December 23, 2010 

Mr. Jimmy D. Givens 

Deputy Executive Director 

Department of Environmental Quality 

707 N. Robinson 

P. O. Box 1677 

Oklahoma City, Oklahoma 73101-1677 

Dear Mr. Givens: 

On November 29, 2010, the Management Review Board (MRB) met to consider the proposed 

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

Agreement State Program. The MRB found the Oklahoma Agreement State Program adequate 

to protect public health and safety and compatible with the U.S. Nuclear Regulatory 

Commission=s (NRC) program. 

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

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

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

meeting tentatively scheduled for September 2012. 

During the periodic meeting and at the next IMPEP review, NRC will evaluate the effectiveness 

of the State’s response to the review team’s recommendations, as well as the overall 

implementation of your 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/ 

Michael F. Weber 

Deputy Executive Director for Materials, Waste, 

 Research, State, Tribal, and Compliance Programs 

Office of the Executive Director for Operations 

Enclosure: 

Oklahoma Final IMPEP Report 

cc: Mike Broderick, Manager 

 Radiation Management Section 
December 23, 2010 

Mr. Jimmy D. Givens 

Deputy Executive Director 

Department of Environmental Quality 

707 N. Robinson 

P. O. Box 1677 

Oklahoma City, Oklahoma 73101-1677 

Dear Mr. Givens: 

On November 29, 2010, the Management Review Board (MRB) met to consider the proposed 

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

Agreement State Program. The MRB found the Oklahoma Agreement State Program adequate 

to protect public health and safety and compatible with the U.S. Nuclear Regulatory 

Commission=s (NRC) program. 

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

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

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

meeting tentatively scheduled for September 2012. 

During the periodic meeting and at the next IMPEP review, NRC will evaluate the effectiveness 

of the State’s response to the review team’s recommendations, as well as the overall 

implementation of your 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/ 

Michael F. Weber 

Deputy Executive Director for Materials, Waste, 

 Research, State, Tribal, and Compliance Programs 

Office of the Executive Director for Operations 

Enclosure: 

Oklahoma Final IMPEP Report 

cc: Mike Broderick, Manager 

 Radiation Management Section 

DISTRIBUTION: See next page 

ADAMS ACCESSION NUMBER: ML103350315 EDATS: FSME-2010-0319 

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

NAME MOrendi DWhite TReis RLewis 

DATE 12/02/10 12/02/10 12/07/10 12/10/10 

OFFICE Tech Editor FSME DEDMRT 

NAME CPoland CMiller MFWeber 

DATE 12/10/10 12/23/10 12/23/10 

OFFICIAL RECORD COPY
Letter to J. Givens from Michael F. Weber dated: 12/23/10 

DISTRIBUTION: EDATS: FSME-2010-0319 

MSSA RF DCD (SP01) 

MSSA_Technical_Asst Resource EDO RF 

RidsEdoMailCenter 

RidsFsmeOd 

RidsSecyCorrespondenceMailCenter Chairman Jaczko 

MBeardsley, FSME/MSSA Commissioner Svinicki 

RBrowder, RIV/RSAO Commissioner Apostolakis 

MArribas-Colon, FSME/MSSA Commissioner Magwood 

JLynch, RIII Commissioner Ostendorff 

David Turberville, AL SECY 

RCaniano, RIV 

KBrock, OEDO 

CMiller, FSME 

BJones, OGC 

JBiggins, OGC 

SReynolds, RIII 

Isabelle Busenitz, KS 

JOlmstead, OGC 

JWeil, OCA (2 copies)
Enclosure 

INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

REVIEW OF THE OKLAHOMA AGREEMENT STATE PROGRAM 

SEPTEMBER 13-17, 2010 

FINAL REPORT
Oklahoma Final Report Page 1 

1.0 INTRODUCTION 

This report presents the results of the review of the Oklahoma Agreement State Program. 

The review was conducted during the period of September 13-17, 2010, by a review team 

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

the State of Alabama. Team members are identified in Appendix A. The review was conducted 

in accordance with the “Implementation of the Integrated Materials Performance Evaluation 

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

Register on October 16, 1997, and NRC Management Directive 5.6, “Integrated Materials 

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

review, which covered the period of June 9, 2006, to September 17, 2010, were discussed with 

Oklahoma managers on the last day of the review. 

A draft of this report was issued to Oklahoma for factual comment on October 13, 2010. The 

State responded by email dated November 15, 2010, from Mike Broderick, Manager, Radiation, 

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

Attachment to this report. The Management Review Board (MRB) met on November 29, 2010, 

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

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

The Oklahoma Agreement State Program is administered by the Section, which is located within 

the Land Protection Division (the Division) of 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 Oklahoma Agreement State Program regulated 242 specific 

licenses authorizing possession and use of radioactive materials. The State of Oklahoma 

became an Agreement State on September 29, 2000. The review focused on the radioactive 

materials program as it is carried out under the Section 274b. (of the Atomic Energy Act of 

1954, as amended) Agreement between NRC and the State of Oklahoma. The Agreement 

includes source material only when it is used to take advantage of the density and high-mass 

property where the use of the specifically licensed source material is subordinate to the primary 

specifically licensed use of either 11e.(1) byproduct material or special nuclear material. 

In preparation for the review, a questionnaire addressing the common and applicable noncommon performance indicators was sent to the Section on May 10, 2010. The Section 

provided its response to the questionnaire on August 31, 2010. A copy of the questionnaire 

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

(ADAMS) using the Accession Number ML102660226. 

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

the Section’s response to the questionnaire, (2) review of applicable Oklahoma statutes and 

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

review of selected regulatory actions, (5) field accompaniments of three inspectors, and 

(6) interviews with staff and managers. The review team evaluated the information gathered 

against the established criteria for each common and the applicable non-common performance
Oklahoma Final Report Page 2 

indicator and made a preliminary assessment of the Oklahoma Agreement State Program’s 

performance. 

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

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

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

 2.0 STATUS OF ITEMS IDENTIFIED IN PREVIOUS REVIEWS 

During the previous IMPEP review, which concluded on June 8, 2006, the review team made 

four recommendations regarding the Oklahoma Agreement State Program’s performance. The 

current status of each recommendation is as follows: 

1. The review team recommends that all inspections be fully documented, and that license 

files be complete and accurate. (Section 3.2 of the 2002 IMPEP report) 

Current Status: The State has taken appropriate measures to assure license files are 

complete and accurate, and inspections are fully documented. Measures included hiring 

experienced administrative personnel to address the inadequate recordkeeping 

identified during previous reviews. This recommendation is closed. 

