September 7, 2012 

Catherine B. Templeton, Director 

Department of Health and Environmental Control 

2600 Bull Street 

Columbia, South Carolina 29201 

Dear Ms. Templeton: 

On August 16, 2012, the Management Review Board (MRB) met to consider the proposed final 

Integrated Materials Performance Evaluation Program (IMPEP) report on the South Carolina 

Agreement State Program. The MRB found the South Carolina program is adequate to protect 

public health and safety and is compatible with the Nuclear Regulatory Commission’s program. 

Section 5.0, page 16, of the enclosed final report contains a summary of the IMPEP review 

team’s findings. The review team made no recommendations in regard to program performance 

by the South Carolina Agreement State Program during this review. Based on the results of the 

current IMPEP review, the next full review of the South Carolina Agreement State Program will 

take place in approximately 5 years from the date of the current review, with a periodic meeting 

tentatively scheduled for January 2015. The South Carolina Agreement State Program received 

an extension of one year for the next IMPEP review based on two consecutive IMPEP reviews 

with satisfactory findings for all the performance indicators reviewed. 

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

acknowledge your continued support for the Agreement State program. I look forward to our 

agencies continuing to work cooperatively in the future. 

 Sincerely, 

 /RA/ 

 Michael F. Weber 

 Deputy Executive Director for Materials, Waste, 

 Research, State, Tribal and Compliance Programs 

 Office of the Executive Director for Operations 

Enclosure: 

South Carolina Final IMPEP Report 

cc w/ encl: Alice Rogers, Texas 

 Organization of Agreement States 

 Liaison to the MRB
Catherine B. Templeton, Director 

Department of Health and Environmental Control 

2600 Bull Street 

Columbia, South Carolina 29201 

Dear Ms. Templeton: 

On August 16, 2012, the Management Review Board (MRB) met to consider the proposed final 

Integrated Materials Performance Evaluation Program (IMPEP) report on the South Carolina 

Agreement State Program. The MRB found the South Carolina program is adequate to protect 

public health and safety and is compatible with the Nuclear Regulatory Commission’s program. 

Section 5.0, page 15, of the enclosed final report contains a summary of the IMPEP review 

team’s findings. The review team made no recommendations in regard to program performance 

by the South Carolina Agreement State Program during this review. Based on the results of the 

current IMPEP review, the next full review of the South Carolina Agreement State Program will 

take place in approximately 5 years from the date of the current review, with a periodic meeting 

tentatively scheduled for January 2015. The South Carolina Agreement Sate Program received 

an extension of one year for the next IMPEP review based on two consecutive IMPEP reviews 

with satisfactory findings for all the performance indicators reviewed. 

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

acknowledge your continued support for the Agreement State program. I look forward to our 

agencies continuing to work cooperatively in the future. 

 Sincerely, 

 /RA/ 

 Michael F. Weber 

 Deputy Executive Director for Materials, Waste, 

 Research, State, Tribal and Compliance Programs 

 Office of the Executive Director for Operations 

Enclosure: 

South Carolina Final IMPEP Report 

cc w/ encl: Alice Rogers, Texas 

 Organization of Agreement States 

 Liaison to the MRB 

 

DISTRIBUTION: EDATS: FSME-2012-0024 

See next page 

ADAMS Accession Number: ML12235A235 

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

NAME LDimmick DWhite / JFKfor PHenderson BMcDermott / PJH for 

DATE 08/24/12 08/28/12 08/29/12 08/29/12 

OFFICE Tech Editor FSME DEDMRT 

NAME 

CPoland 

(PTressler for) 

MSatorius 

(BHolian for) 

MWeber 

 

DATE 08/30 /12 09/4 /12 09/07/12 

OFFICIAL RECORD COPY 
Letter to C. Templeton from Michael F. Weber dated 

SUBJECT: South Carolina 2012 FINAL IMPEP REPORT 

DISTRIBUTION: EDATS: FSME-2012-0024 

MSSA_Technical_Asst_Resource DCD (SP01) 

RidsEdoMailCenter 

RidsFsmeOd 

RidsOgcMailCenter 

RidsRgn1MailCenter 

RidsRgn4MailCenter 

RidsFsmeDmssa 

RidsSecyCorrespondenceMailCenter Chairman Macfarlane 

RErickson, RIV Commissioner Svinicki 

DJanda, RI Commissioner Apostolakis 

JCook, RIV Commissioner Magwood 

CGrossman, FSME Commissioner Ostendorff 

SPoy, FSME SECY 

DShearer, PA 

KSchwab, WA 

MOrendi, RI/RSAO 

RLorson, RI 

DCollins, RI 

AGantt, SC 

MKotzalas, OEDO 

JWeil, OCA (2 copies) 
Enclosure 

INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

REVIEW OF THE SOUTH CAROLINA AGREEMENT STATE PROGRAM 

May 21-25, 2012 

FINAL REPORT
EXECUTIVE SUMMARY 

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

(IMPEP) review of the South Carolina Agreement State Program. The review was conducted 

during the period of May 21-25, 2012, by a review team composed of technical staff members 

from the U.S. Nuclear Regulatory Commission (NRC), the State of Washington, and the 

Commonwealth of Pennsylvania.

Based on the results of this review, South Carolina’s performance was found to be satisfactory 

for all eight performance indicators reviewed. The findings remain unchanged from the previous 

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

by the State. Accordingly, the review team recommended, and the Management Review Board 

(MRB) agreed, that the South Carolina Agreement State Program is adequate to protect public 

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

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

. 
South Carolina Final IMPEP Report Page 1 

1.0 INTRODUCTION 

This report presents the results of the review of the South Carolina Agreement State Program. 

The review was conducted during the period of May 21-25, 2012, by a review team composed 

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

Washington, and the Commonwealth of Pennsylvania. 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 from July 

21, 2007 to May 25, 2012, were discussed with South Carolina managers on the last day of the 

review. 

A draft of this report was issued to South Carolina for factual comment on June 18, 2012. The 

State responded by letter dated July 17, 2012. A copy of the State’s response is included as an 

Attachment to this report, along with the review team’s resolution of the comments submitted by 

South Carolina. The Management Review Board (MRB) met on August 16, 2012, to consider 

the proposed final report. The MRB found the South Carolina Agreement State Program 

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

The radioactive materials portion of the South Carolina Agreement State Program is 

administered by the Bureau of Radiological Health (Bureau), which is located within the 

Department of Health and Environmental Control (Department). The low level radioactive waste 

portion of the South Carolina Agreement State Program is administered by the Division of 

Waste Management (Division), a part of the Bureau of Land and Waste Management also 

located within the Department. Organization charts are included as Appendix B. 

At the time of the review, the Bureau regulated approximately 400 specific licenses authorizing 

possession and use of radioactive materials. The Division regulated 14 licensees in addition to 

the Barnwell low level radioactive waste site. The review focused on the radioactive materials 

program as it is carried out under the Section 274b. (of the Atomic Energy Act of 1954, as 

amended), Agreement between the NRC and the State of South Carolina. 

