September 28, 2007 

 

Mr. Rick Sprott, Executive Director 

Department of Environmental Quality 

168 North 1950 West 

P.O. Box 144810 

Salt Lake City, UT 84114-4810 

Dear Mr. Sprott: 

On September 6, 2007, the Management Review Board (MRB) met to consider the proposed 

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

Agreement State Program. The MRB found the Utah 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 20, of the enclosed final report contains a summary of the IMPEP review 

team=s findings and recommendations. A letter dated August 2, 2007, from Dane Finerfrock, 

Director of the Division of Radiation Control, adequately discusses the State=s action plan for 

resolving the recommendations in the report. No further response is requested at this time. 

At the MRB=s request, a followup IMPEP review focusing on the State=s incident response and 

uranium recovery programs will take place in approximately 1 year. During the followup review, 

the State=s actions in response to the recommendations will be evaluated. As part of the 

followup review, the team will also conduct a periodic meeting to gauge the overall status of the 

Agreement State Program. 

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: Utah Final IMPEP Report 

cc: Dane Finerfrock, Director 

Utah Division of Radiation Control 

Jared Thompson, Arkansas 

Organization of Agreement States 

 Liaison to the MRB 
September 28, 2007 

Mr. Rick Sprott, Executive Director 

Department of Environmental Quality 

168 North 1950 West 

P.O. Box 144810 

Salt Lake City, UT 84114-4810 

Dear Mr. Sprott: 

On September 6, 2007, the Management Review Board (MRB) met to consider the proposed 

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

Agreement State Program. The MRB found the Utah 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 20, of the enclosed final report contains a summary of the IMPEP review 

team=s findings and recommendations. A letter dated August 2, 2007, from Dane Finerfrock, 

Director of the Division of Radiation Control, adequately discusses the State=s action plan for 

resolving the recommendations in the report. No further response is requested at this time. 

At the MRB=s request, a followup IMPEP review focusing on the State=s incident response and 

uranium recovery programs will take place in approximately 1 year. During the followup review, 

the State=s actions in response to the recommendations will be evaluated. As part of the 

followup review, the team will also conduct a periodic meeting to gauge the overall status of the 

Agreement State Program. 

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: Utah Final IMPEP Report 

cc: Dane Finerfrock, Director 

Utah Division of Radiation Control 

Jared Thompson, Arkansas 

Organization of Agreement States 

 Liaison to the MRB 

Distribution: See next page. ML072560279

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

NAME ATMcCraw:kk ADWhite JRSchlueter CPoland 

DATE 09/13/07 09/13/07 09/13/07 09/18/07 

OFFICE FSME DEDMRT 

NAME CLMiller (SReynolds for) MJVirgilio 

DATE 09/19/07 09/28/07 

OFFICIAL RECORD COPY
LETTER TO R. SPROTT FROM M. J. VIRGILIO DATED: September 28, 2007 

SUBJECT: UTAH FINAL IMPEP REPORT 

DISTRIBUTION: EDATS: FSME-2007-0030 DCD (SP01) 

DMSSA RF 

EDO RF 

RidsFsmeOd 

KLukes, FSME/DMSSA Chairman Klein 

JLynch, RIII Commissioner Jaczko 

LMcLean, RIV/RSAO Commissioner Lyons 

PMichalak, FSME/DWMEP SECY 

JCook, RIV 

EFordham, WA 

GJohns, MN 

LTrocine, OEDO 

APowell, OCA (2 copies) 

KCyr, OGC 

FCameron, OGC 

JSchlueter, FSME/DMSSA 

RLewis, FSME/DMSSA 

Duncan White, FSME/DMSSA 

DSollenberger, FSME/DMSSA 

WRautzen, FSME/DMSSA 

MSatorius, RIII 
 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

 REVIEW OF UTAH AGREEMENT STATE PROGRAM 

 June 11-15, 2007 

FINAL REPORT

 U.S. Nuclear Regulatory Commission 

ENCLOSURE
Utah Final Report Page 1 

1.0 INTRODUCTION 

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

was conducted during the period of June 11-15, 2007, by a review team comprised of technical 

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

Washington and Minnesota. Team members are identified in Appendix A. The review was 

conducted in accordance with the AImplementation 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, AIntegrated Materials Performance Evaluation Program (IMPEP).@ Preliminary results of the 

review, which covered the period of June 28, 2003, to June 15, 2007, were discussed with Utah 

management on the last day of the review. 

A draft of this report was issued to Utah for factual comment on July 13, 2007. The State 

responded by letter on August 2, 2007, from Dane Finerfrock, Director, Division of Radiation 

Control (the Division). The Management Review Board (MRB) met on September 6, 2007, to 

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

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

The Agreement State program is administered by the Division. The Division is located within the 

Department of Environmental Quality (the Department). Organization charts for the Department 

and the Division are included as Appendix B. 

At the time of the review, the Utah Agreement State Program regulated approximately 192 

specific licenses, including naturally occurring or accelerator-produced radioactive material 

(NARM). The Division=s responsibilities include regulatory authority for 11e.(2) byproduct 

material (uranium recovery activities). The Division currently regulates three uranium mill sites 

and a commercial 11e.(2) disposal facility. The Division also has regulatory responsibility for a 

low-level radioactive waste (LLRW) disposal site. 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 Utah. The Agreement was 

amended in 1990 to add the LLRW disposal program, and in 2004 to include the uranium 

recovery program. 

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

performance indicators was sent to the Division on January 10, 2007. The Division provided its 

response to the questionnaire on May 25, 2007. A copy of the questionnaire response may be 

found in the NRC=s Agencywide Documents Access and Management System (ADAMS) using 

Accession Number ML071490307. 

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

the Division=s response to the questionnaire; (2) review of applicable Utah statutes and 

regulations; (3) analysis of quantitative information from the Division=s licensing and inspection 

database; (4) technical evaluation of selected regulatory actions; (5) field accompaniments of six 

of the Division=s inspectors; and (6) interviews with staff and management to answer questions 

or clarify issues. The review team evaluated the information gathered against the established 

criteria for each common and applicable non-common performance indicator and made a 

preliminary assessment of the Agreement State program=s performance. 
Utah Final Report Page 2 

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

following the previous IMPEP review. Results of the current review of the common performance 

indicators are presented in Section 3.0. Section 4.0 details results of the review of the 

applicable non-common performance indicators, and Section 5.0 summarizes the review team's 

findings and recommendations. The recommendations made by the review team are comments 

that relate directly to program performance by the State. 

2.0 STATUS OF ITEMS IDENTIFIED IN PREVIOUS REVIEWS 

During the previous IMPEP review, which concluded on June 27, 2003, one recommendation 

was made. The results of that review were transmitted to Dianne R. Nielson, Ph.D., Executive 

Director of the Department, on December 8, 2003. 

The review team=s evaluation of the current status of the recommendation is as follows: 

The review team recommends that LLRW inspectors receive annual supervisory 

accompaniments in a systematic fashion, and that accompaniments be appropriately 

documented. (Section 4.3.3 of the 2003 report) 

Current Status: 

Supervisory accompaniments showed improvement over the review period in both quality and 

quantity. While no accompaniments occurred in 2003 and 2004, the review team noted that by 

2006, all LLRW inspectors were being accompanied on an annual basis. Written 

accompaniment reports were critical, when necessary, and complete. 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 Division=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 Division=s questionnaire response relative to this 

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

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

evaluating this indicator. 

The Division consists of the Division Director, two administrative staff, and three technical 

Sections: the Radioactive Materials and X-Ray Section, the Geotechnical Services Section, and 

the Health Physics Support Section. The Radioactive Materials and X-Ray Section includes a 

Section Manager and eight full-time Health Physicist positions, four in the Radioactive Materials 

Program and four in the X-Ray Program. The Radioactive Materials and X-Ray Section also 
Utah Final Report Page 3 

includes the Support Services Program with five staff members. The Geotechnical Services 

Section and the Health Physics Support Section were born out of a reorganization following the 

addition of uranium recovery activities to Utah=s Agreement State Program. Details of the 

Geotechnical Services Section=s and the Health Physics Support Section=s staffing and training 

are discussed in Sections 4.3.1 and 4.4.1. 

Division staffing was stable during the review period. Only two staff members left, one of whom 

retired. At the time of the review, the Division had no vacant positions. 

The Division has a comprehensive and effective training plan for staff and new employees, 

comparable to the NRC=s Inspection Manual Chapter (IMC) 1246, “Formal Qualification 

Programs in the Nuclear Material Safety and Safeguards Program Area.” Records show that the 

qualified health physicists have received required and recommended courses for their positions. 

 Staff members demonstrated knowledge of Utah regulations, policies, and procedures. New 

staff members are scheduled to take required training courses. The Division uses a combination 

of formal training and on-the-job experience to qualify staff. Three staff members and the 

Radioactive Materials and X-Ray Section Manager have attended the NRC=s Security Systems 

and Principles Course. 

The training records demonstrated that Division management is committed to training for the 

staff. The review team concluded that the Division has a well-balanced staff and a sufficient 

number of trained personnel to carry out its regulatory duties. 

The Utah Radiation Control Board (the Board) guides development of radiation control policy 

and regulations in the State. Members are appointed by the Governor, with the consent of the 

Senate. The Board meets at least ten times per year. All members are subject to the Utah 

Public Officers= and Employees= Ethics Act. 

