August 21, 2008 

Ms. Mary C. Selecky 

Secretary 

Washington State Department of Health 

101 Israel Road, SE 

P.O. Box 47890 

Olympia, WA 98504-7890 

Dear Ms. Selecky: 

On July 22, 2008, the Management Review Board (MRB) met to consider the proposed final 

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

Agreement State Program. The MRB found the Washington 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 19, of the enclosed final report contains a summary of the IMPEP review 

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

Washington Agreement State Program will take place in approximately 4 years, with a periodic 

meeting tentatively scheduled for April 2010. 

The MRB recognized that this review marked the third consecutive IMPEP review in which the 

Washington Agreement State Program was found adequate to protect public health and safety, 

compatible with the NRC’s program, and satisfactory for all performance indicators reviewed. 

These are the highest possible ratings for an IMPEP review. I applaud your staff for their 

dedication to excellence in radiation protection. 

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: 

Washington Final IMPEP Report 

cc w/encl.: See next page 
cc w/encl.: Gary Robertson, Director 

 Washington Office of Radiation Protection 

 Matthew Steuerwalt, State Liaison Officer 

 Washington Office of the Governor 

 Jack Ferruolo, Rhode Island 

 Organization of Agreement States 

 Liaison to the MRB 
August 21, 2008 

Mary C. Selecky 

Secretary 

Washington State Department of Health 

101 Israel Road, SE 

P.O. Box 47890 

Olympia, WA 98504-7890 

Dear Ms. Selecky: 

On July 22, 2008, the Management Review Board (MRB) met to consider the proposed final 

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

Agreement State Program. The MRB found the Washington 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 19, of the enclosed final report contains a summary of the IMPEP review 

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

Washington Agreement State Program will take place in approximately 4 years, with a periodic 

meeting tentatively scheduled for April 2010. 

The MRB recognized that this review marked the third consecutive IMPEP review in which the 

Washington Agreement State Program was found adequate to protect public health and safety, 

compatible with the NRC’s program, and satisfactory for all performance indicators reviewed. 

These are the highest possible ratings for an IMPEP review. I applaud your staff for their 

dedication to excellence in radiation protection. 

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: 

Washington Final IMPEP Report 

cc w/encl.: See next page 

Distribution: See next page. EDATS: FSME-2008-0031 

 Package ML082100343 

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

NAME ATMcCraw:km ADWhite RJLewis CPoland (P.Tressler for)

DATE 7/29/08 7/30/08 7/30/08 7/30/08 

OFFICE FSME DEDMRT 

NAME CLMiller(G.Pangburn for) MJVirgilio 

DATE 8/7/08 8/21/08 

OFFICIAL RECORD COPY
LETTER TO MARY C. SELECKY FROM MARTIN J. VIRGILIO DATED: August 21, 2008 

Distribution: EDATS: FSME-2008-0031 

DMSSA RF DCD (SP01) 

EDO RF 

RidsEdoMailCenter 

RidsFsmeOd 

RidsSecyCorrespondenceMailCenter Chairman Klein 

KLukes, FSME/DMSSA Commissioner Jaczko 

JLynch, RIII Commissioner Lyons 

RErickson, RIV/RSAO Commissioner Svinicki 

WRautzen, FSME/DMSSA SECY 

JBuckley, FSME/DWMEP 

JShaffner, FSME/DWMEP 

SCampbell, OEDO 

KCyr, OGC 

BJones, OGC 

JKinneman, RI 

APowell, OCA (2 copies) 
Enclosure 

INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

REVIEW OF THE WASHINGTON AGREEMENT STATE PROGRAM 

May 5-9, 2008 

FINAL REPORT
Washington Final Report Page 1 

1.0 INTRODUCTION 

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

review was conducted during the period of May 5-9, 2008, by a review team comprised of 

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

North Carolina. Team members are identified in Appendix A. The review was conducted in 

accordance with the “Implementation of the Integrated Materials Performance Evaluation 

Program and Rescission of Final General Statement of Policy,” published in the Federal 

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

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

review, which covered the period of September 13, 2003, to May 9, 2008, were discussed with 

Washington State managers on the last day of the review. 

A draft of this report was issued to the State of Washington for factual comment on June 5, 

2008. The State responded by letter on June 27, 2008, from Mary C. Selecky, Secretary, 

Department of Health (the Department). A copy of the State’s response is included as the 

Attachment to this report. The Management Review Board (MRB) met on July 22, 2008, to 

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

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

The Washington Agreement State program is administered by the Office of Radiation Protection 

(the Office) in the Division of Environmental Health. The Division is part of the Department. 

Organization charts for the Department and Office are included in Appendix B. 

At the time of the review, the Washington Agreement State program regulated 447 specific 

licenses authorizing the use of byproduct, source, and special nuclear material. 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 the NRC and the State of 

Washington. 

In preparation for the review, a questionnaire addressing the common and applicable noncommon performance indicators was sent to the Office on January 14, 2008. The Office 

provided its response to the questionnaire on April 18, 2008. A copy of the questionnaire 

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

(ADAMS) using the Accession Numbers ML081140419 and ML081140420. 

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

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

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

review of selected regulatory actions; (5) field accompaniments of eight 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 Washington Agreement State Program’s 

performance. 

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 
Washington Final Report Page 2 

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. 

2.0 STATUS OF ITEMS IDENTIFIED IN PREVIOUS REVIEWS 

During the previous IMPEP review, covering the period of September 14, 1999 through 

September 12, 2003, the review team made one recommendation regarding program 

performance. The current status of the recommendation is as follows: 

 The review team recommends that the Office develop and implement a plan to 

adequately and consistently address the financial assurance for decommissioning 

portions of material license regulations. (Section 3.4 of the 2003 IMPEP report) 

Current Status: Office management presented a plan to NRC’s MRB on 

December 10, 2003, describing the steps to be taken to address the financial 

assurance requirements for material licenses. The review team confirmed that 

adequate financial assurance reviews were being performed by a consultant. In 

the near future, the Office plans to have the consultant train staff members to 

perform financial assurance reviews. The training is scheduled to occur by 

September 2009. This recommendation is closed. 

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 Office’s staffing level and staff 

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

these issues, the review team examined the Office’s questionnaire response relative to this 

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

and considered any possible workload backlogs. 

The Office is managed by the Office Director and two Regional Directors. The Office is 

comprised of seven sections split between the two Regions. The Western Regional Director is 

located in the Olympia Office and is responsible for the operations of three sections: the 

Radioactive Materials Section (the Materials Section), the X-ray Section, and the Information 

Management and Process Development Section. The Eastern Regional Director is located in 

the Richland Office and is responsible for the operations of four sections: the Radioactive Air 

Emissions Section, the Environmental Radiation Monitoring and Assessment Section, the 

Radiological Emergency Preparedness Section, and the Waste Management Section (the 

Waste Section). The Agreement State program is primarily administered by the Materials 

Section and the Waste Section, with the other sections providing various degrees of support. 

Staffing and training for the Materials Section will be covered in this section of the report, and 
Washington Final Report Page 3 

staffing and training for the Waste Section will be covered in Sections 4.3.1 and 4.4.1 of the 

report. 

The Materials Section is responsible for radioactive materials licensing, inspection, and 

emergency response activities. At the time of the review, the Materials Section employed eight 

technical staff members and an administrative staff member. The technical staff members, 

called Health Physicists, perform licensing, inspection, and emergency response activities. 

The Materials Section is headed by the Materials Section Supervisor. Three senior staff 

members act as Program Managers for three major licensee groups: medical, industrial, and 

laboratories. The other technical staff members are assigned to assist the Program Managers. 

Four staff members left the Materials Section during the review period. One of the individuals 

was promoted to a position in the Waste Section, and the other three either resigned or were 

terminated. The Office was able to fill the vacancies in an expedient manner. At the time of the 

review, the Materials Section was fully staffed. 

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

who perform licensing and inspection duties and investigate incidents. The training and 

qualification program is equivalent to NRC Inspection Manual Chapter (IMC) 1246, “Formal 

Qualification Programs in the Nuclear Material Safety and Safeguards Program Area” and is 

consistent with the NRC and Organization of Agreement States (OAS) Training Working Group 

Recommendations for Agreement State Training Programs. Qualification is achieved through a 

combination of education and experience, formal classroom training, and on-the-job training. 

