January 9, 2013 

Jose T. Montero, M.D. 

Director 

Division of Public Health Services 

Department of Health and Human Services 

29 Hazen Drive 

Concord, New Hampshire 03301-6504 

Dear Dr. Montero: 

On December 18, 2012, the Management Review Board (MRB) met to consider the proposed 

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

Hampshire Agreement State Program. The MRB found the New Hampshire program adequate 

to protect public health and safety and not compatible with the U.S. Nuclear Regulatory 

Commission’s (NRC) program. 

Section 5.0, page 12 of the enclosed final report contains a summary of the IMPEP team’s 

findings and recommendations. A recommendation from the 2008 IMPEP review was held 

open pending development and implementation of the State’s action plan to adopt the NRC 

regulations in accordance with the NRC policy on adequacy and compatibility. The Radiological 

Health Section Administrator committed to the MRB that the action plan would be submitted to 

the NRC in January 2013. 

Based on the results of the current IMPEP review, the next full review of the New Hampshire 

Agreement State Program will take place in approximately four years with a periodic meeting 

occurring mid-cycle. In addition, the MRB directed Monitoring be initiated with Monitoring calls 

occurring at a frequency of every four months. According to the criteria in the NRC 

Management Directive 5.6, “Integrated Materials Performance Evaluation Program (IMPEP),” 

Monitoring may be used in cases where weaknesses in a program result in a less than fully 

satisfactory performance for one or more performance indicators. Monitoring is an informal 

process that allows the NRC to maintain an increased level of communication with an 

Agreement State program. The MRB determined that Monitoring will be a useful tool in 

assessing the State’s progress toward completion of the overdue regulations.
J. Montero - 2 - 

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

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

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

 Sincerely, 

/RA/ 

 Michael F. Weber 

 Deputy Executive Director for Materials, Waste, 

 Research, State, Tribal and Compliance Programs 

 Office of the Executive Director for Operations 

Enclosure: 

New Hampshire Final IMPEP Report 

cc w/ encl: Bill Dundulis, RI 

 Organization of Agreement States 

 Liaison to the MRB 

 Michael J. Dumond, Administrator 

New Hampshire Bureau 

 of Public Health Protection 

Augustinus Ong, Administrator 

New Hampshire Radiological 

 Health Section 
J. Montero - 2- 

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

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

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

 Sincerely, 

 /RA/ 

 Michael F. Weber 

 Deputy Executive Director for Materials, Waste, 

 Research, State, Tribal and Compliance Programs 

 Office of the Executive Director for Operations 

Enclosure: 

New Hampshire Final IMPEP Report 

cc w/ encl: Bill Dundulis, RI 

 Organization of Agreement States 

 Liaison to the MRB 

 Michael J. Dumond, Administrator 

New Hampshire Bureau 

 of Public Health Protection 

Augustinus Ong, Administrator 

New Hampshire Radiological 

 Health Section 

DISTRIBUTION: 

See next page 

 ML12354A179 

OFC MSSA:TL MSSA MSSA MSSA MSSA:D TechEd FSME:D EDO 

NAME LDimmick 

(MBeardsley for) 

MBeardsley DWhite PHenderson BMcDermott CPoland 

(PTressler for) 

MSatorius 

(BHolian for) 

MWeber 

DATE 12/19 /12 12/19/12 12/19/12 12/19 /12 12/21/12 12/27/12 1/2 /13 1/ 9 /13 

OFFICIAL RECORD COPY 

 
Letter to J. Montero, M.D. from Michael F. Weber dated 

SUBJECT: NEW HAMPSHIRE FY2013 FINAL IMPEP REPORT 

DISTRIBUTION: 

MSSA_Technical_Asst_Resource DCD (SP01) 

RidsEdoMailCenter 

RidsFsmeOd 

RidsOgcMailCenter 

RidsRgn1MailCenter 

RidsRgn4MailCenter 

RidsFsmeDmssa 

RidsSecyCorrespondenceMailCenter Chairman Macfarlane 

DJanda, RI/RSAO Commissioner Svinicki 

SPoy, FSME Commissioner Apostolakis 

JWalden, KS Commissioner Magwood 

MOrendi, RI Commissioner Ostendorff 

RLorson, RI SECY 

DLew, RI 

TKenna, NH 

JFoster, OEDO 

JWeil, OCA (2 copies) 
Enclosure 

INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

REVIEW OF THE NEW HAMPSHIRE AGREEMENT STATE PROGRAM 

OCTOBER 2 – 5, 2012 

FINAL REPORT

 
EXECUTIVE SUMMARY 

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

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

during the period October 2 – 5, 2012, by a review team composed of technical staff members 

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

Based on the results of this review, New Hampshire’s performance was found satisfactory for 

six performance indicators and unsatisfactory for the Compatibility Requirements indicator. The 

State has not yet addressed ten regulation amendments that are overdue for adoption. 

The review team did not make any recommendations regarding program performance by the 

State. However, the review team determined that the recommendation from the 2008 IMPEP 

review, regarding the development and implementation of an action plan to adopt NRC 

regulations in accordance with the current NRC policy, should be kept open. 

