UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

November 7, 2014 

Mr. Scott Thompson 

Executive Director 

Department of Environmental Quality 

P.O. Box 1677 

Oklahoma City, OK 73101-1677 

Dear Mr. Thompson: 

On October 24, 2014, 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 program adequate to protect public 

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

Section 5.0, page 12, of the enclosed final report contains a summary of the IMPEP team’s 

findings and recommendations. The review team made two recommendations in regard to 

program performance by the Oklahoma Agreement State Program during this review. The MRB 

determined the recommendation concerning information security could be removed since the 

Oklahoma program took action following the onsite review to fully address the issue. We 

request your evaluation and response to the second recommendation in the report within 30 

days from receipt of this letter. 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 August 2016. 
S. Thompson -2- 

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/ 

 Roy P. Zimmerman 

 Acting 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: Bill Dundulis, RI 

 Organization of Agreement States 

 Liaison to the MRB 

 Jimmy D. Givens, Deputy Executive Director 

 Department of Environmental Quality 

 Mike Broderick, Manager 

 Radiation Management Section 
S. Thompson -2- 

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/

 Roy P. Zimmerman 

 Acting 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: Bill Dundulis, RI 

 Organization of Agreement States 

 Liaison to the MRB 

 Jimmy D. Givens, Deputy Executive Director 

 Department of Environmental Quality 

 Mike Broderick, Manager 

 Radiation Management Section 

DISTRIBUTION: 

See Next Page) 

ADAMS Accession No.: ML14300A380

OFFICE RngI:TL MSTR MSTR MSTR:D TechEd NMSS:D EDO:Acting DEDMRT

NAME MFord 

via email

LDimmick DWhite 

w/edits

LDudes 

(SAbrahams for) 

CPoland 

(PTressler for) 

CHaney RZimmerman 

DATE 10/27/14 10/27/14 10/27/14 10/29/24 10/30/14 10/30/14 11/07/14 

OFFICIAL RECORD COPY
Letter to S. Thompson from R. Zimmerman dated: November 07, 2014 

SUBJECT: OKLAHOMA FY2014 FINAL IMPEP REPORT 

DISTRIBUTION: (SP08) 

RidsEdoMailCenter 

JFoster, OEDO 

RidsOgcMailCenter 

JBiggins, OGC 

JOlmstead, OGC 

RidsRgn3MailCenter 

DRoberts, RIII 

RidsRgn4MailCenter 

MShaffer, RUV 

LHowell, RIV 

RErickson, RIV 

RidsSecyCorrespondenceMailCenter Chairman Macfarlane 

KMcConnell, NMSS Commissioner Svinicki 

SMoore, NMSS Commissioner Ostendorff 

PHenderson, NMSS Commissioner Baran 

BTharakan, RIV/RSAO SECY 

SSeeley, RI 

JWalden, KS 

MBeardsley, NMSS 

OAS Board 

JWeil, OCA (2 copies) 
Enclosure 

INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

REVIEW OF THE OKLAHOMA AGREEMENT STATE PROGRAM 

August 4–8, 2014 

FINAL REPORT
EXECUTIVE SUMMARY 

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

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

the period of August 4–8, 2014, by a review team composed of technical staff members from 

the U.S. Nuclear Regulatory Commission (NRC) and the State of Kansas.

Based on the results of this review, Oklahoma’s performance was found satisfactory for all 

performance indicators reviewed. The review team made two recommendations concerning 

program performance by the State regarding the marking of sensitive information/securing of 

documents and incident reporting and follow-up. In the Management Review Board (MRB) 

discussion of the IMPEP team’s recommendations, the MRB determined the recommendation 

concerning information security could be removed since the Oklahoma program took action 

following the onsite review to fully address the issue (Section 3.4). In addition, the review team 

determined that the four recommendations from the 2010 IMPEP review should be closed. 

Accordingly, the review team recommended, and the MRB agreed, that the Oklahoma 

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

with the NRC's program. The review team recommended, and the MRB, that the next IMPEP 

review take place in approximately 4 years and that a periodic meeting be held in 2 years. 
Oklahoma Final IMPEP 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 August 4-8, 2014, by a review team composed of 

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

Kansas. 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 September 18, 2010 to August 8, 2014, were discussed 

with Oklahoma managers on the last day of the review. 

A draft of this report was issued to Oklahoma on September 2, 2014, for factual comment. 

Oklahoma responded to the findings and conclusions of the review by letter dated September 

18, 2014. A copy of the State’s response is included as an attachment to this report. The 

Management Review Board (MRB) met on October 24, 2014, to consider the proposed final 

report. The MRB found the Oklahoma Agreement State Program adequate to protect public 

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

The Oklahoma Agreement State Program is administered by the Radiation Management 

Section (the Section) which is located within the Land Protection Division (the Division). The 

Division is part of the Department of Environmental Quality (The Department). Organization 

charts for the Department, the Division, and the Section are included as Appendix B. 

At the time of the review, the Oklahoma Agreement State Program regulated 224 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 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 

non-common performance indicators was sent to the Section on April 24, 2014. The Section 

provided its response to the questionnaire on July 19, 2014. A copy of the questionnaire 

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

(ADAMS) using the Accession Number ML14216A025. 