New staff members are required to have a Bachelor’s degree in a physical or biological science 

or engineering and a minimum of 2 years experience in the use of radiation. 

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

noted that Office managers encourage and support training opportunities, based on program 

needs and funding. The review team concluded that the Materials Section’s staffing and 

training is adequate to carry out its regulatory duties. 

The Materials Section is a 100 percent fee-supported regulatory program. Licensees are 

assessed an annual fee to cover the costs associated with amendments, routine inspections, 

and investigations. New license applicants are assessed a small fee to cover the initial prelicensing inspection costs. In addition, the Office receives a small apportionment from the State 

general fund to cover costs associated with incident response for the entire program. 

In early 2008, the Washington legislature approved a proposed rule to increase fees. A public 

hearing for the rulemaking was scheduled for May 30, 2008. The proposed rule would increase 

fees for radioactive material licensees by up to 30 percent and x-ray registrants by up to 

40 percent. Approval of the rulemaking will allow the Office to add 2.5 full-time equivalents 

(FTE), of which 1.0 FTE would be dedicated to the Materials Section. The fee increase would 

avoid a projected budget shortfall, which may have required a reduction in staff levels, and 

would allow a planned upgrade to the Office’s computer database. 

The Office initiated a major effort to focus on organizational development and leadership. Using 

leadership models, concepts, and theories, Office managers, with the assistance of a full-time 

specialist, implemented a number of in-house information gathering forums. These forums were 
Washington Final Report Page 4 

designed to engage staff members at all levels of the organization in the development of Office 

values, mission, and vision, as well as strategic and succession planning. The Office performs 

effectiveness monitoring for key activities, including the effectiveness of managers. Built into 

the process is executive coaching of the Office and Regional Directors. Staff reaction to the 

process appeared to be favorable. 

The State of Washington does not have an established State radiation oversight board. If the 

Office determines that advice is needed on a particular subject, a group of licensee 

representatives is convened to act in an advisory role to the Office. 

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

that Washington’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 while reviewing this indicator: inspection frequency, 

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

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

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

database, examination of completed inspection casework, and interviews with the Materials 

Section Supervisor and staff members. 

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

frequencies for all types of Washington material licenses are at least the same frequency as 

those listed in IMC 2800, “Materials Inspection Program.” Some categories of licenses were 

assigned inspection priority codes that prescribe a more frequent inspection schedule than 

those prescribed in IMC 2800. 

The Materials Section conducted a total of 440 inspections of high priority (Priority 1, 2, and 3) 

licensees during the 5-year review period. The review team determined that no inspections 

were performed overdue or were overdue at the time of the review. The review team also 

evaluated the Materials Section’s timeliness for conducting initial inspections. The review team 

noted that the Materials Section conducted 24 initial inspections during the review period. All 

were inspected within one year, in accordance with IMC 2800 guidelines. . 

The review team evaluated the Materials Section’s timeliness of issuance of inspection reports 

and determined that the Materials Section has an effective and efficient process that helps 

ensure that inspection findings are communicated to licensees in a timely manner. Inspection 

findings are communicated to the licensee using a form (DOH 322-015) similar to NRC’s Form 

591, “Safety Inspection Report and Compliance Inspection.” These forms are generally used for 

infractions or deficiencies. A completed form is typically issued on-site upon the completion of 

an inspection or included in a notice of correction letter. The review team determined that, if not 

issued at the conclusion of the onsite inspection, these forms were issued within 30 days of the 

inspection. Of the 34 inspection files reviewed by the review team, one inspection summary 

was issued beyond the 30-day goal. 
Washington Final Report Page 5 

During the review period, the Materials Section received requests for reciprocity from 144 

licensees. The review team determined that the Materials Section conducted reciprocity 

inspections of 20 percent of those licensees during the review period. The Section met the 

criterion in IMC 1220 “Processing of NRC Form 241 and Inspection of Agreement State 

Licensees Operating Under 10 CFR 150.20,” that requires on-site inspection of 20 percent of 

candidate licensees operating under reciprocity. 

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

Increased Controls inspections for materials security measures of affected licensees. The 

review team evaluated the Materials Section’s prioritization methodology and found it 

acceptable. The Materials Section identified 29 licensees that were subject to the Increased 

Controls and performed all of the first-year inspections in a timely manner. The review team 

determined that the Materials Section re-evaluated the pertinent aspects of the security 

measures during subsequent routine safety inspections following the initial Increased Controls 

inspections. 

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

that Washington’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 34 radioactive materials inspections 

conducted during the review period. The casework examined included a cross-section of 

inspections conducted by one former and eight current inspectors and covered a wide variety of 

inspection types. These included medical, academic, and research and development 

broadscope licensees; industrial radiography; well logging; self-shielded irradiator; service 

provider; gamma knife; positron emission tomography; veterinarian nuclear medicine; medical; 

nuclear pharmacy; portable gauges; and reciprocity licensees. The review also included both 

initial and followup Increased Controls inspections. Appendix C lists the inspection casework 

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

accompaniments. 

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 support 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 Materials Section’s inspection procedures are consistent with the inspection guidance 

found in IMC 2800. At the conclusion of each inspection, the inspectors have the option to send 

inspection findings from the office or to use a form similar to NRC’s Form 591 that can be left 

with the licensee at the conclusion of the inspection. The Materials Section uses this form to 

document both clear inspections and inspections identifying infractions, deficiencies, or 

recommendations. The inspector can require a written response from the licensee describing 
Washington Final Report Page 6 

corrective actions to address any infractions, deficiencies, or recommendations. Inspectors can 

also use this form to document investigations, field site surveys, and close-out surveys. 

Violations are considered the most severe type of finding and can only be dispatched from the 

office after management review and approval. 

The Materials Section performed quality assurance peer reviews on at least 20 percent of all 

inspection documentation. All inspection documentation is entered into the Office’s electronic 

filing system, which is accessible to all staff members. 

The Materials Section performs staff accompaniments annually. The Materials Section 

Supervisor accompanied each Health Physicist yearly. He accompanied each Program 

Manager every other year. In the interim years, Program Managers performed 

accompaniments of each other. The Materials Section uses this system so that the Program 

Managers have the benefit of being accompanied by other senior staff members and not just the 

Materials Section Supervisor. 

The review team determined that documents involving Increased Controls inspections were 

protected, segregated from the electronic file storage system, and maintained in a locked file 

cabinet with limited access. Files are maintained in visually distinct folders so staff can easily 

differentiate them from other files for licensees subject to the Increased Controls. Documents 

observed were sufficiently marked as sensitive information to be withheld from public disclosure. 

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

calibrated survey instruments to support the inspection program, and to respond to radioactive 

materials incidents. Instruments used to support the materials inspection program are sent 

either to the University of Washington Calibration Laboratory, or the manufacturer, for 

calibration. 

The Office receives laboratory and sample analysis support from the State laboratory. The 

State laboratory is a licensee of the Office and performs sample analysis for multiple programs 

within the Department. The laboratory has a wide array of analytical equipment capable of 

detailed radiochemistry analysis. The equipment includes high purity germanium detectors, 

gamma counters, and various scintillation counters. 

The review team accompanied four of the Section’s inspectors during the week of April 14-17, 

2008, at a nuclear cardiology office, two surgery centers performing radioactive seed implants, a 

gamma knife center, and a research facility using a self-shielded irradiator. The inspectors 

demonstrated appropriate 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 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. 
Washington Final Report Page 7 

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

that Washington’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 

28 specific licenses. Licensing actions were reviewed for completeness, consistency, 

possession authorization, 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 deficiency letters and cover 

letters, reference to appropriate regulations, supporting documentation, consideration of 

enforcement history, pre-licensing visits, 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 five new 

licenses, nine renewals, nine amendments, and five license terminations. Files reviewed 

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

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

licensees. The casework sample represented work from each of the license reviewers. A listing 

of the licensing casework reviewed, with case-specific comments, may be found in Appendix D. 

