Enclosure 

INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

REVIEW OF THE TEXAS AGREEMENT STATE PROGRAM 

February 10-14, 2014 

FINAL REPORT 
EXECUTIVE SUMMARY 

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

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

period of February 10 – 14, 2014, by a review team composed of technical staff members from 

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

Based on the results of this review, Texas’ performance was found satisfactory for all 

performance indicators reviewed. The review team made three recommendations regarding 

program performance by the State regarding (1) developing and implementing a strategy to 

address staffing in the low-level radioactive waste (LLRW) and uranium recovery inspection 

areas; (2) developing detailed inspection procedures for LLRW inspections to provide feedback 

to the LLRW program and enhance the inspection program; and (3) developing detailed 

inspection procedures for uranium recovery inspections to provide feedback to the uranium 

recovery program and enhance the inspection program. 

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

agreed, that the Texas Agreement State Program is 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. 

. 
Texas Final IMPEP Report Page 2 

1.0 INTRODUCTION 

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

review was conducted during the period of February 10 –14, 2014, by a review team composed 

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

of Washington. 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 February 27, 2010, to February 14, 2014, were discussed 

with Texas managers on the last day of the review. Subsequent to the exit meeting, the review 

team reconvened to finalize the review of the low-level radioactive waste (LLRW) and uranium 

recovery indicators. The review team’s recommendations for these indicators were discussed 

with the Director, Radioactive Materials Division, and the Director, Critical Infrastructure 

Division, of the Texas Commission on Environmental Quality on April 14 and May 14, 2014. 

A draft of this report was provided to Texas for factual comment on May 21, 2014. The State 

responded by letters dated June 12, 2014, and June 20, 2014. Copies of the State’s responses 

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

July 22, 2014, to consider the proposed final report. The MRB found the Texas Agreement 

State Program adequate to protect public health and safety and compatible with the NRC’s 

program. 

The Texas Agreement State Program is administered by two State agencies, the Texas 

Department of State Health Services (the Department) and the Texas Commission on 

Environmental Quality (the Commission). Organization charts for the Department and the 

Commission are included as Appendix B. 

The Department’s portion of the Agreement State program is located in the Division for 

Regulatory Services. This Division has two sections: the Health Care Quality Section, which 

includes all licensing functions and the Environmental and Consumer Safety Section, which 

includes the inspection, investigation and quality assurance programs. 

The Commission’s portion of the Agreement State program is located in two offices. The Office 

of Waste, Radioactive Materials Division, performs licensing and permitting functions. The 

Commission’s inspection program is located in the Office of Compliance and Enforcement, 

Critical Infrastructure Division. 

At the time of the review, the Department regulated approximately 1,578 specific licenses 

authorizing the possession and use of radioactive materials. The Commission has regulatory 

authority for LLRW disposal activities and uranium recovery facilities in Texas. 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 NRC and the State of Texas. 
Texas Final IMPEP Report Page 3 

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

non-common performance indicators was sent to the Department and the Commission on 

December 5, 2013. The Department provided its response to the questionnaire on January 14, 

2014, and the Commission provided its response to the questionnaire on February 4, 2014. 

Copies of the Department’s and the Commission’s questionnaire responses can be found in 

NRC’s Agencywide Documents Access and Management System (ADAMS) using the 

Accession Number ML14070A117 for the Department’s response and Accession Number 

ML14070A055 for the Commission’s response. 

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

Texas response to the questionnaire, (2) review of applicable Texas statutes and regulations, 

(3) analysis of quantitative information from the State’s databases, (4) technical review of 

selected regulatory actions, (5) field accompaniments of eight of the Department’s inspectors, 

and two of the Commission’s 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 Texas Agreement State Program’s performance. 

There were no recommendations made during the previous review. 

Results of the current review of the common performance indicators are presented in Section 

2.0. Section 3.0 details the results of the review of the applicable non-common performance 

indicators, and Section 4.0 summarizes the review team's findings. 

2.0 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. 

2.1 Technical Staffing and Training

The Department’s staffing and training for the radioactive materials program will be covered in 

this section of the report. The Commission’s staffing and training for the LLRW and uranium 

recovery programs will be covered in Sections 3.3.1 and 3.4.1 of this report, respectively. 

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

relative to this indicator, interviewed Department managers and staff, reviewed job descriptions 

and training records, and considered workload backlogs. 

The Department is organized into functional groups rather than program groups. The 

Radiation Safety Licensing Branch Manager is designated as the radiation control program 

director and provides a coordinating role among the functional groups. Licensing functions, 
Texas Final IMPEP Report Page 4 

including sealed source and device reviews, are performed in the Austin office by the 

Radioactive Materials Group of the Radiation Safety Licensing Branch, which is located in the 

Health Care Quality Section. The inspection and incident response functions are performed 

by the Radiation Branch of the Inspection Unit, which is located in the Environmental and 

Consumer Safety Section. Most of the inspection staff is based in 11 regional offices, which 

are located throughout the State. The Radiation Group in the Policy/Standards/Quality 

Assurance Unit coordinates rule development, prepares enforcement cases for referral to the 

Enforcement Review Committee, and plays a major role in quality assurance for the 

inspection program. 

At the time of the review, there were 42 individuals, totaling approximately 38 full-time 

equivalents (FTE), with various degrees of involvement in the radioactive materials program. 

One position in the Radiation Safety Licensing Branch was vacant at the time of this review. 

During the review period, a total of 18 individuals left the radioactive materials program, 

including four managers. The staff departures occurred intermittently and the vacancies were 

filled with well qualified technical staff holding science degrees. Eighteen staff members were 

added during the review period, including four managers. The review team determined that 

staffing levels were adequate for the Agreement State program. 

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

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

NRC’s Inspection Manual Chapter (IMC) 1248, “Formal Qualification Program for Federal and 

State Materials and Environmental management Programs”. New licensing and inspection staff 

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

process. Qualified staff mentor new staff and keep their qualification current through 

professional education training. The licensing and inspection program managers maintain the 

training and qualification records for technical staff. In addition, one technical staff member in 

the Policy/Standards/Quality Assurance Unit is responsible for coordinating training requests 

and acceptances at NRC qualification courses. The review team concluded that the 

Department’s training program is adequate to carry out its regulatory duties and noted that 

Texas management supports the radiation control program’s training program. 

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

that Texas’ performance with respect to the indicator, Technical Staffing and Training, be found 

satisfactory. 

2.2 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 Department’s questionnaire response relative to this indicator, data gathered from the 

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

management and staff. 

The review team verified that the Department’s inspection frequencies for all types of 

radioactive material licenses are similar or more frequent as similar license types listed in IMC 

2800, “Materials Inspection Program.” For the license categories established by the 
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Department, 56 of 115 are assigned inspection priority codes that prescribe a more frequent 

inspection schedule than those established in IMC 2800 for similar license types. 

The Department conducted 1,403 Priority 1, 2, and 3 inspections during the review period, 

based on the inspection frequencies established in IMC 2800. Seven of these inspections were 

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

2800. In addition, the Department performed 204 initial inspections during the review period, 

7 of which were conducted overdue. As required by IMC 2800, initial inspections should be 

conducted within 12 months of license issuance. The initial inspections were conducted late 

due to inspector vacancies or the licensee had not initiated use of radioactive material. 

According to Department staff, initial inspections are attempted within the first 12 months after 

the license is issued. The Department considers the initial inspection to be completed only after 

the licensee has initiated licensed activities which may exceed 12 months after the license has 

been issued. Overall, the review team calculated that the Department performed 2.9 percent of 

its inspections overdue during the review period. 

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

licensees. A sampling of 32 inspection reports indicated that none of the inspection findings 

were communicated to the licensees beyond the Department’s goal of 30 days after the 

inspection. 

During the review period, the Department issued 133 reciprocity permits, of which 41 were 

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

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

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

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

that Texas’ performance with respect to the indicator, Status of Materials Inspection Program, 

be found satisfactory. 

2.3 Technical Quality of Inspections

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

notes, and interviewed inspectors for 25 radioactive materials inspections conducted during the 

review period. The casework reviewed included inspections conducted by 16 Department 

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

institutions-therapy (high dose rate remote afterloader, unsealed radioiodine therapy, permanent 

or temporary implant brachytherapy), medical diagnostic, portable gauges, industrial 

radiography, self-shielded irradiators, nuclear pharmacy, manufacturing and distribution, well 

logging, and Increased Security Controls for Large Quantities of Radioactive Materials 

(Increased Controls). Appendix C lists the inspection casework files reviewed, with a 

case-specific comment, 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 
Texas Final IMPEP Report Page 6 

discussions held with licensees during exit interviews. The inspection procedures utilized by the 

Department 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 Quality 

Assurance reviewer. Supervisory accompaniments were conducted annually for all inspectors. 

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

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

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

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

inspection or a Notice of Violation (NOV), in letter format, which details the results of the 

inspection. When the Department issues an NOV, 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 Quality Assurance reviewer. 

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

support their inspection program. Appropriate, calibrated survey instrumentation, such as 

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

observed to be available. Instruments are calibrated at least annually, or as needed, by the 

Department with National Institute of Standards and Technology traceable sources. The 

Department uses a database to track each instrument, its current location, and next calibration 

date. 

Accompaniments of eight Department inspectors were conducted by two IMPEP team members 

between December 16, 2013, and January 29, 2014. The inspectors were accompanied during 

health and safety inspections of industrial radiography, medical therapy (high dose rate remote 

afterloader, gamma knife, unsealed radioiodine therapy/permanent implant brachytherapy), well 

logging, and medical diagnostic licenses. 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 Texas’ performance with respect to the indicator, Technical Quality of Inspections, be found 

satisfactory. 

2.4 Technical Quality of Licensing Actions

The review team examined completed licensing casework, pending complex license renewal 

applications that were over 1 year old, and interviewed license reviewers for 27 specific 

licensing actions and one registrant licensing action. 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 
Texas Final IMPEP Report Page 7 

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 and pending complex renewal actions. Licensing actions 

selected for evaluation included five new licenses, ten renewals (two complete and eight 

pending), four termination actions, six amendments, and three exemption requests. Files 

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

therapy including high dose rate remote afterloader and unsealed radioiodine therapy, 

accelerator and commercial distribution, industrial radiography, research and development, 

academic, nuclear pharmacy, gauges, source manufacturer, panoramic and self-shielded 

irradiators, tracer study service provider, well-logging, storage only, and radioactive waste 

broker. The casework sample represented work from nine fully-qualified license reviewers. A 

list of the licensing casework evaluated with a case-specific comment 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 

Radioactive Material Licensing Group regulatory guides and procedures, policies, checklists, 

and standard license conditions specific to the type of licensing actions to ensure consistency in 

licenses. 

All nine license reviewers have full signature authority for signing deficiency letters and 

follow-up letters. Three of the nine reviewers were also Program Coordinators. The Program 

Coordinators and/or Radioactive Material Licensing Group Manager perform a technical and 

supervisory review on all licensing actions. The Program Coordinators also sign the licenses 

before issuance to the licensee. In addition, the Radioactive Materials Licensing Group 

Manager was appointed to this position in April 2012. Prior to this time, he was a Program 

Coordinator and the review team looked at some of his licensing casework as part of the review. 

There are two additional personnel in the Radioactive Materials Licensing Group who are 

training to become fully qualified reviewers. Licenses are issued for a 10-year period under a 

timely renewal system. As of January 2014, the State had 1,578 specific licenses and 45 waste 

shippers and transporters. 