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 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 

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

performance. 
Oklahoma Final IMPEP Report Page 2 

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 

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 September 17, 2010, the review team 

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

The status of each recommendation is as follows: 

Recommendation 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 of the 2010 IMPEP report)” 

Status: The Section has continued to implement its corrective action program as identified 

during the 2010 IMPEP review. The review team calculated that the Section performed 

5.6 percent of its Priority 1, 2, 3, and initial inspections overdue during the review period which 

is significantly less than the 17.9 percent that were performed overdue during the previous 

review period. The review team determined that the Section is adequately tracking and 

performing inspections to ensure that the number of inspections performed overdue is less than 

10 percent. Pursuant to Management Directive (MD) 5.6 the Section needs to complete less 

than 10 percent of Priority 1, 2, 3, and initial inspections overdue during a review period to meet 

one of the criteria for a satisfactory rating. This recommendation is closed. 

Recommendation 2: “The review team recommends that the Section 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 of the 2010 IMPEP report)” 

Status: The Section made a request to the NRC Region IV office to provide on-site training, 

involving medical licensing requirements, to its staff. A Region IV staff member provided a two 

day training presentation on medical licensing to Section staff shortly after the 2010 IMPEP 

review. The Section also performed an audit of its medical licenses during the review period 

and found that the issues as mentioned during the 2010 IMPEP review had been resolved. 

The review team found that medical licensing actions were completed appropriately and found 

no additional issues in regards to the Section’s performance of medical licensing actions 

completed during the review period. This recommendation is closed. 

Recommendation 3: “The review team recommends that the Section 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 and 2010 IMPEP reports)” 

Status: After the 2010 IMPEP review, measures taken by the Section included developing 

and implementing a standard operating procedure and flowchart for responding to incidents 

and allegations. The standard operating procedure and flowchart ensures that proper 

documentation and appropriate response, review, enforcement, and follow-up of radioactive 

materials incidents are achieved. The Section received initial training on the standard 

operating procedure after it was finalized. Documentation of incidents is officially maintained 
Oklahoma Final IMPEP Report Page 3 

in license files per Section policy. General information describing the incident is maintained 

the Section’s database as well as in the Section’s local version of the Nuclear Materials 

Events Database (NMED). While some incidents were reported late during the review period, 

the IMPEP team determined that this did not represent a trend from what was seen during the 

2006 and 2010 IMPEP reviews and that the root cause of the currently identified issue was a 

lack of training on the program’s procedure. The procedure developed and implemented in 

response to the recommendation is adequate for incident response, review, enforcement, and 

follow up. This recommendation is closed. 

Recommendation 4: “The review team recommends that the Section take measures to ensure 

proper documentation and appropriate tracking and closure of all allegations involving 

radioactive material. (Section 3.5 of the 2006 and 2010 IMPEP reports)” 

Status: During the previous IMPEP review, the review team determined that the Section was 

not able to verify if closure information was provided to the concerned individual for one 

allegation the team reviewed. Since the 2010 IMPEP, the Section developed and 

implemented a standard operating procedure and flowchart for responding to incidents and 

allegations. In 2013, the Section revised the procedure to ensure the proper tracking, 

documentation, and closure of allegations is achieved. The review team determined that the 

Section has appropriately responded to the concerned individuals and that a copy of the 

closure letter was contained in each license file. 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 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 a Section manager, eight technical 

staff positions, and one administrative staff person. Technical staff members conduct 

inspections, perform licensing actions, and respond to incidents and allegations, based on 

individual qualifications. The technical staff members also have additional responsibilities that 

are outside of the Agreement State Program, most notably the regulation of industrial and 

therapeutic x-ray and radon in Oklahoma. The Section devotes approximately 5.6 technical 

staff full-time equivalents (FTE) to administer the Agreement State Program which is 

comparable to other programs of similar size and complexity. 

At the time of the review, the Section had no vacant positions. At the time of the previous 

review there were two vacant positions. During this four year review period, three technical staff 
Oklahoma Final IMPEP Report Page 4 

left the program. The departure dates for these three staff were October 2010, March 2011, 

and January 2012. This amounted to five total vacant positions over the four year review 

period. Of the three technical staff that left the Section during this review period, one retired, 

one left for personal reasons, and one left for a higher paying job in the private sector. The 

Section was able to hire four technical staff over the course of the review period. Two staff 

started with the Section in January 2011, one staff started with the Section in September 2011, 

and one staff started with the Section in May 2012. Three of the newly hired staff were hired 

right out of school with no prior experience and the other new hire came from another Section in 

the Department. All four newly hired staff have at least a bachelor of science degree. Although 

the Section hired four staff to cover the five vacant positions, the level of effort on the part of 

each staff member in regards to the Agreement State Program has increased so no overall 

change in FTE from the previous review has occurred. The legislature passed a fee increase 

that was tied to the consumer price index so that the program can be funded and account for 

increased costs as time goes on. The first consumer price index increase in fees went into 

effect on July 1, 2014, at the start of the current fiscal year. The Department suffered a 

significant cut in appropriations after the 2014 legislative session. Section management stated 

that this cut in appropriations is not currently affecting the Agreement State Program or the 

staffing of the Section. 

