November 1, 2007 

Mr. C. Earl Hunter, Commissioner 

South Carolina Department of 

 Health and Environmental Control 

2600 Bull Street 

Columbia, SC 29201 

Dear Commissioner Hunter: 

On October 15, 2007, the Management Review Board (MRB) met to consider the proposed final 

Integrated Materials Performance Evaluation Program (IMPEP) report on the South Carolina 

Agreement State Program. The MRB found the South Carolina Agreement State Program 

adequate to protect public health and safety and compatible with the U.S. Nuclear Regulatory 

Commission=s program. 

Section 5.0, page 18, of the enclosed final report contains a summary of the IMPEP review 

team=s findings. Based on the results of the current IMPEP review, the next full review of the 

South Carolina Agreement State Program will take place in approximately 4 years, with a 

periodic meeting tentatively scheduled for July 2009. 

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. I look 

forward to our agencies continuing to work cooperatively in the future. 

Sincerely, 

 /RA/ 

Martin J. Virgilio 

Deputy Executive Director for Materials, Waste, 

Research, State, Tribal, and Compliance Programs 

Office of the Executive Director for Operations 

Enclosure: 

South Carolina Final IMPEP Report 

cc w/encl.: See next page 
Letter to C. Earl Hunter from Martin J. Virgilio dated November 1, 2007 

cc w/encl.: Aaron A Gantt, Program Director 

 South Carolina Bureau of Radiological Health 

 Richard Haynes, P.E., Director 

 South Carolina Division of Waste Management 

 Julia Schmitt, Nebraska 

 Organization of Agreement States 

 Liaison to the MRB 

 
November 1, 2007 

Mr. C. Earl Hunter, Commissioner 

South Carolina Department of 

 Health and Environmental Control 

2600 Bull Street 

Columbia, SC 29201 

Dear Commissioner Hunter: 

On October 15, 2007, the Management Review Board (MRB) met to consider the proposed final 

Integrated Materials Performance Evaluation Program (IMPEP) report on the South Carolina 

Agreement State Program. The MRB found the South Carolina Agreement State Program 

adequate to protect public health and safety and compatible with the U.S. Nuclear Regulatory 

Commission=s program. 

Section 5.0, page 18, of the enclosed final report contains a summary of the IMPEP review 

team=s findings. Based on the results of the current IMPEP review, the next full review of the 

South Carolina Agreement State Program will take place in approximately 4 years, with a 

periodic meeting tentatively scheduled for July 2009. 

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. I look 

forward to our agencies continuing to work cooperatively in the future. 

Sincerely, 

 /RA/ 

Martin J. Virgilio 

Deputy Executive Director for Materials, Waste, 

Research, State, Tribal, and Compliance Programs 

Office of the Executive Director for Operations 

Enclosure: 

South Carolina Final IMPEP Report 

cc w/encl.: See next page 

Distribution: See next page. 

 ML072900341 EDATS: FSME-2007-0032

OFFICE FSME/DMSSA FSME/DMSSA FSME/DMSSA Tech Editor 

NAME ATMcCraw:kk ADWhite JRSchlueter CPoland 

DATE 10/17/07 10/17/07 10/22/07 10/22/07 

OFFICE FSME DEDMRT 

NAME GPangburn MJVirgilio 

DATE 10/25/07 10/01/07 

OFFICIAL RECORD COPY
Letter to C. Earl Hunter from Martin J. Virgilio dated November 1, 2007 

cc w/encl.: Aaron A Gantt, Program Director 

 South Carolina Bureau of Radiological Health 

 Richard Haynes, P.E., Director 

 South Carolina Division of Waste Management 

 Julia Schmitt, Nebraska 

 Organization of Agreement States 

 Liaison to the MRB 

DISTRIBUTION: DCD (SP01) 

DMSSA RF 

EDO RF Chairman Klein 

RidsFsmeOd Commissioner Jaczko 

RidsEdoMailCenter Commissioner Lyons 

RidsSecyCorrespondenceMailCenter SECY 

KLukes, FSME/DMSSA 

RBlanton, FSME/DMSSA 

JKottan, RI/RSAO 

SMulay, RIII 

MAbbaszadeh, TX 

JDaehler, MA 

DDiaz-Toro, OEDO 

APowell, OCA (2 copies) 

KCyr, OGC 

FCameron, OGC 

CMiller, FSME 

JSchlueter, FSME/DMSSA 

RLewis, FSME/DMSSA 

Duncan White, FSME/DMSSA 

KSchneider, FSME/DMSSA 

MOrendi, FSME/DMSSA 

PGwynn, RIV 
INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

REVIEW OF THE SOUTH CAROLINA AGREEMENT STATE PROGRAM 

July 16-20, 2007 

FINAL REPORT

ENCLOSURE 
South Carolina Final Report Page 1 

1.0 INTRODUCTION 

This report presents the results of a review of the South Carolina Agreement State Program. 

The review was conducted during the period of July 16-20, 2007, by a review team comprised of 

technical staff members from the U.S. Nuclear Regulatory Commission (NRC), the 

Commonwealth of Massachusetts, and the State of Texas. 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 

June 13, 2003, to July 20, 2007, were discussed with South Carolina managers on the last day 

of the review. 

A draft of this report was issued to South Carolina for factual comment on August 22, 2007. 

The State responded by letter on September 20, 2007, from C. Earl Hunter, Commissioner, 

Department of Health and Environmental Control (the Department). This letter is provided in the 

Attachment. The Management Review Board (MRB) met on October 15, 2007, to consider the 

proposed final report. The MRB found the South Carolina Agreement State Program adequate 

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

The South Carolina Agreement State Program is located in the Department. Within the 

Department, the Division of Waste Management (the Division of Waste) in the Bureau of Land 

and Waste Management, under the Deputy Commissioner for Environmental Quality Control, is 

responsible for the oversight of the Barnwell radioactive waste disposal site and approximately 

14 other licenses for waste-related operations. The Bureau of Radiological Health (the Bureau), 

under the Deputy Commissioner for Health Regulation, administers the remainder of the 

radiation control program. The Division of Radioactive Materials Licensing and Compliance (the 

Division of Radioactive Materials), which is part of the Bureau, administers the radioactive 

materials program. Organization charts for the Department, the Division, and the Bureau are 

included as Appendix B. 

At the time of the review, the South Carolina program regulated approximately 380 specific 

licenses authorizing Agreement materials, in addition to the Barnwell site. The review focused 

on the 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 South Carolina. 

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

performance indicators was sent to the State on April 9, 2007. The Division of Waste and the 

Division of Radioactive Materials provided responses to the questionnaire on May 16, 2007, and 

June 26, 2007, respectively. Copies of the questionnaire responses can be found in the NRC’s 

Agencywide Document Access and Management System (ADAMS) using Accession Number 

ML072330456. 

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

South Carolina’s response to the questionnaire; (2) review of applicable South Carolina statutes 

and regulations; (3) analysis of quantitative information from the Division of Radioactive 

Materials’ database; (4) technical evaluation of selected regulatory actions; (5) field 
South Carolina Final Report Page 2 

accompaniments of four South Carolina inspectors; and (6) interviews with staff and managers 

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

against the established criteria for each common and applicable non-common performance 

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

Section 2.0 of this report covers the NRC’s actions in response to recommendations made 

during the previous review. There were no recommendations made to the State during the 

previous review. Results of the current review of the common performance indicators are 

presented in Section 3.0. Section 4.0 details results of the applicable non-common 

performance indicators, and Section 5.0 summarizes the review team’s findings. 

2.0 STATUS OF ITEMS IDENTIFIED IN PREVIOUS REVIEWS 

During the previous review, which concluded on June 13, 2003, no recommendations were 

made to the State, and two recommendations were made to the NRC. The review team’s 

evaluation of the current status of the recommendations for the NRC was as follows: 

1. The review team recommends that NRC adopt and disseminate final guidance on field 

inspections for industrial radiography operations in the interest of establishing an 

identifiable national materials program standard. (Section 3.3 of the 2003 report) 

Current Status: The 2003 review team noted that many industrial radiography 

inspections were office, not field, inspections. One licensee was never inspected in the 

field in an 8-year period. The 2003 review team noted that a Temporary Instruction (TI) 

was implemented by the NRC that provided for an increased frequency for field 

inspections. The 2003 review team recommended that NRC adopt and disseminate final 

guidance on field inspections for industrial radiography operations in the interest of 

establishing an identifiable national materials program standard. 

The current review team is unable to determine if the final guidance has been issued. 

Although the TI referenced by the 2003 review team is not listed as a current TI, NRC 

Inspection Procedure 87121, “Industrial Radiography Programs,” reissued on August 22, 

2005, does not indicate a change to the guidance on field inspections. As well, NRC’s 

Inspection Manual Chapter (IMC) 2800, “Materials Inspection Program,” was reissued 

September 28, 2005, but no change to the guidance relevant to this recommendation is 

indicated. A review of the All Agreement States Letters from 2003 to present uncovered 

no letter forwarding revised guidance to the States. The review team recommended 

holding this recommendation open. 

