ML22038A305

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01-26-2022 e-mail from C Steward Re Arkansas Response to Impep Questionnaire
ML22038A305
Person / Time
Issue date: 01/26/2022
From: Stephen Poy, Steward C
NRC/NMSS/DMSST/ASPB, State of AL, Dept of Public Health
To: Steward C
State of AR, Dept of Health
Poy S
References
Download: ML22038A305 (42)
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Text

Radiation Control Section IMPEP Questionnaire 2022

Approved by OMB1 Control No.: 3150-0183 Expires: 02/28/2023 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE Reporting Period:

Note: If there has been no change in the response to a specific question since the last IMPEP questionnaire, the State or Region may copy the previous answer, if appropriate.

A. GENERAL

1. Please prepare a summary of the status of the State's or Region's actions taken in response to each of the open recommendations from previous IMPEP reviews.
1. Section 3. 1 Technical Quali~)I o_/Licensing Actions "The lean , reco mmends that Arkansas continue to pe1fo n11 and update its quarterly Quality Improvement a udits to ensure that licensing actions are thorough, consistent, and adhere to Arkansas's licensing procedures.for the use o/standarc/ license condit ions. standard authori::.ed use conditions. standard authorized medical user materials a11thori::.atio11; and to ensure that staff is appropriatelv implementing the RSRM checklist. especially in cases where the request is to remove or decrease RSR M" Quarte rl y Audi ts (20 18 throu gh present) were perfo rm ed to revi ew licensing act ions fo llow ing thi s recomm endati on. A ll iss ues di scove red th ro ughout the audit process were ac kn ow ledged and corrected .

Audits ensured th at lice nsing ac ti ons, standard li cense condi tions, stand ard auth ori zed use condi tions, standa rd auth ori zed medi ca l user materi als authori zati on we re thorough, co nsistent, and adh ere to Arka nsas' licensing procedures .

8. COMMON PERFORMANCE INDICATORS I. Technical Staffing and Training
2. Please provide the following organization charts, including names and positions:

(a) A chart showing positions from the Governor down to the Radiation Control Program Director SEE ATTACHED ITEM 2A (b) A chart showing positions of the radiation control program, including management; and SEE ATTACHED ITEM 2B (c) Equivalent charts for sealed source and device evaluation, low-level radioactive waste and uranium recovery programs, if applicable.

This is not applicabl e.

3. Please provide a staffing plan, or complete a listing using the suggested format below, of the professional (technical) full-time equivalents (FTE) applied to the radioactive materials program by individual. Include the name, position, and, for Agreement States, the fraction of time spent in the following areas: administration, materials licensing &

compliance, emergency response, low-level radioactive waste, uranium recovery, other.

If these regulatory responsibilities are divided between offices, the table should be consolidated to include all personnel contributing to the radioactive materials program.

If consultants were used to carry out the program's radioactive materials responsibilities,

include their efforts. The table heading should be: Name Position Area of Effort FTE%

SEE ATTACHE D ITE M( S) 3; 4; 7; 8; 9

4. Please provide a listing of all new professional personnel hired into your radioactive materials program since the last review, indicate the date of hire; the degree(s) they received, if applicable; additional training; and years of experience in health physics or other disciplines, as appropriate.

SEE ATTACHED ITE M(S) 3; 4; 7; 8; 9

5. Please list all professional staff who have not yet met the qualification requirements for a radioactive materials license reviewer or inspector. For each, list the courses or equivalent training/experience they need and a tentative schedule for completion of these requirements.

SEE ATTACH ED ITE M 5

6. Identify any changes to your qualification and training procedure that occurred during the review period.

There are no changes to the program 's qua Ii fication and tra ining procedure .

7. Please identify the technical staff that left your radioactive materials program during the review period and indicate the date they left.

SEE ATTACH ED ITE M(S) 3; 4; 7; 8; 9

8. List any vacant positions in your radioactive materials program, the length of time each position has been vacant, and a brief summary of efforts to fill the vacancy.

SEE ATTAC HED ITEM(S ) 3; 4; 7; 8; 9

9. For Agreement States, does your program have an oversight board or committee which provides direction to the program and is composed of licensees and/or members of the public? If so, please describe the procedures used to avoid any potential conflict of interest.

SEE ATTACHE D ITEM(S) 3; 4; 7; 8; 9 II. Status of Materials Inspection Program

10. Please identify individual licensees or categories of licensees the State is inspecting less frequently than called for in NRC's Inspection Manual Chapter (IMC) 2800 and explain the reason for the difference. The list only needs to include the following information:

license category or licensee name and license number, your inspection interval, and rationale for the difference.

There are no li censees or categori es of li censees in spected less freq uent ly than IMC 2800.

11. Please provide the number of routine inspections of Priority 1, 2, and 3 licensees, as defined in IMC 2800 and the number of initial inspections that were completed during each year of the review period.

Priority 12/2()1 7 2018 2019 2020 2()21 I 1 8 9 9 Il lI 7 7 6 5 Ill I ' 18 4 12 17 Totals 2 .) .) 20 27 .) .)

Initia ls .) .) 9 .)

12. Please submit a table, or a computer printout, that identifies inspections of Priority 1, 2, and 3 licensees and initial inspections that were conducted overdue.

At a minimum, the list should include the following information for each inspection that was conducted overdue during the review period:

(1) Licensee Name (2) License Number (3) Priority (IMC 2800)

(4) Last inspection date or license issuance date, if initial inspection (5) Date Due (6) Date Performed (7) Amount of Time Overdue (8) Date inspection findings issued Tbere was one overdue:

Desert NDT dba Sha wcor ARK- IO l 0-033 l O l Last ln sp 09/14/20 18, Due 09/ 14/2019 (+6111 03/ 14/2020)

Performed 06/09/2020, (3 months past 50% all owance)

Inspection findings issued 06/17/2020 with no violations noted .

This Business is restructuring and no longer at job site in Arkansas.

13. Please submit a table or computer printout that identifies any Priority 1, 2, and 3 licensees and initial inspections that are currently overdue, per IMC 2800. At a minimum, the list should include the same information for each overdue inspection provided for Question 12 plus your action plan for completing the inspection. Also include your plan for completing the overdue inspections.

There are no inspections currently overdue of Priority 1,2, and 3 li censees.

There are no initi al in spections currently overdue.