Accordingly, the review team recommended, and the MRB agreed, that the New Hampshire 

Agreement State Program is adequate to protect public health and safety and is not 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 and that the State enter a period of 

Monitoring with Monitoring calls conducted every four months. The review team determined 

that Monitoring would be a useful tool in assessing the State’s progress toward completion of 

the overdue regulations. 

. 
New Hampshire Final IMPEP Report Page 1 

1.0 INTRODUCTION 

This report presents the results of the review of the New Hampshire Agreement State Program. 

The review was conducted October 2 – 5, 2012, by a review team composed of technical staff 

members from the U.S. Nuclear Regulatory Commission (NRC) and the State of Kansas. 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 September 20, 2008 to October 5, 2012, were discussed with New Hampshire managers on 

the last day of the review. 

A draft of this report was provided to New Hampshire for factual comment on November 1, 

2012. The State responded by letter dated November 29, 2012. A copy of the State’s response 

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

December 18, 2012, to consider the proposed final report. The MRB found the New Hampshire 

Agreement State Program adequate to protect public health and safety, and not compatible with 

the NRC’s program. 

The New Hampshire Agreement State Program is administered by the Radiological Health 

Section (the Section), which is part of the Bureau of Public Health Protection (the Bureau). The 

Bureau is located within the Division of Public Health Services (the Division). The Division is 

part of the Department of Health and Human Services (the Department). The Commissioner of 

the Department reports to the Governor. Organization charts for the Department and the 

Bureau are included in Appendix B. 

At the time of the review, the New Hampshire Agreement State Program regulated 82 specific 

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

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

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

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

non-common performance indicators was sent to the Section on April 11, 2012. The Section 

provided its response to the questionnaire on September 13, 2012. A copy of the questionnaire 

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

(ADAMS) using the Accession Number ML12261A055. 

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

the Section’s response to the questionnaire, (2) review of applicable New Hampshire statutes 

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

technical review of selected regulatory actions, (5) field accompaniments of two 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 New Hampshire Agreement State 

Program’s performance. 
New Hampshire Final IMPEP Report Page 2 

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

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

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

non-common performance indicators, and Section 5.0 summarizes the review team's findings. 

2.0 STATUS OF ITEMS IDENTIFIED IN PREVIOUS REVIEWS 

During the previous IMPEP review, which concluded on September 19, 2008, the review team 

made one recommendation regarding the New Hampshire Agreement State Program’s 

performance. The status of the recommendation is as follows: 

“The review team recommends that the State develop and implement an action plan to 

adopt NRC regulations in accordance with the current NRC policy on adequacy and 

compatibility.” (Section 4.1 of the 2008 IMPEP Report) 

Status: The State has not yet developed an action plan to address this 

recommendation. Historically, the Administrator has been responsible for rules. 

Pursuant to the 2008 IMPEP, the Administrator’s staffing request included one position 

in the Section that would be partially dedicated to regulation development and 

maintenance. However, the position was not allocated. During the review period, the 

Administrator position was vacated and subsequently filled in June 2012. The new 

Administrator has begun work on several of the overdue regulations. The 

recommendation remains pertinent and open. 

3.0 COMMON PERFORMANCE INDICATORS 

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

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

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

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

3.1 Technical Staffing and Training

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

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

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

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

and considered workload backlogs. 

The Section is managed by the Administrator and has two managers and four technical staff. 

One manager is dedicated to the Radioactive Materials Program; the other is dedicated to the 

Radiation Machines Program. The technical staff shares responsibility for the radioactive 

materials and radiation machine programs’ licensing, inspection, and incident response 

activities. At the time of the review, the Section had 2.7 full-time equivalents (FTE) dedicated 

to the Radioactive Materials Program, not including the Administrator or clerical support. The 

Section has a dedicated staff member that coordinates the Radiological Emergency Response 

Program. There are two vacant positions: a part-time word processor and new Radiation 

Health Physicist III position. Interviews for the word processor were underway at the time of 
New Hampshire Final IMPEP Report Page 3 

the review. The Health Physicist III position is being finalized in Bureau management. The 

FTE for the position would be split between mammography and rulemaking. Therefore, the 

position is partially funded by the U.S. Food and Drug Administration. There is uncertainty as 

to when this position might be filled. 

Technical staffs are classified as Radiation Health Physicists. Candidates for technical 

positions are required to have a bachelor’s degree in a science or engineering, and certification 

or equivalent experience in radiation-related work. All technical staff members meet the 

qualification requirements for their respective positions. 

During the review period, there was some turnover; however, the Section was able to fill the 

positions. The Administrator left the program in June 2011. The position was subsequently 

staffed by June 2012. A Radiation Health Physicist II position, contributing 0.45 FTE to the 

Radioactive Materials Program, turned over twice during the review period (4/30/2010 and 

9/2/2011). On both occasions, the position was posted and staffed within 12 months of it 

becoming vacant. 