2. The review team recommends that NRC clarify which supervisory levels require an 

inspection accompaniment, the frequency of those accompaniments and what level of 

documentation is appropriate. (Section 3.3 of the 2003 report) 

Current Status: In the 2005 revision of the Office of Federal and State Materials and 

Environmental Management Programs (FSME) Procedure SA-102, “Reviewing the 

Common Performance Indicator, Technical Quality of Licensing Actions,” the following 

question and answer was added in Appendix C, Frequently Asked Questions, to provide 

interim guidance: 
South Carolina Final Report Page 3 

Q: If a supervisor routinely performs inspections in an Agreement State, should 

the supervisor be accompanied annually also? 

A: Yes, supervisors who routinely perform inspections should be accompanied. 

During an IMPEP review in 2003, a recommendation was made to the NRC to 

develop specific guidance on what level of supervisor needs to be accompanied, 

how often, and what documentation is necessary. Until this guidance is 

finalized, it should be assumed that any supervisor that performs inspections 

should be accompanied at least annually. (Emphasis added) 

The review team determined that the final guidance has not been developed and issued. 

The review team recommended holding this recommendation open. 

In light of the relatively low risk significance of the recommendations and the need to address 

higher priority work, the review team was less concerned that the recommendations remain 

open than it was about the lack of central documentation and working knowledge of the 

continuing consideration of the recommendations. Over the 4-year review period, significant 

changes of NRC organization and staff occurred. Considering projections of future staff 

turnover and office relocations, the review team was concerned that the handling of these 

recommendations demonstrates the potential for future recommendations to the NRC by IMPEP 

review teams becoming lost. The review team initially recommended that the NRC strengthen 

its system for tracking recommendations made to the NRC by IMPEP review teams. The MRB 

agreed with this recommendation and determined that the recommendations from the 2003 

IMPEP review, as well as future recommendations made to the NRC by IMPEP review teams, 

and agreed upon by the MRB, will be ticketed and tracked in the NRC’s internal tracking 

system. Upon the MRB’s agreement with such recommendations, they will be removed from 

the final IMPEP reports. 

3.0 COMMON PERFORMANCE INDICATORS 

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

Regional and Agreement State radioactive materials programs. These indicators are: 

(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 Division of Radioactive Materials’ 

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 Division of Radioactive 

Materials’ questionnaire response relative to this indicator, interviewed Division of Radioactive 

Materials managers and staff, reviewed job descriptions and training records, and considered 

any possible workload backlogs. 
South Carolina Final Report Page 4 

The Division of Radioactive Materials is staffed by the Radioactive Materials Division Director, 

who reports to the Bureau Chief; the Radioactive Materials Program Manager; and four health 

physicists. In response to the questionnaire, the Division of Radioactive Materials reported that 

the Bureau Chief spends approximately 50 percent of his effort supervising the radioactive 

materials program, while the Radioactive Materials Division Director and Radioactive Materials 

Program Manager devote all of their time to the program. The Radioactive Materials Division 

Director and the Radioactive Materials Program Manager perform licensing actions, conduct 

inspections, and respond to radioactive materials events. 

Since the last review, the former Bureau Chief was replaced and the former Industrial Program 

Manager left the Division of Radioactive Materials. The Bureau used the departures as an 

opportunity to reorganize and replaced the Industrial Program Manager position with an entrylevel staff position. Both the Bureau Chief and the staff positions were filled within a reasonable 

time. At the time of the review, the Division of Radioactive Materials was fully staffed. The 

review team concluded that the Division of Radioactive Materials’ staffing level was adequate. 

The Division of Waste is responsible for the Barnwell site, radioactive waste-related licensees, 

and decommissioning activities. Details of the Division of Waste’s staffing and training are 

discussed in Section 4.3.1. 

The qualifications of the Division of Radioactive Materials’ staff were determined from the 

questionnaire, training records, and interviews of personnel. The Division of Radioactive 

Materials has a documented training program for new staff that is comparable to the 

NRC/Organization of Agreement States, Inc., Working Group Recommendations for Agreement 

State Training Programs. The staff is qualified from an education and experience standpoint; all 

have Bachelor’s degrees in the sciences or equivalent training and experience. The 

experienced license reviewers/inspectors have attended the training courses as prescribed by 

IMC 1246, “Formal Qualification Programs in Nuclear Material Safety and Safeguards Program 

Area,” and have received training in the areas needed for their assignments. They are familiar 

with South Carolina regulations, policies, and procedures. Managers are supportive of staff 

training and demonstrated a commitment to staff training during the review period. The training 

of new staff is proceeding according to the Division of Radioactive Materials’ training plan, with 

minor delays due to limited availability of slots at NRC training course sessions for which they 

apply. 

The review team discussed the role of the Technical Advisory Radiation Control Council (the 

Council) with the Bureau Chief. The Council holds statutory authority to review all proposed 

regulations prior to adoption. The Council also serves as an advisory committee to both the 

Division of Radioactive Materials and the Division of Waste. The Council meets as needed. 

Since the last review, the Council has met only once. The Council is authorized to review and 

approve proposed regulations by e-mail and has done so. No evidence of any conflict of 

interest issues was identified. Council members are subject to the State Ethics Act. 

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

that South Carolina’s performance with respect to the indicator, Technical Staffing and Training, 

was satisfactory. 
South Carolina Final Report Page 5 

3.2 Status of Materials Inspection Program

The review team focused on five factors while reviewing this indicator: inspection frequency, 

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

licensees, and performance of reciprocity inspections. The review team’s evaluation was based 

on the Division of Radioactive Materials’ questionnaire response relative to this indicator, data 

gathered from the Division of Radioactive Materials’ database, examination of completed 

inspection casework, and interviews with managers and staff. 

The review team verified that the Division of Radioactive Materials’ inspection priorities for 

various license types are at least as frequent as, and typically more frequent than, the 

inspection priorities for similar license types listed in IMC 2800. The Division of Radioactive 

Materials’ maximum inspection interval is 5 years. For medical facilities conducting activities 

subject to multiple priorities, all activities of the licensee are inspected according to the most 

restrictive priority. The Division of Radioactive Materials uses this approach to simplify the 

inspection schedule, and to limit the impact of inspections on licensees. 

Since the last IMPEP review, the Division of Radioactive Materials has maintained a 

computerized Environmental Facility Information System to review and track licensee inspection 

data. All inspection timeliness calculations are performed by the computer program. The 

Radioactive Materials Program Manager prints out reports for materials inspections that are 

coming due in the next 6 months. The printout identifies the last inspection date, the inspection 

due date, and the 25 percent overdue date, consistent with IMC 2800. 

In their response to the questionnaire, the Division of Radioactive Materials indicated that there 

were no inspections currently overdue by more than 25 percent of the NRC frequency. In 

addition, the Division of Radioactive Materials revealed that approximately 150 Priority 1, 2, and 

3 inspections were performed for the review period. The review team confirmed that there were 

no routine Priority 1, 2, and 3 inspections overdue at the time of the review and determined that 

only five Priority 1, 2, and 3 inspections were conducted overdue by more than 25 percent of the 

NRC frequency during the review period. 

The Division of Radioactive Materials requires that new licensees be inspected within 6 months 

of license issuance or within 6 months of the initial receipt of radioactive materials, but always 

within one year of license issuance. According to the questionnaire, 60 initial inspections were 

completed during the review period and were performed within the above criteria, which meet 

the requirements of IMC 2800. Based on a sample of initial inspection reports completed, none 

were overdue at the time of the review. The review team calculated that approximately 2.4 

percent of the total Priority 1, 2, and 3 and initial inspections conducted by the Division of 

Radioactive Materials during the review period were performed overdue. 

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

casework review. The majority of the Division of Radioactive Materials’ routine inspections are 

documented with the issuance of a Form 591, “Field Compliance Form,” at the completion of the 

on-site inspection. Other inspection findings are routinely dispatched to licensees within 30 

days of completing an inspection. 
South Carolina Final Report Page 6 

The Division of Radioactive Materials issues reciprocity permits based on their July 1 - June 30 

fiscal year. During the review period, the Division of Radioactive Materials had 45 reciprocity 

licensees that were candidates for inspection based upon the criteria in IMC 1220, “Processing 

of NRC Form 241 and Inspection of Agreement State Licensees Operating Under 10 CFR 

150.20.” The Division of Radioactive Materials met and/or exceeded the NRC’s requirement of 

inspecting 20 percent of candidate licensees operating under reciprocity each year in each of 

the 4 years of the review period. 

The review team determined that with respect to Commission Staff Requirements Memorandum 

(SRM) for COMSECY-05-0028, “Staff Response to SRM for COMSECY-05-0015: Initiatives for 

Increasing Agreement State Participation in the Control of Sources,” on Increased Controls, the 

Division of Radioactive Materials planned for the initial set of inspections of licensees subject to 

the Increased Controls in accordance with the SRM. The review team evaluated the Division of 

Radioactive Materials' prioritization methodology and found it acceptable. The Division of 

Radioactive Materials has 31 active Increased Controls licensees, 15 of which were identified as 

needing to be inspected within the first year. The Division of Radioactive Materials has 

conducted and completed all 15 inspections of the first year inspections. The Division of 

Radioactive Materials expects to complete the remaining IC inspections in the next 2 years. 