In preparation for the review, a questionnaire addressing the common and applicable noncommon performance indicators was sent to both the Bureau and Division on February 29, 

2012. The Bureau provided its response to the questionnaire on April 30, 2012. The response 

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

using the Accession Number ML12122A078. The attachments to the response can be found in 

ADAMS using Accession Number ML12220A287. The Division provided its response to the 

questionnaire on May 4, 2012. The response can be found in ADAMS using Accession Number 

ML121280003. 

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

examination of each agency’s response to the questionnaire, (2) review of applicable South 

Carolina statutes and regulations, (3) analysis of quantitative information from each agency’s 

database, (4) technical review of selected regulatory actions, (5) field accompaniments of six 

inspectors, and (6) interviews with staff and managers. The review team evaluated the 
South Carolina Final IMPEP Report Page 2 

information gathered against the established criteria for each common and the applicable noncommon performance indicators and made a preliminary assessment of the South Carolina 

Agreement State Program’s performance. 

There were no recommendations made to the State during the previous review. Section 2.0 of 

this report identifies two recommendations initially identified for NRC’s action by the 2003 review 

team, noted again by the 2007 review team, and again evaluated by the current review team. 

The status of the results of the current review of the common performance indicators are 

presented in Section 3.0. Section 4.0 discusses results 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 2003 review, no recommendations were made to the State; however, two 

recommendations were made to the NRC by the review team. The two recommendations 

remained open through the 2007 review and were again evaluated by the current review 

team. The recommendations for the NRC were as follows: 

1. “The review team recommends that the NRC adopt and disseminate final guidance on 

field inspections for industrial radiography operations in the interest of establishing an 

identifiable national materials program standard. (Section 3.3 of the 2003 report)” 

2. “The review team recommends that the NRC clarify which supervisory levels require 

an inspection accompaniment, the frequency of those accompaniments and what 

level of documentation is appropriate. (Section 3.3 of the 2003 report)” 

Status: The NRC’s Office of Federal and State Materials and Environmental Management 

Programs (FSME) has addressed these recommendations separately from this report and they 

have been removed from IMPEP tracking. 

3.0 COMMON PERFORMANCE INDICATORS 

Five common performance indicators are used to review the NRC regional and Agreement 

State radioactive materials programs. These indicators are as follows: (1) Technical Staffing 

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

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

Activities. 

3.1 Technical Staffing and Training

Issues central to the evaluation of this indicator include 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 questionnaire response from the Bureau relative to this indicator, 

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

workload backlogs. To evaluate the Division, the review team focused on the qualifications of 

the technical staff and the expertise necessary to regulate a Low Level Radioactive Waste 

(LLRW) disposal facility, the development and implementation of a staff training program, and 

the evaluation of staffing trends that could have an adverse impact on performance.
South Carolina Final IMPEP Report Page 3 

The Bureau is staffed by the Bureau Chief, a Radioactive Materials Division Director, a 

Section Manager, and four technical staff members. All Bureau staff members, including the 

Radioactive Materials Director and Section Manager, are responsible for materials licensing, 

inspection, compliance, and emergency response activities. 

The review team noted that because of reduced staffing levels, Bureau management was 

involved to varying degrees in the day to day operations of the Bureau. With their direct 

involvement, the materials program was operating with approximately 4.3 full-time equivalents 

(FTE). Two additional full-time technical staff positions were vacant at the time of the review. 

One position has been vacant since December 2010, and the other has been vacant since 

April 2011. The Bureau received approval to fill one of the open positions and had posted it 

while the review team was on site. 

Within the Division, six staff members implement the LLRW program including the Division 

Director and five staff members assigned to the Infectious and Radioactive Waste 

Management Section (Section). The Section consists of a Section Manager, three Health 

Physicists, and an Environmental Engineer. Since the last review, the Division has lost one 

Health Physicist position which was permanently eliminated and as a result, the Division is 

now considered fully staffed. The review team determined that staffing levels were adequate 

for the Agreement State program. 

The review team interviewed Division staff and noted that the decreased staffing level has not 

had a significant impact on their licensing or inspection programs or their ability to conduct their 

work in a timely manner. The review team determined that there was adequate technical 

expertise within the Division and that additional expertise was obtained from other organizations 

within the Department when warranted. The review team also noted the seniority of staff both 

within the Bureau and the Division and discussed the importance of succession planning with 

management. 

The Bureau 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 

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

Nuclear Material Safety and Safeguards Program Area.” Staff members are assigned 

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

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

and noted that South Carolina management supports the Bureau training program. 

The review team examined the Division’s staff training documentation and conducted interviews 

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

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

qualification forms are maintained for each person. The review team concluded that the 

Division’s training program is adequate to carry out their regulatory duties. 

The review team also discussed the role of the Technical Advisory Radiation Control Council 

(Council) with the Bureau Chief. The Council holds statutory authority to review all proposed 

regulations prior to adoption. The Council also serves as an advisory committee to both the 

Bureau and the Division. The Council meets as needed rather than on a specific schedule. 
South Carolina Final IMPEP Report Page 4 

Since the last IMPEP review in 2007, the Council has met only once. No evidence of conflict of 

interest issues was identified. Council members are subject to the State Ethics Act. 

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

agreed, that South Carolina’s performance with respect to the indicator, Technical Staffing 

and Training, be found satisfactory. 

3.2 Status of Materials Inspection Program

The review team focused on five factors while reviewing this indicator: inspection frequency, 

overdue inspections, initial inspections of new licenses, timely dispatch of inspection findings to 

licensees, and performance of reciprocity inspections. The review team’s evaluation was based 

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

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

management and staff. 

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

material licenses are at least as frequent as license types listed in IMC 2800, “Materials 

Inspection Program.” 

The Bureau conducted approximately 240 higher priority (Priority 1, 2, and 3) inspections over 

the review period. None were conducted overdue. Initial inspections should be conducted 

within 12 months of license issuance. The review team found that the Bureau performed 69 

initial inspections over the review period with none performed overdue. Overall, the review 

team calculated that the Bureau performed no inspections overdue during the review period. 

The Division conducted 39 inspections for 14 waste licensees. None were performed overdue. 

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

The majority of the Bureau’s routine inspections were documented with the issuance of a 

BRH-Form 591, “Field Compliance Form,” and left with the licensee at the completion of the onsite inspection. These are issued for inspections with no findings or minor violations. Other 

inspection findings are routinely sent to licensees on a Form BRH-592, “Notice of NonCompliance” within 30 days of completing an inspection. This form is used for more significant 

violations and is issued from the Bureau office. A sampling of 20 inspection reports found that 

none of the inspection findings were communicated to the licensees beyond the Bureau’s goal 

of 30 days following the inspection. 

The review team determined that the Division’s inspection findings were also communicated in a 

timely manner. Inspectors verbally relay inspection findings and recommendations to the 

licensee during the close-out meeting. The review team found that while not all findings were 

communicated to the licensee within 30 days, the team found that the majority do get 

communicated in a timely manner. The review team evaluated 17 inspection files and found 

only two occasions where findings were not communicated to the licensee within 30 days. 

The review team found that over the review period, the Bureau issued 56 reciprocity permits 

that were candidates for inspection based upon the criteria found in IMC 1220, “Processing of 

NRC Form 241 and Inspection of Agreement State Licensees Operating Under 10 CFR 150.20”. 

The review team determined that the Bureau exceeded the NRC’s criteria of inspecting 20 
South Carolina Final IMPEP Report Page 5 

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

review period. 

