a two-year frequency compared to the

NRC’s three-year frequency. Portable gauge licenses are inspected on a four-year frequency

compared to the NRC’s five-year frequency for this type of license.

The Section tracks all inspection activities in a computer database. The team observed that the

database can easily be queried by program managers and staff members to determine

inspection status for any licensed facility.

In their response to the questionnaire, the Section indicated that there was only one inspection,

an academic broad scope program, currently overdue by more than 25 percent of the NRC’s

frequency. This licensee was cited for numerous compliance issues during the review period. 
Kansas Final Report Page 6

Consultations with licensee staff and management are on-going to correct the issues. During

the resolution period, a scheduled periodic inspection did not occur. Kansas staff considers

re-inspection a priority and have scheduled it to be performed in May 2006. Of 61 initial

inspections completed during the review period, only one was not conducted within one year of

license issuance. It was completed 15 months after license issuance.

The timeliness of the issuance of inspection findings was determined by the review team’s

evaluation of inspection casework. Completed inspection reports are reviewed and signed by

the Materials Supervisor. A majority of inspection letters regarding inspection results were sent

within 30 days of the inspection date. With nearly 500 inspections conducted during this review

period, only 26 letters were issued later than 30 days after the inspection. The longest overdue

letter was 123 days after an April 2004 inspection during the 2004-2005 timeframe when

program staffing was a primary concern.

Reciprocity was granted to 44 licensees in 2002, 30 licensees in 2003, 33 licensees in 2004,

26 licensees in 2005 and to 17 licensees thus far in 2006. The Section’s reciprocity inspection

goals are equivalent to the requirements in MC 1220 (20 percent for Priority 1, 2, and 3

licensees). The team found the Section inspected 12 percent of candidate reciprocity licensees

during the review period, which is less than MC 1220 reciprocity inspection requirements. The

review team recommends that the State place greater emphasis and resource allocation

towards reciprocity inspections in accordance with program goals and the criteria in MC 1220.

The review team examined the licensees that the Section had determined met the criteria for

the increased controls, as per COMSECY-05-0028. The review team determined that the

Section had correctly identified the Kansas licensees that require increased controls based on

this criteria. The Section has prioritized its licensees and started to plan for the initial set of

inspections of these licensees in accordance with the increased control requirements.

The team also reviewed the Section's work on general licensees. The Section currently has 91

registered general licensees. Each year, the Section requires a confirmatory inventory and a fee

from registrants. General licensees are not normally inspected. Nationally, Kansas has joined

the Organization of Agreement States in petitioning the NRC for rulemaking concerning general

licenses (and specifically compatibility of regulations). Presently, compatibility with the NRC's

general license rule (10 CFR 31.5) is held in abeyance pending Commission action on the

petition. Additionally, the Section has a change to their general license regulations pending. 

The amendment is for certain detecting, measuring, gauging, or controlling devices and certain

devices designed for producing light or an ionized atmosphere (contained in K.A.R. 28-35-178b)

and will require further registration and timely response to written Section inquiries. When the

amendment is codified, the Section has identified nine general licensees that under new

regulations will be required to obtain a specific license due to exceeding threshold levels for

cesium-137, strontium-90, cobalt-60, and americium-241 (or other transuranic elements).

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

that Kansas’ performance with respect to the indicator, Status of Materials Inspection Program,

be found satisfactory.
Kansas Final Report Page 7

3.3 Technical Quality of Inspections

The review team evaluated the inspection reports and enforcement documentation and

interviewed inspectors for 23 radioactive materials inspections conducted during the review

period. The casework reviewed included work performed by eight of the Section’s radioactive

materials inspectors and covered a variety of license types including: academic broad scope,

medical (broad scope, diagnostic and therapy), high dose-rate remote afterloader, mobile

nuclear medicine, gamma stereotactic radiosurgery, industrial radiography, well logging,

manufacturing and distribution, and portable gauge. Appendix C lists the inspection casework

reviewed, with case-specific comments, as well as the results of the inspector accompaniments.