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

that South Carolina’s performance with respect to the indicator, Status of Materials Inspection 

Program, was satisfactory. 

3.3 Technical Quality of Inspections

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

field notes and interviewed inspectors for 33 radioactive materials inspections conducted during 

the review period. The casework reviewed included inspections conducted by four Division of 

Radioactive Materials inspectors and two managers. The casework covered inspections of 

various license types, including: medical broad scope, medical institutions requiring written 

directives, medical private practice, fixed and portable gauges, industrial radiography, academic 

broad scope, irradiator, medical therapy, nuclear pharmacy, Increased Controls, and reciprocity. 

Appendix C lists the inspection casework files reviewed, with case-specific comments, as well 

as the results of the inspector accompaniments. 

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

aspects of the licensees’ radiation safety programs. Inspection reports were thorough, 

complete, consistent, and of high quality, with sufficient documentation to ensure acceptable 

performance with respect to health, safety, and security issues. Exit interviews were held with 

appropriate licensee personnel. Team inspections were performed when appropriate and for 

training purposes. Inspection reports are examined and signed by the Radioactive Materials 

Division Director. 

South Carolina’s inspection procedures are consistent with the NRC’s procedures. Division of 

Radioactive Materials inspectors attempt to perform unannounced inspections; however, 

inspections may be announced a few days before the inspection to ensure the appropriate 

personnel are available during the inspection. The review team noted that 12 of 33 inspection 
South Carolina Final Report Page 7 

files indicated that the inspections were unannounced during this review period, as compared to 

6 of 28 inspection files during the previous review. 

The Division of Radioactive Materials emphasizes the performance of field audits for licensees 

authorized to conduct operations at temporary jobsites. One industrial radiography licensee has 

not had a field audit conducted since the license was issued on August 21, 1998. An 

unsuccessful attempt was made to arrange for a field audit during the August 16, 2006, 

inspection. The MRB agreed that the Division of Radioactive Materials’ attempts to arrange for 

a field audit, although unsuccessful, met the intent of the IMC 2800 guidance on performance of 

inspections at temporary jobsites. This instance is similar to an occurrence identified during the 

previous review, in which a radiographer had not been inspected in the field for a period of 8 

years. The 2003 review team recommended that NRC adopt and disseminate final guidance on 

field inspections for industrial radiography operations in the interest of establishing an 

identifiable national materials program standard. As noted in Section 2.0, the guidance has not 

yet been developed. The review team discussed with the Division of Radioactive Materials the 

need to continue to place more emphasis on conducting field inspections for licensees 

authorized for use of licensed material at temporary jobsites pending the issuance of the final 

guidance. 

During the review period, Division of Radioactive Materials managers performed annual 

accompaniments of all individuals who performed radioactive materials inspections. The 

accompaniment reports contained sufficient details to document the areas covered. 

The review team verified that the Division of Radioactive Materials maintains an adequate 

supply of survey instruments to support the current inspection program. Appropriate, calibrated 

survey instrumentation, such as Geiger-Mueller survey meters, scintillation survey meters, ion 

chambers, and micro-R meters, were observed to be available. Most instruments are calibrated 

by the Department’s Calibration Laboratory, which is a Certified Regional Calibration facility. 

Instrument repair and calibration is also available from the instrument manufacturers, as 

needed. Inspectors on call for incident response are issued an emergency kit that contains two 

calibrated survey instruments, tape, spare batteries, etc. The Department’s Environmental 

Laboratory and a contract laboratory provide support to the Division of Radioactive Materials 

through radioanalyses of environmental samples and samples taken by inspectors during 

inspections, as well as environmental dosimetry around nuclear facilities. 

Accompaniments of three of the Division of Radioactive Materials’ inspectors were conducted 

by a review team member during the week of May 7, 2007. The accompaniments are identified 

in Appendix C. During the accompaniments, the inspectors demonstrated appropriate 

inspection techniques and knowledge of the regulations. The inspectors were well prepared 

and thorough in their reviews of the licensees’ radiation safety and security programs. The 

inspections were adequate to assess radiological health and safety and Increased Controls at 

the licensed facilities. 

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

that South Carolina’s performance with respect to the indicator, Technical Quality of 

Inspections, was satisfactory. 
South Carolina Final Report Page 8 

3.4 Technical Quality of Licensing Actions

The review team examined completed licensing casework and interviewed license reviewers for 

14 specific licenses issued by the Division of Radioactive Materials. 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 license 

conditions, Increased Controls, 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/peer review, and proper signatures. The casework was 

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. Licensing actions selected for evaluation included three 

new licenses, three renewals, six amendments, one termination, and one reciprocity request. 

The sampling included the following license types: medical (broad-scope, gamma knife, high 

dose-rate remote afterloader, and private practice), manufacturing and distribution, irradiator, 

industrial radiography, portable gauge, fixed gauge, academic, research and development, and 

nuclear pharmacy. A listing of the licensing casework evaluated can be found in Appendix D. 

The review team found that the licensing actions were thorough, complete, consistent, and of 

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

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

Licenses and correspondence were generated using standardized conditions and formats. 

Licensing staff appropriately used licensing guides, policies, and standard license conditions. 

The review team noted that licensees’ compliance histories were taken into account when 

reviewing renewal applications. Each licensing action was given a technical review by a license 

evaluator. Senior managers performed a technical and supervisory review on each licensing 

action before the license or amendment was issued. During the review period, the Bureau 

extended the standard license expiration date from 5 to 8 years from the date of issue. The 

review team did not note any timely license renewals pending for a period of greater than 

1 year. 

The review team evaluated financial assurance and decommissioning activities. The review 

team found that the terminated licensing action reviewed was well documented, showing 

appropriate radioactive material transfer and survey records. The review team noted that a site 

visit was performed and confirmatory surveys were conducted prior to termination of the license. 

The review team identified no performance issues with the handling of financial assurance or 

decommissioning. 

The review team examined licenses subject to pre-licensing guidance described by FSME 07-

026, “Evaluation of the Implementation of the Pre-licensing Guidance During Integrated 

Materials Performance Evaluation Program (IMPEP) Reviews,” dated March 20, 2007. The 

Division of Radioactive Materials had implemented the pre-licensing guidance by the time of the 

review, well in advance of the September 20, 2007, due date for Agreement States to 
South Carolina Final Report Page 9 

implement the pre-licensing guidance. The review team noted that as of the end of the review 

period, the Division of Radioactive Materials had resumed hand-delivering new licenses. 

The review team examined the list of licensees that the Division of Radioactive Materials had 

determined met the criteria for the Increased Controls, per COMSECY-05-0028. The review 

team determined that the Division of Radioactive Materials correctly identified the licensees that 

require the Increased Controls based on the criteria. Each licensee was issued a license 

amendment requiring the Increased Controls in accordance with the time lines established by 

the Commission in the SRM for COMSECY-05-0028. The Division of Radioactive Materials will 

issue the Increased Controls to any additional licensees, as appropriate. 

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

that South Carolina’s performance with respect to the indicator, Technical Quality of Licensing 

Actions, was satisfactory. 

3.5 Technical Quality of Incident and Allegation Activities

To evaluate the effectiveness of the Division of Radioactive Materials’ actions in responding to 

incidents and allegations, the review team examined the Division of Radioactive Materials’ 

response to the questionnaire relative to this indicator, evaluated selected incidents reported for 

South Carolina in the Nuclear Material Events Database (NMED) against those contained in the 

Division of Radioactive Materials’ files, and evaluated the casework for 18 radioactive materials 

incidents. A listing of the incident casework examined can be found in Appendix E. The review 

team also evaluated the Division of Radioactive Materials’ response to two allegations involving 

radioactive materials, one of which was referred to the State by the NRC during the review 

period. 

The review team discussed the Division of Radioactive Materials’ incident and allegation 

processes including file documentation, notification of incidents to the NRC Headquarters 

Operations Center, and the use of NMED software. When a notification of an incident or 

allegation is received, managers and staff discuss the event and determine the level of initial 

response based on the health and safety risk associated with the event. The actions taken in 

response to an event are documented and filed, and the data are processed into NMED. The 

Division of Radioactive Materials’ understanding and use of the NMED system was verified by a 

demonstration of a data search and generation of specific reports. 

The Division of Radioactive Materials had 40 events documented in their Incident and Allegation 

Log. The review team selected 18 radioactive material incidents for evaluation. These 

incidents included medical events, lost/stolen material, an overexposure, and equipment 

malfunctions. The Division of Radioactive Materials’ responses to the incidents were complete 

and comprehensive. Initial responses were prompt and well-coordinated, and the level of effort 

was commensurate with the health and safety significance. Inspectors were dispatched for onsite investigations when appropriate. Enforcement and/or other regulatory actions were taken 

as appropriate. 