All licensing actions in the Materials Section are assigned a tracking number and logged into a 

computer tracking system. For routine amendments, the action is then given to a license 

reviewer. For new license applications, the Materials Section sends a letter notifying local 

government officials of the proposed use of radioactive materials in their jurisdiction. State law 

(Revised Code of Washington (RCW) 70.98.80) requires this notification. Local officials have 

20 days from the date of the notification to provide written comment on the proposed facility. 

After this 20-day period has elapsed, the application is assigned to a reviewer. 

If needed, the reviewer generates a deficiency letter and produces a draft licensing action upon 

final resolution of all deficiency items. The draft licensing action receives a quality assurance 

(QA) review by peer license reviewers. Corrections are made, as needed, and the licensing 

action is issued. The license reviewers in the Materials Section have signature authority and 

sign their own licensing actions. The QA reviewer initials each final licensing action, and places 

a QA checklist in the file. Each license reviewer uses boilerplate licenses specific to the type of 

licensing actions (i.e., industrial, medical, or laboratory) to ensure consistency in standard 

licenses. As another QA measure, the Materials Section Supervisor reviews approximately 

10 percent of all licensing actions that the Materials Section issues. 

The review team noted the licensing actions were of high quality and consistent with the 

Material Section’s procedures, the State’s regulations, and good health physics practices. The 

consistent use of templates and peer reviews contribute to the overall high quality noted in the 

casework reviews. 

The Materials Section transmits copies of medical licenses they have amended within a 

calendar quarter to each of their nuclear pharmacy licensees. This enables the pharmacy to 
Washington Final Report Page 8 

cross-reference with the “hard copy” they maintain on file. The State’s nuclear pharmacy 

licensees support this practice, as it allows them to have a current copy of their clients’ licenses. 

The nuclear pharmacy licensees have agreed to maintain appropriate control over the license 

documents in their possession. This practice will continue until the nationwide electronic license 

verification system is populated and functional. The review team recommended, and the MRB 

agreed, that the State’s practice of transmitting copies of amended medical licenses to nuclear 

pharmacies for verification of license possession limits, is a good practice. 

The review team evaluated several license files where financial assurance for decommissioning 

was required. Those licensees have submitted the decommissioning funding plan required 

under Washington’s regulations. The review team determined that the Office has appropriately 

identified licensees required to maintain financial assurance and have taken appropriate steps 

to ensure the licensees remain compliant with the financial assurance requirements. Financial 

instruments are appropriately protected from loss or theft. 

The review team found that decommissioning licensing actions were well documented, showing 

appropriate transfer records and/or appropriate disposal methods and records, confirmatory 

surveys, and survey records. License terminations were well documented, showing appropriate 

transfer and survey records. 

The Materials Section performs pre-licensing checks of all new applicants and new authorized 

users. The method incorporates the use of elements identified in the NRC’s NUREG-1556, 

Volume 20, “Consolidated Guidance About Materials Licenses - Guidance About Administrative 

Licensing Procedures,” to verify that the applicant will use requested radioactive materials as 

intended. Methods used include checks with the Washington Secretary of State’s office and 

local office of the Department of Revenue. Additionally, the reviewers use various on-line 

search mechanisms and interagency communication to verify the identity of individuals. The 

Materials Section has a policy of hand-delivering all new licenses. Each applicant is subject to 

an on-site evaluation of their radiation safety and security programs prior to license receipt. 

This practice ensures that applicants have adequate radiation safety and security programs in 

place prior to the licensees’ taking possession of radioactive material. This also serves as the 

“pre-licensing visit.” The Materials Section was aware of NRC’s recent revision of the prelicensing guidance and has implemented the essential objectives of the revised guidance. 

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

Controls and Fingerprinting Orders. The review team noted that the Materials Section added 

legally binding license conditions to the licenses that met the criteria for implementing the 

Increased Controls, including fingerprinting, as appropriate. The review team analyzed the 

Section’s methodology for identifying those licenses and found the rationale was thorough and 

accurate. License reviewers evaluate new license applications and license amendments using 

the same criteria. 

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

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

Actions, was satisfactory. 
Washington Final Report Page 9 

3.5 Technical Quality of Incident and Allegation Activities

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

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

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

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

casework for 15 of 60 reported radioactive materials incidents. A listing of the casework 

examined can be found in Appendix E. The review team also evaluated the Materials Section’s 

response to five allegations involving radioactive materials reported directly to the State during 

the review period. The NRC did not refer any allegations to the State during the review period. 

When notified of an incident or an allegation, the Materials Section Supervisor and staff discuss 

the initial response and the need for an on-site investigation. The Materials Section maintains a 

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

reportability thresholds, as established in the NRC’s Office of Federal and State Materials and 

Environmental Management Programs (FSME) Procedure SA-300 “Reporting Material Events,” 

the Materials Section promptly notifies the NRC Headquarters Operations Center. If the 

investigation is complex and extends over a period of time, NMED is appropriately updated, 

using the established template. Of the incidents evaluated by the review team, all had been 

reported to the NRC within the required time frame and been properly completed in NMED. 

The incidents selected for review included both medical and industrial events involving lost or 

stolen radioactive material, overexposures, damaged equipment, contamination events, a 

release of radioactive material, and equipment failures. The review team determined that the 

Materials Section’s responses to incidents were thorough, complete, and comprehensive. Initial 

responses were prompt and well coordinated, and the level of effort was commensurate with the 

health and safety significance. The review team noted that at the conclusion of investigations, 

inspectors generated narrative reports that thoroughly documented the investigations. Records 

were stored in the Office’s electronic filing system and were marked appropriately. 

The review team discussed the reporting of incidents involving certain naturally occurring and 

accelerator-produced material (NARM) with the Office managers. A review of the tracking 

database verified that no incidents involving NARM had been reported since the November 30, 

2007 waiver termination date for expansion of the definition of “byproduct material,” as 

established by the Energy Policy Act of 2005. Office managers understood the requirement to 

report NARM events to the NMED contractor. 

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

team evaluated the casework for five allegations. The review team concluded that the Materials 

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

review team noted that the Materials Section thoroughly documented the investigations and 

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

Section notified the allegers of the conclusion of their investigation. The review team 

determined that the Materials Section adequately protected the identity of allegers. 

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

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

Allegation Activities, was satisfactory. 
Washington Final Report Page 10 

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. Washington’s Agreement includes all of the non-common performance indicators. 

4.1 Compatibility Requirements

4.1.1 Legislation

Washington became an Agreement State in 1966. The Department is designated as the State's 

radiation control agency and implements the radiation control program. The effective statutory 

authority for control of radioactive materials is contained in RCW 70.98, “Nuclear Energy and 

Radiation” and RCW 70.121, “Mill Tailings, Licensing and Perpetual Care.” The program also is 

affected by RCW 70.94, “Washington Clean Air Act.” 

During the review period, the Washington legislature passed a proposed bill affecting the 

radiation control program, giving the Office permission to increase radioactive materials license 

fees up to 30 percent and x-ray registrant fees up to 40 percent. A public hearing on the fee 

increase bill took place on May 30, 2008. The State filed the results of that public hearing within 

a few days of the public hearing. The fee increase went into effect 30 days after that filing date. 

4.1.2 Program Elements Required for Compatibility

The RCW applies to all ionizing radiation and provides the statutory authority for radioactive 

materials, the low-level radioactive waste, and the uranium mill programs. Regulations are 

provided in the Washington Administrative Code. Washington requires a license for possession 

and use of all radioactive material, including NARM. Washington also requires registration of all 

equipment designed to produce x-rays or other ionizing radiation. 

The review team examined the State’s administrative rulemaking process and found that the 

process takes approximately 6 to 8 months from the developmental stage to the final adoption 

by the Secretary of Health and filing with the Code Reviser’s Office, after which the rules 

become effective in 31 days. Washington can adopt NRC amendments in this short time frame 

as “Exception” rules. An Exception rule is allowed when the program adopts a Federal rule 

without material change. This shortened process relies on the Federal rulemaking work which 

provides equivalent documentation to the State’s required initial Reasoning for the Rulemaking, 

Economic Impact Analysis, Small Business Economic Impact Statements, and Legislatively 

Significant Analysis (cost benefit analysis). 

The public, the 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 

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

lieu of regulations until compatible regulations become effective. 
Washington Final Report Page 11 

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

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

adequacy and compatibility policy, and verified the adoption of regulations with data obtained 

from the State Regulation Status Sheet that FSME maintains. 