Based on the evaluation of the casework, the review team concluded that the routine inspections

covered all aspects of the licensees’ radiation programs. The review team found that inspection

reports were generally very thorough, complete, consistent, and of high quality, with sufficient

documentation to ensure that a licensee’s performance with respect to health and safety was

acceptable. The documentation supported violations, recommendations made to the licensee,

unresolved safety issues, and discussions held with the licensee during exit interviews. Team

inspections were frequently performed for larger and complex licensees and for training

purposes. The review team noted in the review of the documentation and in discussions with

staff, that although independent and/or confirmatory measurements are routinely conducted,

documentation of these surveys often did not contain all the information needed to validate the

surveys. The Materials Supervisor had previously identified this issue and was already working

with staff to ensure proper survey documentation. During the review of the industrial

radiography licenses, the review team noted that there was no documentation showing that

inspectors had reviewed the radiographers’ certification. Although not documented, the

inspection staff stated that certification was confirmed as part of the inspection.

The inspection findings were appropriate and prompt regulatory actions were taken, as

necessary. The Section issues inspection letters to licensees conveying the results of all

inspections. When a licensee is found in non-compliance, a written notice of non-compliance is

normally issued. The notice requires the licensee to provide a written statement responding to

the violations. Depending on the severity of the violations, the Section can place the licensee on

“heightened oversight,” which reduces the time between inspections. The Section can assess

civil penalties and orders to suspend or cease operations, based on the severity or safety

significance of the violations.

Supervisory accompaniments were conducted annually for all inspectors. The Materials

Supervisor discusses observations with each inspector during the accompaniment and uses

“inspection notes” to communicate general inspection guidance to the staff.

The Section has adequate numbers and types of radiation survey instruments to support their

radiation protection efforts. Instruments are calibrated by the manufacturer or in-house by the

Bureau. Appropriate, calibrated survey instruments such as Geiger-Mueller (GM) meters,

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

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

during the week of March 12, 2006. Inspection accompaniments included: an industrial

radiographer, a veterinary teletherapy licensee and a hospital. These accompaniments and
Kansas Final Report Page 8

associated reviewer comments are identified in Appendix C. During the accompaniments, each

inspector demonstrated appropriate performance-based inspection techniques and knowledge of

the regulations. The inspectors were generally trained, prepared, and thorough in their audits of

the licensees radiation safety programs, however, room for improvement was noted as specified

in the Appendix. The review team conveyed the need for additional staff training to Section

management. Overall, each inspector utilized good health physics practices. Interviews with

licensee personnel were performed in an effective manner, and the inspections were adequate

to assess radiological health and safety at the licensed facilities. Inspectors also showed

familiarity with the upcoming “increased controls” requirements.

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

that Kansas’ performance with respect to the indicator, Technical Quality of Inspections, be

found satisfactory.

3.4 Technical Quality of Licensing Actions

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

licensing casework for 14 specific licenses. Thirty separate licensing actions were reviewed for

completeness, consistency, proper radioisotopes and quantities, qualifications of authorized

users, adequate facilities and equipment, adherence to good health physics practices, financial

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

overall technical quality. The casework was also reviewed for timeliness, use of appropriate

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

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

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

documents and supporting data.

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

completed during the review period. The sampling included the following types: medical and

academic broad scope, academic research and development, manufacturing and distribution,

medical institution-limited, medical private practice, mobile nuclear medicine, nuclear pharmacy,

industrial radiography, well logging, and fixed gauge. Types of licensing actions selected for

evaluation included new licenses, renewals, amendments to existing licenses and license

terminations. A listing of the licensing casework evaluated with case specific comments may be

found in Appendix D.

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

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

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

Deficiency letters clearly stated regulatory positions, were used at the proper time, and identified

substantive deficiencies in the licensees' documents.

The review team found that terminated licensing actions were also well documented. The

license files included the appropriate material transfer records and survey records. Confirmatory

surveys for license terminations were conducted when appropriate. The files showed that

licensee documentation of proper disposal or transfer was provided. The review team also
Kansas Final Report Page 9

evaluated a large decommissioning project of a manufacturing facility with widespread thorium

contamination. The review team determined that the Section provided excellent oversight and

review of the project, ultimately releasing the site, within regulatory limits.