The review team identified several incidents documented in NMED referring to alarms at scrap 

yards and steel mills. These incidents originated from States outside of South Carolina, and the 

material was returned to those States. 
South Carolina Final Report Page 10 

In evaluating the effectiveness of the Division of Radioactive Materials’ actions responding to 

allegations, the review team evaluated the casework for one allegation referred to the Division 

of Radioactive Materials by the NRC and one received directly by the Division of Radioactive 

Materials. The review team’s evaluation indicated that the Division of Radioactive Materials 

took prompt and appropriate action in response to the concerns raised. The allegations were 

appropriately closed, and the appropriate parties were notified of the actions taken. 

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

that South Carolina’s performance with respect to the indicator, Technical Quality of Incident 

and Allegation Activities, was satisfactory. 

4.0 NON-COMMON PERFORMANCE INDICATORS 

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

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. South Carolina’s Agreement does not cover uranium recovery activities, so 

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

4.1 Compatibility Requirements

4.1.1 Legislation

South Carolina became an Agreement State on September 15, 1969. The radiation control 

program’s statutory authority is contained in the 1976 Code of Laws of South Carolina, the 

Atomic Energy and Radiation Control Act, the Radioactive Waste and Transportation Act, and 

the Environmental Fees. The Department is designated the State’s radiation control program 

agency and implements the Agreement State program. In addition to its response to the 

questionnaire, the State provided the review team with a copy of the legislation that affects the 

radiation control program. There have been no changes since the last review. South Carolina 

legislation is not subject to any “sunset” laws. 

4.1.2 Program Elements Required for Compatibility

The Department’s Radioactive Materials Regulations 61-63, Title A, apply to all materials that 

emit ionizing radiation. These regulations were promulgated pursuant to Section 13-7-40 et. 

seq. of the 1976 South Carolina Code (as amended) and the Atomic Energy and Radiation 

Control Act. South Carolina requires a license for possession and use of all radioactive 

material, including naturally occurring materials, such as radium, and accelerator produced 

radionuclides. South Carolina also requires registration of all equipment designed to produce 

x-rays or other ionizing radiation and tanning beds. 

The review team examined South Carolina’s rulemaking process and found that rulemaking 

takes approximately 6 to 9 months from the development stage to the publication of the final 

rule in the State Register. Rules become effective 14 days after the final filing process is 

completed. The public, the NRC, other agencies, and all potentially impacted licensees and 

registrants are offered opportunity to comment during the process. Comments are considered 

and incorporated, as appropriate, before regulations are finalized, approved, and published in 
South Carolina Final Report Page 11 

the State Register. South Carolina can adopt regulations needed for compatibility with approval 

from the Department Board; whereas, other regulations, such for fees, must receive approval 

from the State legislature. 

The State is authorized to adopt other agency regulations by reference, which has been done 

with respect to transportation regulations adopted by the U.S. Department of Transportation. 

The State also has the authority to issue legally binding requirements (e.g., license conditions, 

etc.) until compatible regulations become effective. 

The review team evaluated the State’s responses 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 

from the State Regulation Status Sheet maintained by FSME. 

Current NRC policy requires that Agreement States adopt certain equivalent regulations or 

legally-binding requirements no later than 3 years after they become effective. At the time of 

the review, there were no overdue NRC regulation amendments. Also, at the time of the review, 

the review team did not identify any regulation amendments for future adoption that have not 

already been addressed by the State. 

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

that South Carolina’s performance with respect to the indicator, Compatibility Requirements, 

was satisfactory. 

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

The Division of Radioactive Materials has sole responsibility for performing SS&D evaluations in 

the State. In conducting this review, three sub-elements were used to evaluate the Bureau’s 

performance regarding the SS&D Evaluation Program. The three sub-elements are: 

(1) Technical Staffing and Training; (2) Technical Quality of the Product Evaluation Program; 

and (3) Evaluation of Defects and Incidents Regarding SS&Ds. 

In assessing the Division of Radioactive Materials' SS&D evaluation activities, the review team 

examined information provided by the Division of Radioactive Materials in response to the 

IMPEP questionnaire on this indicator, performed a search of the national SS&D Registry for 

registrations issued by South Carolina, and performed NMED searches of manufacturers and 

distributors identified on SS&D registrations issued by South Carolina. The review team 

conducted a review of the one SS&D evaluation completed by the Division of Radioactive 

Materials during the review period. 

4.2.1 Technical Staffing and Training

The Division of Radioactive Materials has one qualified SS&D reviewer with full signature 

authority and obtained the assistance of another qualified SS&D reviewer from the NRC to 

complete the one new SS&D registration during the review period. The Division of Radioactive 

Materials’ qualified reviewer has over 20 years of experience with the Division of Radioactive 

Materials, has a Bachelor’s degree in a science, and has attended the NRC’s SS&D workshop. 
South Carolina Final Report Page 12 

At the time of the review, the Division of Radioactive Materials did not have any pending SS&D 

evaluations and did not expect any forthcoming SS&D applications. 

The Division of Radioactive Materials has a staff member who attended the NRC’s SS&D 

workshop in April of 2006; however, the staff member was not evaluated by the Division of 

Radioactive Materials to have other training and experience necessary to perform SS&D 

evaluations. Prior to the on-site review, the Division of Radioactive Materials did not have 

documented qualification criteria for SS&D Reviewers. During the on-site review, the Division of 

Radioactive Materials developed and documented qualification criteria for SS&D Reviewers. 

The documented qualification criteria were added to the Division of Radioactive Materials’ 

training procedure manual. The Division of Radioactive Materials indicated that other staff 

members may undergo training to become SS&D reviewers in the future. 

Because of the very light present and future workloads for SS&D evaluations and the availability 

of a second qualified SS&D reviewer from outside of the Division of Radioactive Materials, the 

review team determined that the Division of Radioactive Materials’ retention of one qualified 

SS&D reviewer was adequate. 

4.2.2 Technical Quality of the Product Evaluation Program

During the review period, the Division of Radioactive Materials processed one SS&D action. 

The action was for a new SS&D registration of a device. The casework review included all 

supporting documentation, license, and inspections associated with the distributor of the device. 

A listing of the SS&D registration evaluated by the review team, with case-specific comments, 

may be found in Appendix F. 

Analysis of the casework and interviews with the staff confirmed that the Division of Radioactive 

Materials follows the recommended guidance from the NRC SS&D workshop and NUREG1556, Volume 3, Revision 1. Appropriate review checklists were used to assure all relevant 

materials had been submitted and reviewed. The checklists were retained in the SS&D files 

along with other documents that identified the reviewers. Pertinent American National 

Standards Institute standards, Regulatory Guides, and applicable references were confirmed to 

be available and were used when performing the SS&D review. 

The registration files contained all correspondence, engineering drawings, radiation profiles, and 

details of the applicant’s quality assurance and quality control program, with the exception that 

one of the documents referenced in the registration, a letter dated February 13, 2007, was 

initially missing from the file. The missing document was determined to be identical to another 

letter dated January 18, 2007, that was in the file, except that the document had a different date 

on the letter and was addressed to the NRC instead of the Division of Radioactive Materials. 

The Division of Radioactive Materials obtained a copy of the referenced letter dated February 

13, 2007, from the NRC and completed the file. The registration clearly summarized the 

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

possession and use of the product. Deficiency letters clearly stated regulatory positions, and all 

health and safety issues were properly addressed. The review team found that the evaluation 

was of high quality with health and safety issues properly addressed. The Division of 

Radioactive Materials is legally authorized to enforce the requirements of SS&D registrations 

through regulations issued by the Department. 
South Carolina Final Report Page 13 

4.2.3 Evaluation of Defects and Incidents Regarding SS&Ds

Based upon the Division of Radioactive Materials’ response to the questionnaire, interview of 

the Division of Radioactive Materials managers, and the review team’s searches of NMED, 

there were no reports of any defects or incidents during the review period related to SS&D 

registrations issued by the Division of Radioactive Materials. 

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

that South Carolina’s performance with respect to the indicator, SS&D Evaluation Program, was 

satisfactory. 

4.3 Low-Level Radioactive Waste (LLRW) Disposal Program

Chem-Nuclear Systems, LLC, (Chem-Nuclear) is licensed by the Division of Waste to handle, 

process, store, and dispose of LLRW at the Barnwell site. EnergySolutions, LLC, acquired 

Chem-Nuclear in 2006, but did not effect a name change for the Barnwell operator. The 

Division of Waste is responsible for inspecting, licensing, and responding to incidents and 

allegations at the 14 waste-related radioactive materials licensees, in addition to the Barnwell 

site. 

The LLRW license establishes regulatory conditions and procedures that Chem-Nuclear must 

comply with regarding waste acceptance criteria, site construction, maintenance, environmental 

monitoring, stabilization and closure. Chem-Nuclear began its operation of shallow land 

disposal of LLRW at Barnwell in 1971. Since the last review, the license was amended twice. 

