August 22, 2013 

Joseph G. Klinger, Assistant Director 

Illinois Emergency Management Agency 

Division of Nuclear Safety 

2200 South Dirksen Parkway 

Springfield, IL 62703 

Dear Mr. Klinger: 

On July 8, 2013, the Management Review Board (MRB) met to consider the proposed final 

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

State Program. The MRB found the Illinois program adequate to protect public health and 

safety, and compatible with the U.S. Nuclear Regulatory Commission’s program. 

Section 5.0, page 15, of the enclosed final report contains a summary of the IMPEP team’s 

findings. The review team made no recommendations in regard to program performance by the 

Illinois Agreement State Program during this review. Based on the results of the current IMPEP 

review, the next full review of the Illinois Agreement State Program will take place in 

approximately 5 years, with a periodic meeting tentatively scheduled for October 2015. The 

State received a 1 year extension of its next IMPEP for having two consecutive IMPEP reviews 

with all indicators found satisfactory. 

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 by Catherine Haney for/ 

 Michael F. Weber 

 Deputy Executive Director for Materials, Waste, 

 Research, State, Tribal and Compliance Programs 

 Office of the Executive Director for Operations 

Enclosure: 

Illinois Final IMPEP Report 

cc w/ encl: Michael Snee, OH 

 Organization of Agreement States 

 Liaison to the MRB 

 Don Agnew, Acting Chief 

 Bureau of Radiation Safety 

 Gibb Vinson, Head 

 Radioactive Materials Section 
Joseph G. Klinger, Assistant Director 

Illinois Emergency Management Agency 

Division of Nuclear Safety 

2200 South Dirksen Parkway 

Springfield, IL 62703 

Dear Mr. Klinger: 

On July 8, 2013, the Management Review Board (MRB) met to consider the proposed final 

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

State Program. The MRB found the Illinois program adequate to protect public health and 

safety, and compatible with the U.S. Nuclear Regulatory Commission’s program. 

Section 5.0, page 15, of the enclosed final report contains a summary of the IMPEP team’s 

findings. The review team made no recommendations in regard to program performance by the 

Illinois Agreement State Program during this review. Based on the results of the current IMPEP 

review, the next full review of the Illinois Agreement State Program will take place in 

approximately 5 years, with a periodic meeting tentatively scheduled for October 2015. The 

State received a 1 year extension of its next IMPEP for having two consecutive IMPEP reviews 

with all indicators found satisfactory. 

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 by Catherine Haney for/ 

 Michael F. Weber 

 Deputy Executive Director for Materials, Waste, 

 Research, State, Tribal and Compliance Programs 

 Office of the Executive Director for Operations 

Enclosure: 

Illinois Final IMPEP Report 

cc w/ encl: Michael Snee, OH 

 Organization of Agreement States 

 Liaison to the MRB 

 Don Agnew, Acting Chief 

 Bureau of Radiation Safety 

 Gibb Vinson, Head 

 Radioactive Materials Section 

DISTRIBUTION: 

See next page 

 ML13198A010 

OFC MSSA: TL MSSA MSSA MSSA MSSA:D TechEd FSME:D EDO/DEDMRT 

NAME DJanda 

via email 

LDimmick DWhite PHenderson BMcDermott/ 

PHenderson 

for 

CPoland / 

PTressler 

for 

MSatorius / 

BHolian for 

MWeber 

(CHaney for) 

DATE 07/17/13 07/22/13 08/01/13 08/01/13 08/01/13 08/01/13 08/02/13 08/22/13 

OFFICIAL RECORD COPY 
Letter to J. Klinger from Michael F. Weber dated August 22, 2013 

SUBJECT: ILLINIOS FY2013 FINAL IMPEP REPORT 

DISTRIBUTION: (SP07) 

RidsEdoMailCenter 

JFoster, OEDO 

RidsFsmeOd 

RidsOgcMailCenter 

RidsRgn1MailCenter 

RidsRgn3MailCenter 

ABoland, RIII 

PLouden, RIII 

RidsFsmeMssa 

KMorganButler, FSME 

RidsSecyCorrespondenceMailCenter Chairman Macfarlane 

MBeardsley, FSME Commissioner Svinicki 

SHammann, RI Commissioner Apostolakis 

JLynch, RIII/RSAO Commissioner Magwood 

MArribas-Colon, FSME Commissioner Ostendorff 

JJarvis, CO SECY 

VDanese, TX 

JWeil, OCA (2 copies) 
Enclosure 

 

INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

REVIEW OF THE ILLINOIS AGREEMENT STATE PROGRAM 

APRIL 22-26, 2013 

FINAL REPORT
EXECUTIVE SUMMARY 

This report presents the results of the Integrated Materials Performance Evaluation Program 

(IMPEP) review of the Illinois Agreement State Program. The review was conducted during the 

period of April 22-26, 2013, by a review team composed of technical staff members from the 

U.S. Nuclear Regulatory Commission (NRC), the State of Colorado, and the State of Texas.

Based on the results of this review, Illinois performance was found satisfactory for all indicators 

reviewed. The review team did not make any recommendations regarding program 

performance by the State and determined that the recommendation from the 2009 IMPEP 

review, regarding issuance of inspection findings to licensees within the State’s required 

timeframe, should be closed. 

Accordingly, the review team recommended, and the Management Review Board (MRB) 

agreed, that the Illinois Agreement State Program is adequate to protect public health and 

safety and is compatible with the NRC's program. The review team recommended, and the 

MRB agreed, that the next IMPEP review take place in approximately five years. 

. 
Illinois Final IMPEP Report Page 1 

1.0 INTRODUCTION 

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

review was conducted during the period of April 22 – 26, 2013, by a review team composed of 

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

Colorado, and the State of Texas. 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 May 16, 2009 to April 26, 2013, were 

discussed with Illinois managers on the last day of the review. 

A draft of this report was provided to Illinois for factual comment on May 21, 2013. The State 

responded by email dated May 30, 2013. A copy of the State’s response is included as an 

Attachment to this report. A Management Review Board (MRB) met on July 8, 2013 to consider 

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

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

The Illinois Agreement State Program is administered by the Radioactive Materials Section (the 

RAM Section), which is located within the Bureau of Radiation Safety (the Bureau), and the 

Environmental Management Section (the EM Section) of the Bureau of Environmental Radiation 

Safety (BERS), which regulates low level waste, uranium recovery, decommissioning, and 

financial assurance. In addition, since 2012, the Bureau of Environmental Radiation Safety took 

the lead for responses to scrap yard monitor trips and orphan sources. Both Bureaus are part 

of the Illinois Emergency Management Agency (the Agency). Organization charts for the 

Agency, the Bureau, and the Bureau of Environmental Radiation Safety are included as 

Appendix B. 

At the time of the review, the Illinois Agreement State Program regulated 685 specific licenses 

authorizing possession and use of radioactive 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 Illinois. 

