December 5, 2009 

Mel Kohn, M.D. 

Director 

Oregon Public Health Division 

Department of Human Services 

800 NE Oregon Street, Suite 640 

Portland, OR 97232-2162 

Dear Dr. Kohn: 

On November 10, 2009, the Management Review Board (MRB) met to consider the proposed 

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

Agreement State Program. The MRB found the Oregon Agreement State Program adequate to 

protect public health and safety, but needs improvement, and compatible with the U.S. Nuclear 

Regulatory Commission’s (NRC) program. The MRB extended the period of monitoring of the 

Oregon Agreement State Program. As part of the monitoring process, NRC will conduct calls 

with the appropriate representatives from the Oregon Radiation Protection Services Section 

every 3 months. 

Section 5.0, page 12, of the enclosed final report contains a summary of the IMPEP review 

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 Oregon Agreement 

State Program will take place in approximately 3 years to accommodate the State’s request to 

conduct IMPEP reviews when the Oregon Legislature is not in session. A periodic meeting to 

review the State’s progress of addressing the team’s recommendations is tentatively scheduled 

for August 2010. 

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: 

Oregon Final IMPEP Report 

cc w/enclosure: See next page. 
M. Kohn -2 - 

cc w/encl: Gail R. Shibley, Administrator 

 Office of Environmental Public Health 

 Terry D. Lindsey, Manager 

 Oregon Radiation Protection Services Section 

 Ken Niles, State Liaison Officer 

 Oregon Department of Energy 

 Cindy Cardwell, TX 

 Organization of Agreement States 

 Liaison to the MRB 
December 5, 2009 

Mel Kohn, M.D. 

Director 

Oregon Public Health Division 

Department of Human Services 

800 NE Oregon Street, Suite 640 

Portland, OR 97232-2162 

Dear Dr. Kohn: 

On November 10, 2009, the Management Review Board (MRB) met to consider the proposed 

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

Agreement State Program. The MRB found the Oregon Agreement State Program adequate to 

protect public health and safety, but needs improvement, and compatible with the U.S. Nuclear 

Regulatory Commission’s (NRC) program. The MRB extended the period of monitoring of the 

Oregon Agreement State Program. As part of the monitoring process, NRC will conduct calls 

with the appropriate representatives from the Oregon Radiation Protection Services Section 

every 3 months. 

Section 5.0, page 12, of the enclosed final report contains a summary of the IMPEP review 

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 Oregon Agreement 

State Program will take place in approximately 3 years to accommodate the State’s request to 

conduct IMPEP reviews when the Oregon Legislature is not in session. A periodic meeting to 

review the State’s progress of addressing the team’s recommendations is tentatively scheduled 

for August 2010. 

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: 

Oregon Final IMPEP Report 

cc w/enclosure: See next page. 

Distribution: See next page.

 ML093170065 EDATS: FSME-2009-0061 

OFFICE FSME/MSSA FSME/MSSA FSME/MSSA FSME/MSSA 

NAME ATMcCraw:knm1 ADWhite TReis RJLewis 

DATE 11/13/09 11/ 20/09 11/20/09 11/23/09 

OFFICE Tech Editor FSME DEDMRT 

NAME CPoland (PTressler for) CLMiller MJVirgilio 

DATE 11/25/09 11/27/09 12/05/09 

OFFICIAL RECORD COPY
Letter to Mel Kohn from Martin J. Virgilio dated: December 5, 2009 

DISTRIBUTION: FSME-2009-0061

MSSA RF DCD (SP01) 

EDO RF 

RidsFsmeOd Chairman Jaczko 

RidsSecyCorrespondenceMailCenter Commissioner Klein 

MBeardsley, FSME/MSSA Commissioner Svinicki 

LMcLean, RIV/RSAO SECY 

CPederson, RIII 

DSollenberger 

Robert Greger, California 

AHowell, RIV 

SGabriel, RI 

JKatanic, FSME/MSSA 

MFranovich, OEDO 

APowell, OCA (2 copies) 

JGray, OGC 

BJones, OGC 
Enclosure 

INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

REVIEW OF THE OREGON AGREEMENT STATE PROGRAM 

August 24-27, 2009 

FINAL REPORT
Oregon Final Report Page 1 

1.0 INTRODUCTION 

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

review was conducted during the period of August 24-27, 2009, by a review team composed of 

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

California. 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 NRC Management Directive 5.6, “Integrated Materials 

Performance Evaluation Program (IMPEP),” dated February 26, 2004. Preliminary results of the 

review, which covered the period of August 25, 2006, to August 27, 2009, for the performance 

indicators, Technical Staffing and Training and Status of Materials Inspection Program; and the 

period of February 1, 2008, to August 27, 2009, for the other performance indicators; were 

discussed with Oregon managers on the last day of the review. 

A draft of this report was issued to Oregon for factual comment on September 30, 2009. The 

State responded by e-mail dated October 23, 2009, from Terry Lindsey, Manager, Radiation 

Protection Services Section (the Section). A copy of the State’s response is included as the 

Attachment to this report. The Management Review Board (MRB) met on November 11, 2009, 

to consider the proposed final report. The MRB found the Oregon Agreement State Program 

adequate to protect public health and safety, but needs improvement, and compatible with 

NRC’s program. The MRB extended the period of monitoring of the Oregon Agreement State 

Program. 

The Oregon Agreement State Program is administered by the Section in the Division of Public 

Health (the Division). The Division is part of the Oregon Department of Human Services (the 

Department). Organization charts for the State and the Section are included in Appendix B. 

At the time of the review, the Oregon Agreement State Program regulated approximately 400 

specific licenses authorizing byproduct, source, and certain special nuclear materials. The 

review focused on the radioactive materials program as it is carried out under the Section 274b. 

