August 24, 2009 

Joseph G. Klinger, Assistant Director 

Illinois Emergency Management Agency 

Division of Nuclear Safety 

1035 Outer Park Drive 

Springfield, IL 62704 

Dear Mr. Klinger: 

On August 3, 2009, the Management Review Board (MRB) met to consider the proposed final 

Integrated Materials Performance Evaluation Program (IMPEP) report on the Illinois Agreement 

State Program. The MRB found the Illinois 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 13, of the enclosed final report summarizes the IMPEP review team=s findings 

and one recommendation regarding program performance by the State. We request your 

evaluation and response to the recommendation within 30 days from receipt of this letter. 

Based on the results of the current IMPEP review, the next full review of the Illinois Agreement 

State Program will take place in approximately 4 years, with a periodic meeting tentatively 

scheduled for May 2011. 

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: 

Illinois Final IMPEP Report 

cc w/encl.: Paul Eastvold, Chief 

 Illinois Bureau of Radiation Safety 

 Gibb Vinson, Head 

 Illinois Radioactive Materials Section 

 Cindy Cardwell, Texas 

 Organization of Agreement States 

 Liaison to the MRB 
Joseph G. Klinger, Assistant Director 

Illinois Emergency Management Agency 

Division of Nuclear Safety 

1035 Outer Park Drive 

Springfield, IL 62704 

Dear Mr. Klinger: 

On August 3, 2009, the Management Review Board (MRB) met to consider the proposed final 

Integrated Materials Performance Evaluation Program (IMPEP) report on the Illinois Agreement 

State Program. The MRB found the Illinois 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 13, of the enclosed final report summarizes the IMPEP review team=s findings 

and one recommendation regarding program performance by the State. We request your 

evaluation and response to the recommendation within 30 days from receipt of this letter. 

Based on the results of the current IMPEP review, the next full review of the Illinois Agreement 

State Program will take place in approximately 4 years, with a periodic meeting tentatively 

scheduled for May 2011. 

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: 

Illinois Final IMPEP Report 

cc w/encl.: Paul Eastvold, Chief 

 Illinois Bureau of Radiation Safety 

 Gibb Vinson, Head 

 Illinois Radioactive Materials Section 

 Cindy Cardwell, Texas 

 Organization of Agreement States 

 Liaison to the MRB 

Distribution: See next page.

 ML092160019 EDATS: FSME-2009-0026 

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

NAME ATMcCraw:knm1 (KMeyer for) ADWhite TReis RJLewis 

DATE 08/04/09 08/04/09 08/13/09 08/14/09 

OFFICE Tech Editor FSME DEDMRT 

NAME CPoland GCPangburn MJVirgilio 

DATE 08/19/09 08/19/09 08/24/09 

OFFICIAL RECORD COPY
Letter to Joseph G. Klinger from Martin J. Virgilio dated: 

DISTRIBUTION: FSME-2009-0026

MSSA RF DCD (SP01) 

EDO RF 

RidsFsmeOd Chairman Jaczko 

RidsSecyCorrespondenceMailCenter Commissioner Klein 

MBeardsley, FSME/MSSA Commissioner Svinicki 

RErickson, RIV SECY 

JLynch, RIII/RSAO 

SXu, FSME/MSSA 

MOrendi, FSME/MSSA 

Tristan Timm, Florida 

JAdams, OEDO 

APowell, OCA (2 copies) 

JGray, OGC 

BJones, OGC 

CMiller, FSME 

TReis, FSME/MSSA 
Enclosure 

INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

REVIEW OF THE ILLINOIS AGREEMENT STATE PROGRAM 

May 11-15, 2009 

FINAL REPORT
Illinois Final Report Page 1 

1.0 INTRODUCTION 

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

review was conducted during the period of May 11-15, 2009, by a review team composed of 

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

Florida. 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 April 9, 2005, to May 15, 2009, were discussed with Illinois managers on the last 

day of the review. 

A draft of this report was issued to Illinois for factual comment on June 15, 2009. The State 

responded by e-mail dated July 13, 2009, from Joseph Klinger, Assistant Director, Emergency 

Management Agency (the Agency). A copy of the State’s response is included as the 

Attachment to this report. The Management Review Board (MRB) met on August 3, 2009, to 

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

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

By State statute, the Agency is designated as the State’s radiation protection agency. Under 

the Agency is the Division of Nuclear Safety (the Division). The Division comprises the Bureau 

of Radiation Safety (the Bureau), the Bureau of Environmental Safety, and the Bureau of 

Nuclear Facility Safety. The Bureau is headed by the Chief and is composed of the Radioactive 

Materials Section (the Section) and the Electronic Products Section. The Illinois Agreement 

State Program is administered by the Section with decommissioning and financial assurance 

support from the Bureau of Environmental Safety. Organization charts for the Agency, the 

Division, the Bureau, and the Bureau of Environmental Safety are included in Appendix B. 

At the time of the review, the Illinois Agreement State program regulated 736 specific licenses 

authorizing the possession and use of 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 Illinois. 

In preparation for the review, a questionnaire addressing the common and applicable noncommon performance indicators was sent to the Agency on January 21, 2009. The Section 

provided a response to the questionnaire by electronic mail and fax on April 22, 2009. A copy of 

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

Management System (ADAMS) using the Accession Number ML091310423. 

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

Illinois’s response to the questionnaire, (2) review of applicable Illinois statutes and regulations, 

(3) analysis of quantitative information from the Section’s database, (4) technical review of 

selected regulatory actions, (5) field accompaniments of three 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 Illinois Agreement State Program’s performance. 
Illinois Final Report Page 2 

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

during the 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 any 

recommendations in the final report. 

2.0 STATUS OF ITEMS IDENTIFIED IN PREVIOUS REVIEWS 

During the previous IMPEP review, which concluded on April 8, 2005, that review team 

made one recommendation regarding the State’s adoption of regulations or other legally 

binding requirements remained open. At its meeting on June 26, 2005, the MRB placed 

the Illinois Agreement State Program on heightened oversight and directed staff to 

conduct a followup IMPEP review focusing on the non-common performance indicator, 

Compatibility Requirements, approximately one year later. As a result of the followup 

IMPEP review, the recommendation from the 2005 review was closed, and no additional 

recommendations regarding program performance were made. 

3.0 COMMON PERFORMANCE INDICATORS 

IMPEP identifies five common performance indicators to be used in reviewing 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 possible workload backlogs. 

The Section is responsible for radioactive materials licensing, inspection, and incident response 

activities. The Section, supervised by the Section Head, is divided into two units: the Licensing 

Unit and the Inspection and Enforcement Unit. Each of the units has a supervisor. At the time 

of the review, the Section employed 10 technical staff members (Health Physicists) and 2 

administrative staff members. All of the license reviewers and one inspector are located in the 

Springfield office; the other five inspectors are located in the West Chicago field office. 

