July 2, 2009 

MEMORANDUM TO: Elmo E. Collins, Regional Administrator 

 Region IV 

FROM: Martin J. Virgilio /RA/

 Deputy Executive Director for Materials, Waste, 

 Research, State, Tribal, and Compliance Programs 

 Office of the Executive Director for Operations 

SUBJECT: FINAL REPORT OF THE INTEGRATED MATERIALS 

PERFORMANCE EVALUATION PROGRAM REVIEW OF THE 

REGION IV RADIOACTIVE MATERIALS PROGRAM 

On June 15, 2009, the Management Review Board (MRB) met to consider the proposed final 

Integrated Materials Performance Evaluation Program (IMPEP) report of the U.S. Nuclear 

Regulatory Commission’s Region IV radioactive materials program. The MRB found the 

program adequate to protect public health and safety. 

Section 5.0, page 11, of the enclosed final report summarizes the results of the review. The 

review team made no recommendations in regard to program performance by the Region. 

I applaud your staff’s efforts during the IMPEP review period, especially during the time of the 

team’s visit. 

Enclosure: 

Region IV Final IMPEP Report 

cc w/encl: Charles A. Casto, Deputy Regional Administrator 

 Region IV 

 Arthur T. Howell, Director 

 Division of Nuclear Materials Safety 

 Region IV 

 Shawn Seeley, Maine 

 Organization of Agreement States 

 Liaison to the MRB 

CONTACT: Kathleen Schneider, FSME/MSSA 

 (301) 415-2320 
July 2, 2009 

MEMORANDUM TO: Elmo E. Collins, Regional Administrator 

 Region IV 

FROM: Martin J. Virgilio /RA/

 Deputy Executive Director for Materials, Waste, 

 Research, State, Tribal, and Compliance Programs 

 Office of the Executive Director for Operations 

SUBJECT: FINAL REPORT OF THE INTEGRATED MATERIALS 

PERFORMANCE EVALUATION PROGRAM REVIEW OF THE 

REGION IV RADIOACTIVE MATERIALS PROGRAM 

On June 15, 2009, the Management Review Board (MRB) met to consider the proposed final 

Integrated Materials Performance Evaluation Program (IMPEP) report of the U.S. Nuclear 

Regulatory Commission’s Region IV radioactive materials program. The MRB found the 

program adequate to protect public health and safety. 

Section 5.0, page 11, of the enclosed final report summarizes the results of the review. The 

review team made no recommendations in regard to program performance by the Region. 

I applaud your staff’s efforts during the IMPEP review period, especially during the time of the 

team’s visit. 

Enclosure: 

Region IV Final IMPEP Report 

cc w/encl: Charles A. Casto, Deputy Regional Administrator 

 Region IV 

 Arthur T. Howell, Director 

 Division of Nuclear Materials Safety 

 Region IV 

 Shawn Seeley, Maine 

 Organization of Agreement States 

 Liaison to the MRB 

CONTACT: Kathleen Schneider, FSME/MSSA 

 (301) 415-2320 

Distribution: See next page 

ML091670278 EDATS: FSME-2009-0021

OFFICE FSME/MSSA FSME/MSSA FSME/MSSA Tech Editor 

NAME ATMcCraw (KMeyer for) ADWhite RJLewis CPoland 

DATE 6/16/09 6/17/09 6/21/09 6/23/09 

OFFICE FSME DEDMRT 

NAME GPangburn MJVirgilio 

DATE 6/26/09 07/02/09 

OFFICIAL RECORD COPY 
Memorandum to Elmo E. Collins from Martin J. Virgilio dated July 2, 2009 

SUBJECT: FINAL REPORT OF THE INTEGRATED MATERIALS PERFORMANCE 

EVALUATION PROGRAM REVIEW OF THE REGION IV RADIOACTIVE 

 MATERIALS PROGRAM 

DISTRIBUTION: FSME-2009-0021

MSSA RF DCD (SP01) 

EDO RF Chairman Jaczko 

RidsFsmeOd Commissioner Klein 

RidsSecyCorrespondenceMailCenter Commissioner Svinicki 

KSchneider, FSME/MSSA SECY 

MBeardsley, FSME/MSSA 

GParker, Region III 

Stephen James, OH 

Dorothy Stoffel, WA 

LMcLean, RIV/RSAO 

RErickson, RIV/RSAO 

JKatanic, FSME/MSSA 

WRautzen, FSME/MSSA 

ARivera, OEDO 

APowell, OCA (2 copies) 

SBurns, OGC 

JGray, OGC 

BJones, OGC 

TReis, FSME/MSSA 
Enclosure 

INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM 

REVIEW OF THE NRC REGION IV RADIOACTIVE MATERIALS PROGRAM 

March 23 - April 3, 2009 

FINAL REPORT
Region IV Final Report Page 1 

1.0 INTRODUCTION 

This report presents the results of the review of the U.S. Nuclear Regulatory Commission (NRC) 

Region IV radioactive materials program. The review was conducted during the period of 

March 23 – April 3, 2009, by a review team comprised of technical staff members from NRC and 

the States of Ohio and 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 April 2004 to March 2009, were discussed 

with Region IV managers on March 27, 2009, and April 3, 2009. 

A draft of this report was issued to Region IV for factual comment on April 28, 2009. Region IV 

responded by memorandum dated May 21, 2009, from Arthur T. Howell, Director, Division of 

Nuclear Materials Safety (the Division). A copy of the Division’s response is included as the 

Attachment to this report. The Management Review Board (MRB) met on June 15, 2009, to 

consider the proposed final report. The MRB found the NRC Region IV radioactive materials 

program adequate to protect public health and safety. 

The Region IV radioactive materials program is administered by the Director of the Division, 

who reports directly to the Regional Administrator. Organization charts for Region IV and the 

Division are included as Appendix B. At the time of the review, the Division regulated 

approximately 574 specific licenses authorizing the possession and use of byproduct, source, 

and special nuclear materials. 

In preparation for the review, a questionnaire addressing the common and non-common 

performance indicators was sent to the Division on December 22, 2008. The Division provided 

its response to the questionnaire on March 6, 2009. A copy of the questionnaire response may 

be found in NRC’s Agencywide Documents Access and Management System (ADAMS) using 

Accession Number ML090930292. 