The current license expired in July 2000 and is currently in timely renewal. Under timely 

renewal, Chem-Nuclear may continue to operate the facility under the existing license and 

regulations until the Division of Waste takes final action on the renewal application. The 

application for renewal was submitted on April 27, 2000. In response to the recommendations 

provided by the Division of Waste, Chem-Nuclear submitted an Environmental Radiological 

Performance Verification (ERPV) report to demonstrate the performance of the site after 

closure. The Division of Waste formed a Blue Ribbon Panel (the Panel) of experts to provide a 

third-party, independent review of the ERPV report. The ERPV report was reviewed by the 

Panel as part of the renewal package. In 2003, Chem-Nuclear revised the ERPV report to 

address the Panel’s recommendations. 

The proposed license renewal went through a public hearing in 2003. On March 15, 2004, the 

Division of Waste approved the license renewal. The license renewal was challenged by 

environmental stakeholders. In 2005, the South Carolina Administrative Law Court (the Court) 

issued a final order, which sustained the Division of Waste’s approval of the license renewal. In 

2006, the stakeholders appealed the Court’s decision to the Board. The Board upheld the 

Court’s decision. In 2007, the Board’s decision was appealed to and heard by South Carolina 

Supreme Court to determine where the case will be sent. The South Carolina Supreme Court’s 

decision was still pending at the time of the review. 

The Division of Waste monitors the maximum radioactivity limits, mass, and volume of each 

waste shipment and the total annual waste inventory at the facility. Under the restrictions of the 

Atlantic Compact, the amount of waste allowed to be received by the Barnwell site has reduced 
South Carolina Final Report Page 14 

and will continue to reduce over the years. Barnwell received 71,416 cubic feet in 2003; 57,242 

cubic feet in 2004; 42,785 cubic feet in 2005; and 38,466 cubic feet in 2006. As of May 31, 

Barnwell received 12,736 for 2007. Since 1971, Barnwell has received 28,047,035 cubic feet of 

waste. 

The review team noted that site monitoring data continues to show on- and off-site groundwater 

tritium contamination. A tritium plume has migrated off site, but remains within the property 

owned and controlled by EnergySolutions, LLC. Tritium was first measured in the disposal 

trench sumps in 1974 and in on-site monitoring wells in 1978. The enhancement of the final 

covers over the older disposal trenches appears to be effective as the on-site tritium 

concentrations are decreasing. The tritium level in groundwater collected from on- and off-site 

monitor wells exceeds the effluent concentration release limit specified in Department’s 

regulations; however, the Division of Waste estimates that doses from such releases are less 

than allowable dose limits of 25 millirem per year under Department regulations. The Division of 

Waste does have a contingency plan that has a series of action levels based on tritium 

concentrations at the compliance point. The third and final action level, requiring construction of 

a pump and treat system, is set at a concentration that correlates to a dose limit of 14 millirem 

per year. 

EnergySolutions, LLC, is required to provide temporal trends in groundwater concentrations at 

selected wells on an annual basis. The new requirement for trending data will enhance the 

Division of Waste’s ability to evaluate this issue. EnergySolutions, LLC, has been submitting an 

annual trending data report on tritium to the Division of Waste since fall of 2003. 

4.3.1 Technical Staffing and Training

The Division of Waste currently has six full-time technical staff (a reduction of one staff member 

since the last review). Four staff members (the Division of Waste’s Assistant Director, the 

Radioactive Waste Management Section Manager, the Radioactive Waste Management 

Consultant, and a part-time Environmental Engineer) left the program during the review period. 

The Assistant Director accepted a position in another area of the Department, the Consultant (a 

retired annuitant) retired, and the Radioactive Waste Management Section Manager left 

government service. The Division of Waste re-hired the Environmental Engineer as the full-time 

Radioactive Waste Management Section Manager. All staff members have, at least, Bachelor’s 

degrees or equivalent training and experience. Training procedures are outlined in the Division 

of Waste’s Standard Operating Procedures. The Division of Waste also maintains a Training 

Database for each staff member. The Training Database was not up to date at the time of the 

review. The review team discussed the benefits of maintaining an up-to-date record of staff’s 

training with Division of Waste managers. 

Staff training is adequate and comparable to IMC 1246. Two staff members attended the 

NRC’s Inspection Procedures Course in 2004. Three staff members attended the NRC’s 

Materials Control and Security Course in 2006. Division of Waste staff is very familiar with the 

regulations, policies, and procedures. 

The review team interviewed each of the staff members to discuss inspection procedures, 

inspection reports, and their technical backgrounds. The review team determined that the 

Division of Waste has an adequate level of well-trained, experienced, and professional staff. 
South Carolina Final Report Page 15 

4.3.2 Status of LLRW Disposal Inspections

The review team examined the status of the Barnwell site inspections. The Division of Waste 

performs inspections in accordance with the Radioactive Materials Licensing and Compliance 

Administrative Procedures Manual. This manual did not include time frames for report 

completion or for sending the inspection findings to the licensee. Inspections were conducted 

unannounced. The review team found that the Division of Waste’s site inspector conducts 

routine vehicle and shipment inspections and surveys, performs visual inspection of the vehicle 

for package integrity, observes preparation of shipments prior to disposal, and splits 

groundwater samples from on- and off-site monitor wells with EnergySolutions, LLC, on a 

quarterly basis. The review team also noted that Division of Waste health physicists perform 

weekly inspections and semi-annual inspections include Division of Waste managers, health 

physicists, and environmental engineers. 

The Division of Waste has changed the inspection frequency at the Barnwell site from annual to 

semi-annual. The review team confirmed the frequency of inspections through review of the site 

inspector logbook, and weekly and semi-annual inspection reports. In addition, the Division of 

Waste inspected five other licenses related to the Barnwell site operations during the review 

period. The frequency of inspections exceeded the inspection frequency requirements specified 

in IMC 2800. The Division of Waste’s maximum inspection interval is 3 years. The review team 

confirmed that there were no routine inspections overdue at the time of the review. 

The review team evaluated the timeliness of the issuance of inspection findings during the 

inspection casework review. For 19 routine inspection files examined, completion dates for 6 of 

the inspection reports ranged from 2 to 6 months after the inspection; therefore, the inspection 

finding letters for these inspections were not sent to the licensee within 30 days. For all other 

inspection files reviewed, the Division of Waste communicated inspection findings, including 

recommendations, to the licensee within 30 days. 

4.3.3 Technical Quality of Inspections

Nineteen inspection reports, as well as the site inspector logbook, were examined by the review 

team. The inspection reports were thorough and complete. Inspectors performed independent 

surveys and analyses during their inspections. The Division of Waste uses digital imaging to 

document site and shipment conditions during their inspections. 

Beginning in May 2004, the Division of Waste implemented a checklist-fashion inspection 

report. The Division of Waste maintains copies of all inspections reports. Depending on the 

outcome of the inspection, either a Form 591 (compliance form that may include 

recommendations) or a Form 592 (Notice of Violation) will be completed and sent to the 

licensee. Inspection findings, licensee’s responses, and closure of inspection issues were 

generally well documented. Copies of the inspection reports maintained in the Division of 

Waste’s files were not always signed by the inspector; however, the inspector’s name was 

printed on the form. 

Several of the inspection finding letters were dated prior to the Division of Waste managers’ 

review; however, none of the letters were transmitted to the licensee prior to review by the 

Division of Waste managers. Inspection findings were typically discussed with the Division of 
South Carolina Final Report Page 16 

Waste managers after the inspection. Once the manager concurred with the findings, the letter 

was sent out. Usually letters were sent out on the same day the report was completed. 

The site inspector maintains a log of each waste shipment received by the Barnwell site. The 

review team examined the waste shipment records and found them to be complete. 

The review team confirmed that the Division of Waste has an adequate supply of radiation 

detection instruments to support the current inspection program. Appropriate, calibrated survey 

instrumentation, such as a portable germanium detector, a portable smear counter, GeigerMueller survey meters, scintillation survey meters, ion chambers, and micro-R meters, was 

available. 

The review team examined the Division of Waste’s program to monitor the Barnwell site’s 

condition during operations. The Division of Waste reviews characterization of disposal 

trenches, including depth of the water table. Staff documented trench construction to ensure 

structural stability and took action regarding any deviations from the approved designs. The site 

inspector kept detailed and complete records of waste shipments, type, originator, volume, and 

activity. 

In addition to the review of information and interviews with the Division of Waste’s staff and 

managers during the on-site portion of the review, a 2-day visit to the Barnwell site was 

conducted on July 12-13, 2007. At the site, the Division of Waste’s on-site inspector was 

interviewed, facility operations and overall site conditions were examined, and another Division 

of Waste inspector was accompanied on the weekly site inspection. Both inspectors were very 

knowledgeable of the operations at the site and provided a thorough explanation of the site 

background, site description, storage facilities, and current activities, including environmental 

monitoring by EnergySolutions, LLC, and the Division. 

The Radiation and Environmental Monitoring Laboratory was visited on July 13, 2007. The 

Division of Waste oversees the laboratory. The laboratory was well maintained and equipped 

with adequate radiological instrumentation for sample analysis. The laboratory technical staff 

involved with the site are health physicists, who have been trained in radiochemistry, 

environmental sampling and analysis, and data evaluation. Results of environmental monitoring 

are maintained at the laboratory. 