The review team examined the licensees that the Section had determined met the criteria for the

increased controls, as per COMSECY-05-0028. The review team determined that the Section

had correctly identified the Kansas licensees that require increased controls based on this

criteria, and have procedures in place to issue increased controls to any additional licensees, as

appropriate. Each licensee was issued a license amendment requiring increased controls in

accordance with the timelines established by the Commission in the Staff Requirements

Memorandum for COMSECY-05-0028.

In July 1998, the NRC revised its regulations to require all industrial radiographers to be certified

by an approved certifying entity (10 CFR 34.43(a)(1)) and the effective date for Agreement

States to adopt compatible regulations was July 9, 2001. However, this requirement was not

incorporated into the Kansas regulations until December 2005. In addition, the Section did not

have other legally binding requirements in place during the interim period to ensure that all

radiographers listed on Kansas licenses and those filing reciprocity in the State were in fact

certified. Radiographer certifications did appear to be reviewed as part of inspections, and thus

the review team believes there was no indication of an immediate safety issue related to this

matter. During the on-site review, the review team discussed with Section management the

benefits of ensuring that all radiographers working in the State are appropriately certified by an

approved certifying entity. Since the on-site review, the Section has evaluated the majority of

industrial radiography licenses to ensure that only certified industrial radiographers were

performing radiography in Kansas despite the apparent regulatory gap.

The administrative staff receives all licensing actions and enters all pertinent information into the

Section’s database. The status of all actions is tracked by the database. The senior license

reviewer manages each action and completes them on a first-come, first-serve basis. Other

license reviewers complete actions on an as-needed basis based on workload and experience

for training purposes and/or to maintain familiarity with the licensing process. The senior license

reviewer completes the majority of the actions. For license reviewers with less experience in a

given area, the senior license reviewer provides additional oversight and/or assigns another

experienced license reviewer as a mentor. All completed actions are reviewed and signed by

the Section Chief. Cover letters and deficiency letters are reviewed and signed by the reviewers.

The Section uses templates to generate correspondence, as well as new and renewed licenses. 

Most amendments are made from the previous electronic version and then re-saved as the next

amendment. The Section uses standard formats and license conditions for each license type

and it utilizes licensing guides based on NRC licensing guides (NUREG-1556 series) as

appropriate and maintains other licensing guidance (i.e., Technical Assistance Requests,

regulatory guides) that are the same or similar to those used by the NRC.

Previously, the Section would renew licenses “as-is” every two years and require a “full” renewal

every 10 years or every fifth amendment, whichever came first. During the review period, the

Section began phasing out that process and converting licenses from the two year term to the
Kansas Final Report Page 10

more standard five year term. Full renewals will now be required every five years with only

limited use of “as-is” renewals. Actual expiration dates are staggered to avoid numerous

licenses coming due for renewal at the same time in the future.

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

that Kansas’ performance with respect to the indicator, Technical Quality of Licensing Actions,

be found satisfactory.

3.5 Technical Quality of Incident and Allegation Activities

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

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

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

those contained in the State database and incident files, and evaluated the casework and

supporting documentation for nine radioactive materials incidents. A list of the incident

casework examined, with case-specific comments, is included in Appendix E. The team also

reviewed the Section’s response to allegations involving radioactive materials, including

allegations referred to the State by the NRC. Incident and allegation policies, file

documentation, the Section’s incident and allegation tracking system, NMED, and notification of

incidents to the NRC Headquarters Operations Center were discussed with the Section Chief

and staff.

When notified of an incident, the Section Chief or Materials Supervisor assigns a member of the

inspection staff to investigate the incident and determine if the event requires a call to the NRC

Headquarters Operations Center. The staff member is then responsible for recording the event

in the Kansas incident database and the licensee file and leads any required follow-up activities. 

The Section responded to a total of 43 radioactive material incidents during the review period. 

Twelve of those incidents were reportable to the State within 24 hours. All 12 were conveyed to

the NRC Headquarters Operations Center and submitted to the NMED contractor. Monthly

reports and follow-up information are submitted electronically by transmitting the contents of the

Kansas database to the NMED system. One designated staff member manages the

submissions to the NMED contractor. The review team evaluated nine of the incidents, which

were required to be reported to the State. The incidents included: personnel overexposures, a

stolen gauge, damage to equipment, and loss of radioactive material.

The review team noted that close coordination with the NRC was maintained, and the Section’s

response to incidents was commensurate with the health and safety significance of the event. 