2. The review team recommends that the State document corrective actions for cited 

violations issued on DEQ Form 410-591. (Section 3.3 of the 2006 IMPEP report) 

Current Status: The review team concluded that the Section has taken appropriate 

measures to review and document all corrective measures for cited violations, including 

violations issued on DEQ Form 410-591. This recommendation is closed. 

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

documentation and appropriate response, review, enforcement, and follow up of all 

radioactive materials incidents. (Section 3.5 of the 2006 IMPEP report) 

Current Status: The review team concluded that the State has done an excellent job of 

responding to radioactive materials incidents, including follow up during subsequent 

inspections and with enforcement tools. Documentation of incidents was found to be 

incomplete, however, and documents were not located in license files as per Section 

policy. This recommendation remains open. (See Section 3.5) 

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

documentation and appropriate tracking and closure of all allegations involving 

radioactive material. (Section 3.5 of the 2006 IMPEP report) 

Current Status: The review team identified that the State could not verify that allegers 

were provided with the results of allegation investigations for two allegations referred to 

the State by the NRC. This recommendation remains open. (See Section 3.5) 
Oklahoma Final Report Page 3 

3.0 COMMON PERFORMANCE INDICATORS 

Five common performance indicators are used to review NRC Regional and Agreement State 

radioactive materials programs. These indicators are: (1) Technical Staffing and Training, 

(2) Status of Materials Inspection Program, (3) Technical Quality of Inspections, (4) Technical 

Quality of Licensing Actions, and (5) Technical Quality of Incident and Allegation Activities. 

3.1 Technical Staffing and Training

Issues central to the evaluation of this indicator include the Section’s staffing level and staff 

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

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

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

considered workload backlogs. 

The Oklahoma Agreement State Program is composed of the Section manager, nine technical 

staff positions (Environmental Program Specialists) and administrative staff. Technical staff 

members conduct inspections, perform licensing actions, and respond to incidents and 

allegations, based on individual qualifications. The technical staff members also have 

responsibilities outside the Agreement State program, notably the regulation of industrial and 

therapeutic x-ray, and radon in Oklahoma. The Section currently devotes approximately 4.8 

technical staff full-time equivalents to administer the Agreement State program. 

At the time of the review, the Section had two Environmental Program Specialist vacant 

positions. One of the vacancies has been open since January 2010 and the other since July 

2010. Since the review, another technical staff member gave notice that he is leaving State 

employment for a higher-paying private sector job. Due to a Department funding shortage, no 

approval to fill the positions has been given to the Section Manager. The Section Manager 

stated that the reason for the shortage is a deficit in program fees, which have not been raised 

since 2004. The Department has initiated a rulemaking process to raise fees to a level that will 

fully fund the Agreement State program after July 2011; however, no definitive approval of this 

rulemaking is guaranteed. 

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

implementation of the Agreement State program; however, continued vacancies could 

potentially impact the Section’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 were researching future staffing solutions. 

The Section has a documented training plan for technical staff that is consistent with the 

requirements in the NRC/Organization of Agreement States Training Working Group Report and 

NRC’s Inspection Manual Chapter (IMC) 1246, “Formal Qualification Programs in the Nuclear 

Material Safety and Safeguards Program Area.” The Section uses on-the-job training, such as 

inspector accompaniments, to supplement formal coursework. Staff members are assigned 

increasingly complex duties as they progress through the qualification process. The Section 

Manager signs off on all staff qualifications, which are documented by the training coordinator in 

staff members’ personal files. The review team noted that the most recently hired technical staff 

members were successfully progressing through the Section’s qualification process. The review 
Oklahoma Final Report Page 4 

team concluded that the Section’s training program is adequate to carry out its regulatory duties 

and noted that Oklahoma management supports the Section training program. 

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

that Oklahoma’s performance with respect to the indicator, Technical Staffing and Training, be 

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

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

Section Manager and staff members. 

The review team verified that the Section’s inspection frequencies for all types of radioactive 

materials licenses are at least the same frequency as those listed in IMC 2800, “Materials 

Inspection Program.” The only major difference noted between IMC 2800 and the Section’s list 

of inspection frequencies was program code 2121 “Medical Institution – WD Not Required,” 

which had a priority code of 3 instead of a priority code of 5 as prescribed by IMC 2800. This 

was discussed with the Section Manager and it was determined that this was an oversight. The 

Section Manager indicated that the program code would be updated to reflect the same priority 

as in IMC 2800. Other differences included program codes identified as telephone notifications 

in IMC 2800 were assigned a priority code of 7 by the Section and decommissioning activities 

identified in IMC 2800 were assigned a priority code of 1 by the Section. The review team also 

verified that the Section conducts inspections of multiple locations of use for multi-site licenses. 

In all instances reviewed by the team, the Section met or exceeded the minimum criterion 

identified in IMC 2800 of sites inspected for licenses with multiple locations of use listed on the 

license. 

The Section indicated in its response to the questionnaire that a total of 198 Priority 1, 2, and 3 

(high priority) inspections were conducted during the review period. The Section initially 

indicated in its response to the questionnaire that 33 of the 198 high priority inspections were 

conducted overdue by more than 25 percent of the inspection frequency prescribed by IMC 

2800. The review team noted that the response to the questionnaire did not include inspection 

numbers for the entire time period since the last review. During the on-site review, the Section 

provided the requested inspection information for the 2006 timeframe, and the review team 

determined that during the review period, a total of 215 Priority 1, 2, and 3 inspections were 

conducted during the review period and 33 of the these inspections were conducted overdue by 

more than 25 percent of the inspection frequency prescribed by IMC 2800. Days overdue 

ranged from 6 to 695 days. The review team verified that no high priority inspections were 

overdue at the time of the review. 

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

review team noted that the Section conducted 42 initial inspections during the review period, of 

which 13 were conducted greater than 12 months after license issuance as prescribed by IMC
Oklahoma Final Report Page 5 

2800. The review team verified that no initial inspections were overdue at the time of the 

review. 

Based on conversations with the manager and staff members, the review team noted that 

during the review period, 15 of the 33 Priority 1, 2 and 3 inspections and 11 of the 13 initial 

inspections conducted overdue were assigned for inspection after they were already due. This 

occurred for a variety of factors including: 

• Initial inspection data that needed to be created by the license reviewer upon issuance 

of a new license was not always performed by the license reviewer. 