14. Please provide the number of reciprocity licensees that were candidates for inspection per year as described in IMC 1220 and indicate the number of reciprocity inspections of candidate licensees that were completed each year during the review period.

Totals inclu~e all pri ority codes 201 8 - 36 Candidates with 6 Inspecti ons perfo rmed 20 I 9 - 3 l Candidates with 7 fnspection s performed 2020 - 32 Ca ndidates with 3 Inspection s performed (c ov id impact on inspections) 202 l - 30 Candidates with 6 Inspecti ons perform ed Ill. Technical Quality of Inspections

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

SEE ATTACHED ITEM 15

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

Inspector Supervisor License Category Date SEE ATTACH ED ITEM 16

17. Describe or provide an update on your instrumentation, methods of calibration, and laboratory capabilities . Are all instruments properly calibrated at the present time? Were there sufficient calibrated instruments available throughout the review period?

The Radiation Co ntro l Section's Radi ati on Sa fety Manual descri bes procedures fo r th e ca librati on of radi ation detecti on instrum ents . Mos t instrum ents are sent to th e manufac turer or oth er qualifi ed vendor fo r ca libration on an annu al bas is. A small number of pocket dos im eters are chec ked aga inst a so urce/leakage chec ked in-h ouse ann ually.

In addi tion, it is the Hea lth Phys icists' responsibility to ass ure th at instru ments are in calib ra tion and are worki ng properl y at the time of use or oth erwise obta in an instrum ent that is in calib rati on and operating pro perly.

A suffi cient numb er of calibra ted instruments are ava ilab le to support th e Arka nsas Program . See attac hed ltem 17," HP Equipm ent List," fo r instrum ent spec ifi ca ti ons and laboratory ca pabi lities .

SEE ATTAC HE D ITEM 17 IV. Technical Quality of Licensing Actions

18. How many specific radioactive material licenses does your program regulate at this time?

The program currently regulates 176 spec ifi c radioac ti ve material li censes .

19. Please identify any major, unusual, or complex licenses which were issued, received a

major amendment, were terminated, decommissioned, submitted a bankruptcy notification or renewed in this period.

SEE ATTACHED ITE M 19

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

No variances in licensing polici es and proced ures or exemptions from the regulations were granted during the rev iew peri od.

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

SEE ATTACHED ITEM 21

22. Identify by licensee name and license number any renewal applications that have been pending for one year or more. Please indicate why these reviews have been delayed and describe your action plan to reduce the backlog.

There are no renewa l app li cati ons that have been pending fo r one year or more. Currentl y, one renewa l has been in tim ely renewal for eleven months.

V. Technical Quality of Incident and Allegation Activities

23. For Agreement States, please provide a list of any reportable incidents not previously submitted to NRC (See Procedure SA-300, Reporting Material Events, for additional guidance, 0MB clearance number 3150-0178). The list should be in the following format:

Licensee Name License# Date of Incident/Report Type of Incident SEE ATTACHED ITEM 23

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

There are no changes to proced ures fo r respo nding to incidents and all egations that occurred during the peri od of thi s rev iew.

C. NON-COMMON PERFORMANCE INDICATORS I. Compatibility Requirements

25. Please list all currently effective legislation that affects the radiation control program.

Denote any legislation that was enacted or amended during the review period.

Arka nsas beca me an Agreement Sta te on July I, 1963. Legislati ve au thority to create a rad iation contro l agency an d enter into an Agreement with NRC was granted in Arkansas Code Annotated

§ 20-21 -20 I et seq . The State Board of Health is designated as the State Rad iation Co ntrol Agency, with the day-to-day administrative duties being ca1Tied out by the Secretary of the Department of Health's designee in accordance with A.C.A . § 20-2 1-206. The Arkansas Department of Energy and Env ironment, Division of Environmental Quali ty, has very limited provisions in Title.8, Chapter 7 - Hazardous Substances, Subcb apter 6 - Low-Leve l Radi oactive Waste, that address disposal and storage of low-leve l rad ioacti ve waste.

Act 315 of2019 eliminates "unnecessary references to regulations throughout the Arkansas Code" and provides for "co nsistent references to rules throughout the Arkansas Code." This Ac t will require the Program to amend all regulations, licenses, license conditions, fo rms, etc. to remove references to the wo rd "regu lati on" and to rep lace with "rul e."

Act 517 of 2019 requires eac h state age nc y, after each regular and fiscal session of the General Assemb ly, to review any new ly enacted laws to determine whether any ex isting rule should be repea led or amended or any new rule should be adopted. These new, amended, or repealed rules genera lly must be filed for adoption with the Secretary of State on or before January I of the fo ll owing year.

Act 662 of 2019 estab lishes the Code of Arkansas Rul es (CAR) . The Act instructs the Bureau of Leg islative Researc h (BLR) to develop a uniform sty le, for mat, and numbering system fo r the rules in the CAR. A Word document of our rules was submitted to BLR on August 3, 202 1. The Program has littl e in fo rmat ion on how this convers ion will occur and has stressed that rules of an Agreement State must be compatib le with tha t of the NRC and therefore must adhere to certain rul emaking procedures in order to demonstrate "adequacy" of the Program.

Act 268 of2021 ensures co mpatibi lity of Arkansas law concerning ion izing radiation with NRC law and regulati ons and provides for updating of the Arka nsas Code Annotated to reflect current terminology and techno logica l advances . Th is was a Program -initiated Bill.

Rul e changes pursuant to Act 268 of 2021 have been accomplished (as requ ired by Act 5 17 of 2019) but a considerable amou nt of wo rk wil I need to be do ne to be in compliance with Act 3 15 of 20 l 9 and Act 662 of 20 19.

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

The Arkansas Sta te Board o l"Hea lth Ru les for Contro l of So urces of Ionizing Radiation is not subject to a "sunset" or equivalent law.

27. Please review and verify that the information in the enclosed State Regulation Status (SRS) sheet is correct. For those regulations that have not been adopted by the State, explain why they were not adopted, and discuss actions being taken to adopt them. If legally binding requirements were used in lieu of regulations and they have not been reviewed by NRC for compatibility, please describe their use.

The most current State Regu lation Status (SRS) sheet is dated October 1, 2021 and is correct.