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

that Utah=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 Division=s questionnaire response relative to this indicator, data gathered from the 

Division=s database, examination of completed inspection casework, and interviews with 

managers and staff. 

The Division tracks all inspection activities in a computer database. The review team observed 

that the database could easily be queried by managers and staff to determine the inspection 

status for any licensed facility. 

The review team verified that the Division=s inspection priorities for various types of licenses are 

the same as, or more frequent than, those currently prescribed in IMC 2800, “Materials 

Inspection Program.” The review team identified three instances where the Division extended 

inspection frequencies for individual licensees based on good performance. The extensions 
Utah Final Report Page 4 

resulted in the inspection frequencies exceeding IMC 2800 frequencies. Division staff were 

unaware that the 2005 revision of IMC 2800 eliminated the inspection extension option. The 

Radioactive Materials and X-Ray Section Manager stated that the extension policy would be 

reevaluated based on the change to IMC 2800. 

The Division completed 132 routine Priority 1, 2, and 3 inspections during the review period. 

The review team determined that only two of those inspections were conducted overdue by more 

than 25 percent of the inspection frequency listed in IMC 2800. Both overdue inspections were 

Priority 1 industrial radiography licensees. 

The Division conducted 31 initial inspections during the review period. Two of those inspections 

were conducted overdue by IMC 2800 standards. IMC 2800 prescribes initial inspections to be 

completed within 12 months of license issuance. Of the 10 initial inspection reports evaluated by 

the review team, the average time for an initial inspection was approximately five months after 

license issuance. 

Overall, the review team calculated that 2 percent of the Priority 1, 2, and 3 and initial 

inspections conducted by the Division during the review period were conducted overdue. The 

review team noted that for those instances where a license was inspected late, documentation 

showed that inspections had been attempted or other extenuating circumstances prevented a 

timely inspection. 

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

evaluation of inspection casework. The majority of inspection letters regarding inspection results 

were sent within 30 days of the inspection date. For the 38 inspections reviewed, the average 

time for reports to be issued was 26 days. 

Reciprocity was granted to 7 licensees in 2004, 5 licensees in 2005, 14 licensees in 2006, and 

to 11 licensees thus far in 2007. The Section=s reciprocity inspection goals are equivalent to the 

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

Licensees Operating under 10CFR150.20,” (20 percent of candidate licensees). During 2004 

through 2006, the Division met or exceeded the 20 percent requirement in IMC 1220. The 

review team noted that, thus far, the Division had completed inspections of 11 percent of the 

licensees granted reciprocity in 2007. The Division expects to reach or exceed 20 percent by 

the end of the year. 

The review team also examined the Division's General License Program. The Division currently 

has 47 registered general licensees possessing radioactive material in quantities consistent with 

the NRC rule for registration of generally licensed devices. The Division completed 44 general 

license inspections during the review period. 

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

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

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

Division planned for the initial set of inspections of licensees subject to the Increased Controls in 

accordance with the SRM. The review team evaluated the Division's prioritization methodology 

and found it acceptable. The Division has 19 active Increased Controls licensees. The Division 

has conducted all nine inspections of licensees identified as needed to be inspected in the first 

year. In addition, the Division completed three additional Increased Controls inspections at the 
Utah Final Report Page 5 

time of the review. The Division also inspected licensees subject to the Increased Controls 

granted reciprocity to work in Utah. 

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

that Utah=s performance with respect to the indicator, Status of Materials Inspection Program, 

was satisfactory. 

3.3 Technical Quality of Inspections

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

inspectors for 38 radioactive materials inspections conducted during the review period. The 

casework reviewed included inspections conducted by all radioactive materials program 

inspectors and covered inspections of a variety of licensed activities, including: academic and 

medical broad scope, decommissioning, fixed and portable gauge, high-dose rate remote after 

loader (HDR), industrial radiography, pool irradiator, medical institution, nuclear pharmacy, 

waste disposal, and well logging. 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 noted that inspections covered all 

aspects of licensed radiation programs. The review team found that inspection reports were 

generally thorough, complete, consistent, and of high quality, with sufficient documentation to 

ensure that licensees= performance with respect to health and safety was acceptable. The 

documentation supported violations, recommendations made to licensees, unresolved safety 

issues, and discussions held with licensees during exit interviews. 

The inspection procedures utilized by the Division are generally consistent with the inspection 

guidance outlined in IMC 2800. All completed inspection reports are reviewed by a peer and the 

Radioactive Materials and X-Ray Section Manager. Inspection reports are signed by the 

Division Director. Supervisory accompaniments are being conducted annually for all 

Radioactive Materials Program inspectors. 

The review team determined that the inspection findings were appropriate and that prompt 

regulatory actions were taken, as necessary. All inspection findings are clearly stated and 

documented in the report. A Notice of Violation (NOV) is issued to licensees in letter format 

detailing the results of the inspection. When the Division issues an NOV, the licensee is 

required to provide a written plan of correction for the violations within 30 days. Inspection 

closure letters are normally signed by the Executive Secretary of the Board. 

The review team noted that the Division maintains an adequate supply of portable instruments 

for routine confirmatory surveys and incident/emergency response. The instruments are 

calibrated annually, or as needed, by the Division using an in-house calibration source. An 

electronic pulser is used to calibrate exposure rate instruments. Instruments used for 

contamination surveys are calibrated with a variety of alpha- and beta-particle calibration 

sources. 

Accompaniments of two Radioactive Materials Program inspectors were conducted by a review 

team member during the week of April 9, 2007. The accompaniments included an Increased 

Controls inspection of an industrial radiography licensee and a health and safety inspection of a 

medical institution. The accompaniments are identified in Appendix C. During the 
Utah Final Report Page 6 

accompaniments, the inspectors demonstrated appropriate inspection techniques, knowledge of 

the regulations, and conducted performance-based inspections. The inspectors were trained, 

well-prepared for the inspection, and thorough in the audits of the licensees= radiation safety and 

Increased Controls programs. The inspectors conducted interviews with appropriate licensee 

personnel, observed licensed operations, conducted confirmatory measurements, and utilized 

good health physics practices. The inspections were adequate to assess radiological health and 

safety and Increased Controls at the licensed facilities. 

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

that Utah=s performance with respect to the indicator, Technical Quality of Inspections, was 

satisfactory. 

3.4 Technical Quality of Licensing Actions

The review team reviewed the Division=s response to the questionnaire and evaluated 

completed licensing casework and interviewed license reviewers for licensing actions involving 

25 radioactive materials licenses. Licensing actions were evaluated for completeness, 

consistency, proper isotopes and quantities used, qualifications of authorized users, adequate 

facilities and equipment, and operating and emergency procedures sufficient to establish the 

basis for licensing actions. Licenses were evaluated for overall technical quality including 

accuracy, appropriateness of the license, its conditions, and tie-down conditions. Casework was 

evaluated for timeliness, adherence to good health physics practices, reference to appropriate 

regulations, documentation of safety evaluation reports, product certifications or other supporting 

documentation, consideration of enforcement history on renewals, pre-licensing visits, peer or 

supervisory review as indicated, and proper signature authority. The files were checked for 

retention of necessary documents and supporting data. 

The licensing actions reviewed included the following types of licenses: medical institution, 

academic broad scope, pool irradiator, industrial radiography, medical private practice, portable 

gauge, waste disposal service, well logging, service provider, gamma stereotactic radiosurgery, 

and nuclear pharmacy. Licensing actions reviewed included 6 new licenses, 11 amendments, 

11 renewals, and 3 terminations. A listing of the licensing actions reviewed, with case-specific 

comments, can be found in Appendix D. 

The review team found that the Support Services Coordinator logs all licensing actions into the 

Division=s radioactive materials database. This database allows the Division to efficiently assign 

and track all actions throughout the cycle of the licensing action. The Support Services 

Coordinator then distributes the actions to the appropriate license reviewers, who are 

automatically assigned by the database. 

The review team noted that each licensing action is thoroughly reviewed using a two-phase 

process. The license reviewers use checklists, that generally follow the NUREG-1556, 

“Consolidated Guidance About Materials Licenses,” series, to assist in the reviews. A second 

qualified reviewer or senior reviewer reviews all actions before they are sent to the Radioactive 

Materials and X-Ray Section Manager. The Radioactive Materials and X-Ray Section Manager 

does a tertiary review of all licensing actions before they are sent to the Executive Secretary of 

the Board for signature. The Radioactive Materials and X-Ray Section Manager=s review 

includes the use of a checklist from which the license is generated. 
Utah Final Report Page 7 

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

high quality, with health, safety, and security issues properly addressed. Tie-down conditions 

were supported by information contained in the file and were inspectible. Deficiency letters 

clearly stated regulatory positions, were used at the appropriate time, and identified deficiencies 

in the licensees= documents. Terminated licensing actions were well-documented, showing 

appropriate transfer and survey records. The Radioactive Materials and X-Ray Section Manager 

completed the technical review of all terminations completed during the review period. License 

files were complete and well-organized. Applicable guidance documents were complete, wellorganized, and available to reviewers, and appeared to be followed. 

The review team found that the 11 renewal files reviewed did not contain documentation of a 

review of the licensee=s enforcement history, however, reviewers were aware of the importance 

of a licensee=s enforcement history evaluation in the licensing process. 