• New inspection data that needed to be created by the inspectors following the 

completion of their assigned inspections was not always completed by the inspector. 

• Inspection assignments had been the responsibility of a staff member prior to retirement 

in March, 2007. An incorrect assumption was made by management that inspection 

assignments for the remainder of 2007 had been completed by the individual prior to the 

retirement. This incorrect assumption caused a delay in the assignment of inspection 

responsibilities to inspection staff. 

Overall, the review team calculated that the Section performed 17.9 percent of its Priority 1, 2, 

and 3 and initial inspections overdue during the review period. The review team recognized that 

the Section promptly self identified this problem early in the review period and immediately 

undertook a corrective action program. The review team recommends that the Section take 

appropriate measures to conduct their inspection program in a sustainable manner by 

continuing to implement their corrective action program. 

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

Section has a policy of issuing the inspection findings to licensees within 30 days from the date 

of the inspection. Of the 30 inspection files reviewed, the review team identified four inspection 

findings that were issued beyond the 30-day goal. Days beyond the 30-day goal ranged from 

2 to 18 days. Based on the review of the inspection files, the average time for the issuance of 

inspection findings was approximately 30 days. 

During the review period, the Section granted 109 reciprocity permits, 46 were determined to be 

for Priority 1, 2 and 3 licensees. IMC 1220, “Processing of NRC Form 241 and Inspection of 

Agreement State Licensees Operating Under 10 CFR 150.20,” requires inspection of 20 percent 

of candidate licensees operating under reciprocity annually. The review team determined that 

the Section met or exceeded the criterion of inspecting 20 percent of candidate licensees 

operating under reciprocity in each of the 4 years covered by the review period. 

Based on the IMPEP evaluation criteria, the review team recommended that Oklahoma’s 

performance with respect to the indicator, Status of Materials Inspection Program, be found 

satisfactory, but needs improvement. However, after discussion with regard to Oklahoma’s self 

identification and improved performance, the MRB found that Oklahoma’s performance with 

respect to the indicator, Status of Materials Inspection Program, be found satisfactory. 
Oklahoma Final Report Page 6 

3.3 Technical Quality of Inspections

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

responsible inspector, if possible, for 30 radioactive materials inspections conducted during the 

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

seven current inspectors and three former inspectors, and covered a wide variety of inspection 

types. These included diagnostic nuclear medicine, high dose-rate remote afterloaders, 

industrial radiography, nuclear pharmacy, well logging, research and development, portable and 

fixed gauges, and service providers. The casework included initial, routine, follow-up, 

reciprocity, and Increased Controls inspections. Appendix C lists the inspection casework files 

reviewed. 

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

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

the inspections evaluated Increased Controls, fingerprinting, and the National Source Tracking 

System when appropriate. The review team found that inspection reports were complete, 

consistent, and with sufficient documentation to ensure that the licensees’ performances with 

respect to health, safety, and security were acceptable. Inspection report documentation 

supported violations, recommendations made to licensees, and unresolved safety issues. 

While on site, the review team evaluated the Section’s handling and storing of sensitive 

documents. The review team determined that documents containing sensitive information were 

appropriately protected and maintained in a manner to limit access. 

The Section has a policy to accompany all staff performing radioactive materials inspections on 

an annual basis. The Section Manager performs the inspector accompaniments. It was noted 

that one inspector was not accompanied during the 2007 calendar year and another inspector 

was not accompanied during the 2008 calendar year. The review team verified that all other 

staff members that regularly perform inspections were accompanied annually during the review 

period. To ensure that accompaniments are performed annually for all inspection staff, the 

Section Manager has set a goal to accompany 75 percent of the inspection staff by September 

of each year and has also approved a senior inspector to assist in this function if needed. 

The review team accompanied three of the Section's inspectors during the period of July 13-15, 

2010. The inspectors conducted inspections of a medical therapy licensee, an industrial 

radiography licensee, and a veterinary nuclear medicine licensee. The inspector 

accompaniments are listed in Appendix C. The inspectors demonstrated performance-based 

inspection techniques and knowledge of the regulations. The inspectors were well trained, 

prepared for the inspections, and thorough in their audits of the licensees’ radiation safety and 

security programs. The inspectors conducted interviews with appropriate personnel, observed 

licensed operations, conducted confirmatory measurements, and utilized good health physics 

practices. The review team determined that the inspections were adequate to assess 

radiological health, safety, and security at the licensed facilities. 

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

that Oklahoma’s performance with respect to the indicator, Technical Quality of Inspections, be 

found satisfactory. 
Oklahoma Final Report Page 7 

3.4 Technical Quality of Licensing Actions

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

27 licensing actions for 26 specific licenses. Licensing actions were reviewed for completeness, 

consistency, proper radioisotopes and quantities, qualifications of authorized users, adequacy of 

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

security requirements, operating and emergency procedures, appropriateness of license 

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

appropriate correspondence, reference to appropriate regulations, supporting documentation, 

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

signatures. 

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

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

licenses, eight renewals, nine amendments, and five license terminations. Casework reviewed 

included a cross-section of license types, including: medical and academic broadscope, 

medical institution, nuclear pharmacy, mobile nuclear medicine, industrial radiography, gauges, 

and self-shielded irradiator. A listing of the licensing casework reviewed can be found in 

Appendix D. 

All licensing actions received by the Section are assigned a log number and entered into the 

RADMAN license database tracking system. Once the action is entered into the database, the 

Section Manager reviews the action and assigns it to a license reviewer. All licensing actions 

are reviewed by a peer license reviewer prior to having a final approval and signature by the 

Section Manager. The licensing staff uses formal correspondence to licensees for technical 

notices of deficiencies. The review team assessed that there was not a backlog of licensing 

actions at the time of the review. 

The review team identified several instances where medical licensing actions were authorized 

with incomplete supporting documentation. For example: 

• Physicians were authorized for 10 CFR 35.300 uses when the documentation supported 

only 10 CFR 35.100 and 200 uses or the authorization should have been limited to the 

use of sodium iodide I-131, only, 

• Reviewers accepted specialty board certifications that were dated previous to the 

specialty board certifications recognized by the Commission, 

• Physicians were approved without the required specialty board attestations provided in 

the supporting documentation, 

• A Delegation of Authority was not included with the supporting documentation for a new 

Radiation Safety Officer, 

• A medical physicist and authorized user were authorized for 10 CFR 35.600 materials, 

but did not appear to meet the authorized requirements for high-dose rate 

brachytherapy. 
Oklahoma Final Report Page 8 

The review team recommends that the program retrain its staff to gain increased familiarity with 

the regulations under 10 CFR Part 35 and the appropriate NRC guidance documents for 

medical use authorizations. The Section requested the NRC Region IV office to provide on-site 

training involving medical license requirements to its staff, which the Region IV office is willing to 

support. The review team found this to be an acceptable approach to enhance the medical 

license review training for the Section. 