W ith the adopti on of the most recent rule package effective Dece mber 20, 2021, the Arka nsas Program has adopted a ll RA TS amendments clue at thi s t ime . However, RA TS ID 2018- 1 is clue Janu ary 14, 2022, and did not make it onto the Exec utive Staff agenda in order to begin the rulemaking process with other RA TS that became effective December 20, 2021. Proposed language for thi s particular RATS has been reviewed by th e NRC, though, w ith no comments.

The other six RA TS amendments, through RA TS ID 202 1-2 (plus 20 18-1 ), sho uld ente r the ru le making process thi s year. RA TS lDs 20 18-2, 20 18-3 , 2019- l , and a few prov isions not assoc iated w ith a RATS 1D were contained in the rul e package effective December 20, 2021, and we re submi tted to the NRC on January 7, 2022, for final rev iew .

28. 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 normal length of time anticipated to complete each step.

The process for amendi ng rules in cludes the fo llow ing :

  • Deve lopment of the proposed rule, includi ng approva l by ou r Center Director and Agency Attorney
  • Appearance before the Execu ti ve Staff of the Arka nsas Department of Health to seek approval to proceed to the Arka nsas State Board of Health
  • Appearance before the Arkansas State Board of Hea lth for approva l to proceed with rul emaking
  • Approval of the rul e package by the Govern or's Office prior to announcing the Public Com men t Period
  • Filing and distr ibut ion of the proposed rule
  • A 30-day P ublic Comment Period to rece ive co mm ents on the proposed revisions (if substant ive comments received, rulem ak ing process restarts)
  • Appearance before the Senate and Ho use Joi nt Committee on Public Hea lth, Welfare , a nd Labo r for rul e rev iew
  • Appeara nce before the A dministrative R ul es and Regul at ions Subc om mittee of the Arkansas Legislative Co uncil (ALC) for rule rev iew and approva l
  • Appearan ce before the full ALC for fina l approval
  • S ignature of lh e fina l rule by the "D irector" of lhe Arka nsas Departm ent of Hea lth, who serves as the Secretary of th e Arkan sas State Boa rd of Hea lth ; and fi li ng and distrib ut ion of th e final rule.

The ru lemaking process generall y takes at least one year to comp lete . The length of time required to complete each step varies depending on many factors .

II. Sealed Source and Device (SS&D) Evaluation Program - NOT APPLICABLE

29. Prepare a table listing new and amended (including transfers to inactive status) SS&D registrations of sources and devices issued during the review period . The table heading should be:

SS&D Manufacturer, Registry Distributor or Product Type Date Type of Number Custom User or Use Issued Action

30. Please include information on the following questions in Section A, as they apply to the SS&D Program:

Technical Staffing and Training - Questions 2-9 Technical Quality of Licensing Actions - Questions 18-22 Technical Quality of Incident and Allegation Activities - Questions 23-24 Ill. Low-level Radioactive Waste Disposal Program - NOT APPLICABLE 31 . Please include information on the following questions in Section A, as they apply to the Low-Level Radioactive Waste Disposal Program:

Technical Staffing and Training - Questions 2-9 Status of Materials Inspection Program - Questions 10-14 Technical Quality of Inspections - Questions 15-17 Technical Quality of Licensing Actions - Questions 18-22 Technical Quality of Incident and Allegation Activities - Questions 23-24 IV. Uranium Recovery Program - NOT APPLICABLE

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

Technical Staffing and Training - Questions 2-9 Status of Materials Inspection Program - Questions 10-14 Technical Quality of Inspections - Questions 15-17 Technical Quality of Licensing Actions - Questions 18-22 Technical Quality of Incident and Allegation Activities - Questions 23-24

RADIATION CONTROL SECTION INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM ITEM 2A

ORGANIZA TION CHART FROM GOVERNOR TO SECTION CHIEF ASA HUTCHINSON GOVERNO R DR. JOSE' R. ROMERO, MD DIRECTOR ARKANSAS SECRETA RY OF HEALTH RENEE MALLORY, RN CHIEF OF STAFF CONNIE MELTON DIRECTOR CENTER FOR HEALTH PROTECTION BETH WILLIAMS CHIEF HEALTH SYSTEMS LICENSING AND REGULATION BRANCH BERNARD (BERNIE) BEVILL

.SECTION CHIEF RADIATION CONTROL SECTION December 2021

RADIATION CONTROL SECTION INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM ITEM 28

Arkansas Department of Health Radiation Control Section Bernie Bevill, Section Chief Angela Minden, Health Physicist, RSO Jacqueline Carpenter, Budget Specialist Don H. Betts, Health Physicist Supervisor (Radioactive Materials Program) Adelia Oldenbroek, Health Physicist Supervisor (X-ray and Mammography Angie Morgan Hill, Health Physicist Programs)

Steve Mack, Health Physicist Deanna Benson, Health Physicist Christy Stewart, Health Physicist Donna Paxton, Health Physicist Vacant, Vacant, Health Physicist Health Program Specialist II Blain Workman, Health Physicist (Radiologic Technologist Licensure Program)

Tracy Land, Vacant, Health Physicist Administrative Specialist III Glynis Elmore, Administrative Specialist III Kellye Brown-Nichols, Administrative Vacant, Health Physicist Specialist III Valerie Forrest, Administrative Specialist III Last Update: 1/3/2022

RADIATION CONTROL SECTION INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM ITEM(S) 3.4. 7.8.9

I. Tech. Staff and Training INDICATOR - STAFF Bernard Bevill Don H. Betts Steve Mack Radiation Control Section RAM Position Chief Program Manager Health Physicist Status of Employment current current current Area of Effort Inspections 20% 35%

Area of Effort Licensing 30% 35%

Area of Effort Emergency Response 10% 5% 5%

Area of Effort Administrative 10% 45% 15%

Area of Effort GL Program 10%

Area of Effort Training (received)

Date of Hire 10/18/2021 Degree(s) Received Additional Training Years of Experience License Reviewer Yes No Yes Qualified Inspector Yes No Yes Vacant Staff - Hiring Efforts The Medical Advisory RAM-01.5 MAC Approval Committee is appointed Process. Conflict of by the Arkansas Chapter, Interest is avoided by American College of identifying potential Radiology. Member connections between a Radiologist are MAC member and the appointed by the licensee in question. If a Chapter President to MAC member were serve on this committee. associated with the The MAC has not been licensee, they would not used during the IMPEP be included in the MAC Oversight Board/ Committee evaluation period. Approval Process.