Three staff members left the Section during the review period. The former Section Head was 

promoted to the Agency’s Assistant Director in 2007, and two license reviewers left the 

program. One of the license reviewer positions was filled in 2008; the other remains vacant. An 

additional technical position is also vacant as a result of a string of internal promotions 

subsequent to the former Section Head’s promotion. This position was assigned on May 1, 

2009, to a former member of the program who is now serving as the Supervisor of the Licensing 
Illinois Final Report Page 3 

Unit. The review team noted that the licensing program is stressed by the current workload. 

The Section has a tremendous licensing workload for only two qualified license reviewers with 

over 700 licensees and sealed source and device evaluation authority. The recent hiring of an 

additional license reviewer will alleviate some of the stress on the licensing program as he 

becomes fully trained. Additionally, as the number of security initiatives increases, the 

inspection staff’s workload is also becoming overwhelming for the staff. Division managers 

indicated that they are hopeful that they will be able to fill the vacant positions despite the 

State’s budgetary shortfalls. 

The Section has a documented training and qualification program for staff members who 

perform licensing, inspection, and incident response duties. The training and qualification 

program is consistent with NRC Inspection Manual Chapter (IMC) 1246, “Formal Qualification 

Programs in the Nuclear Material Safety and Safeguards Program Area” and the NRC and 

Organization of Agreement States Training Working Group’s Recommendations for Agreement 

State Training Programs. Qualification is achieved through a combination of education and 

experience, formal classroom training, and on-the-job training. Staff members are required to 

have a Bachelor’s degree or equivalent experience in a physical or biological science or 

engineering. 

The Section maintains training and qualification records for each staff member. The review 

team noted that Section management encourages and supports training opportunities, based on 

program needs and funding. The review team concluded that the Section has an adequate and 

well-balanced staff capable of carrying out their regulatory responsibilities. 

The Agreement State program receives approximately 88 percent of its budget from licensee 

fees; the other 12 percent comes from other sources. The fee-based funding level was 

increased from approximately 50 percent to its current level with a fee increase in March 2009. 

Licensees are assessed annual fees to cover the costs associated with licensing amendments, 

routine inspections, and investigations. In addition, licensees are charged a small Recovery 

and Remediation fee that allows the Section to build up a fund for emergency remediation at 

licensee facilities. 

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

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

satisfactory. 

3.2 Status of Materials Inspection Program

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

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

performance of reciprocity inspections. The review team’s evaluation was based on the 

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

licensing and inspection database, the examination of completed inspection casework, and 

interviews with managers and staff. 

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

frequencies for various license types are as frequent, or more frequent, than similar license 

types listed in IMC 2800, “Materials Inspection Program.” Examples of license types the 
Illinois Final Report Page 4 

Section inspects more frequently include broadscope licenses, large irradiators, nuclear laundry 

licenses, and nuclear pharmacy licenses. 

The Section performed a total of 713 high priority (Priority 1, 2, and 3) inspections during the 

review period. The review team evaluated the Section’s performance with regards to Priority 1, 

2, and 3 inspections and estimated that approximately 8 percent of these inspections were 

performed overdue. The review team estimated the percent overdue because an exact number 

of overdue inspections could not be ascertained based on the information obtained from the 

Section’s database. The review team also evaluated the Section’s timeliness for conducting 

initial inspections and found that the Section performed 6 initial inspections greater than 12 

months after issuance out of the 108 initial inspections conducted during the review period. No 

initial inspections were overdue at the time of the review. Overall, the review team determined 

that the Section performed less than 10 percent of all Priority 1, 2, and 3 and initial inspections 

overdue during the review period. 

The review team determined that the Section adequately planned for the initial set of Increased 

Controls inspections. The review team evaluated the Section’s prioritization methodology and 

found it acceptable. The review team verified that the Section performed all of the first-year 

inspections in a timely manner. The Section also completed all of its Increased Controls 

inspections within the required 3-year time frame. The Section performs subsequent Increased 

Controls inspections in conjunction with routine health and safety inspections at the appropriate 

inspection frequency, based on license type. 

The review team evaluated the Section’s timeliness in issuing inspection reports through a 

review of inspection casework and data obtained from the Section’s licensing and inspection 

database. The review team noted that in approximately 65 percent of the cases inspection 

findings were transmitted to licensees greater than 30 days after the inspection date. The 

review team determined that the underlying cause of the tardiness of issuance of inspection 

documentation is due to the overwhelming number of inspection reports that must be reviewed 

and signed by the Inspection & Enforcement Unit Supervisor. The review team found that 

competing priorities detract from the Inspection & Enforcement Unit Supervisor’s time to review 

the inspection documentation within 30 days of the inspection. The review team and Section 

managers discussed the Section’s procedures and practices for issuing inspection 

documentation to licensees and areas where the Section might be able to gain efficiencies in 

the process without compromising quality or consistency of the inspection reports. The review 

team recommends that the State provide inspection documentation to its licensees within 30 

days of a completed inspection in accordance with the Section’s policies and procedures. 

The Section does not maintain records reflecting which reciprocity licenses are candidates for 

inspection on a calendar-year basis. Instead, the Section identifies these licensees as “current” 

or “not current” on a rotating 12-month interval. Consequently, the review team was unable to 

apply the reciprocity inspection frequency criteria prescribed by IMC 1220, “Processing of NRC 

Form 241 and Inspection of Agreement State Licensees Operating under 10 CFR 150.20.” The 

review team used information obtained from the Section’s license and inspection database and 

information provided by the Section in its response to the questionnaire to determine the 

number of reciprocity licensees inspected each year. The review team concluded that the 

Section did not consistently inspect a minimum of 20 percent of candidate reciprocity licensees 

in each of the calendar years covered by review period. The review team determined that the 
Illinois Final Report Page 5 

Section’s performance of reciprocity inspections decreased later in the review period, because 

the Section redirected resources to address new security initiatives in a timely manner. 

Although the Section did not inspect the minimum of 20 percent of candidate reciprocity 

licensees in each of the calendar years covered by review period, the review team found that 

the Section used a risk-informed approach to conduct reciprocity inspections during the years 

that the 20 percent requirement was not met. 

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

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

was satisfactory. 

3.3 Technical Quality of Inspections

The review team evaluated inspection reports, enforcement documentation, inspection field 

notes, and interviewed the responsible inspectors for 24 radioactive materials inspections 

conducted during the review period. The casework examined consisted of inspections 

conducted by seven current inspectors. The casework covered a variety of license types, 

including: academic broadscope, medical broadscope, industrial radiography, self-shielded 

irradiator, service provider, gamma knife, positron emission tomography, high dose-rate remote 

after loader (HDR), nuclear pharmacy, fixed gauge, decommissioning, and reciprocity. The 

review also included initial and followup Increased Controls inspections. Appendix C lists the 

inspection casework files reviewed and includes case-specific comments. 

