ML22110A132

04-18-2022 Colorado Impep Questionnaire

ML22110A132
Person / Time
Issue date:	04/13/2018
From:	Office of Nuclear Material Safety and Safeguards
To:
Gaskins F
References
OMB 3150-0183
Download: ML22110A132 (12)

Text

Approved by OMB1 Control No.: 3150-0183 Expires: 02/28/2023 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE Reporting Period: April 13, 2018 - May 6, 2022 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.

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.

Response

There were no open recommendations from the 2018 IMPEP review.

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

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

Response

See Attachment A.

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%

Response

Name Position Area of effort FTE%

James Grice Program Manager Management 100%

Phillip Peterson Unit Leader Management 100%

Derek Bailey Licensing Lead Licensing 90%

Emergency Response 10%

Ramon Li Inspection Lead Inspections 90%

Emergency Response 10%

Carrie Romanchek License reviewer and inspector Licensing and compliance 90%

Emergency response 10%

Heather Gilbert License reviewer and inspector Licensing and compliance 90%

Emergency response 10%

1

Matt Gift License reviewer and inspector Licensing and compliance 90%

Emergency response 10%

Meghan Cromie License reviewer and inspector Licensing and compliance 90%

Emergency response 10%

Tim Thorvaldson License reviewer and inspector Licensing and compliance 90%

Emergency response 10%

Will Hageman License reviewer and inspector Licensing and compliance 90%

Emergency response 10%

Kathryn Kirk (Mote) General license coordinator GL registrations, 100%

reciprocity James Jarvis Regulations coordinator Compatibility 90%

Emergency response 10%

Shiya Wang Uranium work lead Uranium recovery 90%

Emergency response 10%

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.

Response

Name Date of Highest degree Additional Years of experience hire received training Meghan Cromie 3/18/2019 Ph.D. in Environmental NRC training 3+ years as RAM unit staff Toxicology courses Carrie Romanchek 4/1/2019 B.A. in Classics NRC training 6+ years as RAM unit (rehire) courses staff, previous experience at CU-Boulder Heather Gilbert 2/1/2021 Masters in NRC training 1+ year as RAM unit staff, Environmental Science courses 2 years as environmental scientist including NORM management Joel Doebele 3/8/2021 M.S. in Health Physics NRC training 10 years health physicist courses experience Will Hageman 7/19/2021 B.A. in Environmental NRC training <1 year as RAM unit staff; Studies courses 4 years as Machinist Mate-Nuclear (Navy)

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.

Response

Will Hageman has completed NRC course G-108 (Inspection Procedures), H-117S (Introductory Health Physics Self-Study), H-122S (Fundamental Health Physics Self-Study), and H-308S (Transportation of Radioactive Materials). Will needs additional experience in licensing and inspections and is tentatively scheduled for certification in portable moisture / density gauges this summer.

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

Response

No changes to the qualification and training procedure during the review period.

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

Response

Joel Doebele, 12/17/2021 2

Peter Rottenborn, 02/12/2021 Mark Dater, 06/19/2020 Cheri Douglas (Hall), 09/04/2018 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.

Response

The program has a vacancy in the TENORM/Uranium recovery group. The position was vacated in December of 2021 and the program is in the process of conducting interviews in April of 2022 to fill that position.

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.

Response

As required by Colorado Radiation Control Act, the Radiation Program has a nine member, governor appointed committee which provides technical guidance and advice to the program. The statute requires that there be three representatives from each of the following areas: higher education, healing arts, and industry, and that no more than four be from any one political party.

There is not a specific requirement that the representatives be licensees, although eight of the current committee members are affiliated with Colorado licensees. The committee is governed by bylaws, statute, and executive orders which address conflict of interest issues.

Status of Materials Inspection Program

10. Please identify individual licensees or categories of licensees the State is inspecting less frequently than called for in NRCs 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.

Response

Colorado follows IMC 2800 for inspection frequencies and does not inspect any facilities less frequently. The Colorado Inspection Manual was last updated in August 2020 and matches the revision of IMC 2800 issued March 2, 2020. For program code 03900, the Office of Nuclear Materials Safety and Safeguards Program Code Descriptions and Inspection Priorities has a priority code D. Colorado inspects sites that are actively decommissioning annually and sites that have completed decommissioning and are in long term care every three years.

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.

Response

4/13/18 - 12/31/18: Routine priority 1, 2, 3: 32. Initial: 5.

1/1/19 - 12/31/19: Routine priority 1, 2, 3: 54. Initial: 7.

1/1/20 - 12/31/20: Routine priority 1, 2, 3: 29. Initial: 11.

