UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

October 27, 2014 

Charles Warzecha, Deputy Administrator 

Division of Public Health 

Wisconsin Department of Health Services 

1 West Wilson Street, Room 250 

Madison, WI 53701-2659 

Dear Mr. Warzecha: 

On October 9, 2014, the Management Review Board (MRB) met to consider the proposed final 

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

Agreement State Program. The MRB found the Wisconsin program adequate to protect public 

health and safety and compatible with the U.S. Nuclear Regulatory Commission’s (NRC) 

program. 

Section 5.0, page 10 of the enclosed final report contains a summary of the IMPEP team’s 

findings. Based on the results of this review, Wisconsin’s performance was found satisfactory 

for all six of the performance indicators reviewed. The review team identified a “Good Practice” 

by the program for implementing the use of a Pre-Inspection Plan by each inspector to ensure 

that all required information is addressed during special or follow up inspections. The review 

team determined that the use of these plans contributed to the consistent, high technical quality 

of inspections conducted during a period of high staff turnover. The ability to conduct effective 

licensing and inspection programs is largely dependent on having a sufficient number of 

experienced and well-trained technical staff. The MRB commends the Wisconsin program for 

its high performance despite the significant staff turnover during the review period. Based on 

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

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

for January 2017. 
C. Warzecha -2- 

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

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

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

Sincerely, 

 /RA/ 

 Roy P. Zimmerman 

 Acting Deputy Executive Director for 

 Materials, Waste, Research, State, Tribal and 

 Compliance Programs 

Office of the Executive Director for Operations 

Enclosure: 

Wisconsin Proposed Final Report

cc: Michael Snee, OH 

 Organization of Agreement States 

 Liaison to the MRB 

 

Paul Schmidt, Chief 

Radiation Protection Section 

Cheryl Rogers, Supervisor 

Radioactive Materials Unit
C. Warzecha -2- 

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

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

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

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

Sincerely, 

 /RA/ 

 Roy P. Zimmerman 

 Acting Deputy Executive Director for 

 Materials, Waste, Research, State, Tribal and 

 Compliance Programs 

Office of the Executive Director for Operations 

Enclosure: 

Wisconsin Proposed Final Report

cc: Michael Snee, OH 

 Organization of Agreement States 

 Liaison to the MRB 

 

Paul Schmidt, Chief 

Radiation Protection Section 

Cheryl Rogers, Supervisor 

Radioactive Materials Unit

Distribution: (See Attached) 

ML14288A074 

OFC RI:TL MSTR MSTR MSTR:D TechEd NMSS:D EDO:Acting 

DEDMRT 

NAME OMasnykBailey 

via eimail

LDimmick 

/ADW

DWhite 

w/edits 

LDudes /SA 

w/edits 

CPoland 

/CMD

CHaney RZimmerman 

DATE 10/15/14 10/15/14 10/15/14 10/16/14 10/17/14 10/20/14 10/27/14 

OFFICIAL RECORD COPY
Letter to C. Warzecha from Roy P. Zimmerman dated: October 27, 2014 

SUBJECT: WISCONSIN FY2014 FINAL IMPEP REPORT 

DISTRIBUTION: (SP07) 

RidsEdoMailCenter 

JFoster, OEDO 

RidsNmssOd 

RidsOgcMailCenter 

JOlmstead, OGC 

RidsRgn4MailCenter 

MDapas, RIV 

RidsRgn3MailCenter 

PLouden, RIII 

RidsSecyCorrespondenceMailCenter Chairman Macfarlane 

RidsNmssMstr Commissioner Svinicki 

SAbraham, MSTR Commissioner Ostendorff 

PHenderson, MSTR Commissioner Baran 

MBeardsley, MSTR SECY 

JLynch, RIII 

LRoldenOtero, RIV 

MRiley, AL 

OAS Board 

JWeil, OCA (2 copies) 
Enclosure 

INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

REVIEW OF THE WISCONSIN AGREEMENT STATE PROGRAM 

JULY 14-18, 2014 

FINAL REPORT
EXECUTIVE SUMMARY 

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

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

the period of July 14-18, 2014, by a review team composed of technical staff members from the 

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

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

the performance indicators reviewed. 

The review team did not make any recommendations. The review team identified a “Good 

Practice” by the Section for implementing the use of a Pre-Inspection Plan by each inspector to 

ensure that all required information is addressed during special or follow up inspections. The 

review team determined that the use of these plans contributed to the consistent, high technical 

quality of inspections conducted during a period of high staff turnover, (Section 3.3). 

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

agreed, that the Wisconsin 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 IMPEP review take place in approximately 5 years. 
Wisconsin Final IMPEP Report Page 1 

1.0 INTRODUCTION 

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

review was conducted during the period of July 14-18, 2014, by a review team composed of 

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

Alabama. 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 July 18, 2009, to June 30, 2014, were discussed with 

Wisconsin managers on the last day of the review. 

A draft of this report was issued to Wisconsin on August 20, 2014, for factual comment. 