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

aspects of the licensees’ radiation safety programs. The review team noted that inspection 

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

documentation to ensure that licensees’ performances with respect to health, safety, and 

security were acceptable. Inspection report documentation supported violations, 

recommendations made to licensees, unresolved safety issues, and discussions held with 

licensees during exit interviews. 

The Section’s inspection procedures are consistent with the inspection guidance found in IMC 

2800. At the conclusion of each inspection, if no potential violations are identified, inspectors 

have the option to leave the inspection results on a form similar to NRC’s Form 591 or to send 

results from the office. All inspection documentation sent from the office is dispatched under the 

signature of the Inspection and Enforcement Unit Supervisor. The Section dispatches the 

majority of its inspection documentation from the office, which has led to the large number of 

inspection reports dispatched beyond the 30-day goal. 

The review team determined that documents involving Increased Controls inspections were 

uniquely identified to ensure protection from inadvertent release or unauthorized disclosure. 

Files were held in individual color coded folders, clearly identifying each licensee subject to the 

Increased Controls. Documents observed were sufficiently marked as sensitive information to 

be withheld from public disclosure. Increased Controls documentation is not subject to 

Freedom of Information Act or State equivalent law requests. 

The review team verified that the Section maintains an adequate supply of appropriately 

calibrated survey instruments to support the inspection program, as well as to respond to 
Illinois Final Report Page 6 

radioactive materials incidents and emergency conditions. The State has its own accredited 

calibration laboratory in Springfield. The State Radiation Safety Officer heads the calibration lab 

and is responsible for ensuring that the calibration lab maintains its accreditation and that 

survey instruments are properly calibrated and distributed. 

The Section receives laboratory and sample analysis support from the State laboratory located 

in Springfield. The State laboratory has a wide array of analytical equipment and is capable of 

detailed radiochemistry analysis. Their work is primarily in support of the power plants but they 

also provide support to the Section, as requested. The uranium recovery site currently under 

decommissioning has its own lab for sample analysis and is located in West Chicago. 

The Section has a policy to perform supervisory accompaniments of all inspectors annually. 

The supervisor in the Chicago area office performs accompaniments for the inspectors in that 

area annually. The Inspection & Enforcement Unit Supervisor accompanies the one inspector 

in the southern part of the State annually. 

The review team accompanied three of the Section’s inspectors in March and April 2009. The 

licensees inspected were an industrial radiography facility, a gamma stereotactic radiosurgery 

center, and a pool irradiator facility. Two of the inspections included a review of the licensees’ 

implementation of the Increased Controls. Appendix C lists the inspector accompaniments. 

The inspectors demonstrated performance-based inspection techniques and knowledge of the 

regulations. The inspectors were well 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 security at the 

licensed facilities. 

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

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

satisfactory. 

3.4 Technical Quality of Licensing Actions

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

30 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, Increased Controls 

requirements, the use of pre-licensing guidance, 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, peer/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 6 new 

licenses, 14 renewals, 7 amendments, and 3 license terminations. The casework reviewed 
Illinois Final Report Page 7 

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

brachytherapy, gamma knife, industrial radiography, nuclear pharmacies, and industrial 

licensees. A listing of the licensing casework reviewed can be found in Appendix D. 

The review team found that the license reviewers follow appropriate licensing guides, similar to 

NRC’s NUREG-1556 series, during the review process to ensure that licensees submit all the 

necessary information to support the licensing request. The review team found the checklists 

used for each license type were comprehensive and incorporated excellent notes to assist the 

staff with their review of the applications. Letters, documented telephone conversations, and 

electronic communications retained in the licensing files contained appropriate regulatory 

language and addressed deficiencies. The Section’s use of license templates, including the use 

of standard license conditions, resulted in notable consistency between reviewers. Overall, the 

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

quality, and properly addressed health, safety, and security issues. 

When a licensing action is completed by a reviewer, the entire package is given to the Licensing 

Unit Supervisor who reviews and signs the licensing action. Licenses are issued for a 5-year 

term. The Section has an expedited renewal process, where a licensee submits an application 

and identifies any parts of his radiation safety program that have changed, and confirms that all 

other portions are still current. Licenses that are under timely renewal are amended as 

necessary to ensure that public health and safety issues are addressed during the period that 

the license is undergoing the renewal process. 

The Section requires certain licensees to maintain financial assurance for decommissioning. 

Surety instruments are maintained in a locked cabinet. The Bureau of Environmental Safety 

determines the financial assurance requirements for the licensing staff. The review team noted 

good communication between the Section and the Bureau of Environmental Safety. The review 

team evaluated the contents of several financial assurance folders, all of which were properly 

maintained. 

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

included the appropriate radioactive material transfer reports and survey records. An evaluation 

of selected termination records indicated excellent communication between the licensing, 

inspection, and decommissioning staff to prevent abandonment of radioactive material. The 

files contained documentation of proper disposal or transfer. 

The review team examined the Section’s licensing practices regarding the Increased Controls 

and fingerprinting orders. The review team noted that the Licensing Unit added legally binding 

license conditions to the licenses that met the criteria for implementing the Increased Controls 

and the fingerprinting requirements. The review team found that some medical licenses were 

authorized possession limits in quantities of concern for certain isotopes that were not subject to 

the Increased Controls, because the licenses did not contain the appropriate license condition. 

The Section identified the licenses that potentially contained the error. While the review team 

was on site, the Section contacted the affected licensees and began the process of issuing the 

corrected copies of the licenses that reduced authorization limits. The Section completed the 

issuance of corrected licenses on June 2, 2009. The Section was planning to draft a policy 

memorandum with instructions and a new medical license template that will be presented at a 

staff meeting as part of the implementation plan. 
Illinois Final Report Page 8 

The review team reviewed the Section’s program for the implementation of pre-licensing 

guidance. At the time of the review, the Section had incorporated the essential objectives of the 

original pre-licensing guidance that required site visits and background checks of applicants 

requesting risk-significant quantities of radioactive materials; however, the Section had not yet 

incorporated all of the essential objectives of the revised pre-licensing guidance. As detailed in 

NRC’s Office of Federal and State Materials and Environmental Management Programs (FSME) 

Letter RCPD-08-020, dated September 22, 2008, States were given 6 months from the date of 

the letter to incorporate the essential objectives of the revised pre-licensing guidance into their 

respective licensing program. The review team noted two instances where site visits had not 

been performed following the implementation deadline, because of a misinterpretation of the 

new requirements. During the on-site review, the review team and the Section received 

clarification on the essential objectives of the revised pre-licensing guidance. The Section 

committed to immediately implement all of the new requirements. 

The review team noted that the Section has implemented an additional pre-licensing 

requirement, above the required guidance. The Section performs a due diligence background 

check on all using radiation safety officers, chief executive officers, authorized users, and 

medical physicists who have not been previously listed on a license using a commercial service 

approved by the Agency. 