For medical licensees, the review team noted that information regarding each authorized user=s 

(AU), authorized medical physicist=s (AMP), or authorized nuclear pharmacist=s (ANP) 

qualifications are maintained in a file in the Division=s library. For amendments to the license 

requesting the addition of an AU, AMP, or ANP, information is appropriately noted and removed 

from the application by the reviewer and put in the applicable file in the Division=s library. 

The Division is aware of the pre-licensing guidance distributed to Agreement States in the All 

Agreement State letter, FSME-06-114, “Implementation of Pre-Licensing Guidance,” dated 

December 21, 2006. License reviewers use an electronic checklist to ensure that radioactive 

materials will be used as intended prior to issuance of a license to a new applicant. The review 

team determined that this process met the essential objectives of the NRC=s pre-licensing 

guidance. The Division does not perform pre-licensing visits for all new licenses. 

The review team examined the list of licensees that the Division determined to meet the criteria 

for the Increased Controls, per COMSECY-05-0028. The review team determined that the 

Division had correctly identified the licensees that require Increased Controls, based on the 

criteria. Each affected licensee was issued an administrative license amendment on 

November 15, 2005, requiring Increased Controls by May 15, 2006. The Division has 

procedures in place to issue Increased Controls to any additional licensees, as appropriate. 

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

that Utah=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 Division=s actions in responding to radioactive material 

incidents, the review team examined the Division=s response to the questionnaire relative to this 

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

Database (NMED) against those contained in the State=s database and files, and evaluated the 

casework and supporting documentation for 16 incidents. Incident and allegation policies, 

NMED, and notification of incidents to the NRC Headquarters Operations Center were 

discussed with Division managers and staff. A list of the incident casework examined, with 

case-specific comments, can be found in Appendix E. During the review period, the Radioactive 
Utah Final Report Page 8 

Materials and X-Ray Section received no allegations involving radioactive materials regulated 

under the Agreement. 

Written procedures exist for handling radioactive materials incidents in the Division=s 

Administrative Policy manual. When notification of an incident is received, the appropriate 

Section Manager and staff discuss what level of initial response is appropriate and determine if 

the event requires reporting to the NRC Headquarters Operations Center. The review team 

determined that the Division appropriately reported incidents to the NRC Headquarters 

Operations Center in a timely manner. Incidents were also submitted for inclusion in NMED, as 

necessary. The review team found that the NMED database accurately reflected the information 

contained in the Division=s files and that all of the reports were complete and properly closed. 

During the review period, the Radioactive Materials and X-Ray Section received reports of 19 

radioactive material incidents. The review team evaluated all 16 of the incidents that required 

reporting to the NRC Headquarters Operations Center under NRC reporting criteria. The 

incidents selected for review included the following categories: equipment failure, lost/stolen 

radioactive material, and medical event. The review team determined that, when on-site 

investigations were conducted, initial responses were prompt and the level of effort was 

commensurate with the health and safety significance. 

Through the reviews of the incident documentation, the review team determined that inspectors 

were dispatched for on-site investigations for two lost material incidents and took appropriate 

followup actions, including enforcement. In seven cases (four medical events and three 

radiography incidents) where the review team believed that followup actions were appropriate, 

reactive inspections were not conducted. 

The four medical events involved two administrations of the wrong radiopharmaceutical doses 

and two HDR events resulting in overdoses to unintended sites. Two of these medical events 

were reported to Congress as Abnormal Occurrences. The specifics of these incidents are 

described below. 

$ A patient received a dose of 640 to 1,860 rad to an unintended site during an HDR 

procedure. The licensee stated that the cause of the event was Ainsufficient time to 

insure adequate preparation and verification for a non-typical HDR treatment.@

$ A patient was administered a 100 times greater than prescribed dose of technetium-99m, 

resulting in estimated radiation doses to the patient of 100 rad to certain organs and 5 

rad to the whole body. The event occurred when the technologist picked up the wrong 

syringe. 

$ A patient received approximately five times the prescribed dose to a treatment site during 

an HDR procedure. The medical event was attributed to human error. 

$ A patient was administered a larger than prescribed dose of iodine-131. The cause of 

the event was reported to be that the dose calibrator was not used prior to administering 

the dose. 

Two of the three industrial radiography incidents involved the same licensee. The specifics of 

the three events are described below. 
Utah Final Report Page 9 

$ An industrial radiographer reported a disconnect of a radiography source. The cause 

was that the guide tube had not been connected tightly to the exposure device and 

allowed the source to rotate and disconnect. 

$ Six months earlier, the same licensee reported that a crimped fitting on a radiography 

crank cable housing came loose when a radiographer was moving an exposure device. 

$ An industrial radiographer had a radiography source disconnect from the drive cable. 

The licensee concluded that the event resulted from a worn control adapter but the 

manufacturer believed that the source was not connected appropriately by the user. 

The review team evaluated the next routine inspection reports of the licensees involved in the 

seven cases and found that the reports had minimal information or no information about event 

followup. Interviews with inspection staff indicated that incident followup was done during the 

routine inspections, but was not always documented or was poorly documented in the inspection 

reports. 

The review team discussed this issue with Division managers and determined that the 

Radioactive Materials and X-Ray Section Manager followed the Division=s administrative 

procedures in determining whether an incident warranted a physical inspection or investigation. 

For each of the events noted above, the management decision was that no on-site investigation 

was necessary. For some of the incidents, Division staff talked with the licensees via telephone 

and requested additional information about the incident. The review team believes that on-site 

investigations should be performed as followup to significant incidents (e.g., medical events, 

source disconnects, etc.) to fully evaluate the potential safety impacts. The investigation should 

include an analysis of the sequence of events and conditions that existed at the time of the 

event and interviews of the staff involved in the incident. In addition, the investigation should 

determine the root cause of the incident and include a review of the licensee=s corrective actions 

to prevent recurrence. 

By failing to perform on-site investigations, the Division missed opportunities to fully evaluate 

each incident and its root cause. For example, interaction with the licensee that reported the 

cause of the medical event to be Ainsufficient time to insure adequate preparation and 

verification for a non-typical HDR treatment@ may have been a good opportunity to evaluate a 

production versus quality issue at the hospital. Interaction with the radiography licensees may 

have increased safety awareness during future radiographic operations and possibly prevented 

similar incidents. The review team recommends that the State conduct on-site investigations of 

complex incidents to determine potential health and safety impacts and to evaluate licensees=

actions to prevent recurrences. 

During the last IMPEP review, the team noted that some Division staff members were not fully 

cognizant of the allegation procedures in the Administrative Policy manual, particularly with 

respect to the threshold of concerns to be reported as allegations. The review team determined, 

through interviews with staff members, that appropriate training in the allegation process was 

provided to all staff members. 

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

that Utah=s performance with respect to the indicator, Technical Quality of Incident and 

Allegation Activities, was satisfactory, but needs improvement. 
Utah 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. Utah=s Agreement does not include a sealed source and device evaluation program, 

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

4.1 Compatibility Requirements

4.1.1 Legislation

Utah became an Agreement State on April 1, 1984. In addition to their response to the 

questionnaire, the Division provided the review team with the opportunity to review copies of 

legislation that affects the Radiation Control Program. The current effective statutory authority is 

contained in the Utah Code Annotated, Title 19, Chapter 3, Radiation Control Act. The Division 

implements the Radiation Control Program. The review team noted that no legislation affecting 

the Radiation Control Program was passed during the review period. 

4.1.2 Program Elements Required for Compatibility

The State=s regulations for control of radiation are located in Title R313 of the Utah 

Administrative Code and apply to all ionizing radiation, whether emitted from a radionuclide or 

device. Utah requires a license for possession and use of all radioactive materials, including 

naturally occurring materials, such as radium and accelerator-produced radionuclides. 

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

process takes 120 days after filing a draft administrative rule. Draft administrative rules are sent 

to the Board for permission to get public comments and to file the proposed rule. Proposed 

rules are published in the State Bulletin. After a public comment period, the rule is returned to 

the Board for final approval. The State has the authority to issue legally binding requirements 

(e.g., license conditions) in lieu of regulations until compatible regulations become effective. 

Many of Utah=s compatibility-required regulations are incorporated by reference to NRC 

regulations. 

The review team evaluated the Division=s response to the questionnaire relative to this indicator, 

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

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

from the Office of Federal and State Materials and Environmental Management Programs=

(FSME) State Regulation Status Sheet. 

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

legally binding requirements no later than three years after they become effective. The review 

team identified that the following eight amendments, adopted by the State in the 1990s, were 

never reviewed by the NRC in final form. 

$ ADefinition of Land Disposal and Waste Site QA Program,@ Title 10 of the Code of 

Federal Regulation (10 CFR) Part 61 amendment (58 Federal Regulation (FR) 33886) 
Utah Final Report Page 11 

$ that became effective July 22, 1993, and was due for Agreement State adoption by 

 July 22, 1996. 

$ AFrequency of Medical Examinations for Use of Respiratory Protection Equipment,@ 10 

CFR Part 20 amendment (60 FR 7900) that became effective March 13, 1995, and was 

due for Agreement State adoption by March 13, 1998. 

