UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

August 20, 2014 

MEMORANDUM TO: Marc L. Dapas, Regional Administrator 

Region IV 

FROM: Roy P. Zimmerman /RA/ 

 Acting Deputy Executive Director for Materials, Waste, 

 Research, State, Tribal, and Compliance Programs 

Office of the Executive Director for Operations 

SUBJECT: FINAL REPORT OF THE INTEGRATED MATERIALS 

PERFORMANCE EVALUATION PROGRAM REVIEW OF 

THE REGION IV RADIOACTIVE MATERIALS PROGRAM 

On July 28, 2014, the Management Review Board (MRB) met to consider the proposed final 

Integrated Materials Performance Evaluation Program (IMPEP) report of the U.S. Nuclear 

Regulatory Commission’s (NRC) Region IV Radioactive Materials Program. The MRB found 

the program adequate to protect public health and safety. 

The enclosed final report concluded that Region IV (RIV) was satisfactory for all six 

performance indicators reviewed. The review team made no recommendations in regard to 

program performance by the Region. 

The MRB discussed at length RIV’s missed metrics on reciprocity inspections and credits the 

Region for the self-assessment in this area. The MRB acknowledges the reciprocity criteria 

should be assessed with consideration to making it more risk informed in the next revision of 

“IMC 1220,” Processing of NRC Form 241 and Inspection of Agreement State Licensees 

operating under 10 CFR 150.20.” Region IV noted the challenges in meeting the current 

reciprocity criteria planning and indicated its intent to focus additional attention in this area. 

Based on the results of the current IMPEP review, the next full review of the NRC Region IV 

program will take place in approximately 5 years, with a periodic meeting tentatively scheduled 

mid-cycle. The program received a 1 year extension based on two consecutive IMPEPs 

resulting in satisfactory ratings for all indicators reviewed. 

CONTACT: Lisa Dimmick, FSME/MSSA 

 (301) 415-0694
M. Dapas 2 

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

applaud your staff’s efforts during the IMPEP review period. 

Enclosure: 

Region IV Final IMPEP Report 

cc: Dwight Shearer, PA 

 Organization of Agreement States 

 Liaison to the MRB 

 

 Mark Shaffer, Director 

 Division of Nuclear Materials Safety, RIV 
M. Dapas 2 

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

applaud your staff’s efforts during the IMPEP review period. 

Enclosure: 

Region IV Final IMPEP Report 

cc: Dwight Shearer, PA 

 Organization of Agreement States 

 Liaison to the MRB 

 

 Mark Shaffer, Director 

 Division of Nuclear Materials Safety, RIV 

DISTRIBUTION: See next page 

ML14212A345 

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

NAME With edits 

LDimmick 

Via e-mail 

with edits 

MBeardsley 

DWhite LDudes PTressler 

for 

CPoland 

RLorson 

for 

BHolian 

RZimmerman

DATE 8/05/14 8/01/14 8/05/14 8/06/14 8/07/14 8/08/14 8/20/14 

OFFICIAL RECORD COPY 
DISTRIBUTION: (SP08) 

MSSA_Technical_Asst_Resource DCD (SP01) 

RidsEdoMailCenter 

RidsFsmeOd 

RidsOgcMailCenter 

RidsRgn1MailCenter 

RidsRgn3MailCenter 

RidsFsmeDmssa 

RidsSecyCorrespondenceMailCenter 

RLorson, FSME 

LDudes, FSME 

SAbraham, FSME 

Chairman Macfarlane 

Commissioner Svinicki 

Commissioner Magwood 

Commissioner Ostendorff 

SECY 

JWeil, OCA (2 copies) 

RidsRgn1MailCenter PLanzisera, RI 

RidsRgn4MailCenter GWarren, RIII 

MShaffer, RIV DSollenberger, FSME 

LHowell, RIV SMack, AR 

MBeardsley, FSME LDimmick, FSME 

MSampson, OEDO 

OAS Board 
Enclosure 

INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

REVIEW OF THE NRC REGION IV RADIOACTIVE MATERIALS PROGRAM 

April 28–May 2, 2014 

FINAL REPORT
EXECUTIVE SUMMARY 

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

(IMPEP) review of the U.S. Nuclear Regulatory Commission (NRC) Region IV materials 

program. The review was conducted during the period of April 28 – May 2, 2014, by a review 

team composed of technical staff members from the NRC and the State of Arkansas.

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

indicators reviewed. The findings for the indicators remain unchanged from the previous two 

IMPEP reviews. The review team did not make any recommendations. 

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

agreed, that the NRC Region IV materials program is adequate to protect public health and 

safety. The review team recommended, and the MRB agreed, that the next IMPEP review take 

place in approximately 5 years. 
NRC Region IV Final IMPEP Report Page 2 

1.0 INTRODUCTION 

This report presents the results of the review of the U.S. Nuclear Regulatory Commission (NRC) 

Region IV radioactive materials program. The review was conducted during the period of 

April 28 – May 2, 2014, by a review team composed of technical staff members from the NRC and 

the State of Arkansas. 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 April 4, 2009–May 2, 2014, were discussed with the NRC Region IV 

managers on the last day of the review. 

A draft of this report was provided to Region IV for factual comment on June 11, 2014. Region IV 

responded to the findings and conclusions of the review by memorandum dated July 2, 2014. A 

copy of the region’s response is included as an Attachment to this report. A Management Review 

Board (MRB) met on July 28, 2014, to consider the proposed final report. The MRB found the 

NRC Region IV materials program adequate to protect public health and safety. 

The Region IV radioactive materials program is administered by the Director of the Division of 

Nuclear Materials Safety (the Division) who reports directly to the Regional Administrator. 