1/1/21 - 12/31/21: Routine priority 1, 2, 3: 45. Initial: 13.

1/1/22 - 4/18/22: Routine priority 1, 2, 3: 21. Initial: 2.

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 3

(7) Amount of Time Overdue (8) Date inspection findings issued

Response

Note: the inspections below do not take into account inspections performed overdue due to the covid-19 public health emergency. Please refer to the written response to temporary instructions TI-003 for those inspections.

Licensee Name License Priority Last Date Date Time Findings Number inspection due performed overdue issued date Sweeney Mining CO 149-01 2 4/28/15 4/28/17 5/22/18 24 days 5/22/18 and Milling Glacier View CO 1283-01 5 (initial) - 5/27/21 5/28/21 1 day 6/14/21 Meadows Water &

Sewer Association Cal-Cert Company CO 1295-01 5 (initial) - 9/22/21 10/19/21 27 days 10/19/21 Causes of overdue inspections:

Sweeney Mining and Milling: A delay in the deliverance of the 2015 inspection results and the subsequent delayed recording of that delivery in WBL caused the normally automatically created WBL inspection ID and associated inspection due date to be created incorrectly. As a result, the correct inspection window and due date were not included on the inspection schedule. Once the unit became aware of the error the facility was promptly inspected. In order to avoid a potential future repeat error, the unit will now create future inspection IDs in WBL manually if there is a lengthy delay in closing an inspection.

Cal-Cert Company: the assigned inspector reached out to the licensee prior to the inspection due date to schedule the inspection. No responses were received from the radiation safety officer or the corporate office until after the inspection due date when the department was notified by the corporate office that the radiation safety officer was no longer with the company. A virtual inspection with the corporate radiation safety officer was conducted.

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.

Response

As of April 18, 2022, there are no inspections that are currently overdue. Additionally, there are no inspections that will become overdue between April 18, 2022 and May 6, 2022.

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.

Response

IMC 1220 is no longer active with prescriptive reciprocity inspections (NRC change notice 20-012). Colorado performs reciprocity inspections with the following number of reciprocity inspections performed during the review period:

4/13/18 - 12/31/18: 11 1/1/19 - 12/31/19: 9 1/1/20 - 12/31/20: 4 1/1/21 - 12/31/21: 4 1/1/22 - 4/18/22: 1 The decreasing number of performed reciprocity inspections is primarily due to COVID-19 restrictions, both with restrictions on performing all inspections and then with putting an emphasis on conducting routine inspections that were delayed. It is anticipated that reciprocity inspections will resume with more frequency during the next review period.

Technical Quality of Inspections

15. What, if any, changes were made to your written inspection procedures during the reporting 4

period?

Response

The inspection manual was revised in August 2020. The changes to the inspection manual were primarily based on changes to the NRC IMC 2800 (initial inspections could be extended up to 18 months if the licensee did not possess radioactive materials in the first 12 months; the inspection window was increased to +/- 50% for priority code 1 licensees and increased to +/- 1 year for priority code 2, 3, 4, and 5 licensees; the removal of the requirement to inspect at least 20% of NRC-eligible reciprocity licensees; and updating Appendix A [the program codes for licensee type]). Additional edits to the manual included adding information regarding inspections of provisional licensees and adding information on conducting remote inspections.

The internal WBL guidance was updated in August 2021 to reflect updates that have been made to the WBL program as well as updates to entering in data to the database and minor edits to how documentation is processed by the program.

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

Inspector Supervisor License Category Date

Response

Inspector Supervisor License Category Date Carrie Romanchek Ramon Li 3.P 8/6/2019 (II 128080)

Carrie Romanchek Ramon Li 3.O 8/9/2019 (II 152408)

Carrie Romanchek Ramon Li 3.P 6/18/2021 (II 133136)

Heather Gilbert Ramon Li 3.P 1/21/2022 (II 172517)

Mark Dater Phillip Peterson 7.C (HDR only) 12/21/2018 (II 133562)

Mark Dater Ramon Li 7.C 4/16/2019 (II 131692)

Mark Dater Ramon Li 7.C (7.62) 11/04/2019 (II 143863)

Matt Gift Phillip Peterson 3.P 4/19/2018 (II 126975)

Matt Gift Ramon Li 7.C (7.30, 32, 36) 3/12 - 3/22/2019 (II 131688)

Matt Gift Phillip Peterson 3.B 1/24/2019 (II 126505)

Matt Gift Ramon Li 3.O 12/10/19 - 1/24/20 (II 154191)

Matt Gift Ramon Li 7.C (HDR) 2/13/2020 (II 143564)