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

the Division’s response to the questionnaire; (2) analysis of quantitative information from the 

licensing, inspection, and allegation databases, as well as ADAMS; (3) technical review of 

selected regulatory actions; (4) field accompaniments of three of the Division’s radioactive 

materials inspectors; and (5) interviews with staff and managers. The review team evaluated 

the information gathered against the established criteria for each common and applicable noncommon performance indicator and made a preliminary assessment of the Division’s 

performance. 

Section 2 below discusses Region IV’s actions in response to recommendations made following 

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

presented in Section 3. Section 4 discusses results of the applicable non-common indicators, 

and Section 5 summarizes the review team's findings. 
Region IV Final Report Page 2 

2.0 STATUS OF ITEMS IDENTIFIED IN PREVIOUS REVIEWS 

During the previous IMPEP review, which concluded on April 8, 2004, the review team made 

one recommendation in regard to program performance. The current status of the 

recommendation is as follows: 

The review team recommends that guidelines be provided to the Regions on revising 

inspection frequencies for licensees who were extended due to good performance prior 

to Temporary Instruction 2800/033, dated December 31, 2002. (Section 3.2) 

Current Status: Guidance was provided to the Regions in a May 11, 2004 memorandum 

from the Division of Industrial and Medical Nuclear Safety, Office of Nuclear Material 

Safety and Safeguards, and was implemented by all NRC Regions subsequent to the 

2004 Region IV IMPEP Review. This recommendation is closed. 

3.0 COMMON PERFORMANCE INDICATORS 

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

radioactive materials programs. These indicators are: (1) Technical Staffing and Training, (2) 

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

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

3.1 Technical Staffing and Training

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

indicator, interviewed Division managers and staff, and reviewed job descriptions, training plans, 

and training records and considered any possible workload backlogs in evaluating this indicator. 

During the 2004 IMPEP review, the Division was composed of three branches: the Nuclear 

Materials Licensing Branch, the Nuclear Materials Inspection Branch, and the Fuel Cycle and 

Decommissioning Branch. In 2006, the Division reorganized into the Nuclear Materials Safety 

Branch A (Branch A), the Nuclear Materials Safety Branch B (Branch B) and the Repository & 

Spent Fuel Safety Branch. The reorganization consolidated the uranium recovery and 

decommissioning activities into Branch B in order to focus the Repository & Spent Fuel Safety 

Branch on the anticipated workload from the high-level waste repository application from the 

U.S. Department of Energy. The Division is managed by a Director. The previous Senior 

Materials Analyst position is now a Deputy Director position within the Division. Each branch is 

headed by a Branch Chief. 

The Division experienced turnover of approximately two positions per year since the previous 

review. One branch chief and 11 staff members either retired or transferred to other NRC 

positions. At the time of the review, the Division had seven materials inspectors, three materials 

license reviewers, one licensing assistant, and one inspector who primarily performed 

decommissioning inspections. In its response to the questionnaire, the Division reported that 

three technical staff members had been hired during the review period. Technical staffing and 

qualifications of the uranium recovery inspectors are discussed in Section 4.1.1 of this report. 
Region IV Final Report Page 3 

There were four technical position vacancies in the Division at the time of the on-site review as 

a result of two recent retirements, one recent transfer, and a new position that was added to 

reflect increased uranium recovery inspection activities. One vacancy is for an inspector in 

Branch A. Three vacancies in Branch B are for a decommissioning/uranium recovery inspector, 

a license reviewer, and a decommissioning inspector. At the time of the review, Division 

managers were reviewing applications and scheduling interviews with qualified candidates. 

When these positions are filled, the Division will have a staff of 17 direct full-time equivalents 

devoted to the radioactive materials program, including the uranium recovery effort. 

The Division uses Inspection Manual Chapter (IMC) 1246, “Formal Qualification Programs in the 

Nuclear Material Safety and Safeguards Program Area,” and associated procedures as its 

qualification and training program. The qualifications of the staff were determined from the 

questionnaire, training records, and interviews of managers and personnel. The review team 

determined that the staff is well qualified from an education and experience standpoint. All staff 

has at least a Bachelor’s degree in the one of the sciences or has equivalent training and 

experience. 

Generally, newly hired inspectors and license reviewers are trained and certified in a reasonable 

time period. In cases where completion of the qualification journal or certification process took 

longer than originally expected, the Branch Chiefs adequately documented the exception and 

justification in the appropriate personnel files. 

The Division has a policy of qualifying personnel as either license reviewers or inspectors; 

however, the Division has implemented a voluntary cross-training program among staff of 

Branches A and B. This allows Division managers to have flexibility to allocate resources where 

needed and to readjust the workload between licensing and inspection, as necessary. 

The review team determined that Region IV has a well-organized system for planning, 

approving, and tracking training. Division managers were fully cognizant of the qualification 

status and training plans for their staff, and the managers exhibited a commitment to training. 

Technical staff members regularly attended specialty training courses and refresher training and 

appeared to maintain technical currency for their assigned positions. The review team 

concluded that Region IV has a good mix in staffing for materials licensing and inspection 

activities, as well as decommissioning activities. 

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

that Region IV's performance with respect to the indicator, Technical Staffing and Training, was 

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

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

Division managers and staff. 
Region IV Final Report Page 4 

The review team verified that the Division adheres to the inspection priorities prescribed in IMC 

2800, “Materials Inspection Program.” The Division appropriately modified inspection schedules 

in response to revisions to IMC 2800 during the review period. 

The review team determined that the Division conducted 382 inspections of high priority (Priority 

1, 2, and 3) licensees during the review period. The review team identified 11 of these 

inspections as performed overdue by more than 25 percent of the inspection frequency listed in 

IMC 2800. Six of the overdue inspections had been delayed in order to conduct the Increased 

Controls inspections coincidental with the health and safety inspection, as permitted by NRC’s 

Guidance for Increased Controls Prioritization Methodology. The remaining overdue 

inspections can be attributed to input errors in the Licensing Tracking System. Region IV 

covers a significant geographical area, and Division managers schedule inspections in remote 

locations to minimize resource implications when possible. The review team determined that 

the Division conducted 118 initial inspections of new radioactive materials licenses during the 

review period. Of the 118 initial inspections, 4 were performed greater than 12 months after 

license issuance. Overall, the review team calculated that the Division performed 3 percent of 

all Priority 1, 2, and 3 inspections and initial inspections overdue during the review period. 