The review team determined that the Section’s staffing level is adequate for its licensing, 

inspection, and incident response duties. However as discussed later in this report, regulation 

development continues to be an ongoing challenge for the Section. The review team noted that 

additional staff to support rule development was proposed by the Section during the 2008 

IMPEP, but State budget cuts prevented allocation of the position. The review of New 

Hampshire’s regulations required for compatibility is discussed in Section 4.1.2. New 

Hampshire management is cognizant of the need for a solution to address regulation 

development and maintenance. 

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

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

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

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

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

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

New Hampshire’s management supports the Section’s training program. 

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

that New Hampshire’s performance with respect to the indicator, Technical Staffing and 

Training, be found satisfactory. 

3.2 Status of Materials Inspection Program

The review team focused on five factors while reviewing this indicator: inspection frequency, 

overdue inspections, initial inspections of new licenses, timely dispatch of inspection findings to 

licensees, and performance of reciprocity inspections. The review team’s evaluation was based 

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

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

management and staff. 
New Hampshire Final IMPEP Report Page 4 

The review team verified that New Hampshire’s inspection frequencies for all types of 

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

“Materials Inspection Program.” In addition, the review team confirmed the Section is 

conducting Increased Controls inspections in conjunction with routine health and safety 

inspections. 

The Section conducted 39 higher priority inspections (Priority 1, 2, and 3) during the review 

period. One of these inspections was conducted overdue by more than 25 percent of the 

inspection frequency prescribed in IMC 2800. In addition, the Section performed 14 initial 

inspections during the review period, one of which was conducted overdue. As required by IMC 

2800, initial inspections should be conducted within 12 months of license issuance. The Section 

purposely deferred the initial inspection pending the receipt of radioactive sources by the 

licensee. The Section had conducted a pre-licensing site visit of this licensee. The initial 

inspection was conducted one month overdue. Overall, the review team calculated that the 

Section performed 3.8 percent of its inspections (Priority 1, 2, 3, and Initials) overdue during the 

review period. At the time of the review, there were no overdue inspections. 

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

A sampling of 14 inspection reports indicated that two of the inspection findings were 

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

Section tracks this metric in its inspection database. Based on information collected from the 

database, the review team determined that 13 of 100 inspection reports were submitted to the 

licensee beyond 30 days. None of these occurrences contained inspection reports with a notice 

of violation (NOV). 

The review team found that the Section issued 25 reciprocity permits over the four year review 

period that were candidates for inspection based upon the criteria found in IMC 1220, 

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

10 CFR 150.20.” The Section inspected seven of the candidate licensees. The review team 

determined that the Section met the NRC’s criteria of inspecting 20 percent of candidate 

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

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

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

Program, be found satisfactory. 

3.3 Technical Quality of Inspections

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

notes, and interviewed inspectors for 15 radioactive materials inspections conducted during the 

review period. The casework reviewed included inspections conducted by four Section 

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

institutions-therapy including high dose rate remote afterloader and unsealed radioiodine 

therapy, medical-diagnostic, fixed gauges, industrial radiography, veterinary use, self-shielded 

irradiators, mobile nuclear medicine, 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. 
New Hampshire Final IMPEP Report Page 5 

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

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

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

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

documentation supported violations, recommendations made to licensees, unresolved safety 

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

discussions held with licensees during exit interviews. 

The inspection procedures utilized by the Section 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 Section Manager. Supervisory accompaniments were conducted annually for 

all inspectors. The Section Manager also conducts radioactive materials inspections and was 

accompanied by the former Program Administrator in 2009 and 2010. The current Administrator 

is not a qualified inspector; therefore, to meet this requirement, the Program will use a senior 

staff inspector to accompany the Manager on future annual accompaniments. 

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

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

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

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

inspection or NOV which details the results of the inspection. When the Bureau issues an NOV, 

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

within 30 days. All findings and corrective actions are reviewed by the Section Manager. 

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

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

emergency response events. Instruments are calibrated at least annually, or as needed, by the 

manufacturer or a properly licensed facility. The Section has access to the Public Health 

Laboratory, which is a well-equipped and adequately staffed analytical laboratory. The Public 

Health Laboratory has broad analytical capabilities using liquid scintillation counters, gas 

proportional counters, intrinsic germanium detectors, multichannel analyzers, alpha 

spectroscopy, and radiochemistry. 

One IMPEP team member accompanied two Section inspectors on routine inspections 

during the week of September 10, 2012. The inspectors were accompanied during health 

and safety inspections of an industrial radiography facility, including a temporary job site, 

and medical facility with authorization for use of unsealed radioiodine therapy. 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. 
New Hampshire Final IMPEP Report Page 6 

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

that New Hampshire’s performance with respect to the indicator, Technical Quality of 

Inspections, be found satisfactory. 

3.4 Technical Quality of Licensing Actions

The review team examined completed licensing casework and interviewed license reviewers for 

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

proper radioisotopes and quantities, qualifications of authorized users, adherence to good 

health physics practices, financial assurance, operating and emergency procedures, 

appropriateness of license conditions, and overall technical quality. The casework was also 

reviewed for timeliness, use of appropriate deficiency letters and cover letters, reference to 

appropriate regulations, supporting documentation, consideration of enforcement history, prelicensing visits, supervisory review, and proper signatures. 

