December 27, 2007 

Mr. Thomas Newton, Director 

Iowa Department of Public Health 

Lucas State Office Building 

321 East 12th Street 

Des Moines, Iowa 50319 

Dear Mr. Newton: 

On December 4, 2007, the Management Review Board (MRB) met to consider the proposed 

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

Agreement State Program. The MRB found the Iowa 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 9, of the enclosed final report contains a summary of the IMPEP review team=s 

findings and recommendation. We request your evaluation and response to the 

recommendation within 30 days from receipt of this letter. 

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

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

scheduled for September 2009. 

I appreciate the courtesy and cooperation extended to the IMPEP team during the review. 

I also wish to acknowledge your continued support for the Agreement State Program. I look 

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

Sincerely, 

 /RA/ 

Martin J. Virgilio 

Deputy Executive Director for Materials, Waste, 

Research, State, Tribal, and Compliance Programs 

Office of the Executive Director for Operations 

Enclosure: 

Iowa Final IMPEP Report 

cc w/encl.: Melanie Rasmusson, Chief 

 Iowa Bureau of Radiological Health 

 Dennis O’Dowd, New Hampshire 

 Organization of Agreement States 

 Liaison to the MRB 
December 27, 2007 

Mr. Thomas Newton, Director 

Iowa Department of Public Health 

Lucas State Office Building 

321 East 12th Street 

Des Moines, Iowa 50319 

Dear Mr. Newton: 

On December 4, 2007, the Management Review Board (MRB) met to consider the proposed 

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

Agreement State Program. The MRB found the Iowa 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 9, of the enclosed final report contains a summary of the IMPEP review team=s 

findings and recommendation. We request your evaluation and response to the 

recommendation within 30 days from receipt of this letter. 

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

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

scheduled for September 2009. 

I appreciate the courtesy and cooperation extended to the IMPEP team during the review. 

I also wish to acknowledge your continued support for the Agreement State Program. I look 

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

Sincerely, 

 /RA/ 

Martin J. Virgilio 

Deputy Executive Director for Materials, Waste, 

Research, State, Tribal, and Compliance Programs 

Office of the Executive Director for Operations 

Enclosure: 

Iowa Final IMPEP Report 

cc w/encl.: Melanie Rasmusson, Chief 

 Iowa Bureau of Radiological Health 

 Dennis O’Dowd, New Hampshire 

 Organization of Agreement States 

 Liaison to the MRB 

Distribution: See next page. EDATS: FSME-2007-0038 

 ML073390030 

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

NAME ATMcCraw:kk ADWhite RJLewis CPoland 

DATE 12/5/07 12/5/07 12/5/07 12/5/07 

OFFICE FSME DEDMRT 

NAME CLMiller MJVirgilio 

DATE 12/17/07 12/27/07 

OFFICIAL RECORD COPY
Letter to Thomas Newton from Martin J. Virgilio dated December 27, 2007 

Distribution: 

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EDO RF 

RidsEdoMailCenter 

RidsFsmeOd 

RidsSecyCorrespondenceMailCenter Chairman Klein 

KLukes, FSME/DMSSA Commissioner Jaczko 

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KNull, RIII 

Mark Light, OH 

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KCyr, OGC 

FCameron, OGC 

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APowell, OCA (2 copies) 
INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

REVIEW OF THE IOWA AGREEMENT STATE PROGRAM 

September 11-14, 2007 

FINAL REPORT

ENCLOSURE 
Iowa Final Report Page 1 

1.0 INTRODUCTION 

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

was conducted during the period of September 11-14, 2007, by a review team comprised of 

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

Ohio. 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 August 1, 2003, to September 14, 2007, were discussed with Iowa 

managers on the last day of the review. 

A draft of this report was issued to Iowa for factual comment on October 12, 2007. The State 

responded by e-mail on October 19, 2007, from Melanie Rasmusson, Chief, Bureau of 

Radiological Health (the Bureau). A copy of the State’s response is included as the Attachment 

to this report. The Management Review Board (MRB) met on December 4, 2007, to consider 

the proposed final report. The MRB found the Iowa Agreement State Program to be adequate to 

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

The Iowa Agreement State Program is administered by the Department of Public Health (the 

Department). The Department Director is appointed by and reports directly to the Governor. 