Organization charts for Region IV and the Division are included as Appendix B. At the time of the 

review, the Division regulated 564 specific licenses authorizing possession and use of radioactive 

materials, and 15 uranium recovery licensees. 

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

non-common performance indicators was sent to the Region on December 18, 2013. The Region 

provided its response to the questionnaire on April 9, 2014. A copy of the questionnaire response 

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

the Accession Number ML14107A418.

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

Region’s response to the questionnaire, (2) analysis of quantitative information from the licensing, 

inspection, and allegation databases, as well as ADAMS, (3) technical review of selected 

regulatory actions, (4) field accompaniments of four inspectors, and (5) interviews with staff and 

managers. The review team evaluated the information gathered against the established criteria 

for each common and the applicable non-common performance indicator and made a preliminary 

assessment of Region IV’s performance. 

Section 2.0 of this report covers actions in response to recommendations made during the 

previous review(s). 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. 
NRC Region IV Final IMPEP Report Page 3 

2.0 STATUS OF ITEMS IDENTIFIED IN PREVIOUS REVIEWS 

There were no performance recommendations for Region IV’s action made during the previous 

review. The 2009 review team did recommend that the Office of Federal and State Materials and 

Environmental Management Programs (FSME) develop and provide clarification to the NRC 

Regions on the requirements for marking of inspection and licensing correspondence. FSME 

issued a Radiation Control Program Director (RCPD) letter RCPD-11-005 (ML110330345) 

“Additional Guidance and Clarification Regarding the Review of the Control of Sensitive 

Information During Integrated Materials Performance Evaluation Program Reviews.” This 

recommendation is closed. 

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 (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 Division’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 Division’s questionnaire response relative to this 

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

considered workload backlogs. 

The Division is managed by the Director who is supported by a deputy. The Division is composed 

of three branches: the Nuclear Materials Safety Branch (NMSB) A, NMSB B, and the Repository 

and Spent Fuel Safety Branch (RSFSB). Each is headed by a Branch Chief. The NMSB A 

performs routine and reactive inspections of materials licensees, and processes enforcement 

casework associated with these inspections. The NMSB A is responsible to track Region IV 

materials event reports. The NMSB B performs materials licensing; evaluates financial assurance 

submittals; processes reciprocity requests from Agreement State licensees; and maintains the 

materials docket file room. The RSFSB conducts inspections of independent spent fuel storage 

installations and of sites and facilities under decommissioning. The RSFSB also conducts routine 

and reactive uranium recovery inspections. There has been no change in the Division’s structure 

since 2011 when the uranium recovery activities were moved from NMSB B to RSFSB. 

At the time of the review, there were 14 technical staff members involved in the radioactive 

materials program, totaling approximately 14 full-time equivalents (FTE). There were no positions 

vacant at the time of this review and the Division is fully staffed. During the 5 year review period, 

there was some turnover due to retirements and transfers. Vacated positions were filled promptly. 

There were six technical staff hired into the Division over the review period backfilling vacated 

positions. The review team determined that staffing levels are adequate for the Region IV’s 

materials program. 
NRC Region IV Final IMPEP Report Page 4 

The Division has implemented Inspection Manual Chapter (IMC) 1248, “Formal Qualification 

Program for Federal and State Material and Environmental Management Program.” Staff 

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

process. To promote knowledge management and succession planning, the Division takes 

advantage of mentoring opportunities for less experienced staff. The Division cross-trains 

licensing staff for materials inspections on a voluntary basis. This affords Division managers the 

flexibility to allocate resources where needed to adjust workloads between licensing and 

inspection. Division managers were fully cognizant of the qualification status and training plans 

for their staff. At the time of the review all materials license reviewers were fully qualified and all 

but two inspectors were fully qualified. The review team concluded that the Division’s training 

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

Division training program. The staffing and training status for the uranium recovery inspectors is 

discussed in Section 4.1.1. 

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

that Region IV’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 Division’s questionnaire response relative to this indicator, data gathered from the 

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

management and staff. 

The review team verified that the Division adheres to the inspection priorities prescribed in IMC 

2800, “Materials Inspection Program.” The Division conducted 416 Priority 1, 2, and 3 inspections 

during the review period, based on the inspection frequencies established in IMC 2800. Three of 

these inspections were conducted overdue by more than 25 percent of the inspection frequency 

prescribed in IMC 2800. In addition, the Division performed 139 initial inspections during the 

review period, none of which were conducted overdue. Overall, the review team calculated that 

the Division performed less than one percent of high priority and initial inspections overdue during 

the review period. 

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

A sampling of 22 inspection reports and review of computer printouts used to track this metric 

indicated that none of the inspection findings were communicated to the licensees beyond 30 

days after the inspection. 

During the review period, the Division granted reciprocity permits; 235 of which were candidate 

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

the Division did not meet the NRC’s criteria of inspecting 20 percent of candidate licensees 

operating under reciprocity in each of the five years covered by the review period (2009–18 

percent, 2010–11 percent, 2011–6 percent, 2012–13 percent, 2013–5 percent). The Division 
NRC Region IV Final IMPEP Report Page 5 

recognized it did not meet the reciprocity goal for the review period and conducted a 

self-assessment in this area. The Division determined the goal was not achieved, in part, due to 

the 2010 Deepwater Horizon Gulf of Mexico oil spill that prohibited helicopter transportation in the 

Gulf of Mexico and impacted the Division in performing offshore reciprocity inspections. In 

addition, the Division is challenged by Region IV’s geography and substantial travel time needed 

to reach an inspection location coupled with the short notice typically associated with reciprocity 

activities. The Division committed to implement a process to provide greater Branch Chief 

oversight and better coordination of reciprocity inspections with routine inspections or with 

inspection trips focused on reciprocity. The MRB noted Region IV plans to revise its process and 

directed that reciprocity be an area of focus at the next periodic meeting for Region IV. 