Page 1 of 4

I. Tech. Staff and Training INDICATOR- STAFF Angie Morgan Hill Christy Steward Vacant RAM Position Health Physicist Health Physicist Health Physicist vacant October Status of Employment current current 2021*

Area of Effort Inspections 35% 35%

Area of Effort Licensing 40% 40%

Area of Effort Emergency Response 5% 5%

Area of Effort Administrative 15% 15%

Area of Effort GL Program 5% 5%

Date of Hire 5/3/2021 Degree(s) Received BS Biology see attached CS Course Log; OTJ Additional Training Inspect Log Environmental Health Inspector Years of Experience 14 years License Reviewer Yes No Qualified Inspector Yes No Vacant Staff - Hiring Efforts Oversight Board/ Committee Page 2 of 4

I. Tech. Staff and Training INDICATOR - STAFF David Stephens Katia Gray Jared Thompson Program RAM Position Health Physicist Health Physicist Manager Status of Employmen t exit: 9/1/2019 exit: 5/8/2020 exit: 6/30/2021 Area of Effort Inspections Area of Effort Licensing Area of Effort Emergency Response Area of Effort Administrati ve Area of Effort GL Program Area of Effort Training (received)

Date of Hire Degree(s) Received Additional Training Years of Experience License Reviewer Yes Yes Yes Qualified Inspector Yes Yes Yes Vacant Staff - Hiring Efforts Oversight Board/ Committee Page 3 of 4

I. Tech. Staff and Training INDICATOR- STAFF Chris Talley RAM Position Health Physicist Status of Employment exit: 10/22/2021

  • Area of Effort Inspections Area of Effort Licensing Area of Effort Emergency Response Area of Effort Administrative Area of Effort GL Program Area of Effort Training (received)

Date of Hire Degree(s) Received Additional Training Years of Experience License Reviewer Yes Qualified Inspector Yes

  • A request for position advertisement was made in October. As of 12-08-2021 ,

this vacant position had not been advertised . Position advertised in mid-December, closing on 12-30-21. No applicants received . Position Vacant Staff - Hiring Efforts was reposted 1/3/2021 .

Oversight Board/ Committee Page 4 of 4

RADIATION CONTROL SECTION INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM ITEM 5

New HP Course Log COURSES - in training (Christy Steward Hire 5/3/2021)

Completion Course ID Course Name Date Certificate Topic Mode ORAU-09 Radiation Protection - EPHOC 5/1/2021 yes preparedness -online Facility Specific Radiation Safety ADH RSO -

na Training 5/21/2021 na radiation safety in person Introductory Health Physics Self- NRC -

H-117S Study Course 6/8/2021 yes health physics online APNGA Portable Nuclear Gauge Safety & US D.O.T. Hazmat APNGA-na Certification Class 7/19/2021 yes portable gauges online NRC RAM inspection instructor G-108 Inspection Procedures 9/24/2021 na procedures led - on line NRC Licensing Practices and RAM licensing instructor G-109 Procedures 9/30/2021 na procedures led- online Fundamental Health Physics Self- NRC-H-122S Study Course 10/18/2021 yes health physics online Fundamental Health Physics Lab H-122Labs Activities NRC NRC Root Cause/Incident application instructor G-205 Investigation Workshop sent 12-2021 led- online H-305 Industrial Radiography NRC H-315 lrradiator Technology NRC H-314 Safety Aspects of Well Logging NRC Diagnostic & Therapeutic Nuclear H-304 Medicine NRC Brachytheraphy, Gamma Knife H-313 and Other Medical Uses NRC Page 1 of 1

New HP OTJ Inspect Log INSPECTIONS - in training (Christy Steward Hire 5/3/2021)

Inspection License# Licencee Name Date Risk Type with HP ARK-1058 Advance Corrosion 6/2/2021 1 3310 SM ARK-0497 Lanxess - Great Lakes - 6/23/2021 5 03120/03122 CT ARK-0920 Highlands Oncology 7/13/2021 2 02200/02230 AH ARK-0344 Team Industrial 7/15/2021 1 3310 CT ARK-1025 Swepco 7/27/2021 5 3120 CT ARK-1055 lngevity 8/20/2021 5 3120 AH ARK-530 Clearwater Paper 8/26/2021 2 3120 AH GL-0003 Ark. Dept. of Health 8/8/2021 na GL-07 AH ARK-0903 Sterigenics 10/26/2021 1 source load in SM ARK-0482 Drew Memorial Hospital 10/28/2021 4 2121 AH ARK-0824 Hembree Mercy Med 11/2/2021 2 2120 AH ARK-0824 Hembree Mercy Med 11/3/2021 2 2120 AH ARK-0001 UAMS 11/16/2021 1 2110 SM ARK-0001 UAMS 11/16/2021 1 2110 SM ARK-0001 UAMS 11/16/2021 1 2110 AH ARK-0903 Sterigenics (IMPEP) 12/7/2021 1 3521 SM ARK-0623 Jefferson Regional (IMPEP) 12/8/2021 3 2120 AH ARK-0576 Applied Inspections (IMPEP) 12/9/2021 1 3310 AH ARK-0664 Arauco 1/5/2022 5 3120 AH Page 1 of 1

RADIATION CONTROL SECTION INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM ITEM 15