The Division of Environmental Health (the Division), within the Department, houses the Bureau, 

which implements the radioactive materials program. Organization charts for the Department 

and the Division are included as Appendix B. 

At the time of the review, the Bureau regulated 175 specific licenses authorizing Agreement 

materials. The review focused on the radioactive materials program as it is carried out under the 

Section 274b. (of the Atomic Energy Act of 1954, as amended) Agreement between the NRC 

and the State of Iowa. 

In preparation for the review, a questionnaire addressing the common and applicable noncommon performance indicators was sent to the Bureau on June 8, 2007. The Bureau provided 

its response to the questionnaire on July 20, 2007. A copy of the questionnaire response may 

be found in the NRC’s Agencywide Documents Access and Management System (ADAMS) 

using the Accession Number ML072610135. 

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

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

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

review of selected regulatory actions; (5) three field accompaniments of two Iowa inspectors; 

and (6) interviews with staff and managers to answer questions or clarify issues. The review 

team evaluated the information gathered against the established criteria for each common and 

applicable non-common performance indicator and made a preliminary assessment of the 

Agreement State program’s performance. 

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

during the previous review. Results of the current review for the common performance 
Iowa Final Report Page 2 

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

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

findings and recommendation. Recommendations made by the review team are comments that 

relate directly to program performance by the State. A response is requested from the State to 

the recommendation in the final report. 

2.0 STATUS OF ITEMS IDENTIFIED IN PREVIOUS REVIEWS 

During the previous IMPEP review, which concluded on August 1, 2003, the review team made 

no recommendations in regard to program performance. 

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 included staffing levels and turnover, in addition 

to staff technical qualifications and training histories. To evaluate these issues, the review team 

examined the Bureau’s questionnaire response relative to this indicator; interviewed managers 

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 Bureau is comprised of seven regulatory programs, one of which is the Radioactive 

Materials Program (the Program). The Program is responsible for radioactive materials 

licensing, inspection, and emergency response activities. At the time of the review, the Program 

employed two technical staff members and one administrative staff member. The technical staff 

members perform licensing and inspection activities. A former staff member, who currently 

works in the X-Ray Program, could be called upon to provide assistance to the Program, if 

needed. 

The review team noted that staffing levels did not present any performance issues affecting 

implementation of the Agreement State program; however, loss of a technical staff member 

could potentially impact the Bureau’s ability to remain current on all regulatory actions. This 

potential vulnerability was discussed with Department managers, who acknowledged the issue 

and indicated that they would assess staffing needs. 

The Program’s staffing was stable over the review period. The former Bureau Chief retired in 

November 2006, and one technical staff member transferred to the X-Ray Program in April 

2007. The current Bureau Chief joined the program in February 2007. At the time of the review, 

there were no vacancies in the Program. 

The Bureau has a documented training plan consistent with the guidance in the 

NRC/Organization of Agreement States Training Working Group Report and the NRC’s 
Iowa Final Report Page 3 

Inspection Manual Chapter (IMC) 1246, “Formal Qualification Programs in the Nuclear Material 

Safety and Safeguards Program Area.” The review team reviewed the Bureau’s qualification 

process and noted that the training program consisted of classroom instruction, on-the-job 

training, and in-house instruction. Qualification journals were maintained for each technical staff 

member. The Bureau Chief was supportive of and actively identified staff training opportunities. 

The Bureau has three staff members who attended the NRC’s Security Systems and Principles 

Course and were qualified to perform Increased Controls inspections. The review team 

concluded that the Bureau has an adequate, well-balanced, and adequately trained staff to carry 

out its regulatory responsibilities. 

The review team noted that the Bureau was adequately funded. The Bureau is authorized to 

assess and collect fees for specific and general radioactive materials licenses, radiation 

machine registrations, industrial radiographer certifications, and medical radiological 

technologist certifications. As of July 2007, fees are deposited into a dedicated Bureau fund. 

The Department collects fees for the transportation of radioactive materials through the State. 

