August 22, 2013 

John Wiesman, DrPH, MPH 

Secretary of Health 

Washington Department of Health 

P.O. Box 47890 

Olympia, WA 98504-7890 

Dear Dr. Wiesman: 

On July 23, 2013, the Management Review Board (MRB) met to consider the proposed final 

Integrated Materials Performance Evaluation Program (IMPEP) report on the Washington 

Agreement State Program for the IMPEP review conducted on May 6-10, 2013. The MRB 

found the Washington Agreement State Program adequate to protect public health and safety 

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

Section 5.0, page 18, of the enclosed final report contains a summary of the IMPEP team’s 

findings and recommendations. The review team made one recommendation regarding the 

assessment of incidents for generic issues. We request your evaluation and response to the 

one recommendation in the report within 30 days from receipt of this letter. Based on the 

results of the current IMPEP review, the next full review of the Washington Agreement State 

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

for May 2014. The Washington Agreement State Program received an extension of 1 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 team during the review. 

I also wish to acknowledge your continued support for the Agreement State program. I look 

forward to our agencies continuing to work cooperatively in the future. 

 Sincerely, 

/RA by Catherine Haney for/ 

 Michael F. Weber 

 Deputy Executive Director for Materials, Waste, 

 Research, State, Tribal and Compliance Programs 

 Office of the Executive Director for Operations 

Enclosure: 

Washington Final IMPEP Report 

cc w/ encl: Maryanne Guichard 

 Assistant Secretary 

 Jared Thompson, AR 

 Organization of Agreement States 

 Liaison to the MRB
John Wiesman, DrPH, MPH 

Secretary of Health 

Washington Department of Health 

P.O. Box 47890 

Olympia, WA 98504-7890 

Dear Dr. Wiesman: 

On July 23, 2013, the Management Review Board (MRB) met to consider the proposed final 

Integrated Materials Performance Evaluation Program (IMPEP) report on the Washington 

Agreement State Program for the IMPEP review conducted on May 6-10, 2013. The MRB 

found the Washington Agreement State Program adequate to protect public health and safety 

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

Section 5.0, page 18, of the enclosed final report contains a summary of the IMPEP team’s 

findings and recommendations. The review team made one recommendation regarding the 

assessment of incidents for generic issues. We request your evaluation and response to the 

one recommendation in the report within 30 days from receipt of this letter. Based on the 

results of the current IMPEP review, the next full review of the Washington Agreement State 

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

for May 2014. The Washington Agreement State Program received an extension of 1 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 team during the review. 

I also wish to acknowledge your continued support for the Agreement State program. I look 

forward to our agencies continuing to work cooperatively in the future. 

 Sincerely, 

/RA by Catherine Haney for/ 

 Michael F. Weber 

 Deputy Executive Director for Materials, Waste, 

 Research, State, Tribal and Compliance Programs 

 Office of the Executive Director for Operations 

Enclosure: 

Washington Final IMPEP Report 

cc w/ encl: Maryanne Guichard 

 Assistant Secretary 

 Jared Thompson, AR 

 Organization of Agreement States 

 Liaison to the MRB 

DISTRIBUTION: 

See next page 

 ML13212A159 

OFC Region III: 

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

NAME AMcCraw 

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DWhite PHenderson BMcDermott/ 

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for 

BHolian MWeber 

DATE 07/31/13 07/31/13 08/01/13 08/05/13 08/05/13 08/0713 08/08/13 08/22/13 

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

SUBJECT: WASHINGTON FY2013 FINAL IMPEP REPORT 

DISTRIBUTION: (SP08) 

RidsEdoMailCenter 

JFoster, OEDO 

VCampbell, OEDO 

RidsFsmeOd 

MSatorius, FSME 

RidsOgcMailCenter 

ABoland, RIII 

RidsRgn4MailCenter 

AVegel, RIV 

RTorres, RIV 

RidsFsmeMssa 

RidsSecyCorrespondenceMailCenter Chairman Macfarlane 

KMorganButler, FSME Commissioner Svinicki 

RErickson, RIV/RSAO Commissioner Apostolakis 

FGaskins, RI Commissioner Magwood 

SPoy, FSME Commissioner Ostendorff 

MHeath, FSME SECY 

MAbbaszadeh, TX 

LHanson, RIV 

MBeardsley, FSME 

BTharakan, RIV 

DJansen, WA 

EFordham, WA 

JWeil, OCA (2 copies) 
Enclosure 

INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

REVIEW OF THE WASHINGTON AGREEMENT STATE PROGRAM 

May 6-10, 2013 

FINAL REPORT
EXECUTIVE SUMMARY 

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

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

during the period of May 6-10, 2013, by a review team composed of technical staff members 

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

Based on the results of this review, the review team recommended and the Management 

Review Board (MRB) agreed that Washington's performance be found satisfactory for all 

performance indicators reviewed. The review team made one recommendation regarding 

program performance by the State. The review team recommends that the State implement a 

process to ensure that radioactive material incidents involving sealed sources and devices 

registered by the State are periodically and independently assessed for generic issues and that 

any potential generic issues are communicated to licensees and fellow regulators in a timely 

manner. 

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

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

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

periodic meeting be held in one year in order to monitor the Office of Radiation Protection’s 

transition to a new director. The review team recommended the next IMPEP review be held in 

four years and not extended to five years in order to monitor the management changes. The 

MRB, however, directed that the next IMPEP review be held in five years and the need for a 

second periodic meeting would be determined after the periodic meeting in May 2014. 
Washington Final IMPEP Report Page 1 

1.0 INTRODUCTION 

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

review was conducted during the period of May 6-10, 2013, by a review team composed of 

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

Texas. Team members are identified in Appendix A. The review was conducted in accordance 

with the “Implementation of the Integrated Materials Performance Evaluation Program and 

Rescission of Final General Statement of Policy,” published in the Federal Register on October 

16, 1997, and NRC Management Directive 5.6, “Integrated Materials Performance Evaluation 

Program (IMPEP),” dated February 26, 2004. Preliminary results of the review, which covered 

the period of May 10, 2008, to May 10, 2013, were discussed with Washington managers on the 

last day of the review. 

A draft of this report was provided to Washington for factual comment on June 10, 2013. The 

State responded by letter dated July 10, 2013. A copy of the State’s response is included as an 

Attachment to this report. A Management Review Board (MRB) met on July 23, 2013, to 

consider the proposed final report. The MRB found the Washington Agreement State Program 

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

The Washington Agreement State program is administered by the Office of Radiation Protection 

(the Office) in the Division of Environmental Public Health (the Division). The Division is part of 

the Department of Health (the Department). Organization charts for the Department, the 

Division, and the Office are included in Appendix B. 

At the time of the review, the Washington Agreement State Program regulated 390 specific 

licenses authorizing possession and use of radioactive materials. The review focused on the 

radioactive materials program as it is carried out under the Section 274b. (of the Atomic Energy 

Act of 1954, as amended) Agreement between the NRC and the State of Washington. 

In preparation for the review, a questionnaire addressing the common and applicable noncommon performance indicators was sent to the Office on January 24, 2013. The Office 

provided its response to the questionnaire on April 18, 2013. A copy of the questionnaire 

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

(ADAMS) using the Accession Number ML13112A246. 

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

the Office’s response to the questionnaire, (2) review of applicable Washington statutes and 

regulations, (3) analysis of quantitative information from the Office’s database, (4) technical 

review of selected regulatory actions, (5) field accompaniments of seven inspectors, and 

(6) interviews with staff and managers. The review team evaluated the information gathered 

against the established criteria for each common and the applicable non-common performance 

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

performance. 

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

during previous reviews. Results of the current review of the common performance indicators 

are presented in Section 3.0. Section 4.0 details the results of the review of the applicable 

non-common performance indicators, and Section 5.0 summarizes the review team’s findings. 
Washington Final IMPEP Report Page 2 

2.0 STATUS OF ITEMS IDENTIFIED IN PREVIOUS REVIEWS 

During the 2008 IMPEP review, which concluded on May 9, 2008, the review team made no 

recommendations regarding the Washington Agreement State Program’s performance 

3.0 COMMON PERFORMANCE INDICATORS 

Five common performance indicators are used to review NRC Regional and Agreement State 

radioactive materials programs. These indicators are (1) Technical Staffing and Training, 

(2) Status of Materials Inspection Program, (3) Technical Quality of Inspections, (4) Technical 

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

3.1 Technical Staffing and Training

Issues central to the evaluation of this indicator include the Office’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 Office’s questionnaire response relative to this 

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

and considered any possible workload backlogs. 

The Office is managed by the Office Director and two Deputy Directors. The Office is 

composed of six sections, each reporting to one of the two Deputy Directors. One Deputy 

Director is located in the Olympia Office and is responsible for the operations of the X-Ray 

Section and the Radiological Emergency Preparedness Section. This Deputy Director also 

has oversight responsibility for support staff that is shared among the Sections. The other 

Deputy Director is stationed in the Richland Office and is responsible for the operations of four 

sections: the Radioactive Air Emissions Section, the Environmental Sciences Section, the 

Radioactive Materials Section (the Materials Section), and the Waste Management Section 

(the Waste Section). 