All licensing actions received by the Radioactive Materials Licensing Group are assigned a log 

number in the computer tracking system. The licensing action is then provided to one of the 

three Program Coordinators (medical/academic, industrial, or advanced technology) who assign 

the action to a license reviewer in their group. The license reviewer is responsible for reviews, 

deficiency letters, coordination and finalizing the licensing action. Deficiencies are typically 

communicated during a telephone call with the licensee and if there is no response, a formal 

deficiency letter is sent to the licensee. When a licensing action is complete, the respective 

program coordinator reviews the action for quality assurance and signs the licensing action. 
Texas Final IMPEP Report Page 8 

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

high quality and consistent with the Radioactive Materials Licensing Group licensing 

procedures, 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 license reviewers perform pre-licensing checks of all new applicants. The Radioactive 

Material Licensing Group’s pre-licensing review methods incorporate the essential elements of 

the NRC’s revised pre-licensing guidance to verify that the applicant will use requested 

radioactive materials as intended. The Radioactive Materials Licensing Group requests a 

pre-licensing site visit from the Radioactive Materials Inspection Group. All new unknown entity 

applicants 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 results of the 

visit are provided to the Radioactive Materials Licensing Group. 

The review team examined the Radioactive Materials Licensing Group’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 Radioactive Materials Licensing Group’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 Radioactive Materials Licensing Group 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 Radioactive Materials Licensing Group’s implementation of its 

Sensitive Information Policy for the control of sensitive information. This policy addresses the 

identification, marking, control, handling, preparation, storage, and transmission of documents 

that contain sensitive information related to the Increased Controls. The review team noted that 

the Radioactive Materials Licensing Group controls access to all of its licensing and inspection 

files via key-pad entry. 

The review team examined the list of pending license renewal actions that were over one year 

old. Renewals do not have a deadline or metric associated with their completion and therefore 

do not take priority over new applications or license amendments. Renewals that are in-house 

over 1 year old are all complex actions. The oldest action dates back to 2006 and the second 

oldest was from 2009. There were thirteen actions from 2010 and 2011, thirty-three actions 

from 2012, and seven actions from January 2013. There were 68 license renewals over a year 

old as of January 2013. In the last year, the Radioactive Materials Licensing Group’s Manager 

and Program Coordinators have prioritized and assigned these actions. License reviewers were 

able to initiate a review and in many cases, deficiency letters have been sent. In the interview 

with the Radioactive Materials Licensing Group’s Manager, he indicated that the combined 

effect of the changes implemented to address this backlog would reduce the backlog by 

approximately ten per month and anticipates that by June 30, 2014, the only renewals over one 

year old will be those where there has been difficulty obtaining satisfactory responses to 

deficiency letters. At the time of the MRB meeting, the Department reported that there were 47 

license renewals in backlog. The Department also reported that the Radioactive Materials 
Texas Final IMPEP Report Page 9 

Licensing Group has implemented a new metric for completing deficiency letters within 90 days 

of receipt of a renewal action. 

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

that Texas’ performance with respect to the indicator, Technical Quality of Licensing Actions, be 

found satisfactory. 

2.5 Technical Quality of Incident and Allegation Activities

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

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

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

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

casework for 23 radioactive materials incidents. A list of the incident casework examined may 

be found in Appendix E. The review team also evaluated the Department’s response to 11 

allegations involving radioactive materials, including 5 allegations referred to the State by the 

NRC during the review period. 

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

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

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

NMED. The incident investigation program staff determines the appropriate level of initial 

response to an incident or allegation. If an immediate response is warranted the incident 

investigation program manager is notified to make the decision about the appropriate level of 

response. 

The review team identified 262 radioactive material incidents in NMED for Texas during the 

review period of which 216 required reporting to the NRC. Four non-reportable incidents in 

NMED for Texas were reviewed for reportability and found to be correctly categorized as 

non-reportable by the Department. The review team selected 23 radioactive material incidents 

for evaluation. These incidents included the following types of events: lost/stolen radioactive 

material, potential overexposure, medical events, damaged equipment, equipment failure, and 

leaking sources. The Department’s responses to the incidents were found to be complete and 

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

commensurate with the potential health and safety significance of the event. Inspectors were 

dispatched for onsite investigations when appropriate. Enforcement and/or other regulatory 

actions were taken as appropriate. The Department reported events to the NRC in a prompt 

manner. The actions taken in response to incidents were documented and filed, and the data 

were submitted to the NRC’s contractor responsible for maintaining NMED for inclusion in the 

database. 

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

evaluated the casework for 11 allegations, including five that NRC referred to the State during 

the review period. The review team concluded that the Department took prompt and 

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

documented the investigations of concerns and retained all necessary documentation to 

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

conclusion of their investigations. The review team determined that Texas has open records 
Texas Final IMPEP Report Page 10 

laws that the Department has adopted when addressing complaints. Due to these laws, the 

Department cannot protect the identity of concerned individuals if there was an open records 

request about the particular complaint. Concerned individuals are informed of these laws. If the 

concerned individual does not provide identifying information, the concerns are kept anonymous 

and resolved without providing a written response about the State’s investigation to the 

concerned individual. The team determined that in cases where the concerned individual’s 

contact information is available, the Department provides a written response about the 

Department’s investigation and resolution of the concerns. 

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

that Texas’ performance with respect to the indicator, Technical Quality of Incident and 

Allegation Activities, be found satisfactory. 

3.0 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. All 

four non-common performance indicators applied to this review. 

3.1 Compatibility Requirements

Texas became an Agreement State in 1963. In assessing Texas’s compatibility requirements, 

the review team examined the Department’s and the Commission’s responses to the 

questionnaire relative to this indicator, reviewed the State Regulation Status (SRS) Data 

Sheets, that the Office of Federal and State Materials and Environmental Management 

Programs (FSME) maintains, for the Department and the Commission, and conducted 

interviews with managers responsible for this program area. 

3.1.1 Legislation

Both the Department and the Commission are granted legal authority through the Texas 

Radiation Control Act, Chapter 401 of the Texas Health and Safety Code. Chapter 401 outlines 

that the Department is the Texas Radiation Control Agency. It further outlines the jurisdictional 

authorities of the two agencies. For simplicity’s sake, the Department has jurisdiction over 

activities related to radiation and radioactive materials except for those activities that are under 

the jurisdiction of the Commission. The Commission has jurisdiction to license and regulate the 

disposal of radioactive materials, the recovery and processing of source material, the 

processing of tailings or waste produced by or resulting from the extraction or concentration of 

uranium or thorium from ore (11e.(2) byproduct material as defined in the Atomic Energy Act, as 

amended), the commercial processing or storage of radioactive waste, and sites for the disposal 

of low-level radioactive waste and byproduct material. The Commission is also affected by the 

Texas Low-level Radioactive Waste Disposal Compact, Chapter 403 of the Texas Health and 

Safety Code. Each agency is indirectly affected by many other Texas rules and legislation. 

The Department and the Commission developed and implemented a Memorandum of 

Understanding (MOU) in 1996. The MOU specified the respective responsibilities of the two 
Texas Final IMPEP Report Page 11 

agencies and stated that the Department and Commission agreed to work together to ensure 

that complete regulation is maintained for sources, uses, and users of radiation. The MOU also 

addressed certain operational functions of the two agencies, such as emergency preparedness, 

instrument calibration, and mutual assistance. Senate Bill 347 requires that the §289.101 

Memorandum of Understanding Between the Department of State Health Services and the 

Texas Commission on Environmental Quality Regarding Radiation Control Functions be 

updated. This rulemaking is underway and anticipated to be completed in August 2014. 

All Texas agencies are subject to sunset review by the Texas Sunset Commission. The next 

sunset review for the Department is anticipated to be within the year. The sunset review for the 

Commission has been completed. Additionally, State agencies are required to perform a review 

of each rule four years from the last effective date of the rule. 

3.1.2 Program Elements Required for Compatibility 

The review team examined the procedures used in the Department’s and the Commission’s 

regulatory processes. Both the Department and the Commission receive recommendations on 

proposed rulemaking from the Texas Radiation Advisory Board. The Department also 

coordinates its rulemaking through the State Health Services Counsel. During the review period 

the Department completed a standardization of its policies and procedures for rulemaking for all 

programs within the Department. Some rulemakings involve public meetings and both 

agencies’ rulemaking processes provide an opportunity for public/stakeholder comment on 

proposed regulations. The Department and the Commission provide any proposed or final rules 

for a compatibility review by the NRC. 

The Department’s rulemaking process often proposes and adopts rules in regulatory packages 

that are different from the NRC’s Review Summary Sheets for Regulation Amendments. This 

results in individual portions of the NRC rule changes being promulgated and adopted by the 

Department at different times. In addition, the Department often combines portions of the NRC 

rule changes into one rulemaking package. 

During the review period, the Department submitted five regulation packages to the NRC for 

review and comment. These packages addressed one proposed regulation amendment and 

four revisions to final regulations addressing all previous NRC comments as a result of the 

NRC’s compatibility reviews. Current NRC policy requires that Agreement States adopt certain 

equivalent regulations or legally-binding requirements no later than three years after they 

become effective. 

The following four packages were submitted overdue by the Department during the review 

period: 

• “Medical Use of Byproduct Material,” 10 CFR Parts 20, 32, and 35 amendment 

(67 FR 20249), that was due for Agreement State adoption on October, 24, 2005. 

• “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 on October 1, 2007.
Texas Final IMPEP Report Page 12 

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

15005), that was due for Agreement State adoption on March 27, 2009. 

• “Requirements for Expanded Definition of Byproduct Material,” 10 CFR Parts 20, 30, 31, 

32, 33, 35, 61, and 150 amendment (72 FR 55864), that was due for Agreement State 

adoption on November 30, 2010. 

The Department also provided a package containing equivalent regulations to 10 CFR Part 34 

and 39 not associated to a specific NRC rule change. The NRC reviewed the package and 

provided comments on January 11, 2012. 

The Department has initiated a rulemaking that it anticipates will be completed by November 

2014 that will address these outstanding comments. The Department will also address the NRC 

rule changes that are due in 2014 and 2015. At the time of this review, the Department did not 

have any overdue amendments. 

During the review period, the Commission sent seven regulation packages to the NRC for 

review and comment. These addressed two proposed regulation amendments and three 

revisions to final regulations addressing all previous NRC comments as a result of the NRC’s 

compatibility reviews. 

The following four packages were submitted overdue by the Commission during the reporting 

period: 

• “Increased Controls for Risk-Significant Radioactive Sources” (NRC Order EA-05-090) 

(70 FR 72128), that was due for Agreement State adoption on December 1, 2005. 

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

59162), that was due for Agreement State adoption on January 31, 2009. 

• “Requirements for Expanded Definition of Byproduct Material,” 10 CFR Parts 20, 30, 31, 

32, 33, 35, 61, and 150 amendments (72 FR 55864), that was due for Agreement State 

adoption on November 30, 2010. 

• “Occupational Dose Records, Labeling Containers, and Total Effective Dose Equivalent 

Parts 19, and 20 amendments (72 FR 68043), that was due for Agreement State 

adoption on February 15, 2011. 

At the time of this review, the following two amendments were overdue for adoption by the 

Commission: 

• “Radiological Criteria for License Termination of Uranium Recovery Facilities,” 10 CFR 

Part 40 (64 FR 17506), that was due for Agreement State adoption on June 11, 2002.1

 

1 Until final amendments are adopted , the Commission applies license termination criteria on a case by 

case basis The NRC has reviewed the two license terminations issued by the State, and determined that 

the lack of adoption of this amendment has not affected their ability to terminate these licenses. 
Texas Final IMPEP Report Page 13 

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

15005), that was due for Agreement State adoption on March 27, 2009. 