Procedures Index for Radioactive Materials Program Procedure# Title Prepared By Effective Date RAM-01.0 Radioactive Materials Section Responsibilities RAM Supervisor 05/15/90 RAM-01.09 Out-of-State Inspections RAM Health Physicist 10/15/14 RAM-01.l License Amendments RAM Health Physicist 08/05/19 RAM-01.2 New Licenses RAM Health Physicist 08/05/19 RAM-01.3 Renewal Licenses RAM Health Physicist 08/05/19 RAM-01.4 Pre-Licensing Visits RAM Health Physicist 11/15/17 RAM-01.5 Medical Advisory Committee Approval Requests RAM Supervisor 12/21/0 l RAM-01.6 License Termination & Decommissioning RAM Health Physicist 12/23/09 RAM-01.7 Issuing Radioactive Material Reciprocity Licenses RAM Health Physicist 01/16/12 RAM-01.8 Signature Authority for Licenses & Amendments RAM Health Physicist 06/07/19 RAM-01.10 Inspection of Licenses RAM Coordinator 10/30/13 RAM-01.ll Inspection Reports & Licensee Correspondence RAM Coordinator 05/14/20 RAM-01.13 Submission of Samples RAM Health Physicist 12/19/14 RAM-01.14 Incident & Allegation Tracking RAM Health Physicist 07/25/19 RAM-01.15 Compliance Inspection Frequency for Reciprocity Licensees RAM Coordinator 0 l/16/12 RAM-01.16 Approval of Radiation Safety Officer and/or RAM Health Physicist 03/21/16 Assistant /Associate Radiation Safety Officer RAM-1.17 Extension of Renewal Licenses RAM Health Physicist 04/29/20 RAM-03.3 Review of Bioassay Programs RAM Supervisor 05/15/90 RAM-03.7 Inspection Form for RAM Shipments RAM Supervisor 05/15/92 RAM-03.8 Escalated Enforcement Actions RAM Supervisor 03/16/98 RAM-04.0 Compliance Inspection Frequency - AR Licensees RAM Coordinator 01/04/07 RAM-04.l Abnormal Occurrence Criteria: Notifying the NRC RAM Supervisor 05/15/90 RAM-04.2 Abnormal Occurrences: New Releases RAM Supervisor 05/15/90 RAM-04.3 Nuclear Materials Events Database RAM Supervisor 11/09/98 RAM-04.4 Responding to Events Involving Radioactive Material RAM Health Physicist 09/03/13 RAM-05.l Reciprocal Exchange of Information or Enforcement RAM Supervisor 06/20/90 RAM-05.4 Shipments of Scrap Metal under DOT-E 10656 Q&E Supervisor 01/28/92 RAM-06.0 Security Risk Checklist RAM Health Physicist 02/20/19 RAM-06.l Protection of Information RAM Health Physicist 03/02/11 RAM-07.0 Training and Qualifying RAM Inspectors and License Reviewers RAM Manager 07/01/19 RAM-07.l Web-Based Licensing RAM Health Physicist 10/14/13 RAM-08.l Inspection of General Radioactive Material Licensees RAM Health Physicist 12/18/13 RAM-09.0 Responding to Receipt ofNRC Manual License RAM Health Physicist 09/06/16 Verification Report RAM-11.0 Preceptor Verification Procedure RAM Health Physicist 02/01/18 RAM-01.8 Signature Authority for Licenses and Amendments RAM Supervisor 06/16/21 1/7/2022

RADIATION CONTROL SECTION INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM ITEM 16

Ill. Tech. Quality Inspections Supervisory Accompaniments License License Inspector Supervisor License# License Name Priority Date Category Description Hembree Medical Mack Thompson ARK-0824 Mercy Cancer 2120 Institution 9/20/2017 Cntr. WO Rq'd 3 lrradiators -

Stephens Thompson

  • ARK-0903 Sterigenics 3521 Oth*er<10,000 Curies 2 10/18/2017 Medical Medical Center Stephens Thompson ARK-0384 2120 Institution of So. Ark WO Rq'd 3 3/21/2018 Medical St. Mary's Mack Thompson ARK-0390 2120 Institution 8/29/2018 Regional MC WO Rq'd 3 Mobile Cardiac Morgan-Hill Thompson REC-474 2220 Medical Svc.

Imaging WO Not Rq'd 3 2/5/2019 Advanced Industrial Talley Thompson ARK-1057 Corrosion Tech 3310 Radiography and Trng.

1 9/20/2019 Stronghold Industrial Talley Thompson REC-483 3310 Inspection Radiography 1 9/20/2019 Medical CHI St. Vincent Morgan-Hill Thompson ARK-0346 2120 Institution Hot Springs WO Rq'd 3 12/17/2019 Measuring Bobby Systems -

Talley Thompson ARK-1050 Kennedy 3121 5 portable Construction gauge 12/20/2019 Acuren Industrial Talley Thompson ARK-1016 3310 Inspection Radiography 1 1/15/2020 Unity Health Medical Gray Thompson ARK-0681 White County 2120 Institution 3/6/2020 MC WO Rq'd 3 Measuring Arkansas Lime Systems -

Talley Thompson ARK-1066 3122 5 (pre-license) Analytical lnst's 3/19/2020 Industrial Industrial Talley Thompson ARK-0773 3310 Quality Svcs Radiography 1 6/26/2020 Howard Medical Talley Thompson ARK-0465 Memorial 2121 Institution 8/25/2020 Hospital WO Not Rq'd 5 Measuring Evergreen Morgan-Hill Thompson ARK-0042 3120 Systems - 5 Packaging fixed gauges 9/30/2020 Fixed Industrial Talley Thompson ARK-1073 Equipment 3310 Radiography Reliability 1 3/11/2021

Ill. Tech. Quality Inspections Supervisory Accompaniments Measuring Entergy - White Mack Thompson ARK-0501 3120 Systems - 5/18/2021 Bluff (Ra-226) fixed gauges 5 Medical Morgan-Hill Bevill Private ARK-0654 CARTI 2200 2 10/26/2021 Practice WO Rq'd

RADIATION CONTROL SECTION INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM ITEM 17

HP Equipment List Manufacturer Model Description Storage Serial no. Calibration** Operational checks Comments (ABC order) location RADeCO H-811 Air sampler s HP Lab 2009 and 2038 annually - flow quarterly - visually available power - AC,

- area rate calibration inspect heads for 12V DC (vehicle), and by approve d damage /wear; and 12V DC via battery vendor; calibrate with head on (media bank; attach to tripod with media to be included), ensure adapter by removing 2 used; flow calibratio n range is small screws on side, sensor is indicated when unit that -attach the case inspecte d as is powered up and halves - sub with 2 part of calibratio n that appropri ate flow longer screws; use (small fan behind rate shows for 2 inch LB-5211 paper front barrel) AC/12V DC when a and CP-100 cartridge test sample is collected F&J Specialt y 12V 50Ah Air sampler Confere nce none seen NA Verify battery is 12V for H-811 Products - lithium-io n room charged prior to use sampling ; after use, battery pack (starting at 100%, charge via AC - 7 bank will run H-811 hours; recharge within with our media ~3 12 hrs if fully hours) discharg ed; store in a charged state -

F&J S13esialty recharqe everv 6 mo.

