ML20211K126

Draft Rept, Integrated Matls Performance Evaluation Program Review of Nevada Agreement State Program, Dtd 970825-29

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Issue date:	08/29/1997
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J k INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM REVIEW OF NEVADA AGREEMENT STATE PROGRAM August 25-29,1997 4

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DRAFT REPORT 4

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Nevada Draft Report Page 1

1.0 INTRODUCTION

This report presents the results of the review of the Nevada radiation control program. The review was conducted during the period August 25 29,1997, by a review team comprised of technical staff members from the Nuclear Regulatory _ Commission (NRC) and the Agreement State of California. Team members are identified in Appendix A. The review was conducted in accordance with the " Interim implementation of the Integrated Materials Performance Evaluation Program Pending Final Commission Approval of the Statement of Principles and Policy for the Agreement State Program and the Policy Statement on Adequacy and Compatibility of Agreement State Programs," published in the Federal Reoister on October 20,1995 and the September 12,1995, NRC Management Directive 5.6, " integrated Materials Performance Evaluation Program (IMPEP)." Preliminary results of

-the review, which covered the period March 6,1993 to August 24,1997 were discussed with Nevada management on August 29,1997.

[A paragraph on the results of the MRB meeting will be included here in the final report.)

The Nevada Agreement State program is administered by the Radiological Health Section (RHS) of the L.ireau of Health Protection Services (BHPS), State Health Division, Nevada Department of Human Resources, Nevada statute designates the' State Health Division as the radiation control agency. Organization charts for the Divis;on, the BHPS. and RHS are included as Appendix B.

At the time of the review, the Nevada progrem regulated 196 specific licenses, including a major decontamination service, broad academic programs, broad medical programs, radiopharmacies, radiographers, a small irradiator, and a non operating Icw level radioactive waste burial site. The program grew during the review period at a rate of about 5 percent per year, as ovidenced by the increase in the number of licenses.

The review focused on the materials program as it is carried out under the Section 274b.

(of the Atomic Energy Act of 1954, as amended) Agreement between the NRC and the State of Nevada.

In preparation for the review, a questionnaire addressing the common and non common indicators was sent to the State on March 28,1997. The State provided a response to the questionnaire on July 30,1997. During the review, discussions with the State staff resulted in the responses being further developed. A copy of the final response is included in Apparw% C to this report.

The review team's general approach for conduct of this review consisted of: (1) examination of Nevada's response to the questionnaire; (2) review of applicable Nevada-statutes and regulations; (3) analysis of quantitative information from the radiation control program licensing and intoection data base; (4) technical review of selected licensing and inspection actions; (5) fleiu accompaniments of two Nevada inspectors; and (6) interviews with staff and menagement to answer questions or clarify issues. The team evaluated the information that it gathered against the IMPEP performance criteria for each common and non common indicator and made a preliminary assessment of the rarf;ation control program's performance.

Nevada Draft Report Page 2 Section 2 below ditcunes tk.s State's actions in response to recommendations made following the previous revkw. Results of the current review for the IMPEP common performance indicen are presented in Section 3. Section 4 discusses results of the applicable norecommon indicators, and Section 5 summarizes the review team's findings and recommerdations. Suggestions made by the review team are comments that the review team believes could enhance the State's program. The State is requested to consider suggestions, but no response is requested. Recommendations relate directly to program performance by the State. A response is requested from the State to di recommendations in the final report.

2.0 STATUS OF ITEMS IDENTIFIED IN PREVIOUS REVIEWS During the previous routine review, which concluded on March 5,1993, eight commente and recommendations were made in five program indicators. Because of the significance of some of the review findings, a follow-up review was conducted in April 1994 and the results transmitted to Ms, Yvonne Sylva, /*dministrator, Nevada State Health Division, on September 21,1994. The follow-up review resulted in the closure of six of the eight recommendations and the addition of two new recommendations. The team's review of the current status of these recommendations is as follows:

(1) Although the State's written enforcement procedures prescribed escalated actions !n general terms, they did not directly address serious first time violations and iacked specific action levels for violations of varying degrees of severity. The NRC recommended that the enforcement procedures be strengthened by requiring escalated enforcement if the licensee has one or more serious violations directly relating to occupational or public health or safety, and by adding specific actions to be taken for violations of various levels of severity.

Current Status: The en?orcement procedures were revised and further strengthened by new procedures dated August 7,1997. The new procedures address the problem of a single, serious violation. Escalated enforcement actions prescribed by various severity lovels include management level meetings with the licensee, follow-up inspections, license restrictions, and temporary suspension or revocation of the license. This recommendation is closed.

(2) Du ing the March 1993 review, three inspections were identified in which

, appropriate escalated enforcement actions were not taken in response to numerous violations, including several repeats. At the time of the April 1994 follow-up review, the State had verified that the two licensees had taken corrective actions; however, the third case remained open.

4 Nevada Draft Report Page 3 Current Status: The State followed through with the enforcement on this medical p.ivate practice licensee by terminating the license and replacing it with a more restrictive medical facility license with requirements for a quality management plan program, a radiation safety committee with quarterly-meetings, and an outside expert to serve as radiation safety officer. This recommendation is closed.

(3) Nevada hospitals are required by regulation to provide dose calculations when reporting m!sadministrations to the State so that each event may be analyzed and reported as necessary. However, in three misadministration cases calculations were not provided; thus the events could not be evaluated against the reporting criteria. We recommended that the State's administrative procedures be revised to improve instructions for evaluating, following and reporting misadministrations and that letters be sent to all Nevada hospitalt 'eminding them of the misadministration reporting criteria, including the requirement for dose, calculation.

Current Status: The review team verified that the State revised and improved the instructions for handling misadministrations. All medicallicensees, including hospitals, were sent letters reminding them of the reporting requireri.ents in the regulations. This recommendation is closed.

(4) Severalinadequacies were found in the State's system for tracking incidents and misadministrations: (a) the incident log was incomplate; (b) some incidents shown as closed in the incident log lacked documentation in the files justifying closure; and (c)in some cases, copies of correspondence were found in the Las Vegas regional Office on events handled by that office that were not in the headquarters office files in Carson City. We recommended that the State improve their events tracking system to ensure complete incident logs, to ensure that all open items are properly documented before closure and to ensure proper dissemination of regional event correspondence to headquarters files.

Current Status: The team reviewed the incident files for the review period and found that allincidents were included in their tracking system, that all open items were properly documented before closure, and that all regional office event documentation is duplicated in headquarters files. This recommendation is closed.

3.0 COMMON PERFORMANCE INDICATORS IMPEP identifies five common performence indicators to be used in reviewing both NRC Regional and Agreement State programs. These indicators are: (1) Status of Materials inspection Program; (2) Technical Staffing and Training; (3) Technical Quality of Ucensing Actions; (4) Technical Quality of Inspections; and (5) Response to incidents and Allegations.

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Nevada Draft Report Page 4 3.1 Status of Materials inspection Prooram The team focused on four factors in reviewing this indicator: inspection frequency, overdue inspections, initial inspection of new licenses, and timely dispatch of inspection findings to licensees. This evaluation is based on the Nevada questionnaire responses relative to this indicator, data gathered independently from the State's licensing and inspection data tracking system, the examination of completed licensing and inspection casework, and interviews with managers and staff.

The State maintains a licensee data base that can sort by a variety of data. During the review the team was provided various lists including: a priority listing for alllicenses, licenses due for inspection during a given period in the future, inspections completed over a given time period, and reciprocity licensee inspections completed for a given period. The data base does not, however, retain historical data. As a result, the team was only able to obtain detailed inspection statistics from the data base for the current year. According to the program manager, prior year statistics could be developed only by a manual search of the files. Bi-yearly statist!cs for budgeting purposes are generated prior to legislative sessions, however, the progt:m does not retain the information in a readily available form due to infrequent demand. Based on the inspection program performance during the past year and the performance of the radiation control program generally during the review period, the team did not request or conduct a manual search.

The printout of the current year inspections showed 89 completed. This printout shows the inspection date, the date of the violation notice, the date of the licensee's response, and the date of the State's acknowledgment letter or inspection closing date.

The State's inspection frequencies were compared to IMC 2800 and verified to be of equal, or in some cases moro frequent than, IMC 2800. The State requires more frequent inspection in some license categories as follows: hospitals and nuclear medicine private practice licenses are inspected on a two year frequency as compared to NRC three year frequency; portable gauge licenses are inspected at a three year frequency as compared to NRC five year frequency; and teletherapy licensees are inspected on a one year frequency as compared to NRC's three year frequency.

Two teletherapy licensee files were reviewed. One licensee was inspected annually; the other was inspected every three years. No reason was evident for the difference; the State priority was 1 for both licenses. The NRC inspection priority for a teletherapy program is 3. The RHS Superviscr indicated that the State will change the inspection priority for teletherapy licenses to a 3.

The radioactive materials low level waste (RAM /LLW) program manager provided the following information on reciprocity, which is maintained separately from the licensee database. The State issued 187 reciprocity authorizations to 23 out-of-state industrial radiography licensees for the period March 3,1993, through June 9,1997. During that period, six inspections were completed and one was attempted. All six completed inspections were of radiography licensees operating in the Las Vegas or Reno / Sparks areas.

Nevada Draft Report Page 5 One licensee from Utah was granted authorization to enter the State 68 times, nowever, it was not inspected during the period because of the difficulty of travel to the remote areas of the State in which the licensee was working.

During ihe last 14 months,18 radiography licensees were granted reciprocity. Ten conducted opnations in urban areas and eight in rural areas of the State. There were four inspections of the licensees who operated in urban areas of the State and none of the licensees who operated in rural areas of the State.

The review team finds that the State has not met the frequency of IMC 1220 *or the inspection of reciprocity licensees. The review team recommends that the Stnte inspect a higher percentage of reciprocity licensees, including high priority industriel radiography licent.ees operating in rural areas.

New licenses are usually inspected six months after they are issued, provided radioactive material has been received by the licensee. The State telephones the licensee to determine if materiei has been received, if it has not, they defer the inspection until material has been received. Only one Nevada licensee experienced a delay of greater than one year in receiving material. This licensee was inspected within one year after the license was issued, but before radioactive material was received, contrary to the State's procedure.

The University of Nevada, Reno, was the only licensee identified by the team as overdue for inspection by the program's standards. Review of the file indicated that the last complete inspection was in September 1991. The University is an Academic Type B Broad licensee, assigned inspection priority 2, and it should have been inspected no later than April 1994. The State made a number of partialinspections at the University since 1991, but none of these inspections were brought to closure, or combincJ to form a complete inspection by State standards.

A review of the inspactions completed printout showed that the State has inspected other licenses within their assignad frequency. The team finds that only one license was overdue for inspection during the review period. Overdue inspections thus do not exceed the evaluation criteria.

The State, by policy, does not extend the inspection interval for good licensee performance. Licensees may be inspected at more frequent intervals as the result of escalated enforcement action. Inspection intervals are returned to normal after the licensee shows improvement, in 4 of the 26 files evaluated, a letter to the licensee informing of violations was mailed more than 30 days following the inspection. In one case, the letter was mailed 70 days after the inspection, the other three letters were mailed between 30 and 60 days after the inspection. Ll:ensees are usually given 20 days to respond, and if their response is satisfactory, an acknowledgment letter is sent by the State and the inspection is closed.

Based on the IMPEP evaluation criteria, the review team recommends that Nevada's performance with respect to the indicator, Status of the Materials Inspection Program, be found satisf actory.

Nevada Draft Report Page 6 3.2 Technical Staffino and Trainina Issues central to the evaluation of this indicator include the radioacdve materials program staffing level, technical qualifications of the staff, training and staff turnover. To evaluate these issues, the review team examined the State's questionnaire responses relative to this indicator, interviewed program management and staff, and considered any possible workload backlogs.

The RHS organization chart shows that the section has a total of 14 positions, including the secretarial positions and the Las Vegas Regional Office. The Radioactive Materials / Low Level Radioactive Waste (RAM /LLW) program manager and the Mammography /X ray program manager in Carson City are classified as Radiological Staff Specialist, while the Las Vegas office manager is classified as a Supervising Radiation Physicist. These positions report to the RHS Supervisor. The five technical staff members area classified as Radiation Control Specialists.

Four of the technical staff members are cross-trained between the x-ray and RAM /LLW rograms All technical staff members participate in eveni response activities. The RAM /LLW Radiological Staff Specialist and one Radiation Control Specialist in Las Vegas are primarily devoted to license reviews and inspection of radioactive materials licensees, including the low-level waste disposal site and licensees authorized to possess and use materials not subject to the Atomic Energy Act. The remaining technical staff members are assigned primarily to other programs, and devote less than 50 percent oi iheir time each to the agreement program, The distribution of effort results in 2.95 technical FTE staffing dedicated to the RAM /LLW program. The RHS also has 3.5 FTE of secretarial staff. The distribution between licensing and inspection effort appears balanced, as evidenced by the lack of significant backlogs. At the time of the review, there were no vacant positions. The team notes that the RHS technical staff has been stable during the review period, with only one departure (due to retirement) and two new hires. Based on the program's functional condition, the staffing levelis sufficient to assure public health and safety.

The review team found that the technical staff positions require a bachelor's degree in the sciences, or an equivalent combination of training and experience New staff members are assigned basic recponsibilities until the training and experience necessary to handle more advanced responsibilities are obtained. They are provided training in the core NRC courses. They are also assigned to work with senior staff members to gain experience.

rogression through the training and experience warrants their assignment to more complex responsibilities, however, they must demonstrate satisfactory performance in a fc,rmal assessment prior to being authorized to conduct independent inspections or license reviews. This general procedure is not, however, delineated in written form. The RHS Supervisor does develop an individual training and qualification plan, usually in anemo form, for each new staff member. The individual plan considers the past training and experience of the new staff member, and the performance requirements of the specific position.

Senior staff members have completed their training and qualification plans.

Nevada Draft Report Page 7 The two new staff members hired during the review period hold associate degrees and have considerable experience in a radiation field. One staff member has 14 years experience in a non Agreement State radiation control program, including 9 years as the program director; the other has 15 years experience in medical x ray. The team finds that the qualifications of the new hires are adequate. The team also finds thet the lack of a written general training and qualification procedure has not adversely affected the development of the new staff members during the review period. The review team recommends that the general training and qualification procedure be adopted in writing.

The team suggests that the State wait until the NRC OAS Joint working group on training issues their final recommendations. The working group recommendations should be considered when developing the written plan.

The RHS, with the support of the BHPS and the State Health Division, has received for the first time a budgetary allotment for training. The State plans to use this funding to complete the training of the new staff members, and to provide continuing training for experienced staff members.

Based on the team's finding and the IMPEP evaluation criterie, the review team recommends that Nevada's performance with respect to this indicator, Technical Staffing and Training, be found setisfactory.

3.3 Technical Quality of Licensino Actions The review team examined completed licensing casework and interviewed the reviewers for 24 specific licenses. Licensing actions were evaluated for completeness, consistency, proper isotopes and quantities used, qualifications of authorized users, adequate facilities and equipment, and operating and emergency procedures sufficient to establish the basis for licensing actions. Licenses were reviewed for accuracy, appropriateness of the license and of its conditions and tie-down conditions, and overall technical quality. Casewor(: was evaluated for timeliness, adhs;ence to good health physics practices, reference to appropriate regulations, documentation of safety evaluation reports, product certifications or other supporting documents, consideration of enforcement history on renewals, pre-

!icensing visits, peer or supervisory review as indicated, and proper signature authorities.

The files were checked for retention of necessary documents and supporting data.

The licensing casework vfas selected to provide a representative sample of licensing actions which had been completed in the reviaw period and to include work by all reviewers. The cross section sampling included all of the State's major licenses as defined by the State in the questionnaire and included the following types: broad academic; decontamination services; in vitro laboratory; industrial radiography; small irradiator; medical brivate practice, teletherapy, and high dose remote afterloader); nuclear pharmacy; welllogging; ordnance testing; and low-level radioactive waste disposal.

Licensing actions included 10 new licenses,4 renewals,5 amendments, and 5 terminations. A list of these licenses with case-specific comments can be found in Appendix D.

Nevada Draft Repc,rt Page 8 The review team found that the quality of the State's licensing actions is excellent. No discrepancies were found in the 24 files reviev ed. The licensing actions were also timely, with uncomplicated actions completed within 60 days, including the exchange of correspondence. Unusual or complex license ac lons required longer completion times.

The State's license termination procedures are based on the NRC's Site Decommissioning Management Plan (SDMP) cleanup criteria, the tables in NRC Regulatory Guide 1.86 on acceptable Surface Contamination levels and other guidance such as NUREG/CR 5849 on Conducting Radiolog!:al Surveys in Support of License Termination and NRC PGD FC 83 23, " Termination of Bypreduct, Source, and SNM Material Licensees." One major facility was decommissioned and the license terminated during the review period when Aerojet-General closed the ordnance testing site at Nellis Air Force Base. In reviewing the casework, the team found that the State had required an extensive decommissioning plan and had carefully monitored the work performed by the licensee and the contractor. All records of transfer of material were on file, as well as the State's confirmatory measurements taken during several on site inspections during the decommissioning activities.

