October 30, 2013 

Mr. Mike Willden, Director 

Nevada Department of Health 

 and Human Services 

4126 Technology Way, Room 100 

Carson City, NV 89706 

Dear Mr. Willden: 

On September 19, 2013, the Management Review Board (MRB) met to consider the proposed 

final Integrated Materials Performance Evaluation Program (IMPEP) report on the Nevada 

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

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

Section 5.0, page 11, of the enclosed final report contains a summary of the IMPEP team’s 

findings. All performance indicators reviewed were found satisfactory, the highest rating. The 

review team made no new recommendations in regard to program performance by the Nevada 

Agreement State Program during this review, but kept two recommendations open from the 

2009 review, and closed two. Based on the results of the current IMPEP review, the next full 

review of the Nevada Agreement State Program will take place in approximately 4 years, with a 

periodic meeting tentatively scheduled for July 2015. 

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/ 

 Michael F. Weber 

 Deputy Executive Director for Materials, Waste, 

 Research, State, Tribal and Compliance Programs 

 Office of the Executive Director for Operations 

Enclosure: 

Nevada Final IMPEP Report 

cc w/encl: Jim McNees, Alabama 

 Organization of Agreement States 

 Liaison to the MRB 

 Karen K. Beckley, Manager 

 Radiation Control Program 
Mr. Mike Willden, Director 

Nevada Department of Health 

 and Human Services 

4126 Technology Way, Room 100 

Carson City, NV 89706 

Dear Mr. Willden: 

On September 19, 2013, the Management Review Board (MRB) met to consider the proposed 

final Integrated Materials Performance Evaluation Program (IMPEP) report on the Nevada 

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

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

Section 5.0, page 11, of the enclosed final report contains a summary of the IMPEP team’s 

findings. All performance indicators reviewed were found satisfactory, the highest rating. The 

review team made no new recommendations in regard to program performance by the Nevada 

Agreement State Program during this review, but kept two recommendations open from the 

2009 review, and closed two. Based on the results of the current IMPEP review, the next full 

review of the Nevada Agreement State Program will take place in approximately 4 years, with a 

periodic meeting tentatively scheduled for July 2015. 

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/ 

 Michael F. Weber 

 Deputy Executive Director for Materials, Waste, 

 Research, State, Tribal and Compliance Programs 

 Office of the Executive Director for Operations 

Enclosure: 

Nevada Final IMPEP Report 

cc w/encl: Jim McNees, Alabama 

 Organization of Agreement States 

 Liaison to the MRB 

 Karen K. Beckley, Manager 

 Radiation Control Program 

DISTRIBUTION: 

See next page 

 ML13273A127 

OFC Region III: TL ASPB/MSSA ASPB:BC MSSA: D TechEd FSME:D EDO/DEDMRT 

NAME JLynch via email LDimmick DWhite PHenderson CPoland BHolian MWeber 

DATE 10/01/13 09/30/13 10/01/13 10/21/13 10/21/13 10/24/13 10/30/13 

OFFICIAL RECORD COPY 
Letter to M. Willden from Michael F. Weber dated October 30, 2013 

SUBJECT: NEVADA FY2013 FINAL IMPEP REPORT 

DISTRIBUTION: (SP08) 

RidsEdoMailCenter 

JFoster, OEDO 

RidsFsmeOd 

RidsOgcMailCenter 

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DLew, RI 

ABoland, RIII 

RidsRgn4MailCenter 

AVegel, RIV 

RTorres, RIV 

BTharakan, RIV 

RidsSecyCorrespondenceMailCenter Chairman Macfarlane 

RidsFsmeMssa Commissioner Svinicki 

RErickson, RIV/RSAO Commissioner Apostolakis 

OMasnykBailey, RI Commissioner Magwood 

AJacobson, MD Commissioner Ostendorff 

JWeil, OCA (2 copies) SECY 

 
 Enclosure 

INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

REVIEW OF THE NEVADA AGREEMENT STATE PROGRAM 

July 15–19, 2013 

FINAL REPORT
EXECUTIVE SUMMARY 

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

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

the period of July 15–19, 2013, by a review team composed of technical staff members from the 

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

Based on the results of this review, Nevada's performance was found satisfactory for all 

performance indicators reviewed: Technical Staffing and Training, Status of Materials 

Inspection Program, Technical Quality of Inspections, Technical Quality of Licensing Actions, 

Technical Quality of Incident and Allegation Activities and Compatibility Requirements. In 

addition, it was determined at the time of the Management Review Board (MRB) meeting that 

the review team should consider a finding be made regarding the non-common indicators 

Sealed Source and Device Program and Low-Level Radioactive Waste Program. The team 

reviewed these indicators and determined that the State was performing oversight activities 

appropriate to the limited scope of these indicators. The review team agreed and 

recommended to the MRB that the State be found satisfactory for the indicators Sealed Source 

and Device and Low-Level Radioactive Waste Programs. 