ECONO AIR AiF SaFR13leF HP Lab FJL5P 00176 8RAl:Jally via a Elay ef 1:Jse 9Re la13el sassette feF 47 PrnEl1:Jsts h-aP 13eFsenal FRini salieFateF 13eint salieFatien FRFR filteF 13a13eF aleRe OUT OF SERVICE (Elen't t:la1.ie), veFifisatien 1.iia a FRini (LP 94 7); 2 SRaFgeFS FeseFR'EI ey F&J salieFateF (Elen't Fe§l:llaF aREI (e 1.ieFEl1:Je 201 J); Rave); FR9RtRly Fl:JR Ql:JiskORe st:laFgeF salieFate 1Nitt:l tt:le saFR13leF 5 6 RFS (eattei:y FRay neeEI te FReElia te ee 1:JseEI tReR FesRaFge ee rn13laseEI]

(FeSeFR'EI ey F&J)

/a.O:A All L " .. \

Ludlum 43-5

~~

Detector s: Storage various none-T hese day of use* for Model 3's; for 43-5 alpha Room detector s will not recomm ended by detectio n only (not for scintillat ors 7 available be utilized if a Ludlum - would be a measure ment); typical non-aua ntitative ops backaro und is 1-3 rev. 12/2021

HP Equipment List calibrated 43-5 is check; use Th-230 cpm; range is bkg -

available for use. source in HP Lab 240 kcpm; Th-230 source should read Ludlum -1.5 kcpm on contact 44-9 Detectors: Storage various none day of use* for Model 3's; for 44-9 Room recommended by detection only (not for "pancakes" 16 available Ludlum - would be a measurement); typical non-quantitative ops background is 60 check; could use 1O cpm; range is bkg -

µCi Cs-137 source 300 kcpm; Mounted HP Lab Cs-137 source should read Mirian -30 kcom on contact RAD-60R Electronic HP Lab various biannually - by day of use - see used to record alarming approved vendor procedure; quarterly exposure; range of dosimeters (TK) for ANO purposes 0.1 mrem - 999 rem and 0.5 mrem/h - 300 NA rem/h NA Lead shot Storage NA NA NA shielding purposes and some Room sheets Arrow-Tech 138 Pocket HP Lab various annuall y- day of use - check to electrical leakage dosimeters response to rad; see if zeroes out checked annually at 6 available in-house (AM) properly sam_e time; range 0-(others that 200mR could be calibrated if needed)

S.E. INT'L 6 Pocket HP Lab various NA CDV-750 NA used for charging dosimet er-(FEMA) pocket dosimeters; charqer "gun" style Jordan Sb Pocket HP Lab various NA NA used for charging Electronics dosimet er- pocket dosimeters; CD V-750 charger unit takes 1 D cell batterv 2

rev. 12/2021

HP Equipment List Arrow-Tech DC- Pocket HP Lab unknown NA NA used for checking DRD6Hole dosimet er-multiple DRD's for checker response to rad; 8 µCi Flir on 04/2011 Cs-137 nanoRaider Radionuclide HP Lab 103156003538 annuall y-AM day of use - check gamma and manned ZH identifier ("preventative battery charge (Li neutron identification; maintenance and ion); AC and car has Dose Rate, performance charger included; Finder, and optimization" - "calibration check" - Identification modes; manual says will ID Cs-137 check can act as a ORD; 30 every 5 yrs)(not source keV - 3 MeV for a true dose rate gamma; $ 1O µrem/hr calibration) - 1.0 rem/hr Berkeley SAM 945-G Radionuclide HP Lab 945032 annuall y-AM day of use - check gamma identification; Nucleonics identifier (annually battery charge (Li ion manual calibration recom'd by BNC in device and PDA) - using -0.5-1.0 µCi

- not in BN recom's charging Cs-137 source manual)(not a both at least required if drift; true dose rate once/month (AM); Gauge, Finder, and calibration) AC and car chargers Identification modes; included for both; 3x3 Nal and GM; 20 auto calibration and keV - 3 MeV; 0.1 auto stabilization via µrem/hr - 10 rem/hr internal KCI powder; will ID Cs-137 check source Spectrum unknown Source - HP Lab- 0214085 NA NA for SAM-945G use -

Techniques Cs-137; black box appropriate distance 0.913 uCi needed for manual (unknown calibration, need cal date)

-2500 cps Spectrum CS137S10 Source - HP Lab unknown NA NA for operational Techniques Cs-137; checks, as 10 uCi in appropriate Aoril 2016 3

rev. 12/2021

HP Equipment List Spectrum CS137S10 Source- X-ray area unknown NA NA for operational Techniques Cs-137; checks, as 10 uCi in appropriate April 2016 North American F710 Source - HP Lab- unknown NA NA for operational Scientific Th-230; 159 black box checks, as Bq (4.297 appropriate, e.g., the nCi) on 43-5's 3/1/97 Victoreen/Fluke 451-B Survey X-ray or RAM various annually-AM day of use* - via 10 see manual for types meter - ion µCi Cs-137 source and E's of emissions chamber 3 available recom'd by Fluke; detected via window see procedure open or closed; up to SN 501 has 50 R/hr; not cal'd for a beta dose or !3; Fluke only correction checks desiccant if factor meter is in for repair or bkg is high during cal (saturated is light pink); AM will inspect desiccant prior to sending for calibration Victoreen/Fluke 451-P Survey X-ray various annually-AM day of use* - via 10 see manual for types meter- ion µCi Cs-137 source and E's of emissions chamber, 4 available recom'd by Fluke; detected (no a); up to pressurized see procedure 50 R/hr; not cal'd for 13 Ludlum 2241-3 Survey HP Lab various annually-AM day of use - via side- ratemeter and scaler meter- kit mounted Cs-137 (set to 1 min count);

with4 8 available check source (1 µCi det's: 44-9, 44-38 detectors on 2/2006); see (not cal'd for 13), 44-2, procedure; quarterly and 133-6 or 133-7; 4 for ANO purposes - kits kept in LR for TK; also consider ANO response (can these checks: all be used for other Rad segments in the Control activities) display are working, typical bkg readino, 4

rev. 12/2021

HP Equipment List audio, alerts and alarms, F or S, initiation of counting, liQht (see manual)