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

that Region IV’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 22 radioactive materials inspections conducted during the 

review period. The casework reviewed included inspections conducted by 11 Division inspectors 

and covered inspections of various license types: broad scope, medical diagnostic and therapy 

(including gamma knife and high dose-rate remote afterloader), portable gauges, industrial 

radiography, nuclear pharmacy, well logging, and Increased Security Controls for Large 

Quantities of Radioactive Materials (Increased Controls). 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 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 and safety was acceptable. The documentation 

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

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

licensees during exit interviews. 

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

outlined in IMC 2800. An inspection report is completed by the inspector which is then reviewed 

and signed by the Branch Chief or senior inspector. Supervisory accompaniments were 

conducted annually for all inspectors. 

The review team determined that the inspection findings were appropriate, and prompt regulatory 

actions were taken, as necessary. Inspection findings were clearly stated and documented in the 

reports and sent to the licensees with the appropriate letter detailing the results of the inspection. 

The Division issues to the licensee, either a letter indicating a clear inspection or a Notice of 

Violation (NOV), in letter format, which details the results of the inspection. When the Division 

issues an NOV, the licensee is required to provide a written response, based on the violations 

cited, within 30 days. All findings are reviewed by the Branch Chief or designee. 
NRC Region IV Final IMPEP Report Page 6 

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

its inspection program. Appropriate, calibrated survey instrumentation, such as Geiger-Mueller 

(GM) meters, scintillation detectors, ion chambers, micro-R meters, and neutron detectors, was 

observed to be available. The Division also has a portable multi-channel analyzer. Instruments 

are calibrated at least annually, or as needed, by an approved vendor with National Institute of 

Standards and Technology traceable sources. The Division uses a database to track each 

instrument, its current location, and next calibration date. 

Accompaniments of four Division inspectors were conducted by an IMPEP team member during 

the weeks of February 24 and April 14, 2014. The inspectors were accompanied during health 

and safety inspections of manufacturing and distribution, industrial radiography, and medical 

therapy including radiopharmaceutical and high dose rate remote afterloader therapies. The 

accompaniments are identified in Appendix C. During 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 and safety and security at the licensed facilities. 

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

that Regions IV’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 on 

20 specific licensing actions. Licensing actions were reviewed for completeness, consistency, 

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

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

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

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

to appropriate regulations, supporting documentation, consideration of enforcement history, 

pre-licensing visits, peer/supervisory review, proper signatures, and marking/control of documents 

that contain sensitive information. 

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

completed during the review period. Licensing actions selected for evaluation included 2 new 

licenses, 4 renewals, 2 decommissioning/termination actions, 11 amendments, and 1 financial 

assurance review. Casework reviewed included a cross-section of license types, including: broad 

scope, medical diagnostic and therapy (including gamma stereotactic radiosurgery, high dose-rate 

remote afterloader, and emerging technologies), service activities, manufacturing and distribution, 

veterinary, industrial radiography, research and development, nuclear pharmacy, portable gauge, 

fixed gauge, and pool irradiators. The casework sample represented work from five current 

license reviewers. A listing of the licensing casework evaluated, with case-specific comments, is 

provided in Appendix D.
NRC Region IV Final IMPEP Report Page 7 

The review team confirmed that all license reviewers had signature authority for licensing actions 

reviewed, or licensing actions were reviewed by a second reviewer while reviewers are under 

training. 

Based on the licensing casework files examined, the review team found that license tie-down 

conditions were stated clearly and were supported by information contained in the file. Deficiency 

letters clearly stated regulatory positions and often identified substantive deficiencies in the 

licensees’ documents. The review team also identified that license reviewers are equipped with 

the NRC’s licensing guides, policies, checklists, and standard license conditions specific to the 

type of licensing actions to ensure consistency in licenses. 

Licensing actions were found to be thorough, complete, consistent, and of high quality with health, 

safety, and security issues properly addressed; however, the review team found that in some of 

the casework reviewed for major complex licensing actions, the license reviewers did not address 

all of the items as described in the NUREG-1556 “Consolidated Guidance About Materials 

Licenses” series. For example, broad scope applications sometimes did not include acceptance 

criteria used by the Radiation Safety Committee (RSC) for approval of new uses, users, or facilities 

or describe approval criteria for non-research activities (e.g., manufacturing and distribution); and 

gamma stereotactic radiosurgery licensees were not always required to submit detailed spot-check 

procedures that would assist inspectors during the conduct of inspections. In another example, 

confirmatory shielding calculations were not performed to verify exposure limits. A listing of file 

specific comments was provided to the Division for its reference. The team concluded that these 

identified items did not impact the protection of public health and safety. 

For one complex license renewal of a broad scope, the license was issued authorizing service of 

any sealed source and device (except Part 36 irradiators), leak testing, emergency response, 

distribution and redistribution, instrument calibration, packaging for disposal, research and 

development with only the program codes for service providers and waste disposal. The IMPEP 

team noted that the reviewer utilized NUREG-1556, Vol. 18 for the review. While this appears 

appropriate for the service activities licensed, the other licensed activities should also have been 

reviewed under the applicable NUREG-1556 Series (e.g., Vol. 5 for irradiators, Vol. 7 for research 

and development, Vol. 11 for broad scope activities, Vols. 12 and 16 for distribution, and Vol. 17 

for Special Nuclear Material). During the review of the renewal, the Division noted that there was 

not a broad scope program code available that reflected all of the licensee’s operations. The 

IMPEP team determined that with fee codes assigned to the license, the license did not properly 

capture broad scope activities, service activities, research and development, and the 

manufacture/distribution of sealed sources or devices to both specific and general licensees. The 

Division committed to taking measures to address the issues identified by the team for this 

particular license. Subsequent to the onsite review, Region IV conducted an extent of condition 

review of the licensing actions and verified that NUREG 1556 Vol. 11 and 18 were applied by the 

license reviewer and that broadscope activities were properly assessed and authorized by the 

license. The team concluded that the identified items on this license did not impact the protection 

of public health and safety. 