During the review period, the Office experienced a high degree of turnover at the supervisory 

positions. The Office Director at the previous IMPEP review retired in November 2010. The 

position was filled by one of the previous Deputy Directors through June 2012. That vacancy 

was filled by an individual outside the Office through December 2012. The resulting vacancy 

was unfilled until May 16, 2013, when the current Office Director reported for duty. During the 

vacancy, both Deputy Directors filled in as the Acting Office Director. In addition to the Office 

Director position, the Office experienced turnover at the Materials Section Supervisor position 

during the review period. The Materials Section Supervisor at the previous IMPEP review 

retired in April 2010. That position remained vacant until July 2010, when the now 

Environmental Sciences Section Supervisor double-filled both positions. The individual left 

employment with the State in March 2011, and the position was vacant again until April 2011 

when the Industrial Program Manager within the Materials Section double-filled both positions. 

That individual later permanently accepted the Materials Section Supervisor position in June 

2011 and vacated the Industrial Program Manager position. The vacated Industrial Program 

Manager position was then filled by a Health Physicist from within the Materials Section in 

November 2011. The review team believes that the high degree of turnover at the supervisory 

positions resulted in a few minor oversights, such as event reporting and generic issue 

assessment, which are noted later in the report. 
Washington Final IMPEP Report Page 3 

The Agreement State program is primarily administered by the Materials Section and the 

Waste Section, with the other sections providing various degrees of support. Staffing and 

training for the Materials Section will be covered in this section of the report, and staffing and 

training for the Waste Section will be covered in Sections 4.3.1 and 4.4.1 of the report. 

At the time of the review, there were eight technical staff members with various degrees of 

involvement in the radioactive materials program. At the time of the review, one technical 

position was vacant. This position was vacated just prior to the onsite portion of the IMPEP 

review. The review team determined that Materials Section’s technical staffing levels were 

adequate for the Materials Section’s current workload. 

The Materials Section has a documented training plan for technical staff that is consistent with 

the requirements in the NRC/Organization of Agreement States Training Working Group Report 

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

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

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

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

and noted that Agency management supports training opportunities. 

During the review of inspection and licensing casework, the review team noted that several 

inspection records and licensing actions were signed by technically unqualified individuals. In 

all cases, the individual signing the action was going through the qualification process, and a 

second qualified individual was present during inspections or conducted a quality assurance 

review on licensing actions. The review team raised a concern to the Materials Section 

Supervisor regarding the appearance of an unqualified individual independently conducting 

regulatory actions. The Materials Section Supervisor stated that this was an existing practice 

used to establish the basis for an individual’s qualifications, but agreed that this practice could 

create the appearance of a technically unqualified individual independently conducting 

inspections or reviewing licensing actions. The Materials Section Supervisor committed to 

having the second qualified individual co-sign the inspection record or licensing action to 

provide proof that all regulatory actions are completed under the supervision of a technically 

qualified inspector or license reviewer, as appropriate. 

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

that Washington’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 Office’s questionnaire response relative to this indicator, data gathered from the Office’s 

database, examination of completed inspection casework, and interviews with management and 

staff. 

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

material licenses are at least as frequent or in most cases more frequent as those license types 
Washington Final IMPEP Report Page 4 

listed in IMC 2800, “Materials Inspection Program.” With the exception of industrial radiography 

licensees, which the Materials Section inspects at the same annual frequency as the NRC, the 

Materials Section inspects all of its licenses one year sooner than prescribed by IMC 2800. For 

example, the Materials Section inspects portable gauge licensees at a 4-year frequency, 

whereas, IMC 2800 prescribes a 5-year inspection frequency. This practice helps ensure that 

few, if any, of the Materials Section’s inspections are performed overdue per IMC 2800. 

The Materials Section conducted approximately 435 Priority 1, 2, and 3 inspections during the 

review period. Only one of these inspections was conducted overdue by more than 25 percent 

of the inspection frequency prescribed in IMC 2800. The overdue inspection was an oversight 

resulting from management transitions within the Office. In addition, the Program performed 59 

initial inspections during the review period, of which none were conducted overdue. Overall, the 

review team calculated that the Materials Section performed less than one percent of its high 

priority inspections overdue during the review period. 

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

licensees. The review team noted that the vast majority of findings are communicated to the 

licensee at the time of inspection on an “Inspection Findings and Licensee Acknowledgement” 

form. The Materials Section dispatches findings from inspections resulting in larger numbers of 

violations and inspections of broad scope licenses from the office. For those inspection findings 

issued from the office, the review team randomly sampled 52 inspection reports and determined 

that six of the inspection findings were communicated to the licensees beyond the Materials 

Section’s goal of 30 days after the inspection was completed. Each of those involved broad 

scope license inspections. The Materials Section self-identified the issue prior to the IMPEP 

review and changed its process for inspecting broad scope licenses to include built-in time to 

document its inspection findings to ensure a more timely dispatch of the findings to the licensee. 

This change has shortened the time for communicating inspection findings to broad scope 

licensees to less than 30 days. 

During the review period, the Program also granted 143 reciprocity permits for candidate 

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

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

reciprocity in each of the four years covered by the review period. 

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

that Washington’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 inspection reports, enforcement documentation, inspection field 

notes, and interviewed the responsible inspectors for 27 radioactive materials inspections 

conducted during the review period. The casework examined included a cross-section of 

inspections conducted by eight current inspectors and one former inspector. The casework 

covered a wide variety of inspection types including initial and followup security inspections, 

portable gauges, industrial radiography, medical, well-logging, academic, broadscope, 

veterinarian nuclear medicine, positron emission tomography, service providers, and gamma 
Washington Final IMPEP Report Page 5 

stereotactic radiosurgery (gamma knife). Appendix C lists the inspection casework files 

reviewed, as well as the results of the inspector accompaniments. 

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

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

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

support that licensees’ performances with respect to health, safety, and security were 

acceptable. Inspection report documentation supported violations, recommendations made to 

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

The Material Section’s inspection procedures were consistent with the inspection guidance 

found in IMC 2800. At the conclusion of each inspection, the inspectors have the option to send 

inspection findings from the office or to use a form similar to the NRC’s Form 591 that can be 

left with the licensee at the conclusion of the inspection. The Materials Section uses this form to 

document both clear inspections and inspections identifying infractions, deficiencies, or 

recommendations. The inspector can require a written response from the licensee describing 

corrective actions to address any infractions, deficiencies, or recommendations. Inspectors can 

also use this form to document investigations, field site surveys, and close-out surveys. 

Violations are considered the most severe type of finding and can only be dispatched from the 

office after management review and approval. 

The Materials Section performed quality assurance peer reviews on at least 10 percent of all 

inspection documentation. All inspection documentation is entered into the Office’s electronic 

filing system, which is accessible to all staff members. 

The Materials Section performed staff accompaniments annually. The Materials Section 

Supervisor accompanied each Health Physicist. He accompanied each Program Manager 

every other year. In the interim years, Program Managers performed peer accompaniments of 

each other. The Materials Section used this system to afford the Program Managers the 

benefits of accompaniments by senior staff members and accompaniments by the Materials 

Section supervisor. 

The review team determined that documents involving Increased Controls inspections were 

protected, segregated from the electronic file storage system, and maintained in a locked file 

cabinet with controlled access. The Materials Section maintained its Increased Controls files in 

visually distinct file folders so staff can easily identify security-related information. The review 

team determined that the documents reviewed were adequately marked as sensitive information 

to be withheld from public disclosure. 

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

calibrated survey instruments to support the inspection program, and to respond to radioactive 

materials incidents. Instruments used to support the materials inspection program are sent to 

the University of Washington Calibration Laboratory or the manufacturer for calibration. The 

Office receives laboratory and sample analysis support from the State Laboratory. The State 

laboratory is a licensee of the Office and performs sample analysis for multiple programs within 

the department. The laboratory has a wide variety of analytical equipment capable of detailed 

radioisotopic analysis. The equipment includes various scintillation and gamma counters, and 

high purity germanium counters. 
Washington Final IMPEP Report Page 6 

An IMPEP team member accompanied five of the Materials Section’s inspectors during the 

week of April 1, 2013. The inspectors were accompanied during inspections of two medical 

facilities using high dose-rate remote afterloaders, a medical facility with a gamma knife unit 

for possession only, a radiography licensee, and a portable gauge licensee. 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 evaluations of the licensees’ radiation safety programs. 

The inspectors conducted interviews with appropriate personnel, identified risk-significant 

activities, observed licensed operations when available, conducted confirmatory 

measurements, and used good health physics practices. The inspections were adequate to 

assess radiological health, safety, and security at the licensed facilities. 