The timeliness of the issuance of inspection findings was evaluated during the inspection 

casework review. For the routine inspection files examined, inspection findings were sent to the 

licensees within 30 days with the exception of one report which was less than a week late. 

The Division granted 39 reciprocity permits in 2004, 39 reciprocity permits in 2005, 

28 reciprocity permits in 2006, 33 reciprocity permits in 2007 and 35 reciprocity permits in 2008 

to candidate licensees, based upon the criteria in IMC 1220. In 2004, the Division missed the 

reciprocity inspection goal of 20 percent by 3 inspections. The Division developed an action 

plan to determine the cause of the missed target and implemented a strategy to achieve the 

reciprocity goal. The Division met the reciprocity inspection goals in 2005 and 2007. In 2006, 

the Division focused resources on completion of the initial Increased Control inspections and 

missed the reciprocity inspection goal by two inspections. Since the reciprocity inspection 

program was unfunded in 2008, the Division attempted to meet the goal by coordinating 

reciprocity inspections with routine inspection trips and inspected 9 percent of the candidates. 

The review team determined that with respect to Commission Staff Requirements Memorandum 

(SRM) for COMSECY-05-0028, on Increased Controls, the Division completed the initial set of 

inspections of these licensees in accordance with the SRM. The Division’s prioritization 

methodology was consistent with the prioritization methodology provided by NRC Headquarters. 

The Division has 78 licensees that are implementing the Increased Controls. They perform 

subsequent inspections of the licensee’s Increased Controls program during the routine health 

and safety inspection. At the time of the review, no Increased Control inspections were 

conducted overdue. 

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

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

Program, was satisfactory. 
Region IV Final Report Page 5 

3.3 Technical Quality of Inspections

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

field notes and interviewed the responsible inspectors for 21 radioactive materials inspections 

conducted during the review period. The casework reviewed included inspections conducted by 

11 of the Division’s inspectors and covered inspections of various license types including: 

medical broadscope, medical institutions-written directive required, medical high dose rate 

afterloader, mobile medical, industrial radiography, research and development broadscope, 

irradiator, well logging, nuclear pharmacy, decommissioning, manufacturing and distribution, 

security, and reciprocity. Appendix C lists the inspection files reviewed and includes casespecific comments. 

The Division uses IMC 2800 and other NRC inspection procedures for its inspection guidance. 

After the conclusion of each inspection, inspectors dispatched inspection findings to the 

respective licensees either in the field or from the office after Branch management review and 

approval. The Branch Chief’s review of each inspection report was appropriately documented 

and all inspection documentation was entered into ADAMS. 

The review team found that inspection reports were thorough, complete, consistent, and of high 

quality, with sufficient documentation to ensure that a licensee’s performance with respect to 

health, safety, and security was acceptable. Inspection findings led to appropriate and prompt 

regulatory action, when necessary. Based on the review of casework, the review team 

concluded that the inspections covered all aspects of the licensees’ radiation safety programs 

commensurate with licensed activities. 

During the casework review, the review team found that some documents containing securityrelated information were not marked with the appropriate designation of “Official Use Only – 

Security-Related Information”. These documents included NRC Form 591 Part 3 inspection 

forms. The review team did not discover any evidence that any of the information was 

inadvertently released to the public. The Division identified and marked all documentation that 

contained security-related information while the review team was on site. In addition, the 

Division retrained staff to use the 591 Part 3 template with the appropriate markings if securityrelated information is included on the form. 

The review team determined that supervisory accompaniments were conducted annually for all 

inspectors. The Branch Chiefs made a total of 92 accompaniments during the review period. 

Inspectors receive verbal feedback at the time of the accompaniments and a portion of the 

inspectors’ annual performance appraisals address their inspection skills, as demonstrated 

during the accompaniments. 

The review team observed that the Division maintains 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, was 

observed to be available. Instruments are calibrated annually through several commercial 

calibration services. The Division uses the services of the Oak Ridge Institute for Science and 

Education for the analysis of wipe samples taken during inspections. 
Region IV Final Report Page 6 

The review team accompanied two of the Division’s inspectors during the months of February 

and March 2009. The inspectors were accompanied during health and safety inspections of 

mobile and fixed medical programs, an academic broadscope, and a research and development 

facility. The review team also observed an inspector perform a security inspection. The 

accompaniments are identified in Appendix C. During the accompaniments, both 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 and implementation of 

the Increased Controls requirements. 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, 

safety, and security at the licensed facilities. 

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

that Region IV’s performance with respect to the indicator, Technical Quality of Inspections, was 

satisfactory. 

3.4 Technical Quality of Licensing Actions

The review team examined the casework for 27 materials licensing actions, and held interviews 

with the license reviewers, the licensing assistant, the Branch Chief and the project manager for 

the Department of the Air Force Master Materials License. The licensing casework was 

selected to provide a cross-section of the different types of licensing actions completed by all 

license reviewers during the review period. The following types of licenses were included in the 

review: industrial radiography, research and development, medical institution - written directive 

required, medical private practice, medical high dose rate afterloader, portable gauge, well 

logging, manufacturing and distribution, special nuclear material, irradiator, master materials 

license, and possession only. Licensing actions included 4 new applications, 3 renewals 

(including associated decommissioning financial assurance), 3 terminations, and 17 

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

be found in Appendix D. 

The review team examined the processes used by Branch for receipt and assignment of 

licensing actions. Licensing actions are logged in by the licensing assistant upon receipt. 

Branch staff members pre-screen the actions received each week using an Acceptance Review 

Memo (ARM) to ensure the applicant has provided sufficient information for license reviewers to 

conduct a review of the request. The ARM is periodically updated to reference changes in 

regulations and licensing guidance. The pre-screening also checks if the request contains 

sensitive information to ensure that the documents are appropriately scanned, marked, and 

entered into ADAMS. Licensing actions are then assigned to a reviewer during a weekly Branch 

meeting. 

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, backed by information contained in the file, and auditable. 

Licenses and correspondence are generated using standardized conditions and formats. 