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.” However, the review team identified to Section 

staff and management that the formal qualification plan, Section 6.2: Formal Qualification Plan 

from the State of Oklahoma, Department of Environmental Quality, Radiation Management 

Section, had not been updated since December 14, 1999, which was prior to Oklahoma 

becoming an Agreement State. The Section’s documented training program is also inconsistent 

with NRC’s IMC 1248, “Qualification Programs for Federal and State Materials and 

Environmental Management Programs,” which the States were required to adopt the essential 

elements of, as a matter of compatibility by November 2013. During the onsite review, Section 

management committed to updating the document to meet the latest guidance and standards 

described in IMC 1248. Section management stated that the Section hopes to have this 

completed by December 31, 2014. 

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 and placed in staff members’ training files. The review 

team noted that the most recently hired technical staff members were successfully progressing 

through the Section’s qualification process. The review team concluded that the Section’s 

training program is adequate to carry out its regulatory duties and noted that Oklahoma 

management supports the Section’s 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. 

 
Oklahoma Final IMPEP Report Page 5 

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 

management and staff. 

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

material licenses are the same as similar license types listed in IMC 2800, “Materials Inspection 

Program.” The Section conducted 162 Priority 1, 2, and 3 inspections during the review period, 

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

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

2800. In addition, the Section performed 33 initial inspections during the review period, none of 

which were conducted overdue. Overall, the review team calculated that the Section performed 

5.6 percent of its inspections overdue during the review period. 

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

A sampling of 23 inspection reports indicated that three of the inspection findings were 

communicated to the licensees beyond the Section’s goal of 30 days after the inspection. Two 

of the inspection findings were inspections with no violations issued 5 days and 6 months late 

respectively. Section management stated that the Section was moving towards issuing a form 

similar to NRC’s Form 591 in the field in order to be timelier with its issuance of clear inspection 

findings. In its response to the draft IMPEP report (attached), the Section indicated that its 

experienced inspectors can now issue an equivalent form to NRC’s Form 591. 

During the review period, the Section granted 39 reciprocity permits, 37 of which were candidate 

licensees based upon the criteria in IMC 1220. The review team determined that the Section 

met the NRC’s criteria of inspecting 20 percent of candidate licensees operating under 

reciprocity in calendar years 2013 and 2014 and did not meet the NRC’s criteria in calendar 

years 2011 and 2012. In the two years that the Section did not meet the NRC’s criteria of 

inspecting 20 percent of candidate licensees operating under reciprocity the review team 

determined that the Section inspected 12 percent of candidate licensees in 2011 and no 

candidate licensees in 2012. Section management stated that the reason the Section missed 

the 20 percent criteria in calendar year 2011 and 2012 was due to inspecting one licensee in 

2011 and two licensees in 2012, who originally came in as reciprocity licensees, after they 

became Oklahoma specific licensees. Had these inspections counted as inspections of 

candidate licensees for reciprocity the Section would have exceeded the NRC’s criteria in all 

four years. 

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

that Oklahoma’s performance with respect to the indicator, Status of Materials Inspection 

Program, be found satisfactory. 

 
Oklahoma Final IMPEP Report Page 6 

3.3 Technical Quality of Inspections

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

responsible inspector for 23 radioactive materials inspections conducted during the review 

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

current inspectors and two former inspectors, and covered a wide variety of inspection types. 

These included gamma knife, diagnostic and therapeutic nuclear medicine, high dose-rate 

remote afterloaders, brachytherapy, industrial radiography, nuclear pharmacy, well logging, 

academic, portable and fixed gauges, and service providers. The casework included initial, 

routine, follow-up, reciprocity, and Increased Controls (IC) 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 IC, fingerprinting, and the National Source Tracking System when 

appropriate. The review team found that inspection reports were complete, consistent, and 

contained 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. 

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

calibrated survey instruments to support the inspection program, as well as to respond to 

radioactive materials incidents and emergency situations. 

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

an annual basis. The Section Manager performs most supervisory inspector accompaniments. 

Based on the final report for the previous IMPEP review, the Section Manager stated he 

believed it was acceptable for a senior inspector, who is not a supervisor, to accompany 

inspectors in lieu of the Manager conducting the accompaniment. The review team discussed 

with the Section manager that State Agreements procedure SA-102 “Technical Quality of 

Inspections,” states that “Inspectors should be accompanied by their supervisor at least 

annually as described in the U.S. NRC Inspection Manual Chapter 2800, Materials Inspection 

Program.” In the event that an inspector is not accompanied by his/her supervisor in a 

particular calendar year, it should be documented in the inspector’s personnel file. In 

Agreement States where the program manager is the immediate supervisor, accompaniments 

may be performed by experienced senior staff instead of the program manager, if the program 

manager is fulfilling other obligations. In an Agreement State that is experiencing staffing issues 

where there is a vacancy in a supervisory position, the accompaniments may be performed by 

experienced senior staff during the time the vacancy is “unfilled”. This was discussed with the 

Section Manager who stated that he would conduct all supervisory accompaniments from now 

on. The review team also noted that one senior inspector was not accompanied during the 

2011 calendar year. The review team verified that all other staff members that regularly perform 

inspections were accompanied by the Section Manager or a senior inspector annually during 

the review period. 