Inspectors were dispatched for investigations when appropriate and enforcement action was

taken when needed. Incident reports were thorough, well-documented and were generally

timely. All incident reports were reviewed and signed by the appropriate level of management.

During the review period, the Section received three allegations involving Agreement material.

The team evaluated the casework for all three allegations, two of which were referred to the

State by NRC. The review team’s evaluation indicated that prompt and appropriate action was

taken in response to the concerns raised. Allegers requesting anonymity were informed that
Kansas Final Report Page 11

every effort would be made to protect his/her identity, but could not be guaranteed. Each of the

allegations reviewed were appropriately closed, and the allegers were informed of the results,

when possible. There were no performance issues identified from the review of the allegation

casework documentation.

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

that Kansas’ performance with respect to the indicator, Technical Quality of Incident and

Allegation Activities, 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) Compatibility Requirements, (2) Sealed Source and Device Evaluation

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

Program. Kansas’ Agreement does not cover a uranium recovery program, so only the first

three non-common performance indicators were applicable to this review.

4.1 Compatibility Requirements

4.1.1 Legislation

Kansas became an Agreement State on January 1, 1965. Legislative authority to create an

agency and enter into an Agreement with the NRC is granted in Article 16 - Nuclear Energy

Development and Radiation Control Act, Kansas Statutes, K.S.A. 48-1601 to 48-1619. The

Department Secretary is responsible by law for radiation control. The Division is designated as

the State's radiation control agency. There were no legislative changes during the review

period.

4.1.2 Program Elements Required for Compatibility

The Kansas regulations governing radiation protection requirements are found in KAR 28-35-

133 through KAR 28-35-505, apply to all ionizing radiation, whether emitted from radionuclides

or produced by machines. Kansas requires a license for the possession and use of all

radioactive material, including naturally occurring materials and accelerator-produced

radionuclides. Kansas also requires registration of all machines designed to produce x-rays or

other ionizing radiation.

To the extent practical, the Kansas regulations follow the Suggested State Regulations of the

Conference of Radiation Control Program Directors, Inc. Kansas has a 12-step regulation

promulgation process which includes a 60-day notice for public comment prior to a public

hearing. The entire process nominally takes about 36 weeks from drafting to finalizing a

regulation. The Section Chief currently has the responsibility for maintaining the regulations,

however, a new support staff person was hired in April 2006, partially for the purpose of keeping

the regulations adequate and compatible with NRC.

The review team evaluated the Section’s response to the questionnaire relative to this indicator,

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

adequacy and compatibility policy, and verified the adoption of regulations with data obtained
Kansas Final Report Page 12

from the Office of State and Tribal Program’s State Regulation Status Data Sheet. Since the

previous IMPEP review, the Section has addressed a large number of NRC regulation

amendments by revising their regulations in their entirety. Section management chose to revise

the regulations in whole rather than adopt individual NRC amendments partly because the

required amendments entail conforming changes to a significant number of references. Section

management also chose to address the x-ray program regulations first because those

regulations were more out-of-date than the radioactive materials regulations.

The NRC transmitted ten comments concerning proposed changes to the Kansas regulations, in

a letter dated September 22, 2005. The State intended to make appropriate corrections in the

official copy of the regulations filed with the Kansas State legislature, which became effective on

December 30, 2005. Due to a mistake in transmission, three of the ten NRC- recommended

changes were not made to the legislature-endorsed copy. The program then submitted the

regulations to the NRC as a final version in a letter dated March 21, 2006. NRC staff reviewed

these regulations and noted that the some of the previously identified comments had not been

addressed in the final regulation package. On April 27, 2006, the Section Chief acknowledged

the error and stated that a corrected regulation package would be promptly submitted into the

Kansas rulemaking process.

Interviews conducted with the staff confirmed that the Section uses license conditions when

regulations were not adopted within the 3-year time frame. The Section has the authority to

issue legally binding requirements (e.g., license conditions) in lieu of regulations until compatible

regulations become effective. The team noted that license conditions or other legally binding

requirements were being used for the following rules:

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

amendment (64 FR 54543 and 64 FR 55524) that became effective February 2, 2003.