The review team noted that Washington was up to date on all but one NRC regulatory 

amendment currently required for compatibility. That amendment, “Compatibility with IAEA 

Transportation Safety Standards,” which was due for Agreement State adoption by October 

2007, was reviewed for compatibility by NRC staff subsequent to the IMPEP review. On June 

18, 2008, the NRC notified the State of the results of the compatibility review. NRC staff had 

two comments on the State’s final rule that will need to be addressed. 

Since the previous IMPEP review, the State submitted seven packages covering eight 

amendments for compatibility reviews. The review team reminded Office managers that NRCidentified comments on one earlier submitted regulation package, “Requirements for Certain 

Generally Licensed Industrial Devices,” have yet to be resolved. 

 

The review team identified the following NRC amendments that the State will need to address in 

the future. The Office Director related that the amendments would be addressed in upcoming 

rulemakings or in the adoption of alternate legally binding requirements: 

● “National Source Tracking System,” 10 CFR Part 20 amendment (71 FR 65685), that is 

due for Agreement State adoption by January 31, 2009. 

● “Medical Use of Byproduct Material – Minor Corrections and Clarifications,” 10 CFR 

Parts 32 and 35 amendment (72 FR 45147 and 72 FR 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 Washington’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 Materials 
Washington Final Report Page 12 

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 Materials Section's SS&D evaluation activities, the review team examined 

information contained in the Office’s response to the IMPEP questionnaire for this indicator. 

The review team evaluated all SS&D evaluations and supporting documents processed during 

the review period. The Materials Section conducted one new SS&D evaluation and issued one 

amendment to an existing registration since the last review. The review team 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 Materials Section has six reviewers who are qualified to perform safety evaluations of 

SS&D applications. All have degrees in a physical science or engineering and have attended 

the NRC’s SS&D Workshop. The review team interviewed staff members involved in the 

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

device/source and had access to applicable reference documents. 

4.2.2 Technical Quality of the Product Evaluation Program

The review team evaluated all SS&D actions issued during the review period. One of the 

actions, a NARM source distributor, was performed on behalf of the State of Wisconsin. This 

casework reviewed represented the efforts of three of the six SS&D reviewers. A list of SS&D 

casework examined, with case-specific comments, may be found in Appendix F. 

Analysis of the casework and interviews with staff members confirmed that the Materials 

Section follows the recommended guidance from the NRC’s SS&D Workshop and NUREG1556, 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 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 

Registrations clearly summarized the product evaluations to provide license reviewers with 

adequate information to license the possession and use of the products. Deficiency letters 

clearly stated regulatory positions and all health and safety issues were addressed. The review 

team determined that the product evaluations were thorough, complete, consistent, of 

acceptable technical quality, and adequately addressed the integrity of the products during use 

and under accident conditions. 

4.2.3 Evaluation of Defects and Incidents Regarding SS&Ds

No incidents related to SS&D defects involving sources or devices registered by the State of 

Washington were reported during the review period. Incident procedures are in place should an 

SS&D-related incident occur. Office managers were aware of the need to look at such incidents 
Washington Final Report Page 13 

as potentially generic in nature with possible wide-ranging effects. 

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

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

Evaluation Program, was satisfactory. 

4.3 Low-level Radioactive Waste (LLRW) Disposal Program

In reviewing this indicator, the review team used five subelements to evaluate the Waste 

Section’s performance regarding the LLRW disposal program. These subelements were: 

(1) Technical Staffing and Training, (2) Status of Low-level Radioactive Waste Disposal 

Inspection, (3) Technical Quality of Inspections, (4) Technical Quality of Licensing Actions, and 

(5) Technical Quality of Incident and Allegation Activities. 

The Waste Section currently licenses US Ecology, Inc. (USE) to receive, handle, process, store, 

and dispose of LLRW at the Hanford site. The Waste Section also licenses the Perma-Fix 

Processing Facility and various aspects of the Uranium Milling and Mining Industry (see Section 

4.4, below). 

The Department’s administration of its regulatory roles and responsibilities are properly included 

as part of the periodic IMPEP reviews. In conducting the review, it became apparent that 

implementation of some aspects of its regulatory program, particularly design and construction 

of a permanent cover for closed disposal trenches is dependent on administrative and technical 

decisions of another State agency, the Washington Department of Ecology (Ecology). This 

agency holds the long-term lease with the federal government and it is the State agency 

responsible for regulation of non-radioactive, hazardous constituents in disposed waste. Its 

authority derives in part from the State’s Model Toxics Control Act. Over a decade ago, Ecology 

asserted its interest in conducting site investigations, particularly in the unsaturated zone 

beneath old, closed disposal units in order to ascertain the presence and characteristics of 

substances that are under Ecology’s, not Department of Health, regulatory purview. Ecology’s 

continuing investigations have significantly impacted the Department regarding the timing for 

implementation of a permanent disposal unit cover; the cover design; and the availability of 

funds for such implementation. 

Based on the above, the review team suggested that the MRB consider the feasibility and 

appropriateness of inclusion of aspects of the Ecology program that are related to the regulatory 

oversight of the Hanford LLRW facility be considered for inclusion in the next IMPEP review. 

The MRB directed NRC staff to research this issue and inform them and the State of the 

resolution. 

4.3.1 Technical Staffing and Training

The Waste Section currently has nine full-time and part-time technical, managerial, and 

administrative staff members, with a total staffing level of 5.2 FTE devoted to the LLRW 

program. The LLRW program is also supported by the Environmental Monitoring and 

Assessment Section, the Emergency Preparedness Section, and the Air Emissions Section. 

The staff that currently supports the LLRW program includes the Waste Section Supervisor, an 

administrative assistant, and staff members with diversified backgrounds in health physics, 
Washington Final Report Page 14 

engineering, and earth sciences. During the review period, the staff was relatively stable; 

therefore, the Waste Section was able to maintain a high level of technical competency. Since 

the 2003 IMPEP review, one staff member associated with the LLRW program left the Waste 

Section and has been reassigned to support other activities within the Office. She was replaced 

with an individual qualified in health physics and environmental engineering. The review team 

determined that, at the time of the review, the Waste Section’s staffing level was adequate to 

maintain the quality and performance of the LLRW program. 

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

perform licensing, inspection, and investigations of LLRW activities. The Waste Section has an 

established procedure for staff training consistent with the NRC/OAS Training Working Group 

Recommendations and IMC 1246. The Waste Section Supervisor indicated that they are in the 

process of reviewing and updating procedures, including the training procedure. 

The review team determined that, for the most part, Waste Section staff members completed 

the required training and recommended training courses in accordance with Office requirements 

and consistent with IMC 1246. In a number of cases, training files were supplemented with a 

supervisory memo specifying the exact duties for which a staff member was qualified, but 

training records for several individuals were not complete. Based on interviews with the 

technical and administrative staff and an examination of staff qualifications, duties, and 

functions, the review team concluded that the Waste Section staff was highly qualified, with 

sufficient training, to carry out their regulatory duties. Office managers, after discussion with 

review team members, stated that they would update contents of several training forms in 

accordance with State procedures and supplement training files with summaries of education 

and experience provided by individuals, in an effort to improve training records. Subsequent to 

the review, the Waste Section Supervisor reported that the updated training records were 

placed in the files. 

4.3.2 Status of Low-level Radioactive Waste Disposal Inspection

The disposal site is inspected annually, consistent with IMC 2800. Annual inspections are 

completed over the course of the year using partial inspections, with each partial inspection 

focusing on a different area. In addition to the annual inspections, the Waste Section on-site 

representative performs monthly inspections of the site and confirms licensee inspections in 

accordance with the requirements of the facility license. The review team confirmed the 

frequency of inspections through an analysis of inspection report files and interviews with the 

inspectors. The Waste Section Supervisor and inspection staff use a spreadsheet to track the 

status of inspections. This spreadsheet lists the portion of the annual inspection, the date of last 

inspection, and the inspector assigned to each portion of the annual inspection. A copy of this 

spreadsheet was placed in the annual inspection files for Calendar Years 2005, 2006, 2007, 

and 2008. 