$ ALow-Level Waste Shipment Manifest Information and Reporting,@ 10 CFR Part 20 and 

61 amendments (60 FR 15649 and 25983) that became effective March 1, 1995, and 

was due for Agreement State adoption by March 1, 1998. 

$ "Radiation Protection Requirements: Amended Definitions and Criteria," 10 CFR Part 19 

and 20 amendments (60 FR 36038) that became effective August 14, 1995, and was 

due for Agreement State adoption by August 14, 1998. 

$ AMedical Administration of Radiation and Radioactive Materials,@ 10 CFR Part 20 and 35 

amendments (60 FR 48623) that became effective October 20, 1995, and was due for 

Agreement State adoption by October 20, 1998. 

$ AResolution of Dual Regulation of Airborne Effluents of Radioactive Materials; Clean Air 

Act,@ 10 CFR Part 20 amendment (61 FR 65120) that became effective January 9, 1997, 

and was due for Agreement State adoption by January 9, 2000. 

$ ACriteria for the Release of Individuals Administered Radioactive Material,@ 10 CFR Part 

20 and 35 amendments (62 FR 4120) that became effective May 29, 1997, and was due 

for Agreement State adoption by May 29, 2000. 

$ ALicenses for Industrial Radiography and Radiation Safety Requirements for Industrial 

Radiographic Operations; Clarifying Amendments and Corrections,@ 10 CFR Part 34 

amendment (63 FR 37059) that became effective July 9, 1998, and was due for 

Agreement State adoption by July 9, 2001. 

Proposed versions of these amendments were evaluated by the NRC, with no comments. On 

August 10 and October 2, 2001, the Division sent NRC updated final regulations for a number of 

amendments, including these eight amendments. For unknown reasons, these amendments 

were not evaluated by the NRC and thus remain annotated as AProposed@ on Utah=s State 

Regulation Status Sheet. The review team evaluated three of the amendments during this 

review to determine whether the final Utah regulations differed from the proposed versions. All 

three appeared unchanged and compatible with NRC regulations. 

The Division submitted seven of the eight amendments identified above to the NRC for a final 

compatibility review on July 13, 2007. By letter dated September 4, 2007, the NRC indicated to 

the State that all regulations that were reviewed met their designated compatibility and health 

and safety requirements. The excluded amendment was superceded by other State 

rulemakings. 

The following NRC amendment is overdue; however, the State does not have any facilities 

subject to the provisions and, until they receive a license application for a facility that would be 

subject to these provisions, do not need to adopt this amendment: 
Utah Final Report Page 12 

$ ANational Source Tracking System - Serialization Requirements,@ 10 CFR Part 32 

amendment (with reference to Part 20 Appendix E) (71 FR 65685) that became effective 

February 6, 2007, and was due for Agreement State adoption by February 6, 2007. 

The State will need to address the following two amendments in upcoming rulemakings or by 

adopting alternate legally binding requirements: 

$ "Compatibility with IAEA Transportation Safety Standards and Other Transportation 

Safety Amendments," 10 CFR Part 71 amendment (69 FR 3697) that became effective 

on October 1, 2004, and is due for Agreement State adoption by October 1, 2007. 

$ AMinor Amendments,@ 10 CFR Part 20, 30, 32, 35, 40 and 70 amendments (71 FR 

15005) that became effective March 27, 2006, and is due for Agreement State adoption 

by March 27, 2009. 

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

that Utah=s performance with respect to the indicator, Compatibility Requirements, was 

satisfactory. 

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

Effective June 1, 1996, NRC reassumed regulatory authority for sealed source and device 

evaluations in Utah in response to a request from the State to relinquish that authority. No 

sealed source or device evaluations have been performed in Utah since that relinquishment. 

Accordingly, the review team did not evaluate this indicator. 

4.3 Low-Level Radioactive Waste (LLRW) Disposal Program

Authority to regulate LLRW disposal facilities was added to Utah=s NRC Agreement State 

Program in May 1990. The State of Utah=s LLRW Disposal Program is administered by the 

Division. Regulatory authority is derived from the Radiation Control Act of Utah Code Title 19, 

Chapter 3, and the Radiation Control Rules promulgated in Utah Administrative Code, R313. 

At the time of the review, the Division regulated one LLRW disposal facility, EnergySolutions 

(formerly Envirocare). EnergySolutions is a commercial LLRW disposal facility located 80 miles 

west of Salt Lake City in Tooele County. EnergySolutions is licensed by the Division under a 

license which expired on October 22, 2003, and is currently in timely renewal. The license 

authorizes EnergySolutions to receive, store, possess, and dispose of naturally occurring 

radioactive materials and LLRW less than Class A. Currently, in accordance with Utah statutes, 

EnergySolutions may not receive Class B or Class C waste without first receiving approval from 

the Executive Secretary of the Board, the Governor, and the Legislature. 

With Utah=s assumption of regulatory authority for uranium recovery activities, an additional 

license was issued to EnergySolutions in 2004 for the handling of 11.e(2) material at the facility. 

With the licenses co-located, the health physics licensing and inspections are handled under the 

LLRW license. Additionally, EnergySolutions is required to maintain compliance with all 

conditions and schedules stipulated in their Utah Groundwater Discharge Permit, issued by the 

Utah Water Quality Board. 
Utah Final Report Page 13 

The review team used five sub-elements to evaluate the performance of the LLRW Disposal 

Program. The sub-elements are as follows: (1) Technical Staffing and Training; (2) Status of 

LLRW Disposal Inspection Program; (3) Technical Quality of Inspections; (4) Technical Quality 

of Licensing Actions; and (5) Technical Quality of Incident and Allegation Activities. To evaluate 

the above sub-elements, the team reviewed background materials on the site, performed 

inspector accompaniments, reviewed the Utah response to the questionnaire, interviewed 

managers and staff, and examined records, as appropriate. 

4.3.1 Technical Staffing and Training

The evaluation of this sub-element focused on: (1) qualifications of the technical staff and the 

expertise necessary to regulate a LLRW disposal facility; (2) the development and 

implementation of a training program for the staff; and (3) staffing trends that could have an 

adverse impact on performance. 

As previously noted, the Division reorganized since the last IMPEP review. LLRW 

responsibilities were split between the Geotechnical Services Section and the Health Physics 

Support Section. The Geotechnical Services Section consists of a Section Manager and seven 

full-time positions. The seven staff members include three Environmental Engineers and four 

Environmental Scientists. The Health Physics Support Section consists of a Section Manager 

and six full-time Environmental Scientist positions dedicated to LLRW and Uranium Recovery 

program areas. 

Both the Geotechnical Services Section and the Health Physics Support Section are currently 

fully staffed. The review team determined that there was a good balance of technical expertise 

in the program, and that staff turnover had no adverse impact on the program. 

The review team examined staff training documentation and conducted interviews with all 

available staff to assess qualification and training needs. The Division has a generic training 

plan that specifies required and recommended training for each technical position. Individual 

Training Qualification Forms are maintained for each person. All of the LLRW program staff 

members received necessary training in accordance with the training plan. 

During staff interviews, one staff member expressed a desire for additional health physics 

training. Division management scheduled addition training for that individual, further 

demonstrating the Division management=s commitment to training for its staff. 

4.3.2 Status of LLRW Disposal Inspection Program

The Division has adopted NRC inspection guidance and procedures. The review team 

examined inspection files and conducted interviews with inspectors to determine that: (1) the 

LLRW disposal licensee is inspected at least annually, as prescribed in IMC 2800; (2) any 

deviations from the prescribed inspection schedule are coordinated between working staff and 

management; and (3) inspection findings are communicated to licensees in a timely manner. 

Due to the complexity of the review and timeliness of inspection needs, the Division divided the 

annual inspection of LLRW site into multiple modules (16 modules in 2004 and 2005; 

17 modules in 2006 and 2007). Modular inspections are performed throughout the year and 

may be adjusted to accommodate additional licensing activities. The modules include, but are 

not limited to, reviewing specific license condition compliance, radiation safety, engineering, 
Utah Final Report Page 14 

groundwater, emergency planning, and environmental monitoring. The review team concluded 

that this modular inspection approach is equivalent to a one-time annual inspection for the 

LLRW facility. In addition, the Division conducts inspections of incoming waste shipments at the 

EnergySolutions facility daily, or as needed. 

The review team identified that a complete inspection (all modules) was not performed during 

any calendar year during the review period. In 2004, 9 of 16 modules were completed; 

in 2005, 10 of 16 modules were done; in 2006, 12 of 17 modules were completed; and thus far 

in 2007, a total of 4 modules were completed. Management Directive 5.6 evaluation criteria 

requires most inspections to be completed and reviewed. The review team evaluated the 

completed modules. Critical modules (i.e., radiation safety, dosimetry, and site access/postings) 

were completed annually. With the Division=s practice of having health physics inspectors at 

EnergySolutions nearly continuously, the review team concluded that adequate oversight of 

facility operations and the Radiation Safety Program was occurring. Although all modules were 

not completed on an annual basis, the review team determined that adequate, performancebased inspections of the licensee=s program were completed annually. 

During the 2003 IMPEP review, the Division Director agreed to the development of an 

independent mixed waste module to address unique radiation safety issues at the mixed waste 

operations facility. The current review team noted that an inspection module was created and is 

used for the LLRW disposal license assessment. 