The Commission also provided a package containing equivalent regulations to 10 CFR Part 40 

not associated to a specific NRC rule change. The NRC reviewed the package and provided 

comments on October 3, 2013. 

The Commission intends to open both the uranium recovery and low level waste disposal 

regulations for changes in 2014. The Commission will address the one overdue NRC rule 

change and consider the NRC rule changes that are coming due in 2014 and 2015. 

A complete list of upcoming regulation amendments can be found on the NRC website at the 

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

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

that Texas’ performance with regard to the indicator, Compatibility Requirements, be found 

satisfactory. 

3.2 Sealed Source and Device Evaluation Program

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

Department’s performance regarding the Sealed Source and Device (SS&D) Evaluation 

Program. These subelements were (1) Technical Staffing and Training, (2) Technical Quality of 

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

In assessing the State’s SS&D evaluation activities, the review team examined the information 

provided in response to the IMPEP questionnaire and evaluated the SS&D registry sheets and 

supporting documents processed during the review period. The team also interviewed the staff 

currently conducting SS&D evaluations. 

3.2.1. Technical Staffing and Training

SS&D evaluation responsibilities are distributed amongst the license review staff. The staff is 

divided between industrial SS&D evaluations (Industrial Unit) and the medical SS&D 

evaluations (Medical Unit). 

The Department currently has five reviewers who are qualified to perform safety evaluations of 

SS&D applications. All have science degrees and have attended the NRC’s SS&D Workshop. 

The review team interviewed staff members involved in the reviews and determined that they 

were familiar with the procedures used in the evaluation of a source/device and had access to 

applicable reference documents. Subsequent to the onsite review, the Department sent two 

technical staff members, who are undergoing qualification, to the NRC SS&D Workshop in 

March 2014. The SS&D staffing level and education qualifications for the current staff were 

evaluated and were found adequate. 
Texas Final IMPEP Report Page 14 

3.2.2 Technical Quality of the Product Evaluation Program

The review team evaluated 16 of the 56 SS&D evaluation amendments, inactivations, and new 

registrations, which included custom evaluations issued by the Department during the review 

period, representing the work of nine SS&D reviewers (five active reviewers and four former 

reviewers). The cases selected for review were representative of the Department’s licensees 

and SS&D reviewers throughout the reporting period. The Department stated that they manage 

200 active SS&D registrations. A list of SS&D casework examined, with case-specific 

comments, can be found in Appendix F. 

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

information contained in the Department’s response to the IMPEP questionnaire for this 

indicator and interviewed program staff and managers. The review team confirmed that the 

Department follows the recommended guidance from the NRC’s SS&D workshop, 

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

standards, ISO-9001, and Texas Regulatory Guides. The review team verified that these 

documents were available and used appropriately in performing SS&D reviews. 

During the review of casework, the review team determined that the Department did not ensure 

in three cases (of all SSD registrants in Texas) that the foreign manufacturer/distributor had a 

radioactive materials license, per Texas regulations, or an import/export license. The licensees 

possessed specific licenses to distribute in Texas; however, there was no reference in the 

SS&D files regarding the import/export conditions in the license or the conditions that allowed 

the licensee to manufacture and distribute from abroad. This issue was discussed with the 

Department, and the Department determined that this was an oversight. The Department 

committed to implementing measures to correct these files. The review team concluded that the 

issue was not a public health and safety concern and was not generic in nature. Subsequent to 

the onsite review, the Department informed the review team that all three licensees had an NRC 

exemption to import/export the devices. 

The Department performed evaluations based on sound conservative assumptions to ensure 

public health and safety was adequately protected. Deficiency letters clearly stated regulatory 

positions and all health and safety issues were addressed. The review team determined that 

product evaluations were thorough, complete, consistent, and adequately addressed the 

integrity of the products during use and in the event of accidents. 

3.2.3 Evaluation of Defects and Incidents Regarding SS&Ds

There were no incidents related to SS&D defects involving sources or devices registered by the 

State of Texas during the review period. Utilizing NMED, the review team determined that there 

were no incidents involving SS&D registered products reported during the review period. 

Incident procedures are in place should an SS&D related incident occur. Department managers 

are aware of the need to look at such incidents as potentially generic in nature with possible 

wide-ranging effects. 

The review team did not identify any allegations received by the Department related to defects 

or failures of SS&D products registered in Texas during the review period.
Texas Final IMPEP Report Page 15 

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

that Texas’ performance with respect to the indicator, Sealed Source and Device Evaluation 

Program, be found satisfactory. 

3.3 Low-Level Radioactive Waste Disposal Program 

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

performance regarding the LLRW disposal program. These subelements were (1) Technical 

Staffing and Training, (2) Status of LLRW Disposal Inspection, (3) Technical Quality of 

Inspections, (4) Technical Quality of Licensing Actions, and (5) Technical Quality of Incident and 

Allegation Activities. 

The regulatory responsibility for the LLRW disposal program resides with the Commission. The 

Radioactive Materials Licensing Section, located within the Radioactive Materials Division of the 

Office of Waste, is responsible for the licensing of LLRW disposal and processing activities. 

The inspection responsibility for LLRW disposal activities is in the Office of Compliance & 

Enforcement, Critical Infrastructure Division, Homeland Security Section, Radioactive Materials 

Compliance Team (Compliance Team.) The final pre-operational inspections of the Waste 

Control Specialists, LLC (WCS) LLRW disposal facility, located in Andrews, Texas, occurred on 

April 25, 2012. The facility received its first waste disposal shipment on April 27, 2012. Since 

the 2010 IMPEP review, the Commission has issued 23 amendments to the WCS LLRW 

disposal facility license. 

3.3.1 Technical Staffing and Training

The Radioactive Materials Licensing Section currently has seven full-time and/or part-time staff 

members with a staffing effort of 5 FTE being used for the LLRW disposal program. The FTE 

total includes support by the Uranium Section. Staff supporting the LLRW program includes the 

Division Director, Radioactive Materials Licensing Manager, health physicists, engineers, 

geologists, and an administrative assistant. The Compliance Team has two full-time onsite 

LLRW inspectors and two main office inspectors that are shared with the uranium recovery 

program for a total of 2.4 FTE dedicated to the LLRW inspection program. In addition, 

approximately 1.1 FTE is assigned to the management oversight of the Compliance Team for 

the LLRW inspection and compliance activities. During the review period, six staff joined the 

Radioactive Materials Licensing Section and two inspectors joined the Compliance Team. The 

LLRW program also had seven staff leave the program. At the time of the review, the 

Radioactive Materials Licensing Section had two vacancies (one health physicist and one 

engineer position). The Compliance Team did not have any vacancies at the time of the review. 

During the initial licensing and construction reviews of the LLRW disposal site, staff from the 

Uranium Section was temporarily assigned to the Radioactive Materials Licensing Section to 

support this higher priority work. In addition, contractors were also utilized for technical support 

during the review period. Contractors provided assistance in the areas of socioeconomics, 

ecology, and civil engineering. No contractors are being used at this time. 

 

The review team discussed with the Commission the current workload of the Compliance Team 

inspectors who perform inspections at the LLRW disposal site, the waste processing facility, and 

the uranium recovery facilities. Although fully staffed according to the staffing plan, since
Texas Final IMPEP Report Page 16 

 operations began at the LLRW disposal site, the inspection workload has challenged the staff 

to perform timely and comprehensive inspections. The review team is concerned that any 

losses in staff or increases in workload could severely impact the State’s performance in the 

LLRW and/or uranium recovery inspection functions. The review team recommends that the 

Commission develop and implement a strategy to address staffing in the LLRW and uranium 

recovery inspection programs in order to enhance the effectiveness and efficiency of the 

Program. Additional information on this issue is provided in Section 3.3.2, Status of LLRW 

Inspection Program, and Section 3.4.2, Status of Uranium Recovery Inspection Program. 

The review team examined the training records of the technical staff and found them up to date 

and complete. The review team determined that the current staff has the right balance of 

technical expertise and is adequate to maintain the quality and performance of the LLRW 

program. Through interviews with the technical staff and program managers, combined with an 

evaluation of training and experience, the review team concluded that the Commission staff is 

qualified to carry out regulatory duties for licensing and inspection of the LLRW site. 

3.3.2 Status of Low-Level Radioactive Waste Disposal Inspection Program

The review team focused on three factors while reviewing this indicator. These include the 

inspection frequency, overdue inspections or any deviations from the schedule, and timely 

dispatch of inspection findings to the licensee. The review team’s evaluation was based on the 

Commission’s questionnaire response relative to this indicator, examination of inspection 

casework, and interviews with Commission management and staff. 

Prior to receipt of waste shipments, the Commission performed pre-operational inspections at 

the LLRW disposal site. The site received its first waste shipment on April 27, 2012. The 

Commission performed an inspection of licensee activities during the first waste shipment and 

considers this inspection to be the initial inspection of the LLRW disposal site. Based on 

discussions with Commission managers and staff, the review team determined that this 

inspection was limited to a review of waste receipt and disposal activities, was not documented 

as a routine inspection, and did not include an inspection of other licensee activities that would 

be reviewed during a routine health and safety inspection, such as the licensee’s radiation 

protection and environmental compliance programs. Therefore, the review team did not 

consider the April 2012 inspection to be an initial inspection of the LLRW disposal site and 

concluded that an initial inspection of the LLRW disposal site was not performed within 12 

months after operations began. In addition, the review team determined that, as of the date of 

the onsite review, no overall health and safety inspection for the LLRW disposal site license had 

been conducted since operations commenced. However, resident inspectors provide a daily 

presence to ensure the protection of public health and safety. The Compliance Team 

conducted routine inspections of the radioactive waste processing license in 2010, 2011, 

 and 2013. The waste processing license was not inspected in 2012. 

Commission inspectors perform inspection close out meetings with the licensee management to 

discuss findings and concerns. Letters to licensees are only issued if cited violations are 

identified. The review team noted issuance of written inspection reports varied from less than 

one month to six months and are sent to the licensing section to be placed in the licensing file. 
Texas Final IMPEP Report Page 17 

3.3.3 Technical Quality of Inspections 

The review team assessed the quality of LLRW disposal program inspections by evaluating 

inspector performance during the accompaniments and reviewing inspection field notes, 

completed reports, inspection procedures and the staff’s follow-up to previous inspection 

findings, as well as regulatory actions taken, annual supervisory accompaniments, and available 

instrumentation. 

The Compliance Team maintains two onsite resident inspectors at the WCS LLRW disposal site 

that perform inspections of the incoming waste shipments and disposal operations and two 

inspectors at the main office that perform the overall health and safety inspections of the 

radioactive materials license and radiation safety program at the LLRW site and adjacent waste 

processing facility. The Radioactive Material Licensing Section oversees the review of financial 

assurance, engineering reports, and environmental monitoring reports for the LLRW disposal 

site. The environmental staff visits the facility annually to review the environmental monitoring 

program. The engineering staff does not perform onsite engineering inspections. The resident 

inspectors provide information, including photos of certain aspects of construction or other 

related engineering activities based on their observations, to the engineering staff in the main 

office. 