Wisconsin responded to the findings and conclusions of the review by e-mail dated September 

2, 2014. A copy of the State’s response is included as an attachment to this report. The 

Management Review Board (MRB) met on October 9, 2014, to consider the proposed final 

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

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

The Wisconsin Agreement State Program is administered by the Radiation Protection Section 

(the Section). The Section is part of the Bureau of Environmental and Occupational Health 

within the Division of Public Health (the Division). Organization charts for the Department and 

the Bureau are included as Appendix B. 

At the time of the review, the Wisconsin Agreement State Program regulated approximately 306 

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 Wisconsin. 

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

non-common performance indicators was sent to the Section on April 28, 2014. The Section 

provided its response to the questionnaire on July 1, 2014. A copy of the questionnaire 

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

(ADAMS) using the Accession Number ML14182A620. 

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

the Section’s response to the questionnaire, (2) review of applicable Wisconsin statutes and 

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

review of selected regulatory actions, (5) field accompaniments of five 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 Wisconsin Agreement State Program’s 

performance. 

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 

indicator, and Section 5.0 summarizes the review team's findings. 
Wisconsin Final IMPEP Report Page 2 

2.0 STATUS OF ITEMS IDENTIFIED IN PREVIOUS REVIEWS 

During the previous IMPEP review, that concluded on July 17, 2009, the review team made no 

recommendations regarding the Wisconsin 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

Considerations central to the evaluation of this indicator include the Section’s staffing level and 

staff turnover, as well as the technical qualifications and training histories of the staff. To 

evaluate these issues, the review team examined the Section’s questionnaire response relative 

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

and considered workload backlogs. 

The Section, managed by the Unit Supervisor, has approximately 9.5 full-time equivalents (FTE) 

assigned to the radioactive materials program with 7.5 FTE allotted for inspection and licensing 

which is comparable with other programs of similar size and scope. The remaining FTE include 

program management, administrative support, and a half-time training coordinator. 

The Section experienced significant turnover in technical staff during the review period in which 

eight staff members left the Section and eight new staff members were hired. The Section was 

able to manage this turnover. Two additional staff were hired in 2010, staff departures and new 

hires were staggered such that there was never a period during the five year review cycle that 

the staff level was below full strength. The Section was able to recruit highly qualified, 

experienced and capable staff for all positions (B.S. and M.S. degrees in nuclear/civil 

engineering and nuclear medicine). All but three staff members are currently fully qualified. As 

noted in Section 3.2, the program diverted a few inspections due to staff turnover and State 

mandated furloughs early in the review period. However, as noted in Sections 3.3 and 3.4 the 

team found that the technical quality of inspections and licensing was not substantially impacted 

during the review period due to staff turnover. This can be attributed to the Section’s successful 

use of mentoring, peer review, and consistent management oversight. In addition, the Section 

routinely uses inspection plans. Additionally, peer reviews of licensing casework are performed 

to maintain continuity. 

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

requirements in NRC’s Inspection Manual Chapter (IMC) 1248, “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. Three recently 

hired staff members have been authorized to perform independent inspections and reviews of 

the disciplines for which they had completed training. 
Wisconsin Final IMPEP Report Page 3 

The review team concluded that the Section’s training program is adequate to carry out its 

regulatory duties and noted that Wisconsin management supports the Section’s training 

program. 

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

that Wisconsin’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 Section’s questionnaire response relative to this indicator, data gathered from the 

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

management and staff. 

The review team verified that Wisconsin's inspection frequencies for all types of radioactive 

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

Inspection Program.” Three of the license categories established by the Section were assigned 

inspection priority codes that prescribe a more frequent inspection schedule than those 

established in IMC 2800 for similar license types. Medical broad scope programs, high dose 

rate remote afterloaders, and mobile nuclear medicine licensees are inspected more frequently. 

The Section conducted 279 Priority 1, 2, and 3 inspections during the review period, based on 

the inspection frequencies established in IMC 2800. Fourteen of these inspections were 

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

2800, ranging from several days to 11 months overdue. In addition, the Section performed 37 

initial inspections during the review period of which 3 were conducted overdue. As required by 

IMC 2800, initial inspections should be conducted within 12 months of license issuance. None 

of the overdue inspections occurred in 2013 or 2014. The overdue inspections decreased as 

the staff completed qualifications and gained experience. State mandated employee furloughs 

and staff turnover contributed to the late inspections conducted early in the review period. 

Overall, the review team calculated that the Section performed 5.7 percent of its inspections 

overdue during the review period. 

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

A sampling of 29 inspection reports indicated that 4 of the inspection findings were 

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

reports were issued to licensees within 74 days post inspection. 

During the review period, the Section received 90 reciprocity requests from companies wishing 

to perform work in Wisconsin. The review team determined that the Section conducted 

reciprocity inspections of 54 percent of those licensees thus far in 2014, 60 percent in 2013, 

47 percent in 2012, 67 percent in 2011, 40 percent in 2010, and 53 percent in 2009. The 

Section exceeded the NRC’s criteria of inspecting 20 percent of candidate licensees operating 

under reciprocity in each of the 5 years covered by the review period. 
Wisconsin Final IMPEP Report Page 4 

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

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

Program, be found satisfactory. 