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

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

was satisfactory. 

3.5 Technical Quality of Incident and Allegation Activities

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

allegations, the review team examined the Bureau’s response to the questionnaire relative to 

this indicator, evaluated selected incidents reported for Illinois in the Nuclear Material Events 

Database (NMED) against those contained in the Section’s files, and evaluated the casework 

for 20 of 49 reported radioactive materials incidents. A listing of the casework examined can be 

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

allegations involving radioactive materials reported during the review period. 

When notified of an incident or an allegation, the Section discusses the initial response and the 

need for an on-site investigation, based on the safety significance. The Section maintains a 

database for tracking the status of all incidents and allegations. If the incident meets the 

reporting criteria established in FSME Procedure SA-300, “Reporting Material Events,” the 

Section promptly notifies NRC’s Headquarters Operations Center, typically by e-mail, using the 

information template established for NMED. If the investigation is complex and extends over a 

period of time, NMED is updated as additional information becomes available. Of the incidents 

evaluated by the review team, all had been reported to NRC within the required time frame and 

submitted for inclusion in NMED. 

The incidents selected for review included medical events, lost or stolen radioactive material, 

overexposure, damaged equipment, contamination events, leaking sources, and equipment 

failures. The review team determined that the Section’s response to incidents were thorough, 

complete, and comprehensive. Initial responses were prompt and well coordinated, and the 
Illinois Final Report Page 9 

level of effort was commensurate with the health and safety significance. The Section quickly 

dispatched inspectors to a site when the possibility of an immediate threat to public health and 

safety existed. When no immediate threat was present and the Section determined that the 

licensee had qualified, competent individuals investigating the incident, the Section generally 

responded telephonically with a followup during the next inspection. The review team noted 

that, at the conclusion of investigations, inspectors generated narrative reports that thoroughly 

documented the investigations. 

The Section receives approximately 75 to 100 incidents involving radioactive material annually, 

of which approximately 75 percent are radiation monitor trips at scrap facilities and landfills. 

With support from the Bureau of Environmental Safety, the Section responds to all monitor trips 

with an on-site visit. The Section has made this activity a priority because it believes that 

orphan sources at non-licensed facilities present a serious risk for unnecessary public exposure. 

In 2006, the Bureau of Environmental Safety expanded their Orphan Source Recovery Program 

to include Illinois high schools. This initiative is a non-emergency response hazard mitigation 

program that collects and properly disposes of unwanted radioactive material from the schools. 

The collection of unwanted radioactive material is at no cost to the schools. The review team 

recommended, and the MRB agreed, that the State’s expansion of its orphan source recovery 

initiative to high schools is a good practice. 

In evaluating the effectiveness of the Section's response to allegations, the review team 

evaluated the casework for four allegations reported directly to the State and three allegations 

referred to the State from the NRC during the review period. The review team concluded that 

the Section consistently took prompt and appropriate action in response to concerns raised. 

The review team also noted that the Section thoroughly documented the investigations and 

retained all necessary documentation to appropriately close the allegations. The Section 

notified the allegers of the conclusion of their investigation. Additionally, the review team 

determined that the Section adequately protected the identity of allegers. 

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

that Illinois'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 reviewing Agreement 

State Programs: (1) Compatibility Requirements; (2) Sealed Source and Device Evaluation 

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

Program. 

4.1 Compatibility Requirements

4.1.1 Legislation

Illinois became an Agreement State on June 1, 1987. In their response to the questionnaire, the 

Section provided a listing of legislation that affects the radiation control program. The Agency is 

designated as the State radiation protection agency under the provisions of the Radiation 
Illinois Final Report Page 10 

Protection Act of 1990, as amended (420 Illinois Compiled Statutes (ILCS) 40). The Bureau 

implements the program for the Agency. The Radiation Protection Act of 1990 grants the 

Agency the authority to promulgate rules and regulations to be followed in the administration of 

the State’s radiation protection program. This is the only legislation that affects the program that 

is subject to sunset laws. Public Act 91-752, which was effective June 2, 2000, extended the 

sunset date for the Radiation Protection Act until January 1, 2011. The Agency plans to file the 

necessary paperwork to extend the sunset date for the Radiation Protection Act of 1990 in 

2010. This will extend the sunset date of the legislation for another 10 years. 

Other legislation that affects the radiation control program is as follows: the Radioactive Waste 

Storage Act (420 ILCS 35); the Illinois Low-level Radioactive Waste Management Act (420 ILCS 

20); and the Uranium and Thorium Mill Tailings Control Act (420 ILCS 42), which provide 

authority for the low-level radioactive waste disposal and uranium recovery programs; Freedom 

of Information Act [5 ILCS 140]; and Illinois Administrative Procedure Act [5 ILCS 100]. 

4.1.2 Program Elements Required for Compatibility

The State’s regulations for control of radiation are located in Title 32 of the Illinois Administrative 

Code and apply to all ionizing radiation, whether emitted from radionuclides or devices. Illinois 

requires a license for possession and use of all radioactive materials. 

The public, NRC, other agencies, and all potentially affected licensees and registrants are 

offered an opportunity to comment during the rulemaking process. Comments are considered 

and incorporated, as appropriate, before the regulations are finalized, approved, and filed. The 

Agency also has the authority to issue legally binding requirements (e.g., license conditions) in 

lieu of regulations until compatible regulations become effective. This process generally takes 

between one and two years. Regulations are not subject to sunset laws. 

The review team evaluated the Section’s response to the questionnaire, 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 that FSME maintains. Current NRC policy requires that Agreement 

States adopt certain equivalent regulations or legally binding requirements no later than 3 years 

after they are effective unless otherwise mandated by the Commission. 

Since the followup review, the State submitted six packages covering eight amendments for 

compatibility reviews. The review team noted that Illinois is up to date on all NRC regulatory 

amendments currently required for compatibility. 

The following amendments will become due during the next IMPEP review cycle and are 

included here to assist the Agency in including them 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. 
Illinois Final Report Page 11 

• “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 Illinois’s performance with respect to the indicator, Compatibility Requirements, was 

satisfactory. 

4.2 Sealed Source and Device Evaluation Program

In reviewing this indicator, the review team used three subelements to evaluate the Section’s 

performance regarding the Sealed Source and Device (SS&D) Evaluation Program. These 

subelements were: (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 Section's SS&D evaluation activities, the review team examined information 

contained in the Section’s response to the IMPEP questionnaire for this indicator. The review 

team examined casework, noted the staff's use of guidance documents and procedures, 

interviewed staff members involved in SS&D evaluations, and verified the use of regulations and 

inspections to enforce commitments made in the applications. 