This fee was implemented to fund training for first responders who are responsible for 

responding to transportation accidents involving radioactive materials. Radiological training for 

first responders is performed by Bureau personnel. 

The State Board of Health (the Board) is the policy making body for the Department. Its duties 

include the adoption and implementation of rules and regulations. The Board is comprised of 

nine members, five with experience in health-related disciplines and four representing the 

general public. The Department Director serves as Secretary of the Board. Iowa regulations 

prohibit Board members from engaging in outside employment or activities that are in conflict 

with the individual’s official duties or responsibilities. 

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

that Iowa’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 Bureau’s questionnaire response relative to this indicator, data gathered from the 

Bureau’s database, examination of completed inspection casework, and interviews with 

managers and staff. 

The review team verified that the Bureau’s inspection priorities for various license types were at 

least as frequent as similar license types listed in IMC 2800, “Materials Inspection Program.” 

Thirteen of the 15 license categories established by the Bureau were assigned inspection priority 

codes that resulted in a more frequent inspection schedule than those established in IMC 2800. 

The review team determined that the Bureau conducted approximately 110 Priority 1, 2, and 3 

inspections and 26 initial inspections during the review period. None of these inspections were 

performed overdue by more than 25 percent of the inspection priorities listed in IMC 2800, nor 

were any inspections overdue at the time of the review. 
Iowa Final Report Page 4 

To evaluate the Bureau’s timeliness in providing inspection findings to licensees, the review 

team examined 20 inspection reports, covering a cross-section of the staff, and determined that 

inspection findings were consistently communicated to licensees less than 30 days after the 

inspection. 

Over the review period, the Bureau granted 163 reciprocity permits that were candidates for 

inspection based on the criteria in IMC 1220, “Processing of NRC Form 241 and Inspection of 

Agreement State Licensees Operating under 10 CFR 150.20.” The review team determined that 

the Bureau met or exceeded the goal of inspecting 20 percent of all candidate licensees 

operating under reciprocity in each of the four years covered by the review period. 

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

Controls inspections of affected licensees. The review team evaluated the Bureau’s prioritization 

methodology and found it acceptable. The Bureau identified 13 licensees who are subject to the 

Increased Controls and elected to perform all inspections by December 2006. The review team 

noted that all initial Increased Controls inspections and 10 followup inspections had been 

completed at the time of the review. 

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

that Iowa’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 inspectors for 20 radioactive materials inspections conducted during the 

review period. The casework examined included a cross-section of inspections conducted by 

three Bureau inspectors and covered a wide variety of inspection types, including: broad scope 

medical, industrial radiography, self-shielded irradiators, nuclear pharmacy, Increased Controls, 

and reciprocity. Appendix C lists the inspection casework files reviewed, 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 the licensees’ radiation safety programs. The review team found that inspection 

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

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

security were acceptable. Inspection report documentation supported violations, verbal 

exchanges, unresolved safety issues, and discussions held with licensees during exit interviews. 

The inspection procedures utilized by the Bureau are consistent with the inspection guidance 

found in IMC 2800. After the inspectors complete inspection reports, the reports are peer 

reviewed prior to being reviewed and signed by the Bureau Chief. Once signed, completed 

actions are promptly sent to the licensee. Findings were clearly stated and documented. The 

review team also noted that inspection correspondence involving the Increased Controls was 

appropriately labeled as sensitive information and withheld from public disclosure. 
Iowa Final Report Page 5 

The Bureau requires licensees to respond to any violations within 30 days of issuance of a 

Notice of Violation. Before a Notice of Violation is issued, the Bureau contacts the licensee via 

telephone to ensure the licensee clearly understands the cited violations and is initiating 

corrective actions. This helps ensure that licensees respond to any cited violations in a timely 

manner. All licensee responses are reviewed for adequacy by the inspector and the Bureau 

Chief. Additionally, even prior to telephone discussions with licensees, the Bureau implements a 

practice to discuss potential Notice of Violation with licensees during the exit interviews following 

inspections. The review team recommended, and the MRB agreed, that the State’s practice of 

contacting licensees prior to issuance of Notice of Violations are issued be identified as a good 

practice. 