The review team accompanied four of the Section's inspectors during the period of June 23-27, 

2014. The inspectors conducted inspections of two well logging licensees, an industrial 

radiography licensee, and an academic Type A broad scope licensee. The inspector 

accompaniments are listed in Appendix C. The inspectors demonstrated performance-based 
Oklahoma Final IMPEP Report Page 7 

inspection techniques and had 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. 

3.4 Technical Quality of Licensing Actions

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

28 licensing actions covering 23 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 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 1 new 

license, 4 renewals, 21 amendments, and 2 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, well 

logging, service provider 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 

license database tracking system called RADMAN. 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 found that the Section has gained increased familiarity with the regulations 

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

authorizations. After the previous IMPEP review, the Section requested that the NRC Region IV 

office provide on-site training involving medical license requirements to its staff. Accordingly, an 

NRC Region IV staff member provided two days of training on medical licensing for the Section 

management and staff. The review team determined that this training was beneficial to the 

Section and found that licensing actions for medical licensees performed throughout the review 

period were complete, consistent, and addressed health, safety, and security issues. 
Oklahoma Final IMPEP Report Page 8 

The review team also determined 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 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 

determined that the Section was not tracking when financial assurance documents were due for 

re-evaluation. The Section Manager indicated that the Section would develop a license 

condition to state when the financial assurance documents were due for re-evaluation. The 

review team also 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 has implemented the essential elements of the 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 has addressed maximum possession limits on radioactive materials licenses as 

requested by RCPD-10-007 letter dated June 21, 2010. The Section identified the licenses 

affected and sent letters to the respective licensees requesting information for the maximum 

possession limit authorization. 

The review team evaluated the Section’s handling and storing of sensitive documents. The 

review team noted that the radioactive materials license files were maintained in a secured 

location that was accessed by the central records administration staff. The Section has to 

request the license files from the central records 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 review team also noted that although the files were secured 

while in the Central Records room, the files were not adequately stored or secured while signed 

out to an individual for use during an inspection or licensing action. The review team 

determined that Section staff will leave files in unsecured office cabinets and drawers when 

leaving their desk or when going home for the evening. This was discussed with the Section 

manager who stated that the Section was aware of the issue and had placed an order for each 

staff member to have a locking file cabinet at their desk. The Section stated in its response to 

the draft report (attached), that it had begun implementing guidance on the control of documents 

and also had begun marking documents containing sensitive information. The Section also 
Oklahoma Final IMPEP Report Page 9 

stated that locking cabinets were received and staff locks up documents when they are not in 

use. 

The review team also determined that the Section was not consistently marking documents 

contained within files that contained sensitive or security-related information. This was 

discussed with the Section manager who stated that the Section would also mark inspection 

documents and out-going correspondence that contained sensitive or security-related 

information, in the same manner that the Section marked licensing documents related to 

Increased Controls. The Section manager subsequently notified all staff via email of the 

importance of marking documents containing sensitive or security related information. Lastly 

the Section stated during the MRB that the draft policy, “Information Security Standard 

Operating Procedure,” for document handling and marking was finalized since the onsite review. 

The policy requires the proper marking of inspection reports, license documents, and licensee 

correspondence, as containing sensitive information, if applicable, according to the screening 

criteria specified in NRC Regulatory Issue Summary RIS-2005-31 which was issued to the 

Agreement States in RCPD 11-005 dated May 11, 2011. The review team had recommended 

in the draft report that the Section should finalize its information security policy to ensure proper 

marking, handling, and storing of sensitive documents. The review team did not discover any 

evidence of an unintended release or unauthorized disclosure of sensitive information. The 

MRB discussed and directed that the recommendation concerning information security could be 

removed since the Oklahoma program took action following the onsite review to fully address 

the issue by finalizing its policy and obtaining the locking cabinets. 

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. 

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 Section’s response to the questionnaire relative to 

this indicator, evaluated selected incidents reported for Oklahoma in NMED against those 

contained in the Section’s files, and evaluated the casework for 14 radioactive materials 

incidents. A list of the incident casework examined, with case-specific comments, may be found 

in Appendix E. The review team also evaluated the Section’s response to five allegations 

involving radioactive materials, including one allegation referred to the State by the NRC during 

the review period. 

The incidents selected for review included the following categories: lost/stolen radioactive 

material, potential overexposures, equipment failures, and leaking sources. The review team 

identified 15 radioactive material incidents in NMED for Oklahoma which required reporting 

during the review period. The review team determined that for 5 of the 15 incidents requiring 

reporting to the NRC, the Section was not timely in reporting the incident to the NRC or NMED 

as established in the FSME Procedure SA-300 “Reporting Material Events.” 