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

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

new licenses, three full renewals, one decommissioning, two termination actions, two denials 

and ten amendments. Files reviewed included a cross-section of license types: broadscope, 

medical diagnostic and therapy, brachytherapy, medical institution – private practice, industrial 

radiography, research/development, portable and fixed gauges, manufacturer, and self-shielded 

irradiators. The casework sample represented work from five license reviewers. A list of the 

licensing casework evaluated is provided in Appendix D. 

The review team found that the licensing actions were thorough, complete, consistent, and of 

high quality with health, safety, and security issues properly addressed. License tie-down 

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

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

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

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

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

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

licenses. 

The Section Manager has signature authority for licensing actions. The Section Manager 

performs a technical and supervisory review on all licensing actions before issuance to the 

licensee. The Section issues licenses for a 1-year period based on the collection of an annual 

fee; a full comprehensive technical review is completed every seven years. 

The Section has two licenses that require financial assurance. The review team determined 

that the Section has taken appropriate steps to ensure compliance with the financial assurance 

requirements. The license review process appropriately identifies licensees required to 

maintain financial assurance. 

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

high quality and consistent with the Section’s licensing procedures and/or NUREG-1556 

guidance documents, the State’s Code of Administrative Rules, and good health physics 
New Hampshire Final IMPEP Report Page 7 

practices. The review team attributed the consistent use of templates, checklists and quality 

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

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

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

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

licensees receive a pre-licensing site visit which includes an evaluation of the applicant’s 

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

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

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

identifying those licenses and found the rationale was thorough and accurate. The review team 

confirmed that license reviewers evaluated new license applications and license amendments 

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

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

State also used legally binding license conditions that met the criteria for implementing the 

requirements for two independent physical controls to secure portable gauges, packaging and 

transportation of radioactive materials, financial assurance for decommissioning, patient release 

criteria, inventory reporting for nationally tracked sources, National Source Tracking System 

implementation, training requirements for radiographers’ assistants, and dosimetry technology. 

The review team examined the Section’s implementation of its process for the control of 

sensitive information. Files that contain sensitive information are marked as such and are 

secured in locked file cabinets. 

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

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

Actions, be found satisfactory. 

3.5 Technical Quality of Incident and Allegation Activities

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

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

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

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

casework for four radioactive materials incidents. A listing of the incident casework examined, 

with case-specific comments, may be found in Appendix E. The review team also evaluated the 

Section’s response to one allegation involving radioactive materials. No allegations were 

referred to the State by the NRC during the review period. 

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

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

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

use of NMED software. The Section handles incidents and allegations in the same manner. 

When notified of an incident or allegation, the Manager and staff discuss the issue and 
New Hampshire Final IMPEP Report Page 8 

determine the level of initial response based on the health and safety risk. The Section has a 

spreadsheet to track the status of all incidents and allegations. 

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

material, equipment failure, loss of control. The review team identified one incident which the 

State had initially reported to the NRC in a timely manner, but which should have been updated 

when two additional sources were determined to be missing. The Section Manager determined 

that not updating the event report was an inadvertent oversight on the State’s part. The Section 

provided the updated information to the NRC Headquarters Operations Center on October 4, 

2012, at the direction of the review team. The review team determined that another of the 

incident reports reviewed did not contain sufficient information to determine if the cause of the 

failure of an x-ray fluorescence analyzer (XRF) device to function as required was the result of a 

generic problem and whether the incident met NRC reporting requirements. During the onsite 

review, the inspector was not available to provide additional information on follow-up actions, so 

the Section Manager contacted the licensee and the gauge manufacturer and determined that 

the device failure was not a generic issue; however, the device failure did meet the NRC 

reporting criteria. The State notified the NRC Headquarters Operations Center about this event 

on October 5, 2012, at the direction of the review team. 

Based on the potential issues the review team identified with two of the four incident files 

reviewed, the review team increased the sample size of incidents reviewed to determine if the 

problems were an isolated or chronic issue. The review team determined that upon review of 

four additional incident casework files, the Section responded appropriately to two of the initial 

incidents reviewed and all four of the additional incidents reviewed. Initial responses were 

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

safety significance of the incident. The Section dispatched inspectors for on-site investigations 

in all of the cases reviewed and took suitable enforcement and follow-up actions. The review 

team determined that the issues identified with two of the Section’s incidents were due to 

isolated causes and not a chronic issue. 

The review team identified six radioactive material incidents in NMED for New Hampshire during 

the review period, all of which required reporting. With the exception of the two updates 

described above, the Section 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 Section’s response to allegations, the review team 

evaluated the completed casework for one allegation received by the State during the review 

period. The review team concluded that the Section took prompt and appropriate actions in 

response to the concerns raised. The review team noted that the Section documented the 

investigation of the individual’s concerns and retained all necessary documentation to 

appropriately close the allegation. The Section notified the concerned individual of the 

conclusion of its investigation. The review team determined that the Section adequately 

protected the identity of concerned individuals. 