The review team found that financial assurance requirement, pre-licensing guidance 

implementation, marking of documents, and licensing practices regarding the Increased Controls 

and Fingerprinting requirements were addressed; however, one license was issued prior to the 
NRC Region IV Final IMPEP Report Page 8 

pre-licensing visit being documented and the full documentation of security requirements (Part 37) 

could not be located. However, interviews of the license reviewer confirmed that during the day of 

source installation, the license reviewer and branch chief were on-site and confirmed the required 

information. 

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

that Region IV’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 Division’s actions in responding to incidents and allegations, 

the review team examined the Division’s response to the questionnaire relative to this indicator, 

evaluated selected incidents reported for Region IV in the Nuclear Material Events Database 

(NMED) against those contained in the Division’s files, and evaluated the casework for 12 

radioactive materials incidents. A list of the incident casework examined may be found in 

Appendix E. The review team also evaluated the Division’s response to 11 allegations involving 

radioactive materials. 

The incidents selected for review included the following categories: equipment failure, potential 

and actual overexposure, medical event, lost/stolen/abandoned radioactive materials, damaged 

equipment, and leaking source. The review team determined that the Division’s response to 

incidents were complete and comprehensive. Initial responses were prompt and 

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

of the reported incident. The Division dispatched inspectors for on-site investigations in five of the 

cases reviewed and took suitable enforcement and follow-up actions. The Division provided 

information to NMED to close reported events in a prompt manner. 

The review team examined the Program’s implementation of its incident and allegation processes, 

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

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

determines the appropriate level of initial response. 

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

evaluated the completed casework for 11 allegations. The review team concluded that the 

Program took prompt and appropriate actions in response to concerns raised. The review team 

noted that the Division documented the investigations of concerns and retained all necessary 

documentation to appropriately close the allegations. The Division notified the concerned 

individual(s) of the conclusion of its investigation(s). The review team determined that the 

Division adequately protected the identity of concerned individuals. 

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

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

Allegation Activities, be found satisfactory. 
NRC Region IV Final IMPEP Report Page 9 

4.0 NON-COMMON PERFORMANCE INDICATORS 

IMPEP identifies one non-common performance indicator to be used in reviewing Regional 

radioactive materials programs, the Uranium Recovery Program. 

4.1 Uranium Recovery Program 

This non-common indicator includes five subelements of the uranium recovery regulatory 

program: (1) Technical Staffing and Training, (2) Status of the Uranium Recovery Inspection 

Program, (3) Technical Quality of the Uranium Recovery Inspection Program, (4) Technical 

Quality of Licensing, and (5) Technical Quality of Incidents and Allegation Activities. Region IV 

does not conduct uranium recovery licensing, this is performed by staff in the Division of Waste 

Management and Environmental Protection, FSME; therefore, subelement 4 was not addressed 

in this review. 

At the time of this IMPEP review, the Region IV uranium recovery program consists of five 

operating in situ leach facilities (Power Resources Smith Ranch, Crow Butte, Uranium One, Lost 

Creek, and Uranerz); four additional in situ licensed sites that are not currently operational; one 

conventional mill in standby status; and ten conventional mill sites in various phases of 

decommissioning. 

4.1.1 Technical Staffing and Training 

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

the staff, staff training, and staff turnover. The duties and responsibilities for the Region IV 

uranium recovery program are assigned to the staff within the RSFSB in the Division. Presently 

there are two inspectors who perform the uranium recovery inspections. The review team 

determined that the Division’s staffing level for uranium recovery inspections during the review 

period was adequate, but needs to be enhanced based on workload challenges at the time of the 

review and the new licenses recently issued by FSME. The review team discussed the need for 

additional staff trained to conduct uranium recovery inspections with Region IV management after 

reviewing the increase in the uranium recovery budgeted resources for fiscal year 2015 and 

beyond. The review team determined that the current staff qualifications and training were 

adequate. The Region IV uranium recovery inspectors have reactor health physics or radioactive 

materials safety backgrounds. Region IV inspectors routinely coordinated inspections with 

technical staff from FSME for the necessary expertise to review other areas such as geotechnical 

engineering, hydrology, and geosciences. The team found that during the review period there 

was little ongoing activity that warranted joint inspections between Region IV and FSME staff; 

however, Region IV staff maintained communication with FSME technical and licensing uranium 

recovery staff for effective inspections at the decommissioning sites. 

4.1.2 Status of Uranium Recovery Inspection Program 

The review team focused on several factors in evaluating the Division’s performance for this 

subelement, including inspection frequency, overdue inspections, timely issuance of inspection 

findings to licensees, and inspection follow-up. The review team's evaluation is based on a 

review of the Division's response to the questionnaire relative to this indicator, the uranium
NRC Region IV Final IMPEP Report Page 10 

recovery inspection schedule, selected inspection casework files, and interviews with inspection 

staff and managers. 

During the review period, the Division conducted 46 inspections, 3 pre-operational inspections, 

and 14 site visits of Department of Energy generally licensed sites. Most of the sites are 

non-operating conventional mills that are in various stages of decommissioning and reclamation. 

The inspection frequency for each site is established through a Master Inspection Plan developed 

by the Division in conjunction with FSME. The inspection schedule is based on guidance in NRC 

IMC 2641, “In-Situ Leach Facilities Inspection Program,” and IMC 2801, “Uranium Mill and 11e.(2) 

Byproduct Material Disposal Site and Facility Inspection Program.” The review team concluded 

that there were no overdue inspections in the Uranium Recovery Program. The review team 

evaluated the timeliness of the issuance of inspection findings during the inspection file review. 