In preparation for the review, a questionnaire addressing the common and applicable 

non-common performance indicators was sent to the Bureau on January 31, 2013. The Bureau 

provided its response to the questionnaire on April 2, 2013, and an updated response on April 

26, 2013. A copy of the questionnaire response can be found in NRC’s Agencywide Documents 

Access and Management System (ADAMS) using the Accession Number ML13126A084. 

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 Illinois statutes and 

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

technical review of selected regulatory actions, (5) field accompaniments of four 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 

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

performance. 
Illinois Final IMPEP Report Page 2 

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

during the previous review. 

Results of the current review of the common performance indicators are presented in Section 

3.0. Section 4.0 details the results of the review of the applicable non-common 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 May 15, 2009, the review team made 

one recommendation regarding the Illinois Agreement State Program’s performance. The 

status of the recommendation is as follows: 

Recommendation: “The review team recommends that the State provide inspection 

documentation to its licensees within 30 days of a completed inspection in accordance 

with the Section’s policies and procedures. (Section 3.2)” 

Status: The review team evaluated the RAM Section’s timeliness in providing inspection 

findings to licensees. The RAM Section’s policy is to issue inspection findings to 

licensees within 30 days from the date of the inspection. Since the 2009 IMPEP review, 

the RAM Section refined its inspection documentation process, including the use of 

inspection forms similar to NRC Form 591, which can be used to close out inspection 

documentation while in the field. Inspection documentation is also tracked by the 

Bureau Chief on a monthly basis. Based on a review of 48 inspection cases, the review 

team identified one inspection report that was issued beyond the RAM Section’s goal of 

30 days after the inspection. This recommendation is closed. 

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

Considerations central to the evaluation of this indicator include the RAM and EM Sections’ 

staffing levels and staff turnover, as well as the technical qualifications and training histories of 

the staff. To evaluate these issues, the review team examined the Bureau’s questionnaire 

response relative to this indicator, interviewed managers and staff, reviewed job descriptions 

and training records, and considered workload backlogs. 

The RAM Section, which is supervised by the Section Head, is divided into three units: 

Materials Licensing, Inspection and Enforcement, and Materials Security. The RAM Section is 

responsible for licensing, inspection, and incident response activities. At the time of the 

review, there were 14 technical staff members and supervisors in the Bureau with various 

degrees of involvement in the radioactive materials program, totaling approximately 13.7 

full-time equivalents (FTE). 
Illinois Final IMPEP Report Page 3 

Since the 2009 IMPEP review, five individuals left the radioactive materials program, including 

the Bureau Chief, Acting Materials Licensing Supervisor, and three technical staff members. 

Five individuals were hired into the RAM Section, including four license reviewers and one 

inspector. Two positions were vacant at the time of this review including the Bureau Chief 

position. The license reviewer/regulations position has been vacant since January 1, 2012. 

The position will be posted once approval is granted. The Bureau Chief’s position has been 

vacant since January 1, 2013. The Electronic Products Section Head is currently serving as 

the Acting Bureau Chief until the position is permanently filled. 

The EM Section, which is supervised by the Section Head, is divided into three units: 

Environmental Monitoring, Environmental Compliance, and Low Level Radioactive Waste 

(LLRW) and Decommissioning. The EM Section employs one full-time technical staff member 

as a resident inspector at the former uranium recovery site in West Chicago. At the time of 

the review, there were five technical staff members and managers, totaling approximately 3.7 

FTE, in the EM Section who provide technical support to the Bureau by managing the uranium 

recovery, financial assurance, and orphan source programs. They also provide 

decommissioning and license termination support. In addition, since 2012, the Bureau of 

Environmental Safety took the lead for response to radiation monitor trips at scrap facilities 

and landfills. 

Since the 2009 IMPEP review, four individuals left the Bureau of Environmental Safety, 

including the Bureau Chief and staff from the LLRW and Decommissioning Unit. All of these 

positions have been filled. At the time of this review, there were no vacant positions in the 

LLRW and uranium recovery programs. 

The Bureau of Environmental Safety also uses approximately four FTE from contractor 

personnel for engineering technical support for license review and evaluation and construction 

oversight of decommissioning activities at the site. Bureau and contractor staffing levels have 

remained stable throughout the IMPEP review period. The staff has expertise in various 

technical disciplines including health physics, geology, hydrology, environmental laboratory 

analysis and engineering. 

The review team determined that staffing levels in both the RAM Section and EM Section 

were adequate for the Agreement State program. 

The RAM 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.” This training and qualification plan includes a 

plan for the EM Section staff positions which provide technical support to the radioactive 

materials program. The new RAM Section license reviewers and materials inspector are in 

various stages of their qualification process. Qualification is achieved through a combination of 

education and experience, formal classroom training, and on-the-job training. Staff members 

are required to have a Bachelor’s degree or equivalent experience in a physical or biological 

science or engineering. The review team concluded that the RAM Section’s training program is 

adequate to carry out its regulatory duties and noted that Illinois management supports the 

training program. 
Illinois Final IMPEP Report Page 4 

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

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

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

managers and staff members. 

The RAM Section tracks all inspection activities in a computer database. The review team 

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

inspection status for any licensed facility. In addition, the RAM Section maintains separate 

records reflecting which reciprocity licenses are candidates for inspection on a calendar year 

basis. The RAM Section’s database identified these licensees as “current” or “not current” on a 

calendar year basis. 

The review team concluded that the RAM Section’s inspection frequencies for all types of 

radioactive materials licenses are at least as frequent as those listed in NRC’s Inspection 

Manual Chapter (IMC) 2800, “Materials Inspection Program.” The review team confirmed the 

RAM Section is conducting Increased Controls inspections in conjunction with the routine health 

and safety inspections. 

The RAM Section conducted 655 Priority 1, 2, and 3 inspections during the review period based 

on the inspection frequencies established in IMC 2800. Three of these inspections were 

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

2800. The review team verified there were no overdue routine Priority 1, 2, and 3 inspections at 

the time of the review. In addition, the RAM Section performed 21 initial inspections during the 

review period. All initial inspections were conducted within 12 months after license issuance as 

prescribed by IMC 2800. Overall, the review team calculated that that the RAM Section 

performed less than one percent of its Priority 1, 2, and 3 and initial inspections overdue during 

the review period. 

The review team evaluated the RAM Section’s timeliness in providing inspection findings to 

licensees. The RAM Section’s policy is to issue inspection findings to licensees within 30 days 

from the date of the inspection. All inspection reports are submitted for a supervisory review. 

Based on a review of 48 inspection cases, the review team identified one inspection report that 

was issued beyond the RAM Section’s goal of 30 days after the inspection. 

The RAM Section’s reciprocity inspection goals are equivalent to the requirements in IMC 1220, 

“Processing of NRC Form 241 and Inspection of Agreement State Licensees Operating under 

10 CFR 150.20,” which is 20 percent of candidate licensees. During the review period, the RAM 

Section granted 67 reciprocity permits and exceeded the NRC’s criteria of inspecting 20 percent 

of candidate licensees operating under reciprocity in each of the four years covered by the 

review period. 
Illinois Final IMPEP Report Page 5 

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

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

be found satisfactory. 

