October 16, 2014 

Aubrey Godwin, Director 

Arizona Radiation Regulatory Agency 

4814 South 40th Street 

Phoenix, Arizona 85040 

Dear Mr. Godwin: 

A periodic meeting with your State was held on September 17, 2014. The purpose of this 

meeting was to review and discuss the status of the Arizona Agreement State Program. The 

NRC was represented by Mark Shaffer, Director, Division of Nuclear Materials Safety in NRC 

Region IV, Joe O’Hara from the Office of Nuclear Material Safety and Safeguards, and me. I 

have completed and enclosed a general meeting summary, including any specific actions 

resulting from the discussions. 

If you feel that our conclusions do not accurately summarize the meeting discussion, or have 

any additional remarks about the meeting in general, please contact me at 817-200-1143 or 

email Randy.Erickson@nrc.gov to discuss your concerns. 

 Sincerely, 

 /RA/

 Randy Erickson 

 Regional State Agreements Officer 

Enclosure: 

Periodic Meeting Summary for Arizona 

 UNITED STATES

NUCLEAR REGULATORY COMMISSION 

REGION IV

1600 E. LAMAR BLVD. 

ARLINGTON, TX 76011-4511
bcc (via e-mail distribution): 

Mark Shaffer, DNMS 

Linda Howell, DNMS 

Laura Dudes, FSME 

Pamela Henderson, FSME 

Susan Abraham, FSME 

Duncan White, FSME 

Binesh Tharakan, SAO 

Randy Erickson, SAO 

Joe O’Hara, FSME 

Lisa Dimmick, FSME 

Michelle Beardsley, FSME 

Karen Meyer, FSME 

DOCUMENT NAME: 

ADAMS ACCESSION NUMBER: 

X SUNSI Review 

By: RRE

ADAMS 

x Yes  No 

X Publicly Available 

 Non-Publicly Available 

X Non-Sensitive 

 Sensitive 

Keyword: 

OFFICE RIV 

NAME RRErickson 

SIGNATURE /RA/ 

DATE 10/16/14 

OFFICIAL RECORD COPY 
Enclosure 

AGREEMENT STATE PERIODIC MEETING SUMMARY FOR THE 

ARIZONA RADIATION REGULATORY AGENCY 

DATE OF MEETING: SEPTEMBER 17, 2014 

NRC Attendees Arizona Attendees 

Randy Erickson, RSAO Aubrey Godwin, Director 

Mark Shaffer, Director, DNMS, R-IV Brian Goretzki, Program Manager, RAM 

Joe O’Hara, FSME Jerry Perkins, Program Manager, X-Ray 

 Dan Kuhl, Health Physicist 

 Phillip (Rocky) Kern, Health Physicist 

 Wayne Yates, Health Physicist 

DISCUSSION: 

The Arizona Agreement State Program is administered by the Arizona Radiation Regulatory 

Agency (the Agency). The Agency Director reports directly to the Governor. At the time of the 

meeting, the Program regulated the activities of 364 specific licensees. 

The previous IMPEP review was conducted the week of March 26-30, 2012. At the conclusion 

of the review the team found Arizona’s performance to be satisfactory for all common 

performance indicators and satisfactory but needs improvement for the non-common indicator 

Compatibility Requirements. The Program was found adequate to protect public health and 

safety and compatible with the NRC’s program. 

The review team recommended that the next full IMPEP review take place in four years and that 

a Periodic Meeting take place in one year to monitor the Program’s progress on catching up on 

backlogged regulations. That Periodic Meeting was held on February 12, 2013. At the time of 

the 2013 meeting, the Program was under a moratorium regarding new regulation development 

and while the Program has been able to work through the moratorium, they had not yet 

effectively caught up on backlogged regulations. At that time it was agreed upon that another 

Periodic Meeting be held in approximately 18 months to further review the Program’s progress 

on rule development. 

Other topics discussed at the meeting included: 

Program Strengths: 

While the Program is authorized for six health physicists, they are only budgeted for, and 

have four full-time health physicists who are cross trained to perform both inspections and 

licensing actions. This cross training is necessary so that the Program can keep up with the 

workload with limited staff by utilizing them where they are needed the most. The Program 

noted that each of the four health physicists are long term employees and are fully qualified. 