3.3 Technical Quality of Inspections

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

notes, and interviewed inspectors for 29 radioactive materials inspections conducted during the 

review period. The casework reviewed included a cross-section of inspections conducted by 10 

current and former inspectors and covered inspections of various license types. The casework 

included medical broad scope, high dose rate remote afterloader, portable gauges, industrial 

radiography, self-shielded irradiators, gamma knife, nuclear pharmacy, nuclear medicine, and 

Increased Controls for the security of large quantities of radioactive materials. Appendix C lists 

the inspection casework files reviewed. 

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

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

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

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

security were acceptable. The documentation supported violations, recommendations made to 

licensees, unresolved safety issues, the effectiveness of corrective actions taken to resolve 

previous violations and discussions held with licensees during exit interviews. The review team 

verified through interviews that the Section is aware of all aspects of the National Source 

Tracking System program. 

The Section has implemented the use of a Pre-Inspection Plan which is used by each inspector. 

The plan includes basic information about the licensee, priority areas being reviewed, major 

elements of the program, documents used during preparation and the type of equipment being 

used. This is also used to ensure all required information is addressed during special or follow 

up inspections. The use of these plans contributed to the consistent, high technical quality of 

inspections during the period of high staff turnover. Their preparation and use were evaluated 

during the review and inspector accompaniments. Inspectors stated that these were 

instrumental in assuring a good quality inspection. The review team identified this as a “Good 

Practice.” 

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

the review of the Increased Controls inspection casework, the team observed that the Section 

sends separate letters for health and safety, and security inspections. The Section maintains 

two separate color-coded files for licensees subject to increased security. The Section 

implemented this policy for better control of potential security-related information, as the security 

file is stored in a locked file cabinet. 

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

regulatory actions were taken, as necessary. Inspection findings were clearly stated and 

documented in the reports and sent to the licensees with the appropriate letter detailing the 

results of the inspection. The Section issues to the licensee, either a letter indicating a clear 

inspection or a Notice of Violation (NOV), in letter format, which details the results of the 
Wisconsin Final IMPEP Report Page 5 

inspection. When the Section issues an NOV, the licensee is required to provide a written 

corrective action plan, based on the violations cited, within 30 days. 

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

an annual basis. The review team verified that the Unit Supervisor performed staff 

accompaniments annually of all staff performing materials inspections. A record of each 

accompaniment was noted on the inspection report and placed in the staff member’s training 

record. 

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

support its inspection program, as well as to respond to radioactive materials incidents and 

emergency conditions. Instruments used to support the radioactive materials inspection 

program are sent to an authorized entity for calibration. The Section uses a database to track 

each instrument, and its next calibration date. 

Accompaniments of five Section inspectors were conducted by an IMPEP team member 

during June 9-12, 2014. The inspectors were accompanied during health and safety 

inspections of industrial radiography, medical therapy including high dose rate remote 

afterloader/gamma knife, medical diagnostic license and a portable gauge. The 

accompaniments are identified in Appendix C. During the accompaniments, the inspectors 

demonstrated appropriate inspection techniques, knowledge of the regulations, and 

conducted performance-based inspections. The inspectors were trained, well-prepared for 

the inspection, and thorough in their audits of the licensees’ radiation safety programs. The 

inspectors conducted interviews with appropriate personnel, observed licensed operations, 

conducted confirmatory measurements, and utilized good health physics practices. The 

inspections were adequate to assess radiological health and safety and security at the 

licensed facilities. 

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

that Wisconsin’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 

35 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 5 new 

licenses, 9 renewals, 3 decommissioning or termination actions, and 18 amendments. Files 

reviewed included a cross-section of license types including: medical and academic broad 

scope, medical diagnostic and therapy including high dose rate remote afterloader, 
Wisconsin Final IMPEP Report Page 6 

temporary/permanent implant brachytherapy, and gamma knife, industrial radiography for 

permanent and temporary job sites, research and development, nuclear pharmacy, gauges, 

manufacturers, and panoramic and self-shielded irradiators. The casework sample represented 

work from 13 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 

tie-down conditions were stated clearly and were supported by information contained in the file. 

Deficiency letters clearly stated regulatory positions, were used at the proper time, and identified 

substantive deficiencies in the licensees’ documents. Terminated licensing actions were well 

documented, showing appropriate transfer and survey records. License reviewers use the 

Section’s licensing guides and/or NRC NUREG-1556 series guidance documents, policies, 

checklists, and standard license conditions specific to the type of licensing actions to ensure 

consistency in licenses. 

The administrative staff receives all licensing actions and enters all pertinent information into the 

Section’s database, which tracks the status of all actions. The Unit Supervisor assigns each 

action to one of seven reviewers based on workload and experience. For reviewers with less 

experience in a given area, the Unit Supervisor provides additional oversight and/or assigns 

another experienced reviewer as a mentor. Deficiency letters are reviewed and signed by the 

reviewers. When the reviewer completes a licensing action, a second technical review is 

performed by another reviewer or the Unit Supervisor. All completed actions are reviewed and 

signed by the Unit Supervisor. The administrative staff conducts an administrative review and 

final processing before mailing out to the licensee. New and renewed licenses are issued for a 

5-year term. After the 5-year term, licensees are required to submit a complete renewal 

application to maintain current information in the file. 