The review team determined that inspection findings are communicated to the licensee in a 

timely manner. The Waste Section issues inspection findings to the licensee using a form 

similar to NRC’s Form 591, which is typically issued on site upon completion of an inspection or 

included in a notice of correction letter issued within 30 days of the inspection. 
Washington Final Report Page 15 

4.3.3 Technical Quality of Inspections

The Waste Section’s inspection procedures detail the frequency of inspections, inspection 

preparation requirements, inspection reporting requirements, and a checklist of licensing 

requirements. The procedures also include appropriate forms and sample letters for 

documenting findings. 

The review team determined that the Waste Section monthly and annual inspections were 

thorough, technically accurate, complete, consistent, and of high quality with sufficient 

documentation to ensure that the licensee’s performance with respect to protecting health and 

safety was acceptable. A review of the completed inspection reports revealed that inspection 

records are reviewed promptly by the Waste Section Supervisor. The review team found that 

followup inspections addressed previously identified open items and past violations. An annual 

summary is provided in each file identifying open items for the year and whether or not they 

were closed. The files contain the inspection checklist, field notes, notices to the licensee, and 

some digital photographs of the site. On-site files include information on waste generators, 

weekly summary of shipments, fence-line surveys performed by the inspectors, and waste 

container inspections. The review team also determined that supervisory accompaniments of 

each inspector were completed annually and documented. 

On April 16-17, 2008, a review team member accompanied two Waste Management Section 

inspectors at USE’s facility as indicated in Appendix C. The inspectors were well prepared and 

thorough in their review of the aspects of the licensee's radiation safety program included in the 

current module (site security, external dosimetry, radiological surveys, vehicle surveys, posting, 

interviews and follow-up). They conducted proper entrance and exit interviews with licensee 

management and safety staff. They covered the scope of the current inspection, discussed the 

status of previous identified items of noncompliance and clearly articulated any current 

noncompliances. Inspectors conducted interviews with non-supervisory site personnel during 

the course of the inspection to ascertain perspective on licensee commitment to safety and 

training. During the accompaniments, the inspectors demonstrated appropriate performancebased inspection techniques and knowledge of the regulations. The inspections were adequate 

to assess radiological health and safety at the licensed facility. 

4.3.4 Technical Quality of Licensing Actions

Since the 2003 IMPEP review, several factors impacted the licensing program for LLRW 

disposal. These included the completion of an Environmental Impact Statement (EIS) related to 

key decisions at the disposal facility; license renewal; implementation of new security 

requirements; investigation of ground contaminants, pursuant to the State Model Toxics Control 

Act; and expansion of the definition of byproduct material, pursuant to the Energy Policy Act of 

2005. 

The USE license establishes regulatory conditions and procedures that the licensee must 

comply with regarding waste acceptance, site operation, and environmental monitoring. The 

license also contains conditions for the eventual closure and decommissioning of the LLRW 

site. The USE license was in timely renewal since January 1997 until it was renewed in October 

2005 to accommodate information and enhancements discussed in the final EIS, initiated under 

the provisions of the State Environmental Policy Act, for the LLRW facility. These include 
Washington Final Report Page 16 

considerations for design, implementation and funding of a final site cover as well as technical 

justification for quantities of diffuse waste. The Department and the Department of Ecology 

jointly prepared the EIS. The EIS provided a summary of the bases for regulatory decisions 

regarding relicensing, allowable amounts of diffuse waste, and a permanent disposal unit cover. 

It also included a provision for site investigation that addressed the Department of Ecology’s 

concerns regarding hazardous, non-radioactive constituents. 

The review team examined the final EIS, environmental monitoring data, and technical 

evaluations in support of licensing decisions and interviewed most of the staff involved in the 

preparation of these documents. The review team found that these documents were thorough, 

complete, consistent, and of acceptable technical quality. 

The review team evaluated the four license amendments to the USE license that the Waste 

Section issued during the review period, as indicated in Appendix D. These amendments 

involved revisions to the facility standards manual, changes in monitoring frequency, and 

implementation of new security requirements. The review team also analyzed the basis for 

classification of radium-226, because discrete sources of radium-226 are now part of NRC’s 

regulatory authority. The review team found that the licensing actions were thorough, complete, 

consistent, and of high quality, with health, safety, and security issues properly addressed. 

4.3.5 Technical Quality of Incident and Allegation Activities

The review team found that the Waste Section has procedures in place for handling incidents 

and allegations. The procedures for handling incidents include information on what constitutes 

an incident, appropriate documentation of an incident, reference to NRC abnormal occurrence 

criteria for States, and tracking of incident by management. The procedures for handling 

allegations include information on protecting the identity of the alleger, documentation of the 

allegation, and tracking the allegation by management. During the review period, the Waste 

Section received no reports of incidents or allegations pertaining to the LLRW disposal program. 

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

that Washington’s performance with respect to the indicator, Low-Level Radioactive Waste 

Disposal Program, was satisfactory. 

4.4 Uranium Recovery Program 

In reviewing this indicator, the review team used five subelements to evaluate the Waste 

Section’s performance regarding the uranium recovery program. These subelements were: 

(1) Technical Staffing and Training, (2) Status of Uranium Recovery Inspection Program, 

(3) Technical Quality of Inspections, (4) Technical Quality of Licensing Actions, and 

(5) Technical Quality of Incident and Allegation Activities. 

At the time of the review, the Waste Section had one licensed conventional mill site, Dawn 

Mining Company (Dawn). This site was placed in shutdown and initiated reclamation and 

decommissioning activities in 2001. 
Washington Final Report Page 17 

4.4.1 Technical Staffing and Training 

Since the last IMPEP review, the uranium recovery program lost one half-time staff member and 

gained one full-time staff member, with a total staffing level of 1.7 FTE devoted to the uranium 

recovery program. The uranium recovery staff has a wide range of technical expertise 

including: materials licensing, inspection, civil engineering, geology, groundwater hydrology, 

geochemistry, and environmental science. Several members of the uranium recovery staff 

participated in inspections of the Dawn site during the review period. The review team 

determined that the Waste Section’s staffing level is adequate to maintain the quality and 

performance of the uranium recovery program. 

Interviews with uranium recovery staff members and reviews of training and qualification 

records revealed that the uranium recovery staff is experienced, technically competent, and has 

a good understanding of regulatory processes and requirements. The uranium recovery staff 

has the health physics and hydrology expertise necessary to adequately regulate the 

reclamation activities at the Dawn site. 

Although the review team was satisfied that uranium recovery staff had the necessary 

experience and expertise to effectively regulate Dawn reclamation activities, documentation of 

training and qualification of uranium recovery staff members was not up to date for all program 

staff. Office managers committed to appropriately updating the training records of uranium 

recovery staff. Subsequent to the review, the Waste Section Supervisor reported that the 

training records, including summaries of education and experience, were placed in the files. 

4.4.2 Status of Uranium Recovery Inspection Program 

During the review period, the Office conducted annual inspections at the Dawn site, which 

covered all aspects of the uranium recovery program including: site security, personnel dose 

monitoring, internal audits, training, radiological controls and surveys, operations, environmental 

monitoring, instrumentation, site posting, and respiratory protection. 

In addition to the comprehensive annual inspections, uranium recovery staff members 

conducted numerous inspections of significant activities at the Dawn site. During significant 

activities, uranium recovery staff conducted weekly inspections and collected water samples for 

analysis. 

Based on the evaluation of inspection files, the review team determined that the Waste 

Section’s inspection frequency exceeded the requirements of IMC 2801, “Uranium Mill and 

11e.(2) Byproduct Material Disposal Site and Facility Inspection Program.” The review team 

concluded that there were no overdue inspections. 

The review team determined that inspection reports were issued within 30 days of inspections. 

The Waste Section Supervisor promptly reviewed all inspection reports. Appropriate followup 

actions were conducted when items of noncompliance were identified. Inspection casework 

files were easily retrieved and accessible. 
Washington Final Report Page 18 

4.4.3 Technical Quality of Inspections

The review team noted that the Waste Section’s inspection program and procedures were 

consistent with NRC Inspection Procedure 87654, “Uranium Mill, In-Situ Leach Uranium 

Recovery, 11e.(2) Byproduct Material Disposal Site Decommissioning Inspection.” Inspectors 

typically and appropriately observed licensee operations and made independent measurements 

during inspections, as appropriate. Inspectors used relevant procedures with checklists, 

previous inspection reports, and other background information for implementing their 

inspections. Annual comprehensive inspections covered all appropriate functional areas. The 

review team found that the inspection reports provided appropriate depth of coverage, 

addressed license conditions and the regulations, and demonstrated that the inspectors 

pursued corrective actions for items of noncompliance that were identified. 