From discussions with the reviewers and from casework reviews, the team found that the State makes pre licensing visits for complex licensing actions, it was also noted that complex new licenses or renewals are personally delivered so that licensees have the opportunity to discuss the license and their obligations with a State representative.

Licenses are issued for five years and State policy requires a complete new application each time the license is renewed. The team noted during the evaluation of the casework that supporting documentation for new and renewed licenses was current and complete, it was noted that every new or renewed license is tied through license condition to an attached cover letter which clearly explains the licensee's responsibilities when the licensee receive: the license.

The review team found that the State uses the latest NRC standard license conditiou as the basis for their own standard conditions. The review team also noted that the reviewers use licensing checklists based on the NRC's current checklists. The State has copies of the current licensing guidance, including NRC Regulatory Guides, NUREGS, and information notices, supplemented with other professionally recognized health physics reference documents. The team noted from reviewing the licensing checklists that the licensee's compliance history is reviewed before license amendments or renewals are approved.

The team found that the deficiency letters, cover letters, and other types of licensing correspondence were complete and well written with proper regulatory language and were issued promptly.

All staff, including those in the Las Vegas office have licensing responsibilities. After the license is written, the license and copies of the application and all background documents are forwarded to the lead reviewer in Carson City for peer and supervisory review. Major actions are also reviewed by the Supervising Radiation Physicist in the Las Vegas office.

After the peer and supervisory reviews, the license is again reviewed and signed by the RHS Supervisor in his absence, the lead reviewer has signature authority.

Nevada Draft Report Page 9 Based on the IMPEP evaluation criteria, the taview team recommends that Nevada's

- performaace with respect to the indicator, Technical Quality of Licensing Actions, be found '

satisfactory.

3.4 Technical Quality of Inspections The tecm reviewed the inspection reports, enforcement documentation, and inspection field notes and interviewed inspectors for 26 materials inspections conducted during the ,

review period. The casework included all six of the State's materials license inspectors, and covered inspections of various types including radiography, medical, academic, portable gauge, nuclear pharmacy, and teletherapy. Appendix E lists the inspection files reviewed in depth with case specific comments. During the week of August 11 18,1997, a review team member performed accompaniments of two Stata inspectors on separate inspections of licensed facilities.

The State's inspection forms are tailored to the type of license inspected. The forms were complete except for a secron to remind the inspector to review previous incidents by the licensee. The forms contain questionnaires for use b/ the inspector to test the knowledge and understanding of the users. The questionnaires assure that the inspector asks questions appropriate to the type of licensee. The reports evaluated demonstrated that the inspectors crmplete the inspection forms. The team finds that the inspectors followed established State inspection procedures.

Of the 26 inspection reports evaluated, only four inspections were announced. The State's policy is to count any inspection in which the licensee was given less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notice, as an unannounced inspection. The State notes that some licensees do not perform licensed operations daily, and believes that it is a more efficient use of inspection effort to assure that licensed operations will be ln progress during an inspection. The State believes that significant problems in a licensed program would be difficult to conceal from inspectors when the licensee is given less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notice of an inspection. Although this practice differs from NRC guidance, it is a reasonable approach. The review team found this policy acceptable, inspection reports were very high quality and the files were complete with all documents including letters, te!ephone calllogs, license documents and amendment requests. Each report has the signature of the Radiological Staff Specialist or the Supervising Radimn Physicist indicating it was reviewed, and all correspondence is signed by the RHS Supervisor.

When violations are uncovered during an inspection, the inspector drafts a violation notice

- for the RHS Supervisor's signature. A standard letter, addressed to the licensee with the violation notice appended, is mailed to the licenace. The violation notice may also identify items of concern which are not violations (but for which 6 response from the licensee is expected), or contain recommendations, (for which a response is not expected).

- Depending of the nature of the violations, the licensee's response, and the inspector's recommendation, the State may take additional measures to bring the licensee into compliance. For serious or repeated violations, a meeting with licensee management may

Nevada Draft Report Page 10 be scheduled in the State office. For less serious violations, a repeat inspection at a reduced interval may be scheduled. If these methods fall, the State enforcement policy provides for an administrative hearing to revoke the license. There were no administrative hearings during the review period. The RCP does not have authority to levy and collect civil penalties (administrative fines) for violations or the radiation control regulations.

Monetary penalties must be collected through action of the civil csurt.

Enforcement letters are written in appropriate regulatory language and are dispatched in a timely manner. The date the lettor is sent is entered into the data base so that resoonse due dates can be easily tracke6.

If no violations are found during an inspection, the inspection is closed at the exit and the State does not notify the licensee of the findings in writing. The review team suggests that the State provide a letter, or a short form similar to the NRC Form 591, to the licensee indicating that no violations were found as the result of the inspection, when appropriate.

According to program staff, there is an ample supply of radiation survcy instruments at both the Carson City and Las Vegas offices. At Carson City there are 3 Victoreen 450P lon chambers,4 Ludlum micro /R meters,3 Ludlum model 12 or 14.: meters with 6 pancake probes for contaminatior surveys, 2 Eberline emergency kits with alpha, pancake, and end window probes, in addition, each office has an Aptec Odyssey 6 portable multi-channel analyzer for isotope identification.

All survey meters are calibrated annually and are rotated so that they are calibrated at least at the frequency of the licensee inspected. The meters are calibrated by a private firm that uses NIST traceable standards.

All six inspectors have had supervisor accompaniments at least annually. The Compliance Inspection Fieldwork Inspector Evaluation form is maintained in the inspectors file.

A member of the review team conducted accompaniments of two Nevada inspectors prior to the team review. On August 13,1997, one inspector was accompanied during an inspection of a portable gauge licensee in Carson City. The second inspector was accompanied on August 18,1997, during an inspection of a portable gauge licensee in Reno. Both inspectors have extensive experience in x ray programs, and at the time of the review, were being trained in inspecting radioactive materials licensees. Both inspectors had qualified to independently perform inspections of the gauge licensees, but had not yet qualified to inspect more complex licensees.

Both inspectors prepared well and performed thorough inspectio. is of the licensees' radiation safety programs. The inspectors demonstrated appropriate inspection techniques including observations, interviews, review of records, and knowledge of regulations, although one inspector was reminded to cite the regulation or license condition for each item of non-compliance. The technical performance of the ir:epectors was satisfactory, and their inspections were adequate to assess the radiological health and safety program of the licensee. The results of the accompaniments were discussed with the inspectors and their supervisors. The accompaniments are ider,tified in Appendix E.

Nevada Draf t Report Page 11 Based on the IMPEP evaluation criteria, the review team recommenc's that Nevada's performan:e with respect to the indicator, Technical Quality of Inspections, be found satisfactory.

3.5 Resoonse to incidents and Alleastions in evaluating the effectiveness of the State's actions in responding to incidents and allegations, the review team examined the State's response to the questionnaire relative to this indicator and reviewed the incidents reported for Nevada in the " Nuclear Material Events Database (NMED)" against those contained in the Nevada casework and license files, and supponing documentation, as appropriate for ten incidents. The team reviewed the State's response to six allegations, of which NRC referred two allegations. A list of the incident casework with comments is included in Appendix F.

State procedures require an on site investigation for significant incidentc. The procedures do not distinguish between Incidents and allegations. The RHS Supervisor coordinates with the Las Vegas field office Supervising Radiation Physicist on incident response All incident reports and summaries are reviewed by the RHS Supervisor for close out.

The review team found that, with the exception of the reporting incidents to NRC the State responses were within the performance criteria. Notification to the NRC was provided in 1993 through the first half of 1995, for incidents that require reporting under State regulations. Althour ne State licident report log contains an entry space for recording notification to NRC, notific tlons were not moda for incidents occurring in the second half of 1995 through the end of the review period. The reporting of incident information was discussed with the program management, which indicated that a combination of problems with the NMED computer s.,ltware and altered priorities related to the office relocation resulted in a decision to May the reporting to NRC of events the State considered to be of low significance. The State did not consider any of the events that occurred during this penod to be of high significance, however, the team reviewed reports of one damaged and five lost or stolen moisture / density gauges. The team recommends that the State review the incident files back to the last event reported to NRC in 1995, and submit reports to NMED as appropriate.

Responsen were p6ompt and well coordinated, and the level of effort was commensurate with health and safety significance. Inspectors were dispatched for on-site inspections when appropriate in general, the State took suitable corrective and enforcement actions and followed the progress of the inspection until close out.

The team reviewed the files cf six allegations. Two of the aHegations were referred to the State by NRC Region IV. The records indicated a response to the Region when requested.

All six allegations were rer,ponded to promptly with appropriate inspections, follow up, and close out actions. The quality of the State's response was adequate. Persons making allegations are advised that their identity can be protected under State law, but the alleger must request the identity protection in writing.

Nevac's Draf t Report Page 12 Based on the IMPEP evaluation criteria, the review team recommends that Nevada's performance with respect to the indicator, Response to incidents and Allegations, be found satisfactory. ,

4.0 NON COMMON PERFORMANCE INDICATORS IMPEP identifies four non common performance Indicators to be used in reviewing Agreement State programs: (1) Legislation and Regulations; (2) Sealed Source and Device Evaluation Program; (3) Low Level Radioactive Waste Disposal Program; and (4) Uranium Recovery. Nevada's agreement does not cover uranium recovery, so only the first three non comm9n performance indicators were applicable to this review, 4.1 Leaistat!on and Reaulations 4.1.1 Leaistative and Leaal Authority Along with their response to the questionnaire, the State provided the review team with the opportunity to review copies of legislation that affects the radiation control program.

Legislative authority to create an agency and enter into an agreement with the NRC is granted in Nevada Revised Statute Section 459. The Nevada State Health Division is designated as the State's radiation control agency. The review team noted that the legislation had not changed since I eing found adequate during the previous review, and found that the Stata legislation is adequate.

4.1.2 S.tatus and Comoatibility of Reaulations The Nevada Regulations for Control of Radiation, found in Chapter 459 of the Nevada Administrative Code (NAC), apply to allionizing radiation, whether emitted from radionuclides or devices. Nevada requires a license for possession, and use, of all radioactive materialincluding naturally occurring materials, such as radium, and accelerator produced radionuclides. Nevada also requires registration of all equipment designed to produce x rays or other ionizing radiations.

The review team examined the procedures used in the State's regulatory process and found that Nevada offers the public the opportunity to comment on proposed regulations and participate in public hearings before the Board of Health. Procedures also require the proposed regulations, and proposed hearing date, be publicized. Written response to all written public comments must be part of the staff presentation to the Board.

Regulations must be reviewed by the State legislature before they become final. Since the legislature meets biennially, and regulations may be submitted only at specified times, it is difficult for the State to adopt all NRC amendments within the 3 year time period during which Agreement States are generally expected to adopt compatible rules. The team noted that while some of the regulations adopted during the review period were adopted after the 3 year period had expired, Nevada has other legally binding methe.Js of applWng regulatory requiremenu on a temporary basis as needed.

Nevada Draft Report Page 13 The team evaluated Nevada's responses to the questionnaire and reviewed the regulations adopted by the State since the 1993 review to determine the status of the Nevada .

regulations under the Commission's new adequacy and compatibility policy. The team found that the State addressed the following NRC regulation amendments:

1 e " Quality Management Program and Misadministration," 10 CFR Part 35 amendment (56 FR 34104) which became effective on January 27,1992. The State has decided not to adopt a rsgulation equivalent to the quality management and misadministrction rule while NRC is continuing to defer compatibility findings for Agreement States. Nevada intends to revisit the matter when NRC issues a revised Part 35 rule, compatibility designations for the new rule are established, and an effective date for Agreement State implementation has been set.

e " Licensing and Radiation Safety Requirements for irradiators," 10 CFR Part 36 amendment (58 FR 7715) which became effective on July 1,1993. There are no current Nevada lic3nsees that are affected by this rule. The State plans to apply the taquirements by licansa condition and adopt *" mivalent rule if an application for an irradiator is received. NRC has previously found this approach to be compatible, e

• Definition of Land Disposal and Waste Site Quality Assurance Programs," 10 CFR Part 61 amendment (59 FR 33886) which became effective on July 22,1993. This rule, previously considered a matter of compatibility, has been redesl0nated as category D under the Commission's new adequacy and compatibility policy, in consideration of the closed status of the Beatty site, the State does not plan to adopt an equivalent regulation, e " Decommission!ng Record Keep.ng Do::umentation of Restricted Areas and Spill Sites," 10 CFR Parts 30 and 40 (58 FR 39628) that became effective on October 25,1993. This rule has been designated as category D under the Commission's new adequacy and compatibility policy, however, NRC is currently proposing to redesignate it as category D H&S. It should be noted that this rule applies to alllicensees, rather than just those licensees required to file a decommissioning plan.

e "Self. Guarantee as an Additional Financial Mechanism," 10 CFR Parts 30,40, and 70 amendments (59 FR 68726 and 59 FR 1618) that became effective on January 28,1994. This rule, previously considered a matter of compatibility, has been redesignated as category D under the Commission's new adequacy and compatibility policy. The rule affects only one Nevada licensee ano is being adopted by license condition, e " Uranium Mill Tailings Regulations: Conforming NRC Requirements to EPA Standards," 10 CFR Part 40 amendment (59 FR 36026) that became effective on July 1,1994. This rule is not applicable as Nevada does not regulate section 11(e).2 material under the Agreement.

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i Nevada Draf t Report Page 14 l

• " Timeliness in Decommissioning of Materials Facilities," 10 CFR Parts 30,40, and 70 amendments (59 FR 36026) that became effective on August 15,1994. This rule has been designated as category D . H&S under the Commission's new adequacy and compatibility policy. It should be noted that this rule applies to all  :

licensees, rather than just those licensees required to file a decommissioning plan.

The State has expressed the Intent to adopt the following regulations on or about March 1, 1998:

• Preparation, Transfer for Commercial Distribution and Use of Byproduct Material  !

for Medical Use," 10 CFR Parts 30,32 and 35 amendments (59 FR 61767, 59 FR 65243,60 FR 322) that became effective on January 1,1995. This rule is <

category B under the Commission's new adequacy and compatibility policy. The State will temporarily adopt the rule by license condition as necessary.

• " Low Level Waste Shipmen' Manifes't Information and Reporting," 10 CFR Parts 20 and 61 amendments (60 FR 15649,60 FR 25983) that will become 6ffective March 1,1998. Agreement States are expected to have an effective rule on the same date. This rule is category B under the Commission's new adequacy and compatibility policy.

Nevada has not started to address the following rulemakings, but indicat6d the intent to adopt the rules prior to the due date (three years after the effective date given):

e " Performance Requirements for Radiography Equipment," 10 CFR Parts 34, (60 FR .

28323) that bacame effective on June 30,1995.  !

e " Radiation Protection Requirements: Amended Definitions and Criteria,"

10 CFR Parts 19 and 20 amendments (60 FR 36038) that became effective August 14,1995, o " Clarification of Decommissioning Funding Requirements," 10 CFR Parts 30,40, and 70 amendments (60 FR 38235) that became effective November 24,1995.

• " Compatibility with the International Atomic Energy Agency," 10 CFR Part 71 amendment (60 FR 50248) that became effective April 1,1996, o " Medical Administration of Radiation and Radioactive Materials," 10 CFR Part 20.35 amendment (60 FR 48623) that became effective on October 20,1995.

e " Termination or Transfer of Licensed Activities: Record Keeping Requirements,"

10 CFR Parts 20,30,40,61,70 (61 FR 24669) that became effective on May 19, 1996. This requirement need not be in effect until May 19,1999.

• " Resolution of Dual Regulation of Airborne Effluents of Radioactive Materials; Clean Air Act," 10 CFR Part 20 amendment (61 FR 65119) that became effective January 9,1997.

Nevada Draft Report Page 15 e

• Recognition of Agreement State Licenses in Areas Under Exclusive Federal Jurisdiction Within an Agreement State," 10 CFR Part 150 amendment (62 FR 1662) that became effective on January 13,1997.

e " Criteria for the Release of Individuals Administerc'd Radioactive Material," 1L CFR Part 20.35 amendment (62 FR 4120) that became effective on January 20,1997.

As noted above, the rules

• Decommissioning Record Keeping Documentation of Restricted Areas and Spill Sites," and " Timeliness in Decommissioning of Materials Facilities," apply to alllicensees, rather than only to those licensees required to file a decommissioning plan.

The team finds that the Stato needs to adopt both rules, or other generic legally binding requirements, in order to assure consistency with the competibility designations of the new adequacy and compatibility policy.

The team recommends that, as provided by the implementing procedures (" Adequacy ered Compatibility of Agreement State Programs," draft NRC Management Directive 5.9, Handbook Part V), State regulations or other generic legally binding requirements equivalent to the NRC rules be adopted as expeditiously as possible but not later than September 3,2000 (three years after the September 3,1997,162 FR 465171 pubiication of the final policy.)

Based on the IMPEP evaluation criterla, the tsview team recommends that Nevada's performance with respect to the indicator, Legislation and Regulations, be found satisfactory. .