3.3 Technical Quality of Inspections

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

notes for 27 radioactive materials inspections conducted during the review period. The 

casework reviewed included inspections conducted by one former and seven current RAM 

Section inspectors and one EM Section inspector and covered inspections of various license 

types, including: medical broad scope, high dose rate remote afterloader (HDR), positron 

emission tomography, portable gauge, industrial radiography, panoramic irradiator, gamma 

knife, nuclear pharmacy, mobile nuclear medicine, manufacturing, well logging, 

decommissioning, and reciprocity, as well as initial and Increased Controls inspections. 

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 determined that inspections covered all 

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

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

to ensure that licensee performance with respect to health, safety, and security was acceptable. 

The review team noted that the inspections covered the Increased Controls, fingerprinting, and 

the National Source Tracking System when appropriate. Inspection report documentation 

supported violations, recommendations made to licensees, unresolved safety issues, the 

effectiveness of corrective actions taken to resolve previous violations and discussions held with 

licensees during exit interviews. The review team noted that inspectors worked as a team for 

large, complex licensees and for training purposes. 

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

2800. Inspectors have the option to issue inspection results on a form similar to NRC’s Form 

591 or to send results from the office. All inspection documentation sent from the office is 

dispatched under the signature of the Inspection and Enforcement Unit Supervisor, or the 

Licensing Security Manager for security inspections. When the RAM Section issues a Notice of 

Violation (NOV) in letter format, the licensee is required to provide a written corrective action 

plan, based on the violations cited, within 30 days. 

The review team verified that the RAM Section has an adequate supply of survey instruments to 

support the inspection program. The State has its own accredited calibration laboratory in 

Springfield. The State Radiation Safety Officer heads the lab and is responsible for ensuring 

that the calibration lab maintains its accreditation and that survey instruments are properly 

calibrated and distributed. The RAM Section receives laboratory and sample analysis support 

from the State laboratory. 

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

annually. The supervisor in the Chicago area office performs accompaniments for the 

inspectors in that area annually. The Inspection and Enforcement Unit Supervisor accompanies 

the one inspector in the southern part of the State annually. 
Illinois Final IMPEP Report Page 6 

The review team accompanied four RAM Section inspectors in March 2013 during health and 

safety inspections of industrial radiography, panoramic irradiator, medical therapy, and gamma 

knife licensees. Two of the inspections included a review of the licensees’ implementation of 

the Increased Controls. Appendix C lists the inspector accompaniments. The inspectors 

demonstrated appropriate inspection techniques, knowledge of the regulations, and conducted 

performance-based inspections. The inspectors were trained, well-prepared for the inspection, 

and thorough in 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 security at the licensed facilities. 

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

that Illinois’ performance with respect to the indicator, Technical Quality of Inspections, be found 

satisfactory. 

3.4 Technical Quality of Licensing Actions

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

23 specific licensing actions. 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, operating and 

emergency procedures, appropriateness of license conditions, and overall technical quality. 

The casework was also reviewed for timeliness, use of appropriate deficiency letters and cover 

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

enforcement history, pre-licensing visits, peer/supervisory review, and proper signatures. 

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

completed during the review period. Licensing actions selected for evaluation included 4 new 

licenses, 6 renewals, 1 decommissioning and termination action, and 12 amendments. Files 

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

diagnostic and therapy (including: mobile services, HDR, unsealed therapy, and brachytherapy), 

industrial radiography, research and development, nuclear pharmacy, portable and fixed 

gauges, manufacturer and distribution, panoramic and self-shielded irradiators, service 

providers, veterinary, measuring systems, and well logging. The casework sample represented 

work from eight license reviewers. A list of the licensing casework evaluated is provided in 

Appendix D. 

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

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

tie-down conditions were stated clearly and were supported by information contained in the file. 

Deficiency letters clearly stated regulatory positions, were used at the proper time, and identified 

substantive deficiencies in the licensees’ documents. Terminated licensing actions were well 

documented, showing appropriate transfer and survey records. License reviewers use both the 

RAM Section’s licensing guides and NRC NUREG-1556 series guidance documents, policies, 

checklists, and standard license conditions specific to the type of licensing actions to ensure 

consistency in licenses. 
Illinois Final IMPEP Report Page 7 

All licensing actions are signed by the Licensing Supervisor or other management personnel. 

The four main license reviewers are new to the program since the last IMPEP review and are in 

various stages of their training and qualification process. A secondary review is conducted for 

all licensing actions, usually by the Licensing Supervisor, but occasionally by one of the other 

managers with appropriate signature authority. Licenses are issued for a five-year period under 

a timely renewal system. 

The RAM Section performs pre-licensing checks of all new applicants and existing licenses 

requesting a new location of use. The RAM Section’s pre-licensing review methods incorporate 

the essential elements of NRC’s revised pre-licensing guidance to verify that the applicant will 

use requested radioactive materials as intended. All new licensees and existing licensees 

requesting a new location of use receive a pre-licensing site visit which includes an evaluation 

of the applicant’s radiation safety and security programs prior to receipt of the initial license. 

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

Controls and Fingerprinting Orders. The review team noted that the State uses legally binding 

license conditions that meet the criteria for implementing the Increased Controls Orders, 

including fingerprinting, as appropriate. The review team analyzed the RAM Section’s 

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

The review team confirmed that license reviewers evaluated new license applications and 

license amendments using the same criteria. The RAM Section requires full implementation of 

the Increased Controls prior to issuance of a new license or license amendment that meets the 

established criteria. 

The review team examined the RAM Section’s implementation of its procedure for the control of 

sensitive information. This procedure addresses the identification, marking, control, handling, 

preparation, transportation, transmission, and destruction of documents that contain sensitive 

information related to the Increased Controls. The review team determined that the RAM 

Section adequately controls the handling of sensitive information. 

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

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

found satisfactory. 

3.5 Technical Quality of Incident and Allegation Activities

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

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

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

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

casework for 22 of 36 reported radioactive materials incidents. A listing of the casework 

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

response to 11 allegations involving radioactive materials reported during the review period. 

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

overexposures, damaged equipment, transportation events, leaking sources, and equipment 

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

thorough, complete, and comprehensive. Initial responses were prompt and were well 
Illinois Final IMPEP Report Page 8 

coordinated, and the level of effort was commensurate with the health and safety significance. 

The RAM Section dispatched inspectors for on-site investigations in eight of the cases reviewed 

and took suitable enforcement and followup actions. When no immediate threat was present 

and the RAM Section determined that the licensee had qualified, competent individuals 

investigating the incident, the RAM Section generally responded by telephone with a followup 

review during the next inspection. The review team noted that, at the conclusion of 

investigations, inspectors generated narrative reports that thoroughly documented the 

investigations. 

If an incident meets the reporting criteria established in the Office of Federal and State Materials 

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

Events,” the RAM Section promptly notifies NRC’s Headquarters Operations Center, typically by 

e-mail, using the information template established for NMED. If the investigation is complex and 

extends over a period of time, NMED is updated as additional information becomes available. 

Of the incidents evaluated by the review team, all had been reported to the NRC within the 

required time frame and submitted for inclusion in NMED. 