Ludlum 2241-3 Survey HP Lab 326346 annually-AM day of use - via side- ratemeter and scaler meter- kit mounted Cs-137 (sefto 1 min count);

with 5 check source (1 µCi det's: 44-9, 44-38 detectors on 11/2016); see (not cal'd for 13), 44-2, procedure; quarterly 44-3, and 133-6; Rad for ANO purposes - Control purchased TK; additional this kit; headphone checks as above capability Ludlum 19 Survey HP Lab various annually-AM day of use* - via 1O internal detector; 0-meter- µCi Cs-137 source 5000 µR/hr; typical micro R 12 available recom'd by Ludlum; background is 5-15 meter see procedure; µR/hr quarterly for ANO purposes - HPs Ludlum 12-4 Survey HP Lab 140119 annually-AM day of use 9 inch sphere; 0-meter- recommended by 10000 mrem/hr; Neutron Ludlum - a neutron detector model 42-31 detector source may be a future purchase Ludlum 3 Survey HP Lab 15038 annually-AM day of use* - via Th- meter cal'd with alpha meters - 92787 230 source in HP scintillator probe; with 43-5 Lab (approved by typical background is detectors Ludlum); see 1-3 cpm; range is bkg procedure; quarterly - 240 kcpm; Th-230 for ANO purposes - source should read HPs ~1500 cpm Ludlum 3 Survey HP Lab various annually-AM day of use* - via 1O meter cal'd with meters - with µCi Cs-137 source gamma scintillator 44-2 4 available recom'd by Ludlum; probe; 4 meters with detectors see procedure; µR/hr face , none in quarterly for ANO cpm; 0-5000 µR/hr; purposes - HPs typical background is 1800 cpm 5

rev. 12/2021

HP Equipment List Ludlum 3 Survey HP Lab various semi-annually - day of use* - via 10 meter cal'd with side meters - with AM µCi Cs-137 source window probe; not 44-6 16 available recom'd by Ludlum; cal'd for !3; 0-200 detectors see procedure; mR/hr; typical quarterly for ANO background is 25-50 purposes - HPs com at 8-15 uR/hr RTI Group Piranha RF X-ray test X-ray various biannually - AM none Solid state detector; detector measures kVp, time, device HVL, total filtration, dose, dose rate, and Unfors oresents waveform DXR+, X-ray/light X-ray various NA none - spec's say all direct x-ray ruler RaySafe 8151011-A field segments should alignment turn on when it's fully ruler irradiated

  • If an overnight stay is required, e.g., due to an inspection, the check may be performe d on the first day only. The check must be performed again upon return to the office.
    • Also, before initial use and after damage, erratic behavior, and repairs. Switchin g to a different length of detector cable for meters such as the Ludlum model 3's or 2241-3's will also require a recalibration .

6 rev. 12/2021

HP Equipment List Public Health Laboratory Manufacturer Model Description Storage Serial no. Calibration Operational Comments location checks PerkinE lmer 4810TR liquid Radiochemistry NA Dionne Dionne Low energy beta scintillation Lab Colbert Colbert counting (C-14, Ni-63, or counter H can convert results to microcuries or dpm as needed)

Canberr a Apex- gamma spec Radiochemistry NA Dionne Dionne Gamma counting of Gamma system - Lab Colbert Colbert various geometries; HPGe Detector 1 with pre-WWII detectors steel shield (better for NORM) but requires longer count, Detector 2 with lead shield Canberr a LB4200 gas flow Radiochemistry NA Dionne Dionne Alpha-beta counting proportional Lab Colbert Colbert (gross alpha and gross counter beta in pCi/swipe and pCi/L)

Note: EPA could possibly help with an infrequent, definite need for alpha spectros copy.

7 rev. 12/2021

HP Equipment List Some other things available in the HP Lab:

air sampling RADeCO 2500-19 combina tion holders (heads) (6, new design) paint cans air samplinq RADeCO CP-100 charcoa l cartridqe s (40x50) - sealed; watch exp date pitchers, plastic air sampling RADeCO LB-5211 particula te filters (2 inch) (2 boxes) posting, CRAM, radiation area air sampling RADeCO tripods (2); H-811 tripod adaptors (2), H-809C tripod adaptors (2),

and screws; O-ring kits (2); H-811 fuses (3 total) rope on a spool applicato rs, cotton-ti ooed spades bags - clear, approx. 13 gallon tape and stickers, RAM baqs - sample, 4x6, 4 mil, Fisher Scientifi c tape for cordonin q off, CRA balance - Dial-O-G ram, 2610q by Ohaus tape for seams of PPE (ChemT ape) batteries , D cell and 9V tape , measuri ng (50 ft) containe rs - plastic, round with lids, 16 oz tape, tamper evidence cubitaine rs, 1G/4L tongs ear pluqs trowels envelope s, sample (glassine )

tweezer s flaqs, sample location Tyvek flashligh ts vials - small, with caps qloves, disposab le wipes, cloth*

goaales - splash and impact resistant, over-the -alasses wipes, paper (ACME) mallet ziplocs, aallon paint, sprav

  • cloth fibers miqht cause self-absorption of alpha 8

rev. 12/2021

RADIATION CONTROL SECTION INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM ITEM 19

TERMIN ATED LICENSES LICENSES TERMINATED SINCE MAY 2019 FOLLOW UP IMPEP Licensee Name Address License Number Termination Date Health Physicist Priority S. H. Smith & Company, Inc. 901 Vine Street ARK-1051-03121 11/24/2020 SM 5 Poplar Bluff, MO 63902 Schlum berger Techno logy Services 300 Schlum berger Drive ARK-0077-03121 12/9/2020 SM 5 Mail Drop 121 Sugar Land, TX 77478 Rajesh K. Shroff, MD 1 Mercy Lane, Suite 305 ARK-0968-02201 12/22/2020 SM 5 Hot Springs, AR 71913 Cudd Pumping Svcs. The Woodlands, Texas GL-0130 1/6/2021 SM Clean Harbors El Dorado, LLC 309 American Circle ARK-0557-03120 3/2/2021 SM 5 El Dorado, AR 71730 Mercy Health Center - Bentonville 3101 S.E. 14th Street ARK-0880-02120 3/10/2021 SM 3 Bentonville, AR 72712 Caddo Inspections, Inc P.O. Box 267 ARK-0881-03310 3/30/2021 CT 1 Crossett, Arkansas 71635 Heart Associates of South Arkansa s 619 West Grove Street ARK-0961-02201 4/29/2021 AH 5 El Dorado, AR 71730 FutureFuel Chemical Compan y 2800 Gap Road GL-0032 06/21/2 0201 CT Batesville, AR 72503 Ackley Engineering Inc. 428 Highway 5 N ARK-1011-03121 8/23/2021 ADMH/C S 5 Benton, AR 72019 Twin Lakes Quarry's, Inc. P.O. Box 705 Mountain Home, AR 72653 ARK-0700-03121 11/9/20 21 cs 5