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

that Washington’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 

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

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

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

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

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

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

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

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

completed during the review period. Licensing actions selected for evaluation included 3 new 

licenses, 10 renewal applications, 2 terminations, and 4 amendments. Files reviewed included 

a cross-section of license types, including: industrial radiography, research laboratories 

(including universities), medical broadscope, gauges, production using an accelerator, 

manufacturing and distribution, and gamma knife. The casework sample represented work from 

nine current and former license reviewers. A list of the licensing casework evaluated is provided 

in Appendix D. 

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

and of high quality with health, safety, and security issues properly addressed. License tiedown conditions were stated clearly and were supported by information contained in the file. 

Deficiency emails and letters clearly stated regulatory positions and were used at the proper 

time. Terminated licensing actions were well documented, showing appropriate transfer and 

survey records. License reviewers use standard checklists and/or NRC NUREG-1556 series 

guidance documents, policies, and standard license conditions specific to the type of licensing 

actions to ensure consistency in licenses. 

The license reviewers in the Materials Section have signature authority to sign their own 

licenses. Every licensing action has a secondary quality assurance (QA) review by another 
Washington Final IMPEP Report Page 7 

experienced reviewer. Corrections are made, as needed, and the licensing action is issued. 

The Materials Section Supervisor reviews every tenth licensing action for technical quality and 

accuracy. 

The Materials Section performed pre-licensing checks on all new applicants. The Materials 

Section has a policy of hand delivering all new licenses. Each applicant is subject to an onsite 

evaluation of their radiation safety and security programs prior to license receipt. This practice 

ensures that applicants have adequate radiation safety and security programs in place prior to 

the licensees’ taking possession of radioactive material. This also serves as the pre-licensing 

visit. 

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

Controls and Fingerprinting Orders. The review team noted that the Materials Section uses 

legally binding license conditions that meet the criteria for implementing the Increased Controls 

Orders, including fingerprinting, as appropriate. The review team analyzed the Materials 

Section’s methodology for identifying those licenses and found the rationale was thorough and 

accurate. The review team confirmed that license reviewers evaluated new license applications 

and license amendments using the same criteria. 

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

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

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

sensitive information related to the Increased Controls. Files that contained sensitive 

information were further secured in locked file cabinets. 

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

that Washington’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 Materials Section’s actions in responding to incidents and 

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

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

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

casework for 28 of 393 reported radioactive materials incidents. The casework reviewed 

included nine incidents reported by the NRC or other Agreement States to evaluate 

Washington’s responses to reports of events involving sealed sources and devices registered 

by the State, as further discussed in Section 4.2.3 of this report. A complete listing of the 

casework examined can be found in Appendix E. The review team also evaluated the Materials 

Section’s response to the nine allegations involving radioactive materials. The NRC referred 

eight of these allegations to the State during the review period. The review team evaluated the 

Materials Section’s response to all eight NRC-referred allegations. 

When notified of an incident or an allegation, the Materials Section Supervisor and staff discuss 

the initial response and the need for an on-site investigation. The Materials Section maintains a 

database for tracking the status of all incidents and allegations. If the incident meets the 

reportability thresholds, as established in the NRC’s Office of Federal and State Materials and 
Washington Final IMPEP Report Page 8 

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

the Materials Section notifies the NRC Headquarters Operation Center within the required 

timeframe (except in the cases described below). If the investigation is complex and extends 

over a period of time, NMED is appropriately updated, using the established template. 

The review team noted that there were five incidents during the review period involving lost 

tritium exit signs. The Materials Section did not report these events to the NRC Headquarters 

Operations Center, as dictated by SA-300. The review team discussed the reportability of lost 

tritium exit signs and the requirements of reporting under SA-300 with the Materials Section. 

The Materials Section stated that not reporting the lost tritium exit signs was an oversight and 

indicated that they would institute a policy to report future incidents of lost tritium exit signs to 

the NRC Headquarters Operations Center and NMED. The review team believes that the 

oversight resulted from the management turnover that occurred during the review period. A 

review of other types of incidents revealed that the Materials Section was properly reporting 

events to the NRC Headquarter Operations Center. The Materials Section indicated that the 

five incidents would be submitted for inclusion in NMED in the near future. 

The incidents selected for review included both medical and industrial events involving lost or 

stolen radioactive material, overexposures, damaged equipment, contamination events, a 

release of radioactive material, and equipment failures. The review team determined that the 

Materials Section responses to incidents were thorough, complete, and comprehensive. Initial 

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

health and safety significance. The review team noted that at the conclusion of investigations, 

inspectors generated narrative reports that thoroughly documented the investigations. Records 

were stored in the Office’s electronic system and were marked appropriately. 

In evaluating the effectiveness of the Materials Section’s response to allegations, the review 

team evaluated the casework for nine allegations. The review team concluded that the 

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

raised. The review team noted that the Materials Section thoroughly documented the 

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

The Materials Section notified the allegers of the conclusion of its investigation. The review 

team determined that the Materials Section adequately protected an alleger’s identity. 

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

that Washington’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) Low-Level Radioactive Waste Disposal Program, and (4) Uranium Recovery Program. 

NRC’s Agreement with Washington includes all of the non-common performance indicators. 
Washington Final IMPEP Report Page 9 

4.1 Compatibility Requirements

4.1.1 Legislation

Washington became an Agreement State on December 31, 1966. The Department is 

designated as the States radiation control agency and implements the radiation control 

program. The effective statutory authority for control of radioactive materials is contained in 

RCW 70.98, “Nuclear Energy and Radiation,” and RCW 70.121, “Mill Tailings, Licensing and 

Perpetual Care.” The program also is affected by RCW 70.94, “Washington Clean Air Act.” 

During the review period, the Washington legislature passed two bills affecting the radiation 

control program. One bill, passed in 2011, gave the Department authority to increase its 

radioactive waste site surveillance fee to the actual costs of conducting business. The 

Department adopted the fee increase on August 1, 2012. The other bill, passed in 2012, 

transferred authority for the low-level radioactive waste site use permit program from the 

Department of Ecology to the Department. With this transfer, the Department will become the 

sole agency responsible for the review of permit applications and issuance of site use permits. 

The Department anticipated adopting this new authority in July 2013. 

4.1.2 Program Elements Required for Compatibility 

Washington’s regulations for control of radiation are found in the Washington Administrative 

Code and apply to all radioactive materials and devices designed to produce radiation. 

Washington’s radiation regulations are not subject to any “sunset” laws. 

The review team examined the State’s administrative rulemaking process and found that the 

process takes approximately 9 to 12 months from the developmental stage to the final adoption 

by the Secretary of Health and filing with the Code Reviser’s Office, after which the rules 

become effective in 31 days. Washington can adopt the NRC amendments in a shortened time 

frame as “Exception” rules. An Exception rule is allowed when the program adopts a Federal 

rule without material change. This shortened process relies on the Federal rulemaking work 

which provides equivalent documentation to the State’s required initial Reasoning for the 

Rulemaking, Economic Impact Analysis, Small Business Economic Impact Statements, and 

Legislatively Significant Analysis (cost benefit analysis). 

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

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

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

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

lieu of regulations until compatible regulations become effective. 

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

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

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

from the State Regulation Status Sheet that FSME maintains. 

During the review period, Washington submitted seven final regulation amendments and four 

proposed regulations amendments to the NRC for a compatibility review. Current NRC policy 
Washington Final IMPEP Report Page 10 

requires that Agreement States adopt certain equivalent regulations or legally binding 

requirements no later than three years after the effective date of NRC’s regulations. Most of the 

regulation amendments were submitted for review and adopted within the required timeframe. 

There were a few exceptions where the State coupled regulation amendments to more 

efficiently process the amendments through the State’s adoption process. There were no 

compatibility issues resulting from the few regulation amendments being overdue. 

At the time of the review, there were no overdue amendments. A complete list of upcoming 

regulation amendments that will need to be addressed can be found on the NRC website at the 

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

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

that Washington’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 Materials 

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

These subelements were (1) Technical Staffing and Training; (2) Technical Quality of the 

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

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

information contained in the Office’s response to the IMPEP questionnaire for this indicator. 

The Materials Section conducted one new SS&D evaluation and issued two amendments to 

existing registrations since the last review. The review team evaluated all three of the SS&D 

actions processed during the review period and their supporting documents. The review team 

noted the staff’s use of guidance documents and procedures, interviewed staff members 

involved in the SS&D evaluations, and verified the use of regulations and inspections to enforce 

commitments made in the applications. 

4.2.1 Technical Staffing and Training

The Materials Section has five reviewers who are qualified to perform safety evaluations of 

SS&D applications. All reviewers have been qualified for a number of years. No new reviewers 

were qualified during the review period. All have degrees in a physical science or engineering 

and have attended the NRC’s SS&D Workshop. The review team interviewed staff members 

involved in the reviews and determined that they were familiar with the procedures used in the 

evaluation of a device/source and had access to applicable reference documents. 