The review team examined the RAM Section’s implementation of its incident and allegation 

processes, including written procedures for handling allegations and incident response, file 

documentation, notification of incidents to the NRC Headquarters Operations Center, and the 

use of NMED software. When notification of an incident or an allegation is received, the 

Inspection and Enforcement Manager determines the appropriate level of initial response. 

The RAM Section receives approximately 75 to 100 incidents involving radioactive material 

annually, of which approximately 75 percent are radiation monitor trips at scrap facilities and 

landfills. Since 2012, the Bureau of Environmental Safety took the lead for monitor trip 

response. All monitor trips are responded to with an onsite visit. The State has made this 

activity a priority because it believes that orphan sources at non-licensed facilities present a risk 

for unnecessary public exposure. 

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

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

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

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

raised. The review team also noted that the RAM Section thoroughly documented the 

investigations and retained all necessary documentation to appropriately close the allegations. 

The RAM Section notified the allegers of the conclusion of its investigation. Additionally, the 

review team determined that the RAM Section adequately protected the identity of allegers. 

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

that Illinois’ 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. The NRC’s 
Illinois Final IMPEP Report Page 9 

Agreement with Illinois does not relinquish regulatory authority for a low level radioactive waste 

disposal program; therefore, this non-common performance indicator did not apply to this 

review. 

4.1 Compatibility Requirements

4.1.1 Legislation

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

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

designated as the State radiation protection agency under the provisions of the Radiation 

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

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

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

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

is subject to sunset laws. Public Act 91-752, which was effective June 1, 2005, extended the 

sunset date for the Radiation Protection Act until January 1, 2021. 

Other legislation that affects the radiation control program is as follows: the Illinois Emergency 

Management Agency Act (20 ILCS 3305); the Nuclear Safety Law of 2004 (20 ILCS 3310); the 

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

Management Act (420 ILCS 20); and the Uranium and Thorium Mill Tailings Control Act (420 

ILCS 42), which provide authority for the low-level radioactive waste disposal and uranium 

recovery programs; Freedom of Information Act (5 ILCS 140); and Illinois Administrative 

Procedure Act (5 ILCS 100). 

4.1.2 Program Elements Required for Compatibility 

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

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

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

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

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

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

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

lieu of regulations. This process generally takes approximately one year to complete. 

Regulations are not subject to sunset laws. 

Once drafted, a proposed regulation is sent to the Agency Director’s office and to the 

Governor’s office for initial approval. Next, the proposed regulation is submitted to the Joint 

Committee on Administrative Rules (JCAR), a bipartisan legislative committee. Comments on 

the regulation are then requested with publication in the Illinois Register. After comment 

resolution and a hearing before JCAR, the Agency may file for regulation adoption. An 

expedited process may be used for regulations that require strict compatibility with the NRC 

regulations. 
Illinois Final IMPEP Report Page 10 

The review team evaluated the Bureau’s response to the questionnaire, reviewed the status of 

regulations required to be adopted by the State under the Commission’s adequacy and 

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

Regulation Status Sheet that FSME maintains. Current NRC policy requires that Agreement 

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

after they are effective unless otherwise mandated by the Commission. 

Since the last IMPEP review, the State submitted two packages covering six amendments for 

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

amendments currently required for compatibility. 

A list of regulations that are due for adoption may be found at: 

http://nrc-stp.ornl.gov/rss_regamendents.html.

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

that Illinois’ performance with respect to the indicator, Compatibility Requirements, be found 

satisfactory. 

4.2 Sealed Source and Device Evaluation Program

In reviewing this indicator, the review team used three subelements to evaluate the RAM 

Section’s performance regarding the Sealed Source and Device (SS&D) Evaluation Program. 

These subelements are (1) Technical Staffing and Training, (2) Technical Quality of the Product 

Evaluation Program, and (3) Evaluation of Defects and Incidents Regarding SS&Ds. 

In assessing the State SS&D evaluation activities, the review team examined the information 

provided in response to the IMPEP questionnaire and evaluated the SS&D registry sheets and 

supporting documents processed during the review period. The team also evaluated SS&D 

staff training records, the use of guidance documents and procedures, and interviewed the staff 

currently conducting SS&D evaluations. 

4.2.1. Technical Staffing and Training

The RAM Section has a documented qualification program for SS&D reviewers as a subsection 

of its overall staff qualification procedures. The RAM Section currently has three qualified 

reviewers, all of whom have completed the NRC SS&D Workshop/course. One of the reviewers 

primarily performs concurrence reviews. The RAM Section intends to seek training for at least 

one additional staff member when the NRC SS&D training course is offered in 2014. 

4.2.2 Technical Quality of the Product Evaluation Program

During the review period, the RAM Section processed 19 SS&D actions: 9 inactivations, 9 

amendments, and 1 new application. There were no emerging technology evaluations 

processed during the review period. The review team evaluated six actions processed during 

the review period. The casework selected for review was representative of two of the three 

primary qualified reviewers. A listing of the SS&D registries reviewed by the review team may 

be found in Appendix F. 
Illinois Final IMPEP Report Page 11 

The review team identified that all of the SS&D registries issued were signed by two qualified 

individuals. The RAM Section performed evaluations based on sound conservative 

assumptions and good health physics practices to ensure public health and safety was 

adequately protected. 

In assessing the RAM Section’s SS&D evaluation activities, the review team examined 

information contained in the questionnaire response, and interviewed program staff and 

supervisors. The review team confirmed that the RAM Section follows the recommended 

guidance from the NRC SS&D Workshop, NUREG-1556 Series Guidance, applicable and 

pertinent American National Standards Institute (ANSI) standards and Illinois regulations, 

statutes, policies and procedures. The review team verified these documents were available 

and used appropriately in performing SS&D evaluations. 

Reviewers documented detailed information pertaining to the SS&D review process in the files. 

The review team determined that product evaluations were complete and adequately addressed 

the integrity of the products during use and in the event of accidents. 

4.2.3 Evaluation of Defects and Incidents Regarding SS&Ds

Utilizing NMED, the review team determined that no events were reported during the review 

period that involved sources/devices manufactured or distributed by a licensee with a SS&D 

registered in Illinois. The review team also interviewed program staff who confirmed that no 

devices registered in Illinois had been involved in an incident during the review period. 

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

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

Program, be found satisfactory. 

4.3 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 Illinois Agreement State Program has 

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

LLRW disposal facility until such time as the State begins the siting process 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 Illinois. Accordingly, the review team did not review this 

indicator. 

4.4 Uranium Recovery Program 

In reviewing this indicator, the review team used five subelements to evaluate the State’s 

performance regarding the uranium (source material) recovery program. These subelements 

are (1) Technical Staffing and Training, (2) Status of Uranium Recovery Inspection Program, (3) 
Illinois Final IMPEP Report Page 12 

Technical Quality of Inspections, (4) Technical Quality of Licensing Actions, and (5) Technical 

Quality of Incident and Allegation Activities. 