The review team determined that inspection findings were communicated to the licensee within 

30 days following the inspection. Typically, inspection findings were issued in the third week 

after the inspection was completed. 

4.3.3 Technical Quality of Inspections

The review team assessed the quality of LLRW disposal inspections by evaluating: 

(1) inspector performance during accompaniments; (2) inspection field notes and completed 

reports; (3) inspection procedures; (4) followup on previous inspection findings; (5) regulatory 

actions; and (6) annual supervisory accompaniments. 

Two Health Physics Support Section inspectors were accompanied by an IMPEP team member 

on May 3, 2007. One of the inspectors inspected the facility under the ARadiation Safety-Site 

Access/Posting@ module. The other inspector was observed inspecting incoming waste 

shipments. The inspectors demonstrated appropriate surveying skills and knowledge of the 

regulations. An adequate supply of calibrated radiation survey instruments were available to the 

inspectors. The inspections were adequate to assess radiological health and safety at the 

facility. 

The review team determined from an evaluation of the inspection files sampled that modular 

inspections were complete, with the findings well-founded, appropriately documented, and 

reviewed by the Health Physics Support Section Manager. With regulatory references, the 

modular inspection documentation identified poor licensee performance and root causes. The 

Health Physics Support Section Manager reviews all inspection findings. The Executive 

Secretary of the Board signs and issues enforcement letters, notices of violations, and/or 

penalties, as necessary. The findings and observations are maintained in a detailed inspection 

log. All open items from the previous inspection files were either closed out, scheduled for 
Utah Final Report Page 15 

followup action during the next modular inspection, or tracked as escalated enforcement items. 

In addition, the Division maintains a database detailing EnergySolutions=s compliance history. 

This database is a valuable tool for assessing and monitoring the LLRW disposal operations 

and performance. There were no performance issues identified in the inspections that were 

evaluated. 

As noted in Section 2.0 of this report, supervisory accompaniments of inspectors showed 

improvement over the review period in both quality and quantity compared to the previous review 

period. While no accompaniments occurred in 2003 and 2004, the review team noted that by 

2006, all LLRW inspectors were being accompanied on an annual basis. Written 

accompaniment reports were critical, when necessary, and complete. 

4.3.4 Technical Quality of Licensing Actions

The LLRW site license has been in timely renewal since July 2003. During that time, 

EnergySolutions requested amendments to modify its operations to enhance safety aspects and 

to remain competitive. After the initial renewal application was received in July 2003, four 

operational amendment requests were processed. The Health Physics Support Section 

Manager was innovative in assigning amendment tracking numbers through the use of letters 

versus sequential number (e.g., 22A, 22B). The 11e.(2) disposal license has been amended 

three times since 2004. The major licensing actions were reviewed and were determined to be 

thorough, complete, consistent, and of acceptable technical quality. The license conditions are 

clear and auditable. Health and safety issues were properly addressed. Tie-down conditions 

were complete and verifiable, and the licensing process appeared to be thorough and 

consistent. License variances were granted, when appropriate. 

The Division used independent analyses and public hearings in the license review process. The 

Division hired a technical consultant to address certain complex technical issues to verify the 

licensee=s analysis for license renewal and facility improvements. Public hearings are held, 

when needed. 

With the license in timely renewal for nearly 4 years, the review team evaluated any public health 

and safety impacts that may have developed. No health and safety impacts were identified. A 

completeness review of the renewal request has been completed and discussed with 

EnergySolutions. In June 2005, EnergySolutions resubmitted its renewal application. The 

application analysis was recently completed and the Division initiated a 60-day public review of 

the draft license in June 2007. 

With the Division=s reorganization, hydrology and engineering issues at EnergySolutions are 

addressed by the Division=s Geotechnical Section. These reviews were thorough, adhered to 

standard engineering practices, were of high quality, and reviewed by management. 

The review team evaluated the Division=s process for obtaining adequate financial assurance for 

the EnergySolutions facility. The review team determined that the Division has obtained 

adequate financial assurance for the site, based on NRC methodology. 

4.3.5 Technical Quality of Incident and Allegation Activities
Utah Final Report Page 16 

During the review period, the State received and addressed three allegations involving LLRW 

activities, including allegations provided directly to the State and those referred to the Division by 

the NRC. The review team determined that the Division took prompt and appropriate action in 

response to the concerns raised, including conducting independent surveys and on-site 

investigations, as needed. The review team noted that all documentation related to the 

investigation of allegations was appropriately maintained in a separate file. As noted in Section 

3.5, additional training was provided to LLRW Program staff with respect to the threshold of 

concerns to be reported as allegations. 

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

Utah=s performance with respect to the indicator, LLRW Disposal Program, was satisfactory. 

4.4 Uranium Recovery Program

Authority to regulate uranium recovery activities was added to Utah=s NRC Agreement State 

Program in August 2004. The applicable regulations for the uranium recovery program include 

Utah Administrative Code R313-24 B AUranium Mills and Source Material Mill Tailings Disposal 

Facility Requirements.@

In February 2005, the Division issued licenses to the following four facilities: EnergySolutions, 

LLC; Denison Mines (USA) Corporation, White Mesa Uranium Mill; Rio Algom Mining 

Corporation, Lisbon Valley Uranium Mill; and SXR Uranium One, Shootaring Canyon Mill. The 

Division=s Uranium Recovery Program has not been previously assessed by the IMPEP process. 

In conducting this review, five sub-elements were used to evaluate the performance of the 

Uranium Recovery Program. These sub-elements 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. 

4.4.1 Technical Staffing and Training

In reviewing this sub-element, the review team evaluated the Uranium Recovery Program 

staffing level, the technical qualifications of the staff, staff training, and staff turnover. This 

evaluation included general examination of the qualifications of the inspectors and licensing 

personnel and interviews with Uranium Recovery Program staff. 

As described in Section 4.3.1, oversight of the Uranium Recovery Program is provided by both 

the Geotechnical Services Section and the Health Physics Support Section. Various members 

of the Uranium Recovery Program staff participated in inspections and licensing activities at the 

three uranium mill facilities regulated by the Division. The amount of participation varied, 

depending on the individual=s qualifications and workload. As discussed in Section 4.4.3, during 

the 2005-2006 timeframe, personnel issues resulted in gaps in the quality of radiation protection 

and safety inspections at uranium recovery facilities. Division managers prioritized the resolution 

of the personnel issues which delayed the full implementation of the Radiation Safety Program 

at the facilities. Those issues were resolved and the Division currently has an effective 

interdisciplinary team of expertise, with an appropriate training program in place, for its Uranium 

Recovery Program. 
Utah Final Report Page 17 

The review team found that the Uranium Recovery Program contains expertise in geology; 

hydrogeology; construction management; drainage and run off systems; storm water and 

wastewater design, permitting, and compliance; health physics; and radiation control. For topics 

where in-house expertise was not available or when work loads did not permit timely reviews of 

submittals, the Division has outsourced technical review work. Currently, the Division is utilizing 

an environmental and engineering design firm to assist in a major license amendment review 

and smaller licensing related work. The technical qualifications of consultant personnel 

available to the Uranium Recovery Program for technical reviews include civil, environmental, 

mechanical, and nuclear engineers; geochemists; hydrogeologists; and laboratory technicians. 

The review team found the Division=s outsourcing of technical reviews to be an effective tool in 

conducting sound technical evaluations while providing the licensees with timely responses to 

their submittals. 

4.4.2 Status of Uranium Recovery Inspection Program

The review team focused on several factors in evaluating this sub-element, including inspection 

frequency, overdue inspections, and timely issuance of inspection reports and findings to 

licensees. The review team=s evaluation is based on an evaluation of the Division=s response to 

the questionnaire relative to this indicator, the uranium recovery inspection schedule, inspection 

casework files, and interviews with inspection staff and management. 

From 2005 through May 2007, 4 radiation safety inspections, 18 groundwater inspections and 17 

engineering inspections were conducted by the Division. With respect to radiation safety 

inspections, the review team determined that the inspection frequency was not consistent with 

IMC 2801, AUranium Mill and 11e.(2) Byproduct Material Disposal Site and Facility Inspection 

Program,@ requirements. No inspections were performed of the Shootaring Canyon Mill since 

Utah assumed authority over the uranium recovery activities. Only one radiation safety 

inspection for the Lisbon Valley Mill was performed during the review period. Three radiation 

safety inspections were conducted at the White Mesa Mill from 2005 through May 2007; 

however, several important areas of radiation protection and safety do not appear to have been 

evaluated on an annual basis (see Section 4.4.3 for detailed discussion). 

Of the three uranium mill sites regulated by the Division, only one site is active. The White Mesa 

Mill is currently in "operational status," processing alternate feed material for its uranium and 

vanadium content. The Shootaring Canyon Mill operated for only three months in 1982, 

generating a small amount of mill tailings (the byproduct material wastes produced by extraction 

of uranium from ore). The mill was on standby status until 2002, at which time a 

decommissioning and reclamation schedule was established. The Lisbon Valley Mill has been 

in decommissioning status since November 1995. As a result, the Division prioritized inspection 

efforts to focus on the White Mesa Mill. The Division is currently reviewing a Shootaring Canyon 

Mill license amendment to return the facility to operational status. Division managers anticipate 

that as the Shootaring Canyon Mill approaches “operational status,” the frequency of inspections 

of the facility will be increased. 