The Section uses templates to generate most correspondence and licenses, and there are 

standard formats and license conditions for each license type. The Section utilizes licensing 

guides based on NRC licensing guidance (NUREG-1556 series), as appropriate, and maintains 

other licensing guidance (i.e., Technical Assistance Requests, regulatory guides) that are the 

same or similar to those used by NRC. Based on the casework evaluated, the review team 

concluded that the licensing actions were of high quality and consistent with the Section’s 

licensing procedures. The review team attributed the consistent use of templates and quality 

assurance reviews to the overall quality noted in the casework reviews. 

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

review methods incorporate the essential elements of NRC’s revised pre-licensing guidance to 

verify that the applicant will use requested radioactive materials as intended. All new licensees 

not meeting the exclusion criteria receive a pre-licensing site visit which includes an evaluation 

of the applicant’s radiation safety and security programs prior to receipt of the initial license. 

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

and Fingerprinting Orders. The review team noted that the 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 Section’s methodology for 

identifying those licenses and found the rationale was thorough and accurate. The review team 
Wisconsin Final IMPEP Report Page 7 

confirmed that license reviewers evaluated new license applications and license amendments 

using the same criteria. The Section requires full implementation of the Increased Controls prior 

to issuance of a new license or license amendment that meets the established criteria. 

The review team examined the 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. 

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

that Wisconsin’s performance with respect to the indicator, Technical Quality of Licensing 

Actions, be found satisfactory. 

3.5 Technical Quality of Incident and Allegation Activities

In evaluating the effectiveness of the Section’s actions in responding to incidents and 

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

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

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

casework for 11 radioactive materials incidents. A list of the incident casework examined may 

be found in Appendix E. The review team also evaluated the Section’s response to all seven of 

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

by the NRC during the review period. 

The incidents selected for review included the following categories: stolen or missing 

radioactive material, potential overexposure, medical event, damaged equipment, and leaking 

sources. The review team determined that the Section’s response to incidents was complete 

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

was commensurate with the health and safety significance. The Section dispatched inspectors 

for on-site investigations in five of the cases reviewed and took suitable enforcement and 

follow-up actions for the remainder. The follow-up actions consisted of monitoring licensee 

progress and review during the next inspection. If the incident met the reportability thresholds, 

as established in the Office of Federal and State Materials and Environmental Management 

Programs (FSME) Procedure SA-300 “Reporting Material Events,” the State notified the NRC 

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

The review team examined the Section’s implementation of its incident and allegation 

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

documentation, notification of incidents to the NRC Headquarters Operations Center, and the 

use of NMED software. When notification of an incident or an allegation is received, the Unit 

Supervisor determines the appropriate level of initial response. 

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

evaluated the completed casework for all seven allegations received during the review period, 

including three that the NRC referred to the State during the review period. The review team 

concluded that the Section took prompt and appropriate actions in response to concerns raised. 

The review team noted that the Section documented the investigations of concerns and retained 

all necessary documentation to appropriately close the allegations. The Section notified the 

concerned individuals at the conclusion of their investigations. The review team determined that 

the Section adequately protected the identity of concerned individuals. 
Wisconsin Final IMPEP Report Page 8 

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

that Wisconsin’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. The 

NRC’s Agreement with Wisconsin does not relinquish regulatory authority for a sealed source 

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

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

4.1 Compatibility Requirements

4.1.1 Legislation

Wisconsin became an Agreement State on August 11, 2003. The current effective statutory 

authority is contained in Wisconsin Statutes, Chapter 254, Sections 254.31 through 254.45. 

The Department is designated as the State’s radiation control agency. The Section implements 

the radiation control program. The review team noted that no legislation affecting the radiation 

control program was passed during the review period. 

4.1.2 Program Elements Required for Compatibility

The regulations governing radiation protection requirements are located in Chapter DHS 157 of 

the Wisconsin Administrative Code and apply to all ionizing radiation. Wisconsin requires a 

license for possession and use of all radioactive material. Wisconsin also requires registration 

of all equipment designed to produce x-rays or other ionizing radiation. 

For each rulemaking initiative, Division staff develops a rulemaking plan that provides overview 

information (reason for rule changes, potential costs, stakeholder involvement, etc.), and details 

of the existing rule. Once approved, the plan is submitted to the Office of Legal Counsel for 

review and Department approval. A Statement of Scope is then submitted by the Office of the 

Secretary to the Governor’s office. After approval, the Statement of Scope is published in the 

Wisconsin Register. The rulemaking package is developed and published for public comment. 

At the same time, the Section sends the proposed rule to the NRC for a compatibility review. A 

public hearing is required for all rulemaking packages. After the hearing process, a resolution of 

comments document is prepared and sent to the Governor’s office for approval of the final 

proposed rules package. The rulemaking process, as recently modified by State lawmakers, is 

expected to take a minimum of two years to complete. 