The review team found that non-medical licensing actions were thorough, complete, consistent, 

and addressed health, safety, and security issues. License tie-down conditions were stated 

clearly, backed by information contained in the file and enforceable. The review team found that 

actions terminating licenses were well documented, included the appropriate material survey 

records, and contained documentation of proper disposal or transfer of radioactive material, as 

appropriate. 

The review team evaluated the financial assurance documents and verified a sampling of the 

calculations and instruments provided for two licensees. The documentation was maintained by 

the Section and it was determined to be appropriate, physically secured, and contained the 

originally signed documents. The review team identified one license condition that allowed the 

cost estimate for a decommissioning funding plan to be adjusted at a 4-year interval rather than 

a 3-year interval, as required by regulation. The Section Manager indicated that they would 

modify the license condition to resolve this oversight. The review team determined that the 

financial assurance documents and determination of licenses that required financial assurance 

were adequate. 

The review team assessed the Section’s implementation of the pre-licensing guidance. The 

Section had implemented the essential elements of NRC’s pre-licensing guidance issued on 

September 22, 2008, and transmitted to the Agreement States via Office of Federal and State 

Materials and Environmental Management Programs (FSME) Letter RCPD-08-020, “Requesting 

Implementation of the Checklist to Provide a Basis for Confidence That Radioactive Material 

Will Be Used as Specified on a License and the Checklist for Risk-Significant Radioactive 

Material.” Based on the files reviewed, the review team determined that the assigned license 

reviewer conducted the respective pre-licensing visit prior to the issuance of the license. The 

pre-licensing checklists were documented sufficiently and the licenses were issued from the 

office under the Section Manager’s signature. 

The Section had initiated the process to address maximum possession limits on radioactive 

materials licenses as requested by RCPD-10-007 letter dated June 21, 2010. The Section had 

identified the licenses affected and had sent letters to the respective licensees requesting 

information for the maximum possession limit authorization. 

The radioactive materials license files were maintained in a secured location that was accessed 

by the records administration staff. The radiation management section had to request the 

license files from the records administration staff. Warning labels on all license files alert staff to 

ensure that files are appropriately reviewed by the Section for sensitive or security-related 

information prior to being released to a member of the public under the State’s Freedom of 

Information laws. The Section decided, during the review, to also mark licensing documents 

that contained sensitive or security-related information, in the same manner that they were 

marking enforcement documents related to increased controls. 
Oklahoma Final Report Page 9 

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

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

Actions, be found satisfactory, but needs improvement. 

3.5 Technical Quality of Incident and Allegation Activities

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

allegations, the review team examined the response to the questionnaire relative to this 

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

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

for 16 of the 23 reported radioactive materials incidents. A listing of the casework examined 

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

allegations (complaints) received during the review period, including three allegations referred to 

the State by the NRC. 

When notified of an incident or an allegation, the Section Manager and inspection staff discuss 

the initial response and the need for an on-site investigation, based on the safety significance. 

If the incident meets the reportability thresholds, as established in FSME Procedure SA-300 

“Reporting Material Events,” the Section notifies the NRC Headquarters Operations Center and 

updates NMED. Of the 16 incidents evaluated by the review team, all but one had been 

reported to NRC within the required time frame. The one incident not reported was a 2008 

medical event. The Section Manager stated that it was an oversight and it would be sent to the 

Headquarters Operations Center. The incident was reported to the Headquarters Operations 

Center on September 24, 2010. 

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

equipment, overexposures, loss of control, contamination, and equipment failures. The review 

team determined that the Section’s responses to incidents were thorough, complete, and 

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

commensurate with the health and safety significance. The Section immediately dispatched 

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

existed. The review team noted that the Section consistently made a strong commitment to 

perform on-site investigations of incidents. 

During the 2006 IMPEP review, the review team recommended that the State take measures to 

ensure proper documentation and appropriate response, review, enforcement, and follow up of 

all radioactive materials incidents. As noted above, the review team determined that the 

Section’s response to incidents during the review period was excellent. Documentation of 

incident investigations, however, was lacking for many of the incidents evaluated by the review 

team. Section policy is to maintain incident records in individual license files. Of the 16 files 

reviewed, six did not have the incident investigation reports or other indications to alert 

inspectors and license reviewers that an incident had occurred at that facility. Investigation 

reports, sometimes in draft form, were often located in inspectors’ personal files. Based on the 

review team’s findings, the recommendation from the 2006 IMPEP review regarding proper 

documentation of incidents will remain open. 

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

evaluated the completed casework for seven allegations. The review team concluded that the 
Oklahoma Final Report Page 10 

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

adequately protected the identity of allegers. The review team noted that the Section thoroughly 

documented the investigations and retained all necessary documentation to appropriately close 

the allegations except that they could not verify that allegers were notified of investigation 

results at the conclusion of one investigation. Based on the review team’s findings, the 

recommendation from the 2006 IMPEP review regarding proper closure of allegations will 

remain open. 

During the review, the Section Manager provided a refresher training session for all staff 

members on the handling of allegations, including the alleger notification component. 

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

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

Allegation Activities, be found satisfactory. 

4.0 NON-COMMON PERFORMANCE INDICATORS 

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

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

Agreement with Oklahoma does not relinquish regulatory authority for a sealed source and 

device evaluation program or a uranium recovery program; therefore, only the other two noncommon performance indicators applied to this review. 

4.1 Compatibility Requirements

4.1.1 Legislation

The Oklahoma Department of Environmental Quality is designated as the State’s radiation 

control agency. The review team did not identify any legislative bills that would affect the 

State’s agreement program that were passed or pending during the review period. 

4.1.2 Program Elements Required for Compatibility

The State=s regulations for radiation management are located in Chapter 410 of the Oklahoma 

Administrative Code, Title 252, and apply to all sources of radiation except materials subject to 

regulation under NRC or a diagnostic x-ray facility regulated by the Oklahoma Department of 

Public Health. Oklahoma regulations require a license for all persons who receive, possess, 

use, transfer, own, handle, dispose, store, house, or acquire sources of radiation. 