With respect to the communication of inspection findings to licensees, the review team found 

that inspection findings are communicated to licensees in a timely manner, during exit interviews 

and through inspection correspondence. 
Utah Final Report Page 18 

4.4.3 Technical Quality of Inspections

In reviewing this sub-element, the review team examined inspection files, inspection reports, and 

enforcement documentation. The review of records covered inspections conducted from 2005 

until May 2007 and included radiation safety, groundwater, and engineering related inspections. 

The review team found that the inspections were generally conducted using a site-specific 

modular approach. Inspection modules were set up at the beginning of the year by 

management and appropriate staff members. 

The Division=s records indicated that supervisor accompaniments of radiation safety, 

groundwater, and engineering inspectors occurred during both 2005 and 2006. The 

accompaniment documentation contained detailed comments on inspector performance and 

appeared to provide a sufficient evaluation of the inspector. 

The review team found that the inspection reports and memoranda generally provided an 

appropriate depth of coverage. Inspectors addressed compliance conditions for the licensees, 

and the reports and memoranda demonstrated that the inspectors pursued root causes where 

problems or violations were identified. Inspection files contained excellent photographs 

documenting both general facility features and items of interest/concern. The review team 

discussed the Division=s approach to conducting uranium recovery inspections and that it should 

ensure that, at a minimum, all elements of a uranium recovery facility are inspected and 

documented on an annual basis. Appendix C lists the inspection files examined by the review 

team. 

On May 9, 2007, members of the review team accompanied two Uranium Recovery Program 

inspectors during an inspection of the White Mesa Mill. The review team found that the 

inspectors focused on specific aspects of the licensee=s radiation protection and environmental 

programs. Although the inspection was not comprehensive, the areas of the radiation protection 

and environmental programs examined during the inspection were reviewed in detail. 

Inspection records indicated that one specific radiation protection issue has not been resolved in 

a timely manner. Specifically, in March 2005, during a radiation safety inspection of the White 

Mesa Mill, Division inspectors identified that facility personnel were clipping their dosimeters to 

the back of their hard hats, thereby violating standard external radiation exposure monitoring 

procedures and requirements specified in UAC R313-15-503, ALocation of Individual Monitoring 

Devices.@ Despite a 26-month interval, personal dosimeter placement at the White Mesa facility 

was still an unresolved issue during the May 2007 radiation safety inspection. 

Overall, based on a review of inspection records and interviews with staff, the review team 

identified deficiencies in the radiation protection and safety inspections performed since 2005. 

Specifically, for the White Mesa Mill, all of the elements identified in IMC 2801 do not appear to 

have been evaluated. Since 2005, the following AInspection Procedures@ have not been 

reviewed on a yearly basis: Radiation Protection, Inspection of Transportation Activities, 

Management Organization and Controls, Operator Training/Retraining, and Emergency 

Preparedness. The review team recommends that the State institute a more comprehensive 

inspection program that ensures radiation safety and protection at uranium recovery facilities, 

including compliance with applicable regulatory requirements and license conditions. 
Utah Final Report Page 19 

Division management indicated that gaps in the quality of radiation protection and safety 

inspections are attributable primarily to personnel issues. Specifically, for the period of 2005 

through 2006, a technical staff member, assigned to developing and implementing the radiation 

safety inspection program, under-performed and was eventually dismissed. Division 

management appeared to rectify this situation by hiring a qualified replacement. Recently, three 

radiation protection inspection modules (Internal/External Monitoring, Training/Posting/Exit 

Monitoring, and ALARA) were developed for the White Mesa Mill by Division staff. The review 

team found these modules to be comprehensive and appropriately based on requirements in the 

licensee=s application, radioactive material license, and/or relevant NRC Regulatory Guides. 

Although the Division inspectors are qualified to perform uranium recovery inspections, the 

review team identified a beneficial knowledge transfer opportunity. Because the NRC had a long 

history of regulation of the uranium mills in Utah, NRC Region IV inspectors have a wealth of 

site-specific information and general uranium recovery radiological inspection knowledge, which 

could be valuable to the State. The Division Director and the NRC agreed to pursue the idea, in 

the interest of knowledge transfer. 

4.4.4 Technical Quality of Licensing Actions

Licenses and amendments for the Lisbon Valley, White Mesa, and Shootaring Canyon Mills 

were evaluated. Licensing actions for the review period included two amendments for Lisbon 

Valley Mill, two amendments for the White Mesa Mill, and three amendments for the Shootaring 

Canyon Mill. At the time of the review, two proposed license modifications were pending for the 

White Mesa Mill, and one proposed license modification was pending for the Shootaring Canyon 

Mill. The licenses for these facilities properly addressed health, safety, and environmental 

issues. The licenses were thorough, and the license conditions were clear and well-written. 

Requirements associated with these license conditions were based on a need to meet 

regulations and to protect health and safety. 

The review team examined files and documentation for one completed licensing action at the 

White Mesa Mill and one pending licensing action at the Shootaring Canyon Mill. Division staff 

reviews utilized appropriate methodologies in their evaluations of the license requests. The 

review team concluded that these licensing actions were appropriate and that the Division=s 

evaluation was of acceptable technical quality. Appendix D lists the licensing files reviewed for 

completeness and accuracy. 

4.4.5 Technical Quality of Incident and Allegation Activities

For the review period, no incidents or allegations were identified for the Uranium Recovery 

Program. This sub-element was reviewed under the common performance indicator, Technical 

Quality of Incident and Allegation Activities, in Section 3.5. 

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

that Utah=s performance with respect to the indicator, Uranium Recovery Program, was 

satisfactory, but needs improvement. 
Utah Final Report Page 20 

5.0 SUMMARY 

As noted in Sections 3.0 and 4.0, Utah=s performance was found satisfactory, but needs 

improvement, for the performance indicators, Technical Quality of Incident and Allegation 

Activities, and Uranium Recovery Program. Utah=s performance for the other six performance 

indicators reviewed was found satisfactory. The review team made two recommendations 

regarding the performance of the Utah Agreement State Program. Accordingly, the review team 

recommended, and the MRB agreed, that the Utah Agreement State Program was adequate to 

protect public health and safety and compatible with NRC's program. The MRB requested that a 

followup IMPEP review focusing on the performance indicators, Technical Quality of Incident 

and Allegation Activities and Uranium Recovery Program, take place in approximately 1 year. 

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

evaluation and implementation, as appropriate, by the State. 

RECOMMENDATIONS: 

1. The review team recommends that the State conduct on-site investigations of complex 

incidents to determine potential health and safety impacts and to evaluate licensees=

actions to prevent recurrences. (Section 3.5) 

2. The review team recommends that the State institute a more comprehensive inspection 

program that ensures radiation safety and protection at uranium recovery facilities, 

including compliance with applicable regulatory requirements and license conditions. 

(Section 4.4.3) 
 LIST OF APPENDIXES AND ATTACHMENT 

Appendix A IMPEP Review Team Members 

Appendix B Utah Organization Charts 

Appendix C Inspection Casework Reviews 

Appendix D License Casework Reviews 

Appendix E Incident Casework Reviews 

Attachment August 2, 2007, Letter from Dane Finerfrock 

Utah=s Response to Draft IMPEP Report 
 APPENDIX A 

 IMPEP REVIEW TEAM MEMBERS 

Name Area of Responsibility

James Lynch, RIII Team Leader 

Compatibility Requirements 

Inspector Accompaniments 

Linda McLean, RIV Technical Staffing and Training 

Technical Quality of Incident and Allegation 

 Activities 

Inspector Accompaniments 

George Johns, Minnesota Status of Materials Inspection Program 

Technical Quality of Inspections 

Jacqueline Cook, RIV Technical Quality of Licensing Actions 

Paul Michalak, FSME Uranium Recovery Program 

Inspector Accompaniments 

Earl Fordham, Washington Low-Level Radioactive Waste Disposal Program 

Inspector Accompaniments 
 APPENDIX B 

 UTAH ORGANIZATION CHARTS 

 

 ADAMS: ML071490305 
 APPENDIX C 

 INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: Consolidated Coal Company License No.: UT0800490 

Inspection Type: Initial, Unannounced Priority: 5 

Inspection Date: 5/22/06 Inspector: DH 

File No.: 2 

Licensee: City of Moab License No.: UT1000499 

Inspection Type: Initial Priority: 5 

Inspection Date: 4/24/07 Inspector: GG 

File No.: 3 

Licensee: Anderson Engineering Company License No.: UT1800270 

Inspection Type: Initial, Unannounced Priority: 5 

Inspection Date: 6/7/07 Inspector: PG 

File No.: 4 

Licensee: Alpha Testing Labs, Inc. License No.: UT1800485 

Inspection Type: Initial Priority: 1 

Inspection Date: 11/7/05 Inspector: GG 

File No.: 5 

Licensee: Utah Cancer Specialists License No.: UT1800491 

Inspection Type: Initial, Unannounced Priority: 3 

Inspection Date: 8/16/06 Inspector: GG 

File No.: 6 

Licensee: Parsons Corporation License No.: UT1800492 

Inspection Type: Initial, Unannounced Priority: 5 

Inspection Date: 10/12/06 Inspector: DH 

File No.: 7 

Licensee: CCU Diagnostics, LLC License No.: UT1800496 

Inspection Type: Initial, Unannounced Priority: 3 

Inspection Date: 12/19/06 Inspector: PG 

File No.: 8 

Licensee: Canyon Fuel Company License No.: UT2100493 

Inspection Type: Initial, Unannounced Priority: 5 

Inspection Date: 10/12/06 Inspector: PG 
Utah Final Report Page C.2 

Inspection Casework Reviews 

File No.: 9 

Licensee: Superior Well Services License No.: UT2400489 

Inspection Type: Initial, Unannounced Priority: 5 

Inspection Dates: 8/22-23/06 Inspector: DH 

File No.: 10 

Licensee: IHC Heber Valley Medical Center License No.: UT2900497 

Inspection Type: Initial, Unannounced Priority: 3 

Inspection Date: 1/25/07 Inspector: GG 

Comment: 

Report cover letter was not signed. 