4.2.1 Technical Staffing and Training

The Section has three staff members who are qualified to perform safety evaluations of SS&D 

applications and amendments. The review team interviewed each staff member involved in the 

reviews and determined that they were familiar with the procedures used in the evaluation of a 

source or device and had access to applicable reference documents. 

4.2.2 Technical Quality of the Product Evaluation Program

During the review period, the Section conducted six new SS&D evaluations and issued thirteen 

amendments to an existing registration. The review team examined casework for 10 actions 

covering work from each of the SS&D reviewers. A list of SS&D casework examined, with casespecific comments, may be found in Appendix F. 

Analysis of the casework and interviews with staff members confirmed that the Section follows 

the recommended guidance from NRC’s SS&D Workshop and NUREG-1556, Volume 3, 

Revision 1, “Consolidated Guidance About Materials Licenses – Applications for Sealed Source 

and Device Evaluation and Registration.” The review team confirmed that all applicable and 
Illinois Final Report Page 12 

pertinent American National Standards Institute standards, NUREG-1556 Series guides, NRC 

Regulatory Guides, and applicable references were available and used appropriately in 

performing the SS&D reviews. 

The review team determined that the registration files contained all photographs, engineering 

drawings, radiation profiles, and details of the applicant’s quality assurance and quality control 

program. The registrations 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 evaluations were generally of high quality 

with health and safety issues properly addressed. 

4.2.3 Evaluation of Defects and Incidents Regarding SS&Ds

Utilizing NMED and the Section’s response to the questionnaire, the review team examined a 

selected sample of events involving registered products that occurred during the review period. 

The events involved equipment and sources, registered by the State of Illinois, that occurred 

both within the State and nationwide. 

One event related to a leaking source registered by the State was reported during the review 

period. The State conducted an investigation to obtain additional information about the leaking 

source. The results of the investigation were documented and complete, and stated corrective 

actions taken by the licensee. These corrective actions, relating to the licensee’s quality 

assurance program, were never incorporated into the license or the SS&D registry. For future 

events of this nature, the Section committed to leaving NMED reports open until the license has 

been appropriately amended and the licensee has implemented their corrective actions. 

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

that Illinois’s performance with respect to the indicator, Sealed Source and Device Evaluation 

Program, was satisfactory. 

4.3 Low-level Radioactive Waste Disposal Program 

Although NRC’s Agreement with the State of Illinois relinquishes the authority for a low-level 

radioactive waste (LLRW) program, the State’s LLRW program is currently inactive. No further 

activity is anticipated at this time; therefore, the LLRW program staff is working on other 

projects. Accordingly, the review team did not review this indicator. 

4.4 Uranium Recovery Program 

The Bureau of Environmental Safety administers the State’s uranium recovery program. The 

Bureau of Environmental Safety regulates one uranium recovery license, which is in the process 

of decommissioning. During the review period, operations at the site included accepting 

excavated contaminated material from off site properties for limited storage, the shipment of 

material for disposal, and water treatment and groundwater monitoring. 

On January 11, 2009, the licensee notified the Bureau of Environmental Safety that they had 

filed under Chapter 11 of the U.S. Bankruptcy laws. The Bureau of Environmental Safety holds 
Illinois Final Report Page 13 

a financial surety instrument to cover any outstanding remediation activities at the site and is 

closely monitoring the situation to determine if that financial surety instrument needs to be used. 

The surety instrument does not cover any Superfund remedial activities. 

The State’s uranium recovery activities are currently inactive, and it’s anticipated that the only 

remaining activities at the site will be decommissioning activities. Staff has been reassigned to 

other activities. Accordingly, the review team did not review this indicator. 

5.0 SUMMARY 

As noted in Sections 3.0 and 4.0, Illinois’s performance was found satisfactory for all 

performance indicators reviewed. The review team made one recommendation in regard to 

program performance by the State. The review team also identified one good practice. Overall, 

the review team recommended, and the MRB agreed, that the Illinois Agreement State Program 

is 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. 

Below is the recommendation, as mentioned earlier in the report, for evaluation and 

implementation by the State: 

The review team recommends that the State provide inspection documentation to its 

licensees within 30 days of a completed inspection in accordance with the Section’s policies 

and procedures. (Section 3.2) 

Below is the good practice, as mentioned earlier in the report: 

In 2006, the Bureau of Environmental Safety expanded their Orphan Source Recovery 

Program to include Illinois high schools. This initiative is a non-emergency response hazard 

mitigation program that collects and properly disposes of unwanted radioactive material from 

the schools. The collection of unwanted radioactive material is at no cost to the schools. 

(Section 3.5) 
LIST OF APPENDIXES AND ATTACHMENT 

Appendix A IMPEP Review Team Members 

Appendix B Illinois Organization Charts 

Appendix C Inspection Casework Reviews 

Appendix D License Casework Reviews 

Appendix E Incident Casework Reviews 

Appendix F Sealed Source and Device Casework Reviews 

Attachment July 13, 2009 E-mail from Joseph Klinger 

 Illinois’s Response to Draft IMPEP Report 
APPENDIX A 

IMPEP REVIEW TEAM MEMBERS 

Name Area of Responsibility

Randy Erickson, Region IV Team Leader 

 Technical Quality of Inspections 

James Lynch, Region III Technical Staffing and Training 

Technical Quality of Incident and Allegation 

 Activities 

 Inspector Accompaniments 

Monica Orendi, FSME Status of the Materials Inspection Program 

 Compatibility Requirements 

Shirley Xu, FSME Technical Quality of Licensing Actions 

 Uranium Recovery Program 

Tristan Timm, Florida Sealed Source and Device Evaluation Program 
APPENDIX B 

ILLINOIS ORGANIZATION CHARTS 

ADAMS ACCESSION NO.: ML091170313 
APPENDIX C 

INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: PetroChem Inspection Services License No.: IL-00408-01 

Inspection Type: Reciprocity/Special, Announced Priority: 1 

Inspection Date: 11/12/08 Inspector: JP 

Comment: 

 Inspection documentation issued to licensee 56 days late. 

File No.: 2 

Licensee: Advanced Radiation Oncology Center License No.: IL-02178-01 

Inspection Type: Routine/Special, Announced Priority: 2 

Inspection Date: 9/7/07 Inspector: JK 

File No.: 3 

Licensee: Southern Illinois School of Medicine License No.: IL -01161-01 

Inspection Type: Routine/Special, Announced Priority: 2 

Inspection Date: 6/25/08 Inspector: GM 

Comment: 

 Inspection documentation issued to licensee 46 days late. 

File No.: 4 

Licensee: Caterpillar, Inc. License No.: IL-01463-01 

Inspection Type: Routine/Special, Announced Priority: 1 

Inspection Date: 1/5/07 Inspector: GM 

Comment: 

 Inspection documentation issued to licensee 13 days late. 