Licensing staff appropriately used licensing guides, policies, and standard license conditions. 
Region IV Final Report Page 7 

Licensees’ compliance histories were taken into account when reviewing all renewal 

applications and major amendments. 

The review team examined the list of licensees that were determined to meet the criteria for the 

Increased Controls. The review team found that the appropriate license conditions were added 

to those licenses in a timely manner. In reviewing the licensing documents, the review team 

found that licenses containing sensitive information were properly marked as such; however, the 

cover letter transmitting the license was not always appropriately marked as required by NRC 

Management Directive 12.6, “NRC Sensitive Unclassified Information Security Program.” The 

Division identified that discrepancies exist between Management Directive 12.6 and Regulatory 

Information Summary (RIS) 2005-031 regarding the marking of transmittal documents. The 

review team recommends that the Office of Federal and State Materials and Environmental 

Management Programs (FSME) develop and provide clarification to the NRC Regions on the 

requirements for marking of inspection and licensing correspondence. 

The review team found that the Division reduced authorized possession limits on some licenses 

listing radionuclides of concern in order to be below the threshold limits requiring 

implementation of the Increased Controls; however, these lower possession limits were 

calculated based on activities in curies instead of terabequerels. As a result, possession limits 

for certain isotopes were authorized at quantities that were still above the Increased Controls 

threshold limits and did not contain the appropriate license condition. The Division identified 

those licenses that potentially contained such errors and gave refresher training on the 

Guidance for Applying the Additional Requirements for Increased Controls, issued December 

14, 2006. While the review team was on site, the Division completed corrections on a number 

of the affected licenses and developed an action plan to correct the remainder in a timely 

manner. 

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

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

Actions, was satisfactory. 

3.5 Technical Quality of Incident and Allegation Activities

In evaluating the effectiveness of the Division’s actions in responding to incidents, the review 

team examined the Division’s response to the questionnaire relative to this indicator, evaluated 

selected incidents reported for Region IV in the Nuclear Material Events Database (NMED) 

against those contained in the Division’s files, and evaluated the casework for 21 radioactive 

materials incidents. A listing of the incident casework examined can be found in Appendix E. 

The review team also evaluated the Division’s response to 19 allegations involving radioactive 

materials. 

The review team identified 220 radioactive materials incidents in NMED for Region IV during the 

review period. The incidents selected for review included the following categories: medical, 

lost/stolen material, exposure to the embryo/fetus, contamination events, and equipment failure. 

The review team discussed incident and allegation procedures, file documentation, NMED, and 

the role of the NRC Headquarters Operations Center with Division staff and managers. The 

Division is responsible for initial response and followup actions to radioactive materials 

incidents. The review team determined that the Division’s response to incidents was complete 
Region IV Final Report Page 8 

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

was commensurate with the health and safety significance in all cases. The Division dispatched 

inspectors for on-site investigations, as appropriate, and took suitable enforcement and followup 

actions. 

In evaluating the effectiveness of the Division’s actions in response to allegations, the review 

team evaluated the casework for 19 allegations. The review team held interviews with the 

Regional Allegation Coordinators, Division managers, and Division technical staff regarding the 

handling of allegations. The Division adheres to NRC Management Directive 8.8, “Management 

of Allegations” in the handling of allegations. The review team’s evaluations of casework, 

associated documentation, and interviews of staff and managers revealed that the Division has 

an effective and efficient program for managing radioactive materials allegations. The casework 

review indicated that the Division took prompt and appropriate action in response to all concerns 

raised. All of the allegations reviewed were appropriately closed, and appropriate parties were 

notified of the actions taken. 

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

that Region IV’s performance with respect to the indicator, Technical Quality of Incident and 

Allegation Activities, was satisfactory. 

4.0 NON-COMMON PERFORMANCE INDICATORS 

IMPEP identifies one non-common performance indicator to be used in reviewing Regional 

radioactive materials programs, the Uranium Recovery Program. 

4.1 Uranium Recovery Program

This non-common indicator includes five subelements of the uranium recovery regulatory 

program: 1) Technical Staffing and Training, 2) Status of the Uranium Recovery Inspection 

Program, 3) Technical Quality of the Uranium Recovery Inspection Program, 4) Technical 

Quality of Licensing, and 5) Technical Quality of Incidents and Allegation Activities. Region IV 

does not conduct uranium recovery licensing, this is performed by staff in the Division of Waste 

Management and Environmental Protection, FSME; therefore, Subelement 4 was not addressed 

in this review. 

4.1.1 Technical Staffing and Training 

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

of the staff, staff training, and staff turnover. There are presently two inspectors who perform 

the uranium recovery inspections. The review team determined that the Division’s staffing level 

for uranium recovery inspections was appropriate based on workload at the time of the review. 

The review team determined that staff qualifications and training were adequate. The Region IV 

uranium recovery inspectors have reactor health physics or radioactive materials safety 

backgrounds, so the health physics focus of the inspections was strong. Region IV inspectors 

routinely coordinated inspections with technical staff from FSME for the necessary expertise to 

review other areas; such as geotechnical engineering, hydrology, and geosciences; for the two 
Region IV Final Report Page 9 

operating in situ leach facilities: Power Resources Smith Ranch and Crow Butte. At the 

conventional mill sites in decommissioning, there was little ongoing activity that warranted joint 

inspections between Region IV and FSME staff; however, Region IV staff maintained 

communication with FSME technical and licensing uranium recovery staff for effective 

inspections at the decommissioning sites. 

4.1.2 Status of the Uranium Recovery Inspection Program

The review team focused on several factors in evaluating Region IV's performance for this 

subelement, including inspection frequency, overdue inspections, timely issuance of inspection 

findings to licensees, and inspection followup. The review team's evaluation is based on a 

review of the Division's 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 Division conducted 39 inspections and 5 site visits. Most of the 

sites are non-operating conventional mills that are in various stages of decommissioning and 

reclamation. Inspection frequency is established through a Master Inspection Plan developed 

by the Division in conjunction with the FSME. The inspection schedule is based on guidance in 

NRC IMC 2641, “In-Situ Leach Facilities Inspection Program,” and IMC 2801, “Uranium Mill and 

11e.(2) Byproduct Material Disposal Site and Facility Inspection Program.” There were three 

inspections during the review period that were conducted overdue. During Fiscal Years 2003-

2007, two inspections, Western Nuclear – Split Rock and Anadarko Petroleum – Bear Creek, 

were deferred at the request of the FSME. These inspections were subsequently performed 

during 2008. Another inspection, Hydro Resources, was also deferred because the licensee 

was issued a source material license, although construction had not started due to adjudication. 