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

that South Carolina‘s performance with respect to the indicator, Status of Materials Inspection 

Program, be found satisfactory. 

3.3 Technical Quality of Inspections

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

notes, and interviewed inspectors for 20 radioactive materials inspections conducted by the 

Bureau over the review period. The casework reviewed included inspections conducted by six 

former and current Bureau inspectors and covered inspections of various license types, 

including: academic broad scope, medical broad scope, medical institutions-therapy including 

high dose rate remote after-loader and permanent implant brachytherapy, industrial 

radiography, panoramic and self-shielded irradiators, gamma knife, nuclear pharmacy, mobile 

nuclear medicine and Increased Security Controls for Large Quantities of Radioactive Materials 

(Increased Controls). The review team also examined 27 inspection reports of waste related 

licensees conducted by the Division over the review period. Appendix C lists the inspection 

casework files reviewed, with case specific comments, as well as the results of the inspector 

accompaniments. 

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

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

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

to ensure that a licensee’s performance with respect to health, safety and security was 

acceptable. The documentation supported violations, recommendations made to licensees, 

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

The Bureau uses inspection procedures that are consistent with the inspection guidance 

outlined in IMC 2800. The majority of inspections are documented on BRH-Form 591, “Field 

Compliance Forms,” then left with the licensee at the conclusion of the inspection. Other 

inspection findings are routinely dispatched to licensees on a Form BRH-592, “Notice of NonCompliance” within 30 days of completing an inspection. The review team determined that the 

Bureau’s inspection findings were prompt and appropriate, and regulatory actions were taken 

when necessary. Inspection findings were found to be clearly stated and documented in the 

reports. 

The Division performs inspections in accordance with its Radioactive Materials Licensing and 

Compliance Administrative Procedures Manual. Inspection reports are appropriately 

documented and reviewed by the Section Manager prior to sending close-out letters to the 

licensee or pursuing enforcement actions. The review team found the Division’s inspection 

findings to be well-founded and appropriately documented in their reports. 

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

an annual basis. All inspector accompaniments were performed annually over the review 

period. The accompaniment reports contained sufficient details to document the areas covered 

during the accompaniments. 
South Carolina Final IMPEP Report Page 6 

The review team noted that the Department has an adequate supply of survey instruments to 

support both the Bureau’s and Division’s inspection programs. Appropriate, calibrated survey 

instrumentation, such as Geiger-Mueller (GM) meters, scintillation detectors, ion chambers, 

micro-R meters, multi-channel analyzers and neutron detectors, were available. Instruments 

are calibrated at least annually, or as needed, by a South Carolina calibration lab with National 

Institute of Standards and Technology traceable sources. The Bureau tracks each instrument, 

its current location, and next calibration date. 

The review team accompanied two Bureau inspectors on March 5-6, 2012, and two Division 

inspectors on April 9, 2012. The Bureau inspectors were accompanied during health, safety 

and security inspections of an industrial radiography facility and a large medical institution. The 

Division inspectors were accompanied during an inspection of a waste related licensee. 

Inspector accompaniments are identified in Appendix C. During each of the 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, safety and security at each of the 

licensed facilities. 

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

that South Carolina’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 

15 specific licenses issued by the Bureau and four by the Division. Licensing actions were 

reviewed for completeness, consistency, proper radioisotopes and quantities, qualifications of 

authorized users, adequate facilities and equipment, adherence to good health physics 

practices, financial assurance, operating and emergency procedures, appropriateness of license 

conditions, increased controls, and overall technical quality. The casework was also reviewed 

for timeliness, use of appropriate deficiency letters and cover letters, reference to appropriate 

regulations, product certifications, supporting documentation, consideration of enforcement 

history, pre-licensing visits, supervisory/peer review, and proper signatures. The casework was 

checked for retention of necessary documents and supporting data. 

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

completed during the review period. The Bureau’s licensing actions selected for evaluation 

included four new licenses, five renewals, four amendments, and two terminations. The 

sampling included the following license types: medical (broad-scope, gamma knife, high doserate remote afterloader, written directive required, written directive not required, and private 

practice), irradiator, industrial radiography, portable gauge, fixed gauge, academic (broad-scope 

and limited), service provider (survey meter calibration), and nuclear pharmacy. The Division’s 

licensing casework involved four actions including two renewals, one amendment, and a license 

termination. Each of the Division’s licensing actions only involved waste related facilities. A 

listing of all licensing casework evaluated may be found in Appendix D. 
South Carolina Final IMPEP Report Page 7 

The review team found that 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, backed by information contained in the file, and auditable. Licenses and 

correspondence were generated using standardized conditions and formats. License reviewers 

use the Bureau’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. The review team found that the terminated licensing actions reviewed 

were well-documented, showing appropriate radioactive material transfer and survey records. 

Senior managers performed a review on each licensing action before the license or amendment 

was issued. The review team noted that license actions were timely. Deficiency letters clearly 

stated regulatory positions and were used at the appropriate time and identified substantive 

deficiencies in the licensees’ documents. Health and safety issues are properly addressed and 

tie-down conditions are complete and enforceable. The licensee’s compliance history was also 

taken into account when reviewing renewal applications. 

The review team noted that the Bureau performed site visits for all new licensees and all new 

licenses are hand-delivered to the licensee. During the review period, the Bureau extended the 

standard license expiration date from 8 to 10 years from date of issue to be consistent with NRC 

policy. The review team did not note any timely license renewals pending. 

The review team evaluated both the Bureau’s and Division’s financial assurance and 

decommissioning activities. The review team identified no performance issues with the handling 

of financial assurance or decommissioning by either the Bureau or the Division. 

The Bureau performs pre-licensing checks of all new applicants. The Bureau’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 

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 Bureau’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 Bureau’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 Bureau 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 Bureau’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. Files that contained sensitive information were 

further secured in locked file cabinets. 
South Carolina Final IMPEP Report Page 8 

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

that South Carolina’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 Bureau’s actions in responding to incidents and 

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

this indicator, evaluated selected incidents reported for South Carolina in the Nuclear Material 

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

casework for 10 radioactive materials incidents. A listing of the incident casework examined 

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

allegations involving radioactive materials, including three allegations referred to the State by 

the NRC during the review period. 

The review team examined the Bureau’s 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, Program managers and staff discuss the 

event and determine level of initial response based on the health and safety risk associated with 

the event. 

The review team identified 38 radioactive material incidents in NMED for South Carolina during 

the review period, of which 22 required reporting. A total of 16 non-reportable incidents in 

NMED for South Carolina were reviewed for reportability and found to be correctly categorized 

as non-reportable by the Bureau. The review team selected 10 radioactive material incidents 

for evaluation. These incidents included the following types of events: lost/stolen radioactive 

material, potential overexposure, medical event, damaged equipment, and contamination 

events. The Bureau’s responses to the incidents were found to be complete and 

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

commensurate with the potential health and safety significance of the event. Inspectors were 

dispatched for onsite investigations when appropriate. Enforcement and/or other regulatory 

actions were taken as appropriate. If the incident met the reportability thresholds, as 

established in the FSME Procedure SA-300 “Reporting Material Events,” the State notified the 

NRC Headquarters Operations Center and entered the information into NMED, in a prompt 

manner. 