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

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

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

compatible regulations become effective. In the event that Wisconsin’s security regulations 

equivalent to 10 CFR 37 are not adopted by the March 2016 compatibility deadline, the State 

developed a license condition, approved by the NRC, to add to licenses. 
Wisconsin Final IMPEP Report Page 9 

The review team evaluated Wisconsin’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, Wisconsin submitted 11 final regulation amendments and 1 legally 

binding license condition to the NRC for a compatibility review. Current NRC policy requires 

that Agreement States adopt certain equivalent regulations or legally-binding requirements no 

later than 3 years after they become effective. Five of the amendments were overdue for State 

adoption at the time of submission. No regulation amendments were overdue at the time of the 

IMPEP review. The NRC’s compatibility review resulted in seven comments, which will need to 

be addressed by the State. According to the Section Chief, who is responsible for oversight of 

rulemaking activities, the Section is addressing the comments in a rulemaking package that is in 

process. 

The five amendments adopted overdue are as follows: 

• “Compatibility With IAEA Transportation Safety Standards and Other Transportation 

Safety Amendments,” 10 CFR Part 71 amendment (69 FR 3697), that was due for 

Agreement State adoption by October 1, 2007. (RATS 2004-1) 

• “Medical Use of Byproduct Material – Recognition of Specialty Boards,” 10 CFR Part 35 

amendment (70 FR 16336 and 71 FR 1926), that was due for Agreement State adoption 

by September 28, 2012. (RATS 2005-2) 

• “Minor Amendments,” 10 CFR Parts 20, 30, 32, 35, 40 and 70 amendment (71 FR 

15005), that was due for Agreement State adoption by March 27, 2009. (RATS 2006-1) 

• “National Source Tracking System – Serialization Requirements,” 10 CFR Part 32 with 

reference to Part 20 Appendix E amendment (71 FR 65685), that was due for 

Agreement State adoption by February 6, 2007. (RATS 2006-2) 

• “National Source Tracking System,” 10 CFR Part 20 amendment (71 FR 65685 and 72 

FR 59162), that was due for Agreement State adoption by January 31, 2009. (RATS 

2006-3) 

A complete list of regulation amendments may 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 Wisconsin’s performance with respect to the indicator, Compatibility Requirements, be 

found satisfactory. 

 
Wisconsin Final IMPEP Report Page 10 

5.0 SUMMARY 

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

of the performance indicators reviewed. The review team did not make any recommendations. 

The review team identified a “Good Practice” by the Section for implementing the use of a 

Pre-Inspection Plan by each inspector to ensure that all required information is addressed 

during special or follow up inspections. The review team determined that the use of these plans 

may have contributed to the consistent, high technical quality of inspections during the period of 

high staff turnover experienced during the review period. Accordingly, the review team 

recommended, and the MRB agreed, that the Wisconsin Agreement State Program be found 

adequate to protect public health and safety and compatible with the NRC's program. Based on 

the results of the current IMPEP review, the review team recommended, and the MRB agreed, 

that the next full IMPEP review take place in approximately 5 years. 
LIST OF APPENDICES 

Appendix A IMPEP Review Team Members 

Appendix B Wisconsin Organization Charts 

Appendix C Inspection Casework Reviews 

Appendix D License Casework Reviews 

Appendix E Incident Casework Reviews 

 
APPENDIX A 

IMPEP REVIEW TEAM MEMBERS 

Name Area of Responsibility

Orysia Masnyk Bailey, Region I Team Leader 

 Technical Quality of Incident and Allegation 

Activities 

 Staffing and Training 

 Inspector Accompaniments 

Jim Lynch, Region III Compatibility Requirements 

 Status of Materials Inspection Program 

Myron Riley, Alabama Technical Quality of Inspections 

Lizette Roldán-Otero, Ph.D., Region IV Technical Quality of Licensing Actions 

 
APPENDIX B 

WISCONSIN ORGANIZATION CHARTS 

ADAMS ACCESSION NO.: ML14182A609 
 

 APPENDIX C 

INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Cardinal Health License No.: 141-1306-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 2/14/14 Inspectors: KW, LJ 

File No.: 2 

Licensee: Aspirus-Wausau Hospital License No.: 073-1342-01 

Inspection Type: Initial, Announced Priority: 1 

Inspection Date: 5/2/14 Inspector: CT 

File No.: 3 

Licensee: ECS Midwest, LLC License No.: 101-2041-01 

Inspection Type: Initial, Announced Priority: 5 

Inspection Date: 9/26/12 Inspectors: AT, LJ 

File No.: 4 

Licensee: Divine Savior Healthcare, Inc. License No.: 021-1380-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 10/24/13 Inspector: AT 

File No.: 5 

Licensee: NDT Specialists, Inc. License No.: 079-1199-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 6/19/14 Inspectors: KK, MP 

File No.: 6 

Licensee: Great Lakes Testing License No.: 009-1116-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 9/18/13 Inspector: MP 

File No.: 7 

Licensee: Team Industrial Services, Inc. License No.: 079-2005-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 11/30/11 Inspectors: CT, RN 

File No.: 8 

Licensee: Aurora Medical Center of Washington County, Inc. License No.: 131-1024-01 

Inspection Type: Special, Announced Priority: 3 

Inspection Date: 8/31/11 Inspectors: KK, PC 
Wisconsin Final IMPEP Report Page C. 2 

Inspection Casework Reviews 

File No.: 9 

Licensee: Howard Young Medical Center License No.: 085-1126-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 11/18/12 Inspectors: LJ, KK 