On January 29–30, 2014, two review team members accompanied two onsite resident 

inspectors at the LLRW disposal site, as indicated in Appendix C. Since no shipments arrived 

at the LLRW site during the accompaniments, the onsite resident inspectors performed a 

simulated inspection. The inspectors were well prepared and thorough during the limited 

accompaniment. The inspectors demonstrated appropriate performance-based inspection 

techniques and knowledge of the regulations. The review team found the inspections were 

adequate to assess the safety and radiological hazards at the LLRW disposal site during waste 

receipt and disposal operations. 

Based on an evaluation of six inspection files for waste shipments to the WCS LLRW disposal 

site, the review team determined that these inspection reports were thorough, complete, 

consistent, and had sufficient documentation to ensure that licensee’s waste receipt and 

disposal practices were acceptable with respect to health, safety and security. The review team 

noted there were no documented inspection reports for the overall LLRW disposal site license. 

Therefore, the review team was unable to determine the technical quality of the overall LLRW 

site inspections. The review team discussed with the Commission staff the importance of 

having an inspection report completed annually for each overall inspection of the LLRW license 

in order to ensure all aspects of a licensee’s LLRW disposal program are inspected and open 

items are addressed or followed up on subsequent inspections, and providing feedback to the 

licensing staff on potential amendments to the LLRW license. 

Four inspection reports for the waste processor license were reviewed. The review team noted 

that the 2013 inspection of the waste processing facility was documented using a pre-drafted 

report format that did not clearly identify the scope of the inspection and was being finalized 

during this onsite review. 
Texas Final IMPEP Report Page 18 

The review team noted that the Commission has a basic inspection guideline and template 

report forms for the onsite resident inspections and the overall LLRW inspections. The 

Commission has not yet developed comprehensive inspection procedures to support the overall 

LLRW inspection program. The overall inspection report template is a general, pre-drafted, 

semi-completed inspection report that does not clearly identify the scope of the inspection or 

document all the appropriate health and safety issues. The review team recommends that the 

Compliance Team, in coordination with the Radioactive Materials Section, develop detailed 

inspection procedures for LLRW inspections to provide feedback to the LLRW program and 

enhance the inspection program. 

Based on a review of inspection casework and discussions with inspection staff, the review 

team determined that inspectors either followed up on previous inspection findings during the 

subsequent inspection or dispositioned the findings as escalated enforcement actions. The 

review team noted that completion of inspection reports varied from less than one month to over 

six months, with supervisor review occurring in a timely fashion after report completion. 

Commission staff had adequate numbers and varieties of calibrated instruments to perform 

inspections. 

In accordance with IMC 2800, increased controls inspections are required to be performed at 

the same frequency/priority as the routine health and safety inspection. The review team noted 

that a routine increased controls inspection of the radioactive waste processor license occurred 

in January 2010; however, no subsequent routine increased controls inspections have been 

conducted of either the waste processing or disposal site license. The onsite resident 

inspectors oversee all waste receipts and disposal operations and ensure the increased controls 

plan is implemented when required; however, this inspection is limited to waste disposal 

operations and does not include review of other aspects of the licensee’s increased controls 

program (e.g., trustworthiness and reliability determinations). Additionally the inspection is not 

documented. The review team discussed with the Commission staff the need to perform routine 

increased controls inspections at the same inspection frequency/priority as the routine LLRW 

health and safety site inspection. Subsequent to the onsite review, the Commission informed 

the review team that the Commission conducted a routine increased control inspection at the 

LLRW facility in May 2014. 

Supervisor accompaniments were conducted annually for all inspectors, with the exception of 

one inspector who received only one supervisor accompaniment during the review period. The 

review team discussed with the Commission the need for a supervisory accompaniment of all 

LLRW inspectors during an inspection of the LLRW facility. 

3.3.4 Technical Quality of Licensing Actions 

The team reviewed a selection of licensing actions that were completed during the review 

period, including financial assurance reviews, and engineering and environmental monitoring 

amendments. A listing of the licensing casework reviewed, with a case-specific comment, can 

be found in Appendix D. 

Since the last IMPEP review the Radioactive Materials Licensing Section issued 23 

amendments to the LLRW license, including an amendment on July 24, 2013, that merged the 

WCS waste processing license with the LLRW disposal license. The Commission hired 
Texas Final IMPEP Report Page 19 

technical consultants to address certain complex technical issues when needed, and generated 

technical summaries of all licensing actions that include details regarding the review and 

decision process. The license conditions, including the tie-down conditions, were stated clearly, 

supported by information contained in the file, and were enforceable. The Radioactive Materials 

Licensing Section used independent analyses and actively solicited public comments during the 

licensing amendment process through public hearings. The review team determined that 

Texas’ licensing process was thorough, complete, consistent, and of acceptable technical 

quality. The review team found that health and safety issues were properly addressed as part 

of the licensing process. 

The review team evaluated a sample of the performance assessment models and associated 

documents for licensing and license amendment actions. Based on a review of licensing 

documents, the review team determined that the Commission’s licensing staff asked appropriate 

technical questions on risk-significant topics. The licensing staff documented their acceptance 

or rejection of the responses and communicated the results to the licensee. The review team 

determined that Texas’ licensing process was thorough, complete, consistent, and of acceptable 

technical quality. The review team found that health and safety issues were properly addressed 

as part of the licensing process. 

The review team examined the financial surety proposed for the LLRW facility. Per license 

condition, discrete financial surety amounts for several categories (e.g., decommissioning, 

closure, and post-closure) are stated. The review team determined that Texas adequately 

addressed the financial surety component of the license. 

3.3.5 Technical Quality of Incident and Allegation Activities 

The review team found that the Commission had procedures in place for handling incidents 

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

an incident, appropriate documentation of the incident, reference to NRC abnormal occurrence 

criteria, and incident tracking. The procedures for handling allegations include information on 

protecting the identity of the alleger, documentation of the allegation, and allegation tracking. 

During the review period, the State reported no events to the NRC and addressed two 

allegations involving LLRW disposal program activities. One of the allegations was referred by 

the NRC and resolved with NRC support, and the second allegation was submitted directly to 

the Commission. The review team determined that the Commission took prompt and 

appropriate action for both allegations. The review team noted that all documentation related to 

the investigation of the allegations was complete and appropriately maintained in a separate file. 

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

that Texas’ performance with respect to the indicator, Low-Level Radioactive Waste Disposal 

Program, be found satisfactory. 

3.4 Uranium Recovery Program 

In reviewing this indicator, the review team used five subelements to evaluate the State’s 

performance regarding the uranium recovery program. These subelements were (1) Technical 

Staffing and Training, (2) Status of Uranium Recovery Inspection Program, (3) Technical Quality 
Texas Final IMPEP Report Page 20 

of Inspections, (4) Technical Quality of Licensing Actions, and (5) Technical Quality of Incident 

and Allegation Activities. 

The Texas uranium recovery program has been implemented by the Commission since 2007 

when the program was transferred from DSHS’s authority to the Commission. The licensing 

and permitting program for uranium recovery is divided between two sections in the Radioactive 

Materials Division, the Uranium Section and the Underground Injection Control (UIC) Permits 

Section. 

The Uranium Section has jurisdiction for the licensing of the above ground processes at 

licensed sites, including the review of the design and construction of all infrastructure and fluid 

transmission lines, operation, record keeping, maintenance, decommissioning (except ground 

water restoration), decontamination, and surface reclamation. The Uranium Section issues a 

radioactive materials license for uranium recovery in-situ recovery (ISR) or conventional mill 

sites. The Uranium Section also is responsible for ground water protection for conventional mill 

sites. 

The Texas uranium recovery program implements its ground water protection program 

responsibilities for ISR facilities through the UIC permit program under the Commission’s 

equivalent regulations to Appendix A of 10 CFR Part 40. The UIC Permits Section implements 

its ground water protection program, restoration and liquid 11e.(2) byproduct waste disposal 

program, through permitting of all Class III uranium recovery wells, Class I waste disposal wells 

and associated surface impoundments at a uranium recovery ISR facility under the 

U.S. Environmental Protection Agency (EPA) UIC program, for which the State has primacy. 

The Class I disposal well permits also include all earthen impoundments and/or tanks defined 

as Pre-Injection Units (PIUs) used to store fluid 11e.(2) byproduct material before injection. 

Each uranium recovery ISR site has a radioactive materials license, a base UIC permit, one or 

more production area permits and one or more Class I disposal well permits which include the 

PIUs. 

The inspection and enforcement of both the radioactive materials licenses and the UIC permits 

are done through the Office of Compliance and Enforcement, Critical Infrastructure Division, 

Homeland Security Section, Radioactive Materials Compliance Team. The inspectors in this 

section perform separate radioactive material license inspections and UIC permit inspections. 

The inspection of the Class I wells and pre-injection units (earthen impoundments or tanks) 

have been performed by the UIC regional offices since 2013. 

At the time of this IMPEP review, the Texas uranium recovery program consisted of eleven 

active radioactive material licenses and one revoked license. Three of the licenses are for 

conventional mills currently under decommissioning. One license is for disposal of 11e.(2) 

byproduct material from others. The uranium recovery program has seven in-situ recovery 

licenses: two licenses in “standby” status; one license in active production; one license for resin 

processing only, and three licenses are approved but not in operation. One ISR license 

received NRC approval and has been terminated by the State. One site with a revoked license 

has not completed decommissioning and the financial surety for the site is in litigation. 
Texas Final IMPEP Report Page 21 

3.4.1 Technical Staffing and Training

 

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

of the staff, staff training, and staff turnover. 

The Uranium Section staffing level currently consists of five technical staff and one full time 

manager. There are no vacant positions. The Uranium Section staff has expertise in various 

technical disciplines including health physics, geology, hydrology, and engineering. A civil 

engineer from the Radioactive Material Licensing Section is occasionally utilized for licensing 

actions. Expertise in socioeconomics and ecological assessment is provided by contractors as 

needed. All staff but one has a professional registration and/or an advanced degree. Uranium 

Section staff receive yearly training through web-based courses, private or NRC courses, 

attendance at professional meetings and memberships in professional societies or working 

groups. Staffing levels have dropped throughout the IMPEP review period from eleven to six. 

Several staff members have been reassigned to the Radioactive Materials Section to support 

the high priority work on the LLRW disposal site. Staff indicated that they had deferred licensing 

actions because they were assigned higher priority work. The Division management indicated 

that an engineer will be reassigned to the Uranium Section when the engineering vacancy in the 

Radioactive Materials Section is filled. 

The UIC Permits Section staffing level is currently at nine staff and one full time manager. The 

section manager is new since the last IMPEP review. Four staff left the program during the 

IMPEP review period and five new employees were hired. This represents an increase of one 

position since the last IMPEP review. There are currently two vacant positions, one engineering 

position and one administrative position. Interviews for these positions were being conducted at 

the time of this review. The technical staff has various degrees of involvement in the uranium 

recovery program. Most staff members are associated with Class III permitting and one staff 

member does Class I permitting full time. The UIC Permits Section staff has expertise in 

various technical disciplines including geology, hydrology, and engineering. Interviews with staff 

indicate all possess professional licenses. The UIC staff receives yearly training through 

web-based courses, private or NRC courses, attendance at professional meetings and 

memberships in professional societies or working groups. 

