UNITED STATES 

NUCLEAR REGULATORY COMMISSION REGION IV

 1600 E. LAMAR BLVD. 

 ARLINGTON, TX 76011-4511

 

September 30, 2016 

Mike Broderick, Manager 

Radiation Management Section 

Department of Environmental Quality 

P.O. Box 1677 

Oklahoma City, OK 73101 

Dear Mr. Broderick: 

A periodic meeting with you and your staff was held on August 10, 2016. The purpose of this 

meeting was to review and discuss the status of the Oklahoma Agreement State Program. The 

U.S. Nuclear Regulatory Commission (NRC) was represented by Mark Shaffer, Director, 

Division of Nuclear Materials Safety (DNMS) and me. 

I have completed and enclosed a general meeting summary, including any specific actions 

resulting from the discussions. A Management Review Board (MRB) meeting to discuss the 

outcome of the periodic meeting has been scheduled for January 12, 2017 at 1:00 p.m. (ET). 

Call in information for the MRB will be provided in a separate transmission. 

If you feel that our conclusions do not accurately summarize the meeting discussion, or have 

any additional remarks about the meeting in general, please contact me at (817) 200-1143 or 

via e-mail at Randy.Erickson@nrc.gov to discuss your concerns. 

 Sincerely, 

 /RA/ 

 Randy R. Erickson 

 State Agreements Officer 

 Division of Nuclear Materials Safety 

Enclosure: 

Periodic Meeting Summary 

 
Mike Broderick, Manager 

Radiation Management Section 

Department of Environmental Quality 

P.O. Box 1677 

Oklahoma City, OK 73101 

Dear Mr. Broderick: 

A periodic meeting with you and your staff was held on August 10, 2016. The purpose of this 

meeting was to review and discuss the status of the Oklahoma Agreement State Program. The 

U.S. Nuclear Regulatory Commission (NRC) was represented by Mark Shaffer, Director, 

Division of Nuclear Materials Safety (DNMS) and me. 

I have completed and enclosed a general meeting summary, including any specific actions 

resulting from the discussions. A Management Review Board (MRB) meeting to discuss the 

outcome of the periodic meeting has been scheduled for January 12, 2017 at 1:00 p.m. (ET). 

Call in information for the MRB will be provided in a separate transmission. 

If you feel that our conclusions do not accurately summarize the meeting discussion, or have 

any additional remarks about the meeting in general, please contact me at (817) 200-1143 or 

via e-mail at Randy.Erickson@nrc.gov to discuss your concerns. 

 Sincerely, 

 /RA/ 

 Randy R. Erickson 

 State Agreements Officer 

 Division of Nuclear Materials Safety 

Enclosure: 

Periodic Meeting Summary 

DISTRIBUTION: SP08 

M. Shaffer, D:DNMS L. Howell, DD:DNMS V. Campbell, TA:DNMS 

D. Collins, D: NMSS P. Henderson, NMSS P. Michalak, NMSS 

R. Erickson, SAO B. Tharakan, SAO L. Dimmick, NMSS 

M. Beardsley, NMSS K. Meyer, NMSS D. White, NMSS 

ML16274A391 

X SUNSI Review 

By: RRE

ADAMS 

X Yes 

No 

X Publicly Available 

 Non-Publicly 

Available 

X Non-Sensitive 

 Sensitive 

Keyword: 

OFFICE RIV:SAO 

NAME RRErickson 

SIGNATURE 

DATE 9/30/16 

OFFICIAL RECORD COPY
AGREEMENT STATE PERIODIC MEETING SUMMARY FOR 

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY 

DATE OF MEETING: AUGUST 10, 2016 

U.S. Nuclear Regulatory 

Commission (NRC) Attendees 

Oklahoma Department of Environmental Quality 

Attendees 

Randy Erickson, State Agreements 

Officer, Region IV 

Mike Broderick, Environmental Programs Manager 

Radiation Management Section 

Mark Shaffer, Director, Division of 

Nuclear Materials Safety, Region IV 

Pam Dizikes, Attorney 

Department of Environmental Quality 

 Kevin Sampson, Environmental Program Specialist 

 John Flynn, Professional Engineer 

 Libby McCaskill, Environmental Program Specialist 

 Jennifer McAllister, Environmental Program 

Specialist 

 Keisha Cornelius, Environmental Program Specialist 

 Michael Reid, Environmental Program Specialist 

DISCUSSION: 

The Oklahoma Agreement State Program (Program) is administered by the Radiation 

Management Section of the Land Protection Division which is a part of the Department of 

Environmental Quality. 

The previous IMPEP review (ML14273A535) was conducted the week of August 4-8, 2014. 

The Program was found to be satisfactory for all performance indicators reviewed. The review 

team made two recommendations for the Program regarding the marking of sensitive 

documents and incident reporting. The Management Review Board (MRB) determined the 

recommendation concerning information security could be removed since the Program took 

action following the onsite review to fully address the issue. The remaining recommendation will 

be discussed later in this summary. The review team also recommended and the MRB agreed 

that the Oklahoma Program was adequate to protect public health and safety and is compatible 

with NRC’s program. The team recommended that the next full IMPEP review take place in four 

years and that a periodic meeting take place in approximately two years. 