FSME uranium recovery staff requested inspection deferral until the adjudication is complete. 

The review team evaluated the timeliness of the issuance of inspection findings during the 

inspection file review. The review team determined that all inspection reports that were 

reviewed were issued within 30 days after completion of the inspection and final closeout with 

licensee managers and operations staff. 

4.1.3 Technical Quality of Uranium Recovery Inspections

In reviewing this subelement, the review team examined inspection reports and other 

documentation for eight inspections conducted during the review period. The cases selected for 

review covered various licensees representing 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, the depth and content of the actual 

inspections, and the appropriateness of inspection findings. A list of the uranium recovery 

inspection files that were reviewed is included as Appendix F. 

Generally, one Region IV uranium recovery inspector will conduct an inspection with occasional 

assistance from other inspectors, supervisors, or FSME technical staff. The inspectors 

coordinate, plan, and prepare for inspections by reviewing relevant manual chapters, inspection 

procedures, previous inspection reports, licenses, incident reports, notices of violations, and 
Region IV Final Report Page 10 

other background information. They will often consult with the uranium recovery licensing staff 

in FSME before inspections. 

The review determined that, during a typical inspection, inspectors observe licensee operations; 

interview workers, managers, and contractors; review facility records; examine site operating 

plans and procedures; and make independent measurements during inspections. 

During the week of March 16, 2009, a review team member accompanied an inspector at the 

Power Resources, Inc. facility, as indicated in Appendix F. The inspector was prepared and 

thorough in her review of the aspects of the licensee's radiation safety program. Although the 

Division’s uranium recovery inspectors primarily focus on health physics and radiation safety 

issues, they also routinely inspect for environmental monitoring, management, and 

organizational issues. The inspectors typically observe a broad spectrum of licensee 

operations. 

The review team found that the Region IV uranium recovery inspection reports were well 

written, provided appropriate depth, and were promptly reviewed by supervisors. They 

addressed compliance conditions for the licensees, and demonstrated that the inspectors 

pursued root causes where problems or violations were identified. 

The inspection findings lead to appropriate and prompt regulatory action. Licensees are given 

30 days to reply to the Notice of Violation. After the response, a letter is sent to the licensee 

indicating if the review of the proposed corrective actions is satisfactory or not. 

The review team determined that during the review period, the uranium recovery inspectors had 

been accompanied by their supervisors at least once a year. The review team found that the 

supervisors routinely meet with the uranium recovery inspectors after their inspections to review 

inspection findings and to plan followup strategy. 

4.1.4 Technical Quality of Licensing Actions

Since the Division does not perform uranium recovery licensing actions, this subelement was 

not evaluated during the review. 

4.1.5 Technical Quality of Incident and Allegation Activities

To evaluate this subelement, the review team examined the information on the uranium 

recovery incidents provided by the Division in its response to the questionnaire. The Division 

received notification of one uranium recovery incident during the review period. The incident 

was captured in NMED; however, it did not meet the reporting criteria. A followup inspection 

was performed during which the inspector determined that the license condition requiring 

reporting of events needed clarification. This was discussed with FSME uranium recovery staff 

as an item to be resolved during the next license renewal.

4.1.6 Conclusion

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

that Region IV’s performance with respect to the indicator, Uranium Recovery Program, was 

satisfactory. 
Region IV Final Report Page 11 

5.0 SUMMARY 

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

performance indicators reviewed. Accordingly, the review team recommended, and the MRB 

agreed, that the NRC Region IV radioactive materials program be found adequate to protect 

public health and safety. Based on the results of the current IMPEP review, the review team 

recommended, and the MRB agreed, that the next full IMPEP review of the NRC Region IV 

radioactive materials program take place in approximately 4 years. 

Below is the recommendation, as mentioned earlier in the report, for evaluation and 

implementation, as appropriate, by FSME: 

The review team recommends that FSME develop and provide clarification to the NRC 

Regions on the requirements for marking of inspection and licensing correspondence. 

(Section 3.4) 
LIST OF APPENDIXES AND ATTACHMENT 

Appendix A IMPEP Review Team Members 

Appendix B Region IV Organization Charts 

Appendix C Inspection Casework Reviews 

Appendix D License Casework Reviews 

Appendix E Incident Casework Reviews 

Appendix F Uranium Recovery Casework Reviews 

Attachment May 21, 2009 Memorandum from Arthur T. Howell 

 Region IV’s Response to the Draft Report 
APPENDIX A 

IMPEP REVIEW TEAM MEMBERS 

Name Area of Responsibility

Kathleen Schneider, FSME Team Leader 

 Technical Staffing and Training 

 Status of Materials Inspection Program 

Michele Beardsley, FSME Technical Quality of Inspections 

 Inspector Accompaniments 

Stephen James, OH Technical Quality of Licensing Actions 

George Parker, Region III Technical Quality of Incident and Allegation 

 Activities 

Dorothy Stoffel, WA Uranium Recovery Program 

 Inspector Accompaniments 
APPENDIX B 

REGION IV ORGANIZATION CHARTS 

ADAMS ACCESSION NO.: ML091120066 
APPENDIX C 

INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: Materials Integrity Inc. License No.: 50-27722-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 12/10/08 Inspector: LD 

File No.: 2 

Licensee: Materials Integrity, Inc. License No.: 50-27722-01 

Inspection Type: Special, Announced Priority: 1 

Inspection Date: 9/19/07 Inspector: LD 

Comment: 

NRC 591 Part 3 not marked appropriately. 

File No.: 3 

Licensee: Como Tech Inspection License No.: 15-26978-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 2/26/09 Inspector: AG 

Comment: 

NRC 591 Part 3 not marked appropriately. 