! “Increased Controls for Risk-Significant Radioactive Sources,” NRC Order EA-05-090 (70

FR 72128) that became effective December 1, 2005.

At the time of the on-site review, the review team determined that there were no overdue

regulations. The review team identified the following regulation amendment that will need to be

addressed in the future. Section management indicated that the regulation is currently proposed

and going through the rule promulgation process:

! “Security Requirements for Portable Gauges Containing Byproduct Material,” 10 CFR

Part 30 amendment (70 FR 2001) that became effective on July 11, 2005.

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

that Kansas’ performance with respect to the indicator, Compatibility Requirements, be found

satisfactory.

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

At the time of the review, Kansas 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 State committed to have a program
Kansas Final Report Page 13

in place prior to performing evaluations. Accordingly, the review team did not evaluate this

indicator.

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 Kansas has such disposal

authority, NRC has not required States to have a program for licensing a 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 Kansas. Accordingly, the review team did not evaluate this indicator.

5.0 SUMMARY

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

satisfactory but needs improvement for the performance indicator, Technical Staffing and

Training, and satisfactory for all remaining performance indicators reviewed. The review team

made one recommendation regarding the performance of the Kansas Agreement State Program

and recommended that one recommendation from the previous IMPEP review be left open,

pending further staff training and experience. Accordingly, the review team recommended and

the MRB agreed that the Kansas Agreement State Program was adequate to protect public

health and safety and compatible with NRC's program. The team also recommended and the

MRB agreed that the period of heightened oversight should be discontinued. Based on the

results of the current IMPEP review, the review team recommended and the MRB agreed that

the next full IMPEP review should take place in approximately four years.

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

evaluation and implementation, as appropriate, by the State.

RECOMMENDATIONS:

1. The team recommends the State ensure that the Agreement Materials Program has

adequate resources and an adequate complement of qualified staff. (From 2002 IMPEP

review) (Section 3.1)

2. The review team recommends that the State place greater emphasis and resource

allocation towards reciprocity inspections in accordance with program goals and the

criteria in NRC MC 1220. (Section 3.2)
LIST OF APPENDICES AND ATTACHMENT

Appendix A IMPEP Review Team Members

Appendix B Kansas Organization Charts

Appendix C Inspection Casework Reviews

Appendix D License Casework Reviews

Appendix E Incident Casework Reviews

Attachment June 15, 2006 Letter from Thomas A. Conley

Kansas’ Response to Draft IMPEP Report
APPENDIX A

IMPEP REVIEW TEAM MEMBERS 

Name Area of Responsibility

James Lynch, RIII Team Leader

Technical Staffing and Training

Inspector Accompaniments

Earl Fordham, Washington Status of Materials Inspection Program

Vivian Campbell, RIV Technical Quality of Inspections

Bryan Parker, RI Technical Quality of Licensing Actions

Jennifer Tobin, STP Technical Quality of Incident and Allegation 

Activities

Compatibility Requirements
APPENDIX B

KANSAS ORGANIZATION CHARTS

ADAMS Accession No.: ML061020369
APPENDIX C

INSPECTION CASEWORK REVIEWS

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS

ONLY.

File No.: 1

Licensee: University of Kansas Hospital Authority License No.: 18-C800

Inspection Type: Routine, Announced Priority: 1

Inspection Date: 12/13/04 Inspectors: JW, NA, JAJ, DW, JH

Comment:

The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.

File No.: 2

Licensee: University of Kansas Hospital Authority License No.: 18-C800

Inspection Type: Routine, Announced Priority: 1

Inspection Date: 9/24/03 Inspectors: JAJ, JH, RT, DW

Comment:

The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.

File No.: 3

Licensee: Front Range Mobile Imaging License No.: 12-B860

Inspection Type: Routine, Announced Priority: 3

Inspection Date: 10/12/05 Inspector: JB

File No.: 4

Licensee: Eli Wireline Services Inc. License No.: 27-C096-01

Inspection Type: Routine, Announced Priority: 2

Inspection Date: 11/19/04 Inspector: NA

Comment:

The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.