4.2 Sealed Source and Device ISS&D) Evaluation Proaram At the time of the review, Nevada had no sealed source or device manufacturers nor were any applicants anticipated in the near future. The State, however, does not wish to relinquish the authority to regulate SS&D manufacturers in the future. The RHS Supervisor explained the State's provisionary plan as follows:

Upon receipt of an application for a sealed source or device review by any licensee or after State licensure of a manufacturing company in Nevada, BHPS will begin to take steps to develop proposed regulations as appropriate, acquire additional staff andk train existing staff and develop procedures to conduct timely sealed source / device review in accordance with NRC criteria. Considerations to hire new staff or train existing BHPS staff will address all technical disciplines such as mechanical and/or civil engineering expertise, radiation physics, etc., as necessary for this program.

Options for immediate implementation prior to full review program development include: (a) informal or contractual arrangements with other Agreement State (s) to conduct reviews or assist Nevada as they develop various components of the minimum program; (b) contract with an outside consultant to conduct the review or (c) contract with NRC to conduct the review.

Navan Draft Report Page 16 Funj4 tor any of these options would be from revenue collected frorn the apcheen

% Wh ku. finds this approach acceptable and recommends that Nevada's 9 x ence with respect to the indicator, Sealed Source and Device Evaluation Program, w ^ : e 1 satisf actory.

4.3 Low level Radioactive Waste (LLRW) Discosal Proaram The State has no separate LLRW program, but instead regulates the LLRW license in the same manner as any other complex specific licensee. In the process of evaluating this performance indicator, the review team studied the State's responses to the questionnaire, evaluated the qualifications of the technical staff, reviewed the Stete's written procedures and plans, examined parts of the site closure plan and associated documents, reviewed surveillance end inspection reports, and interviewed the principal staff and managers assigned to the LLRW project.

The US Ecology LLRW site, located 11 miles south of Beatty, stopped receiving LLRW on January 1,1993. This decision was formalized by a settlement agreement signed by the Governor on September 24,1993. The site license expit .d December 31,1992, but will remain in effect until the licensre completes their obligations specified in their license and regulations, in the "Deatty, Nevada, Low Level Radio 9ctive Weste Disposal Facility -

Stabilization and Closure Plan Rev 1," and in the lease agreement. Upon completion of the licensee's obligations, the US Ecology license will be transferred to the State of Nevada which will assume all oversight responsibilities and become custodian of the site. This transfer, according to State management, is expected to take place later this year or some time in 1998. Meanwhile, it was verified through file evaluations that the State continues to closely monitor closure activities such as final trench copping, completion of security fencing, and installation of trench markers, it is noted that this LLRW site pre dates the weste site standards adopted in 10 CFR 61.

The team verified by evaluation of State records and the settlement agreement that the State has the funding (approximately nine million dollars) and plans to continue surveillance and necessary repair through inspections and environmental monitoring for 100 years. The Stato currently owns the 80 acre LLRW site and leases a 400 acre buffer zone surrounding the site from the U.S. Bureau of Land Management (BLM). The lease expires in 2007; however, the State is currently in negotiation to buy, trade for, or extend the lease before the expiration date. According to State management, upon transfer of the license to a yet to be named State agency, that agency will assume the responsibility for control of all activities on the site indefinitely.

4.3.1 Etatus of Low Level Radioactive Waste Discosal Insoection The State continues to inspect the facility periodically for trench slumping, security, posting, environmental sampling, and other requirements imposed on the licensee by the license, the regulations and the closure plan. The State's frequency of inspection for the Beatty site is one year, the same as specified in IMC 2800 and IMC 2401. However, due to public and political interests and the potential for changing conditions, the State often 4

Nevada Draft Report Page 17 visits the site on a more frequent basis, conducting additional inspections during most visits. The annual inspection is considered complete when all elements required for closure and/or long term surveillance are covered. The review team examined the reports for nine irispections completed during the review period. There were no inspections in 1993.

There were five inspections in 1994 to observe important closure activities such as trench i

filling and capping. Complete inspections were conducted in 1995,1996, and 1997, it is Nevada's policy to send written confirmation of inspection ndings to the licenses within 30 days after the inspection, but only if items of non compliance are found or if the licensee specifically requests the written confirmstlon, if there are no findings or concerns, the State policy is to present the results orally during the exit meeting. This was the case for the nine inspections conducted during the review period.

4.3.2 Technical Staffina and Trainina in April 1995, the LLRW project manager retired and, because the site was no longer accepting waste, he was not replaced. LLRW functions are now handled by the RHS staff, under the direction of the RHS Supervisor, in addition to his other technical qualifications, the RHS Supervisor has taken all the NRC LLRW specialty courses and has 17 year's experience in regulating the site, both as a reviewer and inspector. The bar:

qualifications for the LLRW program staff are the same as for the RAM program staff, as described in Section 3.2, Technical Staffing and Training.

Becau3e of its proximity to tne site, the Las Vegas office performs most of the licensing and inspection activities, with their work reviewed by the RHS Supervisor. The Lar Vegas Supervising Radiation Physicist has been directly involved in regulating the site since 1978.

He was trainsd and accompanied on many inspections by the retired LLRW project manager. He has taken all of the pertinent courses and workshops given by the NRC and EPA. He,in tum, has trained and assessed another Las Vegas technical staff member to cenduct inspection duties. This inspectra now has five years of on site inspection experience, in addition, RHS has ready access to geologists, civil engineers, hydrologists, and environmentalists within various State agencies or by contract. The review team believes that the technica' staffing and training is adequate to meet the criteria for this indicator.

4.3.3 Technical Quality of Licensina Actions As explained previously, the site license expired December 31,1992, but will remain in effect until the licensee completes their obligations set forth in the closure plan incorporated as a license condition on December 21,1989, the regulations and the lease agreement. A licensee performance assessment was performed at the time the plan was submitted.

Only two licensing amendments were completed during the review period, and both were evaluated. The amendments were minor, involving a change of address, deleting some operational procedures, and clarifying by tie-down exactly what activities the licensee must complete prior to transfer of the license to the State. These licensing actions were done

Nevada Draft Report Page 18 by senior staff nnd were fully acceptable to the review team. Details of the reviews are included in Appendix D.

The team found through observation in Carson City and interviews with the Las Vegas staff that applicable guidance documents such as the NUREGs that support 10 CFR 61 are available and used as needed.

4.3.4 Technical Quality of Insoections The review team evaluated all nine of the on site inspections conducted by the State during the review period. Two were evaluated in depth, and included in Appendix E. The Supervising Radiation Physicist and the inspector were evaluated during the two casework reviews. The inspection reports were complete, thorough, and in accordance with NRC ' l guidance. Both had been reviewed by the supervisors in Las Vegas and Carson City.

No LLRW enforcement actions were needed during the review period because the inspections revealed no items of non-compliance. However, the State does have in place enforcement procedures with severity levels triggering specific escalated actions. These have been used effectively in the past to maintain licensee compliance, and the RHS Supervisor assured the review team that the enforcement procedures would be used as necessary.

Becau6e of site closure, reduced activity, and the use of only senior inspectors, supervisory accompaniments specific to the LLRW program were no longer justifiable. However, the same inspectors are accompanied annually by policy for the radioactive material program.

The review team finds this policy acceptable.

4.3.5 Response to incidents and Alleostions There were no incidents or allegations pertaining to the LLRW program during this review period. There have been reports by the U.S. Geological Survey that they have found tritium at a monitoring well they operate in the buffer zone outside the tence. These reports, however, were never formally submitted to the State, only to the media.

According to program management, RHS, the licensee, and a disinterested third party have continuously and independently monitored for tritium and other isotope migration and have found no evidence of release on or off site. The review team evaluated records including the August 14,1997, " Site Environmental Data Summary," which included more than 2,700 environmental sample results taken by several different parties, including State inspectors and contractors, during the period 1962 to 1997, and found no support for the USGS report. These environmental samples include soll, water, air, vegetation, and direct radiation, both on and off site.

Based on the IMPEP evaluation criteria for the above five performance areas, the review team recommends that Nevada's performance with respect to the indicator, Low level Radioactive Waste Disposal Program, be found satisfactory.

Nevada Draft Report Page 19 5.0

SUMMARY

As noted in Sections 3 and 4 above, the review team found tho, Nevada's performance with respect to each of the performance indicators to be satisfactory. Accordingly, the

, team recommends the Management Review Board find the Nevada program to be adequate to protect public health and safety and compatible with NRC's program.

Below is a summary list of suggestions and recommendations, as mentioned in earlier sections of the report, for evaluation and implementation, as appropriate, by the State.

RECOMMENDATIONS:

1. The review team finds that the State has not met the frequency of IMC 1220 for the inspection of reciprocity licensees. The review team recommends that the State inspect a higher percentage of reciprocity licensees, including high priority industrial radiography licensees operating in rural areas. (Section 3.1)

2. The review team recommends that the general training and qualification procedure be adopted in writing. (Section 3.2)

3. The team recommends that the State review the incident files back to the last event reported to NRC in 1995, and submit reports to NMED as appropriate. (Section 3.5)

4. The team recommends that, as provided by the implementing procedures

(" Adequacy and Compatibility of Agreement State Programs," draft NRC Management Directive 5.9, Handbook Part V), State regulations or other generic legally binding requirements equivalent to the NRC rules be adopted as expeditiously as possible but not later than September 3,2000 (three years after the September 3,1997, [62 FR 46517] publication of the final policy.) (Section 4.1.2)

SUGGESTIONS:

1. The team suggests that the State wait until the NRC OAS joint working group on training issues their final recommendations. The working group recommendations should be considered when developing the written plan.

2 The review team suggests that the State provide a letter, or a short form similar to the NRC Form 501, to the licensee indicating that no violations were found as the result of the inspection, when appropriate.

(

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i LIST OF APPENDICES AND ATTACHMENTS [

Appendix A IMPEP Review Team Members Appenaix B Neverfs Organization Charts ,

Appendix C Nevada's Questionnaire Response [

Appendix D License File Reviews Appendix E Inspection File Reviews Appendix F Incident File Reviews Attachment 1 Nevada's Response to Review Findings t

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APPENDlX A i IMPEP REVIEW TEAM MEMBERS l Nome Area of Responsibility Richard Blanton, OSP On Site Team Leader ,

Technical Scaffing and Training

• Response to !ncidents and Allegations i Legislation stid Regulations Donald E. Bunn, California Status of Materials inspection Technical Quality of Inspections i

Jack Hornor, RIV, WCFO Technical Quality of Licensing Actions Sealed Source and Device Evaluations

Low level Radioactive Waste Disposal Program ,

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4 APPENDIX B NEVADA ,

BUREAU OF HEALTH PROTECTION SERVICES HEALTH DIVISION RADIOLOGICAL HEALTH SECTION ORGANIZATION CHARTS

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APPENDlX C INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM (IMPEP) QUESTIONNAIRE E*J m-N 22-p w 1r g-i -- p-- +,eg-a w ac e..

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0 Nevada Draft Report Page C.1 Approved by OMB' No. 3150 0183 Expires 4/30/98 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE Nevada Program Reporting Period: March 5,1993, to August 25,1997 A. COMMON PERFORMANCE INDICATORS

1. Status of Materials insoection Proaram

1. Please prepare a table identifying the licenses with inspections that are overdue by more than 25% of the scheduled frequency set out in NRC Inspection Manual Chapter 2800 (issu6d 4/17/95). The list should include initialinspections that are overdue.

Resoonse: No Nevada licensees are overdue fqr inspection by more than 25% of the scheduled frequency in NRC Inspection Manual Chapter 2800; 4/17/95.

2. Do you currently have an action plan for completing overdue inspections? If so, please describe the plan or provide a written copy with your response to this questionnaire.

Resoonse: The Nevada action plan for review and completion of overdue inspections consists of periodic review of the computerized inspection file by program management with appropriate staff assignments to minimize overdue inspections. Reviews are conducted ti.e supervisor, radioactive material program manager or southern office enforcement supervisor, making assignments as necessary.

The supervisor has also met with the radioactive material program manager on a monthly basis since December 1996 in preparation for the 1997 audit to be able to provide periodic updates to Division management concerning the status of audit preparation.

3. P: ease identify individual licensees or groups of licensees the State is inspecting less frequently than called for in NRC Inspection Manual Chapter 2800 (issued 4/17/95) and state the reason for the change.-

Estimated burden per response to comply withibis voluntary collection request: 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />.

Forward comments regarding burden estimate to the Information and Records Management Branch (T 6 F33), U.S. Nuclear Regulatory Commission, Washington, DC 20555 0001, and to the Paperwork Reduction Project (3150 0052), Office of Management and Budget, Washington, DC 20503. NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.

Nevada Draft Report Page C.2 Resoonse: No groups of Nevada licensees are scheduled for inspection at frequencies less than the NRC Inspection Manual Chapter 2800;4/17/95.

4. How many licensees filed reciprocity notices in the reporting period?

Resoonse: One hundred twenty one (121) licensees filed two hundred thirty five (235) reciprocity notices during the reporting period,

a. Of these, how many were industrial radiography, welllogging or other users with inspection frequencies of three yeara or less?

Besoonse: Two hundred fifteen (215) reciprocity notices were authorized for industrial radiography, welllogging or other license inspection frequencies of three years or less,

b. For those identified in 4a, how many reciprocity inspections were conducted?

Resoonse: Twenty six (271 reciprocity inspectioes were conducted on industrial radiography, welllogging or other license inspection frequencies of three years or less. .

5. Other than reciprocity licensees, how rnany field inspections of radiographers were performed?

Resoonse: Nine (9) field inspections of industrial radiography licenses were conducted.

6. For NRC Regions, did you establish numerical goals for the number of inspections to be performed during this review period? If so, please describe your goals, the number of inspections actually performed, and the reasons for any differences between the goals and the actual number of inspections performed.

Resoonse: Not Applicable, ll. Technical Staffino and Trainina

7. Please provide a staffing plan, or complete a listing using the suggested format below, of the professional (technical) person years of effort applied to the agreement or radioactive material program by individual, include the name, position, and, for Agreement States, the fraction of time spent in the following areas: administration, mateilats licensing & compliance, emergency response, LLW, U mills, other. If these regulatory responsibilities are divided between offices, the table should be consolidated to include all personnel contributing to the radioactive materials program, include all vacancies and identify all senior personnel assigned to monitor work of junior personnel. If consultants were used to carry out the program's radioactive materials responsibilities, include their efforts.

Nevada Draft Report Page C.3 r

NAME POSITION AREA OF EFFORT Stan Marshall Supervisor 0.20; Admin, ER Larry Boschult Rad. Staff Spec. 0.80; Superv; License, Enforce, ER Larry Franks Sup. Rad. Physicist 0.10; Superv; ER Paul Harvey Red. Control Spec. 0.90; License, Enforce, ER

.lan Hillman Ortiz Red. Control Spec. O.30 License, Enforce, ER Adrian Howe Red. Control Spec. 0.20 License, i Enforce, ER  ;

P.nul Simpson Red. Staff Spec. 0.10 License, '

Enforce, ER Morgan Tyler Rad. Control Spec. 0.35 License, Enforce, ER I TOTAL: 2.95 FTE  :

8. Pletise provide a listing of all new professional personnel hired since the last i review, indicate the degree (s) they received, if applicable, and additional tralriing and years of experience in health physics, or other disciplines, if appropriate.

Busonse: New professional staff hired since the last review include:

Morgan Tyler Start date: March 1994; ARRT (X ray and CT) 15 years in applied radiological technology in private sector; has received all NRC core training (except 5 week course) and other specialized training such as commeicial portable gauge course and OTJ with State of Nevada Adrian Howe Start date: January 1996; ARRT (X ray); 8 years as X ray tech, in Air Force; 3 years as X ray tech, in private medicalindustry; 14 years in State of Montana radiation control program including 9 years as director for that program; has received all NRC core training including 5 week course and other specimilzed training such as commercial portable gauge course and OTJ with the State of Nevada

9. Please list all professional staff who have not yet met the qualification requirements of license reviewer / materials inspection staff (for NRC, inspection Manual Chapters 1245 and 1246; for Agreement States, please describe your qualifications requirements for materlats license reviewtra and inspectors). For each, list the courses or equivalent training / experience they need to attend and a tentative schedule for completion of these requirements.

Response: Morgan Tyler will continue to receive specialized training equivalent to the NRC 5 week health physics course or until such time that his personal schedule and state funding becomes available for his attendance at the course.

1 Nevada Draft Report Page C.4 Adrian Howe will complete the last of four core NRC courses during the '

week of August 11 16,1997 to enable completion of his orientation and final audits for licensing and enforcement activities for alllicense types,

10. Please identify the technical staff who left the RCP/ Regional DNMS program during this period, flesoonse: John Vaden retired from state service in April 1995. No other technical staff has left the program since the previous audit.

Ill. Technical Qualltv of Licensina Actions 11, Please identify any major, unusual, or complex licenses which were issued, received a major amendment, terminated or renewed in this period, fluconse: Seven (7) major, unusual or complex licenses were issued during the reporting period.