Matt Gift Ramon Li 3.B 8/17/2021 (II 132780)

Matt Gift Ramon Li 7.C (7.62) 12/6 - 12/16/2021 (II 154256)

Meghan Cromie Ramon Li 3.P 12/19/2019 (II 127785)

Meghan Cromie Ramon Li 3.P 9/10 - 9/29/20 (II 131173)

Meghan Cromie Ramon Li 3.N 12/9/2021 (reciprocity)

Meghan Cromie Ramon Li 7.C (7.30, 32, 36, 62) 3/29/2022 (II 154516)

Peter Rottenborn Phillip Peterson 3.P 11/15/2018 (II 126997)

Peter Rottenborn Ramon Li 7.C (7.30, 32, 36) 3/21/2019 (II 133691)

Peter Rottenborn Ramon Li 5.A 4/2/2019 (II 133697)

Peter Rottenborn Ramon Li 7.C (7.62) 9/18/2019 (II 142911)

Peter Rottenborn Ramon Li 7.C (HDR) 11/14/2019 (II 133856)

Phillip Peterson Jim Grice 3.E 12/13/2018 (II 126748)

Ramon Li Phillip Peterson 7.A 8/31/2018 (II 127263)

Ramon Li Phillip Peterson 7.B 2/4 - 2/7/2019 (II 133943)

Ramon Li Phillip Peterson 3.O 9/24/2020 (II 163371)

Ramon Li Phillip Peterson 5.A 10/20/2021 (II 154132)

Shiya Wang Phillip Peterson 2.C 5/25/2018 (II 144221)

Shiya Wang Ramon Li 4.A 12/17/2019 (II 154062)

Shiya Wang Ramon Li 14.A 12/3/2020 (II 161605)

Shiya Wang Ramon Li 2.C 12/28/2021 (II 169131)

Tim Thorvaldson Phillip Peterson 3.M 8/7/2018 (II 126491)

Tim Thorvaldson Phillip Peterson 7.C (7.30, 32, 36) 10/18/2018 (II 131177) 5

Tim Thorvaldson Ramon Li 3.L 4/8 - 4/11/2019 (II 130745)

Tim Thorvaldson Ramon Li 3.C 8/27 - 9/11/2019 (II 143813)

Tim Thorvaldson Ramon Li 7.C (HDR) 3/6/2020 (II 154420)

Tim Thorvaldson Ramon Li 7.C (7.62) 3/23/2021 (II 166917)

Tim Thorvaldson Ramon Li 7.B, 7.C (7.42) 4/27 - 4/28/2021 (II 153789)

Missing accompaniments: Peter Rottenborn (2020) and Carrie Romanchek (2020)

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?

Response

CDPHE has the following instrumentation currently available to use for inspections:

• 4 Bicron micro-rem meters to measure dose rate

• 1 Eberline PRM-7 meter to measure dose rate

• 2 Inovision 451B meters to measure dose rate

• 10 Ludlum model 3 meters with GM probes to measure contamination

• 1 Ludlum model 3 meter with a 2x2 NaI detector

• 3 Ludlum model 19 meters to measure dose rate

• 4 Ludlum model 2 meters with GM probes to measure contamination

• 2 Ludlum model 9 meters with ion chambers to measure dose rate

• 1 Ludlum model 2241 scaler with multiple probes

• 1 Ludlum model 12-4 meter to measure neutron dose rate

• 1 Ludlum model 12 meters with NaI probe to measure contamination

• 3 Ludlum model 12 meters with GM probe to measure alpha contamination

• 1 Ludlum model 12 meter with multiple probes

• 1 Ludlum model 15 meter to measure neutron dose rate

• 1 SE International Inspector + meter to measure dose rate and contamination

• 1 Victoreen 450B with ion chamber to measure dose rate

• 1 Victoreen 290 with GM probe to measure contamination

• 1 FLIR Radiation, Inc. IdentiFinder 2 for field isotope identification

• 1 Berkeley SAM for field isotope identification

• 1 ThermoFisher RadEye PRD-ER meter to measure dose rate

• 1 Bicron Analyst meter to measure contamination All meters are calibrated on an annual basis and have been calibrated within the last year.

Meters are calibrated at Ludlum Measurements, Inc. or at ThermoFisher. Any meter found to be out of calibration or not working properly is removed from service until required calibrations or maintenance is performed.

Any samples requiring liquid scintillation, gamma spectroscopy, or radiochemical analysis are sent to an accredited radiochemistry laboratory.

All instruments have been properly calibrated during the review period. Sufficient instrumentation was available during the review period.