(of the Atomic Energy Act of 1954, as amended) Agreement between NRC and the State of 

Oregon. 

In preparation for the review, a questionnaire addressing the common and applicable noncommon performance indicators was sent to the Section on June 15, 2009. The Section 

provided a response to the questionnaire on July 29, 2009. A copy of the questionnaire 

response can be found in the NRC’s Agencywide Documents Access and Management System 

(ADAMS) using the Accession Number ML092720448. 

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 Oregon statutes and 

regulations; (3) analysis of quantitative information from the Section’s database; (4) technical 

review of selected regulatory actions; (5) field accompaniments of four inspectors; and (6) 

interviews with staff and managers. 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 Oregon Agreement State Program’s 

performance. 
Oregon Final Report Page 2 

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

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

are presented in Section 3.0. Section 4.0 details the results of the review of the applicable noncommon performance indicators, and Section 5.0 summarizes the review team's findings and 

recommendations. The review team’s recommendations 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 followup IMPEP review, which concluded on January 31, 2008, the review 

team left three recommendations open regarding program performance that were identified 

during the prior IMPEP review, which concluded on August 24, 2006. The status of the open 

recommendations is as follows: 

1. The review team recommends that the State place greater emphasis on providing 

sufficient detail in inspection reports to allow Section management and staff to 

understand the technical basis for inspection findings. (Section 2.1) 

Status: The review team found that the Section has continued their improved 

inspection documentation, with most reports containing sufficient documentation 

to adequately communicate the scope of the inspection, the scope of the 

licensee’s program, the observed licensee activities, independent survey results, 

and specific inspection findings to support findings communicated to licensees. 

The review team noted isolated documentation issues rather than systemic 

problems. The review team noted that the Field Operations/Emergency 

Response Manager has been auditing the quality of inspection documentation, 

including inspection reports, and has instituted actions to correct individual 

performance issues that he identifies. This recommendation is closed. 

2. The review team recommends that the State ensure that radioactive materials 

inspectors are accompanied by supervisors, at least annually, to promote quality 

and consistency in the inspection program. (Section 2.1) 

Status: The review team was informed by the Section Manager that the Field 

Operations/Emergency Response Manager was considered qualified to perform full 

accompaniments by mid-2008, based on training he had received by that time. The 

review team noted that at least one accompaniment was made annually of each 

inspector subsequent to that time. The Section Manager further stated that the lead 

radioactive material inspector would also accompany each inspector annually in order to 

further strengthen this aspect of the Section’s performance. This recommendation is 

closed. 

3. The review team recommends that the State take measures to ensure proper 

documentation and appropriate response, review, enforcement, and followup of 

all radioactive materials incidents. (Section 2.3) 
Oregon Final Report Page 3 

 Status: The review team reviewed approximately 100 incident files and found 

inadequate followup for one medical licensee that had several medical events 

(under doses) that should have been reported to NMED. The overall incident 

followup as demonstrated in the other files was considered acceptable. This 

recommendation is closed. 

3.0 COMMON PERFORMANCE INDICATORS 

Five common performance indicators are used to review 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 Section’s staffing level and staff 

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

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

indicator; interviewed managers and staff, reviewed job descriptions and training records, and 

considered any workload backlogs. 

The day-to-day operations of the Oregon Agreement State Program are executed by the 

Section. The Section is composed of two management units: the Emergency Preparedness, 

Licensing & Administration Unit and the Emergency Response, Field Operations & Technical 

Services Unit. Each unit is headed by a Manager. Staff members in the Section perform 

licensing, inspection, training, and emergency preparedness and response activities for 

radioactive materials facilities. 

The Section has approximately 5.25 full-time equivalents assigned to perform the technical 

aspects of the radioactive materials program. The Section’s radioactive materials program staff 

is composed of four technical staff members, a medical physicist, and two supervisors. One 

staff member is assigned primarily to licensing activities. The inspection workload was split 

among the other three technical staff members. In addition, the Section is cross-training staff 

from other areas of the Section (e.g., tanning and x-ray) to augment the radioactive materials 

inspection program. One tanning inspector was recently qualified to conduct gauge inspections, 

and the x-ray staff assists in incident response. The review team concluded that the Section’s 

staffing level is adequate to carry out its regulatory duties. 

The review team noted that Section management encourages and supports training 

opportunities based on program needs and funding. The Section’s training and qualification 

program for technical staff uses the technical course requirements in NRC Inspection Manual 

Chapter (IMC) 1246, “Formal Qualification Programs in the Nuclear Material Safety and 

Safeguards Program Area.” 

Technical staff qualification is achieved through a combination of education and experience, 

formal classroom training, and on-the-job training. The review team noted that, while the 

Section maintains records of formal classroom training for each staff member, it does not 

maintain records of self-study or on-the-job qualification training, such as training in applicable 
Oregon Final Report Page 4 

regulatory requirements. This issue was identified during the inspector accompaniments where 

a new inspector was not familiar with the portable gauge security regulatory requirements. The 

inspector’s qualification training had not included a comprehensive review of the applicable 

regulations pertinent to portable gauge inspection. The review team observed through 

interviews, casework examinations, and inspector accompaniments that, while the staff was in 

general technically qualified to perform inspection and licensing activities, some critical 

knowledge of regulatory requirements and guidance documents was in need of improvement in 

the licensing and inspection programs. Sections 3.3 and 3.4 of this report contain the review 

team’s specific observations related to needed improvements in training. The review team 

recommends the State develop and use a documented formal qualification program (including 

refresher training) for inspection and licensing staff that would include journals that clearly 

indicate each individual’s training and qualification including oral and/or written evaluation of 

their understanding of regulations and guidance documents. 