The State of Oklahoma adopts NRC regulations by reference with a list of exemptions for those 

regulations for which NRC retains jurisdiction. Historically, the review team has found that 

adopting regulations by reference allows the State to implement regulations quickly and to avoid 

potential compatibility conflicts. 

The Section Manager has the responsibility for maintaining the Oklahoma Radiation 

Management Regulations compatible with NRC regulations. The rule adoption process involves 

hearings before the Radiation Management Advisory Council, which recommends the rule to the 
Oklahoma Final Report Page 11 

Environmental Quality Board. The Board approves or disapproves the proposed amendments. 

If approved by the Board, the State Legislature considers the amendments during their next 

session; however, there is no active legislature approval required. The Governor signs the rule 

or has the authority to veto proposed amendments. The Council usually considers rules in the 

summer or fall, the Board passes them in the winter, and the rule goes into effect in June or July 

of the following year. The State does have the ability to use emergency regulations. 

Emergency regulations can be effected immediately with the Governor=s signature; however, 

they are effective only until the end of the next legislative session. Oklahoma regulations are 

not subject to Asunset@ laws. 

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

legally binding requirements no later than 3 years after the effective date of NRC’s regulations. 

At the time of the review, it was identified that the following five amendments had not been 

reviewed for compatibility by NRC and were considered overdue. The Section had promulgated 

regulations to incorporate the NRC regulations by reference and was implementing the NRC 

regulations dated January 1, 2008. The Section had not, however, submitted the final 

regulations to the NRC for a formal compatibility review. During the IMPEP review, the Section 

submitted the final rule revisions to the NRC for compatibility review. The five overdue 

amendments were: 

• “Financial Assurance for Materials Licensees,” 10 CFR Parts 30, 40, 70 amendment (68 

FR 57327), that was due for Agreement State implementation on December 3, 2006. 

• “Security Requirements for Portable Gauges Containing Byproduct Material,” 

10 CFR Part 30 amendment (70 FR 2001), that was due for Agreement State 

implementation on July 11, 2008. 

• “Medical Use of Byproduct Material – Recognition of Specialty Boards,” 10 CFR Part 35 

amendment (70 FR 16336, 71 FR 1926), that was due for Agreement State 

implementation on April 29, 2008. 

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

15005), that was due for Agreement State implementation on March 27, 2009. 

• “National Source Tracking System – Serialization Requirements,” 10 CFR Part 32 

amendment with reference to Part 20 Appendix E (71 FR 65685), that was due for 

Agreement State implementation on February 6, 2007. 

The review team identified the following regulation amendments that are also included in the 

compatibility package submitted; however, they are not considered overdue because the date of 

adoption has not passed: 

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

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

adoption by October 29, 2010. 
Oklahoma Final Report Page 12 

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

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

by November 30, 2010. 

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

Licensing and Reporting Requirements,” 10 CFR Parts 30, 31, 32, 150 amendment (72 

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

The Section will need to address the following regulations in upcoming rulemaking or by 

adopting alternate legally binding requirements: 

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

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

adoption by February 15, 2011. 

• “Medical Use of Byproduct Material – Authorized User Clarification,” 10 CFR Part 35 

amendment (74 FR 33901), that is due for Agreement State adoption by September 28, 

2012. 

The Section Manager expressed his intent to submit regulations for a formal compatibility review 

every 2 years in order to meet the 3-year requirement. The State was operating under NRC 

regulations dated January 1, 2008, so while the regulations were not considered compatible, the 

State did not have any significant compatibility issues. 

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

that Oklahoma’s performance with respect to the indicator, Compatibility Requirements, be 

found satisfactory. 

4.2 Low-Level Radioactive Waste Disposal Program

In 1981, the NRC amended its Policy Statement, "Criteria for Guidance of States and NRC in 

Discontinuance of NRC Regulatory Authority and Assumption Thereof by States Through 

Agreement" to allow a State to seek an amendment for the regulation of low-level radioactive 

waste (LLRW) as a separate category. Although the Oklahoma Agreement State Program has 

LLRW disposal authority, NRC has not required States to have a program for licensing a LLRW 

disposal facility until such time as the State has been designated as a host State for a LLRW 

disposal facility. When an Agreement State has been notified or becomes aware of the need to 

regulate a LLRW disposal facility, they are expected to put in place a regulatory program which 

will meet the criteria for an adequate and compatible LLRW disposal program. There are no 

plans for a LLRW disposal facility in Oklahoma. Accordingly, the review team did not review this 

indicator. 

5.0 SUMMARY 

As noted in Sections 3.0 and 4.0 above, Oklahoma’s performance was found satisfactory, but 

needs improvement, for the indicators, Status of Materials Inspection Program and Technical 

Quality of Licensing Actions, and satisfactory for the remaining performance indicators 
Oklahoma Final Report Page 13 

reviewed. After further discussions, the MRB determined that Oklahoma’s performance with 

regard to the Status of Materials Inspection Program indicator was satisfactory, and found 

Oklahoma’s performance to be satisfactory but needs improvement for Technical Quality of 

Licensing Actions, and satisfactory for all other indicators. The review team made two 

recommendations regarding program performance by the State and recommends that two 

recommendations from the 2006 IMPEP review remain open. 

Accordingly, the review team recommends that the Oklahoma Agreement State Program be 

found 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 recommends that the next full 

IMPEP review take place in approximately 4 years, with a periodic meeting tentatively 

scheduled for September 2012. During the periodic meeting and at the next IMPEP review, 

NRC will evaluate the effectiveness of the State’s response to the review team’s 

recommendations, as well as the overall implementation of the Agreement State program. 