4.3.4 Technical Quality of Licensing Actions

The review team evaluated two licensing actions on the waste site license, and 14 actions on 

other Division of Waste licenses completed during the review period. The Division of Waste 

maintains complete records regarding licenses, amendments, and renewals. The review team 

noted that the Division of Waste has adequate internal licensing guides and general licensing 

procedures. Overall, the review team found that the Division of Waste’s licensing actions were 

thorough, complete, and adequate to address health, safety, and security issues. 

A Ninety Days’ Notice is sent to the licensee prior to the license expiration date. Licenses are 

renewed on a 5-year frequency. All new licenses and most amended licenses are handdelivered to the licensee by Division of Waste staff. Each licensing action is reviewed by one 

individual and then discussed with Division of Waste managers prior to issuance. Division of 
South Carolina Final Report Page 17 

Waste managers sign new, amended, and renewed licenses prior to submittal to the licensees. 

Division of Waste staff follows its licensing guides, including checklists/worksheets, during the 

review process to ensure that licensees submit the information necessary to support their 

request. The licensee’s compliance history is taken into account when reviewing renewal 

applications. Deficiencies are addressed by letters and documented telephone conferences. 

For two amendments, the license or amendment copy in the file was not signed by Division of 

Waste managers. Signed copies of the amended licenses were transmitted to the licensee; 

however, the copies were added to the Division of Waste’s files prior to Division of Waste 

managers’ signatures. The review team discussed with the Division of Waste the benefit of 

making photocopies of signed licenses prior to transmitting to licensees to ensure that a signed 

copy is maintained in the Division of Waste’s files. 

The review team examined documentation of interactions with the licensee to ensure proper 

and clear communication of license conditions and regulatory requirements. The review team 

discovered that the Division of Waste’s files contain complete and timely documentation of 

interactions with the licensee and clear regulatory requirements. 

Prior notification is made to the Division of Waste by the licensee before a waste shipment 

leaves the originator. The Division of Waste reviews the “Radioactive Waste Prior Notification 

and Manifest Forms,” before authorizing the shipment of the waste. This review is done to 

ensure that waste characteristics and classifications are adequately determined and 

documented in accordance with license conditions. Waste originators go through a 

comprehensive analysis to demonstrate that radioactive waste complies with the requirements. 

The Division of Waste has procedures and license conditions to ensure that the site licensee 

does not accept radioactive waste for storage or disposal unless the shipper has completed the 

required information for the waste shipment on the NRC’s LLRW Manifest Form 540 “Shipping 

Papers,” Form 541 “Container and Waste Description,” and Form 542 “Manifest Index and 

Regional Compact Tabulation,” as applicable, or approved equivalent forms. 

The Division of Waste may grant variances under certain circumstances for waste type, waste 

class, activity, and volume. The licensee must make prior written notifications to the Division of 

Waste for variances. Approval of variances is part of the license condition. The review team 

evaluated one of the requested variances, which was denied by the Division of Waste. The 

review team found that the Division of Waste’s technical basis for denial was thorough and well 

documented. 

4.3.5 Technical Quality of Incident and Allegation Activities

Management of allegations and confidential sources are performed in accordance with the 

Division of Waste’s internal procedures. This guidance did not specifically include procedures 

for reporting incidents to NMED; however, in case of an incident related to the Division of 

Waste’s licenses, the Division’s inspectors conduct the investigation and coordinate with the 

Division of Radioactive Materials for entering the data into NMED. There were no incidents or 

allegations since the last review. 

The review team evaluated the casework for one concern referred to the Division of Waste by 

the NRC. The review team concluded that the Division of Waste took prompt and appropriate 
South Carolina Final Report Page 18 

action in response to the concern. The concern was appropriately investigated, and the 

appropriate parties were notified of the results. 

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

that South Carolina’s performance with respect to the indicator, LLRW Disposal Program, was 

satisfactory. 

5.0 SUMMARY 

As noted in Sections 3.0 and 4.0, South Carolina’s performance was found to be satisfactory for 

all performance indicators reviewed. The review team made no recommendations regarding the 

performance of the South Carolina Agreement State Program. Accordingly, the review team 

recommended, and the MRB agreed, that the South Carolina Agreement State Program was 

adequate to protect public health and safety and compatible with NRC's program. Based on the 

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

the next full IMPEP review take place in approximately 4 years. 
LIST OF APPENDIXES AND ATTACHMENT 

Appendix A IMPEP Review Team Members 

Appendix B South Carolina Organization Charts 

Appendix C Inspection Casework Reviews 

Appendix D License Casework Reviews 

Appendix E Incident Casework Reviews 

Appendix F Sealed Source and Device Casework Review 

Attachment September 20, 2007, Letter from C. Earl Hunter 

 South Carolina’s Response to Draft IMPEP Report 
APPENDIX A 

IMPEP REVIEW TEAM MEMBERS 

Name Area of Responsibility

Richard Blanton, FSME Team Leader 

 Technical Staffing and Training 

Sam Mulay, Region III Status of Materials Inspection Program 

 Technical Quality of Inspections 

 Inspector Accompaniments 

Joshua Daehler, MA Technical Quality of Licensing Actions 

 Sealed Source and Device Evaluation Program 

James Kottan, Region I Technical Quality of Incident and Allegation 

 Activities 

Monica Orendi, FSME Compatibility Requirements 

Muhammadali Abbaszadeh, TX Low-Level Radioactive Waste Disposal Program 

 Inspector Accompaniments 
APPENDIX B 

SOUTH CAROLINA ORGANIZATION CHARTS 

ADAMS ACCESSION NOS.: 

ML072330462, Pgs. 11-13 

ML072330465, Pg. 10 
APPENDIX C 

INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

SOUTH CAROLINA DIVISION OF RADIOACTIVE MATERIALS

LICENSING AND COMPLIANCE

File No.: 1 

Licensee: Palmetto Richland Memorial Hospital License No.: 40 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 5/8/07 Inspector: AR 

File No.: 2 

Licensee: Palmetto Richland Memorial Hospital License No.: 40 

Inspection Type: Special, Announced Priority: 1 

Inspection Date: 5/31/07 Inspector: JP 

File No.: 3 

Licensee: East Cooper Regional Medical Center License No.: 381 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 11/19/03 Inspector: MB 

File No.: 4 

Licensee: Care Alliance License No.: 646 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 11/21/03 Inspector: AR 

File No.: 5 

Licensee: GHS Hillcrest Hospital License No.: 400 

Inspection Type: Routine, Announced Priority: 3 

Inspection Date: 1/6/05 Inspector: JH 

File No.: 6 

Licensee: Aiken Regional Medical Centers License No.: 233 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 6/16/05 Inspector: AR 

File No.: 7 

Licensee: Applied Technical Services License No.: 410 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 5/9/07 Inspector: LC 

File No.: 8 

Licensee: Applied Technology Services, Inc. License No.: 410 

Inspection Type: Special, Announced Priority: 1 

Inspection Date: 12/13/06 Inspector: MW 
South Carolina Final Report Page C.2 

Inspection Casework Reviews

File No.: 9 

Licensee: Weld-Spect Technologies & Testing, Ltd., Co. License No.: 731 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 3/17/07 Inspector: AR 

File No.: 10 

Licensee: Weld-Spect Technologies & Testing, Ltd., Co. License No.: 731 

Inspection Type: Special, Announced Priority: 1 

Inspection Date: 3/17/07 Inspector: AR 

File No.: 11 

Licensee: Acuren Inspection, Inc. License No.: 595 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 8/16/06 Inspector: AR 

Comment: 

A field inspection has not been performed since August 21, 1998, when the license was 

initially issued; however, a good faith attempt was made to coordinate with the licensee 

to perform a field review as part of the August 16, 2006, inspection. 

File No.: 12 

Licensee: Acuren Inspection, Inc. License No.: 595 

Inspection Type: Special, Announced Priority: 1 

Inspection Date: 12/14/06 Inspector: AR 

File No.: 13 

Licensee: Jacobs Applied Technology, Inc. License No.: 205 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 2/21/07 Inspector: LC 

Comments: 

a) Inspection report did not indicate if visual/audible alarms were verified as operational 

during the inspection. 

b) Inspection report did not indicate if individual radiographers were interviewed. 

File No.: 14 

Licensee: Jacobs Applied Technology, Inc. License No.: 205 

Inspection Type: Special, Announced Priority: 2 

Inspection Date: 5/8/07 Inspector: MW 

File No.: 15 

Licensee: Pee Dee Isotopes, Inc. License No.: 599 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 1/11/06 Inspector: MB 
South Carolina Final Report Page C.3 

Inspection Casework Reviews

File No.: 16 

Licensee: General Engineering & Environmental, LLC. License No.: 601 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 4/22/05 Inspector: MW 

File No.: 17 

Licensee: Medical University of South Carolina License No.: 081 

Inspection Type: Routine, Announced Priority: 2 

Inspection Dates: 5/15-16/07 Inspectors: AR, MW, LC 

File No.: 18 

Licensee: Medical University of South Carolina License No.: 081 

Inspection Type: Special, Announced Priority: 2 

Inspection Date: 5/15/07 Inspector: AR 

File No.: 19 

Licensee: P.E.T. Net Solutions, Inc. License No.: 733 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 11/15/06 Inspector: MB 

File No.: 20 

Licensee: Low Country Diagnostics, Inc. License No.: 521 

Inspection Type: Routine Priority: 2 

Inspection Date: 5/17/07 Inspector: MB 

Comment: 

Final written inspection report was not completed. Inspector indicated the report will be 

completed by 7/31/07. Inspection findings were conveyed to the licensee the day of 

inspection. 