Program Challenges 

The Program reported that they are not having any specific challenges at the present time. In 

the past they have experienced staffing issues, but those are no longer problems for the 

Program. 

Feedback on NRC’s Program 

The Program noted that they appreciate the State Agreement Officer (SAO) program and view it 

as an invaluable resource. They also encouraged SAO participation in national meetings 

involving the Agreement States as these interactions are also viewed as invaluable. 

A discussion was held regarding Cesium-137/Barium generators, their use and availability. This 

was referred to NMSS who has it under review. 
Oklahoma Department of Environmental Quality 

Periodic Meeting Summary Page 2 

Program Reorganizations 

There have been no reorganizations since the 2014 IMPEP review. 

Program Budget/Funding 

The Program reported that their budget is stable. 

Technical Staffing and Training (2014 IMPEP: Satisfactory) 

The Oklahoma Agreement State Program is composed of a Section manager, eight technical 

staff positions, and one administrative staff person. Technical staff members conduct 

inspections, perform licensing actions, and respond to incidents and allegations. 

The Program reported that since the 2014 IMPEP review, they lost one staff member who they 

replaced with a highly qualified individual. At the time of the meeting, the Program was fully 

staffed. 

The Program has a documented training plan that is consistent with NRC’s Inspection Manual 

Chapter (IMC) 1248, “Qualification Programs for Federal and State Materials and Environmental 

Management Programs.” 

Status of Materials Inspection Program (2014 IMPEP: Satisfactory) 

Technical Quality of Inspections (2014 IMPEP: Satisfactory) 

The Program conducted 122 Priority 1, 2 and 3, and 9 initial inspections since the 2014 IMPEP 

review. Two of the inspections were conducted overdue, one due to illness of an inspector, and 

one was the result of a database entry error. No inspections were overdue for inspection at the 

time of the meeting. The Program reported they are meeting the 30 day goal of transmitting 

inspection findings to licensees following an inspection. 

The Program reported that they inspected more than 20 percent of all candidate licensees, as 

defined in Inspection Manual Chapter 1220, applying to work in the state under reciprocity in 

both 2014 and 2015. 

Annual supervisory accompaniments of the inspection staff have been performed for all but one 

staff member since the 2014 IMPEP review. One inspector who was absent from the Program 

for an extended period due to illness, was not accompanied in 2015. 

Technical Quality of Licensing Actions (2014 IMPEP: Satisfactory) 

The Program currently has 232 specific licensees and completed a total of 451 licensing actions 

since the last review. The Program currently has 8 licenses under timely renewal. 

The Program reported they follow the NRC’s revised pre-licensing guidance when performing 

pre-licensing verifications. The Program performs pre-licensing site visits of all new applicants. 

 
Oklahoma Department of Environmental Quality 

Periodic Meeting Summary Page 3 

Technical Quality of Incidents and Allegations (2014 IMPEP: Satisfactory) 

When notification of an incident or an allegation is received, the Program manager determines 

the appropriate level of initial response and assigns it to an inspector. Staff then use an action 

flow chart and standard operating procedures to initiate their response. 

The 2014 IMPEP review team found that some staff did not fully understand the process to be 

followed for incident follow-up which resulted in late notifications to the NRC and to NMED. As 

a result, the review team recommended that the Program provide additional training to the staff 

on their revised standard operating procedure “Environmental Complaints Program” and 

associated flowcharts to ensure consistent, timely, and accurate reporting and adequate 

follow-up of incidents. The program responded by updating their procedures and providing 

additional training to the staff on the process. 

Since the 2014 IMPEP review, the Program had reported 20 events to the NMED database with 

only one event still open due to enforcement action being taken by the Program. 

Since the 2014 IMPEP review, 10 allegations involving Oklahoma licensees and 6 allegations 

involving non-licensees were received by the Program. No allegations were referred from NRC 

to Oklahoma over the same period. All the allegations has been investigated and closed. 

Regulations and Legislative Changes (2014 IMPEP: Satisfactory) 

The Department is authorized as the State’s radiation control agency under the Radiation 

Management Act Chapter 27A, of the Oklahoma Statutes, Section 2-9-101 et seq. 

Oklahoma adopts regulations by reference. All are up-to-date. 

Part 37 was implemented by license condition on March 18, 2016 and Program staff are 

inspecting against it. Final Part 37 equivalent regulations should be in place in 

September 2016. 

Information Exchange 

Current State Initiatives 

Program managers presented initiatives ongoing within the Department. This included: 

• The Program is following up on non-military radium use locations provided to them by 

NRC to determine if legacy radium still exists at those sites. 

Current NRC Initiatives 

NRC managers presented several initiatives ongoing at NRC. These included: 

• Project AIM 2020 

• Rebaselining 

• NMSS Management Changes 

• Agreement State training 

• Changing licensing renewals from 10 to 15 years 
Oklahoma Department of Environmental Quality 

Periodic Meeting Summary Page 4 

• Proposed Rulemaking 

• WBL 

• Non-military radium 

• Revising Inspection Manual Chapter (IMC) 2800 

CONCLUSIONS: 

NRC staff recommends that the next IMPEP review be conducted as scheduled in August 2018.