During the review period, the uranium recovery inspectors were accompanied by their 

supervisor annually. These accompaniments were adequately documented. The review team 

found that the Waste Section Supervisor routinely met with the uranium recovery inspectors to 

review inspection findings and to plan follow-up strategy regarding corrective actions. 

On April 15, 2008, a review team member accompanied two Waste Section inspectors at the 

Dawn facility, as indicated in Appendix C. The inspectors were well prepared and thorough in 

their review of the aspects of the licensee's radiation safety program. They conducted proper 

entrance and exit interviews with licensee management and safety staff. 

Inspectors conducted interviews with non-supervisory site personnel during the course of the 

inspection to ascertain perspective on licensee commitment to safety and training. During the 

accompaniments, the inspectors demonstrated appropriate performance-based inspection 

techniques and knowledge of the regulations. The inspections were adequate to assess 

radiological health and safety at the licensed facilities. 

4.4.4 Technical Quality of Licensing Actions

During the review period, the uranium recovery staff processed one licensing action in 2007 for 

the renewal of Dawn’s license. 
Washington Final Report Page 19 

The review team evaluated documentation associated with the review of Dawn’s renewal 

application and the issuance of the renewal including several deficiency letters and the 

amended license. The review team determined that the license amendment application was 

adequately evaluated, processed, and documented. 

The review team noted that Dawn is required to submit the following annual reports: ALARA 

(acronym for “as low as is reasonable achievable”) Audit Report, Environmental Monitoring 

Report, Facility Utilization Report, Closure Cost Estimate, and Integrated Project Schedule. The 

review team determined that the Waste Section staff adequately reviewed the incoming reports. 

4.4.5 Technical Quality of Incident and Allegation Activities

The review team found that the Waste Section has appropriate procedures in place for handling 

incidents and allegations. 

During the review period, uranium recovery staff members responded to one incident in the 

uranium recovery area. The review team determined that the Office’s response to the incident 

was thorough, complete, and comprehensive. There were no allegations reported for the 

Washington uranium recovery program during the review period. 

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

that Washington’s performance with respect to the indicator, Uranium Recovery Program, was 

satisfactory. 

5.0 SUMMARY 

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

performance indicators. The review team made no recommendations in regard to program 

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

team recommended, and the MRB agreed, that the Washington Agreement State Program was 

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

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

the next full IMPEP review take place in approximately 4 years. 

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

The State transmits copies of medical licenses they have amended within a calendar 

quarter to each of their nuclear pharmacy licensees. This enables the pharmacy to 

cross-reference with the “hard copy” they maintain on file. The State’s nuclear 

pharmacy licensees support this practice, as it allows them to have a current copy of 

their clients’ licenses. (Section 3.4)
LIST OF APPENDIXES AND ATTACHMENT 

Appendix A IMPEP Review Team Members 

Appendix B Washington Organization Charts 

Appendix C Inspection Casework Reviews 

Appendix D License Casework Reviews 

Appendix E Incident Casework Reviews 

Appendix F Sealed Source & Device Casework Reviews 

Attachment June 27, 2008, Letter from Mary C. Selecky 

Washington’s Response to Draft IMPEP Report 
APPENDIX A 

IMPEP REVIEW TEAM MEMBERS 

Name Area of Responsibility

James Lynch, Region III Team Leader 

 Technical Staffing and Training 

William Rautzen, FSME Status of Materials Inspection Program 

 Compatibility Requirements 

Randy Erickson, Region IV Technical Quality of Inspections 

 Technical Quality of Incident and Allegation 

 Activities 

 Inspector Accompaniments 

J. Marion Eaddy, III, North Carolina Technical Quality of Licensing Actions 

 Sealed Source and Device Evaluation Program 

James Shaffner, FSME Low-level Radioactive Waste Disposal Program 

 Inspector Accompaniments 

John Buckley, FSME Uranium Recovery Program
APPENDIX B 

WASHINGTON ORGANIZATION CHARTS 

ADAMS ACCESSION NO.: ML082070058 
APPENDIX C 

INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: University of Washington License No.: WN-C001-1 

Inspection Type: Special, Announced Priority: 3 

Inspection Date: 10/27/06 Inspector: AG 

File No.: 2 

Licensee: University of Washington License No.: WN-C001-1 

Inspection Type: Followup, Unannounced Priority: 3 

Inspection Date: 6/8/06 Inspectors: AG, JS 

Comment: Inspection letter was sent 53 days after the inspection. 

File No.: 3 

Licensee: Pacific Health Physics License No.: WN-L0167-1 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 2/7/07 Inspectors: AG, JS 

File No.: 4 

Licensee: IsoRay, Inc. License No.: WN-L0213-1 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 11/1/07 Inspector: AG 

File No.: 5 

Licensee: IsoRay, Inc. License No.: WN-L0213-1 

Inspection Type: Termination, Announced Priority: 5 

Inspection Date: 11/2/07 Inspector: AG 

File No.: 6 

Licensee: Battelle Memorial Institute License No.: WN-L027-1 

Inspection Type: Routine, Announced Priority: 3 

Inspection Dates: 6/14/06 Inspectors: AG, JS 

File No.: 7 

Licensee: Swedish Medical Center License No.: WN-M008-1 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 3/16/06 Inspector: CD 

File No.: 8 

Licensee: Puget Sound Radiosurgery License No.: WN-M0268-1 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 4/16/08 Inspector: CD 
Washington Final Report Page C.2 

Inspection Casework Reviews

File No.: 9 

Licensee: Edge Testing and Inspection License No.: WN-IR062-1 

Inspection Type: Special, Announced Priority: 1 

Inspection Date: 7/20/06 Inspector: CL 

File No.: 10 

Licensee: Edge Testing and Inspection License No.: WN-IR062-1 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 7/20/06 Inspector: PW 

File No.: 11 

Licensee: Cardinal Health Spokane License No.: WN-NP004-1 

Inspection Type: Field, Unannounced Priority: 2 

Inspection Dates: 10/3/07 Inspector: VD 

File No.: 12 

Licensee: Cardiology Associates License No.: WN-M0215-1 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 1/9/08 Inspector: JK 

File No.: 13 

Licensee: Rainland Farm Equine Clinic License No.: WN-M0285-1 

Inspection Type: Initial, Announced Priority: 5 

Inspection Date: 4/2/08 Inspector: JS 

File No.: 14 

Licensee: Vancouver Clinic PET/CT License No.: WN-M0278-1 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 3/24/08 Inspector: SM 

File No.: 15 

Licensee: Phoenix Central Lab for Pets License No.: WN-L0210-1 

Inspection Type: Initial, Announced Priority: 5 

Inspection Dates: 8/5/04 Inspector: PW 

File No.: 16 

Licensee: PND Engineers License No.: WN-I0553-1 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 9/7/05 Inspectors: WL, AG 

File No.: 17 

Licensee: Seattle Cancer Care Alliance License No.: WN-M0225-1 

Inspection Type: Termination, Announced Priority: 3 

Inspection Date: 11/4/03 Inspector: PW 
Washington Final Report Page C.3 

Inspection Casework Reviews

File No.: 18 

Licensee: Atlas Casting & Technology License No.: WN-IR006-1 

Inspection Type: Routine/Special, Announced Priority: 2 

Inspection Date: 11/20/07 Inspector: SM 

File No.: 19 

Licensee: Infectious Disease Research Institute License No.: WN-L0222-1 

Inspection Type: Initial, Announced Priority: 5 

Inspection Dates: 11/16/06 Inspector: JS 

File No.: 20 

Licensee: Infectious Disease Research Institute License No.: WN-L0222-1 

Inspection Type: Followup, Announced Priority: 5 

Inspection Dates: 12/15/06 Inspector: JS 

File No.: 21 

Licensee: Whitman College License No.: WN-C010-1 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 6/20/07 Inspector: VD 