File No.: 21 

Licensee: Kershaw County Medical Center License No.: 176 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 6/19/03 Inspector: JH 

File No.: 22 

Licensee: Penn Tech Diagnostics, Inc. License No.: 538 

Inspection Type: Routine, Announced Priority: 3 

Inspection Date: 3/18/04 Inspector: JH 

Comment: 

Inspection report was not signed by management. 

File No.: 23 

Licensee: Geo-Systems Design & Testing, Inc. License No.: 421 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 8/4/05 Inspectors: AR, LC 
South Carolina Final Report Page C.4 

Inspection Casework Reviews

File No.: 24 

Licensee: Keowee Primary Care & Internal Medicine, PC License No.: 818 

Inspection Type: Initial, Announced Priority: 5 

Inspection Date: 1/22/07 Inspector: MW 

File No.: 25 

Licensee: GS2 Engineering & Environmental Consultants, Inc. License No.: 796 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 1/25/07 Inspectors: LC, KW 

File No.: 26 

Licensee: Mukesh Gandhi, M.D., PA License No.: 829 

Inspection Type: Initial, Unannounced Priority: 5 

Inspection Date: 4/2/07 Inspectors: MW, KW 

File No.: 27 

Licensee: Froehling & Robertson License No.: 170 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 4/19/07 Inspector: KW 

File No.: 28 

Licensee: Palmetto Primary Care Physicians License No.: 814 

Inspection Type: Initial, Unannounced Priority: 5 

Inspection Date: 11/9/06 Inspector: MW 

File No.: 29 

Licensee: Bausch & Lomb Greenville Solutions Facility License No.: 431 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 2/17/05 Inspector: DK 

File No.: 30 

Licensee: REVISS Services, Inc. License No.: IL-02058-01 

Inspection Type: Reciprocity, Announced Priority: 1 

Inspection Date: 4/17/07 Inspector: MW 

File No.: 31 

Licensee: S&ME, Inc. License No.: 092-0922-1 

Inspection Type: Reciprocity, Announced Priority: 1 

Inspection Date: 5/16/06 Inspector: MW 

File No.: 32 

Licensee: Nucletron Corporation License No.: MD-27-035-01 

Inspection Type: Reciprocity, Unannounced Priority: 2 

Inspection Date: 2/2/07 Inspector: AR 
South Carolina Final Report Page C.5 

Inspection Casework Reviews

File No.: 33 

Licensee: H&H X-Ray Services, Inc. License No.: LA-2970-L01 

Inspection Type: Reciprocity, Announced Priority: 1 

Inspection Date: 5/5/05 Inspector: MW 

SOUTH CAROLINA DIVISION OF WASTE MANAGEMENT

File No.: 34 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Dates: 8/4-8/03 Lead Inspector: JS 

Comments: 

a) Inspection report was completed approximately 3 months after the completion of the 

inspection. 

b) Inspection report and Form 591 were not signed by the lead inspector. 

c) Inspection letter, without violation, not issued until November 24, 2003. 

File No.: 35 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Dates: 4/5-9/04 Lead Inspector: JS 

Comment: 

 Inspection report and Form 591 were not signed by the lead inspector. 

File No.: 36 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Dates: 11/15-18/04 Lead Inspector: JS 

Comment: 

Inspection report was not signed by the lead inspector; however, Form 591 was signed 

by the lead inspector. 

File No.: 37 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Dates: 4/18-22/05 Lead Inspector: JS 

Comments: 

a) Inspection report was completed approximately 2 months after the completion of the 

inspection. 

b) Inspection report and Form 591 were not signed by the lead inspector. 

c) Inspection letter, without violation, was not issued until June 27, 2005. 
South Carolina Final Report Page C.6 

Inspection Casework Reviews

File No.: 38 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Dates: 10/24-27/05 Lead Inspector: JS 

Comment: 

Inspection report was not signed by the lead inspector; however, Form 591 was signed 

by the lead inspector. 

File No.: 39 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Dates: 5/15-19/06 Lead Inspector: JS 

Comment: 

Inspection report was not signed by the lead inspector; however, Form 591 was signed 

by the lead inspector. 

File No.: 40 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Dates: 1/22-25/07 Lead Inspector: JS 

Comments: 

a) Inspection report was not signed by the lead inspector. 

b) Inspection letter, without violation, was not issued until March 21, 2007. 

c) Inspection report was signed off as reviewed by management, but not dated. 

File No.: 41 

Licensee: Chem-Nuclear Systems, LLC License No.: 287-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 11/20/03 Inspector: MG 

Comments: 

a) Inspection report was completed approximately 4 months after the completion of the 

inspection. 

b) Inspection report and Form 591 were not signed by the inspector. 

c) Inspection letter, without violation, was not issued until March 31, 2004. 

File No.: 42 

Licensee: Chem-Nuclear Systems, LLC License No.: 287-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 11/22/05 Inspector: MY 

Comment: 

 Inspection report and Form 591 were not signed by the inspector. 
South Carolina Final Report Page C.7 

Inspection Casework Reviews

File No.: 43 

Licensee: EnergySolutions, LLC License No.: 287-02 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 2/11/03 Inspector: MY 

Comments: 

a) Inspection report was completed approximately 6 months after the completion of the 

inspection. 

b) Inspection report and Form 591 were not signed by the inspector. 

c) Inspection letter, without violation, was not issued until September 3, 2003. 

File No.: 44 

Licensee: EnergySolutions, LLC License No.: 287-02 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 3/23/04 Inspector: MY 

Comment: 

 Inspection report and Form 591 were not signed by the inspector. 

File No.: 45 

Licensee: EnergySolutions, LLC License No.: 287-02 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 11/22/05 Inspector: MP 

Comment: 

 Inspection report and Form 591 were not signed by the inspector. 

File No.: 46 

Licensee: EnergySolutions, LLC License No.: 287-02 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 5/16/07 Inspector: MP 

Comments: 

a) Inspection report was signed off as reviewed by management, but not dated. 

b) Inspection report and Form 591 were not signed by the inspector. 

File No.: 47 

Licensee: Chem-Nuclear, LLC License No.: 287-03 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 6/4/03 Inspector: MG 

Comments: 

a) Inspection report was completed approximately 4 months after the completion of the 

inspection. 

b) Inspection report was not signed by the inspector. 

c) Inspection letter, without violation, was not issued until October 20, 2003. 
South Carolina Final Report Page C.8 

Inspection Casework Reviews

File No.: 48 

Licensee: Chem-Nuclear, LLC License No.: 287-03 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 8/16/05 Inspector: MP 

Comment: 

 Inspection report and Form 591 were not signed by the inspector. 

File No.: 49 

Licensee: EnergySolutions, LLC License No.: 287-04 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 4/17/06 Inspector: JS 

Comment: 

Inspection report was reviewed by two managers. Inspection report was signed, but not 

dated, by one of the managers and neither signed nor dated by the other. 

File No.: 50 

Licensee: EnergySolutions, LLC License No.: 287-04 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 2/12/07 Inspector: JS 

Comments: 

a) Inspection report was signed off as reviewed by management, but not dated. 

b) Inspection report was not signed by the lead inspector; however, Form 591 was signed 

by the lead inspector. 

File No.: 51 

Licensee: EnergySolutions, LLC License No.: 287-05 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 11/20/03 Inspector: MG 

Comments: 

a) Inspection report was completed approximately 4 months after the completion of the 

inspection. 

b) Inspection report and Form 591 were not signed by the inspector. 

File No.: 52 

Licensee: EnergySolutions, LLC License No.: 287-05 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 11/22/05 Inspector: MG 

Comment: 

 Inspection report and Form 591 were not signed by the inspector. 
South Carolina Final Report Page C.9 

Inspection Casework Reviews

INSPECTOR ACCOMPANIMENTS

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

Accompaniment No.: 1 

Licensee: Palmetto Richland Memorial Hospital License No.: 40 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 5/8/07 Inspector: AR 

Comment: 

Inspector did not physically verify the operability of the closed-circuit television, intercom, 

source status indicator lights, etc. 