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

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

State during the review period. The review team concluded that the Bureau consistently took 

prompt and appropriate actions in response to concerns raised. The review team noted that the 

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

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

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

protected the identity of concerned individuals. 

During the review period, the Division reported no incidents or allegations for the 14 materials 

licenses under its jurisdiction (incidents and allegations specific to the LLRW program are 
South Carolina Final IMPEP Report Page 9 

discussed in Section 4.3.5). Based on interviews with Division staff and management and 

reviews of Division administrative policy and training plans, the review team noted that handling 

of allegations appears to be treated consistently. 

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

that South Carolina’s performance with respect to the indicator, Technical Quality of Incident 

and Allegation Activities, be found satisfactory. 

4.0 NON-COMMON PERFORMANCE INDICATORS 

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

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

Agreement with South Carolina does not relinquish regulatory authority for a uranium recovery 

program; therefore, only the first three non-common performance indicators applied to this 

review. 

4.1 Compatibility Requirements

4.1.1 Legislation

South Carolina became an Agreement State on September 15, 1969. The current effective 

statutory authority is contained in the 1969 Code of Laws of South Carolina, the Atomic Energy 

and Radiation Control Act, the Radioactive Waste and Transportation Act, and Environmental 

Fees. The Department is designated as the State’s radiation control program agency and 

implements the Agreement State program. South Carolina legislation is not subject to sunset 

laws. 

4.1.2 Program Elements Required for Compatibility 

The Department’s Radioactive Materials Regulations 61-63, Title A, apply to all materials that 

emit ionizing radiation. These regulations were promulgated pursuant to Section 13-7-40 et. 

seq. of the 1976 South Carolina Code (as amended) and the Atomic Energy and Radiation 

Control Act. South Carolina requires a license for possession and use of all radioactive 

material, including naturally occurring materials, such as radium, and accelerator produced 

radionuclides. South Carolina also requires registration of all equipment designed to produce 

x-ray, other ionizing radiation and tanning beds. 

The review team examined South Carolina’s rulemaking process and found that rulemaking 

takes approximately 6 to 9 months from the development stage to the publication of the final 

rule in the State Register. Rules become effective 14 days after the final filing process is 

completed. The public, the NRC, other agencies, potentially impacted licensees and 

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

considered and incorporated, as appropriate, before regulations are finalized, approved, and 

published in the State Register. South Carolina can adopt regulations needed for 

compatibility with approval from the Department Board. 
South Carolina Final IMPEP Report Page 10 

The State is authorized to adopt other agency regulations by reference, which they have done 

in many areas of their regulations. The State also has the authority to issue legally binding 

requirements in the form of license conditions until compatible regulations become effective. 

The review team evaluated the State’s responses 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 (SRS) sheet maintained by FSME. 

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

legally-binding requirements no later than 3 years after they become effective. At the time of 

the review, there were no overdue regulations. 

The following regulation changes and adoptions will be need to be addressed in the future. The 

State related that the regulations would be addressed in upcoming rulemaking or by adopting 

alternate legally binding requirements: 

• “Decommissioning Planning,” 10 CFR Parts 20, 30, 40, and 70 amendments (76 FR 

35512), due for Agreement State adoption by December 17, 2015. 

• “Licenses, Certifications, and Approvals for Materials Licensees,” 10 CFR Parts 30, 36, 

39, 40, 70, and 150 amendments (76 FR 56951), due for Agreement State adoption by 

November 14, 2014. 

• “Change of Compatibility,” 10 CFR 31.5 and 31.6 amendments (77 FR 3640), due for 

Agreement State adoption by January 25, 2015. 

• “Advance Notification to Native American Tribes of Transportation of Certain Types of 

Nuclear Waste,” 10 CFR Part 71 amendment (77 FR 34194), due for Agreement State 

adoption by August 10, 2015. 

• “Technical Corrections,” 10 CFR Parts 30, 34, 40, and 71 amendments (77 FR 39899), 

due for Agreement State adoption by August 6, 2015. 

• “Requirements for Distribution of Byproduct Material,” 10 CFR Parts 30, 31, 32, 40, and 

70 amendments (77 FR 43666), due for Agreement State adoption by October 23, 2015. 

 

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

that South Carolina’s 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 Bureau’s 

performance regarding the Sealed Source and Device (SS&D) Evaluation Program. These 

subelements include the following: (1) Technical Staffing and Training, (2) Technical Quality of 

the Product Evaluation Program, and (3) Evaluation of Defects and Incidents Regarding SS&Ds. 
South Carolina Final IMPEP Report Page 11 

In assessing the Bureau’s SS&D evaluation activities, the review team examined information 

provided in response to the IMPEP questionnaire, performed searches of the national SS&D 

Registry in addition to NMED searches for manufacturers and distributors identified on SS&D 

registrations issued by South Carolina. The review team conducted a review of the one SS&D 

evaluation completed by the Bureau during the review period. The team also evaluated SS&D 

staff training records, certain reported incidents involving products authorized in South Carolina 

SS&D registrations, the use of guidance documents and procedures, and interviewed the staff 

currently conducting SS&D evaluations. 

4.2.1. Technical Staffing and Training

The Bureau has two qualified SS&D reviewers, each with full signature authority. Each of the 

Bureau’s reviewers has over 20 years of experience, a Bachelor’s degree, and each has 

attended NRC’s SS&D workshop. At the time of the review, the Bureau did not have any 

pending SS&D evaluations. 

The Bureau currently has one staff member working towards full SS&D qualification. The 

Bureau has documented qualification criteria for SS&D Reviewers which is also a part of the 

Bureau’s training manual. The Bureau indicated that other staff members will undergo training 

to become SS&D reviewers in the future. 

The review team determined that the Bureau’s retention of two qualified SS&D reviewers was 

adequate based on current and future workload projections. 

4.2.2 Technical Quality of the Product Evaluation Program

During the review period, the Bureau processed one SS&D action in the form of an amendment. 

The casework review included an evaluation of all supporting documentation, the license, and 

inspections associated with the distributor of the device. A listing of the SS&D registration 

evaluated by the review team may be found in Appendix F. 

The review team confirmed that the Bureau follows the recommended guidance from the NRC 

SS&D Workshop, NUREG-1556 Series Guidance, applicable and pertinent American National 

Standards Institute (ANSI) standards and Military Standards, ISO-9001 and South Carolina 

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

available and used appropriately in performing SS&D reviews. 

The registration file contained all correspondence, engineering drawings, radiation profiles, and 

details of the applicant’s quality assurance and quality control programs. The registration 

clearly summarized the product evaluation to provide license reviewers with adequate 

information to license the possession and use of the product. The review team found that the 

evaluation was of high quality with health and safety issues properly addressed. The Bureau is 

legally authorized to enforce the requirements of SS&D registrations through regulations issued 

by the Department. 

 
South Carolina Final IMPEP Report Page 12 

4.2.3 Evaluation of Defects and Incidents Regarding SS&Ds

Based upon the Bureau’s response to the questionnaire, interviews with managers, and the 

review team’s searches of NMED, the review team found no reports of defects during the review 

period related to SS&D registrations issued by the Bureau. A search of the NMED database 

revealed there were four incidents involving a gauge manufacturer’s devices. All of these 

incidents involved the gauges being lost by their owners and found at scrap yards or by 

members of the public. 