The Homeland Security Section staffing level for uranium recovery is currently at one full-time 

manager and two uranium recovery inspectors. These inspectors also perform the inspections 

at the LLRW disposal site. Approximately 0.70 FTE is assigned to uranium recovery 

inspections, which is shared between the two inspectors. In addition, about 0.45 FTE is 

assigned to the management oversight of the uranium recovery inspection and compliance 

activities. Staffing levels have not changed since the last IMPEP review. There are no vacant 

positions. The staff conducts separate inspections for the UIC permits and radioactive materials 

licenses at uranium recovery facilities. One inspector is fully trained to perform UIC permits 

inspections. The second inspector is being trained to perform UIC inspections and has 

conducted limited UIC permit inspections. Both inspectors conduct the radioactive materials 

license inspections. 

Three ISR licenses not yet constructed may go into operation in the future, which may place 

additional strain on the uranium recovery inspectors. The Commission currently does not plan 

to hire or train a new inspector. The review team is concerned that any losses in staff or 

increases in workload could severely impact the State’s performance in the uranium recovery 
Texas Final IMPEP Report Page 22 

inspection and/or LLRW inspection functions. As discussed previously in Section 3.3.1, the 

review team recommends that the Commission develop and implement a strategy to address 

staffing in the LLRW and uranium recovery inspection programs in order to enhance the 

effectiveness and efficiency of the Program. 

 

3.4.2 Status of Uranium Recovery Inspection Program 

In reviewing this subelement, the review team evaluated the inspection frequency for uranium 

recovery licensees and the timeliness of inspection finding communications to the licensees. 

The review team's evaluation is based on Texas’ response to the questionnaire relative to this 

indicator, the uranium recovery inspection schedule, selected inspection casework files, and 

interviews with inspection staff and managers. 

During the review period, the Commission maintained 12 active licenses: three conventional 

mills in decommissioning, two in-situ recovery licenses in decommissioning, one active but 

non-production in-situ recovery license, two active in-situ recovery licenses, one 11e.(2) 

commercial disposal facility, and three new in-situ recovery facilities which have not begun 

operations. Uranium recovery licensees are inspected separately for radiation safety and the 

UIC program which ensures ground water compliance. 

During the review period, the inspection staff missed 14 of 20 UIC permit inspections and ten of 

44 routine annual radioactive material license inspections. During discussions between the 

review team, Commission managers and uranium recovery inspectors, the Commission 

indicated that they had deferred inspections due to the higher than anticipated workload 

required in preparation for the start of operations at the LLRW disposal site in 2012. 

Based on information provided by the Commission, the review team determined that there were 

no currently overdue radiation safety inspections in the Uranium Mills program. 

The Commission’s procedure requires that inspection findings are communicated to a licensee 

during the exit meeting at the end of the inspection. A written report is generated for each 

inspection and provided to the licensee only upon request. The review team noted that 

inspection reports were not reviewed by management within 30 days of the inspection, as 

specified in Sections 1.6 and 1.7 of the Commission’s Radioactive Materials Compliance 

Investigation Guidance. 

3.4.3 Technical Quality of Inspections 

In reviewing this subelement, the review team examined inspection reports for 14 inspections 

conducted by the Commission during the review period and accompanied inspectors on one 

inspection at a licensed facility. The cases selected for review represented a range of 

uranium recovery licensing activities in different stages of operation. The review team 

interviewed inspectors and managers to assess the adequacy of their preparation for the 

inspections, guidance and/or protocols for inspection procedures, the depth and content of the 

actual inspections, and the appropriateness of inspection findings. A listing of the inspection 

casework reviewed can be found in Appendix C. 
Texas Final IMPEP Report Page 23 

The inspector accompaniments and casework reviews confirmed that Commission radiation 

safety inspections were thorough, included operational and record reviews, and violations were 

communicated by the inspector to the licensee during exit interviews. The inspectors focused 

on interviews with licensee personnel, performed confirmatory radiation surveys, and viewed 

operations in progress. The review team noted that power failure procedures, environmental 

monitoring results, and ground water reports are not reviewed as part of the inspection 

program. The Commission has implemented the semi-annual environmental monitoring 

reports by license condition. The reports are submitted to the Uranium Section for review. 

Inspections for radiation safety compliance were performed in accordance with IMC 2801, 

“Uranium Mill and 11e.(2) Byproduct Material Disposal Site and Facility Inspection Program,” 

and IMC 2641, “In-Situ Leach Facilities Inspection Program” requirements, with one exception. 

IMC 2801 and IMC 2641 state that a pre-operational inspection should be conducted prior to 

startup of new facilities; however, the Commission did not perform pre-operational inspections 

prior to startup of new facilities and has no equivalent guidance for inspection frequency or 

inspection report content of the ground water compliance program to ensure health and safety 

are protected. 

The licensing and permitting staff, with the geohydrology and engineering technical expertise, 

does not routinely accompany the inspection staff who have health physics expertise during 

routine inspections. A multidisciplinary inspection team would be able to conduct a more 

comprehensive technical inspection for the uranium recovery facilities. The feedback of 

compliance information to the licensing staff would be enhanced and the inspectability of license 

conditions enhanced with licensing staff participation in certain inspections. Both the UIC 

Permits Section and the Uranium Section staff use a form titled “Compliance History Report” to 

provide compliance and enforcement history to permitting and licensing staff. During interviews 

with staff, the review team determined that the staff was conducting inspections that address 

appropriate health and safety issues. However, the review team determined that the 

documented information was incomplete based on a discussion with the compliance staff and 

the licensing/permitting staff. Information on the conditions at the sites identified during 

inspections is not timely communicated to the licensing/permitting staff. The review team 

recommends that the Compliance Team, in coordination with the UIC Permits Section and the 

Uranium Section, develop detailed inspection procedures for uranium recovery inspections to 

provide feedback to the uranium recovery program and enhance the inspection program. 

The review team found that the inspection reports provided appropriate depth of coverage, 

addressed license conditions, and demonstrated that the inspector pursued corrective actions 

for items of noncompliance that were identified. Inspection files contained photographs 

documenting both general facility features and items of interest or concerns. 

3.4.4 Technical Quality of Licensing Actions 

For this subelement, the review team examined files and associated documentation related to 

UIC permitting and radioactive material licensing of in-situ recovery and conventional mill 

facilities, license amendment files, financial assurance instruments and other licensing 

documentation. Appendix D lists the licensing files reviewed. 

For the conventional mills, the team reviewed six licensing actions which were completed during 

the review period and consisted of license renewal, annual financial assurance updates, 
Texas Final IMPEP Report Page 24 

compliance monitoring, and post-decommissioning monitoring for ground water compliance. 

For in-situ recovery facilities, the team reviewed eight licensing actions which were completed 

during the review period consisting of license amendments, license renewal, annual financial 

updates and project area authorizations, conventional mill site visits, and ground water and 

health physics monitoring reviews. 

The IMPEP review team conducted interviews with the UIC Permits Section team and Uranium 

Section radioactive material licensing teams to inquire about the application submittal, review 

and license/permit issuance process. Both sections used checklists to meet and verify licensing 

and permitting action milestones had been met. The UIC Permits Sections used the 

“Administrative and Technical Evaluation Checklist, Class III UIC Production Area Authorization 

(PAA) Application” to ensure administrative and technical completeness. The UIC permit staff 

then used the “Class I and Class III UIC Permit Application Process Schedule” to track timely 

execution of all actions. These actions included notices of deficiency (NOD), responses to 

NODs, issuance of the draft permit, public notice and comment periods, notice of public hearing 

opportunity and finalization of the permit. All actions have set time periods for execution. 

The Uranium Section radioactive material license team used the “Uranium License Review 

Sheet” to review and track execution of all licensing actions. These actions included reviews for 

administrative and technical completeness, assignment of review team members, process 

engineering review, hydrology review, structural review concerns, multiple notices of deficiency 

(NOD), reviews of responses to NODs, preparation of the draft license, public notice and 

comment periods, notice of public hearing opportunity and finalization of the license. The 

review sheet is a comprehensive document which contains substantial technical comments by 

all license reviewers and dates of execution for all actions. 

According to the Commission, all three conventional uranium mill licenses are in renewal. 

Uranium Section license staff stated that none of the conventional milling licenses will be 

renewed since all are in decommissioning. Four of the seven active ISR uranium milling 

licenses are in renewal. Uranium Section licensing staff indicated that several staff were 

reassigned for other priorities (WCS LLRW disposal site license application) which has delayed 

the completion of these licenses renewals. Staff expects to reduce the ISR license renewal 

backlog in the future given the expected workload. 

The review team discussed with the Commission the status of one license which was revoked in 

2003 for nonpayment of fees. The ISR wellfields at both sites have been fully restored but the 

surface contamination has not been cleaned up. The licensee abandoned the site in 2006 with 

limited funds remained in the financial trust. The trust is now under litigation and no funds are 

currently available for maintaining or decommissioning the site. A gamma survey was 

performed on both sites in 2012 which confirmed the sites are contaminated. Neither site is 

properly posted or secured according to discussions with Commission staff and observations of 

the site made by NRC staff. Subsequent to the onsite review, the Commission noted that signs 

had been posted during the last Commission review of the site; however, theft of the radiological 

signage has been an ongoing problem at this location. The Commission has issued a letter to 

the owner and the licensee informing them they are still responsible for decommissioning and 

securing the sites. The owner and licensee sued the Commission over the letter. The IMPEP 

review team discussed with the Commission staff their responsibility to protect the public health 

and safety at the site. Commission management is working on a path forward for the site.
Texas Final IMPEP Report Page 25 

All licensing and permitting actions related to amendments, site monitoring visits at 

conventional uranium mills, financial assurance and radioactive effluent and ground water 

monitoring reviews were found to be of high quality and consistent. As noted in Section 3.3.4, 

the feedback loop on existing ISR site infrastructure, inspections and operating issues used to 

inform future licensing and permitting actions needs to be enhanced. 

3.4.5 Technical Quality of Incident and Allegation Activities

 

For this subelement, the review team interviewed the inspection personnel involved with 

incident and allegation activities and reviewed procedures. There were no incidents or 

allegations during the IMPEP review period for the team to evaluate. The Commission has 

incident response procedures that adequately address the actions required. 

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

that Texas’ performance with respect to the indicator, Uranium Recovery Program, be found 

satisfactory. 

4.0 SUMMARY 

As noted in Sections 2.0 and 3.0 above, Texas’ performance was found satisfactory for all 

performance indicators reviewed. The review team made three recommendations regarding 

program performance by the State. 