File No.: 5

Licensee: Eli Wireline Services Inc. License No.: 27-C096-01

Inspection Type: Routine, Announced Priority: 2

Inspection Date: 10/3/02 Inspector: JAJ

Comment:

The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.
Kansas Final Report Page C.2

Inspection Casework Reviews

File No.: 6

Licensee: Cornish Wireline Services Inc. License No.: 27-B128-01

Inspection Type: Routine, Unannounced Priority: 3

Inspection Date: 7/19/05 Inspector: JW

Comment:

The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.

File No.: 7

Licensee: Petro Wireline Service Inc. License No.: 27-B467-01

Inspection Type: Routine, Unannounced Priority: 3

Inspection Date: 7/27/05 Inspector: JTJ

Comment:

The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.

File No.: 8

Licensee: Petro Wireline Service Inc. License No.: 27-B467-01

Inspection Type: Routine, Announced Priority: 3

Inspection Date: 5/16/02 Inspector: JAJ

Comment:

The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.

File No.: 9

Licensee: Acuren License No.: 21-B126-01

Inspection Type: Routine, Announced Priority: 1

Inspection Date: 7/15/05 Inspector: JB

Comments:

a. The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.

b. The report did not contain any documentation that the radiography certification was

reviewed.

File No.: 10

Licensee: Acuren License No.: 21-B126-01

Inspection Type: Routine, Unannounced Priority: 1

Inspection Date: 5/28/04 Inspector: JAJ

Comments:

a. The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.

b. The report did not contain any documentation that the radiography certification was

reviewed.
Kansas Final Report Page C.3

Inspection Casework Reviews
Kansas Final Report Page C.4

Inspection Casework Reviews

File No.: 11

Licensee: Wesley Medical Center LLC License No.: 19-C041-01

Inspection Type: Routine, Announced Priority: 1

Inspection Date: 6/30/04 Inspectors: JAJ, NA

File No.: 12

Licensee: Beta Chem Laboratory License No.: 25-C686-01

Inspection Type: Investigation, Announced Priority: 1

Inspection Date: 9/20/05 Inspectors: JAJ, JB, DW

File No.: 13

Licensee: IRIS NDT License No.: 21-B866

Inspection Type: Termination Survey, Announced Priority: 1

Inspection Date: 3/16/06 Inspectors: JAJ

File No.: 14

Licensee: Mercy Hospital of Kansas, Inc. License No.: 19-C378-01

Inspection Type: Routine, Announced Priority: 3

Inspection Date: 11/16/04 Inspector: NA

Comments:

a. The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.

b. No record was found in the file that the licensee responded to the violation. However, the

database indicated that a response was received.

File No.: 15

Licensee: Kruger Technologies Inc. License No.: 22-B659-01

Inspection Type: Routine, Unannounced Priority: 1

Inspection Date: 8/12/05 Inspectors: JW, JAJ

Comment:

The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.

File No.: 16

Licensee: Kansas State University License No.: 38-C011-01

Inspection Type: Routine, Announced Priority: 1

Inspection Dates: 6/24-26/03 Inspectors: RT, JH, JAJ, DW

File No.: 17

Licensee: Como Tech, Inc. License No.: 21-B629-01

Inspection Type: Routine, Announced field inspection Priority: 1

Inspection Date: 3/4/05 Inspector: JAJ

Comments:

a. The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.

b. The report did not contain any documentation that the radiographer certification was

reviewed.
Kansas Final Report Page C.5

Inspection Casework Reviews

File No.: 18

Licensee: University of Kansas License No.: 38-C019-01

Inspection Type: Routine, Announced Priority: 1

Inspection Dates: 1/24-27/06 Inspectors: JB, DW, JAJ, JTJ, JW

Comment:

The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.

File No.: 19

Licensee: Mt. Carmel Medical Center License No.: 19-C243-01

Inspection Type: Routine, Announced Priority: 1

Inspection Date: 7/19/04 Inspector: JAJ

Comment:

The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.

File No.: 20

Licensee: Morton County Health System License No.: 19-B831

Inspection Type: Routine, Announced Priority: 1

Inspection Date: 10/27/04 Inspector: NA

Comment:

The report noted that confirmatory surveys were conducted, but the survey instrument

used and calibration information was not identified.

File No.: 21

Licensee: Salina Regional Health Center License No.: 19-B112-02

Inspection Type: Routine, Announced Priority: 1

Inspection Date: 11/22/04 Inspector: NA

Comment:

The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.