The review team noted that supervisor accompaniments of the inspection staff had not been 

consistently performed over the review period; however, all accompaniments had been brought 

up to date at the time of review. New procedures have been implemented to ensure that staff is 

accompanied at least annually. 

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

calibrated survey instrumentation to support its inspection program, as well as to respond to 

radioactive materials incidents and emergency conditions. The majority of survey instruments 

are calibrated by the Emergency Management Division Calibration Laboratory at 6-month 

intervals. The remaining instruments are sent to the manufacturer for calibration. 

The review team accompanied two of the Bureau’s inspectors during the week of August 27, 

2007. Health and safety and Increased Controls inspections were performed at a self-shielded 

irradiator and an industrial radiography facility; and a health and safety inspection was performed 

at a nuclear pharmacy. Both 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 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 Iowa’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 

18 specific licenses. Licensing actions were reviewed for completeness, consistency, proper 

radioisotopes and quantities, qualifications of authorized users, adequate facilities and 

equipment, adherence to good health physics practices, financial assurance, operating and 

emergency procedures, appropriateness of license conditions, 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 

casework was checked for retention of necessary documentation and supporting data. 
Iowa Final Report Page 6 

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

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

new licenses, eight renewals, two amendments, and five license terminations. Files reviewed 

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

high dose-rate remote afterloaders), industrial radiography, portable and fixed gauges, academic 

and medical broad scope, research and development, and nuclear pharmacies. A listing of the 

licensing casework reviewed can be found in Appendix D. 

The review team noted that licensing actions were generally thorough, complete, consistent, and 

of high quality, with health, safety, and security properly addressed. License conditions were 

clearly stated and supported by information contained in the license file. Licenses and 

correspondence were created using a standardized format, which included standardized license 

conditions. Licensing staff appropriately used the Bureau’s licensing guides and policies. When 

appropriate, licensees’ compliance histories were taken into account during licensing actions. 

After a licensing action is initially completed by the license reviewer, a peer review of the action 

is performed. A final review is performed by the Bureau Chief. The license reviewer then signs 

out the action, and a concurrence signature by the Bureau Chief is attached. Licenses are 

issued for a 5-year term and can continue under timely renewal until the Bureau issues a 

renewed license. At the time of the review, the Bureau had six open licensing actions, with five 

of the six having been received in August or September 2007. All were on track to meet the 

Bureau’s 30-day goal for processing licensing actions. A new license application was also 

pending completion at the time of the review and was expected to be issued by the end of 

October 2007. 

The review team evaluated the Bureau’s decommissioning financial assurance program and 

noted that the Bureau had identified nine licensees who are required to comply with Iowa’s 

financial assurance requirements. During the review of licensing casework, the review team 

identified an original financial assurance document in the license file. Two other license files 

contained only copies of the original financial assurance documents. The remainder of the files 

reviewed did not reveal either originals or copies of any financial assurance documents. The 

review team discussed the necessity of securing original financial assurance documents with 

Bureau staff and managers, and later with Department managers. The review team 

recommends that the State evaluate their decommissioning financial assurance program to 

identify and secure original financial assurance documentation from current and future licensees 

who are required to comply with Iowa’s financial assurance requirements. 

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

appropriate material transfer and survey records. The review team noted that confirmatory 

surveys were conducted when appropriate. 

Bureau staff conducts pre-licensing visits of new licensees to verify compliance with the 

Increased Controls requirements before a new license is issued. Pre-licensing visits of other 

licensees were not routinely being performed at the time of the review. 

The review team examined the Bureau’s licensing practices in regard to the Increased Controls. 
Iowa Final Report Page 7 

The team noted that the Bureau added legally-binding license conditions to the licenses that met 

the criteria for implementing the Increased Controls. The review team reviewed the Bureau’s 

methodology for identifying those licenses and found the rationale was thorough and accurate, 

and that the Bureau had correctly identified those licenses requiring compliance with the 

Increased Controls. In May 2006, the Bureau amended their regulations to incorporate 

requirements for the Increased Controls and have removed the license conditions from affected 

licenses. 