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

that South Carolina’s performance with respect to the indicator, Sealed Source and Device 

Evaluation Program, be found satisfactory. 

4.3 Low-level Radioactive Waste Disposal Program 

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

performance regarding the LLRW disposal program. These subelements include the following: 

(1) Technical Staffing and Training, (2) Status of Low-level Radioactive Waste Disposal 

Inspection, (3) Technical Quality of Inspections, (4) Technical Quality of Licensing Actions, and 

(5) Technical Quality of Incident and Allegation Activities. To evaluate the above sub-elements, 

the team reviewed background materials on the site, performed inspector accompaniments, 

reviewed the South Carolina response to the questionnaire, interviewed managers and staff, 

and examined records, as appropriate. 

The LLRW disposal program is administered by the Department under regulatory authority 

derived from the South Carolina Atomic Energy and Radiation Control Act, Section 13-7-40, 

1976, S.C. Code of Laws (as amended). Specifically, the LLRW disposal program is 

administered by the Division in the Bureau of Land and Waste Management. At the time of the 

review, the Division regulated one operating LLRW disposal facility, Chem-Nuclear Systems, 

LLC’s, disposal facility located approximately five miles northwest of Barnwell, South Carolina, 

which began operations in 1971. EnergySolutions, LLC acquired Chem-Nuclear Systems, LLC, 

in 2006, but did not affect a name change for the Barnwell LLRW disposal facility license. 

The Barnwell LLRW disposal facility is regulated by the Division under a license which was last 

approved for renewal in 2004. The license authorizes the receipt, storage, and disposal of 

Class A, B, and C LLRW. The 2004 renewal amendment was challenged by environmental 

stakeholders. In 2005, the South Carolina Administrative Law Court ruled in favor of the 

Division’s approval of the renewal. Stakeholders appealed the ruling and the South Carolina 

Supreme Court ruled that the case should be transferred to the South Carolina Court of 

Appeals. The Court of Appeals affirmed the Administrative Law Court’s ruling, but remanded 

the case back to the Administrative Law Court for a ruling on whether the licensee is in 

compliance with Sections 7.11, 7.23.6, and 7.10.5 through 7.10.10 of South Carolina Regulation 

61-63. At the time of this review the case was before the Administrative Law Court pending a 

decision. 

The Division continues to monitor disposal operations at the Barnwell LLRW disposal facility. In 

2008, the Barnwell LLRW disposal facility closed to generators outside the Atlantic Compact. 

As a result, the amount of LLRW received and disposed at the Barnwell facility has decreased 
South Carolina Final IMPEP Report Page 13 

since the last review. The Barnwell LLRW disposal facility received approximately 37,534 cubic 

feet in 2007; 22,856 cubic feet in 2008; 11,315 cubic feet in 2009; 34,916 cubic feet in 2010; 

11,510 cubic feet in 2011, and 3,166 cubic feet as of May 2012. 

The review team noted that groundwater tritium contamination continues at the Barnwell LLRW 

disposal facility. However, the Division estimates that the hypothetical dose from the observed 

contamination continues to remain below 25 millirem per year, which is the allowable limit per 

South Carolina Regulation 61-63. The Division has also developed action levels based on the 

observed tritium concentration at the compliance point, located south of the disposal facility 

along Mary’s Branch Creek, which trigger contingency plans. The Division indicated that the 

final action level, which would require construction of a pump and groundwater remediation 

system, correlates to an annual dose of 14 millirem. 

4.3.1 Technical Staffing and Training 

The evaluation of this sub-element focused on qualifications of the technical staff and the 

expertise necessary to regulate a LLRW disposal facility, the development and implementation 

of a training program for the staff; and staffing trends that could have an adverse impact on 

performance. 

Within the Division, six staff members implement the State of South Carolina’s LLRW Disposal 

Program responsibilities. The Division Director and five staff members are assigned to the 

Infectious and Radioactive Waste Management Section. The Infectious and Radioactive Waste 

Management Section consists of a Section Manager, three Health Physicists, and an 

Environmental Engineer. One of the three Health Physicists is assigned to the Barnwell LLRW 

disposal facility as the resident inspector. Since the last review, the Division lost one Health 

Physicist position; this position was removed, therefore, the Division is currently fully staffed. 

Interviews with Division staff indicated that staffing levels have not resulted in a delay in 

licensing or inspecting work. However, staff indicated that interactions with the Federal 

government (e.g., participation in Federal rulemaking) are occasionally curtailed in order to 

satisfy responsibilities under the Agreement. The review team determined that there was 

adequate technical expertise within the program and that additional expertise would be obtained 

from other organizations within the Department when warranted. The review team confirmed 

that current staffing levels did not have a significant impact on the program’s ability to conduct 

its responsibilities under the agreement. The review team also noted the seniority of the staff 

within the Division and discussed the importance of succession planning with Division 

management. 

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

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

specifies required training for each technical position. Individual training qualification forms are 

maintained for each person. 

 
South Carolina Final IMPEP Report Page 14 

4.3.2 Status of Low-level Radioactive Waste Disposal Inspection Program 

The review team focused on three factors while reviewing this indicator. These include 

inspection frequency, overdue inspections or any deviations from the schedule, and timely 

dispatch of inspection findings to the licensee. The review team’s evaluation was based on the 

Division’s response to the questionnaire, an examination of inspection casework, and interviews 

with management and staff. 

The Division performs inspections in accordance with the Radioactive Materials Licensing and 

Compliance Administrative Procedures Manual. The review team examined 10 inspection files 

and conducted interviews with staff to determine that the Barnwell LLRW disposal facility 

licensee is inspected at least annually as prescribed in IMC 2800. Any deviations from the 

prescribed inspection schedule are coordinated between staff and management, and inspection 

findings are communicated to the licensee in a timely manner. 

The Division performed 10 inspections of the Barnwell facility over the review period. The 

Barnwell LLRW disposal facility license is inspected semi-annually by a team of Division 

inspectors. Division staff also performs weekly site visits and the Division’s resident inspector 

conducts routine vehicle and shipment inspections in addition to observing disposal operations 

and collecting split groundwater samples. The review team determined that the Division 

performed complete inspections of the Barnwell LLRW disposal facility license during each of 

the semiannual inspections. There were no deviations from the prescribed inspection schedule 

during this review period. 

The review team determined that the Division’s inspection findings were communicated in a 

timely manner. Inspectors verbally relay inspection findings and recommendations to the 

licensee during the close-out meeting. While not all written communications to the licensee 

occurred within 30 calendar days, the review team found that the majority of communications 

did occur within 30 working days of the inspection. 

4.3.3 Technical Quality of Inspections 

The review team assessed the quality of LLRW Disposal Program inspections by evaluating 

inspector performance during accompaniments, inspection field notes and completed reports, 

inspection procedures, follow-up on previous inspection findings, as well as regulatory actions 

taken, and annual supervisory accompaniments. 