Technical Quality of Licensing Actions

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

Response

As of April 18, 2022, Colorado has 312 specific radioactive materials licensees, 10 of which are provisional.

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.

Response

Licensee License number, Mail Control Date issued Action amendment number Number Evraz Rocky Mountain CO 250-02, A08 614000 12/17/2019 Amendment, addition Steel of new device type Centura Health Penrose CO 197-02, A136 611912 06/22/2020 Amendment, addition 6

- St. Francis Health of new device type Services (Ruby-Fill)

Disa, Inc. CO 1312-01 A00 630049 Never New license (not issued) issued, application, proposed applicant use of ablation for withdrew remediation under a request source materials license, Department determined that the operations were subject to uranium recovery requirements and a milling license.

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

Response

Swedish Medical Center, license CO 251-02, amendment 51, mail control number 602474. This variance allowed neurodiagnostic technologists, under the supervision of an authorized user, an exemption from appendix 7N training requirements to administer technetium-99m doses to patients undergoing brain imaging seizure studies. Due to the time sensitive nature of the test, a nuclear medicine technologist is unable to perform the injection. Through procedures and training provided, the health and safety of all involved will be preserved in accord with the spirit of the regulatory requirements.

ProTechnics, Division of Core Laboratories LLP, license CO 545-01, amendment 35, mail control number 608724. This variance allowed an alternative disposal for subsurface tracer study wastes to a solid waste disposal site. Wastes are limited to less than 400 pCi/g of scandium-46 (half-life equal to 83.8 days), 200 pCi/g of antimony-124 (half-life equal to 60.2 days), and 400 pCi/g of iridium-192 (half-life equal to 73.8 days) in the form of ZeroWash ceramic beads. The alternative disposal of these materials is similar to the NRC technical evaluation report found in ML16020A283 and followed the NRC guidance for disposal procedures and transfers under 10 CFR 20.2002. The dose assessments at the solid waste disposal site demonstrated that workers would be exposed to less than 7 mrem per year from the waste disposal. The solid waste disposal site also received a variance to receive and dispose of well-logging sandouts and well returns that contain the radioactive materials as mentioned above.

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

Response

A guidance document for licensing actions was created by consolidating and updating notes from previous internal licensing meetings. This guidance document is intended to be updated periodically by the licensing lead or the unit leader.

The internal WBL guidance was updated in August 2021 to reflect updates that have been made to the WBL program as well as updates to entering in data to the database and minor edits to how documentation is processed by the program.

All license templates were updated for correct CDPHE branding and ADA compliance. As needed, minor corrections were made as needed to correct typos, implement a consistent use of Item vs.

Condition in licenses, and remove RH language from license templates.

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.

Response

As of April 18, 2022, there are no open renewals that have been pending for one year or more.

Additionally, there are no open renewals that will have been pending for one year or more between April 18, 2022 and May 6, 2022.

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, OMB clearance 7

number 3150-0178). The list should be in the following format:

Licensee Name License # Date of Incident/Report Type of Incident

Response

The program is unaware of any reportable incidents not previously submitted to the NRC.

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

Response

No changes were made to the procedures for responding to incidents and allegations during the review period.

8

NON-COMMON PERFORMANCE INDICATORS 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.

Response

Colorados radiation control authority and regulations are authorized by Title 25, Article 11, C.R.S.

Colorados legislature is a part time legislative body, with each regular session taking place January through May of each year. Legislation enacted during the regular session typically takes effect by August of the same year pending approval by the Governor.

During the review period, Colorados enabling legislation was amended in 2018 and 2019.

• The 2018 legislation change was initiated by the department and repealed a prohibition against the adoption of rules concerning the disposal of NORM and TENORM materials.

• The 2019 legislation change was initiated by the legislature Statutory Revision Committee to make minor wording changes for consistency with other legislation. The change clarified statutory language allowing members of the Radiation Advisory Committee to be compensated for their actual and necessary expenditures.

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

Response

Under the State Administrative Procedure Act, the Colorado legislature is authorized each year to sunset agency regulations adopted or amended between November 1st and October 31st if they are found to exceed the rulemaking authority of the agency or are inconsistent with law. C.R.S. § 24-4-103(8)(c)(I). When such a finding is made, the regulations are designated to expire the following May 15th. Additionally, each year after Colorados legislative session, the Office of Legislative Legal Services reviews existing regulations to determine if they are in conflict with laws enacted during that legislative session. Historically, the Colorado Rules and Regulations Pertaining to Radiation Control have always been approved for continuation each year, as such regulations are necessary for Colorado to maintain its authority under the agreement with the NRC, consistent with the states policy. C.R.S. § 25-11-102.

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.