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

implementation by the State: 

1. The review team recommends that the Section take appropriate measures to conduct 

their inspection program in a sustainable manner by continuing to implement their 

corrective action program. (Section 3.2) 

2. The review team recommends that the Program retrain its staff to gain increased 

familiarity with the regulations under 10 CFR Part 35 and the appropriate NRC guidance 

documents for medical use authorizations. (Section 3.4) 

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

documentation and appropriate response, review, enforcement, and follow up of all 

radioactive materials incidents. (From the 2006 IMPEP report) (Section 3.5) 

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

documentation and appropriate tracking and closure of all allegations involving 

radioactive material. (From the 2006 IMPEP report) (Section 3.5) 
LIST OF APPENDICES 

Appendix A IMPEP Review Team Members 

Appendix B Oklahoma Organization Charts 

Appendix C Inspection Casework Reviews 

Appendix D License Casework Reviews 

Appendix E Incident Casework Reviews 
APPENDIX A 

IMPEP REVIEW TEAM MEMBERS 

Name Area of Responsibility

Jim Lynch, Region III Team Leader 

 Technical Quality of Incident and Allegation 

 Activities 

 Inspector Accompaniments 

David Turberville, Alabama Status of Materials Inspection Program 

 Technical Quality of Inspections 

Rachel Browder, Region IV Technical Quality of Licensing Actions 

 Compatibility Requirements 

Maria Arribas-Colon, FSME Technical Staffing and Training 
APPENDIX B 

OKLAHOMA ORGANIZATION CHARTS 

ADAMS ACCESSION NO.: ML102450147
 APPENDIX C 

INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: INTEGRIS Grove Hospital License No.: OK-31019-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 6/12/08 Inspector: JM 

File No.: 2 

Licensee: The University of Oklahoma – Norman Campus License No.: OK-07466-05 

Inspection Type: Routine, Announced Priority: 3 

Inspection Date: 3/9/10 Inspectors: NN, MV 

File No.: 3 

Licensee: AIMRIGHT Testing, LLC License No.: OK-32106-01 

Inspection Type: Initial, Announced Priority: 5 

Inspection Date: 9/2/09 Inspector: KC 

Comment: 

The inspection letter was issued 10 days past the Section’s 30-day goal. 

File No.: 4 

Licensee: APAC-Oklahoma, Inc. License No.: OK-26937-02 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 4/1/10 Inspectors: MV, MB 

Comment: 

The inspection letter was issued 13 days past the Section’s 30-day goal. 

File No.: 5 

Licensee: Sherwood Construction Company, Inc. License No.: OK-31031-01 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 8/11/10 Inspector: KC 

File No.: 6 

Licensee: ConocoPhillips Co. License No.: OK-07402-12 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 4/21/10 Inspectors: MV, NN 

File No.: 7 

Licensee: Baker Hughes Oilfield Operations, Inc. License No.: OK-02964-03 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Dates: 7/10/08, 8/21/08 Inspectors: JF, JR 

 
Oklahoma Final Report Page C.2 

Inspection Casework Reviews 

File No.: 8 

Licensee: Halliburton Energy Services, Inc. License No.: OK-00502-03 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 1/12/09 Inspectors: JF, MB 

File No.: 9 

Licensee: Southeast 3 Circuit Engineering District License No.: OK-31056-01 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 8/13/10 Inspector: MB 

File No.: 10 

Licensee: St. John Medical Center License No.: OK-00376-02 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Dates: 6/30/09, 9/15/09 Inspectors: NN, MV 

File No.: 11 

Licensee: Sagebrush Pipeline & Inspection Co., Inc. License No.: OK-32109-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 10/28/09 Inspector: MI 

File No.: 12 

Licensee: Lone Star Industries, Inc. License No.: OK-32111-01 

Inspection Type: Initial Priority: 5 

Inspection Date: 3/10/10 Inspector: KC 

Comment: 

The inspection report was not complete at the time of review, 6 months after the 

inspection. 

File No.: 13 

Licensee: Team Industrial Services, Inc. License No.: OK-31066-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 2/25/10 Inspectors: JR, KC 

File No.: 14 

Licensee: Oklahoma Heart Institute License No.: OK-27613-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 10/8/08 Inspector: MI 

File No.: 15 

Licensee: American Piping Inspections, Inc. License No.: OK-27438-02 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 8/25/09 Inspector: KS 

 
Oklahoma Final Report Page C.3 

Inspection Casework Reviews 

File No.: 16 

Licensee: Midwest Inspection Services License No.: OK-27005-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Dates: 8/10/09, 8/13/09 Inspector: KS 

File No.: 17 

Licensee: HCA Health Services of Oklahoma, Inc. License No.: OK-21035-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 9/18/08 Inspector: MI 

File No.: 18 

Licensee: Memorial Hospital of Texas County License No.: OK-23125-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Dates: 10/1/09 – 1/15/10 Inspector: MV 

File No.: 19 

Licensee: Nuclear Rx, PC License No.: OK-31035-01MD 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 2/7/08 Inspector: JF 

File No.: 20 

Licensee: Baylor Medical Center at Garland License No.: L02398 

Inspection Type: Reciprocity, Announced Priority: 7 

Inspection Date: 11/9/07 Inspectors: JM, MB 

File No.: 21 

Licensee: Koss Construction Company License No.: 22-B780 

Inspection Type: Reciprocity, Unannounced Priority: 5 

Inspection Date: 5/23/07 Inspectors: CC, KS 

File No.: 22 

Licensee: Gulf Coast Weld Specialists License No.: L054261 

Inspection Type: Reciprocity, Unannounced Priority: 1 

Inspection Date: 11/7/08 Inspectors: JM, MI 

Comment: 

The inspection letter was not in file and not located during the review. No violations 

were identified. 

File No.: 23 

Licensee: NQS Inspections, LTD License No.: L06262 

Inspection Type: Reciprocity, Unannounced Priority: 1 

Inspection Date: 2/16/10 Inspector: KS 

 
Oklahoma Final Report Page C.4 

Inspection Casework Reviews 

File No.: 24 

Licensee: J. L. Shepherd and Associates License No.: CA-1777-19 

Inspection Type: Reciprocity, Unannounced Priority: 2 

Inspection Dates: 9/14-15/06 Inspector: JM 

Comment: 

The inspection letter was issued 18 days past the Section’s 30-day goal. 

File No.: 25 

Licensee: Nucletron Corporation License No.: MD-27-035-01 

Inspection Type: Reciprocity, Unannounced Priority: 5 

Inspection Date: 11/15/06 Inspectors: KS, JF 

File No.: 26 

Licensee: Nucletron Corporation License No.: MD-27-035-01 

Inspection Type: Reciprocity, Unannounced Priority: 5 

Inspection Date: 5/21/08 Inspector: JM 

Comment: 

The inspection letter was issued 18 days past the Section’s 30-day goal. 