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

that Oregon's performance with respect to the indicator, Technical Staffing and Training, was 

satisfactory. 

3.2 Status of Materials Inspection Program

The review team focused on five factors in 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 is based 

on the Section’s response to the questionnaire relative to this indicator, data gathered from the 

Section’s licensing and inspection database, examination of completed inspection casework, 

and interviews with Section managers and staff. 

The review team verified that the Section’s inspection priorities, with the exception of one 

category of license, were at least as frequent as the inspection priorities prescribed by NRC’s 

IMC 2800, “Materials Inspection Program.” The Section performs inspection of many license 

categories more frequently than prescribed by IMC 2800. The one exception noted by the 

review team was for medical therapy - emerging technology licenses. The Section inspects this 

category of license every 3 years; whereas, IMC 2800 calls for inspections of this license type 

every 2 years. This discrepancy resulted in an inspection being performed overdue by IMC 

2800 standards during the review period. The discrepancy was corrected by the Section. The 

review team noted that the Section corrected the inspection priority discrepancies for source 

material and special nuclear material possession licenses noted during the 2006 IMPEP review. 

The Section conducted 137 Priority 1, 2, and 3 or initial inspections during the review period. 

Using information gathered from the Section’s database, the review team identified eight 

inspections conducted overdue during the review period, six of which were initial inspections. 

Four of the six overdue initial inspections occurred because Section staff thought initial 

inspections were due by the end of the 1-year anniversary month, not within the 1-year period. 

The review team noted that the length of time inspections were conducted overdue ranged from 

3 to 355 days. The review team verified that there were no overdue inspections at the time of 

the review. The review team calculated that the Section conducted approximately 6 percent of 

all Priority 1, 2, and 3 and initial inspections overdue during the review period. 
Oregon Final Report Page 5 

The Section’s policy is to issue inspection results to licensees at the conclusion of the on-site 

inspection using an Oregon 591 form. Only in infrequent circumstances, such as escalated 

enforcement or the need for further evaluation of inspection findings, are the inspection results 

not provided to licensees before the inspectors leave the inspection sites. The review team 

verified that inspection finding were communicated to licensees within 30 days of completion of 

the inspections. 

The Section receives notifications of reciprocity work within Oregon at a rate of 2-3 per work day 

which are forwarded to the inspection group. Typically all reciprocity work is inspected if the 

reciprocity licensee hasn’t been inspected within the preceding twelve months. Most of the 

reciprocity licensees are NRC Priority 5 licensees. Usually, no more than 15 NRC Priority 1-3 

licensees request reciprocity per year. Reciprocity inspections of candidate licensees during the 

years 2006 to 2009 (through July 31, 2009) totaled 5, 5, 7, and 3, respectively, which 

corresponded to at least 20 percent per year. The review team noted that in the two reciprocity 

inspections reviewed in which regulatory violations were identified, the inspection results were 

communicated to the licensing State. 

The Section has 14 licenses subject to the Increased Controls. The initial inspections of 12 of 

the 14 licenses were completed in the first year, with the remaining two completed in the second 

year. Although documentation was not located that described the prioritization methodology 

utilized for scheduling the initial inspections, the methodology described by Section staff met the 

criteria of COMSECY-05-0028. The review team noted that continuing Increased Controls 

inspections were conducted in conjunction with applicable routine inspections and that new 

licensees subject to the Increased Controls are inspected for compliance prior to receiving 

authorization to possess materials in risk-significant quantities. 

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

that Oregon’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 for 16 radioactive materials inspections conducted during the review period, and 

accompanied each of the four current inspectors on field inspections. The casework examined 

included a cross-section of inspections conducted by the four current inspectors and covered a 

wide variety of inspection types. These included: industrial radiography, high dose-rate remote 

afterloader, mobile nuclear medicine - positron emission tomography, broad scope industrial, 

medical - therapy, gamma knife, medical - diagnostic and imaging, nuclear pharmacy, portable 

gauge, and research and development. The casework also included reciprocity and Increased 

Controls inspections. Appendix C lists the inspection casework reviewed and includes casespecific comments. 

Based on the evaluation of casework, the review team determined that inspections covered 

almost all aspects of the licensees’ radiation safety and security programs. The review team 

noted instances where areas were either missed during the inspection or not described in the 

inspection reports. The inspections for Increased Controls licensees appropriately addressed 

licensee compliance with the Increased Controls requirements. Licensee progress on 
Oregon Final Report Page 6 

implementation of the finger printing and national source tracking requirements were not 

consistently addressed in inspection reports; however, an independent tracking system of the 

licensees’ implementation statuses was maintained by the Section that demonstrated that all 

required licensees had addressed the requirement. 

Documents involving Increased Controls information were maintained in a locked file cabinet 

with limited access; however, the documents (both licensing and inspection) were not marked 

as security sensitive information. Although there were no instances of improper release of 

information, the review team was concerned that without proper marking the likelihood of 

release was much greater. The review team recommends that the State develop and 

implement a procedure for the control of sensitive or security-related information that provides 

guidance to identify, mark, handle, and protect such information. 

The review team noted that the Section is continuing its efforts to upgrade inspection 

procedures. Currently, one procedure, covering fixed and portable gauges, has been formally 

adopted, with several others in various stages of development. Pending completion of the 

upgraded procedures, a mixture of draft and existing Section inspection procedures and NRC 

inspection procedures are being utilized by inspectors. In one instance during the review team 

accompaniments, an important inspection issue (securing of portable gauges), and one of 

lesser importance, were not covered by the inspector. The review team discussed with the 

Section the benefits of the emphasis on continued development of inspection procedures and 

training in use of these procedures. 