The review team accompanied four Division inspectors the week of April 9, 2012. All four 

inspectors were accompanied during a team inspection of the Barnwell LLRW disposal facility, 

and one of the inspectors was accompanied during the weekly site visit at the Barnwell LLRW 

disposal facility. The inspectors were experienced, prepared, and knowledgeable of the facility, 

the inspection requirements, and the regulations. The inspections were adequate to assess the 

safety and radiological hazards at the LLRW disposal facility. 

The review team determined from an evaluation of 10 inspection files that previous inspection 

findings were addressed adequately and in a timely manner during subsequent inspections. 

Inspection reports were complete with the findings well-founded, appropriately documented and 
South Carolina Final IMPEP Report Page 15 

reviewed by the Section Manager prior to sending close-out letters to the licensee or pursuing 

enforcement actions. Inspectors receive supervisory accompaniments annually. 

4.3.4 Technical Quality of Licensing Actions 

The Division renewed the Barnwell LLRW disposal facility license in 2004, and as of this review 

continues to await the pending decision of the Administrative Law Court as described in Section 

4.3. During this review period, the Division approved four amendments to the Barnwell LLRW 

disposal facility license. The review team reviewed all four license amendments completed 

during this review period. A listing of the licensing casework reviewed can be found in 

Appendix D. 

The review team found the casework to be thorough, complete, consistent, and of acceptable 

technical quality. The license conditions are clear and auditable. Health and safety issues were 

properly addressed. Tie-down conditions are stated clearly, backed by information contained in 

the file, and enforceable. Public hearings are held when needed and the Division engages in 

public outreach, particularly regarding the groundwater contamination. As a result, the licensing 

process appeared to be thorough and consistent. 

The review team also reviewed a sample of licensing actions related to the Phase I Closure 

Performance Objective Plan. A component of the Phase I Closure Performance Objective Plan 

is the disposal facility’s Environmental Radiological Performance Verification (ERPV). The 

ERPV involves averaging observed radiological concentrations in groundwater and estimating 

the migration of observed radionuclides to the compliance point located along Mary’s Branch 

Creek. The review team noted that the ERPV did not appear to account for the radiological 

source term remaining in disposal trenches, and discussed the importance of a performance 

assessment, including a full source term, to assess compliance with the performance objectives 

during its review of the Phase I Closure Performance Objective Plan. 

Finally, the review team evaluated the State’s process for obtaining adequate financial 

assurance for the Barnwell LLRW disposal facility. The review team determined that the State 

has obtained financial assurance for the site and that the State of South Carolina’s Budget and 

Control Board had commissioned an independent assessment of the adequacy of the financial 

assurance. 

4.3.5 Technical Quality of Incident and Allegation Activities 

During the review period, the Division reported no incidents and only one allegation involving 

LLRW Disposal Program activities. Interviews with Division staff and management, and reviews 

of Division administrative policy and training plans, the review team noted that handling of 

allegations appears to be treated consistently across the LLRW Disposal Program. In regard to 

the allegation, the review team determined that the LLRW staff took prompt and appropriate 

action in response to the concerns raised in the allegation. The review team noted that all 

documentation related to the investigation of the allegation was complete and appropriately 

maintained in a separate file. 

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

South Carolina’s performance with respect to the indicator, LLRW Disposal Program, be found 

satisfactory. 
South Carolina Final IMPEP Report Page 16 

5.0 SUMMARY 

As noted in Sections 3.0 and 4.0 above, South Carolina’s performance was found to be 

satisfactory for all performance indicators reviewed. The review team did not make any 

recommendations regarding program performance by the State and determined that the 

recommendations for the NRC initially identified during the 2003 and 2007 reviews should be 

removed. Accordingly, the review team recommended, and the MRB agreed, that the South 

Carolina 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 five years. 
LIST OF APPENDICES 

Appendix A IMPEP Review Team Members 

Appendix B South Carolina 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

Randy Erickson, Region IV Team Leader 

 Technical Quality of Inspections 

 Inspector Accompaniments 

Donna Janda, Region I Technical Staffing and Training 

 Technical Quality of Incident and Allegation 

 Activities 

Jackie Cook, Region IV Technical Quality of Licensing Actions 

Dwight Shearer, Pennsylvania Status of the Materials Inspection Program 

 Technical Quality of Incident and Allegation 

 Activities 

Kristen Schwab, Washington Low-Level Radioactive Waste Disposal Program 

 Inspector Accompaniments 

Christopher Grossman, FSME Low-Level Radioactive Waste Disposal Program 

 Inspector Accompaniments 

Stephen Poy, FSME Sealed Source and Device Evaluation Program 
APPENDIX B 

SOUTH CAROLINA ORGANIZATION CHARTS 

ADAMS ACCESSION NO.: ML12220A287 
 APPENDIX C 

INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

SOUTH CAROLINA BUREAU OF RADIOLOGICAL HEALTH

File No.: 1 

Licensee: Carolina Regional Cancer Center License No.: 515 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 6/10/10 Inspector: AR 

File No.: 2 

Licensee: Synthetopes, Inc. License No.: 882 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 9/30/11 Inspector: AR 

File No.: 3 

Licensee: Spartanburg Regional Medical Center License No.: 086 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 6/14/11 Inspector: LC 

File No.: 4 

Licensee: Cardinal Health License No.: 448 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 11/6/09 Inspector: MW 

File No.: 5 

Licensee: Direct Diagnostic Services, LLC License No.: 855 

Inspection Type: Routine/Unannounced Priority: 3 

Inspection Date: 11/14/08 Inspector: AR 

File No.: 6 

Licensee: AnMed Women’s and Children’s Hospital License No.: 566 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 1/11/12 Inspector: MW 

File No.: 7 

Licensee: WELD-SPECT Technologies and Testing, LLC License No.: 731 

Inspection Type: Special/Announced Priority: 1 

Inspection Date: 5/18/11 Inspector: LC 

File No.: 8 

Licensee: Mistras Group, Inc. License No.: 730 

Inspection Type: Special/Announced Priority: 1 

Inspection Date: 4/12/11 Inspector: KW
South Carolina Final IMPEP Report Page C. 2 

Inspection Casework Reviews 

File No.: 9 

Licensee: CareAlliance Health Services License No.: 646 

Inspection Type: Special/Unannounced Priority: 2 

Inspection Date: 9/30/09 Inspector: AR 

File No.: 10 

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

Inspection Type: Reciprocoity/Special/Unannounced Priority: 1 

Inspection Date: 4/20/12 Inspectors: JP, MW 

File No.: 11 

Licensee: Acuren Inspection, Inc. License No.: GA-1115-1 

Inspection Type: Reciprocity/Unannounced Priority: 1 

Inspection Date: 2/28/12 Inspector: AR 

File No.: 12 

Licensee: Wesdyne International License No.: 900 

Inspection Type: Initial/Special/Unannounced Priority: 1 

Inspection Date: 8/25/10 Inspector: AR 

File No.: 13 

Licensee: Roper Saint Francis Mount Pleasant Hospital License No.: 903 

Inspection Type: Initial, Unannounced Priority: 5 

Inspection Date: 4/12/11 Inspector: LC 

File No.: 14 

Licensee: Sullivan & Associates, Inc. License No.: 383 

Inspection Type: Special/Announced Priority: 1 

Inspection Date: 3/6/12 Inspector: MW 

File No.: 15 

Licensee: B.F. Shaw, Inc. License No.: 074 

Inspection Type: Special/Unannounced Priority: 2 

Inspection Date: 5/21/10 Inspector: AR 

File No.: 16 

Licensee: University of South Carolina License No.: 405 

Inspection Type: Initial/Special/Announced Priority: 3 

Inspection Date: 3/4/09 Inspector: MW 

File No.: 17 

Licensee: BD Vacutainer Systems License No.: 315 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 10/8/08 Inspector: MW 