File No.: 5 

Licensee: Senco Construction, Inc. License No.: IL-02002-01 

Inspection Type: Routine/Special, Unannounced Priority: 1 

Inspection Date: 7/5/06 Inspector: GM 

File No.: 6 

Licensee: St. Francis Medical Center License No.: IL-01361-01 

Inspection Type: Special, Announced Priority: 2 

Inspection Dates: 1/8-10/08 Inspector: GM 
Illinois Final Report Page C.2 

Inspection Casework Reviews

File No.: 7 

Licensee: Northern Illinois University License No.: IL-01773-01 

Inspection Type: Routine/Special, Unannounced Priority: 3 

Inspection Dates: 7/13-14/06 Inspectors: RM, AG 

Comment: 

 Inspection documentation issued to licensee 12 days late. 

File No.: 8 

Licensee: Mistras Group, Inc. License No.: IL-01968-01 

Inspection Type: Routine/Special, Announced Priority: 1 

Inspection Dates: 8/30/06 and 9/5/06 Inspector: AG 

Comment: 

 Inspection documentation issued to licensee 22 days late. 

File No.: 9 

Licensee: Baxter Healthcare Corporation License No.: IL-01278-02 

Inspection Type: Routine/Special, Unannounced Priority: 5 

Inspection Dates: 5/7-8/08 Inspector: WH 

Comment: 

 Inspection documentation issued to licensee 34 days late. 

File No.: 10 

Licensee: Neurologic and Orthopedic Institute of Chicago License No.: IL-02207-01 

Inspection Type: Initial/Special, Announced Priority: 2 

Inspection Date: 2/1/07 Inspector: JP 

File No.: 11 

Licensee: Ingalls Memorial Hospital License No.: IL-01342-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Dates: 4/19-20/07 Inspector: WH 

File No.: 12 

Licensee: ConocoPhillips Pipe Line Company License No.: IL-01332-01 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 6/22/06 Inspector: GM 

File No.: 13 

Licensee: Chicago Magnesium Casting Company License No.: IL-01077-01 

Inspection Type: Decommissioning, Announced Priority: 1 

Inspection Date: 11/10/08 Inspector: DP 
Illinois Final Report Page C.3 

Inspection Casework Reviews

File No.: 14 

Licensee: Pathfinder Brain SPECT, LLC. License No.: IL-02247-01 

Inspection Type: Initial, Announced Priority: 5 

Inspection Date: 3/13/06 Inspector: AG 

File No.: 15 

Licensee: Southwest Comprehensive Oncology Center License No.: IL-02328-01 

Inspection Type: Initial, Unannounced Priority: 2 

Inspection Date: 11/9/07 Inspector: RM 

Comment: 

 Inspection documentation issued to licensee 30 days late. 

File No.: 16 

Licensee: Landauer License No.: IL-01376-01 

Inspection Type: Routine/Special, Announced Priority: 1 

Inspection Date: 1/22/08 Inspector: JP 

File No.: 17 

Licensee: River to River Heart Group License No.: IL-02351-01 

Inspection Type: Initial, Unannounced Priority: 5 

Inspection Date: 7/7/08 Inspector: GM 

Comment: 

 Inspection documentation issued to licensee 37 days late. 

File No.: 18 

Licensee: Advanced Cardiology and Vascular Services, LLC. License No.: IL-02308-01 

Inspection Type: Routine/Special, Announced Priority: 5 

Inspection Date: 4/30/08 Inspector: GM 

Comment: 

 Inspection documentation issued to licensee 13 days late. 

File No.: 19 

Licensee: Joliet Radiation Oncology at Hoffman License No.: IL-02344-01 

 Cancer Center 

Inspection Type: Initial, Announced Priority: 2 

Inspection Date: 11/21/08 Inspector: JK 

File No.: 20 

Licensee: The Heart Care Group License No.: IL-02302-01 

Inspection Type: Initial, Announced Priority: 5 

Inspection Date: 10/5/06 Inspector: GM 
Illinois Final Report Page C.4 

Inspection Casework Reviews

File No.: 21 

Licensee: Gamma Irradiator Service License No.: IL-00392-01 

Inspection Type: Reciprocity, Announced Priority: 5 

Inspection Date: 3/23/06 Inspector: JK 

File No.: 22 

Licensee: Berwyn Radiation Oncology Center License No.: IL-02240-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 2/25/09 Inspector: WH 

Comment: 

 Inspection documentation issued to licensee 6 days late. 

File No.: 23 

Licensee: Varian Medical Systems License No.: IL-01143-01 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 11/29/06 Inspector: JP 

File No.: 24 

Licensee: Chicago Prostate Cancer Center License No.: IL-02015-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 10/6/06 Inspector: JK 

INSPECTOR ACCOMPANIMENTS 

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

Accompaniment No.: 1 

Licensee: PetroChem Inspection Services, Inc. License No.: IL-02365-01 

Inspection Type: Special, Announced Priority: 1 

Inspection Date: 3/6/09 Inspector: AG 

Accompaniment No.: 2 

Licensee: Neurologic and Orthopedic Institute of Chicago License No.: IL-02207-01 

Inspection Type: Special, Announced Priority: 2 

Inspection Date: 3/19/09 Inspector: JP 

Accompaniment No.: 3 

Licensee: STERIS, Inc. License No.: IL-01123-02 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 4/8/09 Inspector: JK 
APPENDIX D 

LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: ADCO Services, Inc License No.: IL-01347-01 