File No.: 27 

Licensee: Nucletron Corporation License No.: MD-27-035-01 

Inspection Type: Reciprocity, Unannounced Priority: 5 

Inspection Dates: 1/13-15/08 Inspectors: MI, JR 

File No.: 28 

Licensee: Best Theratronics License No.: 45-31299-01 

Inspection Type: Reciprocity, Unannounced Priority: 2 

Inspection Date: 9/29/09 Inspector: JF 

File No.: 29 

Licensee: Alpha-Omega Services, Inc. License No.: CA-3925-19 

Inspection Type: Reciprocity, Unannounced Priority: 2 

Inspection Dates: 3/3-6/09 Inspector: MI 

File No.: 30 

Licensee: Nondestructive and Visual Inspection License No.: LA-5601-L01 

Inspection Type: Reciprocity, Announced Priority: 1 

Inspection Date: 9/5/08 Inspector: MI 
Oklahoma Final Report Page C.5 

Inspection Casework Reviews 

INSPECTOR ACCOMPANIMENTS 

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

Accompaniment No.: 1 

Licensee: INTEGRIS Southwest Medical Center License No.: OK-13127-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 7/13/10 Inspector: NN 

Accompaniment No.: 2 

Licensee: MISTRAS Group, Inc License No.: OK-31077-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 7/14/10 Inspector: MI 

Accompaniment No.: 3 

Licensee: Equine Medical Associates, Inc. License No.: OK-27487-01 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 7/15/10 Inspector: MV 
APPENDIX D 

LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Cancer Care Associates License No.: OK-27631-01 

Type of Action: Renewal Amendment No.: 18 

Date Issued: 1/27/10 License Reviewer: KS 

Comment: 

A Delegation of Authority for the Radiation Safety Officer was not included as part of the 

renewal package, to meet 10 CFR 35.24(b). 

File No.: 2 

Licensee: Century Geophysical Corporation License No.: OK-04017-05 

Type of Action: Renewal Amendment No.: 07 

Dates Issued: 11/12/08 License Reviewer: JF 

File No.: 3 

Licensee: AIMRIGHT Testing, LLC License No.: OK-32106-01 

Type of Action: New Amendment No.: New 

Dates Issued: 4/22/09 License Reviewer: KC 

File No.: 4 

Licensee: Comprehensive Cancer Center of Oklahoma License No.: OK-31053-01 

Type of Action: Amendment Amendment No.: 05 

Date Issued: 6/22/09 License Reviewer: NN 

Comments: 

a) A physician was authorized for samarium-153, which is a 10 CFR 35.300 modality, 

without supporting documentation. 

b) There was no Delegation of Authority for the new Radiation Safety Officer that was 

authorized on the license. 

File No.: 5 

Licensee: Muskogee Regional Medical Center License No.: OK-13157-01 

Type of Action: Amendment Amendment No.: 60 

Date Issued: 4/30/10 License Reviewer: MV 

Comment: 

A physician was authorized for 10 CFR 35.300 uses without supporting documentation. 

File No.: 6 

Licensee: Oklahoma Blood Institute License No.: OK-17900-02 

Type of Action: Renewal Amendment No.: 04 

Date Issued: 8/22/07 License Reviewer: JF
Oklahoma Final Report Page D.2 

License Casework Reviews 

File No.: 7 

Licensee: Oklahoma State University Medical Center License No.: OK-05860-01 

Type of Action: Amendment Amendment No.: 66 

Date Issued: 12/11/09 License Reviewer: MB 

Comment: 

A physician was authorized for 10 CFR 35.500 uses without supporting documentation. 

File No.: 8 

Licensee: Midwest City H.M.A., Inc. License No.: OK-14990-01 

Type of Action: Renewal Amendment No.: 38 

Date Issued: 7/29/10 License Reviewer: MV 

Comment: 

A physician was authorized for 10 CFR 35.300 uses; however, based on the 

documentation submitted, the physician should have been limited to “oral administration 

of sodium iodide I-131.” 

File No.: 9 

Licensee: Schlumberger Technology Corporation License No.: OK-00090-03 

Type of Action: Renewal Amendment No.: 06 

Date Issued: 4/23/09 License Reviewer: JF 

File No.: 10 

Licensee: Lone Star Industries, Inc. License No.: OK-32111-01 

Type of Action: New Amendment No.: New 

Date Issued: 10/15/09 License Reviewer: JR 

File No.: 11 

Licensee: INTEGRIS Baptist Medical Center License No.: OK-11022-01 

Types of Action: Amendment Amendment No.: 69 

Dates Issued: 9/7/06 License Reviewer: KS 

Comments: 

a) A medical physicist was authorized for iridium-192 high dose-rate brachytherapy, without 

supporting documentation. 

b) A physician was authorized for 10 CFR 35.600 uses without adequate supporting 

documentation. 

File No.: 12 

Licensee: Sagebrush Pipeline and Equipment Company, Inc. License No.: OK-32109-01 

Types of Action: New Amendment No.: New 

Dates Issued: 4/27/09 License Reviewer: KS 

 
Oklahoma Final Report Page D.3 

License Casework Reviews 

File No.: 13 

Licensee: Terracon, Inc. License No.: OK-27070-02 

Type of Action: Amendment Amendment No.: 09 

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

File No.: 14 

Licensee: J&L Oilfield Services License No.: OK-32093-01 

Type of Actions: New & Termination Amendment Nos.: New & 01 

Dates Issued: 10/19/07 & 11/14/08 License Reviewers: KS, MV 

Comment: 

The license reviewer did not authorize the correct quantity of americium-241 for Troxler 

Model 3440 gauges. 

File No.: 15 

Licensee: Desert Industrial X-Ray, L.P. License No.: OK-32104-01 

Type of Action: New Amendment No.: New 

Date Issued: 2/26/09 License Reviewer: KS 

File No.: 16 

Licensee: Core Laboratories LP License No.: OK-26928-02 

Type of Action: Renewal Amendment No.: 07 

Date Issued: 3/9/09 License Reviewer: KS 

Comment: 

The license reviewer authorized a 100 uCi quantity for collar markers which exceeded 

the regulatory limits authorized in 10 CFR 30.71. 

File No.: 17 

Licensee: American Castings, LLC License No.: OK-18099-01 

Type of Action: Renewal Amendment No.: 17 

Date Issued: 9/22/09 License Reviewer: JR 

Comment: 

The renewal application did not contain procedures, radiography test with answers, 

drawings of the facility/storage areas, policy for dosimetry and instrument calibration, 

which are considered to be some of the essential elements of the radiation safety 

program. 