Meensee Lic. No, jnued License Tvoe Sunrise Hospital, 03 12 0325 01 4/93 Nuclear Medicine /Tx Blotech Pharmacy 03 11 0332 01 8/93 Nuclear Pharmacy Syncor 16 11 0333 01 8/93 Nuclear Pharmacy Century Geophysical 00 11 0354 01 12/94 Well Logging Fluid Tech, Inc. 03 11 0369 01 5/95 Decon. Service Sierra Pharmacy 16 11 0373 01 1/96 Nuclear Pharmacy Rad. Onc. Ctr. LV 03 12 0394 01 5/97 HDR Afterloader

12. Please identify any new or amended licenses added or removed from the list of licensees requiring emergency plans?

Response: No new and/or amended licenses were added/ removed from the list of licensees requiring emergency plans.

13. Discuss any variances in licensing policies and procedures or exemptions from the regulations granted during the review period.

Response: No variances in licensing policies and procedures or exemptions from the regulations granted during the review period.

14. What, if any, changes were made in your written licensing procedures (new procedures, updates, policy memoranda, etc.) during the reporting period?

Resoonsti No changes were made in your written licensing procedures (new procedures, updates, policy memoranda, etc.) during the reporting period?

15. For NRC Regions, identify by licensee name, license number and type, any renewal applications that have been pending for one year or more.

Response: Not Applicable.

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Nevada Draft Report Page C.5 IV. Technical Quality of insosctions

16. What, if any, changes were made to your written inspection procedures during the reporting period?

Resoonse: No changes were rnade to your written inspection procedures during the reporting period?  ;

17. Prepare a table showing the number and types of supervisory accompaniments made during the review period, include:

Auditor Innocetol License Cat. Q11a Stan Marshall Larry Boschult Nuc. Med. 1/21/03 Port. Gauge 1/7/94 ,

Port. Gauge 6/1/95 Work performance standards wer6 i.vis d for Larry Buechuli tu e 61gn supervisory accompaniments and basic and LLW program management on 10/11/95, Larry became no longer subject to inspection accompaniments.

, Larry Boschult Paul Harvey Port. Gauge 8/11/92 Larry Franks LLW 8/24/92 Nuc. Med. 9/15/92 Small Lab. 5/23/94 Nuc. Med 5/26/95 Ind. Rad. 8/22/96 Nuc. Med. 6/25/97 Larry Franks Jan Hillman Ortiz Ind. Rad. 8/11/92 Nuc. Pharm. 2/5/93 Port Gauge 6/13/94

. Nuc. Med. 6/19/95 Bld. Irrad. 8/29/96 Nuc. Med 7/29/97 Larry Boschult Adrian Howe Port. Gauge 1/29/97 Stan Marshall Paul Simpson Service 2/5/93 Larry Boschult Nuc. Med. 2/1/94 Nuc. Med. 11/9/95 Nuc. Med. 4/17/97 Larry Boschult Morgan Tyler Port. Gauge 3/12/98 Port Gauge 7/10/97

18. Describe internal procedures for conducting supervisory accompaniments of inspectors in the field, if supervisory accompaniments were documented, please provide copies of the documentation for each accompaniment.

Bgmonal Supervisory accompaniments are conducted by program management or senior staff. Enclosed are copies of the sci'ompaniment

. audit reports since the previous audit are on file in the age.cy.

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Nevada Draft Report Page C.6  ;

19. Describe or provide an update on your instrumentation and methods of  ;

calibration. Are allinstruments properly calibrated at the present time?

Response; We maintain at least a minimum of properly calibrated ,

instruments at any given time to conduct insr'*:tions. The equipment is prepared for shipment by staff in the Carson v.ty and Las Vegas offices periodically throughout the calendar yert to ensure that equipment is ,

available for inspections in accordance with agency policy and consistent with requirements for the inspected licensee.

New equipment acquired during the reporting period since the last review includes two portable MCA systems equipped with Nel detectors, s

V. Resoonses to incidents and Alleantions-

20. Please provide a list of the me:t :W:nificant incidsnts (i.e., medical misedministration, overexposures, lost and abandoned sources, incidents i requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less notification, etc.) that occurred in the Region / State

. during the review period. For Agreement States,information included in previous submittels to NRC need not be repeated. The list should be in the following format:

Response; See the attached incident log sheets for allincidents in this reporting period.

21. During this review period, did any incidents occur that involved equipment or source failure or approved operating procedures that were deficient? If so, how and when were other State /NRC licensees who might be affected notified?

Resoonse: Reported incidents did not involve any equipment, source fallce or deficient operating procedures determined to be generic or that would require notification to other state /NRC licensees.

22. For incidents involving failure of equipment or sources, was information on the incident provided to the agency responsible for evaluation of the device for an assessment of possible generic design deficiency? Please provide details for each case.

Responaal Not applicable.

23. In the period covered by this review, were there any cases involving possible

wrongdoing that were reviewed or are presently undergoing review? If so, please describe the circumstances for each case.

Response; The incident log indicates no cases of possible wrongdoing during the review period.

24. Identify any changes to your procedures for handling allegations that occurred during the period of this review.

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Nevada Draft Report Page C.7 s Nr Agreement States, please identify any allegations referred to wur program by the NRC that have not been closed.

fitananagi All cases of allegations that have been referred to this office from the NRC have been closed. ,

VI. Gersral

25. Please prepara a summary of the status of the State's or Region's actions 7;, ken in recponse to the comments and recommendations following the last review.

fleAngrat; Encloesd are status remarks concorr Ing the 1993 NRC audit and 1994 NRC Followup audit recommendations:

1SfjltlMC Audit Recommenda1[gna a dyJ%futud91l0K! bat the state make an effort to exceed the Janymy jf,Qi.WL4L(0/ihpo:lon l of all oylstandina roaoistions: Regulations pertaining to the Emeisecy 71anning P.ule, Standard) for ProtecHon Against Hadlation, Safety Requirements for Radiographic Equipment, Nomication of incidents, and the Quality Management Program and Misadministrations have been adopted by the Nevada State Board of Health.

b. Recommendation that increased mannaement overslaht be orovided to the enforcement oroaram: The Bureau Chlef is periodically informed of pOnding escalated enforcement actions such as management conferences, etc. on a weekly basis and is provided the opportunity to panicipate if he desires,

c. R9 commendation that the state develoo and lmolement written enforcement orocedures which soecific actions to be taken at various levels of severitv: Written enforcement procedures have been developed and are on file with other Radiological Health bection procedures.

d. Recommendation that the state consider various methods of escalated enforcemant actions =used bv other states without civil oenattv: The state has expanded tho variety of escalated enforcement options,

e. Recommendation that the state follow their own poliev in reouiring bloassavs for all forms of I 1'31: Standardized license conditions are routinely issued at the time of licensure to require thyroid bloassays. All existing licenses were amended to require bloassays or revise other licensee procedures to do so,

f. Recomrpandation that written termination orocedures be revised to include the license termination reauirements in the Nevada reaulations: The written termination procedures have been so revised,

g. Recommend1tion that the state use a checklist or form to verify the final disposition of all radioactive material: An existing license termination

,- checklist was revised to include a section to document disposit!on of materials.

l l

. . _ _ _ _ _ - - ~ _ . _._ _ __ _ - ._ . __ _ _ __ _.- _

a Nevada Draft Report Page C.8 l h. Recommendation that certification of disoosal or transfer should bg reauired when recelots cannot be obtained from the new raciolent:

Procedures have been revised to require the licensee to certify in writing the disposition of materials when transfer receipts are not available from the recipient.

l. Recommendation that the state resume the oractice of sendiria cooles of new and amended licenses to the NRC: The agency received written .

notification that copies of licensing actions should no longer be sent to the NRC.

1994 NRC Followuo Audit Regommendations J. Recommendation to revise existina escalated enforcement rocedures to include criteria for manaaement conferences for multiple violations and to describe vlotation severitv: Program nianagement decided to maintain case-by case review to apply the need for management conferences based on inspector's recommendations and discussion with program management.

l. Recommendation to imorove instructions for evaluatina, followuo and gaportina incidents to NRC: also suaaests letters to hosoitals re: the misadministration reoortinal The established process of evaluation, followup 2

and reporting incidents to the NRC was determined to be adequate, incidents continue to be reviewed as they occur to determine whether reporting to NRC is necessary. A letter was sent to all hospitals to emphaalze the medical misadministration reporting requirement in NAC 459.257.

k. Recommendation for an imoroved incident trackina mechanism:

Computerized tracking of incidents was initiated in 1994; however, the initial effort did not prove to be adequate. Tracking reverted to handwritten logging; recent installation of Windows version of NMED in 1997 indicates that the sof tware works; however, its use is not fully implemented.

26. Provide a brief description of your program's strengths and weaknesses.

These strengths and weaknesses should be supported by examples of successes, problems or difficuttles which occurred during this review period.

Resoonsgi Strenath: Comarehensive radiation control authority and oroaram imolementation Nevada law and regulations remain comprehensive to ensure radiation control regulatory and rion regulatory service activities are in one state agency. This approach to program implementation has capitalized on economies of scale to utilize skilled, experienced staff and other resources in multiple program areas.

As new radiation issues mature in the public interest, the agency has added appropriate regulatory / service programs as appropriate. Three examples since the last NRC audit include development of a program for oversight of DOE radiological activities on and around.the Nevada Test Site, regulation adoption and program implementation of a state-mandated mammography X-ray certification including a service contract to conduct inspections for federal certification purposes, and potential radon hazard awareness among all Nevada counties.

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Nevada Draf t Report Page C.9 Weakness: Automatic Loss of Industrv Growth Fee Revenue -Industry growth fee revenue above legislature authorized spending authority is deposited into the general fund. Industry growth fee revenue beyond spending authority is not available to the program without legislature interim finance committee approval or legislative approval during session. Any across the board fee increases or acquisition of other funding without associated spending authority from state legislature can not be used to increase equipment, staff or other resources for the radioactive material program unless legislative authority is approved and in place in advance of acquiring / receiving the revenue.

B. NON COMMON PERFORMANCE INDICATORS

1. Reaulations and Leoal Authority

27. Please list all currently effective legislation that affects the radiation control program (RCP).

BesDonse Nevada Revised Statute INRS) 459 radiation control NRS 457 mammography cert.fication NRS 439 administrative procedures NRS 414 emergency response

28. Are your regulations subject to a Sunset" or equivalent law? If so, explain and include the next expiration date for your regulations.

Resoonse: No.

29. Please complete the enclosed table based on NRC chronology of arnendments. Identify those that have not been adopted by the State, explain why they were not adopted, and discuss any actions being taken to adopt them.

Response: It is not necessary to adopt rules pertaining to poolirradiators and uranium mill tailings at this time as no licenses in these categories are currently used by the Nevada Health Division. Steps will be taken to initiate public hearings and regulation adoption upon contact by a possible applicant or receipt of application in these license categories.

Rules not adopted by the state pertaining to decommissioning are incorporated into one applicable license by license condition. Adoption of the requirements will be initiated at the next occasion to revise state regulations.

30. If you have not adopted all amendments within three years from the date of NRC rule promulgation, briefly describe your State's procedures for amending regulations in order to maintain compatibility with the NRC, showing the normallength of time anticipated to complete each step.

Resoonse: The process for regulation adoption requires a minimum of six (6) months during specific times of the two-year biennium, otherwise, adopted regulations are considered to be temporary and must be revisited for adoption by tha Nevada State Board of Health or they will expire.

s Nevada Draft Report Page C.10 The adoption process involves development of proposed text, distribution to the affected public and public notice locations in the state, public workshops where determined necessary by staff or agency management, written response to all written comments, due process notice of the Board of Health adoption hearing, staff presentation at the announced Board of Health meeting at which time the Governor appointed, seven-member board will adopt with or without revisions to staff recommendations, or table or veto the regulations.

II. Sealed Source and Device Proaram

31. Prepare a table listing new and revised SS&D registrations of sealed sources and devices issued during the rcview period. The table heading should be:

Resoonse: No sealed source manufacturers are located in the state of Nevada, therefore, no SS&D registrations have been issued. We no not intend to develop capability for this activity at this time but also do not intend to relinquish authority for the activity either.

A memorandum to file has been developed to indicate that the agency will develop procedures and regulations as necessary in the event an application for sealed source manufacturing is delivered to the office.

32. What guides, standards and procedures are used to evaluate registry applications?

flgiggnsm Not applicable at this time; see ll.31 response.

33. Please include information on the following questions in Section A, as they apply to the Sealed Source and Device Program:

Technical Staffino and Trainina - A.II.710 Not applicable Igchnical Quality of Licensina Actions A.lll.11. A.III.1314 Not applicable Resoonses to incidents and Allocations A.V.20 23 Not applicable 111. Low level Waste Proaram

34. Please include information on the following questions in Section A, as they apply to the Low level Waste Program:

A. Status of Materials Inspection Proaram A.I.13. A.I.6 - No material inspection program element exists due to site closure, inspections at the closed Beatty low level radioactive waste facility occur periodically as appropriate relative to completion of remaining post-closure activities.

Since the low level waste site was closed; inspections are limited to review of custodial post closure activities such as verifying integrity of trench caps, inspection of the perimeter fence, review of post-closure records, etc.

Nevada Draft Report Page C.11 B. Technical Staffina and Trainino A.fl.710 Program staff and associated training is status quo with existing staff continuing evaluation of the last post closure activities. Las Vegas Radiological Health Section senior staff continue to perform review / inspections as necetsary; Carson City senior staff continues with program administrative activities, etc.

C. Technical Quality of Licensina Actions A.llt.11. A.lli.1314 -

Licensing actions have , aan minimal since site closure on December 31,1992 with anticipation that a ilcense transfer amendment may be issued in the near future after completion M post-closure activities by tht, licensee and acceptance of technical mformation and activity status by the agency.

D. Technical Quality of Insoections - A.IV.1019 - Site inspections continue as appropriate concerning the final post closure activities not completed by the' licensee. Inspection and review activities have continued at a less aggressive rate than during waste disposal while the site was open in accordance with diminishing post closure activities.

As a result, low level waste site inspection policy and inspection forms are under review to implement appropriate modification to reflect site closure elements that are yet to be completed before and af ter license transfer.

E. Responses to incidents and All t aations A.V.20 23 No allegations have been filed with this office and no incidents occurred during the review period.

IV. Uranium Mill Proaram

35. Please include iriformation on the following questions in Section A, as they apply to the Uranium Mill Program:

Status of Materials insoection Proaram - A.I.13. A.I.Q Not applicable Technical Staffino and Trainino - A.ll.710 Not applicable Technical Quality of Licensina Actions - A.lll.11. A.Ill.1314 Not applicable Technical Quality of insoections - A.IV.1619 Not applicable Resoonses to incidents and Alleaations - A.V.20-23 Not applicable

j Nevada Draft Report Page 12 TABLE FOR QUESTION 29.

OR DATE DATE NT UPECTED 10 CFR RULE DUE ADOPTED STATUS ADOFnDN Any amendment due prior to 1991. Identify each regulation (refer to the Chronology of Amendments)

Dew... ....siorung: 7/27/91 6/11/93 Parts 30,40,'70 E.Tepsi Plannmg: 4/7/93 6/11/93 Parts 30,40,70 Standards for Protection Against Radiation: 1/1/94 12/8/93 Part 20 Safety Requirements for Radiographic 1/10/94 12/8/93 l Equipment: Part 34 Notification of incidents: 10/15/94 1/18/94 i Parts 20, 30, 31, 34, 39, 40, 70 Ouality Management Program and 1/27/95 7/7/94  ;

Misedmmistrations: Part 35 Licensing and Radation Safety Requerements 7/1/96 N/A: no irradiators licensed in Nevada. Requirements wiB be applied for Irradiators: Part 36 - by lic. condition until they are adopted by the Bd. of Health.

Definition of Land Disposal 7/22/96 N/A; no intent to license future LLW sites.

and Weste Site QA Program: Part 61 Dm.v......;ssionmg Recordkeepmg Docu- 10/25/96 Not adopted yet; addressed by license condition for one license. 3/1/98 mentation Additions: Parts 30,40,70 Self<suarantee as an Additional Financial 1/28/97 Not adopted yet; addressed by license condition for one license. 3/1/98 Mechanism: Parts 30,40,70 j

Uraruum MiB Tasimos: Conformmg to EPA 7/1/97 N/A: no uranrum mill tailmgs licensees in Nevado.

Standards: Part 40 Timereness in Decommessionmg 8/15/97 Not adopted yet; addressed by Ecense condition for one license. 3/1/98 Parts 30,40,70

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O APPENDIX D

. LICENSE FILE REVIEWS File No.: 1 Licensee: Diversified Consulting Services License No.: 00 11 0344 01 Location: Carson City, NV Amendment No.: 1 '

License Type: Portable Gauges Type of Action: New/ Amendment Date New Ucense issued: 6/26/94 License Reviewer: LB ,

Date Amendment issued: 7/6/94 License Reviewer: MT +

File No.: 2 Licensee: Resource Concepts, Inc. License No.: 00 11 0343 01 Location: Carson City, NV License Type: Portable Gauge Type of Action: New Date lasued: 6/3/94 License Reviewer: LB C

Fi% No.: 3 Licenswe: Century Geophysical Corp. License No.: 00 11 0354 01 Location: Les Vegas, NV License Type: Well Logging Type of Action: New Date issued: 12/6/94 .