Type of Action: Renewal Amendment No.: 35 

Date Issued: 2/27/09 License Reviewer: MB 

File No.: 2 

Licensee: Eichrom Technologies, LLC License No.: IL-02371-01 

Type of Action: New Amendment No.: 0 

Date Issued: 2/23/09 License Reviewer: SK 

File No.: 3 

Licensee: Equistar Chemicals, LP License No.: IL-01737-01 

Type of Action: Renewal Amendment No.: 15 

Date Issued: 12/5/07 License Reviewer: SK 

File No.: 4 

Licensee: Raymond G. Scott Cancer Care License No.: IL-02217-01 

Type of Action: New Amendment No.: 0 

Date Issued: 12/17/08 License Reviewer: SK 

File No.: 5 

Licensee: Brian Szydzik License No.: IL-02337-01 

Type of Action: New Amendment No.: 0 

Date Issued: 8/30/07 License Reviewer: MB 

File No.: 6 

Licensee: Southern Cook Radiation Oncology, Ltd. License No.: IL-02299-01 

Type of Action: New Amendment No.: 0 

Date Issued: 9/20/06 License Reviewer: SK 

File No.: 7 

Licensee: MidWest Brachytherapy, Inc. License No.: IL-02262-01 

Type of Action: New Amendment No.: 0 

Date Issued: 10/12/05 License Reviewer: SK 

File No.: 8 

Licensee: Viktron-West Chicago License No.: IL-01101-01 

Type of Action: Termination Amendment No.: 4 

Date Issued: 2/27/09 License Reviewer: RH 
Illinois Final Report Page D.2 

License Casework Reviews

File No.: 9 

Licensee: Abbott Laboratories License No.: IL-01478-01 

Type of Action: Amendment Amendment No.: 22 

Date Issued: 12/4/07 License Reviewer: SK 

File No.: 10 

Licensee: UniTech Services Group, Inc. License No.: IL-01008-01 

Type of Action: Renewal Amendment No.: 31 

Date Issued: 4/9/09 License Reviewer: MB 

File No.: 11 

Licensee: Northwestern University License No.: IL-01879-01 

Type of Action: Renewal Amendment No.: 17 

Date Issued: 10/12/07 License Reviewer: MB 

File No.: 12 

Licensee: Veterinary Specialty Center License No.: IL-02071-01 

Type of Action: Amendment Amendment No.: 9 

Date Issued: 2/23/09 License Reviewer: DP 

File No.: 13 

Licensee: Northwestern memorial Hospital License No.: IL-01037-01 

Type of Action: Amendment Amendment No.: 40 

Date Issued: 1/14/09 License Reviewer: MB 

File No.: 14 

Licensee: Mallinckrodt, Inc License No.: IL-01117-01 

Type of Action: Renewal Amendment No.: 38 

Date Issued: 3/29/09 License Reviewer: SK 

File No.: 15 

Licensee: Radiocat License No.: IL-02024-01 

Type of Action: Renewal Amendment No.: 8 

Date Issued: 12/20/07 License Reviewer: MB 

File No.: 16 

Licensee: Principia College License No.: IL-01650-01 

Type of Action: Amendment Amendment No.: 7 

Date Issued: 3/22/06 License Reviewer: SK 

File No.: 17 

Licensee: Rosalind Franklin University of Medicine License No.: IL-01480-02 

 and Science 

Type of Action: New Amendment No.: 0 

Date Issued: 11/17/06 License Reviewer: MB 
Illinois Final Report Page D.3 

License Casework Reviews

File No.: 18 

Licensee: Northrop Grumman Systems Company License No.: IL-02127-01 

Type of Action: Amendment Amendment No.: 11 

Date Issued: 4/10/08 License Reviewer: CV 

File No.: 19 

Licensee: Cardinal Health, Inc. License No.: IL-01721-01 

Type of Action: Renewal Amendment No.: 42 

Date Issued: 6/26/07 License Reviewer: MB 

File No.: 20 

Licensee: Oxford Instruments America, Inc. License No.: IL-01694-01 

Type of Action: Renewal Amendment No.: 18 

Date Issued: 12/29/08 License Reviewer: SK 

File No.: 21 

Licensee: Rush University Medical Center License No.: IL-01766-03 

Type of Action: Renewal Amendment No.: 5 

Date Issued: 01/22/07 License Reviewer: TH 

File No.: 22 

Licensee: Landauer, Inc. License No.: IL-01376-01 

Type of Action: Renewal Amendment No.: 11 

Date Issued: 2/5/09 License Reviewer: MB 

File No.: 23 

Licensee: The Art Institute of Chicago License No.: IL-01631-01 

Type of Action: Amendment Amendment No.: 9 

Date Issued: 6/21/07 License Reviewer: MB 

File No.: 24 

Licensee: Orland Park Equine Hospital, Ltd. License No.: IL-07152-01 

Type of Action: Renewal Amendment No.: 11 

Date Issued: 10/26/06 License Reviewer: SK 

File No.: 25 

Licensee: Varian Medical Systems License No.: IL-01143-01 

Type of Action: Renewal Amendment No.: 13 

Date Issued: 1/14/08 License Reviewer: TH 

File No.: 26 

Licensee: Bard Brachytherapy, Inc. License No.: IL-02062-01 

Type of Action: Renewal Amendment No.: 9 

Date Issued: 5/24/05 License Reviewer: MB 
Illinois Final Report Page D.4 

License Casework Reviews

File No.: 27 

Licensee: Tronox LLC License No.: STA-583 

Type of Action: Renewal Amendment No.: 73 

Date Issued: 2/25/09 License Reviewer: JB 

File No.: 28 

Licensee: Raymond G. Scott Cancer Center License No.: IL-02371-01 

Type of Action: Termination Amendment No.: 1 

Date Issued: 1/11/06 License Reviewer: SK 

File No.: 29 

Licensee: Life Source Blood Services of Corporate License No.: IL-01851-01 

Type of Action: Termination Amendment No.: 12 

Date Issued: 8/17/07 License Reviewer: TH 

File No.: 30 

Licensee: Washington County Hospital License No.: IL-01035-01 

Type of Action: Amendment Amendment No.: 27 

Date Issued: 10/23/08 License Reviewer: RH 
APPENDIX E 

INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: Pharmacy Services of Peoria License No.: IL-01874-01 

Date of Incident: 10/26/05 NMED Log No.: 050720 

Investigation Dates: 10/26-27/05 Type of Incident: Contamination 

 Type of Investigation: Telephone 

File No.: 2 

Licensee: Medi-Physics, Inc. License No.: IL-01052-01 

Date of Incident: 11/28/05 NMED Log No.: 050782 

Investigation Date: 11/29/05 Type of Incident: Contamination 

 Type of Investigation: Telephone 

File No.: 3 

Licensee: Indev Gauging Systems License No.: IL-02050-01 

Date of Incident: 8/24/05 NMED Log No.: 050599 

Investigation Date: 8/26/05 Type of Incident: Leaking Source 

 Type of Investigation: Site 

File No.: 4 

Licensee: Bard Brachytherapy License No.: IL-02062-01 

Date of Incident: 11/9/06 NMED Log No.: 060695 

Investigation Date: 11/10/06 Type of Incident: Lost Material 

 Type of Investigation: Telephone 

File No.: 5 

Licensee: Rush-Copley Medical Center License No.: IL-01207-01 

Dates of Incidents: 7/28/06 and 8/22/06 NMED Log No.: 060551 

Investigation Date: 8/28/06 Type of Incident: Medical Event 

 Type of Investigation: Telephone 

File No.: 6 

Licensee: Oxford Instruments License No.: IL-01694-01 

Date of Incident: 4/18/06 NMED Log No.: 060602 

Investigation Date: 6/23/06 Type of Incident: Leaking Source 

 Type of Investigation: Telephone 

File No.: 7 

Licensee: Children's Memorial Medical Center License No.: IL-01165-01 

Date of Incident: 7/24/06 NMED Log No.: 060480 

Investigation Date: 7/28/06 Type of Incident: Medical Event 

 Type of Investigation: Site 
Illinois Final Report Page E.2 

Incident Casework Reviews

File No.: 8 

Licensee: Quad City Testing Laboratory License No.: IL-01089-01 

Date of Incident: 7/17/06 NMED Log No.: 060493 

Investigation Date: 7/18/06 Type of Incident: Overexposure 

 Type of Investigation: Site 

File No.: 9 

Licensee: S.T.A.T.E Testing, LLC License No.: IL-01015-01 

Date of Incident: 6/2/06 NMED Log No.: 060368 

Investigation Date: 6/2/06 Type of Incident: Stolen Material 

 Type of Investigation: Site 

File No.: 10 

Licensee: Chicago Prostate Cancer Center License No.: IL-02015-01 

Date of Incident: 1/5/06 NMED Log No.: 0060040 

Investigation Date: 1/11/06 Type of Incident: Leaking Source 

 Type of Investigation: Site 

File No.: 11 

Licensee: St. James Hospital and Health Center License No.: IL-01289-01 

Date of Incident: 11/29/06 NMED Log No.: 070014 

Investigation Date: 1/8/07 Type of Incident: Medical Event 

 Type of Investigation: Site 

File No.: 12 

Licensee: Pinnacle Foods Group, Inc. License No.: 9223630 (General) 