The BERS administers the State’s uranium recovery program. At the time of the IMPEP 

review, the BERS regulated one uranium recovery license, which is in the process of 

decommissioning. During the review period, the site has operated primarily in maintenance 

and monitoring mode. Site activities have consisted of handling, packaging, and shipment 

of overburden from offsite properties being remediated under the U.S. Environmental 

Protection Agency Superfund program. In addition, limited site remediation and ongoing 

environmental monitoring activities continue to be performed. The final phases of 

decommissioning are expected to continue in 2013-2014, pending issuance of a license 

which was under timely renewal at the time of the IMPEP review. 

4.4.1 Technical Staffing and Training 

In reviewing this subelement, the review team considered staffing level, technical 

qualifications of the staff, staff training, and staff turnover. 

The duties and responsibilities for the Illinois uranium recovery program are assigned to staff 

within the EM Section of the BERS. Bureau staff members and management are responsible 

for licensing actions associated with source material licenses. Program staff members are 

responsible for routine/on-going inspections of uranium recovery facilities. 

The EM Section, which is supervised by the Section Head, is divided into three units: 

Environmental Monitoring, Environmental Compliance, and LLRW & Decommissioning. The 

EM Section also employs one full-time technical staff member as a resident inspector at the 

former uranium recovery site in West Chicago. At the time of the review, there were five 

technical staff members and managers, totaling approximately 3.7 FTE, in the EM Section 

who provide technical support to the Bureau by managing the uranium recovery, financial 

assurance, and orphan source programs. They also provide decommissioning and license 

termination support. 

Since the 2009 IMPEP review, four individuals left the BERS, including the Bureau Chief and 

staff from the LLRW and Decommissioning Unit. All of these positions have been filled. At the 

time of this review, there were no vacant positions in the LLRW and uranium recovery 

programs. 

The BERS also uses approximately 4.0 FTE from contractor personnel for engineering 

technical support for license review and evaluation and construction oversight of 

decommissioning activities at the site. Bureau and contractor staffing levels have remained 

stable throughout the IMPEP review period. The staff has expertise in various technical 

disciplines including health physics, geology, hydrology, environmental laboratory analysis and 

engineering. 

The review team examined staff training records as well as interviewed various staff members 

regarding training and areas of expertise. The RAM Section’s training and qualification plan 

includes a plan for the EM Section staff positions which provide technical support to the 

radioactive materials program. Both the RAM Section and the EM Section have the 
Illinois Final IMPEP Report Page 13 

responsibility to maintain their respective staff’s training and qualification records. Staff 

members are assigned increasingly complex duties as they progress through the qualification 

process. The review team concluded that the RAM Section’s training program is adequate to 

carry out its regulatory duties. The review team determined that the staffing levels, staff 

qualifications, and training levels for the uranium recovery program are adequate. 

4.4.2 Status of Uranium Recovery Inspection Program 

In reviewing this subelement, the review team evaluated the inspection frequency for uranium 

recovery licensees and the timeliness of inspection finding communications to the licensee. 

The review team's evaluation is based on Illinois’s response to the questionnaire relative to 

this indicator, the uranium recovery inspection schedule, selected inspection casework 

records, and interviews with inspection staff and managers. 

The site evaluated under the uranium recovery program has an onsite resident inspector who 

performs ongoing, continuous site assessment and inspection related activities. Interviews with 

the onsite inspector and program management indicated that issues and findings are reported 

to management primarily through email and phone contact and are followed up with formal 

correspondence to the licensee when warranted. The review team noted that the BERS does 

not issue a formal inspection report during periods when the site is in monitoring mode. After 

discussions of this matter with the review team, the Bureau Chief and the EM Section Head 

agreed that a formal report, issued on a periodic basis, summarizing the inspection-related 

activities at the uranium recovery site, would be appropriate and beneficial to the Program. The 

EM Section will conduct annual inspections and issue formal inspection reports when the site 

returns to active decommissioning activities. 

In addition to the onsite resident inspector, the BERS relies upon contractors who perform 

periodic site assessments and quality assurance audits and evaluations of activities at the site. 

The licensee also performs similar audits which are reported to the BERS, which reviews the 

contractor audits and reports and takes the appropriate enforcement actions. 

The frequency identified for the source material recovery category is five years. With the 

presence of an on-site inspector on an ongoing basis, and the audit functions performed by 

agency contractors, the review team concluded that there were no overdue inspections in the 

uranium recovery program. 

The review team determined that inspection correspondence was issued within 30 days of the 

inspections or audits. Program management reviewed all inspection findings. Appropriate 

followup actions were conducted when items of noncompliance were identified by the staff 

resident inspector, BERS contractors, or as a result of audit findings by the licensee. 

4.4.3 Technical Quality of Inspections 

In reviewing this subelement, the review team examined contractor audit reports and 

contractor environmental reports, and interviewed the program management and resident 

inspector. The uranium recovery program inspection files evaluated by the review team are 

listed in Appendix C. 
Illinois Final IMPEP Report Page 14 

The inspector interviews and casework reviews confirmed that Illinois inspections were 

adequate and included reviews of operational activities and pertinent records. The review 

team also confirmed that the State appropriately communicated issues and violations to the 

licensee. 

The review team determined that the ongoing activities of the onsite inspector and periodic site 

and contractor audit reports provided appropriate depth of coverage, addressed license 

conditions and regulatory requirements, and demonstrated that the Agency pursued corrective 

actions for items of noncompliance that were identified. Inspection and audit files contained 

information, data, and diagrams documenting both general facility features and items of interest 

or concerns. 

4.4.4 Technical Quality of Licensing Actions 

For this subelement, the review team examined licenses and associated documentation 

related to licensing, license amendments and other licensing documentation of the uranium 

recovery site undergoing decommissioning. Appendix D lists the licensing files reviewed. 

For the uranium recovery facility evaluated, license renewals occurred on an annual basis 

with limited changes in license conditions. During the review period, there was a transition 

of the facility from the licensee who held the license for many years, to a licensee that 

subsequently filed for bankruptcy in 2009. In 2011, through court actions, the site was 

transitioned to the current licensee who also acts as the site trustee. The transition in 

license to the trustee was tied to court action files and activities, making the review complex. 

Interviews with staff legal counsel involved in the transition indicated that the licensing 

process of the trustee was conducted through the legal processes surrounding the site. 

Based on the casework evaluated, the review team concluded that the licensing actions 

were of adequate quality and consistent with Illinois procedures, State regulations, and good 

health physics practices. 

4.4.5 Technical Quality of Incident and Allegation Activities 

For this subelement, the review team examined files and associated documentation and 

correspondence related to incident and allegation activities, response timeliness, and 

inspection and audit reports, and interviewed the personnel involved with incident and 

allegation activities. 

The review team evaluated Illinois’s response to one incident associated with the 

uranium/source recovery program site. The State’s investigation of the incident was 

thorough and results of the incident investigation were discussed with the licensee and other 

regulatory entities. Appropriate enforcement actions were taken given the scope of the 

violations noted. A listing of the incident casework examined can be found in Appendix E. 

No allegations pertaining to the site were indicated for the review period. 