The review team did not make any new recommendations and determined that two 

recommendations from the 2009 IMPEP review should be closed and that the two remaining 

recommendations regarding the development and implementation of a data tracking system, 

and the timely promulgation of regulations, should remain open. 

Accordingly, the review team recommended, and the MRB agreed, that the Nevada 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 four years. 
Nevada Final IMPEP Report Page 1 

1.0 INTRODUCTION 

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

review was conducted during the period of July 15–19, 2013, by a review team composed of 

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

Maryland. 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 June 6, 2009 to July 19, 2013, were discussed with Nevada 

managers on the last day of the review. 

A draft of this report was provided to Nevada for factual comment on August 15, 2013. The 

State responded by letter dated September 13, 2013. A copy of the State’s response is 

included as an Attachment to this report. A Management Review Board (MRB) met on 

September 19, 2013, to consider the proposed final report. The MRB found the Nevada 

Agreement State Program adequate to protect public health and safety, and compatible with the 

NRC’s program. 

The Nevada Agreement State Program is administered by the Radiation Control Program (the 

Program). The Program is part of the Bureau of Health (the Bureau) aligned under the Division 

of Public and Behavior Health (the Division) in the Department of Health and Human Services 

(the Department). Organization charts for the Department, Division, and Program are included 

as Appendix B. 

During the review period, the Nevada Radiation Control Program was briefly reorganized. In 

October 2012, Division administration decided to split the radioactive materials and radiation 

machines programs, with the materials program going to another Division. In March 2013, after 

further consideration of reorganization, a decision was made by the Division Administrator to 

restore the Program to its original structure. The review team did not identify any negative 

impact on performance during this five-month reorganization. 

At the time of the review, the Nevada Agreement State Program regulated 239 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 Nevada. 

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

non-common performance indicators was sent to the Program on March 21, 2013. The 

Program provided its response to the questionnaire on June 28, 2013. A copy of the 

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

Management System (ADAMS) using the Accession Number ML13183A116. 

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

the Program’s response to the questionnaire, (2) review of applicable Nevada statutes and 

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

review of selected regulatory actions, (5) field accompaniments of three inspectors, and 
Nevada Final IMPEP Report Page 2 

(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 Nevada Agreement State Program’s 

performance. 

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

during previous reviews. 

2.0 STATUS OF ITEMS IDENTIFIED IN PREVIOUS REVIEWS 

During the previous IMPEP review, which concluded on June 5, 2009, the review team made 

four recommendations regarding the Nevada Agreement State Program’s performance. The 

status of the recommendations is as follows: 

1. “The review team recommends that the Program revise their inspection procedures and 

provide training to implement a policy for timely and orderly license termination of 

licensed materials not in use. (Section 3.3 of the 2005 IMPEP Report)” 

Current Status: The Program noted that this issue was also identified by a Nevada 

legislative audit as an item needing correction. In response to both the NRC and the 

legislative audit, the Program developed and implemented a procedure to ensure that 

those licenses that need to be terminated are terminated in a timely fashion. The staff 

has been trained and understands the procedure. The review team evaluated licensing 

files for five license terminations (Appendix D) and found no issues with timely handling 

of terminations. The Program has also strengthened its enforcement procedure 

regarding license termination. This recommendation is closed. 

2. “The review team recommends that the Program develop, implement, and maintain a 

reliable and comprehensive licensing and inspection database that serves as an 

effective and efficient planning, tracking, and management tool. (Section 3.4 of the 2005 

IMPEP Report)” 

Current Status: The Program noted that development of a reliable database is still a 

work in progress, but it is moving forward. The Program secured a copy of the Oregon 

database, made changes specific to its Program, and submitted it to the IT Department 

for approval. The Program was unable to obtain funding during fiscal year 2013 to 

complete this project but, if funding is available in fiscal year 2014, the database will be 

completed and put into use. In the interim, the Program modified its current database, 

implemented new quality assurance procedures for it, and continues to use it. The 

Program found that while not perfect, the current database is now more accurate. This 

recommendation remains open. 

3. “The review team recommends that the State submit proposed and final regulations to 

the NRC for compatibility reviews. (Section 4.1.2)” 

Current Status: Previously the Program believed it was not to send regulations to the 

NRC for final review until the regulations had been codified, a practice that could take 

several years for the Legislative Council Bureau to complete. This was a 
Nevada Final IMPEP Report Page 3 

misunderstanding which has been corrected. The Program now sends regulation 

packages for initial and final reviews in a timely manner. This recommendation is 

closed. 

4. “The review team recommends that the State develop all required regulations within the 

required timeframe. (Section 4.1.2)” 

Current Status: Over the previous review period, the State was found to be significantly 

behind on regulation development. Over the current review period it was noted that 

while the State has made significant progress in rule development, the State continues 

to work towards becoming timely in its rule development process. Since the last review, 

the State also added an additional step in the rule development process, adding to the 

process time. The review team determined it appropriate to leave this recommendation 

open until the State demonstrates sustained performance in this area. This 

recommendation remains open. 