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

that New Hampshire’s performance with respect to the indicator, Technical Quality of Incident 

and Allegation Activities, be found satisfactory. 
New Hampshire Final IMPEP Report Page 9 

4.0 NON-COMMON PERFORMANCE INDICATORS 

Four non-common performance indicators are used to review Agreement State programs: 

(1) Compatibility Requirements, (2) Sealed Source and Device Evaluation Program (SS&D), (3) 

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

NRC’s Agreement with New Hampshire does not relinquish regulatory authority for a uranium 

recovery program; therefore, only the first three non-common performance indicators applied to 

this review. 

4.1 Compatibility Requirements

4.1.1 Legislation

New Hampshire became an Agreement State on May 16, 1966. The Department is authorized 

as the State’s radiation control agency under the New Hampshire Revised Statutes Annotated 

(RSA) 1990, Chapter 125. The Section has been delegated to administer the State’s radiation 

control program. The review team did not identify any legislative changes affecting the radiation 

control program during the review period. 

4.1.2 Program Elements Required for Compatibility 

The New Hampshire Rules for Control of Radiation are found in He-P 4000-4095 and apply to 

all ionizing radiation, whether emitted from radionuclides or radiation producing machines. New 

Hampshire requires a license for possession and use of all radioactive material. 

The review team examined the procedures used in the State’s administrative rulemaking 

process and found that the process takes at least 12 months for rule promulgation. In practice, 

this process may take much longer for more complex or large rulemaking packages. After 

preparation of a package of draft regulations by the Section, the draft regulations are reviewed 

by the Department’s Administrative Rules Unit. The draft regulations are then sent to the 

Department Commissioner for approval. Final approval of all regulations is completed by the 

Joint Legislative Committee on Administrative Rules. The public and other interested parties 

are provided an opportunity to comment on proposed rules. The State has the authority to issue 

legally binding requirements (e.g., license conditions) in lieu of regulations. The NRC is 

provided the draft and final regulations and legally binding requirements for comment. The 

Section submits proposed rules to the NRC for review before rules are reviewed by the New 

Hampshire Administrative Unit. The Section sends final rules to the NRC for review once they 

are finalized as New Hampshire regulation. 

Final regulations in New Hampshire are subject to a sunset law. Rules expire exactly 8 years 

after adoption for rules filed prior to September 11, 2011. Regulations with rulemaking notices 

filed after September 11, 2011, now expire 10 years after the rule’s effective date. After 

expiration, these regulations must be resubmitted in their entirety to remain in effect. Parts of 

New Hampshire regulations (He-P 4036 Irradiators and He-P 4039 Well Logging) were set to 

expire on November 23, 2012, unless re-adopted. These rules were re-adopted without incident 

on September 25, 2012. 
New Hampshire Final IMPEP Report Page 10 

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

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

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

from the State Regulation Status sheet that FSME maintains. 

New Hampshire submitted two legally binding license conditions to the NRC for a compatibility 

review early in the review period. Current NRC policy requires that Agreement States adopt 

certain equivalent regulations or legally-binding requirements no later than 3 years after they 

become effective. Both of these legally-binding requirements were overdue for State adoption 

at the time of submission. In addition, the following ten amendments are overdue for State 

adoption, some significantly longer than three years from their effective date. (Two of the 

following ten rules were submitted as proposed for review by the NRC, but final rules are not yet 

adopted). 

• “Criteria for the Release of Individuals Administered Radioactive Material,” 10 CFR Parts 

20 and 35 amendments (62FR 4120) that became effective on May 29, 20001

. 

• “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 became effective 

October 1, 20072

. 

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

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

April 29, 2008. 

• “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. 

• “Medical Use of Byproduct Material – Minor Corrections and Clarifications,” 10 CFR 

Parts 32 and 35 amendments (72 FR 45147, 72 FR 54207) that became effective on 

October 29, 2007, and were due for Agreement State adoption on October 29, 2010. 

• “Exemptions from Licensing, General Licenses, and Distribution of Byproduct Material; 

Licensing and Reporting Requirements,” 10 CFR Parts 30, 31, 32, and 150 amendment 

(72 FR 58473), that was due for Agreement State adoption by December 17, 2010. 

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

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

adoption by November 30, 2010. 

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

 

1 Proposed rule submitted to the NRC on 6/6/2012. The NRC reviewed with no comment on 7/25/12. 2

 Proposed rule submitted to the NRC on 9/15/2009. The NRC reviewed with comment on 11/20/2009. 
New Hampshire Final IMPEP Report Page 11 

10 CFR Parts 19 and 20 amendment (72 FR 68043) that was due for Agreement State 

adoption on February 15, 2011. 

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

amendment (74 FR 33901) that became effective on September 28, 2009, that was due 

for Agreement State adoption by September 28, 2012. 