With infrequent exceptions, inspection findings were routinely provided to licensees at the 

conclusion of inspections using an Oregon 591 form. An inspection report is routinely 

generated after returning to the office. In addition to the Oregon 591 form that is left at the time 

of the inspection, the Section also provides the inspection report to the licensee with a cover 

letter communicating the significance of the inspection findings. The Section uses a severity of 

non-compliances system based on a severity level scale of 1-5. The review team noted 

inconsistency in applying this system and the assigning of severity levels which could be 

addressed by completion of procedures and training in this area. The Section committed to 

implement an enforcement procedure that includes typical violations and related severity levels. 

The review team verified that the Section maintains an adequate supply and types of calibrated 

survey instruments to support the inspection program, and to respond to incidents and 

emergencies. The Section has the capability to conduct gamma analysis of samples and can 

contract for additional analyses, as needed. 

The review team accompanied four inspectors in July 2009. The inspectors conducted 

inspections at a portable gauge user, a nuclear pharmacy, an industrial radiographer, and a 

hospital. Appendix C lists the inspector accompaniments and includes the review team’s 

observations. In general, the inspectors used good inspection techniques including use of 

performance based criteria. The inspectors were trained, prepared for the inspections, and 

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

conducted interviews with appropriate personnel, observed licensed operations, conducted 

confirmatory measurements, and utilized good health physics practices. The inspectors held 

entrance and exit meetings with the appropriate level of licensee management. The review 

team determined that the inspections were adequate to assess radiological health, safety, and 
Oregon Final Report Page 7 

security at the licensed facilities with one exception. During one accompaniment, the inspector 

did not identify a portable gauge licensee’s failure to provide two independent physical controls 

to secure gauges from unauthorized removal, for both storage and transportation. The 

inspector was unfamiliar with this regulatory requirement, as well as other applicable Oregon 

regulations. The review team found that the Section individual who had been assigned to train 

this inspector also was found not to be knowledgeable of the Oregon regulation to secure 

portable gauges from unauthorized removal. The remaining two Oregon inspectors were 

knowledgeable of the requirement. The inspection procedure carried by an inspector 

referenced the two-physical-control requirement in somewhat general terms. The review team 

noted that, while the portable gauge licensee was subsequently informed of the regulatory 

requirement for two independent physical controls for their portable gauge, the licensee was not 

cited for the non-compliance. 

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

that Oregon’s performance with respect to the indicator, Technical Quality of Inspections, was 

satisfactory, but needs improvement. 

3.4 Technical Quality of Licensing Actions

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

19 licensing actions involving 17 specific licenses. Licensing actions were reviewed for 

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

users, adequacy of facilities and equipment, adherence to good health physics practices, 

financial assurance, operating and emergency procedures, appropriateness of license 

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

appropriate correspondence, reference to appropriate regulations, supporting documentation, 

consideration of enforcement history, pre-licensing visits, peer or supervisory review, and proper 

signatures. 

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

completed during the review period. Licensing actions selected for evaluation included 3 new 

licenses, 11 amendments, 3 renewals, and 2 license terminations. Files reviewed included a 

cross-section of license types, including: medical diagnostic and therapy, brachytherapy, 

gamma knife, nuclear pharmacy, cyclotron, academic, medical broad scope, fixed and portable 

gauge, and industrial radiography. A listing of the licensing casework reviewed, with casespecific comments, can be found in Appendix D. 

Overall, the review team found that the licensing actions were complete and addressed health 

and safety issues. In most cases, the staff followed appropriate licensing guides during the 

review process to ensure that licensees submit information necessary to support their request. 

Deficiency correspondence was used, as appropriate, to obtain additional information from the 

applicant or licensee. The Section has one senior staff member whose primary responsibility is 

licensing and a second staff member is being cross-trained to conduct licensing actions. At a 

minimum, each licensing action has a peer review and a management review. The licensing 

manager signs licenses. 

The review team examined the Section’s licensing practices in regard to the Increased Controls, 

Fingerprinting Orders, and the National Source Tracking System. The review team noted that 
Oregon Final Report Page 8 

the Section added legally binding license conditions to the licenses that met the criteria for 

implementing these requirements in a timely manner. The Section evaluates new license 

applications and license amendments to determine the applicability of enhanced security 

requirements. 

The Section uses NRC’s pre-licensing guidance to evaluate new licensees to determine when 

and how to perform pre-licensing visits of new applicants or licensees requesting radioactive 

material possession limits in quantities of concern. The review team evaluated the casework for 

the pre-licensing visits of new applicants performed during the review period and found that the 

visits were appropriately performed and well documented. 

The review team found that actions terminating licenses were well documented, and included 

the appropriate material survey records. All files reviewed contained documentation of proper 

disposal or transfer. 

Section staff stated that they use licensing procedures include use of the NUREG-1556 series 

and the NRC’s Title 10 Code of Federal Regulations (CFR) Part 35.1000 licensing guidance. 

However, the review team observed inconsistent use of this guidance for certain licensing 

actions that are complex and/or infrequently encountered. The review team identified potential 

health and safety and regulatory compliance issues with several major licensing actions. These 

complex actions raised several significant regulatory issues that were not properly addressed in 

the licensing process such as proper exemption for a new gamma knife design, proper training 

information for an authorized nuclear pharmacist, adequate information for licensing a Type A 

broad scope license, and the need for two independent controls on portable gauge devices. 

During the review, the Section took immediate action to address several licensing actions that 

the review team identified as deviating from licensing guidance and Oregon regulations. The 

review team discussed the need for additional training in regulations and licensing 

guidance/implementation through a more formal qualification/training program as discussed in 

Section 3.1 of this report. In addition, the review team discussed the benefits of engaging the 

services of another Agreement State to provide both didactic training and/or mentoring in the 

more complex licensing procedures. This could be used to train the successor(s) to the senior 

reviewer and could also benefit the licensing manager’s training effort. 