File No.: 10 

Licensee: Acuren Inspection, Inc. License No.: 133-2008-01 

Inspection Type: Routine, Announced-Field Priority: 1 

Inspection Date: 6/10/14 Inspectors: EE, KK 

File No.: 11 

Licensee: Wisconsin Medical Cyclotron, LLC License No.: 079-1366-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 3/12/14 Inspector: MP 

File No.: 12 

Licensee: Aurora Medical Center Grafton, LLC License No.: 089-1392-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 2/26/14 Inspector: KW 

File No.: 13 

Licensee: Scott Construction License No.: 111-1021-01 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 8/17/10 Inspector: SZ 

File No.: 14 

Licensee: Medi-Physics, Inc. License No.: 079-1168-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 1/15/14 Inspectors: LJ, EE 

File No.: 15 

Licensee: Community Blood Center, Inc. License No.: 087-1067-01 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 11/4/09 Inspector: MS 

File No.: 16 

Licensee: Fort Memorial Hospital License No.: 055-1105-01 

Inspection Type: Announced, Special Priority: 3 

Inspection Date: 10/12/09 Inspector: PC 

File No.: 17 

Licensee: Appleton Medical Center License No.: 087-1014-01 

Inspection Type: Initial, Announced, Reactive Priority: 1 

Inspection Date: 2/22/12 Inspectors: MS, LJ 

 
Wisconsin Final IMPEP Report Page C. 3 

Inspection Casework Reviews 

File No.: 18 

Licensee: Gunderson Clinic, Ltd. License No.: 063-1121-01 

Inspection Type: Announced, Special Priority: 1 

Inspection Date: 10/3/12 Inspectors: EE, CT 

File No.: 19 

Licensee: Marshfield Clinic License No.: 141-1162-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 4/29-30/14 Inspectors: KK, MS 

File No.: 20 

Licensee: Aurora Health Care Metro, Inc. License No.: 079-1281-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 8/14-15/13 Inspectors: MS, KK 

File No.: 21 

Licensee: University of Wisconsin-Madison License No.: 025-1323-01 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 2/18-20/14 Inspectors: EE, CT, KK, AT, MP 

File No.: 22 

Licensee: RAM Services, Inc. License No.: 071-1234-01 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 11/12/13 Inspectors: CT, EE, LJ 

File No.: 23 

Licensee: Foss Therapy Services License No.: CA-6875-19 

Inspection Type: Reciprocity-Routine, Unannounced Priority: 2 

Inspection Date: 7/10/13 Inspectors: LJ, MP 

File No.: 24 

Licensee: Best Theratronics, Ltd. License No.: NRC-45-31299-01 

Inspection Type: Reciprocity-Routine, Unannounced Priority: 5 

Inspection Date: 6/7/14 Inspector: KK 

File No.: 25 

Licensee: Viewray, Inc. License No.: OH-0321480085 

Inspection Type: Reciprocity-Routine, Unannounced Priority: 2 

Inspection Date: 7/9/13 Inspector: MS 

File No.: 26 

Licensee: McNDT Leasing, Inc. License No.: IL-01875-01 

Inspection Type: Reciprocity-Routine, Unannounced Priority: 1 

Inspection Date: 2/2/12 Inspectors: CT, LJ, RN 

 
Wisconsin Final IMPEP Report Page C. 4 

Inspection Casework Reviews 

File No.: 27 

Licensee: Varian Medical Systems, Inc. License No.: NRC-45-30957-01 

Inspection Type: Reciprocity-Routine, Unannounced Priority: 1 

Inspection Date: 5/15/14 Inspectors: CT, AT 

File No.: 28 

Licensee: Lawrence University License No.: 087-1153-01 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 6/17/14 Inspector: CT 

File No.: 29 

Licensee: Pharmasan Labs, Inc. License No.: 095-1223-01 

Inspection Type: Reactive, Announced Priority: 5 

Inspection Date: 8/15/13 Inspector: MP 

INSPECTOR ACCOMPANIMENTS 

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

Accompaniment No.: 1 

Licensee: Lakeshore Medical Center License No.: 079-1307-01 

Inspection Type: Routine Priority: 3 

Inspection Date: 6/12/14 Inspector: LJ 

Accompaniment No.: 2 

Licensee: Dane County Sanitary Landfill License No.: 025-1082-01 

Inspection Type: Reactive Priority: 5 

Inspection Date: 6/9/14 Inspector: KW 

Accompaniment No.: 3 

Licensee: Acuren License No.: 133-2008-01 

Inspection Type: Routine Priority: 1 

Inspection Date: 6/10/14 Inspectors: KK, EE 

 

Accompaniment No.: 4 

Licensee: West Allis Memorial Hospital License No.: 079-1347-01 

Inspection Type: Routine Priority: 1 

Inspection Date: 6/11/14 Inspector: MP 
 

APPENDIX D 

LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Green Bay Packaging, Inc. License No.: 009-1119-01 