4.2.2 Technical Quality of the Product Evaluation Program

The review team evaluated the three SS&D actions issued during the review period. The first 

action was an amendment to a registration certificate for a moisture gauge, and the other two 

were a new registration certificate and an amendment for low dose-rate manual brachytherapy 

seeds. A list of SS&D casework examined can be found in Appendix F. 
Washington Final IMPEP Report Page 11 

Analysis of the casework and interviews with staff members confirmed that the Materials 

Section follows the recommended guidance from NRC’s SS&D Workshop and NUREG-1556, 

Volume 3, Revision 1, “Consolidated Guidance About Materials Licenses – Applications for 

Sealed Source and Device Evaluation and Registration.” The review team confirmed that all 

applicable and pertinent American National Standards Institute standards, NUREG-1556 Series 

guides, NRC Regulatory Guides, and applicable references were available and used 

appropriately in performing the SS&D reviews. 

Registration certificates clearly summarized the product evaluations to provide license reviewers 

with adequate information to license the possession and use of the products. Deficiency letters 

clearly stated regulatory positions and all health and safety issues were addressed. The review 

team determined that the product evaluations were thorough, complete, consistent, of 

acceptable technical quality, and adequately addressed the integrity of the products during use 

and under accident conditions. 

4.2.3 Evaluation of Defects and Incidents Regarding SS&Ds

Ten incidents related to SS&D defects involving the same source registered by the State of 

Washington were reported during the review period. The source involved was used in 

brachytherapy applications and the incidents often included damage during routine procedures. 

A listing of the incidents reviewed by the team can be found in Appendix E. 

The review team interviewed Materials Section managers and staff to determine the State’s 

process for evaluating the root causes of radioactive materials incidents involving sealed 

sources and devices registered by the State and to identify potential generic issues. The 

managers and staff indicated that the Materials Section does not have a formal process to 

evaluate incidents for generic defects. Instead, the Materials Section would rely on the 

manufacturer or distributor of the sources or devices to notify the State of any generic issues. 

The review team discussed the importance of conducting an independent assessment of 

incidents for generic issues due to the national implications of the sealed sources or devices 

being distributed across the country. With its SS&D evaluation authority, the State has a 

responsibility to notify its licensees and co-regulators of potential generic issues with sealed 

sources and devices issued by the State. The review team recommends that the State 

implement a process to ensure that radioactive material incidents involving sealed sources and 

devices registered by the State are periodically and independently assessed by the State for 

generic issues and that any potential generic issues are communicated to licensees and fellow 

regulators in a timely manner. 

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

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

Evaluation Program, be found satisfactory. 

4.3 Low-Level Radioactive Waste (LLRW) Disposal Program

In reviewing this indicator, the review team used five subelements to evaluate the Waste 

Section’s performance regarding the LLRW disposal program. These subelements were 

(1) Technical Staffing and Training, (2) Status of Low-Level Radioactive Waste Disposal 
Washington Final IMPEP Report Page 12 

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

Actions, and (5) Technical Quality of Incident and Allegation Activities. 

The U.S. Ecology Low-Level Radioactive Waste Disposal Facility (LLRWDF) is located in 

north-central Benton County, about 20 miles northwest of the city of Richland. The facility is 

situated within the U.S. Department of Energy (DOE) Hanford Site on 100 acres of land. DOE 

leases the site to the State of Washington, and the State subleases to U.S. Ecology. The 

LLRWDF is entirely within the Hanford separations area, which covers approximately 82 square 

miles in the center of the Hanford Site. The U.S. Ecology facility is located within the Hanford 

200 Areas, which contain irradiated uranium fuel processing facilities, plutonium separation 

facilities and the major radioactive waste storage and disposal facilities. The LLRWDF has 

been in operation since 1965 and has been continuously operated by U.S. Ecology, Inc. (U.S. 

Ecology or processors). The Waste Section licenses U.S. Ecology, Inc., to receive, handle, 

process, store, and dispose of LLRW at the Hanford site. 

The Waste Section issues two licenses to Perma-Fix to possess and process radioactive 

material. The processing facility has been in operation since the early 1990s; however, the 

facility has been Perma-Fix since 2007. The Perma-Fix Northwest Richland (PFNW) facility is 

located on 35 acres adjacent to the Hanford Site. This facility manages and treats both 

low-level and mixed low-level radioactive wastes. Perma-Fix has received waste from the 

Federal Government, reactor operators, medical facilities, and other waste brokers and 

processors. The main purpose of the facility is volume reduction and stabilization of radioactive 

waste material. 

Although not an official part of the Washington Agreement State Program, the review team 

noted that the Washington Department of Ecology (Ecology) does have a role in the regulation 

of the Hanford Site. For instance, Ecology has decision-making input on administrative and 

technical decisions, such as the design and construction of a permanent cover for closed 

disposal trenches. Ecology also holds the long-term lease with the Federal Government and is 

the responsible agency for regulation of non-radioactive, hazardous constituents in disposed 

waste. Because of this authority, the review team conducted interviews with Ecology staff as 

part of this IMPEP review. The review team and Ecology staff discussed Ecology’s investigation 

of potential hazardous substances beneath the mixed waste cells, the projected timelines and 

the expected conclusions. Ecology staff stated they expect to conclude the investigation in 

December 2013. 

4.3.1 Technical Staffing and Training

The Waste Section currently has eight full-time and part-time technical, managerial, and 

administrative staff members devoted to the LLRW program. The LLRW program is also 

supported by the Environmental Sciences Section, the Materials Section, and the Air Emissions 

Section. The staff that currently supports the LLRW program includes the Waste Section 

Supervisor, an administrative assistant, and staff members with diversified backgrounds in 

health physics, engineering, and earth sciences. During the review period, the staff was 

relatively stable; however, in February 2013, the Waste Section lost its most experienced 

inspector to a licensee. The inspector was replaced with an experienced team member and the 

Waste Section is training a new hire to eventually be another qualified inspector. The review 
Washington Final IMPEP Report Page 13 

team determined that, at the time of the review, the Waste Section’s staffing level was adequate 

to maintain the quality and performance of the LLRW program. 

The Waste Section has a documented training and qualification program for staff members to 

perform licensing, inspection, and investigations of LLRW activities. The Waste Section has an 

established procedure for staff training consistent with the NRC/OAS Training Working Group 

Recommendations and IMC 1246. 

The review team determined that Waste Section staff members completed the required training 

and recommended training courses in accordance with Office requirements and consistent with 

IMC 1246. The Waste Section Supervisor maintains a training file on every staff member and 

maintains a file that tracks the progress of each employee and provides a benchmark for 

required training. The Waste Section Supervisor verifies each team member takes the required 

training courses as well as the necessary inspection and licensing training. Based on interviews 

with the technical and administrative staff and an examination of staff qualifications, duties, and 

functions, the review team concluded that the Waste Section staff was highly qualified, with 

sufficient training, to carry out their regulatory duties. 

4.3.2 Status of Low-Level Radioactive Waste Disposal Inspection

The disposal site is inspected annually, consistent with IMC 2800. Annual inspections are 

completed over the course of the year using partial inspections, with each partial inspection 

focusing on different areas. In addition to the annual inspections, the Waste Section performs 

monthly inspections of the site and confirms licensee inspections in accordance with the 

requirements of the facility license. The review team confirmed the frequency of inspections 

through an analysis of inspection report files and interviews with the inspectors. The Waste 

Section Supervisor and inspection staff use a spreadsheet to track the status of inspections. 

This spreadsheet lists the portion of the annual inspection, the date of last inspection, and the 

inspector assigned to each portion of the annual inspection. The review team reviewed the 

spreadsheets and the annual inspection reports from 2008 through 2013. 

The review team determined that inspection findings are communicated to the licensee in a 

timely manner. The Waste Section issues inspection findings to the licensee which is typically 

issued on site upon completion of an inspection or included in a notice of correction letter issued 

within 30 days of the inspection. 

4.3.3 Technical Quality of Inspections

The Waste Section’s inspection procedures detail the inspection preparation requirements, 

inspection reporting requirements, frequency of inspections, and a checklist of licensing 

requirements. The procedures also include appropriate forms and example letters for 

documenting findings. A list of the LLRW inspection casework reviewed can be found in 

Appendix C. 

The review team determined that the Waste Section’s monthly and annual inspections were 

thorough, technically accurate, complete, consistent, and of high quality with sufficient 

documentation to ensure that the licensee’s performance with respect to protecting health and 

safety was acceptable. A review of the completed inspection reports revealed that inspection 
Washington Final IMPEP Report Page 14 

records are reviewed promptly by the Waste Section Supervisor. The review team found that 

followup inspections addressed previously identified open items and past violations. An annual 

summary is provided in each file identifying open items for the year and whether or not they 

were closed. The files contain the inspection checklist, field notes, notices to the licensee, and 

some digital photographs of the site. The on-site files include information on the waste 

generator, weekly summary of shipments, fence-line surveys performed by the inspectors, and 

package (waste container) inspections. The review team also determined that supervisory 

accompaniments of each inspector were completed annually and documented. 