File No.: 4 

Licensee: Advanced Isotopes of Idaho License No.: 11-29216-01MD 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 12/4/08 Inspector: JR 

File No.: 5 

Licensee: Anvil Corporation License No.: 46-23236-03 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 8/15/07 Inspector: LD 

File No.: 6 

Licensee: Edge Solutions License No.: 50-29244-01 

Inspection Type: Special, Announced Priority: 1 

Inspection Date: 12/5/07 Inspector: LD 

Comment: 

NRC 591 Part 3 not marked appropriately. 
Region IV Final Report Page C.2 

Inspection Casework Reviews

File No.: 7 

Licensee: Edge Solutions License No.: 50-29244-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 12/9/08 Inspector: LD 

File No.: 8 

Licensee: Alaska Industrial X-Ray License No.: 50-16084-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 8/1/06 Inspector: RE 

File No.: 9 

Licensee: Queens Medical Center License No.: 53-16533-02 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 3/28/08 Inspector: RL 

Comment: 

NRC 591 Part 3 not marked appropriately. 

File No.: 10 

Licensee: Big State X-Ray Inc. License No.: 35-21144-01 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Date: 12/10/07 Inspector: RM 

Comment: 

NRC 591 Part 3 not marked appropriately. 

File No.: 11 

Licensee: Unitech Services Group License No.: 53-13668-01 

Inspection Type: Routine, Announced Priority: N/A 

Inspection Date: 4/22/08 Inspector: RE 

File No.: 12 

Licensee: Department of the Air Force License No.: 42-23539-01AF 

Inspection Type: Routine, Announced Priority: N/A 

Inspection Date: 10/24/08 Inspectors: RB, JC 

File No.: 13 

Licensee: Lovelace Respiratory License No.: 30-29237-01 

Inspection Type: Routine, Unannounced Priority: 5 

Inspection Dates: 5/1/07 and 5/6/07 Inspector: AG 

Comment: 

Report contained a non-cited violation without an explanation as to why it was non-cited 

versus cited. 
Region IV Final Report Page C.3 

Inspection Casework Reviews

File No.: 14 

Licensee: Department of Commerce- NOAA License No.: 25-11997-01 

Inspection Type: Routine, Telephone Priority: 5 

Inspection Date: 6/6/06 Inspector: LG 

File No.: 15 

Licensee: Department of the Army-Wm. Beaumont Med. Ctr. License No.: 42-05255-07 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 11/13/06 Inspector: RL 

File No.: 16 

Licensee: Department of the Army-Tripler Army Med. Ctr. License No.: 53-00458-04 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 10/22/08 Inspector: AG 

File No.: 17 

Licensee: SABIA, Inc. License No.: 11-27727-01 

Inspection Type: Reactive, Follow-up Priority: 5 

Inspection Date: 2/29/08 and 9/18/08 Inspectors: JK, AG, LD 

File No.: 18 

Licensee: Integrated Product Svcs. License No.: 17-27763-01 

Inspection Type: Routine, Announced Priority: 3 

Inspection Date: 10/23/06 Inspector: RL 

File No.: 19 

Licensee: Integrated Product Svcs. License No.: 17-27763-01 

Inspection Type: Initial Special, Announced Priority: 3 

Inspection Date: 9/12/07 Inspector: RM 

File No.: 20 

Licensee: Dept. of Army-White Sands Missile Range License No.: 30-02405-10 

Inspection Type: Routine, Unannounced Priority: 1 

Inspection Dates: 1/18 to 2/13/06 Inspector: RL 

File No.: 21 

Licensee: Riverton Memorial Hospital License No.: 49-21004-01 

Inspection Type: Routine, Announced Priority: 3 

Inspection Date: 11/29/07 Inspector: JT 
Region IV Final Report Page C.4 

Inspection Casework Reviews

INSPECTOR ACCOMPANIMENTS 

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

Accompaniment No.: 1 

Licensee: Lovelace Respiratory License No.: 30-29237-01 

Inspection Type: Routine, Unannounced Priority: 2 

Inspection Date: 3/12/09 Inspector: RM 

Accompaniment No.: 2 

Licensee: Lovelace Respiratory License No.: 30-29237-01 

Inspection Type: Routine/Special, Announced Priority: 2 

Inspection Date: 3/12/09 Inspector: RM 

Accompaniment No.: 3 

Licensee: Front Range Nuclear Svcs. License No.: 49-27531-01 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 2/10/09 Inspector: JR 

Accompaniment No.: 4 

Licensee: University of Wyoming License No.: 49-09955-10 

Inspection Type: Routine, Unannounced Priority: 3 

Inspection Date: 2/10/09 Inspector: JR 
APPENDIX D 

LICENSE CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: Lovelace Respiratory License No.: 30-29237-01 

Type of Action: Amendment Amendment No.: 10 

Date Issued: 11/3/08 License Reviewer: RT 

File No.: 2 

Licensee: Guam Memorial Hospital License No.: 56-18134-01 

Type of Action: Renewal Amendment No.: 25 

Date Issued: 1/13/06 License Reviewer: RT 

File No.: 3 

Licensee: H & H X-Ray License No.: 17-19236-01 

Type of Action: Amendment Amendment No.: 25 

Date Issued: 2/22/05 License Reviewers: RB, AG 

File No.: 4 

Licensee: Precision Energy License No.: 35-26895-02 

Type of Action: Termination Amendment No.: 02 

Date Issued: 2/13/09 License Reviewer: RT 

File No.: 5 

Licensee: Southwest X-Ray Corporation License No.: 49-27434-01 

Type of Action: Amendment Amendment No.: 08 

Date Issued: 9/14/04 License Reviewer: JC 

File No.: 6 

Licensee: The Queen’s Medical Center License No.: 53-16533-02 

Type of Action: Amendment Amendment No.: 53 

Date Issued: 1/19/07 License Reviewer: JC 

File No.: 7 

Licensee: Department of Commerce-NOAA License No.: 05-11997-01 

Type of Action: Amendment Amendment No.: 40 

Date Issued: 2/24/09 License Reviewer: RT 

File No.: 8 

Licensee: Defense Microelectronics Activity License No.: 04-29107-01 

Type of Action: Renewal Amendment No.: 6 

Date Issued: 12/4/07 License Reviewer: JM 

Comment: 

Open-ended authorized possession limits used. 
Region IV Final Report Page D.2 

License Casework Reviews

File No.: 9 

Licensee: Acuren Inspection, Inc License No.: 42-27593-01 

Type of Action: Amendment Amendment No.: 31 

Date Issued: 4/1/08 License Reviewer: RS 

File No.: 10 

Licensee: Sanford Medical Center License No.: 40-12378-01 

Type of Action: Amendment Amendment No.: 68 

Date Issued: 4/16/07 License Reviewer: JM 

Comment: 

Possession limits not calculated properly to exempt licensee from certain license 

conditions. 