3.0 COMMON PERFORMANCE INDICATORS 

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

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

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

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

3.1 Technical Staffing and Training

Considerations central to the evaluation of this indicator include the Program’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 Program’s questionnaire response relative 

to this indicator, interviewed Program managers and staff, reviewed job descriptions and 

training records, and considered possible workload backlogs. 

The Program, headed by the Program Manager, regulates approximately 239 specific licenses 

with 6.7 technical staff full-time equivalents (FTE), which is considered fully staffed. The 

Program has two offices, in Carson City and Las Vegas. There are two supervisors in the 

Carson City office. One supervisor manages radioactive materials licensing and inspection 

activities for both offices; the other supervisor manages incident response and special project 

activities for both offices. In addition, there is one supervisor in the Las Vegas office who 

manages machine-based radiation activities for both offices. 

Four staff members left the Program, and three staff members joined the Program during the 

review period. One position was not filled, lowering the total technical FTE from 7.7 to 6.7. The 

Program Manager stated that the position is not likely to be filled under current economic 

conditions, but that the current staffing level is adequate to maintain a quality program. The 

new staff members have a wide range of technical experience and education, which brings 

depth of knowledge to the Program. Due to State budget difficulties, all employees are subject 

to a 48-hour furlough during the year. The review team determined that staffing levels were 

adequate for the Agreement State Program. 
Nevada Final IMPEP Report Page 4 

The Program has a documented training and qualification program for technical staff members 

that is consistent with 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.” The review team suggested that 

the Program use the recently issued IMC 1248, “Qualification Programs for Federal and State 

Materials and Environmental Management Programs,” with structured qualification journals. 

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

qualification process. The review team noted that several staff members had not attended 

required training courses, such as industrial radiography, brachytherapy, and well logging. 

Training in these areas would provide the Program additional flexibility in work assignments. 

The employees and supervisors were fully aware of the training needs. The review team 

concluded that the Program’s training program is adequate to carry out its regulatory duties. 

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

that Nevada’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 Program’s questionnaire response relative to this indicator, data gathered from the 

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

managers and staff. 

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

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

Inspection Program.” The review team confirmed the Program is conducting Increased Controls 

inspections in conjunction with the routine health and safety inspections. 

The review team found that the Program conducted a total of 255 inspections over the review 

period. Of those, 110 were identified as Priority 1, 2, and 3 inspections. None were conducted 

overdue. The Program also conducted a total of 39 initial inspections over the review period. 

None were conducted overdue. Additionally, the Program performed 214 followup inspections 

over the review period. When the Program issues violations, the Program performs a followup 

inspection of the issues identified during the previous inspection to ensure that corrective 

actions have been implemented. This followup inspection is conducted within one year. 

Followup inspections do not alter the inspection intervals assigned to each licensee. Overall, 

the review team found that the Program performed no inspections overdue during the review 

period. 

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

licensees. The majority of the Program’s routine inspections were documented with the 

issuance of a NV-591 Form, “Inspection Findings and Licensee Acknowledgement Form,” and 

left with the licensee at the completion of the on-site inspection. The NV-591 form is used for 

clear inspections and for those resulting in violations. If a NV-591 form cannot be issued in the 
Nevada Final IMPEP Report Page 5 

field, inspection findings are transmitted by letter to the licensee from the Program office. A 

sampling of 23 inspection reports found that none of the inspection findings were communicated 

to the licensees beyond the Program’s goal of 30 days following the inspection. 

The review team found that over the review period, the Program issued a total of 163 reciprocity 

permits of which 52 were candidates for inspection based upon the criteria found in IMC 1220, 

“Processing of NRC Form 241 and Inspection of Agreement State Licensees Operating under 

10 CFR 150.20”. The review team determined that the Program exceeded the NRC’s criteria of 

inspecting 20 percent of candidate licensees operating under reciprocity in all but one year 

(2010) covered by the review period. The review team found that in 2010, the Program was in a 

period of transition and was down two inspectors. Program managers made a deliberate 

decision to focus their limited staff resources on licensing and inspection of Nevada licensees 

during that year, resulting in only 8 percent of reciprocity candidate licensees being inspected. 

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

that Nevada’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 23 radioactive materials inspections 

conducted during the review period. The casework reviewed included inspections 

conducted by six Bureau inspectors and covered inspections of various license types: 

academic broad scope, medical-therapy, medical-diagnostic, fixed and portable gauges, 

industrial radiography, self-shielded irradiators, cyclotron, nuclear pharmacy, well-logging, 

and Increased Security Controls for Large Quantities of Radioactive Materials (Increased 

Controls). 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 noted that inspections covered all 

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

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

to ensure that a licensee’s performance with respect to health and safety was acceptable. The 

documentation supported violations, recommendations made to licensees, unresolved safety 

issues, the effectiveness of corrective actions taken to resolve previous violations and 

discussions held with licensees during exit interviews. 

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

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

and signed by the Supervisor and then by the Program Manager. Supervisory accompaniments 

were conducted annually for all inspectors. 