RADIATION CONTROL SECTION INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM ITEM 21

Procedures Index for Radioactive Materials Program Procedure# Title Prepared By Effective Date RAM-01.0 Radioactive Materials Section Responsibilities RAM Supervisor 05/15/90 RAM-01.09 Out-of-State Inspections RAM Health Physicist 10/15/14 RAM-01.1 License Amendments RAM Health Physicist 08/05/19 RAM-01.2 New Licenses RAM Health Physicist 08/05/19 RAM-01.3 Renewal Licenses RAM Health Physicist 08/05/19 RAM-01.4 Pre-Licensing Visits RAM Health Physicist 11/15/17 RAM-01.5 Medical Advisory Committee Approval Requests RAM Supervisor 12/21/01 RAM-01.6 License Termination & Decommissioning RAM Health Physicist 12/23/09 RAM-01.7 Issuing Radioactive Material Reciprocity Licenses RAM Health Physicist 01/16/12 RAM-01.8 Signature Authority for Licenses & Amendments RAM Health Physicist 06/07/19 RAM-01.10 Inspection of Licenses RAM Coordinator 10/30/13 RAM-01.11 Inspection Reports & Licensee Correspondence RAM Coordinator 05/14/20 RAM-01.13 Submission of Samples RAM Health Physicist 12/19/14 RAM-01.14 Incident & Allegation Tracking RAM Health Physicist 07/25/19 RAM-01.15 Compliance Inspection Frequency for Reciprocity Licensees RAM Coordinator 01/16/12 RAM-01.16 Approval of Radiation Safety Officer and/or RAM Health Physicist 03/21/16 Assistant IAssociate Radiation Safety Officer RAM-1.17 Extension of Renewal Licenses RAM Health Physicist 04/29/20 RAM-03 .3 Review ofBioassay Programs RAM Supervisor 05/15/90 RAM-03.7 Inspection Form for RAM Shipments RAM Supervisor 05/15/92 RAM-03.8 Escalated Enforcement Actions RAM Supervisor 03/16/98 RAM-04.0 Compliance Inspection Frequency - AR Licensees RAM Coordinator 01/04/07 RAM-04.1 Abnormal Occurrence Criteria: Notifying the NRC RAM Supervisor 05/15/90 RAM-04.2 Abnormal Occurrences: New Releases RAM Supervisor 05/15/90 RAM-04.3 Nuclear Materials Events Database RAM Supervisor 11/09/98 RAM-04.4 Responding to Events Involving Radioactive Material RAM Health Physicist 09/03/ 13 RAM-05.1 Reciprocal Exchange of Information or Enforcement RAM Supervisor 06/20/90 RAM-05.4 Shipments of Scrap Metal under DOT-E 10656 Q&E Supervisor 01/28/92 RAM-06.0 Security Risk Checklist RAM Health Physicist 02/20/19 RAM-06.1 Protection of Information RAM Health Physicist 03/02/11 RAM-07.0 Training and Qualifying RAM Inspectors and License Reviewers RAM Manager 07/01/19 RAM-07.1 Web-Based Licensing RAM Health Physicist 10/14/13 RAM-08.1 Inspection of General Radioactive Material Licensees RAM Health Physicist 12/18/13 RAM-09.0 Responding to Receipt ofNRC Manual License RAM Health Physicist 09/06/16 Verification Report RAM-11.0 Preceptor Verification Procedure RAM Health Physicist 02/01/18 RAM-01.8 Signature Authority for Licenses and Amendments RAM Supervisor 06/16/21 1/7/2022

RADIATION CONTROL SECTION INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM ITEM 23

Appendix F Question 23 Licensee Name License# Date of Incident/Report Type of Incident 2022 Georgia Pacific ARK-0321 01/3/2022 Heat Damaged Exit Sign 2021 3DI ARK-1008 9/15/2021 Lost FedEx RAM Shipment Material Testing ARK-0859 8/16/2021 Lost Gauge During Transport None None 8/03/2021 Vial Removed from Private Residence 3M GL-0048 5/17/2021 Damaged Gauge Terracon ARK-0820 1/21/2021 Unsecured Container 3DI ARK-1008 1/19/2021 Contamination Mid-Continent Labs, Inc. REC-246 1/12/2021 Stolen Gauge 3DI ARK-1008 6/16/2021 Finger dose and Improper Procedure with Zr-89 3DI ARK-1008 10/25/2021 Package contamination in New Jersey 2020 3DI ARK-1008 12/22/2020 Contamination BRMC Gastroenterology ARK-0990 5/29/2020 Lost Source Nucor Steel ARK-786 3/2/2020 Stuck Shutter 2019 JRMC ARK-0623 7/9/2019 Patient Left with IV Port UAMS ARK-0001 2/15/2019 Medical Event

GTS ARK-0995 315/2019 Source Destroyed by Skid Steer 2018 3D1 ARK-1008 11/14/2018 Over Exposure American Interplex GL-0057 1012412018 Leaking Source Cardinal Health ARK-0642 10/1312018 Recovery of Transport Container BionomicslTRG REC-325 8118/2018 Ra-226 Billion-Aire Analyzer Cardinal Health ARK-0642 612712018 Lost Empty Shipping Container Albermarle ARK-0717 411812018 Stuck Shutter Georgia Pacific ARK-0321 2/2812018 Stuck Shutter Clean Harbors ARK-0557 2126/2018 Accidental Incineration Entergy-White Bluff ARK-0501 1/912018 Stuck Plugs in 2 Gauges 2017 NIA NIA 6/712017 Mercury Clean-up, No RAM Clearwater ARK-0530 61612017 Stuck Shutter Baxter Healthcare GL-0026 511/2017 Stuck Shutter Construction Materials Testing Services ARK-0750 411812017 Stolen Gauge

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