The Section is currently drafting proposed regulations for the 10 CFR Part 35 rules. However, 

considering the continued number of overdue amendments and lack of sustained performance 

in the timely adoption of regulations, the review team concluded that the New Hampshire 

Agreement State Program was not meeting the compatibility requirements as identified in the 

IMPEP evaluation criteria. 

The 2008 IMPEP review team made a recommendation that the Section develop and implement 

an action plan to adopt NRC regulations in accordance with the current NRC policy on 

adequacy and compatibility. The current review team concluded that the Section did not 

develop and implement an action plan for adoption of NRC regulations. 

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

that New Hampshire’s performance with respect to the indicator, Compatibility Requirements, 

be found unsatisfactory. 

4.2 Sealed Source and Device Evaluation Program

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

performance regarding the 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 Section’s SS&D evaluation activities, the review team examined information 

contained in the Section’s response to the IMPEP questionnaire for this indicator, verified the 

availability of guidance documents and procedures, and interviewed staff qualified to perform 

SS&D reviews. The Section performed one SS&D evaluation during the review period. 

4.2.1 Technical Staffing and Training

The Section has two qualified SS&D reviewers with full signature authority. Both have degrees 

in a physical science or engineering. One of the individuals has attended the NRC’s SS&D 

Workshop. The other individual received on-the-job training from the Massachusetts Radiation 

Control Program for evaluating SS&D applications. The review team determined that, although 

the Section does not review many SS&D applications, the Section has the necessary 

knowledge and skill among the reviewers to adequately handle applications. The Section has 

plans to train another staff member to be an SS&D reviewer in the near future, and intends to 

send this person to a future NRC SS&D Workshop. 

 
New Hampshire Final IMPEP Report Page 12 

4.2.2 Technical Quality of the Product Evaluation Program

The Section processed one new SS&D application since the last review and performed no 

amendments to existing SS&D evaluations. The listing of the SS&D certificate evaluated by the 

review team can be found in Appendix F. The review team confirmed that the Section follows 

the recommended guidance from the NRC SS&D Workshop, NUREG-1556 Series Guidance, 

applicable and pertinent American National Standards Institute (ANSI) standards and Military 

Standards, ISO-9001 and New Hampshire regulations, statutes, policies and procedures. The 

tie-down conditions on the certificate were stated clearly and are enforceable. Deficiency letters 

clearly stated regulatory positions and were used at the appropriate time. A concurrence review 

was performed by a second SS&D evaluation-qualified reviewer. The review team found no 

health and safety issues relative to the SS&D evaluation. 

4.2.3 Evaluation of Defects and Incidents Regarding SS&Ds

No incidents related to SS&D defects involving sources or devices registered by New 

Hampshire were reported during the review period. Incident procedures are in place should an 

SS&D-related incident occur. 

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

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

Evaluation Program, be found satisfactory. 

4.3 Low-Level Radioactive Waste Disposal Program

In 1981, the NRC amended its Policy Statement, "Criteria for Guidance of States and NRC in 

Discontinuance of NRC Regulatory Authority and Assumption Thereof by States Through 

Agreement," to allow a State to seek an amendment for the regulation of LLRW as a separate 

category. Although the New Hampshire Agreement State Program has LLRW disposal 

authority, NRC has not required States to have a program for licensing a LLRW disposal facility 

until such time as the State has been designated as a host State for a LLRW disposal facility. 

When an Agreement State has been notified or becomes aware of the need to regulate a LLRW 

disposal facility, they are expected to put in place a regulatory program which will meet the 

criteria for an adequate and compatible LLRW disposal program. There are no plans for a 

LLRW disposal facility in New Hampshire. Accordingly, the review team did not review this 

indicator. 

5.0 SUMMARY 

As noted in Sections 3.0 and 4.0 above, New Hampshire’s performance was found satisfactory 

for six of seven performance indicators reviewed. The Compatibility Requirements indicator 

was found unsatisfactory. The review team did not make any new recommendations regarding 

program performance by the State and determined that the recommendation from the 2008 

IMPEP review, concerning Compatibility Requirements, should be kept open. 

Accordingly, the review team recommended, and the MRB agreed, that the New Hampshire 

Agreement State Program be found adequate to protect public health and safety, and not 

compatible with the NRC's program. Based on the results of the current IMPEP review, the 
New Hampshire Final IMPEP Report Page 13 

review team recommended, and the MRB agreed, that the next full IMPEP review take place in 

approximately four years with a Periodic meeting occurring mid-cycle. The mid-cycle meeting 

should place additional emphasis on the status of Compatibility Requirements. In addition, the 

review team recommended, and the MRB agreed, that a period of Monitoring be initiated with 

Monitoring calls occurring at a frequency of every four months. According to the criteria in the 

NRC Management Directive 5.6, “Integrated Materials Performance Evaluation Program 

(IMPEP),” Monitoring may be used in cases where weaknesses in a program result in a less 

than fully satisfactory performance for one or more performance indicators. Monitoring is an 

informal process that allows the NRC to maintain an increased level of communication with an 

Agreement State program. The review team determined that Monitoring will be a useful tool in 

assessing the State’s progress toward completion of the overdue regulations. 