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

with the health and safety significance of the incident. The Section’s policy is to perform a 

reactive inspection for all incidents. During the review period, the timeframe for the start of the 
Oklahoma Final IMPEP Report Page 10 

reactive inspection ranged from immediately after notification to several weeks later depending 

on the significance of the incident. The Section dispatched inspectors for on-site investigations 

in all of the cases reviewed and took suitable enforcement and follow-up actions. The review 

team determined that the Section’s response to incidents was complete and comprehensive in 

all but one case. In that case, the review team determined that the Section had not thoroughly 

documented the Section’s response to a scrap alarm incident. This case appeared to be an 

isolated occurrence at the beginning of the review period, and therefore, no performance trend 

was identified. The case file in question lacked the documentation needed to support a dose 

calculation for a member of the public. At the time of the review, the Section staff could not 

answer the review team’s questions about the dose calculations for members of the public who 

may have been exposed as a result of the incident. The dose calculated for the member of the 

public was not reproducible because of incomplete dose calculation documentation in the file. 

The case file indicated the dose to the member of the public was less than the regulatory limits 

for members of the public (100 millirem annually), but exactly how the Section staff came to that 

conclusion was not fully explained or supported by documentation in the case file. 

The review team examined the 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 Section 

manager determines the appropriate level of initial response and assigns it to an inspector for 

additional follow-up. Management stated that when the incident or allegation is assigned to a 

staff member, the staff is expected to follow the flowchart and standard operating procedures to 

initiate a reactive inspection. During interviews with the staff, some of the staff indicated that the 

management expectations for the use of the flowchart and incident response procedures were 

not clearly understood by all staff and that some staff had not been provided training on the 

procedure or management expectations with respect to incident response. As mentioned above 

the review team found that 5 of 15 incidents were reported late to either the NRC or NMED and 

one incident case file contained incomplete documentation. Consequently, the review team 

recommends that the Section provide additional training to the staff on the Section’s revised 

standard operating procedure “Environmental Complaints Program” and associated flowcharts 

to ensure consistent, timely, and accurate reporting and adequate follow-up of incidents. 

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

evaluated the completed casework for five allegations, including one that NRC referred to the 

State during the review period. The review team determined that the Section took prompt and 

appropriate actions in response to concerns raised. The review team determined that the 

Section documented the investigations of concerns and retained all necessary documentation to 

appropriately close the allegations. The Section notified the concerned individuals of the 

conclusion of their investigations. The review team determined that the Section adequately 

protected the identity of concerned individuals when applicable. 

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. 

 
Oklahoma Final IMPEP Report Page 11 

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) Low-Level Radioactive Waste Disposal Program, and (4) Uranium Recovery Program. The 

NRC’s Agreement with Oklahoma does not relinquish regulatory authority for sealed source and 

device evaluation, low level radioactive waste disposal, or uranium recovery program; therefore, 

only the first non-common performance indicator applied to this review. 

4.1 Compatibility Requirements

4.1.1 Legislation

Oklahoma became an Agreement State on September 29, 2000. The current effective statutory 

authority is contained in the Radiation Management Act Chapter 27A, of the Oklahoma Statutes, 

section 2-9-101 et seq. The Department is designated as the State’s radiation control agency. 

The Section implements the radiation control program. 

The review team noted that one piece of legislation affecting the radiation control program was 

amended during the review period. Chapter 51 of the Oklahoma Statutes Section 24A.1 et seq. 

is the Open Records Act. In 2013, section 24A.28 was amended by adding a subsection A.9 

which allows for records received, maintained, or generated by the Department that contain 

information regarding sources of radiation in quantities determined by the NRC to be significant 

to public health and safety and when the information could reasonably be expected to have an 

adverse effect on public health and safety by increasing the likelihood of theft, diversion, or 

sabotage, to be kept confidential. 

4.1.2 Program Elements Required for Compatibility 

The Oklahoma regulations governing radiation protection requirements are located in Chapter 

410 of the Oklahoma Administrative Code and apply to all ionizing radiation. Oklahoma 

requires a license for possession and use of all radioactive material for which they are granted 

authority under their Agreement. 

The review team examined the administrative rulemaking process and found that the process 

takes approximately 18 months from the development stage to the final approval. This time 

frame increased from the previous review due to an amendment to procedures for promulgating 

rules that occurred in 2014. Section management stated that although the procedure was 

amended it should not impact Oklahoma’s ability to promulgate regulations within the three year 

timeframe established by the NRC. The public, NRC, other agencies, and potentially impacted 

licensees and registrants are offered an opportunity to comment during the process. Comments 

are considered and incorporated, as appropriate, before the regulations are finalized. 

The review team noted that the State’s rules and regulations are not subject to sunset laws. 

The State may adopt the regulations of another agency by reference and also has the authority 

to issue legally binding requirements (e.g., license conditions) in lieu of regulations until 

compatible regulations become effective. 
Oklahoma Final IMPEP Report Page 12 

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

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

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

from the State Regulation Status Sheet that FSME maintains. During the review period, the 

Section submitted 17 final regulation amendments to the NRC for a compatibility review. 

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

legally-binding requirements no later than 3 years after they become effective. None of the 

amendments were overdue for State adoption at the time of submission. The NRC’s 

compatibility review resulted in no comments that need to be addressed by the State in 

upcoming rulemaking activities. 