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

that Illinois’ performance with respect to the indicator, Uranium Recovery Program, be found 

satisfactory. 
Illinois Final IMPEP Report Page 15 

5.0 SUMMARY 

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

performance indicators reviewed. The review team did not make any recommendations 

regarding program performance by the State and determined that the recommendation from the 

2009 IMPEP review should be closed. 

Accordingly, the review team recommended, and the MRB agreed, that the Illinois Agreement 

State Program be found adequate to protect public health and safety and compatible with the 

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 5 years. 
LIST OF APPENDICES 

Appendix A IMPEP Review Team Members 

Appendix B Illinois Organization Charts 

Appendix C Inspection Casework Reviews 

Appendix D License Casework Reviews 

Appendix E Incident Casework Reviews 

Appendix F Sealed Source and Device Casework Reviews 
APPENDIX A 

IMPEP REVIEW TEAM MEMBERS 

Name Area of Responsibility

Donna Janda, Region I Team Leader 

 Technical Staffing and Training 

 Inspection Accompaniments 

Stephen Hammann, Region I Technical Quality of Licensing Actions 

James Lynch, Region III Technical Quality of Incident and Allegation 

Activities 

 Compatibility Requirements 

 Inspection Accompaniments 

Maria Arribas-Colon, FSME Status of Materials Inspection Program 

James Jarvis, State of Colorado Sealed Source and Device Evaluation Program 

 Uranium Recovery Program 

Vanessa Danese, State of Texas Technical Quality of Inspections 
APPENDIX B 

ILLINOIS ORGANIZATION CHARTS 

ADAMS ACCESSION NO.: ML13122A397 
 

 APPENDIX C 

INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

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

Inspection Type: Routine/Special, Announced Priority: 1 

Inspection Date: 07/15/10 Inspectors: GM, SK 

File No.: 2 

Licensee: Richardson Electronics, Ltd. License No.: IL-01477-01 

Inspection Type: Routine, Announced Priority: 3 

Inspection Date: 03/11/11 Inspector: JP 

File No.: 3 

Licensee: Illinois Testing Services, Inc. License No.: IL-01545-01 

Inspection Type: Routine/Special, Unannounced Priority: 1 

Inspection Date: 05/11-14/12 Inspector: AG 

File No.: 4 

Licensee: St. Joseph Medical Center License No.: IL-01206-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 01/05-06/11 Inspector: SK 

File No.: 5 

Licensee: Northwest Cardiovascular Associates, S.C. License No.: IL-02018-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 08/27/10 Inspector: JK 

File No.: 6 

Licensee: Alexian Brothers Medical Center License No.: IL-01418-01 

Inspection Type: Routine/Special, Announced Priority: 2 

Inspection Date: 10/25-26/12 Inspector: WH 

File No.: 7 

Licensee: GeoLog Well Services, Inc. License No.: IL-02277-01 

Inspection Type: Routine, Announced Priority: 3 

Inspection Date: 10/27/10 Inspector: WH 

File No.: 8 

Licensee: McDonough District Hospital License No.: IL-01201-01 

Inspection Type: Routine, Announced Priority: 3 

Inspection Date: 02/07/13 Inspector: BC 

File No.: 9 

Licensee: Advanced Heart Group, S.C. License No.: IL-02254-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 03/30/12 Inspector: JK 
Illinois Final IMPEP Report Page C. 2 

Inspection Casework Reviews 

File No.: 10 

Licensee: Northern Illinois Cancer Treatment Center License No.: IL-02258-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 12/12/11 Inspector: RM 

File No.: 11 

Licensee: Colby-Thielmeier Testing Co. License No.: IL-00144-01 

Inspection Type: Reciprocity, Announced Priority: 1 

Inspection Date: 10/02/09 Inspector: GM 

File No.: 12 

Licensee: Triad Isotopes, Inc. License No.: IL-01117-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 02/24/10 Inspector: JP 

Comment: Inspection documentation issued to licensee 12 days late. 

File No.: 13 

Licensee: Northern Shared Medical Services Inc. License No.: IL-02204-01 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 11/29/12 Inspector: BC 

File No.: 14 

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

Inspection Type: Routine/Special, Announced Priority: 3 

Inspection Date: 07/16-18/12 Inspector: RM, JP 

File No.: 15 

Licensee: Northwestern Memorial Healthcare License No.: IL-01037-02 

Inspection Type: Routine/Special, Announced Priority: 2 

Inspection Date: 07/22-24/09 Inspector: WH, AG 

File No.: 16 

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

Inspection Type: Routine/Special, Unannounced Priority: 2 

Inspection Date: 05/17-18/10 Inspector: JP 

File No.: 17 

Licensee: Children’s Hospital of Chicago Medical Center License No.: IL-01165-01 

Inspection Type: Routine/Special, Announced Priority: 3 

Inspection Date: 07/07-08/11 Inspector: RM 

File No.: 18 

Licensee: Triumph Radiology, Inc. License No.: IL-01816-01 

Inspection Type: Routine, Announced Priority: 3 

Inspection Date: 06/02/11 Inspector: JK 
Illinois Final IMPEP Report Page C. 3 

Inspection Casework Reviews 

File No.: 19 

Licensee: Alliance Healthcare Services, Inc. License No.: IL-02133-01 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 06/08/10 Inspector: JP 

File No.: 20 

Licensee: Mistras Group, Inc. License No.: IL-01225-22 

Inspection Type: Routine/Special, Announced Priority: 1 

Inspection Date: 05/18/11 Inspector: SK 

File No.: 21 

Licensee: Elgiloy Specialty Metals License No.: IL-02397-01 

Inspection Type: Initial, Unannounced Priority: 5 

Inspection Date: 08/27/10 Inspector: AG 

File No.: 22 

Licensee: Chase Environmental Group, Inc. License No.: IL-00386-01 

Inspection Type: Reciprocity, Unannounced Priority: 2 

Inspection Date: 07/06/09 Inspector: KG 

File No.: 23 

Licensee: Mercy Health Systems License No.: IL-02437-01 

Inspection Type: Initial, Unannounced Priority: 3 

Inspection Date: 11/26/12 Inspector: JP 

File No.: 24 

Licensee: GEO Consultants, Inc. License No.: IL-02363-01 

Inspection Type: Initial, Announced Priority: 2 

Inspection Date: 10/19/09 Inspector: GM 

File No.: 25 

Licensee: Knight Hawk Coal, LLC License No.: IL-02431-01 

Inspection Type: Initial, Unannounced Priority: 5 

Inspection Date: 01/30/13 Inspector: SK 

File No.: 26 

Licensee: Toshiba Medical Research Institute USA, Inc. License No.: IL-02373-01 

Inspection Type: Initial, Announced Priority: 5 

Inspection Date: 10/27/09 Inspector: JK 

File No.: 27 

Licensee: Material Service Testing, Inc. License No.: IL-02408-01 

Inspection Type: Initial, Unannounced Priority: 5 

Inspection Date: 08/06/10 Inspector: JP 
Illinois Final IMPEP Report Page C. 4 

Inspection Casework Reviews 

Uranium Recovery Program

File No.: 28 

Licensee: Tronox, LLC License No.: STA-583 

Inspection Type: Special Priority: 5 

Inspection Date: 2010 Inspector(s): Licensee contractor 

File No.: 29 

Licensee: Weston Solutions, Inc. License No.: STA-583 

Inspection Type: Special Priority: 5 

Inspection Date: November 2012 (Draft) Inspector: Bureau contractor 

File No.: 30 

Licensee: Weston Solutions, Inc. License No.: STA-583 

Inspection Type: Special Priority: 5 

Inspection Date: 08/08/12 Inspector: Bureau contractor 

INSPECTOR ACCOMPANIMENTS 

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

Accompaniment No.: 1 

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

Inspection Type: Routine/Special, Announced Priority: 1 

Inspection Date: 03/13/13 Inspector: RM 

Accompaniment No.: 2 

Licensee: Sterigenics U.S., LLC License No.: IL-01220-01 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 03/14/13 Inspector: WH 