 
South Carolina Final IMPEP Report Page C. 3 

Inspection Casework Reviews 

File No.: 18 

Licensee: Bausch & Lomb License No.: 431 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 8/15/07 Inspector: JP 

File No.: 19 

Licensee: Lexington Medical Center License No.: 146 

Inspection Type: Special/Announced Priority: 2 

Inspection Date: 3/5/12 Inspector: AR 

File No.: 20 

Licensee: Applied Technical Services, Inc. License No.: 410 

Inspection Type: Special/Announced Priority: 1 

Inspection Date: 4/4/12 Inspector: LC 

SOUTH CAROLINA DIVISION OF WASTE MANAGEMENT

File No.: 21 

Licensee: Chem-Nuclear Systems, LLC License No.: 287-03 

Inspection Type: Routine/Unannounced Priority: 3 

Inspection Date: 11/29/07 Inspectors: MY, SJ 

File No.: 22 

Licensee: Chem-Nuclear Systems, LLC License No.: 287-03 

Inspection Type: Routine/Unannounced Priority: 3 

Inspection Date: 12/8/09 Inspectors: MY, KS 

File No.: 23 

Licensee: Chem-Nuclear Systems, LLC License No.: 287-03 

Inspection Type: Routine/Unannounced Priority: 3 

Inspection Date: 11/29/07 Inspector: MP 

File No.: 24 

Licensee: Chem-Nuclear Systems, LLC License No.: 287-01 

Inspection Type: Routine/Unannounced Priority: 3 

Inspection Date: 11/19/09 Inspector: MP 

File No.: 25 

Licensee: Chem-Nuclear Systems, LLC License No.: 287-01 

Inspection Type: Routine/Unannounced Priority: 3 

Inspection Date: 4/9/12 Inspectors: MY, MP 

File No.: 26 

Licensee: Clemson University License No.: 482-00 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 4/16/08 Inspector: MG 
South Carolina Final IMPEP Report Page C. 4 

Inspection Casework Reviews 

File No.: 27 

Licensee: Clemson University License No.: 482-00 

Inspection Type: Routine/Unannounced Priority: 3 

Inspection Date: 9/16/08 Inspector: MG 

File No.: 28 

Licensee: Clemson University License No.: 482-00 

Inspection Type: Routine/Unannounced Priority: 3 

Inspection Date: 11/20/09 Inspector: MG 

File No.: 29 

Licensee: Clemson University License No.: 482-00 

Inspection Type: Routine/Unannounced Priority: 3 

Inspection Date: 11/1/10 Inspectors: MP, MY 

File No.: 30 

Licensee: Clemson University License No.: 482-00 

Inspection Type: Routine/Unannounced Priority: 3 

Inspection Date: 10/12/11 Inspectors: MP, MY 

File No.: 31 

Licensee: Energy Solutions, LLC License No.: 287-04 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 5/5/08 Inspectors: MP, JS 

File No.: 32 

Licensee: Energy Solutions, LLC License No.: 287-04 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 5/20/09 Inspectors: MP, JS 

File No.: 33 

Licensee: Energy Solutions, LLC License No.: 287-04 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 5/18/10 Inspectors: MP, JS 

File No.: 34 

Licensee: Energy Solutions, LLC License No.: 287-04 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 5/26/11 Inspectors: MP, JS 

Comment: Inspection performed 05/26/11; inspection report completed and findings 

communicated to the licensee on 07/28/11. 

 
South Carolina Final IMPEP Report Page C. 5 

Inspection Casework Reviews 

File No.: 35 

Licensee: Energy Solutions, LLC License No.: 287-02 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 11/19/08 Inspectors: MY, MP, KS 

Comment: Inspection performed 11/19/08; inspection report completed and findings 

communicated to the licensee on 01/09/09. 

File No.: 36 

Licensee: Energy Solutions, LLC License No.: 287-02 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 11/19/09 Inspectors: MY, MP 

File No.: 37 

Licensee: Energy Solutions, LLC License No.: 287-02 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 12/12/10 Inspectors: MY, MP, KS, JS 

File No.: 38 

Licensee: Energy Solutions, LLC License No.: 287-02 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 12/6/11 Inspectors: MY, MP, KS 

File No.: 39 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine/Unannounced Priority: 1 

Inspection Date: 7/30-8/2/07 Inspectors: MG, MP, JS, KS, MY 

Comment: Inspection performed 07/30-08/02/07; inspection report completed and findings 

communicated to the licensee on 11/07/07. 

File No.: 40 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine/Unannounced Priority: 1 

Inspection Date: 3/3-6/08 Inspectors: MG, MP, JS, KS, MY 

File No.: 41 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine/Unannounced Priority: 1 

Inspection Date: 7/7-10/08 Inspectors: MG, MP, JS, KS, MY 

File No.: 42 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine/Unannounced Priority: 1 

Inspection Date: 1/26-28/09 Inspectors: MG, MP, JS, MY 

 
South Carolina Final IMPEP Report Page C. 6 

Inspection Casework Reviews 

File No.: 43 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine/Unannounced Priority: 1 

Inspection Date: 7/20-22/09 Inspectors: MG, MP, JS, KS, MY 

File No.: 44 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine/Unannounced Priority: 1 

Inspection Date: 2/17-19/10 Inspectors: MG, MP, JS, KS, MY 

File No.: 45 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine/Unannounced Priority: 1 

Inspection Date: 8/16-18/10 Inspectors: MG, MP, JS, KS, MY 

File No.: 46 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine/Unannounced Priority: 1 

Inspection Date: 2/16-17/11 Inspectors: MP, JS, KS, MY 

File No.: 47 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine/Unannounced Priority: 1 

Inspection Date: 4/10-12/12 Inspectors: MP, JS, KS, MY 

INSPECTOR ACCOMPANIMENTS 

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

SOUTH CAROLINA BUREAU OF RADIOLOGICAL HEALTH

Accompaniment No.: 1 

Licensee: Lexington Medical Center License No.: 146 

Inspection Type: Special/Announced Priority: 2 

Inspection Date: 3/5/12 Inspector: AR 

Accompaniment No.: 2 

Licensee: Sullivan & Associates, Inc. License No.: 383 

Inspection Type: Special/Announced Priority: 1 

Inspection Date: 3/6/12 Inspector: MW 

Accompaniment No.: 3 

Licensee: Chem-Nuclear Systems, LLC License No.: 287-01 

Inspection Type: Routine/Announced Priority: 1 

Inspection Date: 4/9/12 Inspectors: MP, MY 
South Carolina Final IMPEP Report Page C. 7 