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

that Iowa’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 Bureau’s actions in responding to incidents and 

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

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

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

eight radioactive materials incidents. A listing of the casework examined, with case-specific 

comments, can be found in Appendix E. The review team also evaluated the Bureau’s response 

to six allegations involving radioactive materials, including two allegations referred to the State 

by the NRC during the review period. 

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

equipment, overexposures, and equipment failures. When notification of an incident is received, 

the Bureau Chief and staff determine the appropriate level of initial response. The review team 

determined that the Bureau’s response to incidents was complete and comprehensive. Initial 

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

health and safety significance. The Bureau dispatched inspectors for on-site investigations in 

appropriate situations and took suitable enforcement and follow-up actions when necessary. 

The review team identified 11 radioactive materials incidents in NMED for Iowa during the review 

period of which eight required reporting. The review team evaluated the Bureau’s timeliness in 

reporting incidents and found that, following notification from the licensee, the Bureau reported 

six of the eight incidents within the required time frame. Of the remaining two cases, one 

incident was not initially reported to the NRC Headquarters Operations Center due to confusion 

over jurisdiction, because the incident occurred directly on the State border with Minnesota. 

Only after Minnesota responded to the incident was it determined that the site was actually on 

the Iowa side of the border. The other case was an oversight and resulted in the event 

information not being submitted for inclusion in NMED. The Bureau reported these two events 

to the NRC Headquarters Operations Center while the review team was on site. 

Bureau staff members incorporate incident information into their incident database and provide 

that information electronically to the NRC’s contractor responsible for maintaining NMED. The 

database is updated as needed. The review team found that incident information in NMED for 

Iowa was up to date and complete, with the exception of the one incident noted above. 

In evaluating the effectiveness of Iowa's response to allegations, the review team evaluated the 
Iowa Final Report Page 8 

casework for two NRC referred allegations, as well as four other allegations reported directly to 

the State during the review period. The team’s review found that the Bureau took prompt and 

appropriate action in response to all concerns raised. All of the allegations reviewed were 

appropriately closed, and affected individuals were notified of the actions taken. Although the 

Bureau makes every effort to protect an alleger’s identity, Iowa law requires that public 

documents be made available upon request. 

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

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

Allegation Activities, was satisfactory. 

4.0 NON-COMMON PERFORMANCE INDICATORS 

IMPEP identifies four non-common performance indicators to be used in reviewing Agreement 

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

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

Program. Iowa’s Agreement does not cover a sealed source and device evaluation program, a 

low-level radioactive waste disposal program, or a uranium recovery program, so only the first 

non-common performance indicator was applicable to this review. 

4.1 Compatibility Requirements

4.1.1 Legislation

Iowa became an Agreement State on January 1, 1986. The statutory authority for the program 

is found in Iowa Code, Chapter 136C. The Department is designated as the State’s radiation 

control agency and the Bureau 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 Iowa Regulations for Control of Radiation are found in Iowa Administrative Code, Section 

641, Chapters 38-45, and apply to radioactive materials and devices designed to produce 

radiation. The Bureau requires a license for possession and use of all radioactive material, 

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

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

approximately 5 months after filing the draft administrative rule with the State Rules Coordinator 

until a final rule is adopted. Draft rules are published in the State Administrative Bulletin and a 

public hearing is scheduled. Rules are presented to the Board prior to being adopted. The 

State has Emergency Rule capability if public health and safety are at risk. State rules and 

regulations are not subject to “sunset” laws. 

Proposed rules are sent to impacted licensees for comment and to NRC for compatibility review. 

Comments are considered and incorporated, as appropriate, before rules are finalized. The 

State has the authority to issue legally-binding requirements (e.g., license conditions) until 

equivalent State rules become effective. 
Iowa Final Report Page 9 

The review team evaluated the Bureau’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’ State 

Regulation Status Sheet. 

Since the previous review, the State has adopted 21 regulation amendments. The review team 

noted that, with the most recent rulemaking package, the State is up to date on all NRC 

amendments. The State submitted a package for a compatibility review of final regulations on 

July 12, 2007. The NRC transmitted the results of the compatibility review via letter on 

September 24, 2007. As a result of the review, the NRC identified 11 comments on the final 

regulations. 