At the time of this review, there were no amendments overdue for adoption. A complete list of 

regulation amendments can be found on the NRC website at the following address: http://nrcstp.ornl.gov/rss_regamendents.html. 

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. 

5.0 SUMMARY 

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

six performance indicators reviewed. The review team made two recommendations regarding 

program performance by the State and determined that the four recommendations from the 

2010 IMPEP review should be closed. In MRB discussion of the IMPEP team’s 

recommendations, the MRB determined the recommendation concerning information security 

could be removed since the Oklahoma program took action following the onsite review to fully 

address the issue. 

Accordingly, the review team recommended, and the MRB agreed, that the Oklahoma 

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 4 years and a periodic meeting be held with the State in approximately 2 years. 

Below is the review team’s recommendation, as mentioned in the report, for evaluation and 

implementation by the State: 

RECOMMENDATION 

The review team recommends that the Section provide additional training to the staff on 

the Section’s revised standard operating procedure “Environmental Complaints 

Program” and associated flowcharts to ensure consistent, timely, and accurate reporting 

and adequate follow-up of incidents. (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

Monica Ford, Region I Team Leader 

 Status of Materials Inspection Program 

 Compatibility Requirements 

Binesh Tharakan, Region IV Technical Staffing and Training 

Technical Quality of Incidents and Allegation 

Activities 

Shawn Seeley, Region I Technical Quality of Inspections 

Judee Walden, Kansas Technical Quality of Licensing Actions 
APPENDIX B 

OKLAHOMA ORGANIZATION CHARTS 

ADAMS ACCESSION NO.: ML14216A042 
APPENDIX C 

INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Advanced Inspection Technologies, Inc. License No.: OK-27588-02 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 6/12/08 Inspectors: NN, MV 

Comment: The inspection correspondence reminded the licensee to sign the form and return it 

to the Section; however, a signed form was not in the file. 

File No.: 2 

Licensee: AHS Claremore Regional Hospital License No.: OK-16298-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 1/3/12 Inspector: NN 

File No.: 3 

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

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 6/23/14 Inspector: MB 

File No.: 4 

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

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 6/26/14 Inspectors: KC,LM 

File No.: 5 

Licensee: Big State X-Ray, Inc. License No.: OK-21144-02 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 4/10/14–5/7/14 Inspector: JM 

Comment: IC inspection letter with results not marked appropriately. 

File No.: 6 

Licensee: E + P Wireline Services, LLC License No.: OK-32122-01 

Inspection Type: Initial, Announced Priority: 3 

Inspection Date: 4/25/11 Inspector: JF 

File No.: 7 

Licensee: Southwestern Medical Center LLC License No.: OK-10669-02 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 3/20/14 Inspector: JF 
Oklahoma Final IMPEP Report Page C. 2 

Inspection Casework Reviews 

File No.: 8 

Licensee: Washita Valley Enterprises, Inc. License No.: OK-23164-01 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 2/16/12 Inspector: JM 

File No.: 9 

Licensee: American Airlines, Maintenance & Engineering Center License No.: OK-13964-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 12/13/12 Inspector: MB 

File No.: 10 

Licensee: Cardinal Health 414, LLC License No.: OK-23359-02MD 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 10/5/11 Inspector: KS 

File No.: 11 

Licensee: Best Theratronics, LTD License No.: 5-31299-01 

Inspection Type: Reciprocity, Unannounced Priority: 2 

Inspection Date: 4/30/14 Inspector: MB 

File No.: 12 

Licensee: DBI, Inc. License No.: KS 21-B805 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 10/17/13 Inspectors: MB,KC 

File No.: 13 

Licensee: Element Materials Technology License No.: MN 1070-201-62 

Inspection Type: Reciprocity, Unannounced Priority: 5 

Inspection Date: 6/12/12 Inspector: LM 

File No.: 14 

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

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 9/17/13–11/18/13 Inspector: LM 

File No.: 15 

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

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 6/24/14 Inspector: JM 

Comment: Inspection correspondence to licensee containing sensitive information was not 

properly marked. 

File No.: 16 

Licensee: INTEGRIS Health, Inc. License No.: OK-11022-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 2/28/13–4/10/13 Inspectors: KS,LM 
Oklahoma Final IMPEP Report Page C. 3 

Inspection Casework Reviews 

File No.: 17 

Licensee: SGS North America Inc. License No.: OK-32124-01 

Inspection Type: Initial, Unannounced Priority: 1 

Inspection Date: 11/22/10 Inspector: MI 

File No.: 18 

Licensee: Allied Wireline Services, LLC License No.: OK-32125-02 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 9/17/13–11/18/13 Inspector: JF 

File No.: 19 

Licensee: Norman Regional Health System License No.: OK-14145-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 8/21–23/2013 Inspector: KC 

File No.: 20 

Licensee: McAlester Regional Health Center License No.: OK-17223-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 9/17/13–11/18/13 Inspector: KC 

File No.: 21 

Licensee: Mercy Health Center License No.: OK-07018-03 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 2/14/14 Inspector: KS 

File No.: 22 

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

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 9/17/13–11/18/13 Inspectors: KS,LM,JM 