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

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

documented in the reports issued to the licensees on the Inspection Findings and Licensee 

Acknowledgement Form at the conclusion of the inspection or an appropriate letter detailing the 

results of the inspection within 30-days. When the Program issues a form or a letter describing 
Nevada Final IMPEP Report Page 6 

violations, the licensee is required to provide a written corrective action plan, based on the 

violations cited, within 30 days. All findings are reviewed by the Supervisor and Program 

Manager. 

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

support their inspection program. Appropriate, calibrated survey instruments, including 

Geiger-Mueller (GM) meters, scintillation detectors, ion chambers, micro-R meters, portable 

multi-channel analyzers and neutron detectors were observed to be operable and available. 

Instruments are calibrated at least annually, or as needed, by a consultant with National Institute 

of Standards and Technology traceable sources. The Program uses a spread sheet to track 

each instrument, its current location, and next calibration date. 

The review team accompanied three of the Program’s inspectors in March 2013. The 

inspectors conducted inspections at a hospital performing both diagnostic and therapy 

procedures and at two industrial radiography facilities. Two of the inspections included a review 

of the licensees’ implementation of the Increased Controls requirements. Appendix C lists the 

inspector accompaniments. The inspectors demonstrated performance-based inspection 

techniques and knowledge of the regulations. The inspectors were well trained, prepared for 

the inspections, and thorough in their audits of the licensees’ radiation safety and security 

programs. The inspectors conducted interviews with appropriate personnel, observed licensed 

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

The inspectors held entrance and exit meetings with the appropriate level of licensee 

management. The review team determined that 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 Nevada’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 

22 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 1 new 

license, 5 renewals, 5 decommissioning or termination actions, and 11 amendments. Files 

reviewed included a cross-section of license types: broad scope, medical diagnostic and 

therapy including, high dose rate remote afterloader, radioiodine therapy, temporary/permanent 

implant brachytherapy, gamma knife, industrial radiography, research and development, nuclear 

pharmacy, portable and fixed gauges, manufacturers, and self-shielded irradiators. The 

casework sample represented work from seven license reviewers. A listing of the licensing 
Nevada Final IMPEP Report Page 7 

casework evaluated is provided in Appendix D. 

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 

Bureau’s licensing guides and/or the NUREG-1556 series guidance documents, policies, 

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

consistency in licenses. 

Licensing actions are assigned a number and tracked on a spreadsheet. The licensing and 

inspection supervisor assigns licensing actions based on the reviewer’s qualifications. Licenses 

are subjected to peer and supervisory reviews before being signed out by the Program 

manager. The Program continues to hand deliver and review with the licensee all new licenses 

and licenses with a change of location or Radiation Safety Officer. This action serves to ensure 

that licensees have adequate radiation safety and security programs in place and serves to 

meet the objective of a pre-licensing visit. 

Based on the casework evaluated, the review team concluded that the licensing actions were of 

high quality and consistent with the Branch licensing procedures and NUREG-1556 guidance 

documents, the State’s regulations, and good health physics practices. The review team 

attributed the consistent use of templates and quality assurance reviews to the overall quality 

noted in the casework reviews. 

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

and Fingerprinting Orders. The review team noted that the State uses legally binding license 

conditions that meet the criteria for implementing the Increased Controls Orders, including 

fingerprinting, as appropriate. The review team analyzed the Program’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 Program 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 Program’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. The review team noted that the Program controls 

access to all of its licensing and inspection files through the use of safes and cipher locks. 

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

that Nevada’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 Program’s actions in responding to incidents and 
Nevada Final IMPEP Report Page 8 

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

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

Database (NMED) against those contained in the Program’s files, and evaluated the casework 

for 13 radioactive materials incidents. A list of the incident casework examined may be found in 

Appendix E. The review team also evaluated the Program’s response to eight allegations 

involving radioactive materials, including two allegations referred to the State by the NRC during 

the review period. 

The incidents selected for review included the following categories: lost/stolen radioactive 

material, potential overexposure, medical event, and equipment failure. The review team 

determined that the Program’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 Program dispatched inspectors for on-site investigations in 

six of the cases reviewed and took suitable enforcement and followup actions. 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. 

An additional incident occurred during the onsite review, and an IMPEP team member 

accompanied a Program inspector on the response to a potential public health and safety 

incident. The Local Law Enforcement Agency identified what appeared to be a contaminated 

area at a public beach. The response by the Program was prompt and well-coordinated. The 

inspector attributed the elevated radiation levels to naturally occurring potassium-40. 

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

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

documentation, 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 

Program Manager and supervisors determine the appropriate level of initial response. 

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

evaluated the completed casework for eight allegations, including two that NRC referred to the 

State during the review period. The review team concluded that the Program took prompt and 

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

documented the investigations of concerns and retained all necessary documentation to 

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

conclusion of its investigations. The review team determined that the Program adequately 

protected the identity of concerned individuals. 

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

that Nevada’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, 
Nevada Final IMPEP Report Page 9 

(3) Low-Level Radioactive Waste Disposal Program, and (4) Uranium Recovery Program. The 

NRC’s Agreement with Nevada does not relinquish authority to regulate a uranium recovery 

program, so only the first three non-common performance indicators were applicable to this 

review. 