Response

Colorado has reviewed the Colorado State Regulation Status (SRS) sheet and believes it to be correct.

Since the prior IMPEP in April 2018, Colorado has submitted draft and final rule packages to address five NRC Regulatory Action Tracking System (RATS) items due during the current review period. Additionally, during the current review period Colorado has submitted draft and final rule packages ahead of schedule for five RATS items that are not due until the next review period (after May 2022).

Three RATS items (2020-3, 2021-1, and 2021-2) are all due during the next review period (late 2023 and beyond) but are scheduled for completion in December 2022.

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.

Response

The program strives to complete all NRC driven regulatory amendments within 3 years of NRCs rule promulgation. All state agencies in Colorado are required to plan and provide notice for future regulatory changes at least one year in advance. Each November a regulatory agenda is established which outlines the rulemaking schedule for the following calendar year. The NRC rule change issuance date will determine whether Colorados rulemaking activity to address federal 9

rule changes will take place in the 2nd or possibly 3rd year following NRC issuance. Except where a regulatory change may be particularly controversial, most rulemaking efforts can typically be completed within approximately 9-18 months.

During the current review period, Colorado provided proposed and final rule packages prior to the adoption date for five RATS items, including 2015-3, 2015-4, 2015-5, 2018-1, and 2018-2. Also within the current IMPEP review period, Colorado completed proposed and final rule packages for RATS items 2018-3, 2019-1, 2019-2, 2020-1, and 2020-2 which are not due until the next review period (after May 2022). The remaining three RATS items due in the next IMPEP review period are in-process and are scheduled for completion by the end of 2022.

II. Sealed Source and Device (SS&D) Evaluation Program

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

Response

SS&D Registry Manufacturer, Product Type of Date Issued Type of Action Number Distributor or Use Custom User CO-1012-D-101-S Thermo MF Neutron 12/26/2018 Amendment, new model Physics, LLC generation tube added

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

Response

See Common Performance Indicator responses. The following staff members have been trained to perform SS&D evaluations: James Grice, Phillip Peterson, Ramon Li, James Jarvis.

Technical Quality of Licensing Actions - Questions 18-22

Response

See Common Performance Indicator responses. Colorado currently has three licensees that have four SS&D sheets issued (1 to Hazen Research, Inc. (CO 1098-01), 1 to Particle Measuring Systems (CO 1073-01), and 2 to Thermo MF Physics (CO 803-02)).

Technical Quality of Incident and Allegation Activities - Questions 23-24

Response

See Common Performance Indicator responses. Incident and allegations for SS&Ds are handled as part of the overall incident and allegation program.

III. Low-level Radioactive Waste Disposal Program

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

Response

See Common Performance Indicator responses. Colorado has one potential low-level radioactive waste disposal license, Clean Harbors Deer Trail, which is authorized to accept for disposal NORM and TENORM. This licensee is regulated as any other licensee.

10

IV. Uranium Recovery Program

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 Specifically Question 19: the entry regarding Disa, Inc. was received as a non-uranium recovery application but the program determined the activities to be subject to the uranium recovery regulatory scheme.

Technical Quality of Incident and Allegation Activities - Questions 23-24

Response

See Common Performance Indicator responses. All uranium recovery licensees are in various phases of decommissioning and are regulated as all other licensees.

11

MATERIALS REQUESTED TO BE AVAILABLE FOR THE ON-SITE PORTION OF AN IMPEP REVIEW Please have the following information available for use by the IMPEP review team when they arrive at your office:

List of open license cases, with date of original request, and dates of follow-up actions.

List of licenses terminated during review period.

Copy of current log or other document used to track licensing actions.

List of all licensing actions completed during the review period (sorted by license reviewer, if possible).

Copy of current log or other document used to track inspections.

List of all inspections completed during the review period (sorted by inspector, if possible).

List of inspection frequencies by license type.

List of all allegations occurring during the review period. Show whether the allegation is open or closed and whether it was referred by NRC.

List of all licenses that your agency has imposed additional security requirements upon.

ALSO, PLEASE HAVE THE FOLLOWING DOCUMENTS AVAILABLE:

All State regulations Documented training plan, if applicable Statutes affecting the regulatory authority Records of results of supervisory of the State program accompaniments of inspectors Standard license conditions Emergency plan and communications list Technical procedures for licensing, Procedures for investigating allegations model licenses, review guides Procedures for investigating incidents SS&D review procedures, guides, and standards Enforcement procedures, including procedures for escalated enforcement, severity levels, civil Instrument calibration records penalties (as applicable)

Inspection procedures and guides Job descriptions Inspection report forms 12