File No.: 22 

Licensee: KeyMaster Technologies, Inc. License No.: WN-I0282-1 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 10/24/07 Inspector: CL 

File No.: 23 

Licensee: Kennewick General Hospital License No.: WN-M0178-1 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 10/21/03 Inspector: CD 

File No.: 24 

Licensee: Providence St. Peter Hospital License No.: WN-M085-1 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 9/21/07 Inspector: JK 

File No.: 25 

Licensee: Oregon Washington Laboratories License No.: WN-IR070-1 

Inspection Type: Special, Unannounced Priority: 1 

Inspection Date: 12/8/06 Inspector: CL 

File No.: 26 

Licensee: ISOSCAN, LLC License No.: WN-M0257-1 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 2/19/08 Inspector: VD 
Washington Final Report Page C.4 

Inspection Casework Reviews

File No.: 27 

Licensee: VLST Corporation License No.: WN-L0224-1 

Inspection Type: Routine/Special, Announced Priority: 3 

Inspection Date: 4/17/08 Inspector: AG 

File No.: 28 

Licensee: The Doctor’s Clinic License No.: WN-M0254-1 

Inspection Type: Routine, Announced Priority: 3 

Inspection Date: 4/15/08 Inspector: VD 

File No.: 29 

Licensee: Puyallup Ambulatory Surgery Center License No.: WN-L0275-1 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 4/14/08 Inspector: JK 

File No.: 30 

Licensee: Thermo Electron Corporation License No.: RECIP-046 

Inspection Type: Reciprocity, Unannounced Priority: 5 

Inspection Date: 5/26/06 Inspector: VD 

File No.: 31 

Licensee: Voith Fabrics License No.: RECIP-060 

Inspection Type: Reciprocity, Unannounced Priority: 5 

Inspection Date: 10/26/05 Inspector: SM 

File No.: 32 

Licensee: J.L. Shepherd & Associates License No.: RECIP-027 

Inspection Type: Reciprocity/Special, Announced Priority: 5 

Inspection Date: 7/6/07 Inspector: VD 

File No.: 33 

Licensee: Alpha Omega Services, Inc. License No.: RECIP-046 

Inspection Type: Reciprocity/Special, Announced Priority: 5 

Inspection Dates: 12/4-5/07 Inspector: VD 

File No.: 34 

Licensee: Thermo Electron Corporation License No.: RECIP-010 

Inspection Type: Reciprocity, Unannounced Priority: 3 

Inspection Date: 9/16/04 Inspector: VD 

File No.: 35 

Licensee: US Ecology, Inc. License No.: WN-I019-2 

Inspection Type: Routine, Announced Priority: Monthly 

Inspection Date: 1/18/07 Inspector: SM 
Washington Final Report Page C.5 

Inspection Casework Reviews

File No.: 36 

Licensee: US Ecology, Inc. License No.: WN-I019-2 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 6/21/07 Inspectors: ME, SM, KS 

File No.: 37 

Licensee: US Ecology, Inc. License No.: WN-I019-2 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 10/25/07 Inspectors: KS, SM, ME 

File No.: 38 

Licensee: Perma-Fix NW License No.: WN-I0393-1 

Inspection Type: Routine, Announced Priority: 1 

Inspection Dates: Various Inspectors: KS, ME, SM 

File No.: 39 

Licensee: Dawn Mining Company License No.: WN-1043-2 

Inspection Type: Routine, Announced Priority: 1 

Inspection Dates: Various Inspectors: DS, ME, KS, DT 

File No.: 40 

Licensee: Dawn Mining Company License No.: WN-1043-2 

Inspection Type: Special, Announced Priority: 1 

Inspection Dates: Various Inspector: DS 

INSPECTOR ACCOMPANIMENTS 

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

Accompaniment No.: 1 

Licensee: Puyallup Ambulatory Surgery Center License No.: WN-M0275-1 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 4/14/08 Inspector: JK 

Accompaniment No.: 2 

Licensee: The Doctor’s Clinic License No.: WN-M0254-1 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 4/15/08 Inspector: VD 

Accompaniment No.: 3 

Licensee: Puget Sound Radiosurgery, LLC License No.: WN-M0268-1 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 4/16/08 Inspector: CD 
Washington Final Report Page C.6 

Inspection Casework Reviews

Accompaniment No.: 4 

Licensee: VLST Corporation License No.: WN-L0224-1 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 4/17/08 Inspector: AG 

Accompaniment No.: 5 

Licensee: Dawn Mining Company License No.: WN-I043-2 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 4/15/08 Inspectors: DS, JR 

Accompaniment No.: 6 

Licensee: US Ecology, Inc. License No.: WN-I019-2 

Inspection Type: Routine, Announced Priority: 1 

Inspection Dates: 4/16-17/08 Inspectors: KS, SM 
APPENDIX D 

LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: IsoRay, Inc. License No.: WN-L0213-1 

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

Date Issued: 7/19/04 License Reviewer: AG 

File No.: 2 

Licensee: Puget Sound Radiosurgery License No.: WN-M0268-1 

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

Date Issued: 6/24/05 License Reviewer: CD 

File No.: 3 

Licensee: Troxler Electronic Laboratories License No.: WN-I0466-1 

Type of Action: Renewal Amendment No.: 4 

Date Issued: 4/11/07 License Reviewer: PK 

File No.: 4 

Licensee: Geotech Consultants, Inc. License No.: WN-I0278-1 

Type of Action: Renewal Amendment No.: 9 

Date Issued: 5/24/06 License Reviewer: KS 

File No.: 5 

Licensee: PetNet Solutions, Inc. - Kent License No.: WN-NP009-1 

Type of Action: Renewal Amendment No.: 10 

Date Issued: 10/24/06 License Reviewer: KS 

File No.: 6 

Licensee: Cardinal Health 412, Inc. License No.: WN-NP010-1 

Type of Action: Termination Amendment No.: 3 

Date Issued: 10/24/03 License Reviewer: PW 

Comment: 

 Primary reviewer was not qualified to perform nuclear pharmacy reviews. Program 

Manager indicated that this amendment was for training. 

File No.: 7 

Licensee: deCODE biostructures License No.: WN-L0201-1 

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

Date Issued: In process License Reviewer: AG 
Washington Final Report Page D.2 

License Casework Reviews

File No.: 8 

Licensee: Washington State University License No.: WN-C003-1 

Type of Action: Amendment Amendment No.: 70 

Date Issued: 11/27/07 License Reviewer: AG 

File No.: 9 

Licensee: Advanced Inspection Technologies, Inc. License No.: WN-IR071-1 

Type of Action: Amendment Amendment No.: 2 

Date Issued: 3/5/08 License Reviewer: CL 

Comment: 

 License authorized possession of a source in excess of license guidance which limits 

quantities without specific topic areas being addressed. Justification was not clearly 

documented in renewal application. Interview with license reviewer and Program 

Manager indicated that the variance had been evaluated prior to approval. 