File No.: 22

Licensee: Log-Tech Inc. License No.: 27-B565-01

Inspection Type: Routine, Unannounced Priority: 3

Inspection Date: 5/13/04 Inspector: JAJ

Comment:

The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.
Kansas Final Report Page C.6

Inspection Casework Reviews

File No.: 23

Licensee: Taylor Forge Engineered Systems, Inc. License No.: 21-B108-01

Inspection Type: Routine, Announced Priority: 1

Inspection Date: 3/16/06 Inspector: JTJ

Comment:

The report did not contain any documentation that the radiographer certification was

reviewed.

File No.: 24

Licensee: Saint John Hospital License No.: 19-B383-01

Inspection Type: Routine, Unannounced Priority: 3

Inspection Date: 11/22/04 Inspector: JW

Comment:

The calibration information and serial number for the survey instrument used to conduct

confirmatory surveys was not recorded.

INSPECTOR ACCOMPANIMENTS

The following inspector accompaniments were performed prior to the on-site IMPEP review:

Accompaniment No.: 1

Licensee: Veterinary Specialty & Emergency Center License No: 19-B822

Inspection Type: Routine, Announced Priority: 1

Inspection Date: 3/14/06 Inspector: JAJ

Comment:

The inspector missed an opportunity to test the teletherapy interlock and radiation alarm

systems.

Accompaniment No.: 2

Licensee: Taylor Forge Engineered Systems, Inc. License No: 21-B108-01

Inspection Type: Routine, Announced Priority: 1

Inspection Date: 3/15/06 Inspector: JTJ

Comments:

a. The inspector missed opportunities to interview and observe less experienced

radiographers.

b. Ancillary personnel working in the vicinity of the radiographic cell were not interviewed to

confirm level of training.
Kansas Final Report Page C.7

Inspection Casework Reviews

Accompaniment No.: 3

Licensee: Lawrence Memorial Hospital License No: 12-B161-01

Inspection Type: Routine, Announced Priority: 3

Inspection Date: 3/16/06 Inspector: JW

Comment:

The inspector needs additional training with regard to evaluation of radiation therapy

patient charts to determine licensee compliance with written directives.
APPENDIX D

LICENSE CASEWORK REVIEWS

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS

ONLY.

File No.: 1

Licensee: St. Francis Health Center License No.: 19-B272-04

Type of Action: Amendments Amendment Nos.: 32, 31, 30, 29, 28

Date Issued: 4/17/06 (latest) License Reviewer: JH

Comment:

License Condition 10 allows all authorized uses for all 11 locations listed, although many

of those uses are not intended for many of those locations and should be clarified (i.e.,

brachytherapy use is not intended at a cardiology clinic).