The review team determined that four inspection reports were issued greater than 30 days after 

completion of the inspection and final closeout with licensee managers and operations staff. In 

addition, there were three inspection reports that have not been issued that were greater than 30 

day from the inspection exit. The review team determined that the increase in inspection 

workload for the Region IV uranium recovery program recently has caused delays in the 

completion of the inspection reports. 

4.1.3 Technical Quality of Inspections 

In reviewing this subelement, the review team examined inspection reports and other 

documentation for 14 inspections conducted by the Division during the review period. The cases 

selected for review covered various licensees representing a range of uranium recovery 

inspection activities for different stages of facility operation. The review team interviewed 

inspectors and managers to assess the adequacy of their preparation for the inspections, the 

depth and content of the actual inspections, and the appropriateness of inspection findings. The 

uranium recovery files evaluated by the review team are listed in Appendix C. 

Generally, one Region IV uranium recovery inspector will conduct an inspection with occasional 

assistance from other inspectors, supervisors, or FSME technical staff. The inspectors 

coordinate, plan, and prepare for inspections by reviewing relevant manual chapters, inspection 

procedures, previous inspection reports, licenses, incident reports, notices of violations, and other 

background information. Division inspectors will often consult with the uranium recovery licensing 

staff in FSME before inspections. 

The review determined that, during a typical inspection, inspectors observe licensee operations; 

interview workers, managers, and contractors; review facility records; examine site operating 

plans and procedures; and make independent measurements during inspections. Although the 

Division’s uranium recovery inspectors primarily focus on health physics and radiation safety 

issues, they also routinely inspect for environmental monitoring, management, and organizational 

issues. The inspectors typically observe a broad spectrum of licensee operations and include 

input from other technical staff assisting in the inspection, as appropriate. The team concluded 

that the inspections were adequate to assess radiological health and safety, and adherence to the 

NRC requirements at licensed facilities.
NRC Region IV Final IMPEP Report Page 11 

The review team found that the Division’s uranium recovery inspection reports were well written, 

provided appropriate depth, and were promptly reviewed by supervisors. They addressed 

compliance conditions for the licensees, and demonstrated that the inspectors pursued root 

causes where problems or violations were identified. The inspection findings lead to appropriate 

and prompt regulatory action. Licensees are given 30 days to reply to the Notice of Violation. 

After the response, an acknowledgement letter is sent to the licensee indicating if the review of 

the proposed corrective actions is satisfactory or not. 

The review team determined that during the review period, uranium recovery inspectors had been 

accompanied by their supervisors at least once a year. The review team found that the 

supervisors routinely meet with the uranium recovery inspectors after their inspections to review 

inspection findings and to plan follow-up strategy. 

4.1.4 Technical Quality of Licensing Actions 

Since the Division does not perform uranium recovery licensing actions, this subelement was 

not evaluated during the review. 

4.1.5 Technical Quality of Incident and Allegation Activities 

For this subelement, the review team examined the files and other information on the uranium 

recovery incidents provided by the Division in its response to the questionnaire, response 

timeliness and inspection reports, and interviewed the inspection staff involved with incident and 

allegation activities. 

The Division received no notifications of uranium recovery incidents during the review period. 

However, there were two incidents that were identified during inspections concerning not properly 

restricting access to and proper posting of areas that exceeded 2 mrem in any one hour. The 

incidents were captured in NMED. The licensees took prompt corrective action in both cases. 

Division staff followed up to ensure actions was properly completed. 

Region IV had four allegations during the review period. One allegation was closed out with an 

appropriate evaluation and response to the concerned individual in accordance with NRC 

allegation procedures. The other three allegations are being addressed by the Office of

Investigations and remained open at the time of the review. 

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

that Regions IV’s performance with respect to the indicator, Uranium Recovery Program, be found 

satisfactory. 
NRC Region IV Final IMPEP Report Page 12 

5.0 SUMMARY 

As noted in Sections 3.0 and 4.0 above, the NRC RIV materials program was found satisfactory 

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

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

2009 IMPEP review made to FSME should be closed. 

Accordingly, the review team recommended, and the MRB agreed, that the NRC Region IV 

program be found adequate to protect public health and safety. Based on the results of the 

current IMPEP review, the review team recommended, and the MRB agreed, that the next full 

IMPEP review take place in approximately 5 years. 
LIST OF APPENDICES 

Appendix A IMPEP Review Team Members 

Appendix B Region IV 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

Lisa Dimmick, FSME Technical Staffing and Training 

 Status of Materials Inspection Program 

 Team Leader 

Penny Lanzisera, Region I Technical Quality of Licensing Actions 

Geoffrey Warren, Region III Technical Quality of Incident and Allegation 

Activities 

 Inspector Accompaniments 

Steve Mack, AR Technical Quality of Inspections 

Dennis Sollenberger, FSME Uranium Recovery Program 

 
APPENDIX B 

NRC REGION IV ORGANIZATION CHARTS 

ADAMS ACCESSION NO.: ML14157A220
 APPENDIX C 

INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Short / Dolan Investments, Inc. License No.: 02-29359-01 