These four health physicists are also required to perform emergency response duties as 

required. 
Arizona Periodic Meeting Summary Page 2 

Program Weaknesses: 

The Program reported they are concerned about staffing and has identified it as a primary 

programmatic weakness. Currently the Program is authorized for six materials inspectors 

but is only allowed to fill four of those positions. Those same four individuals have been 

maintaining the Program for several years. While they have been able to keep up with the 

work to this point, at least two of those individuals are close to retirement and could leave at 

any time. If this happens, the Program believes it would likely cause them to fall behind on 

licensing actions and inspections, and not be able to provide sufficient staff for emergency 

response operations. 

Feedback for NRC: 

 The Program acknowledged that while the theft of portable moisture density gauges is 

an issue affecting all states, Arizona has recently experienced a larger than average 

number of thefts of these devices, with six having been stolen as of the date of the 

review. The Program has recommended a joint NRC-Agreement State working group 

be formed to look into the possibility of placing GPS tracking devices on gauges to aid in 

their recovery. 

 The Program stated they are concerned that RSO’s are allowed to by RSO’s on multiple 

licenses in different geographical areas. The Program does not believe that they are 

able to effectively respond to emergencies, etc., if they are not on or near a site. 

 The Program requested that NRC hold a Financial Assurance Webinar. 

Staffing and training: 

The Arizona Radioactive Materials Program is managed by the Director and a Program 

Manager with responsibility for four inspectors and 364 licensees. The Program is budgeted 

for six staff, but has only been authorized to staff four positions. Each of the staff is fully 

qualified with several years of experience. Two of the staff members are eligible for 

retirement which is expected to present a difficulty for the program when it occurs. Training 

has not been an issue for the Program. 

Program reorganizations: 

The Program has not been subject to reorganization since the 2012 IMPEP review. 

Changes in Program budget/funding: 

The Program is not experiencing any problems with budgeting or funding. 
Arizona Periodic Meeting Summary Page 3 

Materials Inspection Program: 

The Program reported that they have not had any overdue inspections since the 2012 

review. Initial inspections are typically performed within 12 months of issuance. They 

continue to inspect reciprocity licensees and have not had difficulty performing inspections 

on at least 20 percent of candidate reciprocity licensees. The Program performs Increased 

Controls inspections concurrent with health and safety inspections. Supervisory 

accompaniments are performed annually. 

Licensing Program: 

The Program reported that the licensing program is active. Each of the staff performs both 

inspections and licensing actions as assigned. The more senior individuals perform the 

more advanced or complex licensing actions. The Program noted that licensing actions are 

tracked and that no backlogs exist. 

Sealed Source and Device Evaluation Program (SS&D): 

The Program reported that the SS&D Program is inactive at the present time. No actions 

have been taken since the 2013 Periodic Meeting. 

Regulations and Legislative changes: 

The Program reported that one legislative package affecting the Program was adopted since 

the 2013 Periodic Meeting. The Small Business Bill of Rights was passed which allows 

licensees to appeal inspection findings. 

On August 15, 2014, the Program submitted a final regulation package containing 

amendments 2005-2, 2006-1, 2007-1, 2007-3, 2008-1 and 2009-1. This final regulation 

package was approved by NRC. With this submission, the Arizona Program is now up to 

date on regulations. The next amendment due will be 2011-2 due for State adoption on 

November 14, 2014. 

Event reporting, including follow-up and closure information in NMED.

Since the 2013 Periodic Meeting, the Program reported 11 events to NMED. At the time of 

the 2014 Periodic Meeting, all 11 were currently open. Program reported they will complete 

the event reviews and will close them soon. 

Response to incidents and allegations.

The Program continues to be sensitive to notifications of incidents and allegations. 

Incidents are quickly reviewed for their effect on public health and safety. Incidents are 

evaluated for safety significance and staff is dispatched to perform onsite investigations as 

indicated. 
Arizona Periodic Meeting Summary Page 4 

Status of allegations and concerns referred by the NRC for action. 

The Program continues to process allegations as they are received. Since the 2013 

Periodic Meeting, the NRC has referred two allegations to the Program. Each of the 

allegations received by the Program is being investigated and will be closed when 

completed. The Program continues to be sensitive to issues of identity protection regarding 

allegers. 

Current NRC initiatives: 

The following NRC initiatives were discussed with the Program: 

 FSME – NMSS Merger 

 NRC’s inspector qualification program (IMC 1248) 

 Updates on the NUREG 1556 series revisions 

 Rulemaking Initiatives 

 IMPEP Performance Metrics 

 Merging of the Policy Statements and ASPEI activities 

 Policy Statements for Agreement States on Adequacy and Compatibility 

Schedule for the next IMPEP review:

It is recommended that the next IMPEP review to be held on schedule in March 2016.