Accompaniment No.: 3 

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

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 03/19/13 Inspector: BC 

Accompaniment No.: 4 

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

Inspection Type: Routine/Special, Announced Priority: 2 

Inspection Date: 03/20/13 Inspector: SK 
 

APPENDIX D 

LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Granite City Illinois Hospital Company, LLC License No.: IL-01061-01 

Type of Action: Renewal Amendment No.: 29 

Date Issued: 06/29/12 License Reviewer: NA 

File No.: 2 

Licensee: Siemens Medical Solutions USA, Inc. License No: IL-01130-02 

Type of Action: Amendment Amendment No.: 46 

Date Issued: 04/14/13 License Reviewer: MB 

File No.: 3 

Licensee: Terracon Consultants, Inc. License No.: IL-01402-01 

Type of Action: Amendment Amendment No.: 32 

Date Issued: 08/24/12 License Reviewer: NA 

File No.: 4 

Licensee: Varian Medical Systems Security & Inspection Products License No: IL-01555-01 

Type of Action: Amendment Amendment No.: 14 

Date Issued: 03/18/11 License Reviewer: MB 

File No.: 5 

Licensee: Central DuPage Hospital License No.: IL-01208-01 

Type of Action: Amendment Amendment No.: 26 

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

File No.: 6 

Licensee: Civil Constructors, Inc. License No: IL-01730-01 

Type of Action: Renewal Amendment No.: 07 

Date Issued: 12/27/11 License Reviewer: RH 

File No.: 7 

Licensee: REVISS Services, Inc. License No.: IL-02058-01 

Type of Action: Amendment Amendment No.: 22 

Date Issued: 03/29/12 License Reviewer: CV 

File No.: 8 

Licensee: Abb Vie, Inc. License No: IL-01478-01 

Type of Action: Renewal Amendment No.: 25 

Date Issued: 06/04/10 License Reviewer: SK 

File No.: 9 

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

Type of Action: Renewal Amendment No.: 23 

Date Issued: 06/10/11 License Reviewer: MB 
Illinois Final IMPEP Report Page D. 2 

License Casework Reviews 

File No.: 10 

Licensee: Keeley & Sons, Inc. License No: IL-01505-01 

Type of Action: Amendment Amendment No.: 08 

Date Issued: 01/08/13 License Reviewer: WC 

File No.: 11 

Licensee: Sterigenics U.S., LLC License No.: IL-01220-01 

Type of Action: Amendment Amendment No.: 38 

Date Issued: 04/19/12 License Reviewer: MB 

File No.: 12 

Licensee: Cardinal Health 414, LLC License No: IL-01721-03 

Type of Action: Amendment (Financial Assurance) Amendment No.: 03 

Date Issued: 08/24/12 License Reviewer: MK 

File No.: 13 

Licensee: Hot Shots NM, LLC License No.: IL-02322-01 

Type of Action: Amendment Amendment No.: 08 

Date Issued: 07/11/12 License Reviewer: RH 

File No.: 14 

Licensee: Chemtura Corporation License No: IL-01314-01 

Type of Action: Renewal Amendment No.: 15 

Date Issued: 05/26/10 License Reviewer: RH 

File No.: 15 

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

Type of Action: Amendment Amendment No.: 14 

Date Issued: 03/18/13 License Reviewer: TL 

File No.: 16 

Licensee: Baker Atlas License No: IL-01508-01 

Type of Action: Amendment Amendment No.: 18 

Date Issued: 07/09/10 License Reviewer: TL 

File No.: 17 

Licensee: McNDT Pipeline, Ltd. License No.: IL-01875-01 

Type of Action: Renewal Amendment No.: 11 

Date Issued: 09/29/12 License Reviewer: TL 

File No.: 18 

Licensee: Veterinary Speciality Center License No: IL-02071-02 

Type of Action: New Amendment No.: 0 

Date Issued: 12/07/10 License Reviewer: TL 
Illinois Final IMPEP Report Page D. 3 

License Casework Reviews 

File No.: 19 

Licensee: Illinois Regional Cancer Center (IRCC) License No.: IL-02427-01 

Type of Action: New Amendment No.: 0 

Date Issued: 12/01/11 License Reviewer: TL 

File No.: 20 

Licensee: Acuren Inspections, Inc. License No: IL-01899-01 

Type of Action: Amendment Amendment No.: 25 

Date Issued: 02/20/13 License Reviewer: TL 

File No.: 21 

Licensee: STERIS, Inc. License No.: IL-01123-01 

Type of Action: Termination (decommissioning) Amendment No.: 17 

Date Issued: 03/19/12 License Reviewer: SK 

File No.: 22 

Licensee: Advanced Radiotherapy Specialists License No: IL-02433-01 

Type of Action: New (denial of application) Amendment No.: NA 

Date Issued: 11/27/12 License Reviewer: TL 

File No.: 23 

Licensee: Rockford Testing Company, Inc. License No.: IL-02421-01 

Type of Action: New Amendment No.: 0 

Date Issued: 05/24/11 License Reviewer: MB 

Uranium Recovery Program

File No.: 1 

Licensee: Tronox (Formerly Kerr-McGee Chemical LLC) License No.: STA-583 

Type of Action: Renewal Amendment No.: 74 

Date Issued: 02/22/10 License Reviewer: GM 

File No.: 2 

Licensee: Weston Solutions, Inc. License No: STA-583 

Type of Action: Amendment Amendment No.: 75 

Date Issued: 02/14/11 License Reviewer: GM 

File No.: 3 

Licensee: Weston Solutions, Inc. License No.: STA-583 

Type of Action: Renewal Amendment No.: 76 

Date Issued: 02/10/12 License Reviewer: GM 

File No.: 4 

Licensee: Weston Solutions, Inc. License No.: STA-583 

Type of Action: Renewal Amendment No.: 77 

Date Issued: 09/07/12 License Reviewer: AK 
 

APPENDIX E 

INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Iroquois Paving Corporation License No.: IL-01909-01 