4.1 Compatibility Requirements

4.1.1 Legislation

Nevada became an Agreement State in 1972. Legislative authority to create an agency and 

enter into an Agreement with the NRC is granted in Nevada Revised Statutes (NRS) Section 

459. The Nevada State Health Division is designated as the State’s radiation control agency. 

Another NRS section that affects the Agreement State program includes NRS 439, “Public 

Health Administrative Procedures.” The review team noted that no significant legislation 

affecting the radiation control program was passed since the previous review. 

4.1.2 Program Elements Required for Compatibility

The Nevada Radiation Control Program regulations, found in Chapter 459 of the Nevada 

Administrative Code, apply to all ionizing radiation, whether emitted from radionuclides or 

devices. Nevada requires a license for possession and use of all radioactive material. The 

review team noted that the State’s rules and regulations are not subject to “sunset” provisions. 

The State may adopt other agency’s regulations by reference and has the authority to issue 

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

regulations become effective. 

The review team examined the State’s process for adopting regulations. The Program informed 

the review team that in 2011, an additional step was added to the regulation development 

process. After drafting regulations, in addition to sending a copy to the NRC for review, the 

Program now sends regulations to the Division Deputy Administrator who edits the regulations. 

Regulations are then sent to the Legislative Council Bureau (LCB) for review and comment. 

The LCB is a legal office within Nevada that first reviews and then later codifies regulations for 

all Nevada regulatory agencies. When the overall process is complete (including resolution of 

NRC comments), the adopted regulations are sent back to the LCB for codification. Once 

codified, the newly formatted regulations are sent to the Secretary of State’s Office for filing. 

After approximately 30 to 45 days the regulations become final. The State can adopt some 

NRC regulations by reference which speeds up the adoption process significantly. 

During the review period, Nevada submitted 16 final regulation amendments to 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 the effective 

date of NRC’s regulations. A total of 15 of the 16 final amendments were overdue for State 

adoption at the time of submission. The overdue amendments were submitted early in the 

review period, 2010 and 2011, and were remnants of the 2009 IMPEP review. The NRC’s 

compatibility review of the final amendments resulted in no comments. 
Nevada Final IMPEP Report Page 10 

At the time of this review, the following amendment was overdue: 

• “Medical Use of Byproduct Material – Authorized User Clarification,” 10 CFR Part 35 (74 

FR 33901), that was due for Agreement State implementation on September 28, 2012. 

The Program is drafting final regulations for this amendment but the rule package is currently 

pending in the Division. The review team noted that the State had made significant progress in 

the promulgation of regulations since the last IMPEP review, but still faced challenges in 

negotiating the arduous State regulatory process. 

A complete list of upcoming regulation amendments that will need to be addressed in the future 

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 Nevada’s performance with respect to the indicator, Compatibility Requirements, be found 

satisfactory. 

4.2 Sealed Source and Device Evaluation Program

There are currently two manufacturers/distributors licensed by the Program. One of the 

licensees assembles and distributes generally licensed devices in accordance with sealed 

source and device (SS&D) registry certificates issued by another Agreement State. The second 

licensee manufactures gun and bow sights in accordance with an NRC-issued SS&D registry 

certificate and distributes them under an NRC exempt distribution license. 

During a previous IMPEP review, the State indicated that it planned to return its SS&D authority 

to the NRC; however, this plan did not receive management approval. At the time of the review, 

the Program had no staff members qualified to perform safety evaluations of SS&D applications 

and amendments. The Program entered into an agreement with the State of California whereby 

California’s qualified SS&D reviewers will conduct product safety evaluations for the State of 

Nevada. 

During the review period, the Program issued one SS&D certificate to a now terminated 

licensee. The licensee distributed generally licensed exit signs. Technical evaluation of the 

certificate was performed by California SS&D reviewers and was signed by the Program 

Manager and one of the supervisors. Issuance of the sheet was performed in close 

coordination with FSME. 

During MRB deliberations, the review team acknowledged the Program’s oversight of its Sealed 

Source Device Evaluation Program and found the Program’s oversight adequate. The team 

acknowledged the review included an evaluation of the California Agreement State Program’s 

performance of this indicator on its last IMPEP to ensure that the SS&D reviews were 

conducted by qualified reviewers and that the Nevada Program manager maintained oversight 

of the registry reviews. The MRB directed the report be revised to include a finding for the 

indicator. Therefore, the review team recommended, and the MRB agreed, that Nevada’s 

performance with respect to the indicator, Sealed Source Device Evaluation Program, be found 

satisfactory. 
Nevada Final IMPEP Report Page 11 

4.3 Low-Level Radioactive Waste Disposal Program

The former U.S. Ecology low-level radioactive waste disposal facility, located in Nye County, 

opened in 1962 and received radioactive waste for burial until 1992. The former licensee 

completed the State-approved closure plan and the license was subsequently transferred to the 

State of Nevada. The Nevada State Health Division assumed all oversight responsibilities and 

became custodian of the site. The site has continuous security. One of the Program 

supervisors is named as Radiation Safety Officer on the license. 