File No.: 23 

Licensee: AHS Hillcrest Medical Center, LLC License No.: OK-09206-03 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 3/28/13 Inspector: JF 
Oklahoma Final IMPEP Report Page C. 4 

Inspection Casework Reviews 

INSPECTOR ACCOMPANIMENTS 

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

Accompaniment No.: 1 

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

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 6/23/14 Inspector: MB 

Accompaniment No.: 2 

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

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 6/24/14 Inspector: JM 

Accompaniment No.: 3 

Licensee: Allied Wireline Services LLC License No.: OK-32125-02 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 6/25/14 Inspector: JF 

Accompaniment No.: 4 

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

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 6/26/14 Inspector: KC 
APPENDIX D 

LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Diagnostic Physics, LLC. License No.: OK-32097-01 

Type of Action: Amendment Amendment No.: 02 

Date Issued: 1/10/11 License Reviewer: KS 

File No.: 2 

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

Type of Action: Renewal Amendment No.: 41 

Dates Issued: 7/26/11 License Reviewer: KC 

File No.: 3 

Licensee: Southwestern Medical Center LLC. License No.: OK-10669-02 

Type of Action: Amendment Amendment No.: 34 

Dates Issued: 5/28/14 License Reviewer: MB 

File No.: 4 

Licensee: Washita Valley Enterprises, Inc. License No.: OK-23164-01 

Type of Action: Termination Amendment No.: 09 

Date Issued: 10/31/12 License Reviewer: JM 

File No.: 5 

Licensee: E&P Wireline Services License No.: OK-32122-01 

Type of Action: Termination Amendment No.: 02 

Date Issued: 9/1/11 License Reviewer: JF 

File No.: 6 

Licensee: INTEGRIS Health, Inc. License No.: OK-11022-01 

Type of Actions: Amendments Amendment Nos.: 85 & 86 

Dates Issued: 3/28/14, 6/17/14 License Reviewers: MB, MB 

File No.: 7 

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

Type of Action: Renewal Amendment No.: 06 

Date Issued: 10/11/13 License Reviewer: KS 

File No.: 8 

Licensee: AHS Claremore Regional Hospital, LLC License No.: OK-16298-01 

Type of Action: Amendment Amendment No.: 26 

Date Issued: 2/28/14 License Reviewer: JF 

 
Oklahoma Final IMPEP Report Page D. 2 

License Casework Reviews 

File No.: 9 

Licensee: American Red Cross License No.: OK-27576-01 

Type of Action: Amendment Amendment No.: 06 

Date Issued: 3/14/14 License Reviewer: KC 

File No.: 10 

Licensee: Allied Wireline Services, LLC. License No.: OK-32125-01 

Types of Action: Amendments Amendment Nos.: 04, 05 

Dates Issued: 8/16/11, 10/19/12 License Reviewers: KC, KS 

 

File No.: 11 

Licensee: Mercy Health Center License No.: OK-07018-02 

Type of Action: Amendment Amendment No.: 50 

Dates Issued: 5/27/14 License Reviewer: KS 

File No.: 12 

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

Type of Action: Amendment Amendment No.: 02 

Date issued: 6/5/11 License Reviewer: NN 

File No.: 13 

Licensee: Circuit Engineering District #7 License No.: OK-27534-01 

Type of Actions: Amendment Amendment No.: 05 

Date Issued: 1/22/13 License Reviewers: KD 

 

File No.: 14 

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

Type of Actions: Amendments Amendment Nos.: 72, 73, 74 

Dates Issued: 2/16/12, 9/9/13, 11/14/13 License Reviewers: KS, KC, JF 

File No.: 15 

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

Type of Action: Renewal Amendment No.: 15 

Date Issued: 3/12/13 License Reviewer: KS 

File No.: 16 

Licensee: The Boeing Company License No.: OK-32151-01 

Type of Action: New Amendment No.: New 

Date Issued: 5/24/13 License Reviewer: KC 

File No.: 17 

Licensee: Chevron Phillips Chemical Company LLC. License No.: OK-31024-01 

Type of Action: Amendment Amendment No.: 05 

Date Issued: 11/14/13 License Reviewer: LM 

 
Oklahoma Final IMPEP Report Page D. 3 

License Casework Reviews 

File No.: 18 

Licensee: Big State X-Ray, Inc. License No.: OK-21144-02 

Type of Action: Renewal Amendment No.: 09 

Date Issued: 7/22/11 License Reviewer: KS 

File No.: 19 

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

Type of Action: Amendment Amendment No.: 02 

Date Issued: 4/13/12 License Reviewer: KS 

File No.: 20 

Licensee: Tucker Energy Services, Inc. License No.: OK-19815-02 

Type of Action: Amendment Amendment No.: 22 

Date Issued: 5/10/12 License Reviewer: JF 

File No.: 21 

Licensee: Alliance HealthCare Services, Inc. License No.: K-32092-01 

Type of Actions: Amendments Amendment Nos.: 04, 05 

Dates Issued: 8/4/11, 11/21/13 License Reviewers: KS, KC 

File No.: 22 

Licensee: Radiology Associates, LLC. License No.: OK-01332-06 

Type of Action: Amendment Amendment No.: 21 

Date Issued: 4/18/14 License Reviewer: KS 

File No.: 23 

Licensee: Norman Regional Health System License No.: OK-14145-01 

Type of Action: Amendment Amendment No.: 67 

Date Issued: 5/10/12 License Reviewer: MB 
APPENDIX E 

INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Core Laboratories (dba Protechnics) License No.: OK-26928-02 

Date of Incident: 3/17/13 NMED No.: 140317 

Investigation Date: 3/19/13 Type of Incident: Lost RAM 

 Type of Investigation: Site 

Comment: The State was notified about this incident on 3/19/13, and should have reported the 

event to the NRC within 30 days; however, the State reported this incident to NRC 445 days 

later on 6/6/14. 