Type of Action: Renewal Amendment No.: 02 

Date Issued: 6/4/12 License Reviewer: KK 

File No.: 2 

Licensee: Green Bay Packaging, Inc. License No.: 009-1119-01 

Type of Action: Termination Amendment Nos.: 03 

Date Issued: 10/30/13 License Reviewer: MS 

File No.: 3 

Licensee: NDT Specialist, Inc. License No.: 079-1199-01 

Type of Action: Renewal Amendment No.: 08 

Date Issued: 11/18/13 License Reviewer: KK 

File No.: 4 

Licensee: Team Industrial Services License No.: 079-2005-01 

Type of Action: Renewal Amendment No.: 7 

Date Issued: 8/19/11 License Reviewer: CT 

File No.: 5 

Licensee: Team Industrial Services License No.: 079-2005-01 

Type of Action: Amendment Amendment No.: 8 

Date Issued: 11/12/12 License Reviewer: CT 

File No.: 6 

Licensee: Team Industrial Services License No.: 079-2005-01 

Type of Action: Amendment Amendment No.: 10 

Date Issued: 5/5/14 License Reviewer: LJ 

File No.: 7 

Licensee: Great Lakes Testing, Inc. License No.: 09-1116-01 

Type of Action: Amendment Amendment No.: 11 

Date Issued: 11/18/13 License Reviewer: MP 

File No.: 8 

Licensee: Arrowhead-Madison License No.: 025-2027-01 

Type of Action: New Amendment No.: NA 

Date Issued: 10/5/09 License Reviewer: CT 
Wisconsin Final IMPEP Report Page D. 2 

License Casework Reviews 

File No.: 9 

Licensee: Arrowhead-Madison License No.: 025-2027-01 

Type of Action: Amendment Amendment No.: 02 

Date Issued: 5/31/11 License Reviewer: CT 

File No.: 10 

Licensee: Aurora Medical Center Grafton, LLC License No.: 089-1392-01 

Type of Action: New Amendment No.: NA 

Date Issued: 10/1/10 License Reviewer: EE 

File No.: 11 

Licensee: Aurora Medical Center Grafton, LLC License No.: 089-1392-01 

Type of Action: Amendment Amendment No.: 01 

Date Issued: 7/13/11 License Reviewer: MP 

File No.: 12 

Licensee: Comprehensive Genetic Services, S.C. License No: 079-1071-01 

Type of Action: Renewal Amendment No.: 01 

Date Issued: 11/24/09 License Reviewer: RN 

File No.: 13 

Licensee: Comprehensive Genetic Services, S.C. License No: 079-1071-01 

Type of Action: Termination Amendment No.: 02 

Date Issued: 12/29/11 License Reviewer: DMS 

File No.: 14 

Licensee: University of Wisconsin License No.: 025-1323-01 

Type of Action: Amendment Amendment No.: 18 

Date Issued: 6/23/09 License Reviewer: PC 

File No.: 15 

Licensee: University of Wisconsin License No.: 025-1323-01 

Type of Action: Renewal Amendment No.: 29 

Date Issued: 1/8/14 License Reviewer: EE 

File No.: 16 

Licensee: Cardinal Health License No.: 079-1311-01 

Type of Action: Amendment Amendment No.: 13 

Date Issued: 5/3/12 License Reviewer: KK 

File No.: 17 

Licensee: Appleton Medical Center License No.: 087-1014-01 

Type of Action: Amendment Amendment No.: 24 

Date Issued: 5/23/14 License Reviewer: KW 

 
Wisconsin Final IMPEP Report Page D. 3 

License Casework Reviews 

File No.: 18 

Licensee: Appleton Medical Center License No.: 087-1014-01 

Type of Action: Amendment Amendment No.: 25 

Date Issued: 5/23/14 License Reviewer: PS 

File No.: 19 

Licensee: GZA GeoEnvironmental, Inc. License No: 133-2040-01 

Type of Action: New Amendment No.: NA 

Date Issued: 4/8/13 License Reviewer: LNE 

File No.: 20 

Licensee: Promega Corporation License No.: 025-1231-01 

Type of Action: Renewal Amendment No.: 07 

Date Issued: 12/2/13 License Reviewer: LNE 

File No.: 21 

Licensee: Kendrick Laboratories, Inc. License No.: 025-1139-01 

Type of Action: Renewal Amendment No.: 03 

Date Issued: 9/7/11 License Reviewer: KK 

File No.: 22 

Licensee: Kendrick Laboratories, Inc. License No.: 025-1139-01 

Type of Action: Amendment Amendment No.: 04 

Date Issued: 11/29/11 License Reviewer: KK 

File No.: 23 

Licensee: Bio-Technical Resources License No.: 071-1037-01 

Type of Action: Renewal Amendment No.: 02 

Date Issued: 3/26/10 License Reviewer: KP 

File No.: 24 

Licensee: Lucigen Corporation License No.: 025-1047-01 

Type of Action: Renewal Amendment No.: 04 

Date Issued: 6/16/10 License Reviewer: EE 

File No.: 25 

Licensee: MD Imaging, LLC License No.: 079-1190-01 

Type of Action: Amendment Amendment No.: 19 

Date Issued: 7/15/14 License Reviewer: MS 

File No.: 26 

Licensee: J.T. Roofing Inc. License No.: 089-1132-01 

Type of Action: Termination Amendment No.: 05 

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

 
Wisconsin Final IMPEP Report Page D. 4 

License Casework Reviews 

File No.: 27 

Licensee: St. Mary’s Hospital License No.: 025-1293-01 

Type of Action: Amendment Amendment No.: 09 

Date Issued: 7/15/14 License Reviewer: KK 

File No.: 28 

Licensee: Wheaton Franciscan Healthcare License No.: 079-1288-01 

- St. Joseph, Inc. 