Accordingly, the review team recommended, and the MRB agreed, that the Texas 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 review team’s recommendations, as mentioned in the report, for evaluation and 

implementation by the State: 

RECOMMENDATIONS: 

1. The review team recommends that the Commission develop and implement a strategy to 

address staffing in the LLRW and uranium recovery inspection programs in order to 

enhance the effectiveness and efficiency of the Program. (Sections 3.3.1 and 3.4.1) 

2. The review team recommends that the Compliance Team, in coordination with the 

Radioactive Materials Section, develop detailed inspection procedures for LLRW 

inspections to provide feedback to the LLRW program and enhance the inspection 

program. (Section 3.3.3) 

3. The review team recommends that the Compliance Team, in coordination with the UIC 

Permits Section and the Uranium Section, develop detailed inspection procedures for 

uranium recovery inspections to provide feedback to the uranium recovery program and 

enhance the inspection program. (Section 3.4.3) 
LIST OF APPENDICES 

Appendix A IMPEP Review Team Members 

Appendix B Texas Organization Charts 

Appendix C Inspection Casework Reviews 

Appendix D License Casework Reviews 

Appendix E Incident Casework Reviews 

Appendix F Sealed Source and Device Casework Reviews 
APPENDIX A 

IMPEP REVIEW TEAM MEMBERS 

Name Area of Responsibility

Donna Janda, Region I Team Leader 

 Technical Staffing and Training 

 Inspector Accompaniments 

Robert Hays, Region III Status of Materials Inspection Program 

 Technical Quality of Inspections 

 Inspector Accompaniments 

Kathy Modes, Region I Technical Quality of Licensing Actions 

Binesh Tharakan, Region IV Technical Quality of Incident and Allegation 

Activities 

Stephen Poy, FSME Compatibility Requirements 

 Sealed Source and Device Evaluation Program 

Dennis Sollenberger, FSME Technical Staffing and Training 

 Compatibility Requirements 

David Esh, FSME Low-Level Radioactive Waste Disposal Program 

 Inspector Accompaniment 

Kristen Schwab, State of Washington Low-Level Radioactive Waste Disposal Program 

 Inspector Accompaniment 

Linda Gersey, Region IV Uranium Recovery Program 

 Inspector Accompaniment 

Elise Striz, FSME Uranium Recovery Program 

 Inspector Accompaniment 
APPENDIX B 

TEXAS ORGANIZATION CHARTS 

ADAMS ACCESSION NO.: 

ML14070A073 – Texas DSHS 

ML14070A065 – Texas CEQ
 

 APPENDIX C 

INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

Texas Department of State Health Services

File No.: 1 

Licensee: Rio Grande Nuclear Pharmacy License No.: L06362 

Inspection Type: Initial, Announced Priority: 2 

Inspection Date: 2/16/11 Inspector: GG 

File No.: 2 

Licensee: Sightline West Houston IMRT, LLC License No.: L06299 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 4/19/11 Inspector: HA 

File No.: 3 

Licensee: Non Destructive Inspection Corp. License No.: L02712 

Inspection Type: Routine, Special, Announced Priority: 1 

Inspection Date: 9/20/12 Inspector: RH 

File No.: 4 

Licensee: Baylor University Medical Center License No.: L01290 

Inspection Type: Routine, Special, Announced Priority: 2 

Inspection Date: 11/15/11 Inspector: SS 

File No.: 5 

Licensee: Gammatron License No.: L02148 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 6/10/13 Inspector: RP 

File No.: 6 

Licensee: Team Industrial Services, Inc. License No.: L00087 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 8/29/13 Inspector(s): AT, ES 

File No.: 7 

Licensee: Allied Wireline Services License No.: L06374 

Inspection Type: Special, Unannounced Priority: 3 

Inspection Date: 1/17/13 Inspector: RW 

File No.: 8 

Licensee: Medicine and Radiation Oncology, PA License No.: L06503 

Inspection Type: Initial, Unannounced Priority: 2 

Inspection Date: 6/18/13 Inspector(s): RW, JD 
Texas Final IMPEP Report Page C.2

Inspection Casework Reviews 

File No.: 9 

Licensee: IsoRx Texas, LTD License No.: L05284 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 6/6/11 Inspector: ES 

File No.: 10 

Licensee: Blood Systems, Inc. License No.: L05841 

Inspection Type: Special, Announced Priority: 3 

Inspection Date: 7/20/11 Inspector(s): GG, ES 

File No.: 11 

Licensee: Doctor’s Hospital at Renaissance, LTD License No.: L05761 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 4/18/12 Inspector: JC 

File No.: 12 

Licensee: University Medical Center License No.: L04719 

Inspection Type: Routine, Special, Announced Priority: 2 

Inspection Date: 4/13/09 Inspector: ES 

File No.: 13 

Licensee: United Regional Health Care System License No.: L00350 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 10/28/19 Inspector: ES 

File No.: 14 

Licensee: Troxler Electronic Laboratory License No.: L01296 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 1/5/12 Inspector: SS 

File No.: 15 

Licensee: Golden Plains Community Hospital License No.: L04369 

Inspection Type: Routine, Announced Priority: 5 

Inspection Date: 2/23/12 Inspector: ES 

File No.: 16 

Licensee: Christus Hospital – St. Elizabeth License No.: L00269 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 3/2/2011 Inspector: VD 

File No.: 17 

Licensee: Critical Response Inspection Service, LLC License No.: L06497 

Inspection Type: Initial, Special, Announced Priority: 1 

Inspection Date: 6/20/13 Inspector: DP 

 
Texas Final IMPEP Report Page C.3

Inspection Casework Reviews 

File No.: 18 

Licensee: Qal -Tek Associates, LLC License No.: L05965 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 10/28/11 Inspector: LC 

File No.: 19 

Licensee: Houston Thyroid and Endocrine Specialists License No.: L06464 

Inspection Type: Initial, Announced Priority: 3 

Inspection Date: 2/21/13 Inspector: RP 

File No.: 20 

Licensee: Texas Department of Transportation License No.: L00197 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 8/22/13 Inspector(s): RW, RS 

File No.: 21 

Licensee: Weatherford International, LLC License No.: L04286 

Inspection Type: Routine, Special, Announced Priority: 3 

Inspection Date: 4/11/11 Inspector: SF 

File No.: 22 

Licensee: Southern Technical Services, Inc. License No.: L05270 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 10/12/11 Inspector: RH 

File No.: 23 

Licensee: TechCorr USA, LLC License No.: L05972 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 9/18/13 Inspector(s): GG, AT 

File No.: 24 

Licensee: FTI Industries, Inc. License No.: L02810 

Inspection Type: Routine, Special, Announced Priority: 1 

Inspection Date: 10/3/12 Inspector: SS 

File No.: 25 

Licensee: Hendrick Medical Center License No.: L02433 

Inspection Type: Routine, Special, Announced Priority: 3 

Inspection Date: 7/19/11 Inspector: ES 
Texas Final IMPEP Report Page C.4

Inspection Casework Reviews 

Texas Commission on Environmental Quality

File No.: 26 

Licensee: Waste Controls Specialist License No.: R04971 

Inspection Type: Routine, Announced Priority: 1-2 

Inspection Date: 3/4/10 Inspectors: SS, MA, JG, MI 

 Comment: Report issued five months after inspection. 

File No.: 27 

Licensee: Waste Controls Specialist License No.: R04971 

Inspection Type: Routine, Announced Priority: 1-2 

Inspection Date: 8/23-24/11 Inspectors: SS, JG, DJ 

 Comment: Report issued two months after inspection. 

File No.: 28 

Licensee: Waste Controls Specialist License No.: R04971 

Inspection Type: Routine, Announced Priority: 1-2 

Inspection Date: 10/4-5/11 Inspectors: SS, JG 

File No.: 29 

Licensee: Waste Controls Specialist License No.: R04971 

Inspection Type: Routine, Announced Priority: 1-2 

Inspection Date: 7/1-2/13 Inspector: SS 

 Comment: Close-out letter to licensee issued on 1/23/14. 

File No.: 30 

Licensee: Waste Controls Specialist, LLC License No.: R04100 

Inspection Type: Shipment Receipt Routine, Announced Priority: 1-2 

Inspection Date: 4/27/12 Inspector: MA 

File No.: 31 

Licensee: Waste Controls Specialist, LLC License No.: R04100 

Inspection Type: Shipment Receipt Routine, Announced Priority: 1-2 

Inspection Date: 10/19/12 Inspector: MK 

File No.: 32 

Licensee: Waste Controls Specialist, LLC License No.: R04100 

Inspection Type: Shipment Receipt Routine, Announced Priority: 1-2 

Inspection Date: 10/29/12 Inspector: JG 

 
Texas Final IMPEP Report Page C.5

Inspection Casework Reviews 

File No.: 33 

Licensee: Waste Controls Specialist, LLC License No.: R04100 

Inspection Type: Shipment Receipt Routine, Announced Priority: 1-2 

Inspection Date: 5/3/13 Inspector: MK 

File No.: 34 

Licensee: Waste Controls Specialist, LLC License No.: R04100 

Inspection Type: Shipment Receipt Routine, Announced Priority: 1-2 

Inspection Date: 10/16/13 Inspector: JG 

File No.: 35 

Licensee: Waste Controls Specialist, LLC License No.: R04100 

Inspection Type: Shipment Receipt Routine, Announced Priority: 1-2 

Inspection Date: 10/24/13 Inspector: JG 

File No.: 36 

Licensee: Uranium Resources, Inc. Kingsville Dome Facility License No.: R03653 

(UIC Permit UR02827) 

Inspection Type: Routine UIC Priority: 1 

Inspection Date: 3/17 – 3/18/10 Inspector: MA 

File No.: 37 

Licensee: Uranium Resources, Inc. Kingsville Dome Facility License No.: R03653 

(UIC Permit UR02827) 

Inspection Type: Routine UIC Priority: 1 

Inspection Date: 7/2 – 7/3/13 Inspector: MA 

File No.: 38 

Licensee: Uranium Resources, Inc. Rosita Facility License No.: R03653 

(UIC Permit UR02880) 

Inspection Type: Routine UIC Priority: 1 

Inspection Date: 2/2/10 Inspectors: MA, SS 

File No.: 39 

Licensee: Uranium Resources, Inc. Rosita Facility License No.: R03653 

(UIC Permit UR02880) 

Inspection Type: Routine UIC Priority: 1 

Inspection Date: 3/15 – 3/18/11 Inspectors: MA, SS 

File No.: 40 

Licensee: Uranium Resources, Inc. Vasquez Facility License No.: R03653 

(UIC Permit UR03050) 

Inspection Type: Routine UIC Priority: NA 

Inspection Date: 7/2 – 7/3/13 Inspector: MA 
Texas Final IMPEP Report Page C.6

Inspection Casework Reviews 

File No.: 41 

Licensee: Exxon Mobil Ray Point Uranium Mill License No.: R01431 

Inspection Type: Routine Conventional Mill Priority: NA 

Inspection Date: 5/15/13 Inspector: SS 

File No.: 42 

Licensee: Conoco Phillips Conquista Project Uranium Mill License No.: R01634 

Inspection Type: Routine Conventional Mill Priority: NA 

Inspection Date: 5/16/13 Inspector: SS 

File No.: 43 

Licensee: Rio Grande Resources Panna Maria Uranium Mill License No.: R02402 

Inspection Type: Routine Conventional Mill Priority: NA 

Inspection Date: 11/20/13 Inspector: SS 

INSPECTOR ACCOMPANIMENTS 

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

Texas Department of State Health Services

Accompaniment No.: 1 

Licensee: Dallas Oncology Consultants PA License No.: L06352 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 1/13/14 Inspector: SS 

Accompaniment No.: 2 

Licensee: Christus Santa Rosa Hospital – New Braunfels License No.: L02429 

Inspection Type: Routine, Announced Priority: 3 

Inspection Date: 1/14/14 Inspector: JD 

Accompaniment No.: 3 

Licensee Fox NDE, LLC: License No.: L06411 

Inspection Type: Initial, Announced Priority: 1 

Inspection Date: 1/15/14 Inspector: JC 

Accompaniment No.: 4 

Licensee: Diamond Inspection License No.: L06229 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 1/16/14 Inspector: CM 

 
Texas Final IMPEP Report Page C.7

Inspection Casework Reviews 

Accompaniment No.: 5 

Licensee: Team Industrial Services, Inc. License No.: L00087 

Inspection Type: Routine, Announced Priority: 1 

Inspection Date: 12/16/13 Inspector: RP 

Accompaniment No.: 6 

Licensee: Scientific Drilling International License No.: L05105 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 12/17/13 Inspector: TH 

Accompaniment No.: 7 

Licensee: Thrubit, LLC License No.: L06030 

Inspection Type: Initial, Announced Priority: 2 

Inspection Date: 12/18/13 Inspector: DP 

Accompaniment No.: 8 

Licensee: Tenet Hospitals LTD dba Sierra Medical Center License No.: L04758 

Inspection Type: Routine, Announced Priority: 2 

Inspection Date: 1/28/14 Inspector: GG 

Texas Commission on Environmental Quality

Accompaniment No.: 9 

Licensee: Waste Controls Specialist, LLC License No.: R04100 

Inspection Type: Shipment Receipt Mock Inspection Priority: 1-2 

Inspection Date: 1/29-30/14 Inspectors: JG, MK 

 Comment: Due to lack of any waste shipments a mock inspection was performed 

Accompaniment No.: 10 

Licensee: South Texas Mining Venture, LLP License No.: R06062 

Inspection Type: Routine Radioactive License (not UIC) Priority: 1 

Inspection Date: 2/6/14 Inspectors: MA, SS 

 Comment: Power failure procedures, environmental monitoring results, and ground water 

reports were not reviewed as part of the inspection. 
 