On April 17-18, 2013, a review team member accompanied a Waste Section inspector during 

inspections of US Ecology and Perma-Fix. The inspector conducted entrance meetings with the 

licensees, explaining the purpose, the duration and the expectations for the inspection. The 

inspector was well prepared and thorough in her review of the aspects of the licensees radiation 

safety programs including site security, external dosimetry, radiological surveys, vehicle 

surveys, and postings. The inspector conducted multiple interviews with licensee safety staff 

and supervisors. The inspector covered the scope of the inspections, discussed the status of 

previously identified items of noncompliance, and clearly articulated any current items of 

noncompliance. The inspector conducted exit interviews with management to explain any 

findings. During the accompaniments, the inspector demonstrated appropriate 

performance-based inspection techniques and knowledge of the regulations. The inspections 

were adequate to assess radiological health and safety at the licensed facilities. Appendix C 

contains a list of the inspection accompaniments performed for this indicator. 

4.3.4 Technical Quality of Licensing Actions

The review team evaluated the technical quality of eight of the Waste Section’s licensing actions 

issued since the last IMPEP review. The review team also reviewed portions of the 2004 

Environmental Impact Statement (EIS). During the review period the licensing actions included 

renewals and technical licensing amendments. These amendments involved revisions to the 

standards manual, changes in monitoring frequency, and management changes. A list of the 

casework reviewed can be found in Appendix D. 

The Waste Section’s licensing program for LLRW disposal included the completion of an EIS 

related to key decisions at the disposal facility; license renewal; implementation of new security 

requirements; investigation of ground contaminants, pursuant to the State Model Toxics Control 

Act; and expansion of the definition of byproduct material, pursuant to the Energy Policy Act of 

2005. The Waste Section and US Ecology jointly prepared the EIS. The EIS provided a 

summary of the bases for regulatory decisions regarding relicensing, allowable amounts of 

diffuse waste, and a permanent disposal unit cover. During this IMPEP the review team also 

reviewed portions of the final EIS, and interviewed most of the staff involved in the preparation 

of these documents. The review team found that these documents were thorough, complete, 

consistent, and of acceptable technical quality. 

The review team found that the licensing actions in general were thorough, complete, 

consistent, and of high quality, with health, safety, and security issues properly addressed. 
Washington Final IMPEP Report Page 15 

4.3.5 Technical Quality of Incident and Allegation Activities

The review team found that the Waste Section has procedures in place for handling incidents 

and allegations. The procedures for handling incidents include information on what constitutes 

an incident, appropriate documentation of an incident, reference to the NRC’s abnormal 

occurrence criteria for Agreement States, and tracking of incidents by management. The 

procedures for handling allegations include information on protecting the identity of the alleger, 

documentation of the allegation, and tracking the allegation by management. 

During the review period, the Waste Section received five incidents and one allegation 

pertaining to the LLRW disposal program. A list of the incident files reviewed can be found in 

Appendix E. The review team evaluated the Waste Section’s response to each incident by 

verifying the correct procedures were followed, that timely notifications were made, and 

appropriate measures were taken to close the incidents. The review team also evaluated the 

Waste Section’s allegation handling and found it was done according to procedure. Each step 

in the procedure and allegation protocol was followed, documented, and appropriate level of 

management notified. 

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

that Washington’s performance with respect to the indicator LLRW Disposal Program, be found 

satisfactory. 

4.4 Uranium Recovery Program 

In reviewing this indicator, the review team used five subelements to evaluate the Waste 

Section’s performance regarding the uranium recovery program. These subelements were 

(1) Technical Staffing and Training, (2) Status of Uranium Recovery Inspection Program, 

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

(5) Technical Quality of Incident and Allegation Activities. 

At the time of the review, the Waste Section had one licensed conventional mill site: the Dawn 

Mining Company (Dawn). This site was placed in shutdown status and initiated reclamation and 

decommissioning activities in 2001. The process related buildings and structures were 

decommissioned and buried in 2003. The only activities at the site are related to surface 

reclamation and groundwater monitoring. 

4.4.1 Technical Staffing and Training 

The review team evaluated the Waste Section’s uranium recovery program staffing level, the 

technical qualifications of the staff, staff training, and staff turnover. The evaluation included 

general examination of the qualifications of the inspectors and licensing personnel, and 

interviews with uranium recovery program staff and management. At the time of the review, two 

full-time equivalents (FTE) were devoted to the uranium recovery program to perform 

inspections and licensing activities for the Dawn site. The Waste Section’s uranium recovery 

program has a wide range of technical expertise including: health physics, engineering, 

geohydrology, and geochemistry. The review team determined that the Waste Section’s staffing 

level is adequate to maintain the quality and performance of the uranium recovery program. 
Washington Final IMPEP Report Page 16 

Interviews with uranium recovery staff and reviews of training and qualification records revealed 

that the uranium recovery staff is experienced, technically competent, and has a good 

understanding of regulatory processes and requirements. The uranium recovery staff has the 

health physics, engineering, and hydrology expertise necessary to adequately regulate the 

reclamation activities at the Dawn site. Documentation of training and qualification of the 

uranium recovery staff, including summaries of education and experience, was in the Waste 

Section’s personnel files and was up to date. 

4.4.2 Status of Uranium Recovery Inspection Program 

The review team evaluated the uranium recovery program inspection frequency, overdue 

inspections, and timely issuance of inspection reports and findings to the licensee. The review 

team’s evaluation is based on the Office’s response to the IMPEP questionnaire relative to the 

uranium recovery program, inspection casework files, and interviews with inspection staff and 

management. A list of the inspection casework reviewed can be found in Appendix C. 

The Waste Section performed 28 inspections at the Dawn site between July 2008 and April 

2013. This included 5 annual radiation safety inspections and 23 routine field inspections. The 

annual radiation safety inspections covered all aspects of the uranium recovery program 

including: site security, personnel monitoring, radiation protection program audit, training, 

radiological controls and surveys, operations, environmental monitoring, instrumentation, site 

posting, and respiratory protection, site tour, observation of operations, and personnel 

interviews. The routine inspections included observations of the reclamation activities at the 

Dawn site, including collection of groundwater samples for analysis. 

Based on the evaluation of inspection files, the review team determined that the Waste 

Section’s inspection frequency exceeded the requirements of 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. 

The review team determined that inspection reports were issued within 30 days of inspections. 

The Waste Section Supervisor promptly reviewed all inspection reports. Appropriate followup 

actions were conducted when items of an infraction, deficiency, or noncompliance were 

identified. Inspection casework files were easily retrieved and accessible. 

4.4.3 Technical Quality of Inspections

The review team examined inspection files, inspection reports, and enforcement actions. The 

review team noted that the Waste Section’s inspection program and procedures were consistent 

with NRC Inspection Procedure 87654, “Uranium Mill, In-Situ Leach Uranium Recovery, 11e.(2) 

Byproduct Material Disposal Site Decommissioning Inspection.” Inspectors typically and 

appropriately observed licensee operations and made independent measurements during 

inspections, as appropriate. Inspectors used relevant procedures with checklists, previous 

inspection reports, and other background information for implementing their inspections. Annual 

comprehensive inspections covered all appropriate functional areas. The review team found 

that the inspection reports provided appropriate depth of coverage, addressed license 

conditions and the regulations, and demonstrated that the inspectors pursued corrective actions 

for items of an infraction, deficiency, or noncompliance that were identified. 
Washington Final IMPEP Report Page 17 

Supervisor accompaniments of the lead/radiation safety inspector were performed annually. 

The accompaniment documentation contained comments on inspector’s performance and 

appeared to provide a sufficient evaluation for the inspector. The review team found that the 

Waste Section Supervisor routinely met with the uranium recovery inspectors to review 

inspection findings and to plan followup strategy regarding corrective actions. 

On April 16, 2013, a review team member accompanied the Waste Section’s lead inspector for 

the uranium program at the Dawn site. An engineer and a hydrochemist from the uranium 

recovery program joined the lead inspector at the Dawn site. The review team members 

evaluated the lead inspector’s performance. The inspection focused on the site general 

conditions, including reclamation progress, training evaluation of new personnel, follow up on 

items of concern from previous annual inspection, and environmental monitoring stations. The 

lead inspector was well prepared and conducted proper entrance and exit interviews with 

licensee management and safety staff. The lead inspector reviewed training records for the 

new personnel and conducted interviews with licensee’s staff during the course of the inspection 

to ascertain perspective on licensee commitment to safety and training. During the 

accompaniment, the lead inspector used instrumentation to perform independent 

measurements and demonstrated performance-based inspection techniques. A listing of the 

inspector accompaniment can be found in Appendix C. 