File No.: 11 

Licensee: Sanford Medical Center License No.: 40-12378-01 

Type of Action: Amendment Amendment No.: 69 

Date Issued: 11/20/07 License Reviewer: RT 

Comment: 

Possession limits not calculated properly to exempt licensee from certain license 

conditions. 

File No.: 12 

Licensee: Sanford Medical Center License No.: 40-12378-01 

Type of Action: Amendment Amendment No.: 70 

Date Issued: 11/18/08 License Reviewer: RB 

Comment: 

Possession limits not calculated properly to exempt licensee from certain license 

conditions. 

File No.: 13 

Licensee: Texas Gamma Ray, LLC License No.: 42-29303-01 

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

Date Issued: 1/6/09 License Reviewer: JC 

Comment: 

Licensee authorized to analyze own leak tests; however, this activity was not requested 

by licensee. 

File No.: 14 

Licensee: Carroll College License No.: 25-07093-01 

Type of Action: Termination Amendment No.: 12 

Date Issued: 1/17/06 License Reviewer: RB 
Region IV Final Report Page D.3 

License Casework Reviews

File No.: 15 

Licensee: National Aeronautics and Space Administration License No.: 42-09388-01 

Type of Action: Amendment Amendment No.: 33 

Date Issued: 4/21/06 License Reviewer: RB 

File No.: 16 

Licensee: Genencor International License No.: 04-27770-01 

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

Date Issued: 2/5/04 License Reviewer: JM 

File No.: 17 

Licensee: Genencor International License No.: 04-27770-01 

Type of Action: Termination Amendment No.: 01 

Date Issued: 3/10/06 License Reviewer: JM 

File No.: 18 

Licensee: Treadwell & Rollo, Inc. License No.: 04-29219-01 

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

Date Issued: 11/18/05 License Reviewer: RB 

Comment: 

Open-ended authorized possession limits used. 

File No.: 19 

Licensee: GlaxoSmithKline Biologicals License No.: 25-19852-01 

Type of Action: Decommissioning Amendment Amendment No.: 21 

Date Issued: 5/30/07 License Reviewer: RB 

File No.: 20 

Licensee: Avera St. Luke’s License No.: 40-18000-01 

Type of Action: Amendment Amendment No.: 30 

Date Issued: 4/4/07 License Reviewer: RB 

File No.: 21 

Licensee: Pocatello Cardiology Associates License No.: 11-27809-01 

Type of Action: Amendment Amendment No.: 02 

Date Issued: 12/23/08 License Reviewer: JC 

File No.: 22 

Licensee: International Isotopes, Inc. License No.: 11-27680-01 

Type of Action: Amendment Amendment No.: 35 

Date Issued: 3/19/08 License Reviewer: RT 
Region IV Final Report Page D.4 

License Casework Reviews

File No.: 23 

Licensee: Century Geophysical Corporation License No.: 35-04017-04 

Type of Action: Renewal Amendment No.: 30 

Date Issued: 6/10/08 License Reviewer: JC 

Comment: 

 License issued without certain required license condition based on authorized 

possession limits. 

File No.: 24 

Licensee: Souixland Urology Center LLC License No.: 40-34223-01 

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

Date Issued: 7/15/05 License Reviewer: JC 

File No.: 25 

Licensee: Memorial Hospital of Sweetwater License No.: 49-17940-01 

Type of Action: Amendment Amendment No.: 09 

Date Issued: 12/15/08 License Reviewer: RT 

File No.: 26 

Licensee: Cancer Center of Hawaii License No.: 53-27797-01 

Type of Action: Amendment Amendment No.: 01 

Date Issued: 12/18/06 License Reviewer: JC 

Comment: 

Possession limits not calculated properly to exempt licensee from certain license 

conditions. 

File No.: 27 

Licensee: Dept. of the Army, Brooke Army Medical Center License No.: 42-01368-01 

Type of Action: Amendment Amendment No.: 93 

Date Issued: 1/14/09 License Reviewer: RB 
APPENDIX E 

INCIDENT CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: Department of the Army License No.: 30-02405-01 

Date of Incident: 9/25/05 Incident Log No.: 050649 

Investigation Date: 10/4/05 Type of Incident: Equipment failure 

 Type of Investigation: Site 

File No.: 2 

Licensee: TEAM Industrial Svcs. License No.: 42-32219-01 

Date of Incident: 4/18/06 Incident Log No.: 060262 

Investigation Date: 4/19/06 Type of Incident: Equipment failure 

 Type of Investigation: Licensee report 

File No.: 3 

Licensee: National Institute of Standards and Technology License No.: 05-03166-05 