Below is the recommendation held open from the 2008 IMPEP for evaluation and 

implementation by the State. The New Hampshire Agreement State Program committed to 

submit to the NRC in January 2013 its action plan to address the open recommendation 

RECOMMENDATION: 

The review team recommends that the State develop and implement an action plan to 

adopt NRC regulations in accordance with the current NRC policy on adequacy and 

compatibility. 
LIST OF APPENDICES 

Appendix A IMPEP Review Team Members 

Appendix B New Hampshire 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

Lisa Dimmick, FSME Team Leader 

 Technical Staffing and Training 

 Status of the Materials Inspection Program 

 Compatibility Requirements 

Donna Janda, NRC Region I Technical Quality of Inspections 

 Inspector Accompaniments 

 Technical Quality of Incident and 

 Allegation Activities 

 

Judee Walden, Kansas Technical Quality of Licensing Actions 

 

Stephen Poy, FSME Sealed Source and Device Evaluation Program 

 
APPENDIX B 

NEW HAMPSHIRE ORGANIZATION CHARTS 

ADAMS ACCESSION NO.: ML12261A052 
 

 APPENDIX C 

INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Trustees of Dartmouth College License No.: 382R 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Dates: 11/26/08 Inspector: RD 

File No.: 2 

Licensee: Mary Hitchcock Memorial Hospital License No.: 130R 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 04/30/09 Inspectors: TK, RD 

File No.: 3 

Licensee: Nylon Corporation of America License No.: 142R 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Date: 05/12/09 Inspector: DL 

File No.: 4 

Licensee: University of New Hampshire License No.: 190R 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 03/17/10 Inspector: RD 

File No.: 5 

Licensee: Quality Assurance Laboratory, Inc. License No.: 439R 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 08/06/09 Inspectors: TK, RD 

File No.: 6 

Licensee: Monadnock Community Hospital License No.: 368R 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 09/30/09 Inspector: TL 

File No.: 7 

Licensee: Trustees of Dartmouth College License No.: 276R 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 10/28/10 Inspectors: TK, TL 

File No.: 8 

Licensee: Exeter Hospital License No.: 138R 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 02/18/10 Inspector: TL 
New Hampshire Final IMPEP Report Page C. 2 

Inspection Casework Reviews 

 

File No.: 9 

Licensee: Cheshire Medical Center License No.: 256R 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 12/14/10 Inspectors: TL, RD 

File No.: 10 

Licensee: RI Consultants LLC License No.: 469R 

Inspection Type: Initial, Announced Priority: 5 

Inspection Date: 09/20/11 Inspector: RD, TK 

File No.: 11 

Licensee: American Health Centers, Inc. License No.: 450R 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 04/14/11 Inspector: TL 

File No.: 12 

Licensee: New England Equine Medical & Surgical Center License No.: 466R 

Inspection Type: Initial, Announced Priority: 5 

Inspection Date: 11/17/11 Inspector: TK 

File No.: 13 

Licensee: Westinghouse Electric Company License No.: 465R 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 05/17/12 Inspector: RD 

Comment: Inspection report issued 97 days after completion of inspection. 

File No.: 14 

Licensee: Southern New Hampshire Medical Center License No.: 183R 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 08/30/12 Inspectors: TL, RD 

File No.: 15 

Licensee: ABC Testing, Inc. License No.: MA 19-7781 

Inspection Type: Reciprocity, Unannounced Priority: 1 

Inspection Date: 06/16/10 Inspector: RD 

 
New Hampshire Final IMPEP Report Page C. 3 

Inspection Casework Reviews 

 

INSPECTOR ACCOMPANIMENTS 

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

Accompaniment No.: 1 

Licensee: Monadnock Community Hospital License No.: 368R 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 09/11/12 Inspector: TL 

Accompaniment No.: 2 

Licensee: Quality Assurance Laboratories, Inc. License No.: 439R 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 09/12/12 Inspector: RD 
 

APPENDIX D 

LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: John Turner Consulting License No.: 423R 

Type of Action: Amendment Amendment No.: 18 

Date Issued: 08/31/09 License Reviewer: TL 

File No.: 2 

Licensee: Frisbie Memorial Hospital License No.: 357R 

Type of Action: Amendment Amendment No.: 60 

Date Issued: 0 8/28/12 License Reviewer: RD 

File No.: 3 

Licensee: American Health Centers, Inc. License No.: 450R 

Type of Action: Amendment Amendment No.: 18 

Date Issued: 09/25/12 License Reviewer: TL 

File No.: 4 

Licensee: Androscoggin Valley Hospital License No.: 268R 

Type of Action: Amendment Amendment No.: 42 

Date Issued: 06/10/11 License Reviewer: RD 

File No.: 5 

Licensee: Trustees of Dartmouth College License No.: 276R 

Type of Actions: Broadscope Amendment/Decommission Amendment No.: 45 & 46 

Date Issued: Decom-09/23/11, BS-09/30/11 License Reviewers: RD, TL 

File No.: 6 

Licensee: Littleton Regional Hospital License No.: 263R 

Type of Action: Renewal Amendment No.: 43 

Date Issued: 10/27/11 License Reviewer: TK 

File No.: 7 

Licensee: Tyco Electronics Integrated Cable Systems LLC License No.: 143R 

Type of Action: Renewal Amendment No.: 40 

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

File No.: 8 

Licensee: Metabolic Solutions License No.: 418R 

Type of Action: Amendment Amendment No.: 19 

Date Issued: 04/28/10 License Reviewer: TL 

 
New Hampshire Final IMPEP Report Page D. 2 

License Casework Reviews 

 