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

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

satisfactory. 

5.0 SUMMARY 

As noted in Sections 3.0 and 4.0, Iowa’s performance was found to be satisfactory for all six 

performance indicators reviewed. The review team made one recommendation regarding 

program performance and identified one good practice. Accordingly, the review team 

recommended, and the MRB agreed, that the Iowa 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 recommendation for evaluation and implementation by the state, as appropriate, 

and the good practice, as mentioned earlier in the report. 

The review team recommends that the State evaluate their decommissioning financial 

assurance program to identify and secure original financial assurance documentation from 

current and future licensees who are required to comply with Iowa’s financial assurance 

requirements. (Section 3.4) 

The review team identified the State’s practice of contacting licensees prior to issuance of Notice 

of Violation as a good practice. (Section 3.3) 
LIST OF APPENDIXES AND ATTACHMENT 

Appendix A IMPEP Review Team Members 

Appendix B Iowa Organization Charts 

Appendix C Inspection Casework Reviews 

Appendix D License Casework Reviews 

Appendix E Incident Casework Reviews 

Attachment October 19, 2007, E-mail from Melanie Rasmusson 

 Iowa’s Response to Draft IMPEP Report 
APPENDIX A 

IMPEP REVIEW TEAM MEMBERS 

Name Area of Responsibility

Randy Erickson, Region IV Team Leader 

 Compatibility Requirements 

James Lynch, Region III Technical Staffing and Training 

 Technical Quality of Incident and Allegation 

 Activities 

Mark Light, Ohio Status of Materials Inspection Program 

 Technical Quality of Inspections 

Anthony Gaines, Region IV Inspector Accompaniments 

Kevin Null, Region III Technical Quality of Licensing Actions 
APPENDIX B 

IOWA ORGANIZATION CHARTS 

ADAMS ACCESSION NO.: ML072610081 

PAGES 1 and 6 
APPENDIX C 

INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: Keokuk Steel Casings License No.: 0341-1-56-IR2 

Inspection Type: Routine/Special, Unannounced Priority: 2 

Inspection Date: 8/1/07 Inspector: RD 

File No.: 2 

Licensee: Stork Twin City Testing License No.: 0316-1-77-IR1 

Inspection Type: Routine/Special, Unannounced Priority: 1 

Inspection Date: 8/28/07 Inspector: RD 

File No.: 3 

Licensee: WOS Testing, Inc License No.: 0253-1-57-IR1 

Inspection Type: Special, Unannounced Priority: 1 

Inspection Date: 8/14/07 Inspector: RD 

File No.: 4 

Licensee: Cardinal Health, Inc License No.: 0043-1-77-NP 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Dates: 8/29/07 Inspector: NF 

File No.: 5 

Licensee: Iowa State University License No.: 0014-1-85-AAB 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 6/8/05 Inspector: NF 

File No.: 6 

Licensee: Trinity Medical Center-Terrace Park License No.: 0118-1-82-M1 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 5/2/07 Inspector: RD 

File No.: 7 

Licensee: The Blood Center of Central Iowa License No.: 0133-1-77-I1 

Inspection Type: Routine/Special, Unannounced Priority: 5 

Inspection Date: 8/30/07 Inspector: NF 

File No.: 8 

Licensee: Advanced Diagnostic Imaging, Inc. License No.: 0335-1-07-M1 

Inspection Type: Initial, Unannounced Priority: 3 

Inspection Date: 2/21/06 Inspector: RD 
Iowa Final Report Page C.2 

Inspection Casework Reviews

File No.: 9 

Licensee: Mercy Medical Center License No.: 0339-1-57-HDR 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 10/3/06 Inspector: NF 

File No.: 10 

Licensee: Fansteel-Wellman Dynamics Corporation License No.: 0103-1-88-SM1 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 6/19/06 Inspector: DM 

File No.: 11 

Licensee: Iowa Methodist Medical Center. License No.: 0077-1-77-M1 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 1/24/07 Inspector: NF 