4.4.4 Technical Quality of Licensing Actions

The Waste Section utilized regulatory criteria, checklist, and applicable portions of NUREG1620, “Standard Review Plan for the Review of a Reclamation Plan for Mill Tailings Sites Under 

Title II of the Uranium Mill Tailings Radiation Control Act of 1978,” in performing licensing 

actions for the uranium recovery program. Licensing actions for the review period included one 

renewal and two amendments for the Dawn Site. The review team’s evaluation is based on the 

Office’s response to the IMPEP questionnaire relative to the uranium recovery program, 

licensing casework files, and interviews with staff and management. Appendix D lists the 

licensing files reviewed. 

The Dawn Site license has been in timely renewal since January 2012. At the time of the 

review, the licensing action for the renewal of Dawn site was pending. The licensee submitted 

the renewal application on December 30, 2011. The application was administratively completed 

on January 26, 2012. The Waste Section is in the final review stage of engineering and 

hydrologic reviews. Upon completion of the engineering and hydrologic reviews, there will be a 

notice to the public process. The Waste Section anticipates the renewal license will be issued 

by August 2013. 

The Waste Section completed two amendments related to the extension of disposal of sludge 

from the Midnite Mine Water Treatment Plant into the Tailing Disposal Area 4. The initial 

authorization for sludge disposal was granted to the licensee in 2001. The amendments were 

issued in 2009 and 2011. The review team concluded that these licensing actions were 

thorough and the license conditions were clear and well documented. The review team 

concluded that the Waste Section evaluation was of acceptable technical quality. 
Washington Final IMPEP Report Page 18 

4.4.5 Technical Quality of Incident and Allegation Activities

For the review period, the Waste Section did not receive reports of any incidents or allegations 

related to the uranium recovery program. The review team found that the Waste Section has 

appropriate procedures in place for handling incidents and allegations. 

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

that Washington’s performance with respect to the indicator, Uranium Recovery Program, be 

found satisfactory. 

5.0 SUMMARY 

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

all performance indicators reviewed. The review team made one recommendation regarding 

program performance by the State. Accordingly, the review team recommended, and the MRB 

agreed, that the Washington 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 that the next full IMPEP review take place in 

approximately four years, with a periodic meeting in one year in order to monitor the Office’s 

transition to a new director. The MRB, however, directed that the next IMPEP review be held in 

five years with a periodic meeting to be held in one year. The MRB further directed that the 

need for a second periodic meeting in the review period would be determined after the periodic 

meeting in May 2014. 

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

implementation by the State: 

The review team recommends that the State implement a process to ensure that radioactive 

material incidents involving sealed sources and devices registered by the State are 

periodically and independently assessed by the State for generic issues and that any 

potential generic issues are communicated to licensees and fellow regulators in a timely 

manner. 
LIST OF APPENDIXES 

Appendix A IMPEP Review Team Members 

Appendix B Washington 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

Aaron McCraw, Region III Team Leader 

 Technical Staffing and Training 

 Compatibility Requirements 

 Inspector Accompaniments 

Randy Erickson, Region IV Status of Materials Inspection Program 

 Technical Quality of Inspections 

Farrah Gaskins, Region I Technical Quality of Licensing 

 Actions 

Stephen Poy, FSME Technical Quality of Incident and 

 Allegation Activities 

 Sealed Source and Device 

 Evaluation Program 

Maurice Heath, FSME Low-Level Radioactive Waste 

 Disposal Program 

 Inspector Accompaniments 

Muhammadali Abbaszadeh, Texas Uranium Recovery Program 

 Inspector Accompaniments 

Latischa Hanson, Region IV assisted with the team’s review of Technical Quality of Inspections. 
APPENDIX B 

WASHINGTON ORGANIZATION CHARTS 

ADAMS ACCESSION NO.: ML13112A244 
 APPENDIX C 

INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Bradken Atlas License No.: WN-IR066-1 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 2/26/13 Inspector: VD 

File No.: 2 

Licensee: St. John Medical Center License No.: WN-M066-1 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 7/26/11 Inspector: VD 

File No.: 3 

Licensee: Deaconess Medical Center License No.: WN-M0237-1 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 10/27/10 Inspector: AG 

File No.: 4 

Licensee: Lower Columbia Nuclear Medicine & PET Imaging License No.: WN-M0209-1 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 3/27/09 Inspector: AG 

File No.: 5 

Licensee: Puget Sound Radiosurgery License No.: WN-M0268-1 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 12/22/11 Inspector: CD 

File No.: 6 

Licensee: Tri-Cities Cancer Center License No.: WN-M0204-1 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 10/8/09 Inspector: CD 

File No.: 7 

Licensee: Oregon Washington Laboratories License No.: WN-IR070-1 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 6/23/09 Inspector: JK 

File No.: 8 

Licensee: International Inspection License No.: WN-IR-066-1 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 5/29/12 Inspectors: JS, SM 
Washington Final IMPEP Report Page C.2 

Inspection Casework Reviews 

File No.: 9 

Licensee: Northwest Hospital Gamma Knife License No.: WN-M0201-01 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 10/5/10 Inspector: JS 

File No.: 10 

Licensee: Battelle Pacific Northwest National Laboratories License No.: WN-L027-1 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 10/21/09 Inspectors: JS, BH 

File No.: 11 

Licensee: Acuren Inspection License No.: WN-IR067-1 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 5/18/09 Inspector: PW 

File No.: 12 

Licensee: Northwest Hospital Gamma Knife License No.: WN-M0201-1 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 12/10/08 Inspectors: PW, CD 

File No.: 13 

Licensee: Spokane Washington Hospital Company License No.: WN-M005-1 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 7/17/09 Inspector: SM 

File No.: 14 

Licensee: Acuren Inspection License No.: WN-IR067-1 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Dates: 7/19-20/11 Inspector: VD 

File No.: 15 

Licensee: Skagit Valley Hospital License No.: WN-M0196-1 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Dates: 11/7/10 Inspector: VD 

File No.: 16 

Licensee: Team Industrial Services License No.: WN-IR073-1 

Inspection Type: Initial, Unannounced Priority: 1 

Inspection Date: 1/25/11 Inspector: BH 

File No.: 17 

Licensee: Spokane Industries License No.: WN-IR049-1 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 3/12/13 Inspector: BH 
Washington Final IMPEP Report Page C.3 

Inspection Casework Reviews 

File No.: 18 

Licensee: Providence Sacred Heart Medical Center License No.: WN-M031-1 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Dates: 2/14-15/12 Inspector: BH 

File No.: 19 

Licensee: Whitman County Public Works License No.: WN-I0328-1 

Inspection Type: Initial, Unannounced Priority: 4 

Inspection Date: 9/14/12 Inspector: JK 

File No.: 20 

Licensee: Mason General Hospital License No.: WN-M0214-1 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 1/10/13 Inspectors: JK, CD 

File No.: 21 

Licensee: Construction Testing Labs License No.: WN-L092-1 

Inspection Type: Routine, Unannounced Priority: 4 

Inspection Date: 4/1/13 Inspector: JK 

File No.: 22 

Licensee: Overlake Medical License No.: WN-M065-1 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 4/4/13 Inspector: JS 

File No.: 23 

Licensee: Mistras Group Inc. License No.: WN-IR011-1 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 4/5/13 Inspector: JK 

File No.: 24 

Licensee: Northwest Hospital & Medical Center License No.: WN-M004-1/M0201-1 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 4/2/13 Inspector: VD 

File No.: 25 

Licensee: Grays Harbor Community Hospital WN-License No.: WN-M091-1 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 4/2/13 Inspector: JK 

File No.: 26 

Licensee: Dade Moeller WN-License No.: WN-RECIP-197 

Inspection Type: Reciprocity, Unannounced Priority: 3 

Inspection Date: 7/24/08 Inspector: AG 
Washington Final IMPEP Report Page C.4 

Inspection Casework Reviews 

File No.: 27 

Licensee: Providence Everett Medical Center License No.: WN-M0135-1 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 4/3/13 Inspector: BH 

LOW LEVEL RADIOACTIVE WASTE INSPECTION CASEWORK 

File No.: 28 

Licensee: U.S. Ecology, Inc. License No.: WN-I019-2 

Inspection Type: Routine, Announced Priority: 1 

Inspection Dates: Various Inspectors: Various 

File No.: 29 

Licensee: Perma Fix NW License No.: WN-I0393-1 

Inspection Type: Routine, Announced Priority: 1 

Inspection Dates: Various Inspectors: Various 

URANIUM RECOVERY INSPECTION CASEWORK 

File No.: 30 

Licensee: Dawn Mining Company License No.: WN-1043-2 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 10/7/08 Inspectors: DS, ME, DT 

File No.: 31 

Licensee: Dawn Mining Company License No.: WN-1043-2 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 10/7/09 Inspectors: DS, ME, KS, SP 

File No.: 32 

Licensee: Dawn Mining Company License No.: WN-1043-2 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 10/20/10 Inspectors: DS, KS, SP 

File No.: 33 

Licensee: Dawn Mining Company License No.: WN-1043-2 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 11/2/11 Inspectors: DS, KS, JR, SP 