The review team evaluated Nevada’s oversight of the site, and determined that the Program 

performs quarterly visits to the site for a visual examination of the trench cap and to conduct 

radiation surveys. The review team’s evaluation of the quarterly visit reports identified an 

adequate analysis of site radiological hazards. 

During MRB deliberations, the review team acknowledged the closed low-level waste disposal 

site is under custodial care of the Nevada Agreement State Program and found the Program’s 

oversight adequate. The team acknowledged the Program is performing comprehensive audits 

and surveys for the appropriate activity at this site. The MRB directed the report be revised to 

include a finding for the indicator. Therefore, the review team recommended, and the MRB 

agreed, that Nevada’s performance with respect to the indicator, Low-Level Radioactive Waste 

Disposal Program, be found satisfactory. 

5.0 SUMMARY 

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

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

recommendations and determined that two recommendations from the 2009 IMPEP review 

should be closed. The review team determined that the other two recommendations from the 

2009 IMPEP review should remain open in order to monitor pending enhancements of the data 

tracking system and the regulation promulgation process. 

Accordingly, the review team recommended, and the MRB agreed, that the Nevada 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 four years. 

Below are the open recommendations, as mentioned in the report, for continued implementation 

by the State: 

RECOMMENDATIONS 

1. The review team recommends that the Program develop, implement, and maintain a 

reliable and comprehensive licensing and inspection database that serves as an 

effective and efficient planning, tracking, and management tool. (Section 2.0) 

2. The review team recommends that the State develop all required regulations within the 

required timeframe. (Section 2.0) 
LIST OF APPENDICES 

Appendix A IMPEP Review Team Members 

Appendix B Nevada 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

James Lynch, Region III Team Leader 

 Technical Staffing and Training 

 Inspection Accompaniments 

 Sealed Source and Device Evaluation Program∗

 Low-Level Radioactive Waste Review∗

Randy Erickson, Region IV Status of Materials Inspection Program 

 Compatibility Requirements 

Alan Jacobson, Maryland Technical Quality of Inspections 

Orysia Masnyk Bailey, Region I Technical Quality of Licensing Actions 

 Technical Quality of Incident and Allegation 

 Activities 

 

∗

 The Sealed Source and Device Evaluation Program was limited scope review. The team 

evaluated the Program’s oversight activities. Product safety evaluations are contracted to 

another Agreement State Program. ∗

 The Low-Level Radioactive Waste Review was limited scope review. The team evaluated the 

Program’s oversight activities for a closed disposal facility.
APPENDIX B 

NEVADA ORGANIZATION CHARTS 

ADAMS ACCESSION NO.: ML13211A345 
 APPENDIX C 

INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Sierra Vista Surgery Center License No.: 16-12-0648-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 2/15/13 Inspector: JB 

File No.: 2 

Licensee: Desert Radiologist License No.: 03-12-0327-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 10/4/12 Inspector: TS 

File No.: 3 

Licensee: University of Nevada - Las Vegas License No.: 03-13-0305-01 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 3/19/13 Inspector: JB 

File No.: 4 

Licensee: North Vista Hospital License No.: 03-12-0291-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 12/8/10 Inspector: TS 

File No.: 5 

Licensee: United Blood Services License No.: 16-11-0300-01 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 4/5/12 Inspectors: AH, EM 

File No.: 6 

Licensee: Baker Hughes License No.: 00-11-0659-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 5/12/12 Inspector: TM 

File No.: 7 

Licensee: Carson Tahoe Regional Medical Center License No.: 01-12-0032-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 4/13/11 Inspector: TM 

File No.: 8 

Licensee: Black Eagle Consulting License No.: 00-11-0409-02 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 4/15/13 Inspector: JB 
Nevada Final IMPEP Report Page C.2 

Inspection Casework Reviews 

File No.: 9 

Licensee: Western Technologies License No.: 00-11-0019-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 3/6/13 Inspector: JF 

File No.: 10 

Licensee: Aztech Inspection and Testing License No.: 00-11-0482-02 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 8/15/12 Inspectors: TS, JF 

File No.: 11 

Licensee: Black Eagle Consulting License No.: 00-11-0409-02 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 5/11/12 Inspector: TM 

File No. 12 

Licensee: Bigelow Aerospace License No.: 03-11-0622-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 8/24/10 Inspector: TS 

File No. 13 

Licensee: Davis Laboratories License No.: 00-11-0113-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 8/12/12 Inspector: TS 

File No.: 14 

Licensee: Barrick Goldstrike Mines License No.: 05-11-0276-01 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 9/22/12 Inspector: TM 

File No.: 15 

Licensee: Urology Reno License No.: 16-12-0644-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 4/30/12 Inspector: TM 

File No.: 16 

Licensee: St. Mary’s Regional Medical Center License No.: 16-12-0244-02 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 2/15/12 Inspector: TM 