 d/b/a Pacific Island Inspection 

Inspection Type: Initial, Announced Priority: 1 

Inspection Date: 4/28/10 Inspector: RM 

File No.: 2 

Licensee: Short / Dolan Investments, Inc. License No.: 02-29359-01 

 d/b/a Pacific Island Inspection 

Inspection Type: Reciprocity / Unannounced Priority: 1 

Inspection Date: 7/29-8/18/09 Inspector: LD 

File No.: 3 

Licensee: ARS International, Inc. License No.: 17-29441-01 

Inspection Type: Initial, Announced Priority: 2 

Inspection Date: 4/22/13 Inspector: LH 

File No.: 4 

Licensee: Panhandle Geotechnical & Environmental, Inc. License No.: 26-29304-01 

Inspection Type: Initial, Announced Priority: 5 

Inspection Date: 2/9-4/16/09 Inspector: JR 

File No.: 5 

Licensee: Panhandle Geotechnical & Environmental, Inc. License No.: 26-29304-01 

Inspection Type: Follow-up, Unannounced Priority: 5 

Inspection Date: 4/20/10 Inspectors: LH/VC 

File No.: 6 

Licensee: Anchorage Radiation Oncology Management, Inc. License No.: 50-35068-01 

 d/b/a Anchorage Radiation Therapy Center 

Inspection Type: Initial, Announced Priority: 2 

Inspection Date: 12/16-18/13 Inspectors: MS/JW 

File No.: 7 

Licensee: St. Luke Community Hospital License No.: 25-29421-01 

Inspection Type: Initial, Announced Priority: 3 

Inspection Date: 11/15/11 Inspector: JT 

File No.: 8 

Licensee: Uranium One Americas, Inc. License No.: 49-29384-01 

Inspection Type: Initial, Announced Priority: 3 

Inspection Date: 11/17/10, 11/7/13 Inspector: LH 
NRC Region IV Final IMPEP Report 

Inspection Casework Reviews Page C. 2 

File No.: 9 

Licensee: Pacific Radiopharmacy, Ltd. License No.: 53-16991-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 10/29-11/7/13 Inspector: RM 

File No.: 10 

Licensee: Century Geophysical Corporation License No.: 35-04017-04 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 9/10/13 Inspector: LR 

File No.: 11 

Licensee: C & J’s NDT, Inc. License No.: 33-29238-01 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 2/27-3/29/12 Inspector: MH 

File No.: 12 

Licensee: Metals Testing Services, Inc. License No.: 25-29406-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 10/28/13 Inspector: MS 

File No.: 13 

Licensee: Advanced Isotopes of Idaho License No.: 11-29216-01 MD 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 1/24/11 Inspector: LR 

File No.: 14 

Licensee: Qal-Tek, LLC License No.: 11-27610-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 4/13/11 Inspector: MH 

File No.: 15 

Licensee: Qal-Tek, LLC License No.: 11-27610-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 4/11-8/9/13 Inspector: JT 

File No.: 16 

Licensee: Memorial Hospital of Laramie County License No.: 49-01380-01 

 d/b/a Cheyenne Regional Medical Center 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 3/1/12 Inspectors: DS/JT 

File No.: 17 

Licensee: Halliburton Energy Services, Inc. License No.: 42-01068-07 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 9/14/12 Inspector: LH 
NRC Region IV Final IMPEP Report 

Inspection Casework Reviews Page C. 3 

File No.: 18 

Licensee: Halliburton Energy Services, Inc. License No.: 42-01068-07 

Inspection Type: Routine, Unannounced, Field Location Priority: 2 

Inspection Date: 5/13/11 Inspector: JR 

File No.: 19 

Licensee: Southwest X-Ray Corporation License No.: 49-29277-01 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 7/8/13 Inspector: DS 

File No.: 20 

Licensee: The Navajo Nation, Department of Water Resources License No.: 02-29109-02 

Inspection Type: Routine, Announced Priority: 3 

Inspection Date: 3/20/12 Inspectors: RT/TG 

File No.: 21 

Licensee: H&H X-Ray Services, Inc. License No.: 17-19236-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 4/23/13 Inspector: LH 

File No.: 22 

Licensee: Southwest X-Ray Corporation License No.: 49-29277-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 5/16/12 Inspector: TG 

File No.: 23 

Licensee: Uranerz Energy Corp License No.: SUA-1597 

Inspection Type: Initial/Preoperational Inspection Priority: 6 months 

Inspection Date: 11/18-21/13, 1/28-30/14 Inspectors: LG, RE, RL, ES 

Comment: Report was issued 30 days overdue. 

File No.: 24 

Licensee: Lost Creek ISR, LLC License No.: SUA-1598 

Inspection Type: Initial/Preoperational Inspection Priority: 6 months 

Inspection Date: 6/24-27/13, 7/29-30/13, 8/27/13 Inspectors: LG, RE, JS, DM, RL, BvT 

 Comment: Report issued 150 days overdue. 

File No.: 25 

Licensee: Pathfinder Mines Corp. License No.: SUA-442 

Inspection Type: Routine Priority: 2 

Inspection Date: 9/25/13 Inspectors: LG, TC 

 Comment: Report issued 32 days overdue. 
NRC Region IV Final IMPEP Report 

Inspection Casework Reviews Page C. 4 

File No.: 26 

Licensee: Exxon Mobil Environmental Services, Co. License No.: SUA-1139 

Inspection Type: Routine Priority: 2 

Inspection Date: 9/24/13 Inspectors: LG, TC 

 Comment: Report issued 35 days overdue. 

File No.: 27 

Licensee: Power Resources, Inc. License No.: SUA-1548 

Inspection Type: Routine Priority: 6 months 

Inspection Date: 9/9-12/13 Inspectors: LG, DM, ES, BT, AW 

 Comment: Report issued 72 days overdue. 