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

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

was satisfactory, but needs improvement. 

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 Oregon in Nuclear Material Events Database (NMED) against 

those contained in the Section’s files, and evaluated the casework for seven radioactive material 

incidents. A listing of the incident casework examined, with case-specific comments, can be 

found in Appendix E. The review team also evaluated the Section’s response to one allegation 

involving radioactive material received directly by the States. NRC did not forward any 

allegations to the State during the review period. 
Oregon Final Report Page 9 

The Section has written procedures for responding to incidents and allegations. The 

procedures addressed the actions to be taken upon the notification of an incident or allegation 

and an event tracking database system that flags events for follow up during the next routine 

inspection. Although the inspectors conducting the next inspection were identifying the event in 

their inspection report, they did not always discuss whether they actually followed up on the 

licensee’s action in response to the event. 

The incidents selected for review included lost or stolen radioactive material, an overexposure, 

release of contaminated waste, unauthorized access to a radiation area, and medical events. 

The review team also reviewed approximately 100 incident files to determine if there were 

incidents that should have been reported to NMED. The review team found that the Section’s 

responses were thorough, complete, and comprehensive for all but two of the seven incidents 

evaluated. Initial responses were prompt and well coordinated, and the level of effort was 

commensurate with the health and safety significance. The exceptions are noted below. 

The review team determined that two medical events were not adequately reviewed. The 

medical events occurred at the same licensed facility. The events involved yttrium 

microspheres and were reportable because the total doses delivered differed from the 

prescribed dose by 20 percent or more. The same facility had two other events involving the 

release of contaminated waste for disposal and resulted in a licensee management meeting 

with the Section. 

The medical events were reviewed by the Section’s medical physicist telephonically and by email correspondence with the facility’s radiation safety officer; however, no on-site reviews were 

conducted. Given the fact that the same licensee had recurring under dose events involving 

microspheres, an on-site investigation would have been the appropriate response. The review 

team discussed this with Section management, and they agreed that, given the number of 

incidents with this licensee, they should have conducted an on-site review of the incidents. 

Through the review of the information for the events in NMED, the review team noted that, in all 

cases the Section had closed but not completed the events, although the Section’s investigation 

or followup had concluded. In addition, the two aforementioned medical events were either not 

reported to the NRC’s Operations Center or not reported in a timely manner. The review team 

recommends that the Section implement a process to ensure all required information is 

submitted to NMED and to also promote timely completion of NMED entries. 

The Section received one anonymous allegation during the review period. The review team 

concluded that the Section took prompt and appropriate action in response to the one 

anonymous allegation. The Section substantiated four of the five concerns raised by the alleger 

and issued a notice of violation to the individual. Since the allegation was anonymous no 

notification of the alleger was possible. Allegers requesting anonymity are informed that every 

effort would be made to protect his/her identity, but anonymity cannot be guaranteed. 

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

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

Allegation Activities, was satisfactory, but needs improvement. 
Oregon Final Report Page 10 

4.0 NON-COMMON PERFORMANCE INDICATORS 

Four non-common performance indicators are used to review Agreement State Programs: 

(1) Compatibility Requirements, (2) Sealed Source and Device Evaluation Program, (3) Lowlevel Radioactive Waste Disposal Program, and (4) Uranium Recovery Program. NRC’s 

Agreement with the State of Oregon does not relinquish authority to regulate a sealed source 

and device evaluation program or a uranium recovery program, so only the first and the third 

non-common performance indicators were applicable to this review. 

4.1 Compatibility Requirements

4.1.1 Legislation

Oregon became an Agreement State on June 22, 1965. Legislative authority to create an 

agency and enter into an Agreement with the NRC is granted in Oregon Statute 453.625. 

Oregon Statute 453 governs the use of radioactive materials, x-ray, emergency response and 

laboratory services. The Section is designated as the State’s radiation control agency. The 

review team noted that no significant legislation affecting the radiation control program was 

passed since the previous review. 

4.1.2 Program Elements Required for Compatibility

The State’s regulations governing radiation protection requirements are contained in Oregon 

Administrative Rules (OAR) 333. Oregon requires a license for the possession and use of all 

radioactive material. Oregon also requires registration of all machines specifically designed to 

produce x-rays or other ionizing radiation. The review team noted that the State’s rules and 

regulations are not subject to “sunset” provisions. 

The Oregon rulemaking process has five major steps in the process. After the staff drafts the 

rule, the package goes to the Attorney General's office for legal review or to the Radiation 

Advisory Committee for review. The package is submitted to NRC as a proposed rule. The 

package is submitted to the Rules Coordinator for the Department. The rule is submitted to the 

Oregon Bulletin for public comment. The final rule is submitted to the Secretary of State and 

issued as a final rule. The final rule becomes effective after publication. This process takes 

approximately six months from the initial staff draft of a rule package. 

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 

from the State Regulation Status sheet as maintained by NRC’s Office of Federal and State 

Materials and Environmental Management Programs. 

Since the previous IMPEP review, the Section has addressed five NRC regulation amendments 

in either draft or final packages. These actions included two time-sensitive changes addressing 

the National Source Tracking System and Fingerprinting requirements. 
Oregon Final Report Page 11 

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

legally binding requirements within the 3-year time period after the effective date of NRC’s final 

rule. At the time of the review, the following regulation amendments were overdue: 

• “Compatibility with IAEA Transportation Safety Standards and Other Transportation 

Safety,” 10 CFR Part 71 amendment (69 FR 3697), that was due for State adoption by 

October 1, 2007. 

 Status: The proposed regulation was submitted and reviewed by NRC. Comments 

were provided. A final rule should be completed by early 2010. 