File No.: 34 

Licensee: Dawn Mining Company License No.: WN-1043-2 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 11/14/12 Inspectors: DS, SP, JR, DT 
Washington Final IMPEP Report Page C.5 

Inspection Casework Reviews 

INSPECTOR ACCOMPANIMENTS 

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

Accompaniment No.: 1 

Licensee: Construction Testing Laboratories, Inc. License No.: WN-L092-1 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 4/1/13 Inspector: JK 

Accompaniment No.: 2 

Licensee: Northwest Hospital Gamma Knife Center License No.: WN-M0201-1 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 4/2/13 Inspector: VD 

Accompaniment No.: 3 

Licensee: Northwest Hospital and Medical Center License No.: WN-M004-1 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 4/2/13 Inspector: VD 

Accompaniment No.: 4 

Licensee: Providence Everett Medical Center License No.: WN-M0135-1 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 4/3/13 Inspector: BH 

Accompaniment No.: 5 

Licensee: Overlake Hospital Medical Center License No.: WN-M065-1 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 4/4/13 Inspector: JS 

Accompaniment No.: 6 

Licensee: Mistras Group, Inc. License No.: WN-IR011-1 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 4/5/13 Inspector: JK 

LOW-LEVEL RADIOACTIVE WASTE INSPECTION ACCOMPANIMENTS 

. Accompaniment No.: 7 

Licensee: US Ecology, Inc. License No.: WN-I019-2 

Inspection Type: Routine, Announced Priority: 1 

Inspection Dates: 4/17-18/13 Inspector: KS 

Accompaniment No.: 8 

Licensee: Perma-Fix License No.: WN-I0393-1 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 4/18/13 Inspector: KS 
Washington Final IMPEP Report Page C.6 

Inspection Casework Reviews 

URANIUM RECOVERY INSPECTION ACCOMPANIMENT 

Accompaniment No.: 9 

Licensee: Dawn Mining Company License No.: WN-1043-2 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 4/16/13 Inspectors: DS, SP, JR 
APPENDIX D 

LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: IsoRay medical License No.: WN-L0213-1 

Type of Action: Renewal Amendment No.: 16 

Date Issued: 12/10/12 License Reviewer: JS 

File No.: 2 

Licensee: Swedish Medical Center License No: WN-M008-1 

Type of Action: Renewal Amendment No.: 73 

Date Issued: Pending License Reviewer: CD 

File No.: 3 

Licensee: Deaconess Medical Center License No.: WN-M0237-1 

Type of Action: Renewal Amendment No.: 11 

Date Issued: 5/1/12 License Reviewer: CD 

File No.: 4 

Licensee: Battelle Pacific Northwest Laboratories License No.: WN-L027-1 

Type of Action: Renewal Amendment No.: 25 

Date Issued: 11/30/11 License Reviewer: JS 

File No.: 5 

Licensee: Siemens Medical Solutions License No: WN-I030-1 

Type of Action: Renewal Amendment No.: 19 

Date Issued: 3/25/10 License Reviewer: VD 

File No.: 6 

Licensee: Cardinal Health 414 License No.: WN-NP008-1 

Type of Action: Renewal Amendment No.: 25 

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

File No.: 7 

Licensee: Conagra Foods Weston, Inc. License No.: WN-I082-1 

Type of Action: Renewal Amendment No.: 16 

Date Issued: 6/23/10 License Reviewer: SM 

File No.: 8 

Licensee: Pacific Testing and Inspection License No: WN-I0573-1 

Type of Action: Renewal Amendment No.: 3 

Date Issued: 6/27/12 License Reviewer: PW 
Washington Final IMPEP Report Page D.2 

Licensing Casework Reviews 

File No.: 9 

Licensee: Eastern Washington University License No.: WN-C025-1 

Type of Action: Renewal Amendment No.: 17 

Date Issued: 1/27/09 License Reviewer: JS 

File No.: 10 

Licensee: Western Fire and Safety License No.: WN-I0302-1 

Type of Action: Renewal Amendment No.: 8 

Date Issued: 10/23/12 License Reviewer: JK 

File No.: 11 

Licensee: Acuren Inspection License No: WN-IR067-1 

Type of Action: Amendment Amendment No.: 13 

Date Issued: 12/8/10 License Reviewer: CL 

File No.: 12 

Licensee: Fred Hutchinson Research Center License No.: WN-L042-1 

Type of Action: Amendment Amendment No.: 66 

Date Issued: 12/11/09 License Reviewer: JK 

File No.: 13 

Licensee: Washington State University License No.: WN-C003-1 

Type of Action: Amendment Amendment No.: 73 

Date Issued: 10/23/08 License Reviewer: AG 

File No.: 14 

Licensee: Gonzanga University License No: WN-C0012-1 

Type of Action: Amendment Amendment No.: 24 

Date Issued: 3/23/10 License Reviewer: VD 

File No.: 15 

Licensee: Anvil Corporation License No.: WN-IR031-1 

Type of Action: Termination Amendment No.: 45 

Date Issued: 9/17/10 License Reviewer: VD 

File No.: 16 

Licensee: Molecular Epidemiology License No.: WN-L0208-1 

Type of Action: Termination Amendment No.: 6 

Date Issued: 6/2/11 License Reviewer: AG 

File No.: 17 

Licensee: MA DE Atley License No: WN-I0598-1 

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

Date Issued: 6/2/11 License Reviewer: PW 
Washington Final IMPEP Report Page D.3 

Licensing Casework Reviews 

File No.: 18 

Licensee: Quality Inspection Services License No.: WN-IR074-1 

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

Date Issued: 11/19/12 License Reviewer: CL 

File No.: 19 

Licensee: Seattle Procure Management, LLC License No.: WN-M0312-1 

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

Date Issued: 6/12/12 License Reviewer: BH 

LOW LEVEL RADIOACTIVE WASTE LICENSE CASEWORK 

File No.: 20 

Licensee: Perma-Fix License No.: WN-I0393-1 

Type of Action: Amendment Amendment No.: 25 

Inspection Date: 4/10/09 License Reviewer: SM 

File No.: 21 

Licensee: Perma-Fix NW License No.: WN-I0393-1 

Type of Action: Amendment Amendment No.: 27 

Date Issued: 4/18/10 License Reviewer: SM 

File No.: 22 

Licensee: Perma-Fix NW License No.: WN-I0393-1 

Type of Action: Amendment Amendment No.: 31 

Date Issued: 8/30/12 License Reviewer: KS 

File No.: 23 

Licensee: US Ecology, Inc. License No.: WN-I019-2 

Type of Action: Amendment Amendment No.: 33 

Date Issued: 5/12/09 License Reviewer: SM 

File No.: 24 

Licensee: US Ecology, Inc. License No.: WN-I019-2 

Type of Action: Amendment Amendment No.: 34 

Date Issued: 10/23/09 License Reviewer: SM 

File No.: 25 

Licensee: US Ecology, Inc. License No.: WN-I019-2 

Type of Action: Amendment Amendment No.: 35 

Date Issued: 8/2/10 License Reviewer: SM 

File No.: 26 

Licensee: US Ecology, Inc. License No.: WN-I019-2 

Type of Action: Amendment Amendment No.: 36 

Date Issued: 11/21/11 License Reviewer: SM 
Washington Final IMPEP Report Page D.4 

Licensing Casework Reviews 

File No.: 27 

Licensee: US Ecology, Inc. License No.: WN-I019-2 

Type of Action: Amendment Amendment No.: 39 

Date Issued: 4/20/12 License Reviewer: KS 

URANIUM RECOVERY LICENSE CASEWORK 

File No.: 28 

Licensee: Dawn Mining Company License No.: WN-1043-2 

Type of Action: Amendment Amendment No.: 25 

Date Issued: 4/15/09 License Reviewers: DS, KS, JR 

File No.: 29 

Licensee: Dawn Mining Company License No.: WN-1043-2 

Type of Action: Amendment Amendment No.: 26 

Date Issued: 8/16/11 License Reviewers: DS, KS, JR 

File No.: 30 

Licensee: Dawn Mining Company License No.: WN-1043-2 

Type of Action: Renewal Amendment No.: Pending 

Date Issued: Pending License Reviewers: DS, KS, JR, SP 
APPENDIX E 

INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Krazan & Associates License No.: WN-10431 

Date of Incident: 6/17/08 NMED No.: 080356 

Investigation Date: 6/17/08 Type of Incident: Damaged Gauge 

 Type of Investigation: Site 

File No.: 2 

Licensee: Washington State University License No.: WN-C003 

Date of Incident: 6/24/08 NMED No.: 080374 

Investigation Date: 6/24/08 Type of Incident: Leaking Source 

 Type of Investigation: Site 

File No.: 3 

Licensee: N and P Partnership License No.: General 

Date of Incident: 8/22/08 NMED No.: N/A 

Investigation Date: 1/22/13 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Site 

Comment: This incident was not report to the NRC Headquarters Operations Center. The 

State indicated that this event would be submitted for inclusion in NMED in the near future. 