Type of Action: Amendment Amendment No.: 20 

Date Issued: 7/23/13 License Reviewer: MS 

File No.: 29 

Licensee: Agnesian Healthcare, Inc. License No.: 039-1282-01 

Type of Action: Amendment Amendment No.: 09 

Date Issued: 5/20/13 License Reviewer: EE 

File No.: 30 

Licensee: Agnesian Healthcare, Inc. License No.: 039-1282-01 

Type of Action: Amendment Amendment No.: 10 

Date Issued: 11/11/13 License Reviewer: LJ 

File No.: 31 

Licensee: Agnesian Healthcare, Inc. License No.: 039-1282-01 

Type of Action: Amendment Amendment No.: 11 

Date Issued: 3/18/14 License Reviewer: LJ 

File No.: 32 

Licensee: NorthStar Medical Technologies License No.: 025-2038-02 

Type of Action: New Amendment No.: NA 

Date Issued: 1/24/14 License Reviewer: MP 

File No.: 33 

Licensee: NorthStar Medical Technologies License No.: 025-2038-02 

Type of Action: Amendment Amendment No.: 1 

Date Issued: 4/17/14 License Reviewer: MP 

File No.: 34 

Licensee: University of Wisconsin - Madison License No.: 025-1323-05 

Type of Action: New Amendment No.: NA 

Date Issued: 11/30/12 License Reviewer: MS 

File No.: 35 

Licensee: University of Wisconsin - Madison License No.: 025-1323-05 

Type of Action: Amendment Amendment No.: 1 

Date Issued: 1/9/13 License Reviewer: MS 
 

APPENDIX E 

INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Ansul Inc./Tyco Fire Protection Products License No.: 070-4087-01 

Date of Incident: 6/13/14 NMED No.: 140323 

Investigation Date: 6/16/12 Type of Incident: Lost RAM 

 Type of Investigation: Phone 

File No.: 2 

Licensee: NewPage Wisconsin Systems License No.: 141-1258-01 

Date of Incident: 6/7/14 NMED No.: 140308 

Investigation Date: 6/9/14 Type of Incident: Equipment Failure 

 Type of Investigation: Phone 

File No.: 3 

Licensee: Bath, Bath, & Beyond License No.: General 

Date of Incident: 9/17/13 NMED No.: 130472 

Investigation Date: 10/14/13 Type of Incident: Lost RAM 

 Type of Investigation: Phone 

File No.: 4 

Licensee: Monroe Clinic License No.: 045-1197-01 

Date of Incident: 6/13/13 NMED No.: 140077 

Investigation Date: 7/8/13 Type of Incident: Medical Event 

 Type of Investigation: Phone 

File No.: 5 

Licensee: Miller Compressing, Inc. License No.: Non-licensee 

Date of Incident: 3/7/13 NMED No.: 130412 

Investigation Date: 6/4/13 Type of Incident: Unsecured NORM 

 Type of Investigation: Site 

File No.: 6 

Licensee: Acuren Inspection, Inc. License No.: 133-2008-01 

Date of Incident: 2/25/13 NMED No.: 130198 

Investigation Date: 4/19/13 Type of Incident: Equipment Malfunction 

 Type of Investigation: Site 

File No.: 7 

Licensee: University of Wisconsin - Madison License No.: 25-1323-01 

Date of Incident: 9/20/12 NMED No.: 120573 

Investigation Date: 10/17/13 Type of Incident: Contamination 

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

Incident Casework Reviews 

File No.: 8 

Licensee: Frank Jiran Contractor, Inc. License No.: 021-1255-01M 

Date of Incident: 5/1/11 NMED No.: 110273 

Investigation Date: 6/1/11 Type of Incident: Lost RAM 

 Type of Investigation: Phone 

File No.: 9 

Licensee: Miller Compressing, Inc. License No.: Non-Licensee 

Date of Incident: 1/19/10 NMED No.: 100417 

Investigation Date: 6/9/10 Type of Incident: Abandoned RAM 

 Type of Investigation: Site 

File No.: 10 

Licensee: Froedtert & Medical College of Wisconsin License No.: 79-1104-01 

Date of Incident: 6/9/10 NMED No.: 100305 

Investigation Date: 6/10/10 Type of Incident: Medical Event 

 Type of Investigation: Phone 

File No.: 11 

Licensee: Tetra Tech, Inc. License No.: 073-1165-01 

Date of Incident: 6/28/10 NMED No.: 100417 

Investigation Date: 6/28/10 Type of Incident: Damaged Equipment 

 Type of Investigation: Site 
 

ATTACHMENT 

September 2, 2014 Email from Cheryl K. Rogers 

Wisconsin Response to the Draft Report 

ADAMS Accession No.: ML14246A170