File No.: 2 

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

Date of Incident: 3/4/14 NMED No.: 140336 

Investigation Date: 4/17/14 Type of Incident: Overexposure 

 Type of Investigation: Telephone/Site 

Comment: The State was notified about the incident on 3/6/14, and should have reported it to 

NMED within 30 days by 4/5/14; however, the State reported this incident 104 days later on 

6/17/14. 

File No.: 3 

Licensee: Tahlequah City Hospital License No.: OK-15626-01 

Date of Incident: 12/13/13 NMED No.: 140013 

Investigation Date: 1/29/14 Type of Incident: Lost RAM 

 Type of Investigation: Site 

Comment: The State was notified about the incident on 12/23/13 and should have immediately 

reported it to NRC; however, the State reported the incident 3 days later on 12/26/13. 

File No.: 4 

Licensee: Hi-Tech Testing (dba Western X-ray Services) License No.: OK-19993-02 

Date of Incident: 12/31/12 NMED No.: 130131 

Investigation Date: 2/14/13 Type of Incident: Overexposure 

 Type of Investigation: Site 

Comment: The State was notified about this incident on 2/4/13 and should have reported it 

within 30 days to NMED; however, the State reported the incident 32 days later on 3/7/13. 
Oklahoma Final IMPEP Report Page E. 2 

Incident Casework Reviews 

File No.: 5 

Licensee: Building and Earth Sciences License No.: OK-31032-01 

Date of Incident: 6/6/13 NMED No.: 130269 

Investigation Date: 6/11/13 Type of Incident: Lost/Stolen RAM 

 Type of Investigation: Site 

File No.: 6 

Licensee: Metal Check, Inc. License No.: N/A 

Date of Incident: 05/22/12 NMED No.: 120328 

Investigation Date: 05/22/12 Type of Incident: Lost RAM 

 Type of Investigation: Site 

File No.: 7 

Licensee: Yaffe Iron and Metal License No.: N/A 

Date of Incident: 10/24/11 NMED No.: 110568 

Investigation Date: 11/1/11 Type of Incident: Potential Overexposure/Lost RAM 

 Type of Investigation: Site 

Comment: The dose calculated for a scrap yard worker (member of the public) was not 

reproducible because of incomplete dose calculation documentation in the Section’s files. 

However, based on some measurements and the time spent near the lost RAM, the Section 

staff concluded that the dose did not exceed regulatory limits. 

File No.: 8 

Licensee: Cardinal Health License No.: OK-23359-02MD 

Date of Incident: 12/28/11 NMED No.: 120070 

Investigation Date: 1/6/12 Type of Incident: Lost RAM 

 Type of Investigation: Telephone 

File No.: 9 

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

Date of Incident: 10/1/11 NMED No.: 120086 

Investigation Date: 12/21/11 Type of Incident: Overexposure 

 Type of Investigation: Site 

Comment: The State was notified about the incident on 12/5/11 and should have made a 

30-day report to NMED by 1/4/12; however, the State reported this incident 44 days later on 

01/17/12. 

File No.: 10 

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

Date of Incident: 4/23/13 NMED No.: 130266 

Investigation Date: 5/14/13 Type of Incident: Equipment Failure 

 Type of Investigation: Site 

File No.: 11 

Licensee: The University of Oklahoma Health Science Center License No.: OK-03176-01 

Date of Incident: 9/27/13 NMED No.: 130475 

Investigation Date: 9/27/13 Type of Incident: Leaking Source 

 Type of Investigation: Telephone 
Oklahoma Final IMPEP Report Page E. 3 

Incident Casework Reviews 

File No.: 12 

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

Date of Incident: 10/05/11 NMED No.: N/A 

Investigation Date: 10/21/11 Type of Incident: Overexposure 

 Type of Investigation: Site 

File No.: 13 

Licensee: Tulsa Gamma Ray License No.: OK-17178-02 

Date of Incident: 3/19/13 NMED No.: 140317 

Investigation Date: 4/5/13 Type of Incident: Overexposure 

 Type of Investigation: Site 

File No.: 14 

Licensee: Oklahoma Dept. of Environmental Quality License No.: OK-06901-03 

Date of Incident: 8/23/11 NMED No.: N/A 

Investigation Date: 9/9/11 Type of Incident: Leaking Source 

 Type of Investigation: Site 
ATTACHMENT 

September 18, 2014 Letter from Mike Broderick 

Oklahoma Response to the Draft Report 

ADAMS Accession No.: ML14269A339