File No.: 2

Licensee: Southwest Medical Center License No.: 19-B002-02

Type of Action: Renewals Amendment Nos.: 22, 21, 20, 19

Date Issued: 8/17/04 (latest) License Reviewers: NA, JH, TC, VC

File No.: 3

Licensee: COMO Tech, Inc. License No.: 21-B629-01

Type of Action: Amendment, Renewals Amendment Nos.: 14, 13, 12

Date Issued: 9/30/05 (latest) License Reviewers: TC, JH, RT

File No.: 4

Licensee: ELI Wireline License No.: 27-C096-01

Type of Action: Amendments Amendment Nos.: 39, 38, 37

Date Issued: 9/30/05 (latest) License Reviewers: TC, JH

File No.: 5

Licensee: Precision Energy Services License No.: 27-B633-01

Type of Action: Amendment, Renewal Amendment Nos.: 14, 13

Date Issued: 5/9/05 (latest) License Reviewer: JH

File No.: 6

Licensee: University of Kansas License No.: 38-C019-01

Type of Action: Renewal Amendment No.: 61

Date Issued: 3/8/06 License Reviewer: JH

File No.: 7

Licensee: Cardinal Health License No.: 20-B708-01

Type of Action: Amendments Amendment Nos.: 15, 14, 13

Date Issued: 4/17/06 (latest) License Reviewer: JH

File No.: 8

Licensee: Front Range Mobile Imaging License No.: 12-B860

Type of Action: New, Amendment Amendment Nos.: 00, 01

Date Issued: 5/9/05 (latest) License Reviewer: JH
Kansas Final Report Page D.2

Licensing Casework Reviews

File No.: 9

Licensee: St. John Hospital License No.: 19-B383

Type of Action: Renewal Amendment No.: 27

Date Issued: 9/3/05 License Reviewer: JH

File No.: 10

Licensee: Washburn University License No.: 31-B303-01

Type of Action: Termination Amendment No.: 19

Date Issued: 12/15/05 License Reviewer: JAJ

File No.: 11

Licensee: Monarch Cement Co. License No.: 22-B122-01

Type of Action: Termination Amendment No.: 27

Date Issued: 12/29/05 License Reviewer: JAJ

File No.: 12

Licensee: Kramer & Crouse Cardiology License No.: 12-B838

Type of Action: Amendment Amendment No.: 04

Date Issued: 11/23/05 License Reviewer: JB

File No.: 13

Licensee: Team Cooperheat - MQS, Inc. License No.: 21-B875

Type of Actions: New Amendment No.: 00

Dates Issued: 8/8/05 License Reviewer: JW

File No.: 14

Licensee: Meade District Hospital License No.: 12-B854

Type of Action: New, Amendment Amendment Nos.: 00, 01

Date Issued: 4/18/06 (latest) License Reviewers: JW, JH
APPENDIX E

INCIDENT CASEWORK REVIEWS

NOTE: CASEWORK LISTED WITHOUT COMMENT ARE INCLUDED FOR COMPLETENESS

ONLY.

File No.: 1

Licensee: Agricultural Engineering Associates License No.: 22-B484-01

Date of Incident: 1/12/04 NMED No.: 040322

Investigation Date: 1/12/04 Type of Incident: Damaged Gauge

Type of Investigation: Inspection

File No.: 2

Licensee: Chemsyn Science Laboratories License No.: 25-B561-01

Date of Incident: 10/23/03 NMED No.: 030919

Investigation Date: 11/21/03 Type of Incident: Overexposure

Type of Investigation: Inspection

File No.: 3

Licensee: Taylor Forge Engineering License No.: 21-B108-01

Date of Incident: 1/23/04 NMED No.: 040069

Investigation Date: 1/23/04 Type of Incident: Overexposure

Type of Investigation: Inspection

Comment:

The close-out letter was not filed in the incident file.

File No.: 4

Licensee: McAfee, Henderson & Strick, Inc. License No.: 22-B834

Date of Incident: 2/19/06 NMED No.: 060133

Investigation Date: 2/20/06 Type of Incident: Portable Gauge Theft

Type of Investigation: Inspection

File No.: 5

Licensee: Shilling Construction License No.: 22-B741-01

Date of Incident: 7/12/05 NMED No.: 060246

Investigation Date: 7/12/05 Type of Incident: Damaged Gauge

Type of Investigation: Inspection

Comment:

Reported late to NMED on 4/3/06.

File No.: 6

Licensee: Log-Tech Inc. License No.: 27-B565-01

Date of Incident: 3/1/06 NMED No.: 060248

Investigation Date: 3/28/06 Type of Incident: Lost Source

Type of Investigation: Inspection
Kansas Final Report Page E.2

Incident Casework Reviews

File No.: 7

Licensee: The Rosel Company License No.: 27-C057-01

Date of Incident: 6/2/05 NMED No.: 060247

Investigation Date: 6/3/05 Type of Incident: Lost Source

Type of Investigation: Inspection

Comment:

Reported late to NMED on 4/3/06.

File No.: 8

Licensee: Kansas Department of Transportation License No.: 22-B315-01

Date of Incident: 8/5/05 NMED No.: 050520

Investigation Date: 8/5/05 Type of Incident: Damaged Gauge

Type of Investigation: Inspection

File No.: 9

Licensee: Dressler Consulting Engineering License No.: 22-B837

Date of Incident: 4/3/04 NMED No.: 040234

Investigation Date: 4/16/04 Type of Incident: Damaged Gauge

Type of Investigation: Inspection
ATTACHMENT

June 15, 2006 Letter from Thomas A. Conley

Kansas’ Response to Draft IMPEP Report 

ADAMS Accession No.: ML061700496