File No.: 28 

Licensee: Kennecott Uranium Company. License No.: SUA-1350 

Inspection Type: Routine Priority: 2 

Inspection Date: 8/28/13 Inspector: LG 

File No.: 29 

Licensee: United Nuclear Corp. License No.: SUA-1475 

Inspection Type: Routine Priority: 2 

Inspection Date: 7/18/13 Inspector: RE 

File No.: 30 

Licensee: Rio Algom Mining, LLC. License No.: SUA-1473 

Inspection Type: Routine Priority: 2 

Inspection Date: 7/16-17/13 Inspector: RE 

File No.: 31 

Licensee: Crowe Butte Resources, Inc. License No.: SUA-1534 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 6/4-6/13 Inspectors: LG, TL, RB 

File No.: 32 

Licensee: Uranium One License No.: SUA-1341 

Inspection Type: Routine Priority: 6 months 

Inspection Date: 1/29-31/13 Inspectors: LG, RL, AV 

File No.: 33 

Licensee: Power Resources, Inc. License No.: SUA-1548 

Inspection Type: Routine Priority: 6 months 

Inspection Date: 4/1-4/13, 5/29-30/13 Inspectors: LG, ES, VK 
NRC Region IV Final IMPEP Report 

Inspection Casework Reviews Page C. 5 

File No.: 34 

Licensee: Uranium One USA, Inc. License No.: SUA-1341 

Inspection Type: Special (Follow up to CAL) Priority: NA 

Inspection Date: 9/11-13/12, 10/23/12 Inspectors: RE, LG, DBS, +2 DOT 

File No.: 35 

Licensee: Uranium One USA, Inc. License No.: SUA-1341 

Inspection Type: Routine Priority: 6 months 

Inspection Date: 4/16-18/12 Inspectors: LG, RL, HY 

File No.: 36 

Licensee: Homestake Mining Company. License No.: SUA-1471 

Inspection Type: Routine Priority: 2 

Inspection Date: 8/21-22/12 Inspector: GS 

INSPECTOR ACCOMPANIMENTS 

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

Accompaniment No.: 1 

Licensee: Premier Technology, Inc. License No.: 11-27746-01 

Inspection Type: Routine/Special/Unannounced Priority: 1 

Inspection Date: 2/24/14 Inspector: DS 

Accompaniment No.: 2 

Licensee: International Isotopes, Inc. License No.: 11-27680-01 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 2/25/14 Inspectors: DS/MH 

Accompaniment No.: 3 

Licensee: Sabia, Inc. License No.: 11-27727-01 

Inspection Type: Routine/Unannounced Priority: 5 

Inspection Date: 2/26/14 Inspector: MH 

Accompaniment No.: 4 

Licensee: St. Alphonsus Regional Medical Center License No.: 11-27306-01 

Inspection Type: Routine/Unannounced Priority: 2 

Inspection Date: 2/27/14 Inspector: LH 

Accompaniment No.: 5 

Licensee: JanX License No.: 21-16560-01 

Inspection Type: Routine/Special/Unannounced Priority: 1 

Inspection Date: 4/14-15/14 Inspector: JT 
APPENDIX D 

LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Billings Clinic License No.: 25-01051-01 

Type of Action: Amendment Amendment No.: 91 

Date Issued: 10/31/13 License Reviewer: LR 

Comment: Several items discussed in NUREG-1556, Vol. 9 and guidance specific to 

Perfexion were not addressed in this review. 

File No.: 2 

Licensee: Billings Clinic License No.: 25-01051-01 

Type of Action: Amendment Amendment No.: 93 

Date Issued: 2/27/14 License Reviewer: JC 

File No.: 3 

Licensee: Anchorage Radiation Oncology Management, Inc. License No.: 50-35068-01 

Type of Action: New Amendment No.: 0 

Date Issued: 7/3/13 License Reviewer: MS 

 Comments: 

a) Several items discussed in NUREG-1556, Vol. 9 were not addressed in this review. 

b) Pre-licensing checklist was incomplete. 

File No.: 4 

Licensee: Anchorage Radiation Oncology Management, Inc. License No.: 50-35068-01 

Type of Action: Amendment – Perfexion GSR – medical use Amendment No.: 1 

Date Issued: 12/15/13 License Reviewer: MS 

File No.: 5 

Licensee: Qal-Tek Associates, LLC. License No.: 11-27610-01 

Type of Action: Renewal – Type A Broadscope Service License & M&D Amendment No.: 17 

Date Issued: 5/21/09 License Reviewer: RT 

Comment: Applicable NUREG-1556 guidance documents were not used during the 

review and in the license preparation. 

File No.: 6 

Licensee: International Isotopes, Inc. License No.: 11-27680-01 

Type of Action: Financial Assurance - M&D Broad - Type A Amendment No.: n/a 

Date Issued: 2/26/10 License Reviewer: RT 
NRC Region IV Final IMPEP Report 

License Casework Reviews Page D. 2 

File No.: 7 

Licensee: International Isotopes, Inc. License No.: 11-27680-01 

Type of Action: Renewal – Manufacturing & Distribution Broad - Type A Amendment No.: 21 