License Reviewer: PH File No.: 4 Licensee: Kleinfelder, Inc. License No.: 00 11 0278 01 Location: Las Vegas, NV Amendment No.: 8 License Type: Industrial Radiography Type of Action: Renewal Date Renewalissued: 9/26/95 License Reviewer PH File No.: 5 Licensee: Fluid Tech, Inc. License No.: 00 11 0339 01

> Location: Las Vegas, NV Amendment No.: 4 and 5 License T,pe: Decontamination Service Type. of Action: Amendment

Date Amendment issued

4/3/95;5/30/95 License Reviewer: PH File No.: 6 .

~

Licensee: Sierra Pharmacy Services Licens; No.: 16 11 0373 01 Location: Reno,NV License Type: Nuclear Pharmacy Type of Action: New Date issued: 1/29/96 License Reviewer: LB Comment:

a) License hand-delivered to licensee File No.: 7

. Licensee: HSI GeoTrans License No.: 00 11 0397 01

- Location: Reno,NV License Type: Portaole Gauge Type of Action: New Date issued: 5/28/97 License Reviewer: AH 4

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Nevada Draft Report Page D.2 License File Reviews File No.: 8 Licensee: MET ChemTesting Laboratories License No.: 00 11 0335 01 Location: Salt Lake City, UT Amendment No.: 2 License Type: Industrial Radiographer Type of Action: Termination Date Terminated: 5/23/94 License Reviewer: LB Comments:

a) Radioactive material transferred to licensee's UT License (UT 1800146)

File No.: 9 Licensee: J. Daniel Wilkes, M.D., LMC Laboratory License No.: 03 12 0006 01 Location: Las Vegas, NV Amandment No.: 7 License Type: Bio Med In Vitro Testing Type of Action: Termination Date Terminated: 7/29/94 License Reviewer: JHO File No.: 10 Licenseo: Aerojet General Corporation License No.: 13 11 0195 01 Location: Sucramento, CA and Range 63, Nellis AFB Amendment No.: 4 License Type: Ordnance Testing Type of Action: Termination Date Terminated: 2/21/97 License Reviewer: LB File No.: 11 Licensee: BC Environmental License No.: 00 11 0374 01 Location: Reno, NV Amendrrent No.: 2 License Type: Portable Gauge Type of Action: Termination Date Terminated: 3/31/97 License Reviewer: LB File No.: 12 Licensee: Radiation Oncology Center of Las Veges License No.: 03 12 0394 01 Location: Las Vegas, NV License Type: High Dose Afterloader Type of Action: New Date Issued: 5/12/97 License Reviewer: PH Comment:

a) Hand delivered File No.: 13 Licensee: Lockheed Environmental Systems License No.: 00 16-0112 01

& Technologies, Inc.

Location: Las Vegas, NV Amendment No.: 19 License Type: Laboratory & Decontamination Service Type of Action: Renewal Date Renewalissuod: 5/10/96 License Reviewer: PH File No.: 14 Licensee: Rayrock Mines, inc- License No.: 00 11 0386-01 Location: Valmy, NV License Type: Portable Gauge Type of Action: New Date issued: 9/23/96 License Reviewer: PS

~.- - . - . . - . - - .- - - . -

Nevada Draft Report Page D.3 License File Reviews File No.: 15 Licensee: Las Vegas Valley Water District License No.: 00 11-0196 01 Location: Las Vegas, NV Licen::e Type: Portable Gauge 't ype of Action: Renewal Date Renewal issued: 4/19/98 License Reviewer: JHO File No.: 16 Licensee: University of Nevada, Reno License No.: 16-13 0003-07 Location: Reno, NV Amendment No.: 19 License Type: Broad Scope Type B Type of Action: Major Amendment Date Amendment issued: 9/3/96 License Reviewer: LB

^

File No.: 17 Licensee: US Ecology, Inc. License No.: 1-13 0043 02 Location: Oak Ridge, TN (Beatty, NV, site) Amendment No.: 16 License Type: LLRW burial Site Type of Action: Amendment Date Amendment Issued: 10/2/96 License Reviewer: LB Comment:

a) This amendment changes the licensee's home address and re-ties them to the original application, facility standards manual, site closure plan, and lease agreement with Nevada.

File No. 18 Licensee: Sunrise Hospital Laboratory License No.: 03 12-0325 02 Location: Las Vegas, NV License Type: Irradiator (< 10,000 Ci) Type of Action: New Date issued: 2/9/96 License Reviewer: PH File No.: 19 Licensee: Biotech Pharmacy Licente No.: 03-11-0352 01 Location: Las Vegas, NV Amendment No.: 4 License Typo: Nuclear Pharmacy Type of Action: Amendment Date Amendment issued: 5/10/95 License Reviewer: PH File No.: 20 Licensee: Leon H. Steinberg, M.D. License No.: 03 12 0307 01 Location: Las Vegas, NV Amendment No.: 3 License Type: Medical Private Practice Type of Action: Termination Date Terminated: 6/17/97 License Reviewer: PH Comment:

a) Terminated as part of a licensing action to overcome problems with licensee. New, more restrictive license issued (see file 21).

Nevada Draft Report Page D.4 License File Reviews -

File No.: 21 Licensee: Steinberg Diagnostic MedicalImaging Center Location: Las Vegas, NV License No.: 03 12-0352 01 License Type: Nuclear Medicine Clinic Type of Action: New Date issued: 6/17/97 License Reviewer: PH Comments:

a) See comment for file 20.

b) New license requires licensee to follow RG 10.8; requirements include quality management plan program, bloassay by license condition, radiation safety committee for clinic with quarterly meetings, and new radiation safety officer.

File No.: 22 Licensee: Carson Tahoe Hospital License No.: 01 12 0032-01 Location: Carson City, NV Amendment No.: 20 License Type: Medical Institution with therapy Tyr if Action: Renewal Date Renewal Issued: 9/26/95 License Reviewer:

File No.: 23 Licencee: Syncor International Corporation License No.: 16 11-0333 01 Location: Reno, NV Amendment No.: 2 License Type: Nuclear Pharmacy Type of Action: New Date issued: 8/17/93 License Reviewer: PH Comments:

. a) License hand carried to licensi.e b) Prelicensing inspection conducted and documented.

File No.: 24 Licensee: Radiation Oncology Associates License No.: 16 12 0323 Location: Reno, NV License Type: Teletherapy Type of Action: Major amendment

'Jate issued: 8/27/97 License Reviewer: LB 6

..g

APPENDIX E INSPECTION FILE REVIEWS File N o.: 1

' Licensee: US Ecology License No.: 13 11-0043-02 Location: Beatty, NV inspection Type: Announced, Routine License Type: LLRW burial site Priority: 1 Inspection Date: 8/30/95 Inspector: PH File No.: 2 Licensee: US Ecology License No.: 13 11-0043 02 Location: Beatty, NV Inspection Type: Announced, Routint License Type: LLRW burial site Priority: 1 Inspection Date: 3/12/97 Inspector: LF File No.: 3 Licensee: Resource Concepts, Inc. License No.: 00 11-0343-01 Location: Carson City, NV Inspection Type: Unannounced, Routine License Type: Portable Gauge Priority: 3 Inspection Date: 8/13/97 Inspector: MT Comments:

a) Report reviewed at time of accompaniment; enforcement correspondence not ready for review.

b) Inspection form did not have section for reviewing incidents that may nave occurred since last inspection. Upon suggestion by review team, RHS Supervisor added item through memo dated 8/26/97.

File No.: 4 Licensee: Consulting Engineering Services License No.: 0 11-0154 01 Location: Reno, NV inspection Type: Unannounced, Routine License Type: Portable Gauge Priority: 4 Inspection Date: 8/18/97 inspector: AH Comment:

a) Report reviewed at time of accompaniment; enforcement correspondence not ready for review.

File No.: 5 Licensee: Desert Industrial X Ray, Inc. License No.: 00-11-0360-01 Location:- Henderson, NV inspection Type: Unannounced, routine License Type: Industrial Radiography Priority: 1 Inspection Date: 8/21/96 Inspector: PH File No.: 6 Licensee: Desert Radiologists - Eastern License No.: 03-12-0327-01 Location: 1.as Vegas, NV inspection Type: Unannounced, routine License Type: Nuclear Medicine -

Priority: 2 Inspection Date: 12/12/95 Inspector: PH

o Nevada Draft Report Page E.2 1 Inspection File Reviews

! File No.: 7 Licensee: Radiation Oncology Associates License'No.: 16 12 0323 01 Location: Reno, NV- Inspection Type: Unannounced, routine License Type: - Teletherapy Priority: 1 inspection Date: 9/26/96; 10/17/06 Inspector: LB

Comments

a) Teletherapy license inspected at 3 year interval although State calls it Priority 1 (NRC changed to Priority 3).-

b) Inspection conducted on two dates to complete review of records in main office.

File No.: 8 Licensee: Radiation Oncology Associates License No.: 01-12 0225 01 Location: Carson City, NV Inspection Type: Unannounced, routine -

License Type: Teletherapy Priority: 1

Inspection Date: 9/20/96;10/17/96 Inspector: LB

" Comments:

, a) Teletherapy license inspected at 1-year interval.

b) inspection completed on two dates to complete review of records in main office.-

l File No.:- 9 Licensee: Carson-Tahoe Hospital License No.: 01-12 0032 01

[ Location: Carson City, NV Inspection Type: Unannounced, routine License Type: Nuclear Medicine Priority: 2 inspection Date: 6/17/97 Inspector: PS & MT Comments:

a) Licensee notification letter sent 8/11/97 - over 30 days after inspection, b) Previous inspection 2/94; inspection overdue by NV inspection schedule; but not by NRC IMC 2800, f

File No.: 10 i - Licensee: Biotech Pharmacy License No.: 03-11-0332 01 Location:- Las Vegas, NV _ Inspection Type: Unannounced; routine F License Type: Nuclear Pharmacy Priority: 1 Inspection Date: 9/17/96 Inspector: PH Comment:

a) Six serious vielations and four items of concern did not trigger follow-up inspection.

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Nevada Draft Report Page E.3 Inspection File Reviews File No.:' 11 & 12 Licensee: Kleinfelder, Inc. License No.: 00-11 0278 01 Location: Las Vegas, NV Inspection Type: Unannounced, office only, routine License Type: Industrial Radiographer Priority: 1 Inspection Date: 12/21/95 and 2/26/97 Inspector: PH Comments:

a) Five violations including one repeat found during 12/95 inspection resulted in enforcement conference on 1/22/96.

b) Although 12/95 office inspection showed radiography work was conducted by one radiographer in violation of State's two person rule, State did not conduct field inspection during 2/97 inspection.

File No.: 13 & 14 Licensee: University of Nevada, Reno License No.: 16 13 0003-07 Location: Reno, NV Inspection Type: See below License Type: Academic Type B Priority: 2 Inspection Date: 5/18/93 (partial): 11/2/93 (partial) Inspector: LB Inspection Date: 3/28/94 (partial); 4/1/94 (partial); 8/15,18/94 (partial); 12/19/94 memo to file summarized findings during '93 and '94 partialinspections Inspection Date: 1/24 27/95 (partial); 3/9/95 memo to file summarized findings during 1/95 partial inspections inspection Date: 2/11/97 follow up Comments:

a) There had not been a complete inspection of this licensee since September 1991 Following an incident on 2/93 where RAM was released to normal trash, there are a series of partialinspections in which problems were noted with inventory, ovvall control of radiation, and RSO user authorizations, b) No documentation in file that University was advised in writing of violations until NOV sent 6/14/95 - five months after 1/95 inspections.

c) State advises complete inspection conducted on date but report not available to review team.

File No.: 15 Licensee: University of Nevada, Las Vegas, NV License No.: 03-13 0305 01 Location: Las Vegas, NV inspection Type: Unannounced, complete, routine License Type: Academic Type B Priority: 2 inspection Date: 11/25 27/96 Inspector: PH File No.: 16 Licensee: AGRA Earth and Environmental License No.: 00-11-0193-01 Location: Sparks, NV Inspection Type: Announced, routine License Type: Industrial Radiographer Priority: 1 Inspection Date: 5/7/97 Inspector: LB Comments:

a) Thirty-two months between radiography licensee inspections, b) ' Unable to determine from file whether field inspection was conducted.

c) Licensee not advised of results of clear inspection in writing (no short form).

0 Nevada Draft Report Page E.4 Inspection File Reviews Fife No.:- 17 Licensee: AGRA Earth and Environmental License No.: 00 11-0193 02 Location: Sparks, NV inspection Type: Announced, routine -

License Type: Portable Gauge Priority: 3 Inspection Date: 7/10/97 Inspector: MT File No.: 18 Licensee: Terracon Consultants Western, Inc. License No.: 00 11 0326-01 Location: Las Vegas, NV inspection Type: Unannounced, field, routine License Type: Portable Gauge Priority: 3 Inspection Date: 9/11/96 Inspector: PH File No.: 19 Licensee: Boulder City Hospital License No.: 03 12-0342 01 Location: Boulder Cit, NV Inspection Type: Unannounced, routine License Type: Nuclear Medicine Priority: 2 Inspection Date: 4/8/97 Inspector: PH 4

File No.: 20 Licensee: Lockheed Environmental Systems License No.: 00 16 0112 03 Location: Las Vegas, NV Inspection Type: Announced, initial License Type: Fixed Gauge Priority: 3 Inspection Date: 8/9/95 Inspector: PH File No.: 21 Licensee: Covan Pacific Coast Testing License No.: 4886 48 Location: Sparks, NV (Benicia, CA) Inspection Type: Reciprocity, field License Type: Industrial Radiography Priority: 1 Inspection Date: 1/24/96- Inspector: LB File No.: 22 Licensee: Decisive Testing License No.: 1836 80 Location: Las Vegas, NV (San Deigo, CA) Inspection Type: Reciprocity, field Licenae Type: Industrial Radiography Priority: 1 Inspection Date: 6/8/96 Inspector: PH File No.: 23 Licensee: Phoenix National Labs License No.: AZ7 415 Location: Las Vegas, NV (Tempe, AZ) Inspection Type: Reciprocity, field License Type: Industrial Radiographer Priority: 1 Inspection Date: 1/18/97 Inspector: PH Comment:

a) No violations, no written notice to licensee.

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Nevada Draft Report Page E.5 Inspection File Reviews File No.: 24 Licensee: Continental Testing and Inspection License No.: 2535 70 Location: Las Vegas, NV (Signal Hill, CAF.spection Type: Unannounced reciprocity, office License Type: Industrial Radiography Priority: 1 Inspection Date: 6/8/96 Inspector: PH Comments:

a) Inspector visited the Las Vegas business office of this CA licensee after being notified a radiography source would be transferred into State for use between 8/3/96 and 8/10/96. Company advised inspector that source had not been transferred to NV despite notification.

File No.: 25 Licensee: SGS Industrial Services License No.: 341 60 Location: Las Vegas, NV inspection Type: Unannounced, reciprocity, office (San Leandro, CA)

License Type: Industrial Radiography Priority: 1 Inspection Date: 3/14/96 Inspector: PH

. File No.: 26 Licensee: Converse Consultants Southwest, Inc. License No.: 00 11-0094-01 Location: Las Vegas, NV Inspection Type: Unannounced, followup License Type: Portable Gauge Priority: 3 Inspection Date: 8/8/94 Inspector: JH in addition, a review team member made the following inspection accompaniments as part of the on site IMPEP review:

Accompaniment No.: 1 Licensee: Resource Concepts, Inc. License No.: 00 11-0343 01 Location: Carson City, NV inspection Type: Unannounced, Routine License Type: Portable Gauge Priority: 3 Inspection Date: 8/13/97 Inspector: MT Comments:

a) Inspector did not tie items of non-compliance to license conditions or regulations b) inspector did not question licensee regarding incidents; inspection form had no incident review section.

Accompaniment No.: 2 Licensee: Consulting Engineering Services License No.: 00-11-0154-01 Location: Reno, NV inspection Type: Unannounced, Routine License Type: Portable Gauge Priority: 4 inspection Date: 8/18/97 Inspector: AH

c 9

APPENDIX F INCIDENT FILES PEVIEWED File No.: 1 Licensee: Converse Consultants Southwest, Inc License No.: 00-11 0094 01 incident ID No: NV 93 06 Location: Las Vegas, NV Date of Event: 4/26/93 Type of Event: LAS Investigation Date: 4/26/93 Investigation Type: Field Summary of incident and Final Disposition: Portable gauge lost or stolen / recovered.

File No.: 2 Licensee: United Mining of Nevada License No.: General licensee incident ID No: NV 93-09 Location: Houston Oil and Mineral Mine, VI.ginia City Date of Event: 5/31/93 Type of Event: LAS Investigation Date: 6/01/93 Investigation Type: Field Summary of incident and Final Disposition: Fixed gauge found at abandoned mine site /

impounded.

Comment:

a) Not reported to NMED.

File No.: 3 Licensee: Dawn Mining Company License No.: (Unknown - NRC)

Incident ID No: NV 94-05 Location: Elko, NV -

Date of Event: 1965-1975

- Type of Event: Release of Materials investigation Date: 2/09/94 investigation Type: Field Summary of incident and Final Disposition: NRC requested survey of possible residual uranium contamination at storage site of terminated licensee (ORNL).