File No.: 11 

Licensee: Heart of Utah, PC License No.: UT2900495 

Inspection Type: Initial, Unannounced Priority: 3 

Inspection Date: 12/27/06 Inspector: DH 

File No.: 12A 

Licensee: Universal Testing, LLC License No.: UT0600125 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Dates: 6/8/04, 7/29/04 Inspector: GG 

File No.: 12B 

Licensee: Universal Testing, LLC License No.: UT0600125 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 8/22/06 Inspector: PG 

File No.: 13A 

Licensee: University of Utah License No.: UT1800001 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 12/9/05 Inspectors: JF and team 

File No.: 13B 

Licensee: University of Utah License No.: UT1800001 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 2/12/07 Inspectors: PG and team 

File No.: 14A 

Licensee: Isomedix Operations, Inc. License No.: UT1800074 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 1/19/05 Inspector: GG 

File No.: 14B 

Licensee: Isomedix Operations, Inc. License No.: UT1800074 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 3/22/07 Inspector: PG 
Utah Final Report Page C.3 

Inspection Casework Reviews 

File No.: 15A 

Licensee: LDS Hospital License No.: UT1800102 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 5/21/04 Inspector: JF 

File No.: 15B 

Licensee: LDS Hospital License No.: UT1800102 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 5/26/05 Inspector: GG 

File No.: 15C 

Licensee: LDS Hospital License No.: UT1800102 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 7/26/06 Inspector: PG 

File No.: 16 

Licensee: Central Utah Clinic License No.: UT2500361 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 4/14/06 Inspector: JF 

File No.: 17A 

Licensee: University of Utah License No.: UT1800145 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 11/4/03 Inspector: JF 

File No.: 17B 

Licensee: University of Utah License No.: UT1800145 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 11/4/03 Inspectors: PG, DH 

File No.: 18 

Licensee: Salt Lake Regional Medical Center License No.: UT1800165 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Dates: 10/23-12/1/03 Inspector: JF 

Comment: 

The inspection frequency for the HDR was administratively changed to 3 years to 

coincide with the medical institution's inspection schedule. 

File No.: 19 

Licensee: RMW-Utah, Inc. License No.: UT1800308 

Inspection Type: Routine Priority: 2 

Inspection Date: 11/22/05 Inspector: PG 

Comment: 

The subsequent inspection frequency was extended 1 year, which coincides with IMC 

2800 inspection schedule. 
Utah Final Report Page C.4 

Inspection Casework Reviews 

File No.: 20 

Licensee: Mountain West Cardiovascular Associates License No.: UT1800319 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Dates: 9/15-16/05 Inspector: PG 

Comment: 

This Priority 3 license was extended 1 year. The subsequent inspection would be 

overdue using IMC 2800 priorities. 

File No.: 21A 

Licensee: URS Corporation License No.: UT1800410 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 11/13/03 Inspector: GG 

File No.: 21B 

Licensee: URS Corporation License No.: UT1800410 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 3/22/07 Inspector: DH 

File No.: 22 

Licensee: Alpha Testing Labs, Inc. License No.: UT1800485 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 2/1/07 Inspector: DH 

File No.: 23 

Licensee: Schlumberger Technology Corporation License No.: UT1800102 

Inspection Type: Routine Priority: 3 

Inspection Date: 1/7/04 Inspector: JF 

File No.: 24A 

Licensee: Quality Testing & Inspection License No.: UT2500269 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 11/29/05 Inspector: DH 

Comment: Next inspection extended to 2 years based on performance. 

File No.: 24B 

Licensee: Quality Testing & Inspection License No.: UT2500269 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 5/1/07 Inspector: GG 

File No.: 25 

Licensee: Nuclear Apothecary, Inc. License No.: UT2700464 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 7/14/05 Inspector: GG 
Utah Final Report Page C.5 

Inspection Casework Reviews 

File No.: 26 

Licensee: Universal Testing License No.: UT0600125 

Inspection Type: Special Priority: 1 

Inspection Date: 8/22/06 Inspector: PG 

File No.: 27 

Licensee: University of Utah License No.: UT1800001 

Inspection Type: Special Priority: 2 

Inspection Date: 2/14/07 Inspector: PG 

File No.: 28 

Licensee: Brigham Young University License No.: UT2500081 

Inspection Type: Special Priority: 2 

Inspection Date: 7/19/06 Inspector: PG 

File No.: 29 

Licensee: Quality Testing and Inspection License No.: UT2500269 

Inspection Type: Special Priority: 1 

Inspection Date: 4/10/07 Inspector: GG 

File No.: 30 

Licensee: AITEC US Instruments License No.: TX L05718 

Inspection Type: Reciprocity Priority: 1 

Inspection Date: 11/17/06 Inspector: GG 

File No.: 31 

Licensee: International Uranium Corporation (White Mesa Mill) License No.: UT1900479 

Inspection Type: Routine, Announced 

Inspection Date: 3/21/05 Inspectors: CH, JC 

File No.: 32 

Licensee: Rio Algom B Lisbon Valley License No.: UT1000481 

Inspection Type: Routine, Announced 

Inspection Dates: 9/19-20/05 Inspector: CH 

File No.: 33 

Licensee: International Uranium Corporation (White Mesa Mill) License No.: UT1900479 

Inspection Type: Routine, Announced 

Inspection Date: 12/05/06 Inspectors : LM, DR 

File No.: 34 

Licensee: International Uranium Corporation (White Mesa Mill) License No.: UT1900479 

Inspection Type: Routine, Announced 

Inspection Date: 7/11/06 Inspectors: LM, DR 
Utah Final Report Page C.6 

Inspection Casework Reviews 

File No.: 35 

Licensee: International Uranium Corporation (White Mesa Mill) License No.: UT1900479 

Inspection Type: Routine, Announced 

Inspection Date: 12/13/06 Inspectors: RN, JH 

File No.: 36 

Licensee: International Uranium Corporation (White Mesa Mill) License No.: UT1900479 

Inspection Type: Routine, Announced 

Inspection Date: 3/14/07 Inspector: RN 

File No.: 37 

Licensee: International Uranium Corporation (White Mesa Mill) License No.: UT1900479 

Inspection Type: Routine, Announced 

Inspection Date: 5/9/07 Inspectors: RN, DH 

 INSPECTOR ACCOMPANIMENTS 

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

Accompaniment No.: 1 

Licensee: Quality Testing & Inspections License No.: UT2500269 

Inspection Type: Special Priority: 1 

Inspection Date: 4/10/07 Inspector: GG 

Accompaniment No.: 2 

Licensee: Mountain West Medical Center License No.: UT2300452 

Inspection Type: Routine Priority: 3 

Inspection Date: 4/11/07 Inspector: DH 

Accompaniment No.: 3 

Licensee: EnergySolutions, LLC License No.: UT2300249 

Inspection Type: Routine, Unannounced 

Inspection Date: 5/3/07 Inspectors: BI, JF 

Accompaniment No.: 4 

Licensee: International Uranium Corporation (White Mesa Mill) License No.: UT1900479 

Inspection Type: Routine, Announced 

Inspection Date: 5/9/07 Inspectors: RN, DH 
 APPENDIX D 

 LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: JANX Integrity Group License No.: UT0600467 

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

Date Issued: 5/27/05 License Reviewer: DH 

File No.: 2 

Licensee: JANX Integrity Group License No.: UT0600472 

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

Date Issued: 3/7/07 License Reviewer: CJ 

File No.: 3 

Licensee: RWM-Utah, Inc. License No.: UT1800308 

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

Date Issued: 11/14/05 License Reviewers: PG, GG 

File No.: 4 

Licensee: City of Eagle Mountain License No.: UT2500503 

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

Date Issued: 6/12/07 License Reviewers: MB, PG 

File No.: 5 

Licensee: Precision Energy Services, Inc. License No.: UT2400412 

Type of Action: Amendment Amendment No.: 5 

Date Issued: 2/24/05 License Reviewer: PG 

File No.: 6 

Licensee: IHC Heber Valley Medical Center License No.: UT2600497 

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

Date Issued: 8/22/06 License Reviewer: GG 

File No.: 7 

Licensee: LDS Hospital License No.: UT1800102 

Type of Action: Renewal Amendment No.: 21 

Date Issued: 5/25/06 License Reviewer: JF 

File No.: 8 

Licensee: H & H X-Ray Services, Inc. License No.: UT1800459 

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

Date Issued: 8/31/06 License Reviewer: CJ 
Utah Final Report Page D.2 

Licensing Casework Reviews 

File No.: 9 

Licensee: IHC Southwest Cardiology License No.: UT2700419 

Type of Action: Renewal Amendment No.: 9 

Date Issued: 2/4/05 License Reviewer: DH 

Comment: 

Licensee=s compliance history was not documented. 