APPENDIX D 

LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

Texas Department of State Health Services

File No.: 1 

Licensee: Forest Park Medical Center at Southlake LLC License No.: L06600 

Type of Action: New Amendment No.: 00 

Date Issued: 12/16/12 License Reviewer: CH 

File No.: 2 

Licensee: Quantum Technical Services LLC License No: L06406 

Type of Action: New Amendment No.: 00 

Date Issued: 6/9/11 License Reviewer: RF 

File No.: 3 

Licensee: Frontier Tubular Solutions LLC License No.: L06581 

Type of Action: New Amendment No.: 00 

Date Issued: 9/27/13 License Reviewer: KS 

File No.: 4 

Licensee: Control & Inspection Services USA Corporation License No.: L06611 

Type of Action: New Amendment No.: 00 

Date Issued: 2/3/14 License Reviewer: VD 

File No.: 5 

Licensee: Avance Biosciences Inc. License No: L06493 

Type of Action: New Amendment No.: 00 

Date Issued: 8/1/12 License Reviewer: KS 

File No.: 6 

Licensee: The Methodist Hospital License No.: L00457 

Type of Action: Amendment Amendment No.: 192 

Date Issued: 10/16/13 License Reviewer: SS 

File No.: 7 

Licensee: Oceaneering International Inc. License No.: L04463 

Type of Action: Amendment Amendment No.: 80 

Date Issued: 2/15/12 License Reviewer: JK 

File No.: 8 

Licensee: Aluman Mill Products License No.: L04663 

Type of Action: Amendment Amendment No.: 19 

Date Issued: 10/11/13 License Reviewer: SG 
Texas Final IMPEP Report Page D.2 

License Casework Reviews 

File No.: 9 

Licensee: Panhandle Nuclear Rx Ltd License No.: L04683 

Type of Action: Amendment Amendment No.: 28 

Date Issued: 1/30/14 License Reviewer: JSK 

File No.: 10 

Licensee: MISTRAS Group Inc. License No.: L06369 

Type of Action: Amendment Amendment No.: 13 

Date Issued: 12/12/13 License Reviewer: KS 

File No.: 11 

Licensee: Nabors Completion and Production Services Co. License No.: L06375 

Type of Action: Amendment Amendment No.: 2 

Date Issued: 10/25/12 License Reviewer: KS 

File No.: 12 

Licensee: Trace Life Sciences Inc. License No: L05435 

Type of Action: Renewal Amendment No.: 24 

Date Issued: Pending since 12/31/10 License Reviewer: JSK 

File No.: 13 

Licensee: East Texas Medical Center Crockett License No.: L02774 

Type of Action: Renewal Amendment No.: - 

Date Issued: Pending since 1/31/2010 License Reviewer: VD 

File No.: 14 

Licensee: The University of Texas Health Science Center at Houston License No.: L02774 

Type of Action: Renewal Amendment No.: - 

Date Issued: Pending since 1/31/10 License Reviewer: VD 

File No.: 15 

Licensee: Golden Plains Community Hospital License No.: L04369 

Type of Action: Renewal Amendment No.: - 

Date Issued: Pending since 1/31/2010 License Reviewer: PS 

File No.: 16 

Licensee: Mohammed Attar MD PA License No.: L05615 

Type of Action: Renewal Amendment No.: 06 

Date Issued: 6/28/12 License Reviewer: JSK 

File No.: 17 

Licensee: Petnet Houston LLC License No.: L05542 

Type of Action: Renewal Amendment No.: - 

Date Issued: Pending since 8/31/09 License Reviewer: PS 
Texas Final IMPEP Report Page D.3 

License Casework Reviews 

File No.: 18 

Licensee: Flange-Tech License No.: L04281 

Type of Action: Renewal Amendment No.: - 

Date Issued: Pending since 3/31/06 License Reviewer: RF 

File No.: 19 

Licensee: Gammatron Inc. License No.: L02148 

Type of Action: Renewal Amendment No.: - 

Date Issued: Pending since 1/31/12 License Reviewer: JK 

File No.: 20 

Licensee: Southwest Research Institute License No.: L00775 

Type of Action: Renewal Amendment No.: - 

Date Issued: Pending since 12/31/10 License Reviewer: JK 

File No.: 21 

Licensee: Columbia Scientific Balloon Facility License No.: L04717 

Type of Action: Renewal Amendment No.: 10 

Date Issued: 12/11/13 License Reviewer: CH 

File No.: 22 

Licensee: Seton Healthcare License No.: L06492 

Type of Action: Termination Amendment No.: 01 

Date Issued: 1/25/2013 License Reviewer: JSK 

File No.: 23 

Licensee: Metabolic Imaging of Laredo, LLC License No.: L05890 

Type of Action: Termination Amendment No.: 06 

Date Issued: 10/15/13 License Reviewer: SS 

File No.: 24 

Licensee: Tyco Healthcare Kendall LP License No.: L03314 

Type of Action: Termination Amendment No.: 25 

Date Issued: 12/18/13 License Reviewer: JK 

File No.: 25 

Licensee: STP Nuclear Operating Company License No.: L04222 

Type of Action: Termination Amendment No.: 29 

Date Issued: 12/4/13 License Reviewer: SG 

File No.: 26 

Licensee: Sterigenics US LLC License No.: L03851 

Type of Action: Exemption Amendment No.: 42 

Date Issued: 8/22/13 License Reviewer: JK 
Texas Final IMPEP Report Page D.4 

License Casework Reviews 

File No.: 27 

Licensee: Superior Production Logging Inc. License No.: L01983 

Type of Action: Exemption Amendment No.: 42 

Date Issued: 11/1/12 License Reviewer: RF 

File No.: 28 

Registrant: Waste Control Specialists Registrant No.: W0013 

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

Date Issued: 7/17/12 License Reviewer: RF 

Texas Commission on Environmental Quality

File No.: 29 

Licensee: Waste Controls Specialist, LLC License No.: R04100 

Type of Action: Minor Amendment Amendment No.: 3 

Date Issued: 1/6/11 License Reviewer: DC 

File No.: 30 

Licensee: Waste Controls Specialist, LLC License No.: R04100 

Type of Action: Administrative Amendment Amendment No.: 8 

Date Issued: 8/30/11 License Reviewer: ST 

File No.: 31 

Licensee: Waste Controls Specialist, LLC License No.: R04100 

Type of Action: Minor Amendment Amendment No.: 18 

Date Issued: 9/18/12 License Reviewer: BB 

File No.: 32 

Licensee: Waste Controls Specialist, LLC License No.: R04100 

Type of Action: Administrative Amendment Amendment No.: 22 

Date Issued: 7/24/13 License Reviewer: HW 

File No.: 33 

Licensee: Waste Controls Specialist, LLC License No.: R04100 

Type of Action: Minor Amendment Amendment No.: 23 

Date Issued: 9/5/13 License Reviewer: RD, BS, KE 

File No.: 34 

Licensee: South Texas Mining Venture, LLP License No.: R06062 (UIC Permit UR03070) 

Type of Action: Class III UIC PAA Application Amendment No.: UR03070PAA4 

Date Issued: 11/4/10 Permit Reviewer: MR 

File No.: 35 

Licensee: South Texas Mining Venture, LLP License No.: R06062 (UIC Permit UR03070) 

Type of Action: Permit Processing Schedule Amendment No.: UR03070PAA4 

Date Issued: 11/4/10 Permit Reviewer: MR 
Texas Final IMPEP Report Page D.5 

License Casework Reviews 

File No.: 36 

Licensee: South Texas Mining Venture, LLP License No.: R06062 (UIC Permit UR03070) 

Type of Action: Compliance History Report Amendment No.: NA 

Date Issued: 12/5/13 Permit Reviewer: MR 

 Comment: Staff did not demonstrate they were receiving adequate information on site 

performance/compliance history to inform actions using this document. 

File No.: 37 

Licensee: South Texas Mining Venture, LLP License No.: R06062 (UIC Permit UR 03070) 

Type of Action: UIC P&A and Decommissioning Surety Update Amendment No.: NA 

Date Issued: 8/16/13 Permit Reviewer: ST 

File No.: 38 

Licensee: Mestena Uranium, LLC License No.: R05360 (UIC Permit UR03060) 

Type of Action: UIC P&A Surety Update Amendment No.: NA 

Date Issued: 8/9/13 License Reviewer: ST 

File No.: 39 

Licensee: Rio Grande Resources Panna Maria Uranium Mill Site License No.: R02402 

Type of Action: Surveillance Monitoring Report Amendment No.: NA 

Date Issued: 10/17/13 License Reviewer: KT 

File No.: 40 

Licensee: Conoco Phillips Conquista Project Uranium Mill Site License No.: R01634 

Type of Action: Semi-Annual Ground Water Monitoring Report Amendment No.: NA 

Date Issued: 10/24/13 License Reviewer: KT 

File No.: 41 

Licensee: Exxon Mobil Ray Point Uranium Mill Site License No.: R01431 

Type of Action: Quarterly Monitoring Report Amendment No.: NA 

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

File No.: 42 

Licensee: Rio Grande Resources Panna Maria Mill Site License No.: R02402 

Action Type: Uranium Mill Tailings Impoundment Site Visit Amendment No: NA 

Date Issued: 1/27/14 License Reviewer: KT 

File No.: 43 

Licensee: Exxon Mobil Ray Point Uranium Mill Site License No.: R01431 

Action Type: Uranium Mill Tailings Impoundment Site Visit Amendment No: NA 

Inspection Date: 1/27/14 License Reviewer: KT 

File No.: 44 

Licensee: Mestena Uranium, LLC ISR site License No.: R05360 

Type of Action: Amendment Amendment No.: NA 

Date Issued: 2/4/13 Permit Reviewer: ST 
Texas Final IMPEP Report Page D.6 

License Casework Reviews 

File No.: 45 

Licensee: South Texas Mining Venture, LLP License No.: R06062 

Type of Action: Semi-Annual Environmental Monitoring Report Amendment No.: NA 

Date Issued: 8/28/12 License Reviewer: BB 

File No.: 46 

Licensee: South Texas Mining Venture, LLP License No.: R06062 

Type of Action: Amendment Amendment No.: NA 

Date Issued: 11/17/10 License Reviewer: GS 

File No.: 47 

Licensee: Rio Grande Resources Panna Maria Uranium Mill License No.: R02402 

Type of Action: Annual Decommissioning Cost Estimate Amendment No.: NA 

Date Issued: 9/25/13 License Reviewer: ST 

File No.: 48 

Licensee: Mestena Uranium, LLC License No.: R05360 

Type of Action: Annual Decommissioning Cost Estimate Review Amendment No.: NA 

Date Issued: 3/18/13 License Reviewer: GS 

File No.: 49 

Licensee: Intercontinental Energy Corporation Lamprecht and Zamzow ISR Sites 

 Revoked License No.: L02538 

Type of Action: Decommissioning Action Request Letter Amendment No.: NA 

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

APPENDIX E 

INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: MD Anderson Cancer Center License No.: L00466 