• “Minor Amendments," 10 CFR Parts 20, 30, 32, 35, 40 and 70 amendment (71 FR 

15005), that was due for State adoption by March 27, 2009. 

Status: Oregon submitted the proposed rule to NRC for a compatibility review on 

September 22, 2009. The rule was under review at the time of the MRB meeting on 

November 10, 2009. 

In addition, the Section Manager indicated that the NRC comments on two final regulations and 

one proposed regulation are being addressed in a regulation package to be submitted later this 

fall and should be effective in early 2010. Oregon’s regulations will be up-to-date with the 

completion of this rule package. 

The following amendments will need to be addressed by the Sections in future rulemakings or 

by adopting alternate generic legally binding requirements: 

• “Medical Use of Byproduct Material – Minor Corrections and Clarifications,” 

10 CFR Parts 32 and 35 amendment (72 FR 45147, 54207), that is due for Agreement 

State adoption by October 29, 2010. 

• “Requirements for Expanded Definition of Byproduct Material,” 10 CFR Parts 20, 30, 31, 

32, 33, 35, 61, and 150 amendment (72 FR 55864), that is due for Agreement State 

adoption by November 30, 2010. 

• “Exemptions from Licensing, General Licenses, and Distribution of Byproduct Material: 

Licensing and Reporting Requirements,” 10 CFR Parts 30, 31, 32, and 150 amendment 

(72 FR 58473), that is due for Agreement State adoption by December 17, 2010. 

• “Occupational Dose Records, Labeling Containers, and Total Effective Dose Equivalent,” 

10 CFR Parts 19 and 20 amendment (72 FR 68043), that is due for Agreement State 

adoption by February 15, 2011. 

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

that Oregon’s performance with respect to the indicator, Compatibility Requirements, was 

satisfactory. 
Oregon Final Report Page 12 

4.2 Low-level Radioactive Waste Disposal Program

In 1981, 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 low-level radioactive waste (LLRW) as 

a separate category. Those States with existing Agreements prior to 1981 were determined to 

have continued LLRW disposal authority without the need of an amendment. Although the 

Oregon Agreement State Program has authority to regulate a LLRW disposal facility, 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, it is 

expected to put in place a regulatory program that will meet the criteria for an adequate and 

compatibility LLRW program. There are no plans for a LLRW disposal facility in Oregon. 

Accordingly, the review team did not review this indicator. 

5.0 SUMMARY 

As noted in Sections 3.0 and 4.0, Oregon’s performance was found satisfactory for three 

performance indicators and satisfactory, but needs improvement, for the performance 

indicators, Technical Quality of Inspections, Technical Quality of Licensing Actions, and 

Technical Quality of Incident and Allegation Activities. The review team made three 

recommendation regarding program performance by the State. Overall, the review team 

recommended, and the MRB agreed, that the Oregon Agreement State Program be found 

adequate to protect public health and safety, but needs improvement, and compatible with 

NRC's program. Based on the results of the current IMPEP review, the review team 

recommends that the Oregon Agreement State Program remain on monitoring with a periodic 

meeting held in approximately 1 year to assess the program’s progress in addressing the 

recommendations. The next full IMPEP review of the Oregon Agreement State Program will 

take place in approximately 3 years to accommodate the State’s request to conduct the IMPEP 

review when the State Legislature is not in session. 

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

implementation by the State: 

1. The review team recommends the State develop and use a documented formal 

qualification program (including refresher training) for inspection and licensing staff that 

would include journals that clearly indicate each individual’s training and qualification 

including oral and/or written evaluation of their understanding of regulations and 

guidance documents. 

2. The review team recommends that the State develop and implement a procedure for the 

control of sensitive or security-related information that provides guidance to identify, 

mark, handle, and protect such information. 

3. The review team recommends that the Section implement a process to ensure all 

required information is submitted to NMED and to also promote timely completion of 

NMED entries. 
LIST OF APPENDIXES AND ATTACHMENT 

Appendix A IMPEP Review Team Members 

Appendix B Oregon Organization Charts 

Appendix C Inspection Casework Reviews 

Appendix D License Casework Reviews 

Appendix E Incident Casework Reviews 

Attachment October 23, 2009 E-mail from Terry Lindsey 

 Oregon’s Response to Draft IMPEP Report 
APPENDIX A 

IMPEP REVIEW TEAM MEMBERS 

Name Area of Responsibility

Dennis Sollenberger, FSME Team Leader 

 Compatibility Requirements 

Linda McLean, Region IV Technical Staffing and Training 

 Technical Quality of Incident and Allegation 

 Activities 

Robert Greger, California Status of Materials Inspection Program 

 Technical Quality of Inspections 

 Inspector Accompaniments 

Sandra Gabriel, Region I Technical Quality of Licensing Actions 
APPENDIX B 

OREGON ORGANIZATION CHARTS 

ADAMS ACCESSION NO.: ML092720519 
APPENDIX C 

INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: Jim Turin and Sons, Inc. License No.: ORE-90887 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 7/27/09 Inspector: PW 

Comment: 

The Section sent a followup letter informing the licensee of the regulatory requirement 

with which they were not complying. The letter did not cite the licensee for this 

regulatory violation. 

File No.: 2 

Licensee: Mallinckrodt, Inc. License No.: ORE-90702 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 7/28/09 Inspector: JS 

File No.: 3 

Licensee: Providence Hood River Memorial Hospital License No.: ORE-90800 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 7/29/09 Inspector: KS 

Comment: 

Inspection documentation did not support recommendation to licensee. 