Comment:

a) Results reported to Region V but not reported to NMED.

4

Nevada Draft Report _ Page F.2 Incident File Reviews File No.: 4 Licensee: Golden Nugget License No.:- General licensee incident ID No: NV 94-09 Location: Las Vegas, NV Date of Event: 6/02/94 Type of Event: LAS Investigation Date: 6/21/94 investigation Type: Telephone Summary of incident and Final Disposition: Reported loss of two Po 210 (5.0 millicurie each) anti static devices.

Comments:

a) No action taken by RHS - reason given: material had decayed to exempt level, b) Not reported to NMED.

File No.: 5-Licensee: Converse Consultants Southwest, Inc License No.: 00 11 0094 01 incident ID No: NV-94-10 -

Location: Las Vegas, NV Date of Event: 9/14/94 Type of Event: TRS Investigation Date: 9/14/94 investigation-Type: Field Summary of incident and Final Disposition: Portable gauge reported lost or stolen; recovered same day Comments:

a) Reported to NMED; event date, other information in NMED incorrect.

File No.: 6 Licensee: Westec, Inc License No.: 00-11-0197-01 incident ID No: NV 94-12 Location: Newmont Mine; near Carlin, NV Date of Event: 8/25/94

-Type of Event: EQP Investigation Date: 8/26/94 investigation Type: Telephone Summsry of incident and Final Disposition: Portable gauge run over by heavy equipment at job-site; destroyed; no leakage detected.

Comment:

a) NMED item information incorrect: wrong event date, s/n: 10583.

, . ~ . _

Nevada Draft Report Page F.3 incident File Reviews ,

File No.: 7 Licensee: Summit Engineering Corp License No.: 00 11 0180 01 incident ID No: NV 95 01 Location: Reno, NV Date of Event: 2/09/95 Type of Event: LAS Investigation Date: 2/09/95 investigation Type: Field Summary of incident and Final Disposition: Theft of three portable gauges during burglary; two devices recovered on 2/10/95, third on 2/12/95, all three were undamaged.

Comment:

a) Reported on NMED but information not complete.

- File No.: 8 Licensee: SEA, Inc License No.: 00 11-0009 01 incident ID No: NV 95 05 Location: Las Vegas, NV Date of Event: 4/21/95 Type of Event: LAS Investigation Date: 4/21/95 investigation Type: Field Summary of incident and Final Disposition: Portable gauge lost or stolen, not recovered; licensee cited for failure to adequately secure the device.

Comment:

a) Not reported to NMED.

b) State procedures do not require a press release.

File No.: 9 Licensee: Southwest Testing License No.: 00 11 0366-01 incident ID No: NV 96-10; NV-97 07 Location: Las Vegas, NV Date of Event: 5/29/96 Type of Event: LAS Investigation Date: 5/30-31/96 Investigation Type: Telephone Summary of incident and Final Disposition: Licensee cited for inadequate control over RAM: gauge recovered 7/14/97 (NV 97 07).

Comment:

a) Not reported on NMED.

Nevada Draft Report Page F.4 incident File Reviews File No.: 10 -

Licensee: Leslie W. Williams, DVM License No.: 03 12 0155 01 Incident ID No: NV 9611 Location: Las Vegas, NV Date of Event: 8/22/96 Type of Event:- Abandoned source investigation Date: 8/22/96 Investigation Type: Field Summary of incident and Final Disposition: Licensee left State in 1994, reportedly for Missouri, left behind St 90 eye opplicator at LV clinic (unlicensed); device was impounded by RCP.

Comments:

a) -- Not on NMED.

b) Not reported to NRC (in case license sought in MO).

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b LIST OF APPENDICES AND ATTACHMENTS Appendix A IMPEP Review Team Members Appendix B Nevada Organization Charts Appendix C Nevada's Questionnaire Response Appendix D License File Reviews Appendix E Inspection File Reviews Appendix F Incident File Reviews Attachment 1 Nevada's Response to Review Findings

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IMPEP REVIEW TEAM MEMBERS Name' Area of Responsibility Richard Blanton, OSP On Site Team Leader Technical Staffing and Training Response to incidents and Allegations

- Legislation and Regulations Donald E. Bunn, California Status of Materials inspection Technical Quality of Inspections Jack Hornor, RIV, WCFO Technical Quality of Licensing Actions Sealed Source and Device Evaluations Low level Radioactive Waste Disposal Program

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INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM (IMPEP) CUESTIONNAIRE -

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s Nevada Draft Report Page C.1 Approved by OMB' No. 3150-0183 Expires 4/30/98 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE Nevada Program Reporting Period: March 5,1993, to August 25,1997 A. COMMON PERFORMANCE INDICATORS

1. Status of Materials Insoection Proaram

1. Please prepare a table identifying the licenses with inspections that are overdue by more than 25% of the scheduled frequency set out in NRC Inspection Manual Chapter 2800 (issued 4/17/95). The list should include initialinspections that are overdue.

Ruponna: No Nevada licensees are overdue for inspection by more than 25% of the scheduled frequency in NRC Inspection Manual Chapter 2800; 4/17/95.

2. Do you currently have an action plan for completing overdue inspections? If so, please describe the plan or provide a written copy with your response to this questionnaire.

Resoonse: The Nevada action plan for review and completion of overdue inspections consists of periodic review of the computerized inspection file by program management with appropriate staff assignments to minimize overdue inspections. Reviews are conducted the supervisor, radioactive material program manager or southern office enforcement supervisor, making assignments as necessary.

The supervisor has also met with the radioactive material program manager on a monthly basis since December 1996 in preparation for the 1997 audit to be able to provide periodic updates to Division management concerning the status of audit preparation.

3. Please identify individual licensees or groups of licensees the State is inspecting less frequently than called for in NRC Inspection Manual Chapter 2800 (issued 4/17/95) and state the reason for the change.

' Estimated burden per response to comply with this voluntary collection request: 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />.

Forward comtnents regarding burden estimate to the Information and Records Manecement Branch (T 6 F33), U.S. Nuclear Regulatory Commission, Washington, DC 20555 0001, and to the Paperwork Reduction Project (3150 0052), Office of Management and Budget, Washington, DC 20503. NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.

Nevada Draft Report Page C.2 Resoona: No groups of Nevada licensees are scheduled for inspection at frequer'cies less than the NRC inspection Manual Chapter 2800;4/17/95.

4. How many licensees filed reciprocity notices in tha reporting perioc' Resooast One hundred twenty one (121) licensees filed two hundred thirty five (235) reciprocity notices during the reporting penod.

a. Of these, how many were industrial radiograpy, welllogging or other users with inspection frequencies of three years or less?

Resoorise: Two hundred fifteen (215) reciprocity notices were authorized for industrial radiography, welliogging or other license inspection frequencies of three years or less.

b. For those identified in 4a, how many reciprocity inspections were conducted?

Resoonse: Twenty six (27) reciprocity inspections were conducted on industrial radiography, welllogging or other license inspection frequencies of three years or less.

5. Other than reciprocity licensees, how many field it.spections of radiographers were performed?

Resoonse: Nine (9) field inspections of industrial radiography licenses were conducted.

6. For NRC Regions, did you establish numerical goals for the number of inspections to be performed during this revie " period? If so, please describe your goals, the number of inspections actually performed, and the reasons for any differences between the goals and the actual number oiinspections performed.

Response: Not Applicable, ll. Technical Staffino and Trainina

7. Please provide a staffing plan, or complete a listing using the suggested format below, of the professional (technical) person-years of effort applied to the agreement or radioactive material program by individual. Include the name, position, and, for Agreement States, tha fraction of time spent in the following areas: administration, mater:als licensing & compliance, emergency response, LLW, U-mills, other, if these regulatory resoonsibilities are divided between offices, the table should be consolidated to include all personnel -

contributing to the radioactive materials program. Include all vacancies and identify all senior personnel assigned to monitor work of junior personnel. If consultants were used to carry out the program's radioactive materials responsibilities, incluJe their efforts.

Nevada Draft Report Page C.3 lLAME P_OSITION AREA OF EFFORT Stan Marshall Supervisor 0.20; Admin, ER Larry Boscht,lt Rad. Staff Spec. 0.80; Superv; License, Enforce, ER Larry Franks Sup. Rad. Physicist 0.10; Superv; ER Paul Harvey Rad. Control Spec. 0.90; License, Enforce, ER Jan Hillman-Ortiz Rad. Control Spec. O.30 License, Enforce, ER Adrian Howe Rad. Control Spec. O.20 License, Enforce, ER Paul Simpr.on Rad. Staff Spec. 0.10 License, Enforce, ER Morgan Tyler Rad. Control Spec. 0.35 License, Enforce, ER TOTAL: 2.95 FTE

8. Please provide a listing of all new professional personnel hired since the last review, indicate the degree (s) they received, if applicable, and additional training and years of experience in health physics, or other disciplines, if appropriate.

Resoonse: New professional staff hired since the last review include:

Morgan Tyler - Start date: March 1994; ARRT (X-ray and CT) 15 years in applied radiological technology in private sector; has received all NRC core training (except 5 week course) and other specialized training such as commercial portable gauge course and OTJ with State of Nevada Adrian Howe - Start date: January 1996; ARRT (X ray); 8 years as X ray tech. In Air Force; 3 years as X ray tech. in private medicalindustry:.14 years in State of Montana radiation control program including 9 years as director for that program; has received all NRC core training including 5 week course and other specialized training such as commercial portable gauge course and OTJ with the State of Nevada

9. Please list all professional staff who have not yet met the qualification requirements of license reviewer / materials inspection staff (for NRC, Inspection Manual Chapters 1245 and 1246; for Agreement States, please describe your qualifications requirements for materials license reviewers and inspectors). For each, list the courses or equivalent training / experience they need to attend and a tentative schedule for completion of these requirements.

Resoonse: Morgan Tyler will continue to receive specialized training equivalent to the NRC 5-week health physics course or until such time that his personal schedule and state funding becomes available for his attendance at the course.

4

4 Nevada Draft Tieport Page C.4 Adrian Howe will complete the last of four core NRC courses during the week of August 11 - 15,1997 to enable completion of his orientation and final audits for licensing and enforcement activities for alllicense types.

10. Please identify the technical staff who left the RCP/ Reg;onal DNMS program during this period.

Resoonse: John Vaden retired from state service in April 1995. No other technical staff has left the program since the previous audit.

Ill. Technical Quality of Licensina Acticy.ui_

11. Please identify any major unusual, or complex licenses which were issued, received a major amendruent, terminated or renewed in this period.

Equiponse: Seven (7) major, anusual or complex licenses were issued during the reporting period.

lJlUdligg Lic. No. Issued License Tvoe Sunrise Hospital, 03 12-0325 01 4/93 Nuclear Medicine /Tx Biotech Pharmacy 03-11-0332-01 8/93 ~ Nuclear Pharmacy Syncor 16 11-0333-01 8/93 Nuclear Pharmacy Century Geophysical 00-11 0354-01 12/94 Well Logging Fluid Tech, Inc. 03 11-0369 01 5/95 Decon. Service Sierro Pharmacy 16 11-0373-01 1/96 Nuclear Pharmacy Rad. Onc. Ctr. LV 03 12-0394-01 5/97 HDR Afterloader

12. Please identify any new or amended licenses added or removed from the list of licensees requiring emergency plans?

Response: No new and/or amended licenses were added/ removed from the list of licensees requiring emergency plans.

13. Discus.s any variances in licensing policies and procedures or exemptions from the regulations granted during the review period.

Eg199.nEg1 No variances in licensing policies and procedures or exemptions from the regulations granted during the review period.

14. What, if any, changes were made in your written licensing procedures (new procedures, updates, policy memoranda, etc.) during the reporting period?

Response: No changes were made in your written licensing procedures (new procedures, updates, policy memoranda, etc.) during the reporting period?

15. For NRC Regions, identify by licensee name, license number and type, any renewal applications that have been pending for one year or more.

Responsg1 Not Applicable.

Nevada Draft Report Page C.5 IV, Technical Quality of Insoections

16. What, if any, changes were made to your written inspection procedures during the reporting period?

Resoonse: No changes were made to your written inspection procedures during the reporting period?

17. Prepare a table showing the number and types of supervisory accompaniments made during the review period. Include:

Auditor Insoector License Cat. Raig Stan Marshall Larry Boschult Nuc. Med. 1/21/93 Port. Gauge 1/7/94 Port, Gauge 6/1/95 Work performance standards were revised for Larry Boschult to assign supervisory accompaniments and basic and LLW program management on 10/11/95; Larry became no longer subject to inspection accompaniments.

Larry Boschult Paul Harvey Port. Gauge 8/11/92 Larry Franks LLW 8/24/92 Nuc. Med. 9/15/92 Small Lab. 5/23/94 Nuc. Med 5/26/95 Ind. Rad. 8/22/96 Nuc. Med. 6/25/97 Larry Franks Jan Hillman-Ortiz Ind. Rad. 8/11/92 Nuc Pharm. 2/5/93 Port Gauge 6/13/94 Nuc. Med. 6/19/95 Bld. Irrad. 8/29/96 Nuc. Med 7/29/97 Larry Boschult Adrian Howe Port. Gauge 1/29/97 Stan Marshall Paul Simpson Service 2/5/93 Larry Boschult Nuc. Med. 2/1/94 Nuc. Med. 11/9/95 Nuc. Med. 4/17/97 Larry Boschult Morgan Tyler Port. Gauge 3/12/96 Port Gauge 7/10/97

18. Describe internal procedures for conducting supervisory accompaniments of inspectors in the field, if supervisory accompaniments were documented, please provide copies of the documentation for each accompaniment.

Resoonse: Supervisory accompaniments are conducted by program management or senior staff. Enclosed are copies of the accompaniment audit reports since the previous audit are on file in the agency.

Nevada Draft Report Page C,6

19. Describe or provide an update on your instrumentation and methods of calibration. Are allinstruments properly calibrated at the presant time?

Resoonse: We maintain at least a minimum of properly calibrated instruments at any given time to conduct inspections. The equipment is prepared for shipment by staff in the Carson City and Las Vegas offices periodically throughout the calendar year to ensure that equipment is available for 'nspections in accordance with agency policy and consistent with requirements for the inspected licensee.

New equioment acquired during the reporting period since the last review includes two portable MCA systems equipped with Nal detectors.

V. Resoonses to incidents and Alleaations

20. Please provide a list of the mgjit sianificant incidents (i.e., medical misadministration, overexposures, lost and abandoned sources, incidents requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less notification, etc.) that occurred in the Region / State during the review period. For Agreement States,information included in previous submittals to NRC need not be repeated. The list should be in the following form 6t:

Resoonse: See the attached incident log sheets for allincidents in this reporting period.

21. During this review period, did any ine dents occur that involved equipment or source failure or approved operating procedures that were deficient? If so, how and when were other State /NRC licensees who might be affected notified?

Resoonse: Reported incidents did not involve any equipment, source failure or deficient operating procedures determined to be generic or that would require notification to other state /NRC licensees.

22. For incidents involving failure of equipment or sources, was information on the incident provided to the agency responsible for evaluation of the device for an assessment of possible generic design deficiency? Please provide details for each case.

Response: Not applicable.

23. In the period covered by this review, were there any cases involving possible wrongdoing that were reviewed or are presently undergoing review? If so, please describe the circumstances for each case.

Resoonse: The incident log indicates no cases of possible wrongdoing during the review period.

24. Identify any changes to your procedures for handling allegations that occurred during the period of this review.

o Nevada Draft Report Page C.7

a. For Agreement States, please identify any allegations referred to your program by the NRC that have not been closed.

Besoonse All cases of allegations that have been referred to this office from the NRC have been closed.

VI. General

25. Please prepare a summary of the status of the State's or Region's actions taken in response to the comments and recommendations following the last review.

1 i Resoonse: Enclosed are status remarks concerning the 1993 NRC audit and 1994 NRC Followup audit recommendations:

1993 NRC Audit Recommendations

a. Recommendation that the state mako an effort to exceed the January 1994 aoal for adontion of all outstandino reaulations: Regulations pertaining to the Emergency Planning Rule, Standards for Protection Against Radiation, Safety Requirements for Radiographic Equipment, Notification of incidents, and the Quality Management Program and Misadministrations have been adopted by the Nevada State Board of Heaith,

b. Recommendation that increased manaaement oversiaht be orovided to the enforcement oroaram: The Bureau Chief is periodically informed of pending escalated enforcement actions such as management conferences, etc. on a weekly basis and is provided the opportunity to participate if he desires.

c. Recommendation that the state develoo and imolement written enforcement orocedures which soecific actions to be taken at various levels of severitv: Written enforcement procedures have been developed and are on file with other Radiological Health Section procedures.

d. Recommendation that the state consider various methods of escalated enforcement actions used by other states without civil oenattv: The state has expanded the variety of escalated enforcement options.

e. Recommendation that the state follow their own ooliev in reouirina bioassavs for all forms of I 131: Standardized license conditions are routinely issued at the time of licensure to require thyroid bioassays. All existing licenses were amended to require bioassays or revise other licensee procedures to do so.

f. Recommendation that written termination orocedures be revised to include the license termination reouirements in the Nevada reaulations: The written termination procedores have been so revised.

g. Recommendation that the state use a checklist or form to verify the final disoosition of all radioactive material: An existing license termination checklist war revised to include a section to document disposition of materials.