Accompaniment No.: 2 

Licensee: Jacobs Applied Technology, Inc. License No.: 205 

Inspection Type: Special, Announced Priority: 1 

Inspection Date: 5/8/07 Inspector: MW 

Accompaniment No.: 3 

Licensee: Applied Technology Services, Inc. License No.: 410 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 5/9/07 Inspector: LC 

Accompaniment No.: 4 

Licensee: Chem-Nuclear Systems, LLC No.: 097 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 7/12/07 Inspector: MY 
APPENDIX D 

LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

SOUTH CAROLINA DIVISION OF RADIOACTIVE MATERIALS

LICENSING AND COMPLIANCE

File No.: 1 

Licensee: Mahlo America, Inc. License No.: 142 

Type of Action: Amendment Amendment No.: 19 

Date Issued: 5/22/07 License Reviewer: MW 

File No.: 2 

Licensee: Low Country Diagnostics, Inc. License No.: 521 

Type of Action: Renewal Amendment No.: 19 

Date Issued: 12/30/05 License Reviewer: MB 

File No.: 3 

Licensee: Shertech Laboratories, LLC License No.: 816 

Type of Action: New Amendment No.: N/A 

Date Issued: 12/14/05 License Reviewer: MB 

File No.: 4 

Licensee: Smurfit-Stone Container Enterprises, Inc. License No.: 080 

Type of Action: Amendment Amendment No.: 32 

Date Issued: 7/13/07 License Reviewer: MW 

File No.: 5 

Licensee: Medical University of SC License No.: 081 

Type of Action: Renewal Amendment No.: 70 

Date Issued: 1/24/07 License Reviewer: MB 

File No.: 6 

Licensee: Palmetto Health Richland License No.: 586 

Type of Action: Renewal Amendment No.: 9 

Date Issued: 9/9/03 License Reviewer: MB 

File No.: 7 

Licensee: Georgetown Cancer Center License No.: 786 

Type of Action: New Amendment No.: N/A 

Date Issued: 9/28/04 License Reviewer: MB 

File No.: 8 

Licensee: Carolina Cardiology Consultants, P.A. License No.: 854 

Type of Action: New Amendment No.: N/A 

Date Issued: 7/13/07 License Reviewer: KW 
South Carolina Final Report Page D.2 

License Casework Reviews

File No.: 9 

Licensee: ESP Associates, P.A. License No.: 792 

Type of Action: Amendment Amendment No.: 2 

Date Issued: 10/11/06 License Reviewer: LC 

File No.: 10 

Licensee: Furman University License No.: 052 

Type of Action: Amendment Amendment No.: 15 

Date Issued: 3/6/07 License Reviewer: AR 

File No.: 11 

Licensee: Washington Group International, Inc. License No.: 419 

Type of Action: Amendment Amendment No.: 48 

Date Issued: 3/22/07 License Reviewer: MW 

File No.: 12 

Licensee: Bausch & Lomb License No.: 431 

Type of Action: Amendment Amendment No.: 12 

Date Issued: 7/19/06 License Reviewer: AR 

File No.: 13 

Licensee: JANX Integrity Group License No.: NRC 21-16560-01 

Type of Action: Reciprocity Amendment No.: 16 

Date Issued: 6/12/06 License Reviewer: HL 

File No.: 14 

Licensee: Westinghouse Electric Company License No.: 317 

Type of Action: Termination Amendment No.: 18 

Date Issued: 9/10/03 License Reviewer: JP 

SOUTH CAROLINA DIVISION OF WASTE MANAGEMENT

NOTE: In addition to the files listed below, licensing actions in the Division’s casework listed in 

Appendix C were also reviewed without comment. 

File No.: 15 

Licensee: TD*X Technical Center, LLC License No.: 843 

Type of Action: New Amendment No.: 1 

Date Issued: 2/23/07 License Reviewer: MY 

File No.: 16 

Licensee: First Equity Investors, LLC License No.: 847 

Type of Action: New Amendment No.: 1 

Date Issued: 6/4/07 License Reviewer: MY 
APPENDIX E 

INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: Medical University of South Carolina License No.: SC-080 

Date of Incident: 7/31/03 Incident Log No.: SC030006 

Investigation Date: N/A Type of Incident: Medical Event 

 Type of Investigation: N/A 

File No.: 2 

Licensee: Costal Engineering and Testing Co. License No.: SC-368 

Date of Incident: 10/10/03 Incident Log No.: SC030007 

Investigation Date: 10/10/03 Type of Incident: Theft of RAM 

 Type of Investigation: Licensee Report 

File No.: 3 

Licensee: Sun Chemical Co. License No.: SC-765 

Date of Incident: 11/10/03 Incident Log No.: SC030008 

Investigation Date: N/A Type of Incident: Loss of RAM 

 Type of Investigation: N/A 

File No.: 4 

Licensee: Palmetto Health Baptist Hospital License No.: SC-076 

Date of Incident: 3/17/04 Incident Log No.: SC040003 

Investigation Dates: Various Type of Incident: Overexposure 

 Type of Investigation: Licensee Report 

File No.: 5 

Licensee: Cancer Center of the Carollinas License No.: SC-676 

Date of Incident: 6/3/04 Incident Log No.: SC040004 

Investigation Date: N/A Type of Incident: Medical Event 

 Type of Investigation: N/A 

File No.: 6 

Licensee: King Asphalt, Inc. License No.: SC-436 

Date of Incident: 9/3/04 Incident Log No.: SC040005 

Investigation Date: 9/3/04 Type of Incident: Theft of RAM 

 Type of Investigation: Phone 

File No.: 7 

Licensee: Shealy Environmental Services License No.: SC-426 

Date of Incident: 10/18/04 Incident Log No.: SC040006 

Investigation Date: 10/18/04 Type of Incident: Loss of RAM 

 Type of Investigation: Phone 
South Carolina Final Report Page E.2 

Incident Casework Reviews 

File No.: 8 

Licensee: Atlantic Shutter License No.: N/A 

Date of Incident: 3/22/05 Incident Log No.: SC050001 

Investigation Date: N/A Type of Incident: Loss of RAM 

 Type of Investigation: N/A 

File No.: 9 

Licensee: Professional Service Industries, Inc. License No.: SC-090 

Date of Incident: 5/12/05 Incident Log No.: SC050003 

Investigation Date: N/A Type of Incident: Theft of RAM 

 Type of Investigation: N/A 

File No.: 10 

Licensee: Geo-Systems Design and Testing License No.: SC-412 

Date of Incident: 9/1/05 Incident Log No.: SC050004 

Investigation Date: 9/6/05 Type of Incident: Loss of RAM 

 Type of Investigation: Phone 

File No.: 11 

Licensee: East Coast Isotopes, Inc. License No.: SC-705 

Date of Incident: 12/14/05 Incident Log No.: SC050007 

Investigation Date: N/A Type of Incident: Theft of RAM 

 Type of Investigation: N/A 

File No.: 12 

Licensee: Froehling and Robertson, Inc. License No.: SC-170 

Date of Incident: 6/23/06 Incident Log No.: SC060006 

Investigation Date: N/A Type of Incident: Damaged Gauge 

 Type of Investigation: N/A 

File No.: 13 

Licensee: Trident Medical Center License No.: SC-210 

Date of Incident: 6/27/06 Incident Log No.: SC060007 

Investigation Date: N/A Type of Incident: Equipment Failure 

 Type of Investigation: N/A 

File No.: 14 

Licensee: Giant Cement Co. License No.: GL-0081 

Date of Incident: 7/5/2006 Incident Log No.: SC060008 

Investigation Date: N/A Type of Incident: Loss of RAM 

 Type of Investigation: N/A 

File No.: 15 

Licensee: Cryovac Sealed Air Corporation License No.: SC-231 

Date of Incident: 5/6/06 Incident Log No.: SC060009 

Investigation Date: N/A Type of Incident: Leaking Source 

 Type of Investigation: N/A 
South Carolina Final Report Page E.3 

Incident Casework Reviews 

File No.: 16 

Licensee: Care Alliance Health Services-Roper Hospital License No.: SC-646 

Date of Incident: 1/9/07 Incident Log No.: SC070001 

Investigation Date: N/A Type of Incident: Equipment Failure 

 Type of Investigation: N/A 

File No.: 17 

Licensee: Millikin License No.: GL-0060 

Date of Incident: 12/21/06 Incident Log No.: SC070002 

Investigation Date: 1/4/07 Type of Incident: Loss of RAM 

 Type of Investigation: Site 

File No.: 18 

Licensee: McLeod Regional Medical Center License No.: SC-139 

Date of Incident: 10/9/06 Incident Log No.: SC070003 

Investigation Date: 11/2/06 Type of Incident: Medical Event 

 Type of Investigation: Site 
APPENDIX F 

SEALED SOURCE AND DEVICE CASEWORK REVIEW 

File No. 1: 

Registry No.: SC-1276-D-101-G SS&D Use Code: (E) Beta Gauges 

Applicant’s Name: Mahlo America, Inc. Type of Action: New Registration 

Date Issued: 4/26/07 SS&D Reviewers: JJ, JP 

Comments: 

a) Promethium-147 is incorrectly identified as Promathium-147 twice on Page 1 of the 

registration. 

b) Sr-90 is incorrectly identified as Sr-95 on page 4 of the registration. 

c) A letter referenced in the registration as letter dated October 30, 2006, was actually 

received on October 30, 2006. The letter was dated October 24, 2006. 
ATTACHMENT 

September 20, 2007, Letter from C. Earl Hunter 

South Carolina’s Response to Draft IMPEP Report 

ADAMS: ML072770884