File No.: 12 

Licensee: University of Iowa License No.: 0037-1-52-AAB 

Inspection Type: Routine/Special, Unannounced Priority: 2 

Inspection Date: 10/12/06 Inspectors: RD, NF 

File No.: 13 

Licensee: Genesis Medical Center License No.: 0286-1-82-GK 

Inspection Type: Routine/Special, Unannounced Priority: 2 

Inspection Date: 7/10/07 Inspector: RD 

File No.: 14 

Licensee: Genesis Medical Center License No.: 0034-1-82-M1 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Dates: 8/23-25/05 Inspector: RD 

File No.: 15 

Licensee: Mercy Medical Center-Des Moines License No.: 0008-1-77-M1 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 6/22/07 Inspector: NF 

File No.: 16 

Licensee: Iowa Methodist Medical Center. License No.: 0310-1-77-HDR 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 8/6/06 Inspector: NF 

File No.: 17 

Licensee: St. Anthony’s Regional Health Center License No.: 0313-1-14-HDR 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 11/1/06 Inspector: DM 
Iowa Final Report Page C.3 

Inspection Casework Reviews

File No.: 18 

Licensee: Team Industrial Services, Inc License No.: 9009-1-00-IR1 

Inspection Type: Reciprocity Priority: 1 

Inspection Date: 9/5/07 Inspector: RD 

File No.: 19 

Licensee: American Engineering Testing, Inc. License No.: 9102-1-00-IR1 

Inspection Type: Reciprocity Priority: 1 

Inspection Date: 8/22/05 Inspector: NF 

File No.: 20 

Licensee: DBI, Incorporated License No.: 9106-1-00-IR1 

Inspection Type: Reciprocity Priority: 1 

Inspection Date: 9/22/06 Inspector: RD 

INSPECTOR ACCOMPANIMENTS 

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

Accompaniment No.: 1 

Licensee: Stork/Twin Cities Testing License No.: 0316-1-77-IR1 

Inspection Type: Routine/Special, Unannounced Priority: 1 

Inspection Date: 8/28/07 Inspector: RD 

Accompaniment No.: 2 

Licensee: Cardinal Health, Inc License No.: 0043-1-77-NP 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 8/29/07 Inspector: NF 

Accompaniment No.: 3 

Licensee: The Blood Center of Central Iowa License No.: 0133-1-77-I1 

Inspection Type: Routine/Special, Unannounced Priority: 5 

Inspection Date: 8/30/07 Inspector: NF 
APPENDIX D 

LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: St. Anthony’s Regional Medical Center License No.: 0313-1-14-HDR 