- Nevada Draft Report - Page C.8 hc Recommendation that certification of disoonal or transfer should' be reauired when recelots cannot be obtained from the new racioient:

Procedures have been revised to require the licensee to certify in writing the disposition of materials when transfer receipts are not available from the

- recipient.

~

l. Recommendation that the state resume the oractice of sendino cooles of new and amended licenses to the NRC: The agency received written notification that copies of licensing actions should no longer be sent to the NRC.

1994 NRC Followun Audit Recommendations J. Recommendation to revise existina escalated enforcement orocedures to include criteria for manaaement conferarices for multiola violations and to describe violation severity: Program management decided to maintain case-by case review to apply the need for management conferences based on inspector's recommendations and discussion with program management.

I. Recommendation to imorove instructions for evaluatina, followuo and reportina incidents tn NRC: also suaaests letters to hosoitals re: the misadministration reportina: The established process _of evaluation, followup and reporting incidents to the NRC was determined to be adequate.

Incidents continue to be reviewed as they occur to determine whether reporting to NRC is necessary. A letter was sent to all hospitals to emphasize the medical misadministration reporting requirement in NAC 459.257.

k. Recommendation for an imoroved incident trackino mechanism:

Computerized tracking of incidents was initiated in 1994; however, the initial

, effort did not prove to be adequate. Tracking reverted to handwiitten logging; recent installation of Windows version of NMED in 1997 indicates that the software works; however, its use is not fully implemented.

26. Provide a brief description of your program's strengths and weaknesses.

These strengths and weaknesses should be supported by examples of successes, problems or difficulties which occurred during this review period.

Response: Strenoth: Comorebensive radiation control authority and orooram

, implementation - Nevada law and regulations remain comprehensive.to ensure radiation control regulatory and non regulatory service activities are in one state agency. This approach to program implementation h.as capitalized 4

on economies of acale to utilize skilled, experienced staff and other. resources in multiple program areas. >

As new radiation issues mature in the public interest, the agency has added

- appropriate regulatory / service programs as appropriate. Three examples

, since the last NRC audit include development of a program for oversight of DOE radiological activities on and around the Nevada Test Site, regulation adoption and program implementation of a state-mandated mammography X-ray certification including a service contract to conduct inspections for

. federal certification purposc::, end potential radon hazard awareness among all Nevada counties.

Nevada Draft Report Page C.9 Weakness: Automatic Loss of Industrv Growth Fee Revenue -Industry growth fee revenue above legislature authorized spending authority is deposited into the general fund. Industry growth fee revenue beyond spending authority is not available to the program without legislature interim finance committee approval or legislative approval during session. Any across-the board fee increases or acquisition of other fundir.g without associated spending authority frorn state legislature can not be ut.cd to increase equipment, staff or other resources for the radioactive material program unless legislative acthority is approved and in place in advance of acquiring / receiving the revenue.

B. NON COMMON PERFORMANCE INDICATORS

- 1. Reaulations and Leaal Authority

27. Please list all currently effective legislation that affects the radiation control program (RCP).

Resoonse: Nevada Revised Statute (NRS) 459 - radiation control NRS 457 mammography certification NHS 439 - administrative procedures ,

NRS 414 - emergency response

28. Are your regulations subject to a " Sunset" or equivalent law? If so, explain and include the next expiration date for your regulations.

Besoonse: No.

29. Please complete the enclosed table based on NRC chronology of amendments, identify those that have not been adopted by the State, explain why they were not adopted, and discuss any actions being taken to adopt them.

Resoonse: It is not necessary to adopt rules pertaining to pool irradiators and uranium mill tailings at this time as no licenses in these categories are currently used by the Nevada Health Division. Steps will be taken to initiate public hearings and regulation adoption upon contact by a possible applicant or receipt of application in these license categories.

Rules not adopted by the state pertaining to decommissioning are incorporated into one applicable license by license condition. Adoption of the requirements will be initiated at the roxt occasion to revise state regulations.

30. If you have not adopted all amendments within three years from the date of NRC rule promulgation, briefly describe your State's procedures for amending regulations in order to maintain compatibility with the NRC, showing the -

normallength of time anticipated to complete each step.

Resoonse: The process for regulation adoption requires a minimum of six (6) months during specific times of the two-year biennium, otherwise, adopted regulations are considered to be temporary ard must be revisited for adoption by the Nevada State Board of Health or they will expire.

Nevada Draft Report Page C.10 The adoption process involves development of proposed text, distribution to the affected public and public notice locations in the state, public workshops where determined necessary by staff or agency management, written response to all written comments, due process notice of the Board of Health adoption hearing, staff presentation at the announced Board of Health meeting at which time the Governor-appointed, seven-member board will adopt with or without revisions to staff recommendations, or table or veto the regulations, ll. Sealed Source and Device Proarsm

31. Prepare a table listing new and revised SS&D registrations of sealed sources and devices issued during the review period. The table heading should bo:

Resoonse: No sealed source manufacturers are located in the state of Nevada, therefore, no SS&D registrations have been issued. We no not intend to develop capability for this activity at this timo but also do not intend to relinquish authority for the activity either, A memorandum to file has been developed to indicate that the agency will develop procedures and regulations as necessary in the event an application for sealed source manufacturing is delivered to the office.

32. What guides, standards and procedures are used to evaluate registry applications?

Response: Not applicable at this time; see 11.31 response.

33. Please include information on the following questions in Section A, as they apply to the Sealed Source and Device Program:

Technical Staffina and Trainina - A.II.7 Not applicable Technical Qur"ity of Licensina Actions - A lli.11. A.Ill.13 Not applicable Resoonses to incidents and Allocations - A.V.20 Not applicable Ill. Low leve! Waste Procram

34. Please include information on the following questions in Section A, as they apply to tne Low-level Waste Program:

A. Status of Materials insoection Proaram - A.I.1-3, A.I.6 - No material inspection program element exists due to site closure, inspections at the closed Beatty low-level radioactive waste facility occur periodically as appropriate relative to completion of remaining post-closure activities.

Since the low-level waste site was closed; inspections are limited to review of custodial post-closure activities such as verifying integrity of trench caps, inspection of the perimeter fence, review of post-closure records, etc.

Nevada Draft Report Page C.11 B. Technical Staffino ano Trainina - A.ll.710 Program staff and associated training is status quo with existing staff continuing .

evaluation of the last post closure activities. Las Vegas Radiological Health Section senior staff continue to perform review / inspections as necessary; Carson City senior staff continues with program administrative activities, etc.

C. Technical Quality of Licensina Actions A.lll.11. A.lli.1314 -

Licensing actions have been minimal since site closure on December 31,1992 with anticipation that a license transfer amendment may be issued in the near future after completion of post closure activities by the licensee and acceptance of technicalinformation and activity status by the agency.

D. Technical Quality of insoections A.IV.1619 Site inspections continue as appropriate concerning the final post closure activities not completed by the licensee, inspection and review activities have continued at a less aggressive rate than during waste disposal while the site was open in accordance with diminishing post closure activities.

As a result, low level waste site inspection policy and inspection forms are under review to implement appropriate modification to reflect site closure elements that are yet to be completed before and af ter license transfer.

E. Resoonses to incidents and Alleontions - A.V.20 2.1 No allegations hJve been filed with this office and no incidents occurred during the review period.

IV. Utanium Mill Prouram

35. Please include information on the following questions in Section A, as they apply to the Uranium Mill Program:

, Status of Materials inspection Prooram A.I.13. A.I.0 Not applicable Technical Staffino ar}d Trainina A.ll.710 Not applicable Technical Quality of Licensina Actions A.lli.11. A.Ill.1314 Not applicable Technical Quality of Inspections A.IV.1619 Not applicabki Resootags to incidents and Alleantions A.V.20 23 - Not applicable

. _ _ _ _ _ _ _ _ _ . . .. . - . , - - . _ . . - . . - _ - . . . - - - . = - _ _ _ . .. . - . - - . . - . , u - .

J-l- . .

' Nevada Draft Report Page 12 j TABLE FOR QUESTION 29.

i i

i t'

i g ,

DATE DATE 10 CFR RULE DUE ADOPTED STM N

(

Any amendment due prior to 1991. Identify  !

each regidsbon Defer to the Chronology of ,

{, Amendments) f' C+_ _ . - . - _ _ 7/27/91 6/11/93' Parts 30,40,70 i

. - .,., Plannmg: 4/7/93 6/11/93 [

} Parts 30,40,70 l

Standards for Protection Agenst Redebon

1/1/94 12/8/93 i Part 20 f Safety Regurements for Radiographic 1/10/94 12/8/93 j Esopment: Part 34 t

j Notdicamon of incedents: 10/15/94 1/18/94 j

! Parts 20, 30, 31, 34, 39, 40, 70  ;

I Oushty Management Program and 1/27/95 7/7/9d.

Mesadmmestrapons: Part 35

, Licenoeg and Rediscon Sofety Reguwements 7/1/96 N/A: no irradetors Econeed in Newedo. Regarements wiE he appned l for Irradiators: Port 36 ' by Ec. condson until they are adopted 'hy the 9d. of Heefeh.

4 1

, Defirwhen of Land Desposef 7/22/96 N!A: no intent to Econee futuse LLW sites.

i- and Waste Site OA Program, Part 61 Decomnweesorong Recordlieepmg: Cacu-- 10/25/96 Not adopted yet; addressed by liconee consten for one Econes. 3/1/98 mentation Adetsons: Parts 30,40,70 4

i Self-Guerantee as an Addeonel Financial 1/28/97 Not adopted yet; addressed by Econee condesen for one Econse. 3/1/98 Mechenem: Parts 30,40,70 f

Uranium Mill Tadings: Confonneng to EPA 7/1/97 N/A: no uransurn mis tailings Econeses in Nevado.

Standards: Part 40 Timeliness in D -. - - - , 8/15/97 Not adopted yet; addressed by Econee condten for one license. 3/1/98 i Parts 30,40,70

Nevada Draft Report Page 13 ,

OR [

DATF DATE e

10 CFR RULE DUE ADOPTED -

STATUS ADOPTION j Properation, Transfer for Commercsol Dis- 1H/98 . Not adopted yet; wiB be addressed by Econee condeen as necessary. 3/1/98

• treubon, and use of everoduct Mosenes for Me6 col Use: Ports 30,32,35 l

Frogmency of M=ded Emanunetsons for Use 3/13198 3/1/98- [

of 7 .yp Protection Eempment [

i Low-tavel Wast = S>nyment Mendast 3n/98 Plan for % prior to due date. Leur W weses eine essed by 3/1/98 I snsormenori and r L,i Newsde Econeses abeedy regeres NRC mondest. f i

Performance Ibeparemones for Rodography 6/30/98 Plan for adopton prior to due dese.  !

Emmpment  !

Radietson 74s",,w. 7_ . . e. 8/14/98 Piers for adophon prior to due date. I

_ Amended Definitions and Cntone I 7

i Cbinc.i,Gw. of C . . - _ , Funding 11/24/98 Plan for adophon prior to due does. l Z- .Le.

10 CFR Part "1: C . ,_ * ~^i with the

-_ . 4M199 Plan for adopton prior to due date. f Intemational Atomic Energy Agency

[

Modcol Admwootraton of Radston and 10/20/98 Plan for adophon prior to due dMe.

Rodoectswe Motorisie  !

i L

Terrrunston or Transfer of Licensed 5n 6/99 Plan for adopton prior to due date.

Actevotees: Recordheepmg Regurements. }

Resoluton of Duel T ;f:^2-- . of Airbome 1/9mO Plan for adopean prior to due date.

Effluents of Radioactswe Metenels: Cloen Air  !

Act Recognetson of Agreement r, tete beenees in 1113/00 Plan for adopean prior to due doce. l Arees brSw Exclueeve Federal Juno 6cton  !

Wittun Agreeme st State l

t Cntene for the Release of Indviduals 1/29/00 Plan for adophon prior to due date.

l Admwustered Reeoective Metenet l t

_____J

APPENDIX D LICENSE FILE REVIEWS File No.: 1 Licensee: Diversified Consulting Services License No.: 00 11 0344 01 Location: Carson City, NV Amendment No.: 1 License Type: Portable Gauges Type of Action: New/ Amendment Date New License issued: 6/26/94 License Reviewer: LB Date Amendment issued: 7/6/94 License Reviewer: MT File No.: 2 Licensee: Resource Concepts, Inc. License No.: 00 11 0343 01 Location: Carson City, NV License Type: Portable Gauge Type of Action: New Date issued: 6/3/94 License Reviewer: LB File No.: 3 Licensee: Century Geophysical Corp. License No.: 00 11 0354 01 Location: Las Vegas, NV License Type: Well Logging Type of Action: New Date Issued: 12/6/94 License Reviewer: PH File No.: 4 Licensee: Kleinfelder, Inc. License No.: 00 11 0278 01 Location: Las Vegas, NV Amendment No.: 8 License Type: Industri:1 Radiography Type of Action: Renewal Date Renewalissued: 9/26/95 License Reviewer: PH File No.: 5 Licensee: Fluid Tech, Inc. License No.: 00 11 0339 01 Location: Las Vegas, NV Amendment No.: 4 and 5 License Type: Decontamination Service Type of Action: Amendment Date Amendment issued: 4/3/95;5/30/95 License Reviewer: PH File No.: 6 ,-

Licensee: Sierra Pharmacy Services License No.: 16 11 0373 01 Location: Reno,NV License Type: Nuclear Pharmacy Type of Action: New Date issued: 1/29/96 License Reviewer: LB Comment:

a) License hand delivered to licensee File No.: 7 Licensee: HSI GeoTrans License No.: 00 11-0397 01 Location: Reno,NV License Type: Portable Gauge Type of Action: New Date issued: 5/28/97 License Reviewer: AH

- ~ , , , , . - . . - - - . - . , . - _ . . . , _ , , . , , - ~ , . . . ~ , . ,,m.. - ,

Nevada Draft Report Page D.2 License File Reviews File No.: 8 Licensee: MET ChemTesting Laboratories License No.: 00 11 0335 01 Location: Salt Lake City, UT Amendment No.: 2 License Type: Industrial Radiographer Type of Action: Tsimination Date Terminated: 5/23/94 License Reviewer: LB Com:nents:

a) Radioactive material transferred to licensee's UT License (UT 1800146)

File No.: 9 Licensee: J. Daniel Wilkes, M.D., LMC Laboratory License No.: 03 12 0006 01 Location: Las Vegas, NV Amendment No.: 7 License Type: Bio Med In Vitro Testing Type of Action: Termination Date Terminated: 7/29/94 License Reviewer: JHO  ;

File No.: 10 Licensee: Aerojet General Corporation License No.: 13 11 0195 01 Location: Sacramento, CA and Range 63, Nellis AFB Amendment No.: 4 License Type: Ordnance Testing Type of Action: Termination Date Terminated: 2/21/97 -

License Reviewer: LB File No.: 11 Licensee: BC Environmental License No.: 00 11 0374 01 Location: Reno, NV Amendment No.: 2 License Type: Portable Gauge Type of Action: Termination Date Terminated: 3/31/97 License Reviewer: LB File No.: 12 Licensee: Radiation Oncology Center of Las Vegas License No.: 03 12 0394 01 Location: Las Vegas, NV License Type: High Dose Afterloader Type of Action: New Date issued: 5/12/97 License Reviewer: PH Comment:

a) Hand delivered File No.: 13 Licensee: Lockheed Environmental Systems License No.: 00 16-0112 01

& Technologies, Inc.

Location: Las Vegas, NV Amendment No.: 19 License Type: Laboratory & Decontamination Service Type of Action: Renewal Date Renewalissued: 5/16/96 License Reviewer: PH File No.: 14 Licensee: Rayrock Mines, Inc. License No.: 00 11 0386-01 Location: Valmy, NV License Type: Portable Gauge Type of Action: New Date issued: 9/23/96 License Reviewer: PS

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O Nevada Draft' Report Page D.3 License File Reviews ,

File No.: 15 l Licensee: Las Vegas Valley Water District License No.: 00 11 0196 01 l Location: Las Vegas, NV License Type: Portable Gauge Type of Action: Renewal  !

Date RenewalIssued: 4/19/96 License Reviewer: JHO File No.: 16 Licensee: University of Nevada, Reno License No.: 16 13 0003 07  ;

Location: Reno, NV Amendment No.: 19 i License Type: Broad Scope Type B Type of Action: Major Amendment Date Amendment issued: 9/3/96 License Reviewer: LB File No.: 17 Licensee: US Ecology, Inc. License No.: 1 13 0043 02

- Location: Oak Ridge, TN (Beatty, NV, site) Arnendment No.: 16 License Type: LLRW Burial Site Type of Action: Amendment Date Amendment issued:- 10/2/96 License Reviewer: LB Comment:

a) This amendment changes the licensee's home address and re ties them to the original application, f acility standards manual, site closure plan, and lease agreement with Nevada.