Date Issued: 9/14/10 License Reviewer: RT 

File No.: 8 

Licensee: SABIA, Inc. License No.: 11-27727-01 

Type of Action: Renewal - Service Amendment No.: 15 

Date Issued: 10/9/12 License Reviewer: RT 

File No.: 9 

Licensee: Pa’ina Hawaii, LLC License No.: 53-29296-01 

Type of Action: Amendment – Pool Irradiator Amendment No.: 3 

Date Issued: 10/15/12 License Reviewer: RT 

File No.: 10 

Licensee: Horrocks Engineers, Inc. License No.: 43-35140-01 

Type of Action: New – Portable Gauge Amendment No.: 0 

Date Issued: 4/4/14 License Reviewer: MH 

File No.: 11 

Licensee: VCA University Animal Hospital License No.: 53-27684-01 

Type of Action: Termination - Veterinary Amendment No.: 4 

Date Issued: 4/21/14 License Reviewer: MS 

File No.: 12 

Licensee: PP & L Montana, LLC License No.: 25-18011-01 

Type of Action: 3120 – Amendment - Fixed Gauge Amendment No.: 20 

Date Issued: 4/9/14 License Reviewer: LR 

File No.: 13 

Licensee: Techcorr USA, LLC License No.: 42-29261-01 

Type of Action: 3320 – Amendment - Industrial Radiography Amendment No.: 10 

Date Issued: 4/9/14 License Reviewer: JC 

File No.: 14 

Licensee: Kalispell Regional Medical Center License No.: 25-15463-01 

Type of Action: 2240 – Amendment - Emerging Technology Amendment No.: 41 

Date Issued: 4/14/14 License Reviewer: LR 

File No.: 15 

Licensee: Dept. of Health & Human Services License No.: 17-14996-01 

Type of Action: 3620- Amendment - Research & Development Amendment No.: 24 

Date Issued: 1/15/14 License Reviewer: JC 
NRC Region IV Final IMPEP Report 

License Casework Reviews Page D. 3 

File No.: 16 

Licensee: St. Peter’s Hospital License No.: 25-12453-02 

Type of Action: 2120 – Renewal – Medical Institution WD Required Amendment No.: 41 

Date Issued: 2/14/14 License Reviewer: JC 

File No.: 17 

Licensee: St. Vincent Healthcare License No.: 25-07553-01 

Type of Action: Amendment – High Dose Rate Remote Afterloader Amendment No.: 87 

Date Issued: 3/7/14 License Reviewer: MH 

File No.: 18 

Licensee: Pharmalogic MT. Inc. License No.: 09-29398-01MD 

Type of Action: Amendment – Nuclear Pharmacy Amendment No.: 4 

Date Issued: 3/7/14 License Reviewer: MH 

File No.: 19 

Licensee: Cassia Regional Medical Center License No.: 11-27393-01 

Type of Action: Amendment – Medical Institution, No WD Amendment No.: 15 

Date Issued: 3/11/14 License Reviewer: JC 

File No.: 20 

Licensee: Nelcon, Inc. License No.: 5-29423-01 

Type of Action: Termination – Portable Gauge Amendment No.: 1 

Date Issued: 12/3/13 License Reviewer: MH 
APPENDIX E 

INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Acuren USA License No.: 50-32443-01 

Date of Incident: 10/4/12 NMED No.: 120630 

Investigation Date: 10/19/12, 1/18/13 Type of Incident: Equipment Failure 

 Type of Investigation: Site 

File No.: 2 

Licensee: Fairbanks Gold Mining Inc. License No.: 50-29098-01 

Date of Incident: 10/19/11 NMED No.: 110541 

Investigation Date: 2/8/12 Type of Incident: Equipment Failure 

 Type of Investigation: Phone 

File No.: 3 

Licensee: Acuren USA License No.: 42-32443-01 

Date of Incident: 6/22/11 NMED No.: 110455 

Investigation Date: 1/10/12 Type of Incident: Overexposure 

 Type of Investigation: Phone 

File No.: 4 

Licensee: Benefis Hospitals License No.: 25-12710-01 

Date of Incident: 1/5/12 NMED No.: 120054 

Investigation Date: 1/17-19/12 Type of Incident: Medical Event 

 Type of Investigation: Site 

File No.: 5 

Licensee: Western South Dakota Community Action Agency License No.: General Licensee 

Date of Incident: 6/29/11 NMED No.: 110377 

Investigation Date: 8/9/11 Type of Incident: Stolen RAM 

 Type of Investigation: Phone 

File No.: 6 

Licensee: Halliburton Energy Services License No.: Reciprocity Licensee 

Date of Incident: 4/20/10 NMED No.: 100204 

Investigation Date: 7/27/10 Type of Incident: Lost RAM 

 Type of Investigation: Phone 

File No.: 7 

Licensee: FMC Corporation License No.: 49-04295-01 

Date of Incident: 9/3/09 NMED No.: 090883 

Investigation Date: 4/27-29/10 Type of Incident: Overexposure 

 Type of Investigation: Site 
NRC Region IV Final IMPEP Report 

Incident Casework Reviews Page E. 2 

File No.: 8 

Licensee: Century Inspection License No.: 42-08456-02 

Date of Incident: 6/18/09 NMED No.: 090672 

Investigation Date: 6/23/09 – 6/31/09 Type of Incident: Potential Overexposure 

 Type of Investigation: Site 

File No.: 9 

Licensee: Avera McKennan Hospital License No.: 40-16571-01 

Date of Incident: 1/16/12 NMED No.: 120067 

Investigation Date: 1/30-2/2/12 Type of Incident: Medical Event 

 Type of Investigation: Site 

File No.: 10 

Licensee: Mid Pacific Testing & Inspection License No.: 53-29044-01 

Date of Incident: 7/15/10 NMED No.: 100359 

Investigation Date: 12/17/10 Type of Incident: Damage to Equipment 

 Type of Investigation: Phone 

File No.: 11 

Licensee: Sanford Medical Center License No.: 40-12378-01 

Date of Incident: 6/6/12 NMED No.: 130229 

Investigation Date: 4/26/13 Type of Incident: Leaking Source 

 Type of Investigation: Phone 

File No.: 12 

Licensee: Schlumberger Technology Group License No.: 42-00090-03 

Date of Incident: 9/25/13 NMED No.: 130495 

Investigation Date: 9/25/13 Type of Incident: Abandoned RAM 

 Type of Investigation: Phone
Attachment 1 

ATTACHMENT 

July 2, 2014, Memo from Marc L. Dapas 

NRC Region IV Response to the Draft Report 

ADAMS Accession No.: ML14183B686