File No.: 18 

Licensee: Conoco Phillips Co. License No.: OK-07402-11 

Type of Action: Termination Amendment No.: 14 

Date Issued: 8/12/09 License Reviewer: KS 
Oklahoma Final Report Page D.4 

License Casework Reviews 

File No.: 19 

Licensee: Ramey Testing Laboratory, Inc. License No.: OK-21291-01 

Type of Action: Termination Amendment No.: 04 

Date Issued: 5/3/10 License Reviewer: KC 

File No.: 20 

Licensee: HCA Health Services of Oklahoma, Inc. License No.: OK-12091-02 

Type of Action: Amendment Amendment No.: 22 

Date Issued: 7/7/07 License Reviewer: KC 

Comment: 

A physician was authorized for 10 CFR 35.600 (gamma knife) under a board certification 

that was prior to the date approved by the NRC; therefore, the applicant should have 

been reviewed under 10 CFR 35.690(b)(1), training and experience. 

File No.: 21 

Licensee: Cornerstone Healthcare Partners License No.: OK-31042-01 

Type of Action: Termination Amendment No.: 07 

Date Issued: 6/4/09 License Reviewer: NN 

File No.: 22 

Licensee: Bill Miller, Inc. License No.: OK-19048-02 

Type of Action: Termination Amendment No.: 06 

Date Issued: 6/2/10 License Reviewer: KS 

File No.: 23 

Licensee: The University of Oklahoma, Norman License No.: OK-07466-05 

Type of Action: Renewal Amendment No.: 43 

Date Issued: 7/22/08 License Reviewer: KS 

File No.: 24 

Licensee: Oklahoma State University License No.: OK-00237-03 

Type of Action: Amendment Amendment No.: 39 

Date Issued: 11/3/06 License Reviewer: BS 

File No.: 25 

Licensee: PetNet Solutions, Inc. License No.: OK-31050-01MD 

Type of Action: Amendment Amendment No.: 02 

Date Issued: 9/10/09 License Reviewer: NN 

File No.: 26 

Licensee: Oklahoma Medical Research Foundation License No.: OK-07464-03 

Type of Action: Amendment Amendment No.: 48 

Date Issued: 4/1/09 License Reviewer: MV 
APPENDIX E 

INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Capital X-Ray Services, Inc. License No.: OK-11114-02 

Date of Incident: 8/16/09 NMED No.: 090720 

Investigation Date: 10/16/09 Type of Incident: Overexposure 

 Type of Investigation: Site 

Comment: 

The incident report was not located in the license file. 

File No.: 2 

Licensee: Saint Anthony Hospital License No.: OK-01428-03 

Date of Incident: 4/27/07 NMED No.: 070295 

Investigation Date: 5/10/07 Type of Incident: Medical 

 Type of Investigation: Site 

File No.: 3 

Licensee: Oklahoma State University License No.: OK-00237-03 

Date of Incident: 10/30/08 NMED No.: 080753 

Investigation Date: 11/14/08 Type of Incident: Overexposure 

 Type of Investigation: Site 

File No.: 4 

Licensee: ThruBit LLC License No.: OK-32115-01 

Date of Incident: 7/27/10 NMED No.: 100392 

Investigation Date: 7/28/10 Type of Incident: Lost Source 

 Type of Investigation: Telephone 

File No.: 5 

Licensee: American Airlines License No.: OK-13964-01 

Date of Incident: 11/21/09 NMED No.: 100184 

Investigation Date: 3/30/10 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Telephone 

Comment: 

The incident report was not located in the license file. 

File No.: 6 

Licensee: Standard Testing and Engineering Co. License No.: OK-17054-03 

Date of Incident: 6/28/10 NMED No.: 100334 

Investigation Date: 7/20/10 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Site 

 
Oklahoma Final Report Page E.2 

Incident Casework Reviews 

File No.: 7 

Licensee: Burgess Engineering and Testing License No.: OK-27554-01 

Date of Incident: 7/24/10 NMED No.: 100385 

Investigation Date: 7/27/10 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Site 

Comment: 

The incident report was not located in the current license file, but rather in an old license 

file. 

File No.: 8 

Licensee: Midwest Inspection Services License No.: OK-27005-01 

Date of Incident: 1/21/07 NMED No.: 070050 

Investigation Date: 1/21/07 Type of Incident: Loss of Control 

 Type of Investigation: Site 

Comment: 

The incident report was not located in the license file. 

File No.: 9 

Licensee: Globe X-Ray Services License No.: OK-15194-02 

Date of Incident: 8/31/07 NMED No.: 070598 

Investigation Date: 10/3/07 Type of Incident: Overexposure 

 Type of Investigation: Site 

File No.: 10 

Licensee: Kleinfelder Central, Inc. License No.: OK-27597-02 

Date of Incident: 10/24/07 NMED No.: 070658 

Investigation Date: 10/26/07 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Site 

File No.: 11 

Licensee: Kay County Hospital License No.: OK-14046-02 

Date of Incident: 3/28/07 NMED No.: 070183 

Investigation Date: 4/6/07 Type of Incident: Medical 

 Type of Investigation: Site 

File No.: 12 

Licensee: Oklahoma State Univ. Medical Center License No.: OK-05860-01 

Date of Incident: 4/16/08 NMED No.: 080237 

Investigation Date: 4/22/08 Type of Incident: Contamination 

 Type of Investigation: Site 

 
Oklahoma Final Report Page E.3 

Incident Casework Reviews 

File No.: 13 

Licensee: Team Industrial Services, Inc. License No.: OK-31066-01 

Date of Incident: 7/25/07 NMED No.: 070472 

Investigation Date: 7/26/07 Type of Incident: Damaged Equipment 

 Type of Investigation: Site 

Comment: 

The incident report was not located in the license file. 

File No.: 14 

Licensee: Ramey Enterprises License No.: OK-21291-01 

Date of Incident: 6/19/08 NMED No.: 080359 

Investigation Date: 6/19/08 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Site 

File No.: 15 

Licensee: Oklahoma Dept. of Transportation License No.: OK-15794-01 

Date of Incident: 7/22/10 NMED No.: 090684 

Investigation Date: 7/22/10 Type of Incident: Damaged Equipment 

 Type of Investigation: Telephone 

Comment: 

The incident report was not located in the license file. 

File No.: 16 

Licensee: St. John Medical Center License No.: OK-03760-02 

Date of Incident: 1/10/08 NMED No.: N/A 

Investigation Date: 1/30/08 Type of Incident: Medical 

 Type of Investigation: Site 

Comment: 

This incident was not reported to the NRC Operations Center nor entered into the 

Nuclear Material Events Database at the time of the review. The incident was reported 

to the NRC Operations Center, after the review, on September 24, 2010.
ATTACHMENT 

November 15, 2010 Email from Mike Broderick 

Oklahoma’s Response to the Draft Report 

ADAMS Accession No.: ML103190270