File No.: 9 

Licensee: Metabolic Solutions License No.: 418R 

Type of Action: Termination Amendment No.: 20 

Date Issued: 12/28/10 License Reviewer: TL 

File No.: 10 

Licensee: Cardiac Associates of New Hampshire License No.: 454R 

Type of Action: Termination Amendment No.: 02 

Date Issued: 02/27/09 License Reviewer: TK 

File No.: 11 

Licensee: Northeast Electronics Inc. License No.: 421R 

Type of Action: Amendment Amendment No.: 16 

Date Issued: 01/29/10 License Reviewer: DL 

File No.: 12 

Licensee: Mary Hitchcock Memorial Hospital License No.: 130R 

Type of Action: Amendment Amendment No.: 108 

Date Issued: 04/27/09 License Reviewer: DL 

File No.: 13 

Licensee: Quality Assurance Laboratories, Inc. License No.: 439R 

Type of Action: Amendment Amendment No.: 13 

Date Issued: 03/04/10 License Reviewer: TL 

File No.: 14 

Licensee: New England Molecular Imaging LLC License No.: 472R 

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

Date Issued: 11/22/10 License Reviewer: RD 

File No.: 15 

Licensee: Frank W. Whitcomb Construction Corp. License No.: 274R 

Type of Action: Renewal Amendment No.: 30 

Date Issued: 12/22/08 License Reviewer: CK 

File No.: 16 

Licensee: Michael Dutton DVM DABVP License No.: 453R 

Type of Action: Amendment Amendment No.: 06 

Date Issued: 03/28/11 License Reviewer: TK 

File No.: 17 

Licensee: Westinghouse Electric Company License No.: 465R 

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

Date Issued: 02/12/10 License Reviewer: RD 

 
New Hampshire Final IMPEP Report Page D. 3 

License Casework Reviews 

 

File No.: 18 

Licensee: Franklin Plaistow LLC License No.: 462R 

Type of Action: Denial (Failure to respond) Amendment No.: N/A 

Date Issued: N/A License Reviewer: RD 

File No.: 19 

Licensee: Frisbie Memorial Hospital License No.: 57R 

Type of Action: Denial (New User) Amendment No.: N/A 

Date Issued: N/A License Reviewer: TL 

File No.: 20 

Licensee: RI Consultants LLC License No.: 469R 

Type of Action: New License Amendment No.: 00 

Date Issued: 09/30/10 License Reviewers: RD, TK 

File No.: 21 

Licensee: Elliot Hospital License No.: 182R 

Type of Action: Renewal Amendment No.: 99 

Date Issued: 08/19/11 License Reviewer: RD 
 

APPENDIX E 

INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

File No.: 1 

Licensee: Advanced Recycling License No.: N/A 

Date of Incident: 07/20/09 Incident No.: 09-001 

Investigation Date: 07/22/09 Type of Incident: Lost/Stolen RAM 

 Type of Investigation: Site 

File No.: 2 

Licensee: Prolerized New England Company LLC License No.: 461R 

Date of Incident: 04/16/10 Incident No.: 10-001 

Investigation Date: 04/16/10 Type of Incident: Equipment Failure 

 Type of Investigation: Site 

Comment: No record of final disposition regarding cause of stuck shutter on an XRF device. 

Incident not reported to NRC within required timeframe. 

File No.: 3 

Licensee: Saint-Gobain Performance Plastics License No.: N/A 

Date of Incident: 07/14/10 Incident No.: 10-004 

Investigation Date: 08/11/10 Type of Incident: Lost/Stolen RAM 

 Type of Investigation: Site 

Comment: State did not update NRC event report as required after licensee determined two 

additional sources were lost. 

 

File No.: 4 

Licensee: McArdle Gannon Associates, Inc. License No.: MA 48-0518 

Date of Incident: 12/24/10 Incident No.: 10-009 

Investigation Date: 12/24/10 Type of Incident: Loss of Control 

 Type of Investigation: Site 
APPENDIX F 

SEALED SOURCE AND DEVICE CASEWORK REVIEW 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS. 

Registry No.: NH-1332-S-101-S SS&D Type: Brachytherapy Film Source 

Applicant Name: RI Consultants, LLC Type of Action: New Registration 

Date Issued: 09/30/2010 SS&D Reviewers: TK, AB 
ATTACHMENT 

November 29, 2012 letter from Jose T. Montero 

New Hampshire’s Response to the Draft Report 

ADAMS Accession No.: ML12352A061