Date of Incident: 9/9/11 NMED No.: 110486 

Investigation Date: 9/13/11 Type of Incident: Medical Event 

 Type of Investigation: Phone 

File No.: 2 

Licensee: Baylor Radiosurgery Center License No.: L05842 

Date of Incident: 9/30/10 NMED No.: 100492 

Investigation Date: 10/1/10 Type of Incident: Medical Event 

 Type of Investigation: Phone 

File No.: 3 

Licensee: UT Southwest Medical Center License No.: L00384 

Date of Incident: 7/16/10 NMED No.: 110108 

Investigation Date: 3/1/11 Type of Incident: Medical Event 

 Type of Investigation: Site 

File No.: 4 

Licensee: Pasadena Refining System License No.: L01344 

Date of Incident: 12/10/11 NMED No.: 110660 

Investigation Date: 1/12/12 Type of Incident: Damaged Equipment 

 Type of Investigation: Site 

File No.: 5 

Licensee: Cardinal Health Nuclear Pharmacy License No.: L01911 

Date of Incident: 1/11/12 NMED No.: 120060 

Investigation Date: 1/13/12 Type of Incident: Medical Event 

 Type of Investigation: Phone 

File No.: 6 

Licensee: Phoenix NDT License No.: L04454 

Date of Incident: 8/31/11 NMED No.: 120137 

Investigation Date: 1/27/12 Type of Incident: Potential Overexposure 

 Type of Investigation: Site 

File No.: 7 

Licensee: UT Southwest Medical Center License No.: L00384 

Date of Incident: 2/16/12 NMED No.: 120144 

Investigation Date: 2/17/12 Type of Incident: Medical Event 

 Type of Investigation: Phone 

File No.: 8 

Licensee: MD Anderson Cancer Center License No.: L00460 

Date of Incident: 4/11/12 NMED No.: 120225 

Investigation Date: 4/13/12 Type of Incident: Medical Event 

 Type of Investigation: Phone 
Texas Final IMPEP Report Page E.2 

Incident Casework Reviews 

File No.: 9 

Licensee: Goolsby Testing License No.: L03115 

Date of Incident: 10/18/12 NMED No.: 120653 

Investigation Date: 11/1/12 Type of Incident: Damaged Equipment 

 Type of Investigation: Site 

File No.: 10 

Licensee: Physician Reliance License No.: L05545 

Date of Incident: 1/5/12 NMED No.: 120690 

Investigation Date: 11/21/12 Type of Incident: Medical event 

 Type of Investigation: Phone 

File No.: 11 

Licensee: Sterigenics US at Ft. Worth License No.: L03851 

Date of Incident: 2/20/13 NMED No.: 130112 

Investigation Date: 2/20/13 Type of Incident: Equipment Failure 

 Type of Investigation: Phone 

File No.: 12 

Licensee: Sterigenics US at Ft. Worth License No.: L03851 

Date of Incident: 2/28/13 NMED No.: 130122 

Investigation Date: 3/1/13 Type of Incident: Equipment Failure 

 Type of Investigation: Phone 

File No.: 13 

Licensee: Petrochem Inspection Services License No.: L04460 

Date of Incident: 3/26/13 NMED No.: 130147 

Investigation Date: 3/27/13 Type of Incident: Damaged Equipment 

 Type of Investigation: Phone 

File No.: 14 

Licensee: Rosa of North Dallas License No.: L06186 

Date of Incident: 3/27/13 NMED No.: 130150 

Investigation Date: 5/8/13 Type of Incident: Medical Event 

 Type of Investigation: Site 

File No.: 15 

Licensee: Thermo Process Instruments License No.: L03524 

Date of Incident: 5/15/13 NMED No.: 130246 

Investigation Date: 5/24/13 Type of Incident: Contamination 

 Type of Investigation: Site 

File No.: 16 

Licensee: The Methodist Hospital License No.: L00457 

Date of Incident: 6/3/13 NMED No.: 130264 

Investigation Date: 6/3/13 Type of Incident: Equipment Failure 

 Type of Investigation: Phone 

File No.: 17 

Licensee: Lawrence Engineering License No.: L05707 

Date of Incident: 12/2/11 NMED No.: 130561 

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

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

Incident Casework Reviews 

File No.: 18 

Licensee: Texas Gamma Ray License No.: L05561 

Date of Incident: 11/19/13 NMED No.: 130563 

Investigation Date: 11/20/13 Type of Incident: Equipment Failure 

 Type of Investigation: Phone 

File No.: 19 

Licensee: Qualspec Services LLC License No.: L06351 

Date of Incident: 11/20/13 NMED No.: 130566 

Investigation Date: 12/16/13 Type of Incident: Equipment Failure 

 Type of Investigation: Phone 

File No.: 20 

Licensee: Renegade Wire Line Services License No.: L06307 

Date of Incident: 10/25/13 NMED No.: 130575 

Investigation Date: 2/5/14 Type of Incident: Potential Overexposure 

 Type of Investigation: Site 

File No.: 21 

Licensee: Steris Isomedix Services License No.: L04268 

Date of Incident: 11/29/13 NMED No.: 130586 

Investigation Date: 12/2/13 Type of Incident: Equipment Failure 

 Type of Investigation: Phone 

File No.: 22 

Licensee: Wilco NDT License No.: Reciprocity NM IR 470-05 

Date of Incident: 12/10/13 NMED No.: 130614 

Investigation Date: 12/17/13 Type of Incident: Potential Overexposure 

 Type of Investigation: Site 

File No.: 23 

Licensee: Associated Couriers License No.: General 

Date of Incident: 12/8/13 NMED No.: 140029 

Investigation Date: 12/9/13 Type of Incident: Lost/Stolen RAM 

 Type of Investigation: Phone 
 Attachment 

APPENDIX F 

SEALED SOURCE AND DEVICE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Registry No.: TX-1328-D-101-S SS&D Type: (T) Other: Mobile Gamma 

Applicant Name: Nuclear Scanning Services, Inc. Type of Action: New 

Date Issued: 1/11/13 Reviewers: JK, SG 

File No.: 2 

Registry No.: TX-1363-D-101-S SS&D Type: (F) Well Logging 

Applicant Name: Hunter Well Science, Inc. Type of Action: New 

Date Issued: 4/19/13 Reviewers: JK, SG 

File No.: 3 

Registry No.: TX-1376-D-101-S SS&D Type: (D) Gamma Gauge 

Applicant Name: Varco, L.P. Type of Action: New 

Date Issued: 11/20/13 Reviewers: JK, SG 

File No.: 4 

Registry No.: TX-0734-D-107-S SS&D Type: (T) Other: Mobile Gamma 

Applicant Name: Tracerco Type of Action: New 

Date Issued: 1/8/14 Reviewers: JK, KS 

File No.: 5 

Registry No.: TX-0634-D-178-B SS&D Type: (D) Gamma Gauge 

Applicant Name: Thermo Fisher Scientific Type of Action: New 

Date Issued: 3/23/10 Reviewers: JK, RF 

File No.: 6 

Registry No.: TX-0734-D-105-G SS&D Type: (D) Gamma Gauge 

Applicant Name: Tracerco Type of Action: New 

Date Issued: 6/9/10 Reviewers: SG, RF 

File No.: 7 

Registry No.: TX-1141-D-101-S SS&D Type: (B) Medical Radiography 

Applicant Name: Positron Corp. Type of Action: New 

Date Issued: 11/19/10 Reviewers: SG, RF 

 Comment: The reviewers did not ensure that the foreign manufacturer/distributor had a 

 U.S. radioactive materials license, per Texas regulations, or an import/export license. Case 

file was missing a review checklist. SSD registration is for a device that contains NARM 

material that is now distributed from the State of Indiana. The registration will be transferred 

to the NRC. 

 
Texas Final IMPEP Report Page F.2 

Sealed Source and Device Casework Reviews 

File No.: 8 

Registry No.: TX-0734-D-106-S SS&D Type: (D) Gamma Gauge 

Applicant Name: Tracerco Type of Action: New 

Date Issued: 4/8/11 Reviewers: SG, RF 

File No.: 9 

Registry No.: TX-0642-D-105-B SS&D Type: (N) Ion Generator 

Applicant Name: Thermo Finnigan Type of Action: New 

Date Issued: 9/30/11 Reviewers: JK, KE 

File No.: 10 

Registry No.: TX-1351-D-101-B SS&D Type: (D) Gamma Gauge 

Applicant Name: Multi Phase Meters, Inc. Type of Action: New 

Date Issued: 4/17/12 Reviewers: JK, KS 

 Comment: The reviewers did not ensure that the foreign manufacturer/distributor had a 

 U.S. radioactive materials license, per Texas regulations, or an import/export license. 

File No.: 11 

Registry No.: TX-1351-D-102-B SS&D Type: (D) Gamma Gauge 

Applicant Name: Multi Phase Meters, Inc. Type of Action: New 

Date Issued: 7/27/12 Reviewers: JK, KS 

 Comment: The reviewers did not ensure that the foreign manufacturer/distributor ha 

 U.S. radioactive materials license, per Texas regulations, or an import/export license. 

File No.: 12 

Registry No.: TX-0634-D-176-B SS&D Type: (H) General Neutron Source Applications 

Applicant Name: Thermo Fisher Scientific Type of Action: Amendment 

Date Issued: 7/22/10 Reviewers: JK, RF 

File No.: 13 

Registry No.: TX-0734-D-101-B SS&D Type: (D) Gamma Gauge 

Applicant Name: Tracerco Type of Action: Amendment 

Date Issued: 6/4/13 Reviewers: JK, RF 

File No.: 14 

Registry No.: TX-0642-D-803-B SS&D Type: (N) Ion Generator 

Applicant Name: Thermo Finnigan Type of Action: Inactivation 

Date Issued: 2/1/12 Reviewers: JK, KS 

File No.: 15 

Registry No.: TX-8260-S-801-S SS&D Type: (T) Other 

Applicant Name: GNI Incorporated Type of Action: Inactivation 

Date Issued: 10/31/12 Reviewers: JK, KS 

 
Texas Final IMPEP Report Page F.3 

Sealed Source and Device Casework Reviews 

File No.: 16 

Registry No.: TX-8260-S-802-S SS&D Type: (F) Well Logging 

Applicant Name: GNI Incorporated Type of Action: Inactivation 

Date Issued: 11/16/12 Reviewers: JK, KS 
 Attachment 

ATTACHMENT(S) 

June 12, 2014 Letter from Kathryn C. Perkins 

Texas DSHS Response to the Draft Report 

ADAMS Accession No.: ML14177A332 

June 20, 2014 Letter from Kelly Cook and Charles Maguire 

Texas CEQ Response to the Draft Report 

ADAMS Accession No.: ML14174A773 

NRC Comment Resolution to June 12 and June 20, 2014 Letter 

ADAMS Accession No.: ML14192A498