File No.: 10 

Licensee: U2 Technology, Inc. License No.: WN-IR069-1 

Type of Action: Termination Amendment No.: 3 

Date Issued: 4/19/07 License Reviewer: CL 

File No.: 11 

Licensee: Caliber Inspections License No.: WN-IR001-1 

Type of Action: Renewal Amendment No.: 36 

Date Issued: 9/25/06 License Reviewer: SM 

File No.: 12 

Licensee: Alliance Imaging, Inc. License No.: WN-M0222-1 

Type of Action: Amendment Amendment No.: 22 

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

File No.: 13 

Licensee: Medi-Physics d/b/a GE Healthcare License No.: WN-NP002-1 

Type of Action: Routine Amendment No.: 30 

Date Issued: 9/17/07 License Reviewer: CD 

File No.: 14 

Licensee: The Boeing Company License No.: WN-I005-1 

Type of Action: Renewal Amendment No.: 66 

Date Issued: Pending License Reviewer: CL 

File No.: 15 

Licensee: ICOS Corporation License No.: WN-L0142-1 

Type of Action: Amendment Amendment No.: 18 

Date Issued: 6/27/06 License Reviewer: VD 
Washington Final Report Page D.3 

License Casework Reviews

File No.: 16 

Licensee: Molecular Imaging Corporation License No.: WN-M0228-1 

Type of Action: Termination Amendment No.: 6 

Date Issued: 8/9/06 License Reviewer: VD 

File No.: 17 

Licensee: Northwest Hospital Gamma Knife License No.: WN-M0201-1 

Type of Action: Amendment Amendment No.: 15 

Date Issued: 1/31/08 License Reviewer: VD 

File No.: 18 

Licensee: Rainland Farm Equine Clinic License No.: WN-M0255-1 

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

Date Issued: 4/4/07 License Reviewer: JS 

File No.: 19 

Licensee: Evergreen State College License No.: WN-C019-1 

Type of Action: Amendment Amendment No.: 17 

Date Issued: 6/2/04 License Reviewer: AG 

File No.: 20 

Licensee: Inland Cardiology Associates License No.: WN-M0167-1 

Type of Action: Amendment Amendment No.: 22 

Date Issued: 9/26/06 License Reviewer: JS 

File No.: 21 

Licensee: Whidbey General Hospital License No.: WN-M0217-1 

Type of Action: Amendment Amendment No.: 8 

Date Issued: 1/4/08 License Reviewer: JK 

File No.: 22 

Licensee: Yakima Heart Center License No.: WN-M0244-1 

Type of Action: Renewal Amendment No.: 4 

Date Issued: 1/7/08 License Reviewer: JK 

File No.: 23 

Licensee: Klickitat County Public Works License No.: WN-I0569-1 

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

Date Issued: 9/28/06 License Reviewer: PW 

File No.: 24 

Licensee: Wormer and Associates License No.: WN-I0534-1 

Type of Action: Termination Amendment No.: 2 

Date Issued: 6/27/06 License Reviewer: PW 
Washington Final Report Page D.4 

License Casework Reviews

File No.: 25 

Licensee: James A. Sewell & Associates License No.: WN-I0385-1 

Type of Action: Renewal Amendment No.: 7 

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

File No.: 26 

Licensee: Three Rivers Regional Wastewater Plant License No.: WN-I0104-1 

Type of Action: Termination Amendment No.: 9 

Date Issued: 3/27/08 License Reviewer: SM 

File No.: 27 

Licensee: Solomon Park Research Institute License No.: WN-L0199-1 

Type of Action: Renewal Amendment No.: 2 

Date Issued: 12/12/06 License Reviewer: SM 

File No.: 28 

Licensee: Northwest Technical Services License No.: WN-I0570-1 

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

Date Issued: 12/2/06 License Reviewer: SM 

File No.: 29 

Licensee: Perma-Fix NW License No.: WN-I0393-1 

Type of Action: Amendment Amendment No.: 22 

Date Issued: 11/30/05 License Reviewer: KS 

File No.: 30 

Licensee: Perma-Fix NW License No.: WN-I0508-1 

Type of Action: Amendment Amendment No.: 24 

Date Issued: 1/16/08 License Reviewer: KS 

File No.: 31 

Licensee: US Ecology, Inc. License No.: WN-I019-2 

Type of Action: Amendment Amendment No.: 31 

Date Issued: 10/20/05 License Reviewers: Various 

File No.: 32 

Licensee: US Ecology, Inc. License No.: WN-I019-2 

Type of Action: Amendment Amendment No.: 34 

Date Issued: 6/7/07 License Reviewers: KS, AT 

File No.: 33 

Licensee: US Ecology, Inc. License No.: WN-I019-2 

Type of Action: Amendment Amendment No.: 35 

Date Issued: 12/27/07 License Reviewer: KS 
Washington Final Report Page D.5 

License Casework Reviews

File No.: 34 

Licensee: Dawn Mining Company License No.: WN-I043-2 

Type of Action: Renewal Amendment No.: 24 

Date Issued: 1/18/07 License Reviewers: Various 
APPENDIX E 

INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: Swedish Medical Center License No.: WN-M008-1 

Date of Incident: 11/17/03 NMED Log No.: 030933 

Investigation Date: 11/18/03 Type of Incident: Overexposure 

 Type of Investigation: Telephone 

File No.: 2 

Licensee: Northwest Inspection License No.: WN-IR065-01 

Date of Incident: 7/25/04 NMED Log No.: 040552 

Investigation Date: 7/26/04 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Telephone 

File No.: 3 

Licensee: Cardinal Health License No.: WN-NP005-1 

Date of Incident: 8/15/05 NMED Log No.: 050617 

Investigation Date: 8/19/05 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Telephone/Site Visit 

File No.: 4 

Licensee: Earth Consultants License No.: WN-L061-1 

Date of Incident: 11/19/05 NMED Log No.: 050773 

Investigation Date: 11/19/05 Type of Incident: Damaged Equipment 

 Type of Investigation: Telephone/Site Visit 

File No.: 5 

Licensee: Fort James Operating Company License No.: WN-I0228-1 

Date of Incident: 5/5/06 NMED Log No.: 060409 

Investigation Date: 5/23/06 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Telephone 

File No.: 6 

Licensee: Auburn Regional Medical Center License No.: WN-M0149-1 

Date of Incident: 5/30/06 NMED Log No.: 060380 

Investigation Date: 6/5/06 Type of Incident: Contamination Event 

 Type of Investigation: Telephone 

File No.: 7 

Licensee: Sacred Heart Medical Center License No.: WN-M031-1 

Date of Incident: 10/8/03 NMED Log No.: 030807 

Investigation Date: 10/8/03 Type of Incident: Release of RAM 

 Type of Investigation: Telephone 
Washington Final Report Page E.2 

Incident Casework Reviews

File No.: 8 

Licensee: Virginia Mason Medical Center License No.: WN-M048-1 

Date of Incident: 11/29/06 NMED Log No.: 060744 

Investigation Date: 12/5/06 Type of Incident: Release of RAM 

 Type of Investigation: Telephone 

File No.: 9 

Licensee: Zipper Zeman Associates License No.: WN-I0507-1 

Date of Incident: 4/13/05 NMED Log No.: 050268 

Investigation Date: 4/13/05 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Telephone 

File No.: 10 

Licensee: Acuren Inspection License No.: WN-IR067-1 

Date of Incident: 6/30/05 NMED Log No.: 050511 

Investigation Date: 7/29/05 Type of Incident: Overexposure 

 Type of Investigation: Telephone 

File No.: 11 

Licensee: UW Harborview Gamma Knife License No.: WN-M0219-1 

Date of Incident: 11/16/06 NMED Log No.: 060716 

Investigation Date: 11/22/06 Type of Incident: Overexposure 

 Type of Investigation: Telephone 

File No.: 12 

Licensee: IsoRay, Inc. License No.: WN-L0213-1 

Date of Incident: 10/4/06 NMED Log No.: 060630 

Investigation Date: 10/4/06 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Telephone/Site Visit 

File No.: 13 

Licensee: Washington DOT Spokane License No.: WN-L035-1 

Date of Incident: 9/28/07 NMED Log No.: 070608 

Investigation Dates: 10/2/07 Type of Incident: Damaged Equipment 

 Type of Investigation: Telephone/Site Visit 

File No.: 14 

Licensee: Siemens Medical Solutions License No.: WN-L030-1 

Date of Incident: 10/21/04 NMED Log No.: 040765 

Investigation Date: 10/21/04 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Telephone 

File No.: 15 

Licensee: PLSA Engineering License No.: WN-I0143-1 

Date of Incident: 8/8/04 NMED Log No.: 040564 

Investigation Date: 8/9/04 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Telephone/Site Visit 
APPENDIX F 

SEALED SOURCE & DEVICE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Registry No.: WA-1220-S-101-S SS&D Type: (AA) Manual Brachytherapy 

Applicant Name: IsoRay, Inc. Type of Action: New 

Date Issued: 9/17/04 Reviewers: CD, AG 

File No.: 2 

Registry No.: WA-1032-D-102-S SS&D Type: (B) Medical Radiography Imaging 

Applicant Name: GE Healthcare Type of Action: Amendment 

Date Issued: 10/31/04 Reviewers: CD, AS 

Comment: 

 Registration sheet issued by Washington on behalf of a NARM distributor in Wisconsin. 
ATTACHMENT 

June 27, 2008, Letter from Mary C. Selecky 

Washington’s Response to Draft IMPEP Report 

ADAMS Accession No.: ML081840314