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

Date Issued: 11/29/05 License Reviewer: RD 

File No.: 2 

Licensee: BASF Plant Sciences, LLC License No.: 0287-1-85-RD2 

Type of Action: Termination Amendment No.: 02 

Date Issued: 3/29/06 License Reviewer: RD 

File No.: 3 

Licensee: Medical Associates of Iowa License No.: 0297-1-23-M2 

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

Date Issued: 4/10/06 License Reviewer: RD 

File No.: 4 

Licensee: Quad City Testing License No.: 0186-1-82-IR1 

Type of Action: Amendment Amendment No.: 01 

Date Issued: 2/3/05 License Reviewer: RD 

File No.: 5 

Licensee: Quality Inspection Services License No.: 0334-1-78-IR1 

Type of Action: Termination Amendment No.: 02 

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

File No.: 6 

Licensee: Blood Center of Central Iowa License No.: 0133-1-77-I1 

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

Date Issued: 10/10/05 License Reviewer: RD 

File No.: 7 

Licensee: Midwest Industrial X-ray License No.: 0075-1-78-IR1 

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

Date Issued: 1/11/05 License Reviewer: RD 

File No.: 8 

Licensee: Pella Regional Health Center License No.: 0032-1-63-M2 

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

Date Issued: 3/2/05 License Reviewer: RD 
Iowa Final Report Page D.2 

License Casework Reviews

File No.: 9 

Licensee: DBI, Inc. License No.: 0350-1-78-IR1 

Type of Action: Pending Issuance Amendment No.: N/A 

Date Issued: N/A License Reviewer: NF 

File No.: 10 

Licensee: AG Processing License No.: 0263-1-74-FG 

Type of Action: Termination Amendment No.: 01 

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

File No.: 11 

Licensee: Construction Materials Testing License No.: 0299-1-77-PG 

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

Date Issued: 3/13/06 License Reviewer: RD 

File No.: 12 

Licensee: Iowa Blood and Cancer Center License No.: 0340-1-57-M2 

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

Date Issued: 3/31/06 License Reviewer: NF 

File No.: 13 

Licensee: Iowa State University License No.: 0014-1-85-AAB 

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

Date Issued: 9/4/06 License Reviewer: NF 

File No.: 14 

Licensee: Quality Inspection Services License No.: 0334-1-78-IR1 

Type of Action: Termination Amendment No.: 02 

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

File No.: 15 

Licensee: Winneshiek Medical Center License No.: 0346-1-96-M2 

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

Date Issued: 2/15/07 License Reviewer: NF 

File No.: 16 

Licensee: Mercy Medical Center License No.: 0073-1-17-M1 

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

Date Issued: 1/30/07 License Reviewer: NF 

File No.: 17 

Licensee: Cardinal Health License No.: 0043-1-77-NP 

Type of Action: Amendment Amendment No.: 04 

Date Issued: 1/30/07 License Reviewer: NF 
Iowa Final Report Page D.3 

License Casework Reviews

File No.: 18 

Licensee: Iowa Cancer Research Center License No.: 0267-1-77-RD2 

Type of Action: Termination Amendment No.: 03 

Date Issued: 4/4/07 License Reviewer: NF 
APPENDIX E 

INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: Midwest Industrial X-Ray, Inc. License No.: 0075-1-78-IR1 

Date of Incident: 5/15/07 NMED No.: 070500 

Investigation Date: 6/13/07 Type of Incident: Damaged Equipment 

 Type of Investigation: Telephone 

Comment: 

 Incident was not reported to the NRC Headquarters Operations Center. 

File No.: 2 

Licensee: Iowa Health-Des Moines License No.: 0077-1-77-M1 

Date of Incident: 6/14/07 NMED No.: 070369 

Investigation Date: 6/14/07 Type of Incident: Overexposure 

 Type of Investigation: Telephone 

File No.: 3 

Licensee: National By-Products Analytical Laboratories License No.: 0113-1-77-GC 

Date of Incident: 11/18/05 NMED No.: 060303 

Investigation Date: 11/18/05 Type of Incident: Lost Source 

 Type of Investigation: Telephone 

File No.: 4 

Licensee: University of Iowa License No.: 0037-1-52-AAB 

Date of Incident: 2/1/05 NMED No.: N/A 

Investigation Dates: 2/23-25/05 Type of Incident: Medical Event 

 Type of Investigation: Site 

Comments: 

a) Incident was not reported to the NRC Headquarters Operations Center. 

b) Incident was not submitted for inclusion in NMED. 

File No.: 5 

Licensee: Mid-American Energy Company License No.: 0100-1-97-FG 

Date of Incident: 3/14/05 NMED No.: 050613 

Investigation Date: 3/15/05 Type of Incident: Damaged Equipment 

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

Incident Casework Reviews

File No.: 6 

Licensee: Quad City Testing Laboratory License No.: 0186-1-78-IR1 

Date of Incident: 9/3/05 NMED No.: 050701 

Investigation Date: 9/5/05 Type of Incident: Damaged Equipment 

 Type of Investigation: Telephone 

File No.: 7 

Licensee: CMT License No.: 0299-1-77-PG 

Date of Incident: 10/10/05 NMED No.: 050693 

Investigation Date: 10/10/05 Type of Incident: Damaged Equipment 

 Type of Investigation: Site 

File No.: 8 

Licensee: University of Iowa License No.: 0037-1-52-AAB 

Date of Incident: 8/29/06 NMED No.: 060588 

Investigation Date: 8/29/06 Type of Incident: Equipment Failure 

 Type of Investigation: Site 
ATTACHMENT 

October 19, 2007, E-mail from Melanie Rasmusson 

Iowa’s Response to Draft IMPEP Report 

ADAMS: ML072880456