File No.: 4 

Licensee: Seattle Household Hazardous Waste License No.: General 

Date of Incident: 9/18/08 NMED No.: N/A 

Investigation Date: 1/24/13 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Site 

Comment: This incident was not report to the NRC Headquarters Operations Center. The 

State indicated that this event would be submitted for inclusion in NMED in the near future. 

File No.: 5 

Licensee: Northwest Inspection License No.: WN-IR065 

Date of Incident: 9/30/08 NMED No.: 080639 

Investigation Date: 9/30/08 Type of Incident: Equipment 

 Type of Investigation: Site 

File No.: 6 

Licensee: Cancer Care Northwest Pet Center License No.: WN-M0227 

Date of Incident: 4/14/09 NMED No.: 090466 

Investigation Date: 4/14/09 Type of Incident: Equipment 

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

Incident Casework Reviews 

File No.: 7 

Licensee: Georgia Pacific License No.: General 

Date of Incident: 4/16/09 NMED No.: N/A 

Investigation Date: 4/16/09 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Site 

Comment: This incident was not report to the NRC Headquarters Operations Center. The 

State indicated that this event would be submitted for inclusion in NMED in the near future. 

File No.: 8 

Licensee: Longview Fibre License No.: WN-R0205 

Date of Incident: 6/15/09 NMED No.: 090561 

Investigation Date: 6/15/09 Type of Incident: Equipment 

 Type of Investigation: Site 

File No.: 9 

Licensee: Cole and Associates License No.: WN-R0979 

Date of Incident: 6/15/09 NMED No.: 090632 

Investigation Date: 6/15/09 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Site 

File No.: 10 

Licensee: Alano Club License No.: General License 

Date of Incident: 11/24/09 NMED No.: N/A 

Investigation Date: 11/24/09 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Site 

Comment: This incident was not report to the NRC Headquarters Operations Center. The 

State indicated that this event would be submitted for inclusion in NMED in the near future. 

File No.: 11 

Licensee: Mistras Group License No.: WN-IR011 

Date of Incident: 12/15/09 NMED No.: 090886 

Investigation Date: 12/15/09 Type of Incident: Equipment 

 Type of Investigation: Site 

File No.: 12 

Licensee: Georgia Pacific License No.: WN-I0228-1 

Date of Incident: 12/30/09 NMED No.: 100005 

Investigation Date: 12/30/09 Type of Incident: Equipment 

 Type of Investigation: Site 

File No.: 13 

Licensee: Georgia Pacific License No.: WN-M0225 

Date of Incident: 1/26/09 NMED No.: 100196 

Investigation Date: 8/1/09 Type of Incident: Equipment 

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

Incident Casework Reviews 

File No.: 14 

Licensee: Freedom Marine Engineering License No.: General 

Date of Incident: 5/21/10 NMED No.: N/A 

Investigation Date: 1/23/13 Type of Incident: Lost/Stolen 

 Type of Investigation: Site 

Comment: This incident was not report to the NRC Headquarters Operations Center. The 

State indicated that this event would be submitted for inclusion in NMED in the near future. 

File No.: 15 

Licensee: Westport Shipyard License No.: General 

Date of Incident: 6/2/11 NMED No.: 110364 

Investigation Date: 7/10/11 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Site 

File No.: 16 

Licensee: Bruker AXS Handheld License No.: WN-I0282 

Date of Incident: 5/1/11 NMED No.: 120324 

Investigation Date: 5/23/11 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Site 

File No.: 17 

Licensee: Eastern Washington University License No.: General 

Date of Incident: 7/25/11 NMED No.: N/A 

Investigation Date: 9/27/11 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Site 

File No.: 18 

Licensee: Cancer Care Northwest Pet Center License No.: WN-M0227 

Date of Incident: 12/19/12 NMED No.: 130050 

Investigation Date: 12/19/12 Type of Incident: Medical Event 

 Type of Investigation: Site 

SEALED SOURCE AND DEVICE INCIDENT REVIEWS 

File No.: 19 

Licensee: Isoray License No.: WN-L0213 

Date of Incident: 2/19/09 NMED No.: 090376 

Investigation Date: 2/20/09 Type of Incident: Damaged/Leaking Source 

 Type of Investigation: Telephone 

File No.: 20 

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

Date of Incident: 2/25/09 NMED No.: 090418 

Investigation Date: 2/26/09 Type of Incident: Damaged/Leaking Source 

 Type of Investigation: Manufacturer’s Site 
Washington Final IMPEP Report Page E.4 

Incident Casework Reviews 

File No.: 21 

Licensee: Geisinger Health Systems License No.: PA-0006 

Date of Incident: 2/26/09 NMED No.: 090418 

Investigation Date: 2/26/09 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Manufacturer’s Site 

File No.: 22 

Licensee: Valley Hospital License No.: 29-03845-01 

Date of Incident: 7/29/09 NMED No.: 090662 

Investigation Date: 8/6/09 Type of Incident: Medical Event 

 Type of Investigation: Manufacturer’s Site 

File No.: 23 

Licensee: Bristol Hospital License No.: 06-02057-01 

Date of Incident: 1/12/10 NMED No.: 100290 

Investigation Date: 3/1/10 Type of Incident: Medical Event 

 Type of Investigation: Site 

File No.: 24 

Licensee: Warren General Hospital License No.: PA-0083 

Date of Incident: 11/2/10 NMED No.: 100553 

Investigation Date: 11/2/10 Type of Incident: Medical Event 

 Type of Investigation: Site 

File No.: 25 

Licensee: Mount Nittany License No.: PA-0126 

Date of Incident: 3/13/12 NMED No.: 120606 

Investigation Date: 3/15/12 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Site 

File No.: 26 

Licensee: Medical Center Central Georgia License No.: GA-0364-1 

Date of Incident: 8/1/11 NMED No.: 120635 

Investigation Date: 8/2/11 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Site 

File No.: 27 

Licensee: Piedmont Fayette Hospital License No.: GA-1340-1 

Date of Incident: 7/6/10 NMED No.: 120675 

Investigation Date: 7/6/10 Type of Incident: Medical Event 

 Type of Investigation: Site 

File No.: 28 

Licensee: Geisinger Health Systems License No.: PA-0006 

Date of Incident: 10/20/12 NMED No.: 130088 

Investigation Date: 10/22/12 Type of Incident: Lost/Stolen Material 

 Type of Investigation: Site 
Washington Final IMPEP Report Page E.5 

Incident Casework Reviews 

LOW-LEVEL RADIOACTIVE WASTE INCIDENT REVIEWS 

File No.: 29 

Licensee: Perma-Fix Northwest License No.: WN-I0393-1 

Date of Incident: 4/17/08 NMED Log No.: 080249 

Investigation Date: 4/17/08 Type of Incident: Contamination 

 Type of Investigation: Site 

File No.: 30 

Licensee: Perma-Fix Northwest License No.: WN-I0393-1 

Date of Incident: 2/3/09 NMED Log No.: 090452 

Investigation Date: 4/13/09 Type of Incident: Overexposure 

 Type of Investigation: Site 

File No.: 31 

Licensee: Perma-Fix Northwest License No.: WN-I0393-1 

Date of Incident: 12/4/12 NMED Log No.: 130017 

Investigation Date: 4/29/13 Type of Incident: Transportation 

 Type of Investigation: Site 

File No.: 32 

Licensee: US Ecology, Inc. License No.: WN-I019-2 

Date of Incident: 12/11/12 NMED Log No.: 130018 

Investigation Date: N/A Type of Incident: Transportation 

 Type of Investigation: Licensee Report 

File No.: 33 

Licensee: Perma Fix Northwest License No.: WN-I0393-1 

Date of Incident: 3/21/13 NMED Log No.: 130162 

Investigation Date: 4/4/13 Type of Incident: Transportation 

 Type of Investigation: Site
APPENDIX F 

SEALED SOURCE & DEVICE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Registry No.: WA-1220-D-102-S SS&D Type: (AA) Manual Brachytherapy 

Applicant Name: Isoray Medical, Inc. Type of Action: New 

Date of Issue: 11/21/11 Reviewers: CD, AG 

File No.: 2 

Registry No.: WA-1220-D-102-S SS&D Type: (AA) Manual Brachytherapy 

Applicant Name: Isoray Medical, Inc. Type of Action: Amendment 

Date of Issue: 2/15/12 Reviewers: CD, AG 

File No.: 3 

Registry No.: WA-0111-D-102-G SS&D Type: (H) General Neutron 

Source Applications 

Applicant Name: Acrowood Corp. Type of Action: Amendment 

Date of Issue: 7/10/09 Reviewers: SM, CL 
ATTACHMENT 

July 10, 2013 Letter from Maryanne Guichard 

Washington’s Response to the Draft Report 

ADAMS Accession No.: ML1396A003