File No.: 4 

Licensee: Acuren Inspection, Inc. License No.: ORE-90621 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 11/20/08 Inspector: DL 

File No.: 5 

Licensee: Gene Tools, LLC License No.: ORE-91044 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 11/1/06 Inspector: JS 

Comment: 

 The inspection was performed 60 days overdue. 
Oregon Final Report Page C.2 

Inspection Casework Reviews

File No.: 6 

Licensee: International Inspection License No.: ORE-90651 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 2/27/09 Inspector: DL 

Comment: 

The file, which was maintained in locked storage, contained information not 

appropriately marked. 

File No.: 7 

Licensee: Net Compliance Environmental services, LLC License No.: ORE-96152 

Inspection Type: Reciprocity, Unannounced Priority: 5 

Inspection Date: 5/21/09 Inspector: KS 

File No.: 8 

Licensee: Oncology Associates of Oregon License No.: ORE-91030 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 2/23/09 Inspector: KS 

Comment: 

The inspection was conducted 1 month overdue. 

File No.: 9 

Licensee: GN Northern, Inc. License No.: ORE-96129 

Inspection Type: Reciprocity, Unannounced Priority: 5 

Inspection Date: 7/27/09 Inspector: DL 

File No.: 10 

Licensee: Engineering & Testing Innovation, Inc. License No.: WN-IR072-1 

Inspection Type: Reciprocity, Unannounced Priority: 1 

Inspection Date: 1/14/09 Inspector: JS 

File No.: 11 

Licensee: Providence Portland Medical Center License No.: ORE-90946 

Inspection Type: Special, Announced Priority: 2 

Inspection Date: 2/20/08 Inspector: JS 

Comments: 

a) Due to oversight identified by Section, initial letter to licensee was not sent until July 6, 

2009. 

b) The file, which was maintained in locked storage, contained information not 

appropriately marked. 
Oregon Final Report Page C.3 

Inspection Casework Reviews

File No.: 12 

Licensee: Samaritan Albany General Hospital License No.: 91080 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 10/29/08 Inspector: JS 

Comment: 

 The inspection was conducted 10 days overdue. 

File No.: 13 

Licensee: Pacific Agricultural Laboratory License No.: 93172 

Inspection Type: Routine, Unannounced Priority: NA 

Inspection Date: 6/19/09 Inspector: DL 

File No.: 14 

Licensee: PCC Structurals, Inc. License No.: 90232 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 3/28/08 Inspector: DL 

Comment: 

The inspection Supervisory conducted his review of inspection report 8 months after 

inspection. 

File No.: 15 

Licensee: Oregon Imaging Center License No.: 90931 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 1/14/09 Inspector: JS 

File No.: 16 

Licensee: Oregon Health & Science University License No.: ORE-90013 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Dates: 6/15-16/09 Inspector: KS 

Comments: 

a) The report did not describe the full scope of licensed activities for this broad scope 

program and what activities were inspected. Not all areas inspected were documented 

indicating licensee compliance status. 

b) The inspector did not follow up on previous Y-90 liver microsphere events. 
Oregon Final Report Page C.4 

Inspection Casework Reviews

INSPECTOR ACCOMPANIMENTS 

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

Accompaniment No.: 1 

Licensee: Jim Turin and Sons, Inc. License No.: ORE-90887 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 7/27/09 Inspector: PW 

Comment: 

The inspector failed to identify non-compliances that existed for lack of use of two 

independent physical controls that form tangible barriers to secure portable gauges from 

unauthorized removal whenever portable gauges are not under the control and constant 

surveillance of the licensee. 

Accompaniment No.: 2 

Licensee: Mallinckrodt, Inc. License No.: ORE-90702 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 7/28/09 Inspector: JS 

Accompaniment No.: 3 

Licensee: Providence Hood River Memorial Hospital License No.: ORE-90800 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 7/29/09 Inspector: KS 

Accompaniment No.: 4 

Licensee: Acuren Inspection, Inc. License No.: ORE-90621 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 7/30/09 Inspector: DL 

Comment: 

 The inspector should have selected which licensee vehicle would be inspected instead 

of allowing the licensee to make the selection. 
APPENDIX D 

LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: Providence Portland Medical Center License No.: ORE-90946 

Types of Action: Amendment Amendment No.: 7 

Dates Issued: 1/7/08 License Reviewers: DL, SM 

Comments: 

a) The file did not address that this was a new gamma knife design, inconsistent with 

certain existing gamma knife regulatory requirements. The licensing staff had the NRC 

licensing guidance for this specific design but did not use it in the evaluation. 

b) The file did not contain information regarding authorized user or authorized medical 

physicist training for this device model, emergency procedures, spot-check procedures, 

or facility safety features. 

File No.: 2 

Licensee: Portland Adventist Medical Center License No.: ORE-90158 

Type of Action: Amendment Amendment No.: 101 

Date Issued: 4/1/09 License Reviewer: SM 

Comments: 

a) The file for this amendment to add TheraSphere use only addressed a small portion of 

the licensing guidance for emergent technologies. The file did not demonstrate that 

users had the appropriate clinical experience, and addressed only one of the “licensing 

commitments providing regulatory relief.” 

b) A physician who was not already a 35.390 or 35.490 user was authorized for 

TheraSphere use. 

File No.: 3 

Licensee: Pet-Net Pharmaceutical Services, Inc. License No.: ORE-90926 

Types of Action: Amendment Amendment No.: 16 

Dates Issued: 5/26/09 License Reviewer: SM 

Comment: 

 The file did not contain documentation to demonstrate that the proposed Authorized 

Nuclear Pharmacist (ANP) met all the regulatory requirements. 
Oregon Final Report Page D.2 

License Casework Reviews

File No.: 4 

Licensee: PET NET Solutions, Inc. License No.: ORE-90927 

Type of Action: Amendment Amendment No.: 15 

Dates Issued: 5/27/09 License Reviewer: SM 

Comment: 

 The file did not contain documentation to demonstrate that the proposed ANP met the 

educational and preceptor requirements. 