Date of Incident: 3/13/07 NMED Log No.: 070213 

Investigation Date: 4/6/07 Type of Incident: Lost Material 

 Type of Investigation: Telephone/Site 

File No.: 13 

Licensee: McNDT Leasing, Inc. License No.: IL-01875-01 

Date of Incident: 7/20/07 NMED Log No.: 070468 

Investigation Date: 7/20/07 Type of Incident: Damaged Equipment 

 Type of Investigation: Site 

File No.: 14 

Licensee: Nuclear Oncology, S.C. License No.: IL-01641-01 

Date of Incident: 11/19/07 NMED Log No.: 070724 

Investigation Date: 11/21/07 Type of Incident: Medical Event 

 Type of Investigation: Telephone 

File No.: 15 

Licensee: Miller Compressing License No.: Non-Licensee 

Date of Incident: 12/10/07 NMED Log No.: N/A 

Investigation Date: 12/10/07 Type of Incident: Recovered Material 

 Type of Investigation: Telephone 
Illinois Final Report Page E.3 

Incident Casework Reviews

File No.: 16 

Licensee: Chicago Prostate Cancer Center License No.: IL-02015-01 

Date of Incident: 4/24/08 NMED Log No.: 080282 

Investigation Date: 4/25/08 Type of Incident: Leaking Source 

 Type of Investigation: Telephone 

File No.: 17 

Licensee: Sterling Steel Company License No.: IL-01785-01 

Date of Incident: 7/7/08 NMED Log No.: 080518 

Investigation Date: 7/7/08 Type of Incident: Damaged Sources 

 Type of Investigation: Site 

File No.: 18 

Licensee: Team Industrial Services License No.: IL-01136-01 

Date of Incident: 9/12/08 NMED Log No.: 080566 

Investigation Date: 9/12/08 Type of Incident: Equipment Failure 

 Type of Investigation: Telephone 

File No.: 19 

Licensee: GSG Material Testing, Inc. License No.: IL-02340-01 

Date of Incident: 11/6/08 NMED Log No.: 080776 

Investigation Date: 11/7/08 Type of Incident: Stolen Material 

 Type of Investigation: Telephone 

File No.: 20 

Licensee: GE Healthcare License No.: IL-01052-01 

Date of Incident: 12/5/08 NMED Log No.: N/A 

Investigation Date: 12/5/08 Type of Incident: Contamination 

 Type of Investigation: Telephone 
APPENDIX F 

SEALED SOURCE & DEVICE (SS&D) CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Registry No.: IL-1074-S-101-S SS&D Type: (AA) Manual Brachytherapy 

Manufacturer: Bard Brachytherapy, Inc. Model No.: STM 125I 

Date Issued: 4/1/08 Type of Action: Amendment 

 SS&D Reviewers: SK, CV 

Comment: 

Licensee’s corrective actions were not incorporated into the license of the SS&D 

registry. 

File No.: 2 

Registry No.: IL-1074-S-101-S SS&D Type: (AA) Manual Brachytherapy 

Manufacturer: Bard Brachytherapy, Inc. Model No.: STM 125I 

Date Issued: 6/6/07 Type of Action: Amendment 

 SS&D Reviewers: MB, CV 

File No.: 3 

Registry No.: IL-1074-S-101-S SS&D Type: (AA) Manual Brachytherapy 

Manufacturer: Bard Brachytherapy, Inc. Model No.: STM 125I 

Date Issued: 1/31/07 Type of Action: Amendment 

 SS&D Reviewers: MB, CV 

File No.: 4 

Registry No.: IL-1074-S-101-S SS&D Type: (AA) Manual Brachytherapy 

Manufacturer: Bard Brachytherapy, Inc. Model No.: STM 125I 

Date Issued: 1/31/06 Type of Action: Amendment 

SS&D Reviewer: CV 

File No.: 5 

Registry No.: IL-1074-S-101-S SS&D Type: (AA) Manual Brachytherapy 

Manufacturer: Bard Brachytherapy, Inc. Model No.: STM 125I 

Date Issued: 12/16/05 Type of Action: Amendment 

 SS&D Reviewers: SK, CV 

File No.: 6 

Registry No.: IL-1074-S-101-S SS&D Type: (AA) Manual Brachytherapy 

Manufacturer: Bard Brachytherapy, Inc. Model No.: STM 125I 

Date Issued: 9/13/05 Type of Action: Amendment 

 SS&D Reviewers: SK, CV 

File No.: 7 

Registry No.: IL-1082-S-101-S SS&D Type: (J)(K)(L)(M) Gamma Irradiator 

Manufacturer: REVISS Services, Inc. Model No.: RSL2089 

Date Issued: 11/1/08 Type of Action: Amendment 

 SS&D Reviewers: MB, CV 
Illinois Final Report Page F.2 

SS&D Casework Reviews

File No.: 8 

Registry No.: IL-235-D-102-B SS&D Type: (U) X-Ray Fluorescence 

Manufacturer: Oxford Instruments America, Inc. Model No.: Various 

Date Issued: 12/29/08 Type of Action: Amendment 

 SS&D Reviewers: SK, CV 

File No.: 9 

Registry No.: IL-605-D-106-B SS&D Type: (Y) Calibrator 

Manufacturer: Siemens Medical Solutions USA, Inc. Model No.: 07837722 

Date Issued: 10/8/08 Type of Action: Amendment 

 SS&D Reviewers: SK, CV 

File No.: 10 

Registry No.: IL-605-D-106-B SS&D Type: (Y) Calibrator 

Manufacturer: Siemens Medical Solutions USA, Inc. Model No.: 07837722 

Date Issued: 7/25/07 Type of Action: Amendment 

 SS&D Reviewers: SK, CV 
ATTACHMENT 

July 13, 2009 E-mail from Joseph Klinger 

Illinois’s Response to Draft IMPEP Report 

ADAMS Accession No.: ML091970520