Inspection Casework Reviews 

Accompaniment No.: 4 

Licensee: Chem-Nuclear Systems, LLC License No.: 097 

Inspection Type: Routine/Announced Priority: 1 

Inspection Date: 4/10-12/12 Inspectors: MP, JS, KS, MY 
 

APPENDIX D 

LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

SOUTH CAROLINA BUREAU OF RADIOLOGICAL HEALTH

File No.: 1 

Licensee: Trident Medical Center, LLC License No.: 210 

Type of Action: Amendment Amendment No.: 61 

Date Issued: 5/27/11 License Reviewer: MW 

File No.: 2 

Licensee: Specialty Vermiculite Corporation License No.: 300 

Type of Action: Amendment Amendment No.: 20 

Date Issued: 1/20/12 License Reviewer: MW 

File No.: 3 

Licensee: College of Charleston License No.: 220 

Type of Action: Renewal Amendment No.: 18 

Date Issued: 4/7/11 License Reviewer: MW 

File No.: 4 

Licensee: Spartanburg Regional Medical Center License No.: 086 

Type of Action: Amendment Amendment No.: 68 

Date Issued: 7/26/10 License Reviewer: AR 

File No.: 5 

Licensee: Newco, Inc. License No.: 318 

Type of Action: Renewal Amendment No.: 14 

Date Issued: 2/26/10 License Reviewer: LC 

File No.: 6 

Licensee: STERIS, Isomedix Services License No.: 267 

Type of Action: Renewal Amendment No.: 19 

Date Issued: 3/12/12 License Reviewer: JP 

File No.: 7 

Licensee: University of South Carolina License No.: 405 

Type of Action: Renewal Amendment No.: 26 

Date Issued: 10/17/11 License Reviewer: LC 

File No.: 8 

Licensee: Synthetopes, Inc. License No.: 882 

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

Date Issued: 9/3/08 License Reviewer: MW
South Carolina Final IMPEP Report Page D. 2 

License Casework Reviews 

File No.: 9 

Licensee: Williamsburg Regional Hospital License No.: 914 

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

Date Issued: 4/18/11 License Reviewer: MW 

File No.: 10 

Licensee: Piedmont Health Group, LLC License No.: 857 

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

Date Issued: 10/11/07 License Reviewer: LC 

File No.: 11 

Licensee: HDR Construction Control Corporation License No.: 708 

Type of Action: Renewal Amendment No.: 9 

Date Issued: 5/26/09 License Reviewer: LC 

File No.: 12 

Licensee: Medical University of South Carolina License No.: 081 

Type of Action: Amendment Amendment No.: 78 

Date Issued: 9/29/09 License Reviewer: MB 

File No.: 13 

Licensee: The Institute of Electrophysiology License No.: 836 

Type of Action: Termination Amendment No.: 03 

Date Issued: 2/25/10 License Reviewer: LC 

File No.: 14 

Licensee: Wesdyne International License No.: 900 

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

Date Issued: 8/27/09 License Reviewer: AR 

File No.: 15 

Licensee: Acuren Inspection, Inc. License No.: 595 

Type of Action: Termination Amendment No.: 21 

Date Issued: 11/21/08 License Reviewer: LC 

SOUTH CAROLINA DIVISION OF WASTE MANAGEMENT

File No.: 16 

Licensee: Chem-Nuclear Systems, LLC License No.: 287-01 

Type of Action: Amendment Amendment No.: 24 

Date Issued: 9/22/11 License Reviewer: MP 

File No.: 17 

Licensee: Energy Solutions, LLC License No.: 287-02 

Type of Action: Renewal Amendment No.: 34 

Date Issued: 1/30/09 License Reviewer: MY 
South Carolina Final IMPEP Report Page D. 3 

License Casework Reviews 

File No.: 18 

Licensee: Energy Solutions, LLC License No.: 287-05 

Type of Action: Termination Amendment No.: 11 

Date Issued: 12/15/09 License Reviewer: MP 

File No.: 19 

Licensee: TransNuclear, Inc. License No.: 0377-00 

Type of Action: Renewal Amendment No.: 22 

Date Issued: 9/30/10 License Reviewer: MY 
APPENDIX E 

INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Mitsubishi Polyester Film License No.: 36 

Date of Incident: 10/09/08 NMED No.: 080654 

Investigation Date: 10/09/08 Type of Incident: Equipment Failure 

 Type of Investigation: Site 

File No.: 2 

Licensee: Shertech Nuclear Pharmacy License No.: 478 

Date of Incident: 10/08/08 NMED No.: 080868 

Investigation Date: 01/14/09 Type of Incident: Contamination Event 

 Type of Investigation: Next Routine Inspection 

File No.: 3 

Licensee: Waccamaw Hospital License No.: 754 

Date of Incident: 02/06/09 NMED No.: 090371 

Investigation Date: 02/06/09 Type of Incident: Lost/Stolen/Abandoned RAM 

 Type of Investigation: Phone 

File No.: 4 

Licensee: Greenville Hospital System License No.: 257 

Date of Incident: 09/15/09 NMED No.: 090732 

Investigation Date: 09/17/09 Type of Incident: Medical Event 

 Type of Investigation: Site 

File No.: 5 

Licensee: McLeod Regional Medical Center License No.: 139 

Date of Incident: 12/09/09 NMED No.: 090878 

Investigation Date: 12/13–20/09 Type of Incident: Contamination Event 

 Type of Investigation: Site 

File No.: 6 

Licensee: Asten Johnson Inc. License No.: 534 

Date of Incident: 03/28/11 NMED No.: 110150 

Investigation Date: 03/29/11 Type of Incident: Lost/Stolen/Abandoned RAM 

 Type of Investigation: Phone 

File No.: 7 

Licensee: Colleton Medical Center License No.: 226 

Date of Incident: 05/15/11 NMED No.: 110352 

Investigation Date: 07/12/11 Type of Incident: Possible overexposure 

 Type of Investigation: Phone 

 
South Carolina Final IMPEP Report Page E. 2 

Incident Casework Reviews 

File No.: 8 

Licensee: BP Cooper River Plant License No.: 252 

Date of Incident: 01/24/12 NMED No.: 120281 

Investigation Date: 01/25/12 Type of Incident: Equipment Failure 

 Type of Investigation: Phone/Next Routine Inspection 

File No.: 9 

Licensee: McLeod Regional Medical Center License No.: 139 

Date of Incident: 05/01/12 NMED No.: 120295 

Investigation Date: TBD Type of Incident: Contamination Event 

 Type of Investigation: Phone/Next Routine Inspection 

File No.: 10 

Licensee: Applied Technical Services License No.: 410 

Date of Incident: 04/18/12 NMED No.: 120301 

Investigation Date: TBD Type of Incident: Possible Overexposure 

 Type of Investigation: Phone/Next Routine Inspection 
APPENDIX F 

SEALED SOURCE AND DEVICE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No. 1: 

Registry No.: SC-1276-D-101-G SS&D Use Code: (E) Beta Gauges 

Applicant’s Name: Mahlo America, Inc. Type of Action: Amendment 

Date Issued: 12/4/08 SS&D Reviewers: JP, AR 
ATTACHMENT(S) 

July 17, 2012 Letter from Catherine Templeton 

South Carolina Response to the Draft Report 

ADAMS Accession No.: ML12207A296 

NRC Comment Resolution Document 

ADAMS Accession No.: ML12213A591