Date of Incident: 06/05/09 NMED Log No.: 090534 

Investigation Date: 06/05/09 Type of Incident: Damaged Equipment 

 Type of Investigation: Site 

File No.: 2 

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

Date of Incident: 07/27/09 NMED Log No.: 090648 

Investigation Date: 07/29/09 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Telephone 

File No.: 3 

Licensee: H.H. Holmes Testing Laboratories, Inc. License No.: IL-01828-01 

Date of Incident: 08/03/09 NMED Log No.: 090652 

Investigation Date: 08/03/09 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Telephone 

File No.: 4 

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

Date of Incident: 08/18/09 NMED Log No.: 090704 

Investigation Date: 08/18/09 Type of Incident: Leaking Source 

 Type of Investigation: Telephone 

File No.: 5 

Licensee: Loyola University Medical Center License No.: IL-01131-02 

Date of Incident: 09/21/09 NMED Log No.: 090755 

Investigation Date: 09/30/09 Type of Incident: Fetal Overexposure 

 Type of Investigation: Telephone 

File No.: 6 

Licensee: Terracon Consultants License No.: IL-01402-01 

Date of Incident: 10/03/09 NMED Log No.: 090762 

Investigation Date: 10/03/09 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Telephone 

File No.: 7 

Licensee: Mohamed Megahy, MD, Ltd. License No.: IL-02032-01 

Date of Incident: 05/01/07 (reported on 06/17/10) NMED Log No.: 100319 

Investigation Date: 06/17/10 Type of Incident: Fetal Overexposure 

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

Incident Casework Reviews 

File No.: 8 

Licensee: Riverside Medical Center License No.: IL-01242-01 

Date of Incident: 07/13/10 NMED Log No.: 100362 

Investigation Date: 07/15/10 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Site 

File No.: 9 

Licensee: Rush University Medical Center License No.: IL-01766-01 

Date of Incident: 08/18/10 NMED Log No.: 100427 

Investigation Date: 08/18/10 Type of Incident: Medical Event 

 Type of Investigation: Telephone 

File No.: 10 

Licensee: Methodist Hospital of Chicago License No.: IL-01144-01 

Date of Incident: 10/21/10 NMED Log No.: 110012 

Investigation Date: 11/12/10 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Telephone 

File No.: 11 

Licensee: Rush University Medical Center License No.: IL-01766-01 

Date of Incident: 11/23/10 NMED Log No.: 110032 

Investigation Date: 01/19/11 Type of Incident: Medical Event 

 Type of Investigation: Site 

File No.: 12 

Licensee: Northwestern Memorial Hospital License No.: IL-01037-02 

Date of Incident: 04/26/11 NMED Log No.: 110192 

Investigation Date: 04/26/11 Type of Incident: Medical Event 

 Type of Investigation: Telephone 

File No.: 13 

Licensee: Advocate Christ Hospital and Medical Center License No.: IL-01720-01 

Date of Incident: 05/13/11 NMED Log No.: 120582 

Investigation Date: 05/18/11 Type of Incident: Medical Event 

 Type of Investigation: Telephone 

File No.: 14 

Licensee: Wood River Refinery License No.: IL-01282-01 

Date of Incident: 07/22/11 NMED Log No.: 110403 

Investigation Date: 08/8/11 Type of Incident: Damaged Equipment 

 Type of Investigation: Telephone 

File No.: 15 

Licensee: Swedish American Hospital License No.: IL-01067-01 

Date of Incident: 09/13/11 NMED Log No.: 110505 

Investigation Date: 09/26/11 Type of Incident: Medical Event 

 Type of Investigation: Site 
Illinois Final IMPEP Report Page E. 3 

Incident Casework Reviews 

File No.: 16 

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

Date of Incident: 01/04/12 NMED Log No.: 120052 

Investigation Date: 01/09/12 Type of Incident: Equipment Failure 

 Type of Investigation: Telephone 

File No.: 17 

Licensee: Midwest Regional Medical Center License No.: IL-01104-01 

Date of Incident: 03/20/12 NMED Log No.: 120209 

Investigation Date: 04/04/12 Type of Incident: Medical Event 

 Type of Investigation: Site 

File No.: 18 

Licensee: IBA Molecular License No.: IL-02074-01 

Date of Incident: 05/14/12 NMED Log No.: 120334 

Investigation Date: 05/18/12 Type of Incident: Leaking Source 

 Type of Investigation: Telephone 

File No.: 19 

Licensee: Interra, Inc. License No.: IL-02000-01 

Date of Incident: 06/26/12 NMED Log No.: 120381 

Investigation Date: 06/26/12 Type of Incident: Damaged Equipment 

 Type of Investigation: Site 

File No.: 20 

Licensee: GE Healthcare License No.: IL-01044-01 

Date of Incident: 01/21/13 NMED Log No.: 130119 

Investigation Date: 01/22/13 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Telephone 

File No.: 21 

Licensee: Non-Licensee License No.: N/A 

Date of Incident: 04/12/13 NMED Log No.: N/A 

Investigation Date: 04/12/13 Type of Incident: Transportation Event 

 Type of Investigation: Site 

Uranium Recovery Program

File No.: 22 

Licensee: Tronox License No.: STA-583 

Date of Incident: 09/28/10 NMED Log No.: N/A 

Investigation Date: 09/28/10 Type of Incident: Transportation Event 

 Type of Investigation: Telephone 
APPENDIX F 

SEALED SOURCE AND DEVICE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Registry No.: IL-1325-D-101-G SS&D Type: (G) Portable Moisture Gauge 

Applicant Name: Dewpointer Repair Type of Action: New 

Date Issued: 06/07/10 SS&D Reviewer(s): MEB, CGV 

File No.: 2 

Registry No.: IL-136-D-931-S SS&D Type: “General Medical Use” 

Applicant Name: GE Healthcare Type of Action: Inactivation 

Date Issued: 01/05/12 SS&D Reviewer: SMK, MEB 

File No.: 3 

Registry No.: IL-1079-D-101-G SS&D Type: (E) Beta Gauge 

Applicant Name: Indev Gauging Systems, Inc. Type of Action: Amendment 

Date Issued: 12/22/11 SS&D Reviewer(s): SMK, MEB 

File No.: 4 

Registry No.: IL-8230-D-801-G SS&D Type: (D) Gamma Gauging 

Applicant Name: Stan A. Huber Consultants, Inc. Type of Action: Inactivation 

Date Issued: 01/25/11 SS&D Reviewer: MEB, CGV 

File No.: 5 

Registry No.: IL-422-D-101-S SS&D Type: (A) Industrial Radiography 

Applicant Name: Lixi, Inc. Type of Action: Amendment 

Date Issued: 04/20/10 SS&D Reviewer(s): SMK, MEB 

File No.: 6 

Registry No.: IL-422-D-101-S SS&D Type: (A) Industrial Radiography 

Applicant Name: Lixi, Inc. Type of Action: Amendment 

Date Issued: 05/26/11 SS&D Reviewer(s): SMK, MEB 
ATTACHMENT 

May 30, 2013 Email from C. Gibb Vinson 

Illinois’s Response to the Draft Report 

ADAMS Accession No.: ML13155A010