File No.: 17 

Licensee: 21st Century Oncology License No.: 03-12-0429-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 6/29/10 Inspector: TS 

 
Nevada Final IMPEP Report Page C.3 

Inspection Casework Reviews 

File No.: 18 

Licensee: Cardinal Health License No.: 03-11-0332-02 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 5/23/13 Inspector: JF 

File No.: 19 

Licensee: University Medical Center License No.: 03-12-0034-03 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 6/8/11 Inspectors: TS, TM 

File No.: 20 

Licensee: Sunrise Medical Center License No.: 03-12-0395-02 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 12/20/11 Inspectors: JF, TS 

File No.: 21 

Licensee: Newmont Mining License No.: 08-11-0364-01 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 4/6/10 Inspector: TM 

File No.: 22 

Licensee: PETNET Solutions License No.: 03-11-0468-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 2/15/12 Inspector: TS 

File No.: 23 

Licensee: PETNET Solutions License No.: 03-11-0468-02 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 2/15/12 Inspector: TS 

INSPECTOR ACCOMPANIMENTS 

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

Accompaniment No.: 1 

Licensee: Sunrise Hospital and Medical Center License No.: 03-12-0325-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 3/4/13 Inspector: JB 

Accompaniment No.: 2 

Licensee: Davis Laboratories, Inc. License No.: 00-11-0113-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 3/5/13 Inspector: TM 
Nevada Final IMPEP Report Page C.4 

Inspection Casework Reviews 

Accompaniment No.: 3 

Licensee: Western Technologies, Inc. License No.: 00-11-0019-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 3/6/13 Inspector: JF 
APPENDIX D 

LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: University of Nevada - Reno License No.: 16-13-0003-08 