 

File No.: 5 

Licensee: Oregon Medical Laboratories License No.: ORE-90360 

Type of Action: Amendment Amendment No.: 32 

Date Issued: 3/18/09 License Reviewer: SM 

Comment: 

 The new license condition allowing the Radiation Safety Officer to train irradiator users 

did not specify the content of the training program and training records to be maintained. 

File No.: 6 

Licensee: Western Professional, Inc. License No.: ORE-90344 

Type of Action: Renewal Amendment No.: 37 

Date Issued: 4/8/08 License Reviewer: SM 

File No.: 7 

Licensee: P.E.T. Imaging Services, LLC License No.: ORE-91007 

Type of Action: Renewal Amendment No.: 10 

Date Issued: 5/12/08 License Reviewer: SM 

File No.: 8 

Licensee: Arclin Surfaces, Inc. License No.: ORE-91096 

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

Date Issued: 2/17/09 License Reviewer: SM 

File No.: 9 

Licensee: C.M.T.I. Inc. License No.: ORE-91115 

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

Date Issued: 3/19/09 License Reviewer: DL 

Comment: 

 Contrary to standard Oregon practice, the license had no specific license condition to 

address the requirement for two independent physical controls to secure portable 

gauges from unauthorized removal. 

File No.: 10 

Licensee: Cascade Healthcare Community, Inc. License No.: ORE-91008 

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

Date Issued: 4/9/08 License Reviewer: SM 
Oregon Final Report Page D.3 

License Casework Reviews

File No.: 11 

Licensee: Samaritan Albany General Hospital License No.: ORE-91080 

Type of Action: Amendment Amendment No.: 3 

Date Issued: 6/17/09 License Reviewer: SM 

File No.: 12 

Licensee: Pope and Talbot, Inc./Cascade Pacific Pulp, LLC License No.: ORE-90576 

Type of Action: Amendment Amendment No.: 16 

Date Issued: 9/30/08 License Reviewer: SM 

Comment: 

 Bankruptcy/change of control was addressed in an amendment to the existing license 

rather than in termination of the existing license and issuance of a new license. 

File No.: 13 

Licensee: Boise White Paper LLC License No.: ORE-90100 

Type of Action: Amendment Amendment No.: 51 

Date Issued: 3/18/09 License Reviewer: SM 

File No.: 14 

Licensee: Lewis and Clark College License No.: ORE-90079 

Type of Action: Termination Amendment No.: 42 

Date Issued: 6/8/09 License Reviewer: DL 

File No.: 15 

Licensee: AA Testing Services, Inc. License No.: ORE-90969 

Type of Action: Termination Amendment No.: 4 

Date Issued: 7/28/09 License Reviewer: DL 

File No.: 16 

Licensee: Oregon Health & Science University License No.: ORE-90013 

Type of Action: Renewal, Amendment Amendment Nos.: 101, 103 

Date Issued: 2/18/09 License Reviewer: SM 

Comments: 

a) The renewal file did not contain the significant information necessary for proper 

evaluation of a Type A broad license renewal application. 

b) The renewal file did not contain any of the information for self-shielded irradiators. 

File No.: 17 

Licensee: Salem Hospital License No.: ORE-91006 

Type of Action: Amendments Amendment Nos.: 12, 13 

Date Issued: 7/28/09 License Reviewer: SM 
APPENDIX E 

INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: Oregon Health Sciences University License No: ORE-90013 

Date of Incident: 5/7/09 NMED Event No.: 090563 

Investigation Date: 5/12/09 Type of Incident: Medical 

 Type of Investigation: Phone 

Comments: 

a) The event is still open. 

b) The Section did not conduct an on-site inspection. 

c) The event was not reported to the Headquarters Operations Center in a timely manner. 

File No.: 2 

Licensee: Oregon Health Sciences University License No: ORE-90013 

Date of Incident: 9/23/08 OR Event No.: 080079 

Investigation Date: 9/24/08 Type of Incident: Medical 

 Type of Investigation: Phone 

Comments: 

a) The event was not entered into the Nuclear Materials Event Database (NMED). 

b) The event was not reported to the Headquarters Operations Center. 

c) The Section did not conduct an on-site investigation. 

File No.: 3 

Licensee: Oregon Health Sciences University License No: ORE-90013 

Date of Incident: 8/14/08 OR Event No.: 080068 

Investigation Date: 8/14/08 Type of Incident: Contaminated Trash 

 Type of Investigation: On-site 

File No.: 4 

Licensee: Oregon Health Sciences University License No: ORE-90013 

Date of Incident: 2/14/09 OR Event No.: 090008 

Investigation Date: 2/14/09 Type of Incident: Contaminated Trash 

 Type of Investigation: On-site 
Oregon Final Report Page E.2 

Incident Casework Reviews

File No.: 5 

Licensee: Oregon Health Sciences University License No: ORE-90731 

Date of Incident: 2/6/08 NMED Event No.: 080074 

Investigation Date: N/A Type of Incident: Potential Overexposure 

 Type of Investigation: None 

File No.: 6 

Licensee: International Inspection License No: ORE-90651 

Date of Incident: 6/12/09 OR Event No.: 09033 

Investigation Date: N/A Type of Incident: Unauthorized Access 

 Type of Investigation: None required 

File No.: 7 

Licensee: Cardinal Health License No: ORE-90703 

Date of Incident: 2/11/08 OR Event No.: N/A 

Investigation Date: N/A Type of Incident: Stolen Material 

 Type of Investigation: None required 
ATTACHMENT 

October 23, 2009 Letter from Terry Lindsey 

Oregon’s Response to Draft IMPEP Report 

ADAMS Accession No.: ML09306029