File No.: 18  :

Licensee: Sunrise Hospital Laboratory License No.: 03 12 0325 02 i Location: Las Vegas, NV >

License Type: Irradiator (< 10,000 Ci) Type of Action: New Date lasued: 2/9/96 License Reviewer: PH File No.: 19 Licensee: Biotech Pharmacy License No.: 03 11 0352 01 Location: Las Vegas, NV Amendment No.: 4 License Type: Nuclear Pharmacy Type of Action: Amendment Date Amendment issued: 5/10/95 License Reviewer: PH i File No.: 20 Licensee: Leon H. Steinberg, M.D. License No.: 0312 r.- '01 Location: Las Vegas, NV Amendmer.' ..: 3 License Type Medical Private Practice Type of Action: Terr ...iation Date Terminated: 6/17/97 License Reviewer: PH ,

Comment:

a) Terminated as part of a licensing action to overcome problems with licensee. New, more restrictive license issued (see file 21).

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Nevada Draft Report Page D 4 License File Reviews i

File ho.: 21 Licensee: Steinberg Diagnostic MedicalImaging Center Location: Las Vegas, NV License No.: 03 12 0352 01 License Type: Nuclear Medicine Clinic Type of Action: New Date issued: 6/17/97 License Reviewer: PH Comments:

a) See comment for file 20, b) New license requires licensee to follow RG 10.8; requirements include quality i management plan program, bloassay by license condition, radiation safety ,

committee for clinic with quarterly meetings, and new radiation safety officer.

File No.: 22 Licensee: Carson Tahoe Hospital License No.: 01 12 0032 01 Location: Carson City, NV Amendment No.: 20 License Type: Medical Institution with therapy -

Type of Action: Henewal Date Renewal Issued: 9/26/95 License Reviewer:

File No.: 23 Licensee: Syncor International Corporation License No.: 16 11 0333 01 Location: Reno,NV Amendment No.: 2 3

License Type: Nuclear Pharmacy Type of Action: New Date issued: 8/17/93 License Reviewer: PH Comments:

a) License hand carried to licensee b) Prelicensing inspection conducted and documented.

File No.: 24 Licensee: Radiation Oncology Associates License No.: 16 12 0323 Location: Reno, NV License Type: Teletherapy Type of Action: Major amendment Date issued: 8/27/97 License Reviewer: LB

- ....-. ~ . .- . - - _ ..- - =_ - - - . . - - - . - - - - - _ - . - - _ - - . .

APPENDIX E INSPECTION FILE REVIEWS File No.: 1 Licensee: US Ecology License No.: 13 11 0043 02 Location: Beatty, NV Inspection Type: Announced, Routine License Type: LLRW burial site Priority: 1 Inspection Date: 8/30/95 Inspector: PH File No.: 2 Licenses: US Ecology ' License No.: 13 11 0043 02 Location: Beatty, NV inspection Type: Announced, Routine License Type: LLRW burial site Priority: 1 Inspection Date: 3/12/97 Inspector: LF File No.: 3 Licensee:_ Resource Concepts, Inc. License No.: 00 11 0343 01 Location: Carson City, NV inspection Type: Unannounced, Routine License Type: Portable Gauge Priority: 3 Inspection Date: 8/13/97 Inspector: MT Comments:

a) Report reviewed at time of accompaniment; enforcement correspondence not ready

- for review, b) Inspection form did not have section for reviewing incidents that may have occurred since last inspection. Upon suggestion by review team, RHS Supervisor added item through memo dated 8/26/97.

File No.: 4 Licensee: Consulting Engineering Services L' cense No.: 00 11 0154 01 Location: Reno, NV inspection Type: Unannounced, Routine License Type: Portable Gauge Priority: 4 Inspection Date: 8/18/97 Inspector: AH Comment:

a) Report reviewed at time of accompaniment; enforcement correspondence not ready for review.

File No.: 5 Licensee: Desert Industrial X Ray, Inc. License No.: 00 11 0360 01 Location: Henderson, NV inspection Type: Unannounced, routine License Type: Industrial Radiography Priority: 1 Inspection Date: 8/21/96 Inspector: PH File No.: 6 Licensee: Desert Radiologists Eastern License No.: 03 12-0327 01 Location: Las Vegas, NV inspection Type: Unannounced, routine License Type: Nuclear Medicine Priority: 2 Inspection Date: 12;12/95 Inspector: PH s

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Nevada Draft Report Page E.2 inspection File Reviews File No.: 7 Licensee: Radiation Oncology Associates License No.: 16 12 0323 01 Location: Reno, NV inspection Type: Unannounced, routine License Type: Teletherapy Priority: 1 Inspection Date: 9/20/90;10/17/06 Inspector: LB Comments:

a) Teletherapy license inspected at 3 year interval althreugh State calls it Priority 1 (NRC changed to Priority 3).

b) Inspection conducted on two dates to complete review of recordt,in main office.

File No.: 8 Licensee: Radiation Oncology Associates License No.: 01 12 0225 01 Location: Carson City, NV inspe: tion Type: Unannounced, routine License Type: Teletherapy Priority: 1 Inspection Date: 9/20/96;10/17/96 Inspector: LB Comments:

a) Teletherapy license inspector' at 1 year interval, b) Inspection completed on No dates to complete review of records in main offit s.

File No.: 9 Licensee: Carson Tahoe Hospital License No.: 01 12 0032 01 Location: Carson City, NV inspection Type: Unannounced, routine License Type: Nuclear Medicine Priority: 2 Inspection Date: 0/17/97 Inspector: PS & MT Comments:

a) Licensee notification letter sent 8/11/97 over 30 days after inspection.

b) Previous inspection 2/94; inspection ovordue by NV inspection schedule; but not by NRC IMC 2000.

File No.: 10 Licensee: Biotech Pharmacy License No.: 03 11 0332 01 Location: Las Vegas, NV Inspection Type: Unannounced; routine License Type: Nuclear Pharmacy Priority: 1 Inspection Date: 9/17/96 Inspector: PH Comment:

a) Six serious violations and four itoris of concern did not trigger follow up inspection.

Nevada Draft Report Page E.3 Inspection File Reviews File No.: 11 & 12 '

Licensee: Kleinfelder, Inc. License No.: 00 11 0278 01 Location: Las Vegas, NV Inspection Type: Unannounced, office only, routine License Type: Industrial Radiographer Priority: 1 Inspection Date: 12/21/95 and 2/26/97 Inspactor: PH Comments:

a) Five violations including one repeat found during 12/95 inspection resulted in enforcement conference on 1/22/96.

b) Although 12/95 office inspec.tlon showed radiography work was conducted by one radiographer in violation of State's two person rule, Statv did not conduct field inspection during 2/97 inspection.

File No.: 13 & 14 Lir ensee: University of Nevada, Reno License No.: 16 13 0003 07 Location: Reno, NV inspection Type: See below License Type: Academic Type B Priority: 2 Inspection Date: 5/18/93 (partial); 11/2/93 (partial) Inspector: LB Inspection Date: 3/28/94 (partial); 4/1/94 (partial); 8/15,18/94 (partial); 12/19/94 memo to file summarized findings during '93 and '94 partialinspections inspection Date: 1/24 27/95 (partial); 3/9/95 memo to file summarized findings during 1/95 partial inspections inspection Date: 2/11/97 follow up Comments:

a) There had not been a complete inspection of this licensee since September 1991.

Following an incident on 2/93 where RAM was released to normal trash, there were a series of partialinspections in which problems were noted with inventory, overall control of radiation, and RSO user authorizations, b) No documentation in file that University was advised in writing of violation 6 until NOV sent 6/14/95 five months after 1/95 inspections, c) State advises complete inspection conducted on date but report not available to review team.

File No.: 15 Licensee: University of Nevada, Las Vegas, NV License No.: 03 13 0305 01 Location: Las Vegas, NV inspection Type: Unannounced, complete, routine License Type: Academic Type B Priority: 2 Inspection Date: 11/25 27/96 Inspector: PH File No.: 16 Licensee: AGRA Earth and Environmental License No.: 00 11 0193 01 Location: Sparks, NV inspection Type: Announced, routine License Type: Industrial Radiographer Priority: 1 Inspection Date: 5/7/97 Inspector: LB Comments:

a) Thirty two months between radiography licensee inspections, b) Unable to determine from file whether field inspection was conducted, c) Licensee not advised of results of clear inspection in writing (no short form).

-,,,,...---m..-. - , - - c - . ,- -

I Nevada Draft Report Page E.4 Insper tion File Reviews File No.: 17 Licensee: AGRA Earth and Environmental License No.: 00 11 0193 02 -

Location: Sparks, NV Inspection Type: Announced, routine License Type: Portable Gauge Priority: 3 Inspection Date: 7/10/97 Inspector: MT File No.: 18 Licensee: Tetracon Consultantt Western, Inc. License No.: 00 11 0326 01

. Location: Las Vegas, NV inspection Type: Unannounced, field, routine License Type: Portable Gauce Priority: 3 Inspection Date: 9/11/96 Inspector: PH ,

File No.: 19 Licensee: Bouldu City Hospital License No.: 03 12 0342 01 Location: Duulder Cit, NV Inspection Type: Unannounced, routine License Type: Nuclear Medicine Priority: 2 Inspection Date: 4/8/97 Inspector: PH File No.: 20 Licenses: Lockheed Environmental Systems License No.: 00 16 0112 03 Location: Las Vegas, NV Inspection Type: Announced, initini License Type: Fixed Gauge Priority: 3 Inspection Date: 8/9/95 Inspector: PH File No.: 21 Licensee: Covan Pacific Coast Testing License No.: 4886 48 Location: Sparks, NV (8enicia, CA) Inspection Type: Reciprocity, field License Type: Industrial Radiography Priority: 1 Inspection Date: 1/24/96 Inspector: L8 File No.: 22 Licensee: Decisive Testing License No.: 1836 80 Location: Las Vegas, NV (San Delgo, CA) Inspection Type: Reciprocity, field License Type: Ir.dustrial Radiography Prionty: 1 Inspection Date: 6/8/96 Inspector: PH File No.: 23 Licensee: Phoenix National Labs License No.: AZ7 415 Location: Las Vegas, NV (Tempe, AZ) inspection Type: Reciprocity, field License Type: Industrial Radiographer Priority: 1 Inspection Date: 1/18/97 Inspector: PH Comment:

a) No violations, no written notice to licensee, t

1

g Nevada Draft Report Page E.5 i inspection File Reviews  !

, File No.1 24 i Licensee: Continental Testing and Inspection License No.: 2635 70 Location: Les Vegas, NV (Signal Hill, CAbspection Type: Unannounced reciprocity, office i License Type: Industilal Radiography Priority: 1 Inspection Date: 8/8/96 Inspector: PH Comments:

a) Inspector visited the Las Vegas business office of this CA licensee after being i notified a radiography source would be transferred into State for use between  !

8/3/96 and 8/10/96. Company advised inspector that source had not been transferred to NV despite notification.

File No.: 25 Licensee: SGS Industrial Services License No.: 341 60 Location: Las Vegas, NV Inspection Type: Unannounced, reciprocity, office

- (San Leandro, CA)

License Type: Industrial Radiography Priority: 1 Inspection Date: 3/14/96 Inspector: PH i

File No.: 26 Licensee: Converse Consultants Southwest, Inc. License No.: 00 11 0094 01 Location: Las Vegas, NV Inspection Type: Unannounced, followup License Type: Portable Gauge Priority: 3 Inspection Date: 8/8/94 Inspector: JH

! In addition, a review team member made the following inspection accompaniments as part of the on site IMPEP review:

Accompaniment No.: 1 Licensse: Resource Concepts, Inc. License No : 00 11 0343 01 Location: Carson City, NV inspection Type: Unannounced, Routine License Type: Portable Gauge Priority: 3 Inspection Date: 8/13/97 Inspector: MT Comments: ,

a) Inspector did not tie items of non compilance to license conditions or regulations b) Inspector did not question licensee regarding incidents; inspection form had no ,

incident review section .

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Accompaniment No.: 2

- Licenses: Consulting Engineering Services License No.: 00 11 0164 01 Location: Reno, NV Inspection Type: Unannounced, Routine License Type: Portable Gauge Priority: 4 Insoection Date: 8/18/97 Inspector: AH t-

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9 APPENDIX F t INCIDENT FILES REVIEWED File No. 1 Licensee: Converse Consultants Southwest, Inc t License No.: 00 11 0094-01  ;

incident ID No: NV.93 06 Location: Las Vegas, NV Date of Event: 4/26/93 Type of Event. LAS >

Investigation Date: 4/26/93 investigation Type: Field Summary of incident and Final Disposition: Portable gauge lost or stolen / recovered.

File No.: 2 Licensee: United Mining of Nevada License No.: Generallicensee incident ID No: NV 93-09 Location: Houston 011 and Mineral Mine, Virginia City Date of Event: 5/31/93 Type of Event: LAS Investigation Date: 6/)1/93 investigation Type: Field Summary of incident and Final Disposition: Fixed gauge found at abandoned mine site /

Impounded.

Comment: '

a) Not reported to NMED.

File No.: 3 Licensee: Dawn Mining Company License No.: (Unknown NRC) incident ID No: NV 94 05 Location: Elko, NV Date of Event: 1965 1975 Type of Event: Release of Materials Investigation Date: 2/09/94 investigation Type: Field Summary of incident and Final Disposition: NRC requested survey of possible residual uranium contemlnation at storage site of terminated licensee (ORNL).

Comment:

a) Results reported to Region V but not reported to NMED.

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Nevada Draft Report Page F.2 incident File Reviews File No.: 4 Licensee: Golden Nugget License No.: General licensee incident ID No: NV 94 09 Location: Las Vegas, NV Date of Event: 6/02/94 Type of Event: LAS Investigation Date: 6/21/94 Investigation Type: Telephone Summary of incident and Final Disposition: Reported loss of two Po 210 (5.0 millicurie each) anti static devices.

Comments:

a) No action taken by RHS reason given: material had decayed to exempt level, b) Not reported to NMED.

File No.: 6 Licensee: Converse Comultants Soinhwest, Inc License No. 00 11 0094 41 incident ID No: NV 9410 Location: Les Vegas, NV Date of Event: 9/14/94 Type of Event: TRS Investigaticn Date: 9/14/IH Investigation Type: Field Summary ot !r.cident and Final Disposition: Portable gauge reported lost or stolen; recovered same day Comments:

a) Reported to NMED; evsnt date, other information in NMED incorrect.

File No.: 6 Licensee: Westec, Inc License No.: 00 11-0197 01 incident ID No: NV 9412 Location: Newmont Mine; near Carlin, NV Date of Event: 8/25/94 Type of Event: EQP Investigation Date: 8/26/94 investigation Type: Telephone Summary of Incident and Final Disposition: Portable gauge run over by heavy equipment at job site; destroyed; no leakage detected .

Comment:

a) NMED item informt.dsn incorrect: wrong event date, s/n: 10583.

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3 Nevada Draft Report Page F.3 incident File Revirws File No.: 7  ;

Licensee: Summit Engineering Corp License No.: 00 11 0180-01 Incident ID No: NV 95 01 Location: Reno, NV Date of Event: 2/09/95 Type of Event: LAS Investi9ation Date: 2/09/95 Investigation Type: Field Surnmary of Incident and Final Disposition: Theft of three portable gauges during burg lary; two devices recovered on 2/10/95, third on 2/12/95, all three were undamaged.

Comment:

a) Reported on NMED but information not complete.

File No.: 8  ;

Licensee: SEA, Inc t License No.: 00 11 0000 01 Incident ID No: NV 95 05 ,

Location: Las Vegas, NV Date of Fvent: 4/21/95 Type of Event: LAS Investigation Date: 4/21/05 Investigation Type: Field Summary of incident and Finst Disposition: Portable gauge lost or stolen, not recovered; licensee cited for failure to adequately secure the dev!;;e.

Comment:

a) Not reported to NMED. '

b) State procedures do not require a press release.

File No.: 9 Licensee: Southwest Testing ,

License No.: 00 11 0366-01 -

Incident ID No: NV 9610; NV 97 07 -

Location: Las Vegas, NV Date of Event: 5/29/96 Type of Event: LAS Investigation Date: 5/30 31/96 Investigation Type: Telephone Summary of incident and Final Disposition: Licensee cited for inadequate control over RAM; gauge recovered 7/14/97 (NV 97 07).

Comment:

a) Not reported on NMED.

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i Nevada Draft Report Page F.4 incident File Reviews i

2 File No.: 10 l Licensee: Leslie W. Williams, DVM i License No.: 03 12 0155 01  ;

i incident ID No NV 9611 Location: Les Vegas, NV Date of Event: 8/22/96 Type of Event: Abandoned source  ;

investigation Date: 8/22/96 Investigation Type: Field Summary of incident and Final Disposition: Licensee left State in 1994, reportedly for  ;

Missouri, left behind Sr 90 eye applicator at LV clinic (unlicensed); device was impounded  !

by RCP.  ;

Comments a) Not on NMED.

! b) Not reported to NRC (in case license sought in MO). ,

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