Date of Incident: 6/9/08 Incident Log No.: 080326 

Investigation Date: 6/12/08 Type of Incident: Contamination 

 Type of Investigation: Site 

File No.: 4 

Licensee: SABIA License No.: 11-27727-01 

Date of Incident: 2/29/08 Incident Log No.: 080128 

Investigation Date: 2/29/08 Type of Incident: Ruptured source 

 Type of Investigation: Site 

File No.: 5 

Licensee: Department of the Air Force License No.: 42-23539-01AF 

Date of Incident: 6/4/08 Incident Log No.: 080514 

Investigation Date: 9/5/08 Type of Incident: Dose to embryo/fetus 

 Type of Investigation: Site 

File No.: 6 

Licensee: Schlumberger Technology License No.: 42-27055-01 

Date of Incident: 4/5/07 Incident Log No.: 070609 

Investigation Date: 4/6/07 Type of Incident: Abandoned source 

 Type of Investigation: Licensee report 

File No.: 7 

Licensee: Alaska Industrial X-Ray License No.: 50-16084-01 

Date of Incident: 8/30/06 Incident Log No.: 060553 

Investigation Date: 12/15/06 Type of Incident: Lost material 

 Type of Investigation: Licensee report 
Region IV Final Report Page E.2 

Incident Casework Reviews 

File No.: 8 

Licensee: FMC Idaho License No.: 11-27071-01 

Date of Incident: 9/7/06 Incident Log No.: 060565 

Investigation Date: 9/11/06 Type of Incident: Recovered material 

 Type of Investigation: Site 

File No.: 9 

Licensee: National Aeronautics & Space Administration License No.: 04-07845-04 

Date of Incident: 11/13/06 Incident Log No.: 060696 

Investigation Date: 11/14/06 Type of Incident: Lost sources 

 Type of Investigation: Licensee report 

File No.: 10 

Licensee: General Electric License No.: SNM-0960 

Date of Incident: 9/1/06 Incident Log No.: 060663 

Investigation Date: 9/1/06 Type of Incident: Contamination 

 Type of Investigation: Site 

File No.: 11 

Licensee: Department of the Air Force License No.: 42-23539-01AF 

Date of Incident: 9/6/05 Incident Log No.: 050766 

Investigation Date: 11/21/06 Type of Incident: Lost source 

 Type of Investigation: Licensee report 

File No.: 12 

Licensee: TEAM Industrial Svcs. License No.: 42-32219-01 

Date of Incident: 7/22/06 Incident Log No.: 060606 

Investigation Date: 7/22/06 Type of Incident: Equipment failure 

 Type of Investigation: Licensee report 

File No.: 13 

Licensee: Wal-Mart License No.: General licensee 

Date of Incident: 4/28/08 Incident Log No.: 080765 

Investigation Date: 4/28/08 Type of Incident: Equipment failure 

 Type of Investigation: Licensee report 

File No.: 14 

Licensee: Department of Commerce-NOAA License No.: 05-11997-01 

Date of Incident: 8/23/08 Incident Log No.: 080805 

Investigation Date: 8/23/08 Type of Incident: Leaking source 

 Type of Investigation: Site 

File No.: 15 

Licensee: Cardinal Health Radiopharmacy License No.: 04-26507-01MD 

Date of Incident: 7/22/04 Incident Log No.: 040874 

Investigation Date: 7/26/04 Type of Incident: Transportation 

 Type of Investigation: Licensee report 
Region IV Final Report Page E.3 

Incident Casework Reviews 

File No.: 16 

Licensee: Department of the Air Force License No.: 42-23539-01AF 

Date of Incident: 10/6/07 Incident Log No.: 040718 

Investigation Date: 10/7/07 Type of Incident: Lost source 

 Type of Investigation: Licensee report 

File No.: 17 

Licensee: Department of the Air Force License No.: 42-23539-01AF 

Date of Incident: 1/24/05 Incident Log No.: 050051 

Investigation Date: 1/24/05 Type of Incident: Lost equipment 

 Type of Investigation: Licensee report 

File No.: 18 

Licensee: Halliburton Energy Svcs. License No.: 42-01068-07 

Date of Incident: 12/23/07 Incident Log No.: 080040 

Investigation Date: 12/29/07 Type of Incident: Abandoned source 

 Type of Investigation: Licensee report 

File No.: 19 

Licensee: ACUREN USA License No.: 42-32443-01 

Date of Incident: 4/26/07 Incident Log No.: 070260 

Investigation Date: 4/30/07 Type of Incident: Lost source 

 Type of Investigation: Licensee report 

File No.: 20 

Licensee: Baker Hughes Oilfield Ops License No.: 17-27437-01 

Date of Incident: 4/5/07 Incident Log No.: 070251 

Investigation Date: 4/7/07 Type of Incident: Abandoned source 

 Type of Investigation: Licensee report 

File No.: 21 

Licensee: Department of the Interior License No.: 05-01399-08 

Date of Incident: 5/15/06 Incident Log No.: 060426 

Investigation Date: 6/23/06 Type of Incident: Contamination 

 Type of Investigation: Site 
APPENDIX F 

URANIUM RECOVERY INSPECTION CASEWORK REVIEWS 

NOTE: CASEWORK LISTED WITHOUT COMMENT IS INCLUDED FOR COMPLETENESS 

ONLY. 

File No.: 1 

Licensee: Power Resources, Inc. License No.: SUA-1548 

Inspection Type: Routine Priority: N/A 

Inspection Dates: 9/23-25/08 Inspectors: LG, DM, ES 

File No.: 2 

Licensee: Power Resources, Inc. License No.: SUA-1548 

Inspection Type: Routine Priority: N/A 

Inspection Dates: 3/24-27/08 Inspectors: RE, LG, DM, ES 

File No.: 3 

Licensee: Western Nuclear, Inc. License No.: SUA-56 

Inspection Type: Routine Priority: N/A 

Inspection Date: 6/4/08 Inspector: LG 

File No.: 4 

Licensee: Crow Butte License No.: SUA-1534 

Inspection Type: Routine Priority: N/A 

Inspection Dates: 9/17-19/07 Inspectors: RE, RL 

File No.: 5 

Licensee: United Nuclear Corporation License No.: SUA-1475 

Inspection Type: Routine Priority: N/A 

Inspection Date: 7/24/07 Inspector: RE 

File No.: 6 

Licensee: Exxon Mobil Refining and Supply Co. License No.: SUA-1139 

Inspection Type: Routine Priority: N/A 

Inspection Date: 5/1/07 Inspectors: RE, LG 

File No.: 7 

Licensee: Umetco Mineral Corporation License No.: SUA-648 

Inspection Type: Routine Priority: N/A 

Inspection Date: 8/31/06 Inspector: RE 

File No.: 8 

Licensee: Crow Butte Resources, Inc. License No.: SUA-1534 

Inspection Type: Routine Priority: NA 

Inspection Dates: 8/15-17/06 Inspectors: RE, SC 
Region IV Final Report Page F.2 

Uranium Recovery Casework Reviews 

INSPECTOR ACCOMPANIMENT 

The following inspector accompaniment was performed prior to the on-site IMPEP review: 

Accompaniment No.: 5 

Licensee: Power Resources, Inc. License No.: SUA-1548 

Inspection Type: Routine, Announced Priority: NA 

Inspection Dates: 3/16-20/09 Inspector: LG 
ATTACHMENT 

May 21, 2009 Memorandum from Arthur T. Howell 

Region IV’s Response to the Draft Report 

ADAMS Accession No.: ML091420085