File No.: 10 

Licensee: Mountain West Cardiovascular Associates, PC License No.: UT1800319 

Type of Action: Renewal Amendment No.: 21 

Date Issued: 10/16/06 License Reviewer: DH 

File No.: 11 

Licensee: Schlumberger Technology Corporation License No.: UT2400065 

Type of Action: Renewal Amendment No.: 17 

Date Issued: 5/2/05 License Reviewer: GG 

File No.: 12 

Licensee: Geneva Steel Safety Department License No.: UT2500292 

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

Date Issued: 9/12/03 License Reviewer: CJ 

File No.: 13 

Licensee: H & H X-Ray Services, Inc. License No.: UT1800459 

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

Date Issued: 8/15/03 License Reviewer: GG 

File No.: 14 

Licensee: Intermountain Medical Center License No.: UT1800494 

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

Date Issued: 5/25/07 License Reviewer: GG 

File No.: 15 

Licensee: Nuclear Apothecary, Inc. License No.: UT2700464 

Type of Action: Amendment Amendment No.: 3 

Date Issued: 8/30/05 License Reviewer: GG 

File No.: 16 

Licensee: Universal Testing, LLC License No.: UT0600125 

Type of Action: Renewal Amendment No.: 10 

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

Comment: 

Licensee=s compliance history was not documented. 
Utah Final Report Page D.3 

Licensing Casework Reviews 

File No.: 17 

Licensee: Simplot Phosphates, LLC License No.: UT2400201 

Type of Action: Renewal Amendment No.: 14 

Date Issued: 6/26/06 License Reviewer: PG 

Comment: 

Licensee=s compliance history was not documented. 

File No.: 18 

Licensee: Ogden Regional Medical Center License No.: UT2900060 

Type of Action: Renewal Amendment No.: 30 

Date Issued: 4/5/06 License Reviewer: PG 

Comment: 

Licensee=s compliance history was not documented. 

File No.: 19 

Licensee: Isomedix Operations, Inc. License No.: UT1800074 

Type of Action: Renewal Amendment No.: 18 

Date Issued: 4/8/05 License Reviewer: JF 

Comment: 

Licensee=s compliance history was not documented. 

File No.: 20 

Licensee: Utah Power & Light License No.: UT1800136 

Type of Action: Renewal Amendment No.: 13 

Date Issued: 5/4/05 License Reviewer: DH 

Comment: 

Licensee=s compliance history was not documented. 

File No.: 21 

Licensee: URS Corporation License No.: UT1800410 

Type of Action: Amendment Amendment No.: 6 

Date Issued: 2/21/07 License Reviewer: PG 

File No.: 22 

Licensee: Gamma West Brachytherapy, LLC License No.: UT2700488 

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

Date Issued: 12/21/05 License Reviewer: DH 
Utah Final Report Page D.4 

Licensing Casework Reviews 

File No.: 23 

Licensee: Salt Lake Regional Medical Center, Inc. License No.: UT1800165 

Type of Action: Renewal Amendment No.: 52 

Date Issued: 11/7/05 License Reviewer: GG 

Comment: 

Licensee=s compliance history was not documented. 

File No.: 24 

Licensee: Utah State University License No.: UT1800319 

Type of Action: Amendment Amendment No.: 30 

Date Issued: 8/4/06 License Reviewer: GG 

File No.: 25 

Licensee: University of Utah Radiological Health License No.: UT1800145 

Type of Action: Renewal Amendment No.: 14 

Date Issued: 11/1/04 License Reviewer: PG 

File No.: 26 

Licensee: EnergySolutions, LLC License No.: UT2300249 

Type of Action: Renewal Amendment No.: Pending 

Date Issued: Pending License Reviewers: JH, LM 

File No.: 27 

Licensee: Denison Mines B (White Mesa Uranium Mill) License No.: UT1900479 

Type of Action: Amendment Amendment No.: 2 

Date Issued: 4/11/07 License Reviewers: Multiple 

File No.: 28 

Licensee: SXR Uranium One Utah, Inc. License No.: UT0900480 

Type of Action: Amendment Amendment No.: 4 (Pending) 

Date Issued: Pending License Reviewers: Multiple 
APPENDIX E 

 INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT ARE INCLUDED FOR COMPLETENESS 

ONLY 

File No.: 1 

Licensee: Utah Valley Regional Medical Center License No.: UT2500129 

Date of Incident: 8/15/03 Event No.: 030751 

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

 Type of Investigation: Telephone/Licensee=s Report 

Comment: 

No on-site investigation was conducted. 

File No.: 2 

Licensee: Mountain View Hospital License No.: UT2500098 

Date of Incident: 9/30/04 Event No.: 040715 

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

 Type of Investigation: Telephone/Licensee=s Report 

Comment: 

No on-site investigation was conducted. 

File No.: 3 

Licensee: LDS Hospital License No.: UT1800102 

Date of Incident: 10/26/04 Event No.: 040780 

Investigation Date: 11/3/04 Type of Incident: Medical Event 

 Type of Investigation: Telephone/Licensee=s Report 

Comments: 

a) This incident was reported to Congress as an Abnormal Occurrence. 

b) No on-site investigation was conducted. 

File No.: 4 

Licensee: Kennecott Utah Copper License No.: UT1800289 

Date of Incident: 2/18/05 Event No.: 050291 

Investigation Date: 2/18/05 Type of Incident: Equipment Failure 

 Type of Investigation: Licensee=s Report 
Utah Final Report Page E.2 

Incident Casework Reviews 

File No.: 5 

Licensee: University of Utah License No.: UT1800001 

Date of Incident: 8/4/05 Event No.: 050550 

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

 Type of Investigation: Licensee=s Report 

Comments: 

a) This incident was reported to Congress as an Abnormal Occurrence. 

b) No on-site investigation was conducted. 

File No.: 6 

Licensee: University of Utah License No.: UT1800001 

Date of Incident: 5/12/05 Event No.: 050743 

Investigation Dates: 12/7-9/05 Type of Incident: Lost Material 

 Type of Investigation: On-site 

File No.: 7 

Licensee: Alpha Testing Labs License No.: UT1800485 

Date of Incident: 2/23/06 Event No.: 060226 

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

 Type of Investigation: Licensee=s Report 

Comment: 

No on-site investigation was conducted. 

File No.: 8 

Licensee: Superior Well Services, Inc. License No.: UT2400489 

Date of Incident: 8/17/06 Event No.: 060525 

Investigation Dates: 8/22-23/06 Type of Incident: Theft/Lost Material 

 Type of Investigation: On-site 

File No.: 9 

Licensee: Alpha Testing Labs License No.: UT800485 

Date of Incident: 8/21/06 Event No.: 060536 

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

 Type of Investigation: Licensee=s Report 

Comment: 

No on-site investigation was conducted. 

File No.: 10 

Licensee: McKay Dee Hospital License No.: UT2900147 

Date of Incident: 6/19/06 Event No.: 060540 

Investigation Date: 7/17/06 Type of Incident: Medical Event 

 Type of Investigation: Routine Inspection 
Utah Final Report Page E.3 

Incident Casework Reviews 

File No.: 11 

Licensee: Applied Geotechnical Engineering Consultants, PC License No.: UT1800298 

Date of Incident: 12/6/06 Event No.: 060746 

Investigation Date: 1/23/07 Type of Incident: Lost Material 

 Type of Investigation: On-site 

File No.: 12 

Licensee: Shaw Pipeline Services License No.: OK-23193-01 

Date of Incident: 1/15/07 Event No.: 070045 

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

 Type of Investigation: Telephone/Licensee=s Report 

Comment: 

No on-site investigation was conducted. 

File No.: 13 

Licensee: Utah Power and Light Co. License No.: UT1800163 

Date of Incident: 4/2/07 Event No.: 070207 

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

 Type of Investigation: Telephone/Licensee=s Report 

File No.: 14 

Licensee: Applied Geotechnical Engineering Consultants PC License No.: UT1800298 

Date of Incident: 5/18/07 Event No.: 070308 

Investigation Date: 5/18/07 Type of Incident: Lost Material 

 Type of Investigation: On-site 

File No.: 15 

Licensee: Schlumberger Technology Corporation License No.: UT2400065 

Date of incident: 5/10/07 Event No.: UT-07-0003 

Investigation Date: N/A Type of Incident: Abandoned Well-logging Source 

 Type of Investigation: Telephone/Licensee=s Report 

File No.: 16 

Licensee: Utah Inspections, LCC License No.: CO-1043-01 

Date of Incident: 12/1/04 Event No.: 040063 

Investigation Date: N/A Type of Incident: Overexposure 

 Type of Investigation: Telephone/Licensee=s Report 
 ATTACHMENT 

 August 2, 2007, Letter from Dane Finerfrock 

 Utah=s Response to Draft IMPEP Report 

 ADAMS: ML072190525