Type of Action: Termination Amendment No.: 2 

Date Issued: 10/31/12 License Reviewer: SR 

File No.: 2 

Licensee: Cardinal Health 414, LLC License No: 03-11-0332-03 

Type of Action: Amendment Amendment No.: 1 

Date Issued: 2/13/13 License Reviewer: JB 

File No.: 3 

Licensee: A2Z NDT License No.: 00-11-0693-01 

Type of Action: New Amendment No.: 0 

Date Issued: 5/14/13 License Reviewer: JB 

File No.: 4 

Licensee: United Blood Services License No.: 16-11-0300-01 

Type of Action: Renewal Amendment No.: 8 

Date Issued: 5/31/12 License Reviewer: AH 

File No.: 5 

Licensee: Grizzly Materials & Testing License No.: 00-11-0589-01 

Type of Action: Termination Amendment No.: 5 

Date Issued: 6/28/11 License Reviewer: TM 

File No.: 6 

Licensee: Black Eagle Consulting, Inc. License No.: 00-11-0409-02 

Type of Action: Amendment Amendment No.: 3 

Date Issued: 4/23/13 License Reviewer: JB 

File No.: 7 

Licensee: Sunrise Hospital and Medical Center License No.: 03-12-0395-02 

Type of Action: Amendment Amendment No.: 17 

Date Issued: 3/14/13 License Reviewer: JB 

File No.: 8 

Licensee: Animal Imaging & Treatment Center License No.: 03-12-0413-01 

Type of Action: Renewal Amendment No.: 6 

Date Issued: 2/13/13 License Reviewer: SR 
Nevada Final IMPEP Report Page D.2 

Licensing Casework Reviews 

File No.: 9 

Licensee: Renown Regional Medical Center License No.: 16-12-0016-01 

Type of Action: Amendment Amendment No.: 104 

Date Issued: 6/17/13 License Reviewer: AK 

File No.: 10 

Licensee: St. Rose Dominican Hospital License No.: 03-12-0395-02 

Type of Action: Amendment Amendment No.: 7 

Date Issued: 3/20/13 License Reviewer: SR 

File No.: 11 

Licensee: Black Eagle Consulting Company License No.: 00-11-0409-01 

Type of Action: Amendment Amendment No.: 11 

Date Issued: 1/24/13 License Reviewer: AK 

File No.: 12 

Licensee: Nevada Department of Transportation License No.: 00-14-0407-01 

Type of Action: Renewal Amendment No.: 12 

Date Issued: 6/3/13 License Reviewer: TM 

File No.: 13 

Licensee: Premier Magnesia, LLC License No.: 13-11-0612-01 

Type of Action: Renewal Amendment No.: 4 

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

File No.: 14 

Licensee: Varian Medical Systems License No.: 03-11-0637-01 

Type of Action: Amendment Amendment No.: 4 

Date Issued: 11/7/12 License Reviewer: TS 

File No.: 15 

Licensee: Best Lighting Products, Inc. License No.: 03-11-0494-02 

Type of Action: Termination Amendment No.: 14 

Date Issued: 12/17/12 License Reviewer: AK 

File No.: 16 

Licensee: QC Southwest License No.: 00-11-0499-01 

Type of Action: Renewal Amendment No.: 4 

Date Issued: 9/5/12 License Reviewer: TS 

File No.: 17 

Licensee: Renown Regional Medical Center License No.: 16-12-0430-01 

Type of Action: Termination Amendment No.: 24 

Date Issued: 4/12/10 License Reviewer: SR 
Nevada Final IMPEP Report Page D.3 

Licensing Casework Reviews 

File No.: 18 

Licensee: PetNet Solutions, Inc. License No.: 03-1-0468-01 

Type of Action: Amendment Amendment No.: 18 

Date Issued: 5/15/13 License Reviewer: JB 

File No.: 19 

Licensee: Cardinal Health 414, LLC License No.: 01-11-0150-01 

Type of Action: Termination Amendment No.: 56 

Date Issued: 11/17/11 License Reviewer: AK 

File No.: 20 

Licensee: University of Nevada – Las Vegas License No.: 13-13-0305-01 

Type of Action: Amendment Amendment No.: 40 

Date Issued: 4/11/11 License Reviewer: AK 

File No.: 21 

Licensee: Comprehensive Cancer Centers of Nevada License No.: 03-12-0491-01 

Type of Action: Amendment Amendment No.: 18 

Date Issued: 6/10/13 License Reviewer: AK 

File No.: 22 

Licensee: Comprehensive Cancer Centers of Nevada License No.: 03-12-0525-01 

Type of Action: Amendment Amendment No.: 21 

Date Issued: 5/14/13 License Reviewer: AK 
APPENDIX E 

INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Robinson Mining Company License No.: 17-11-0372-01 

Date of Incident: 4/29/10 NMED No.: 100222 

Investigation Date: 4/29/10 Type of Incident: Equipment Failure 

 Type of Investigation: Site 

File No.: 2 

Licensee: St. Mary’s Regional Hospital License No.: 16-12-0244-02 

Date of Incident: 3/16/10 NMED No.: 100263 

Investigation Date: 5/14/10 Type of Incident: Medical Event 

 Type of Investigation: Site 

File No.: 3 

Licensee: West Valley Imaging License No.: 03-23-0384-02 

Date of Incident: 7/21/10 NMED No.: 100381 

Investigation Date: 7/21/10 Type of Incident: Medical Event 

 Type of Investigation: Telephone 

File No.: 4 

Licensee: Round Mountain Gold Corporation License No.: 13-11-0097-01 

Date of Incident: 3/10/10 NMED No.: 100126 

Investigation Date: 3/15/10 Type of Incident: Equipment Failure 

 Type of Investigation: Telephone 

File No.: 5 

Licensee: Las Vegas Paving License No.: 00-22-0255-01 

Date of Incident: 3/10/10 NMED No.: 100114 

Investigation Date: 3/11/10 Type of Incident: Lost/Stolen RAM 

 Type of Investigation: Site 

File No.: 6 

Licensee: James Hardie Building Products License No.: General 

Date of Incident: 1/1/05 NMED No.: 120408 

Investigation Date: 7/9/12 Type of Incident: Lost/Stolen RAM 

 Type of Investigation: Telephone 

File No.: 7 

Licensee: Summerlin Medical Center License No.: 03-12-0388-01 

Date of Incident: 12/23/11 NMED No.: 120089 

Investigation Date: 12/28/11 Type of Incident: Lost/Stolen RAM 

 Type of Investigation: Telephone 

File No.: 8 

Licensee: 21st Century Oncology License No.: 03-12-0429-01 

Date of Incident: 10/12/12 NMED No.: 120621 

Investigation Date: 10/15/12 Type of Incident: Medical Event 

 Type of Investigation: Telephone 
Nevada Final IMPEP Report Page E.2 

Incident Casework Reviews 

File No.: 9 

Licensee: St. Mary’s Regional Hospital License No.: 16-12-0244-02 

Date of Incident: 5/14/13 NMED No.: 130242 

Investigation Date: 5/14/13 Type of Incident: Medical Event 

 Type of Investigation: Telephone 

File No.: 10 

Licensee: Acclaim Material Testing License No.: 00-11-0471-01 

Date of Incident: 12/28/09 NMED No.: 100004 

Investigation Date: 12/28/09 Type of Incident: Equipment Failure 

 Type of Investigation: Site 

File No.: 11 

Licensee: University of Nevada – Las Vegas License No.: 03-13-0305-01 

Date of Incident: 4/5/11 NMED No.: 120515 

Investigation Date: 8/31/12 Type of Incident: Overexposure 

 Type of Investigation: Site 

File No.: 12 

Licensee: Bracco Diagnostics License No.: 03-12-0453-01 

Date of Incident: 2/11/11 NMED No.: 110646 

Investigation Date: 12/5/11 Type of Incident: Medical Event 

 Type of Investigation: Site 

File No.: 13 

Licensee: University Medical Center License No.: 13-12-0034-01 

Date of Incident: 12/9/09 NMED No.: 110339 

Investigation Date: 12/10/09 Type of Incident: Medical Event 

 Type of Investigation: Telephone 
 

ATTACHMENT 

September 13, 2013 Letter from Karen K. Beckley 

Nevada’s Response to the Draft Report 

ADAMS Accession No.: ML13259A002