ML18344A642

Letter to J. Schuerman Louisiana Proposed Regulations to 10 CFR Part 34

ML18344A642
Person / Time
Issue date:	01/18/2019
From:	Kevin Williams Office of Nuclear Material Safety and Safeguards
To:	Schuerman J State of LA, Dept of Environmental Quality
Beardsley M
References
Download: ML18344A642 (23)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 18, 2019 Judith A. Schuerman, Ph.D., Manager Radiation Section Emergency and Radiological Services Division Louisiana Department of Environmental Quality P.O. Box 4312 Baton Rouge, LA 70821-4312

Dear Dr. Schuerman:

We have reviewed the proposed revisions to the Louisiana Department of Environmental Quality rules (equivalent to 10 CFR Part 34) in the Louisiana Administrative Code, Title 33, Part XV, Radiation Protection, received by our office on November 16, 2018. These regulations were reviewed by comparison to the equivalent U.S. Nuclear Regulatory Commission (NRC) rules as identified in the enclosed State Regulation Status (SRS) Data Sheet. We discussed our review of the regulations with you on January 16, 2019.

As a result of our review, we have six comments that have been identified in the enclosure.

Please note that we have limited our review to regulations required for compatibility and/or health and safety. Under our current procedure, a finding that the Louisiana regulations meet the compatibility and health and safety categories of the equivalent NRC regulation may only be made based on a review of the final Louisiana regulations. However, we have determined that if your proposed regulations were adopted, incorporating our comments and without other significant change, they would meet the compatibility and health and safety categories established in the Office of Nuclear Material Safety and Safeguards (NMSS) Procedure SA-200, Compatibility Categories and Health and Safety Identification for NRC Regulations and Other Program Elements.

We request that when the proposed regulations are adopted and published as final regulations, a copy of the as published regulations be provided to us for review. As requested in NMSS Procedure SA-201, Review of State Regulatory Requirements, please highlight the final changes, and provide a copy to Division of Materials Safety, Security, State, and Tribal Programs, NMSS.

The SRS Data Sheet summarizes our knowledge of the status of other Louisiana regulations, as indicated. Please let us know if you note any inaccuracies, or have any comments on the information contained in the SRS Data Sheet. This letter, including the SRS Data Sheet, is posted on the NMSS State Communication Portal: https://scp.nrc.gov/rulemaking.html.

If you have any questions regarding the comments, the compatibility and health and safety categories, or any of the NRC regulations used in the review, please contact Michelle Beardsley, State Regulation Review Coordinator, at 301-415-0275 (michelle.beardsley@nrc.gov) or Stephen Poy at 301-415-7135 (stephen.poy@nrc.gov).

Sincerely,

/RA Paul Michalak for/

Kevin Williams, Deputy Director Division of Materials Safety, Security, State and Tribal Programs Office of Nuclear Material Safety and Safeguards

Enclosures:

1. Compatibility Comments

2. Louisiana SRS Data Sheet

SUBJECT:

01/18/2019 LETTER TO J. SCHUERMAN RE: LOUISIANA PROPOSED REGULATIONS TO 10 CFR PART 34 DISTRIBUTION: SP[08]

Tracking No. LA 19-03 Randy Erickson, RSAO Louisiana File OFFICE ASPB ASPB OGC ASPB:BC MSTR:DD NAME SPoy MBeardsley MSegarnick NLO via email PMichalak PMichalak for:

KWilliams DATE 12/05/18 12/06/18 1/15/19 01/18/19 01/18/19 ML18344A642 OFFICIAL RECORD COPY Package ML18324A728 COMPATIBILITY COMMENTS ON LOUISIANA PROPOSED REGULATIONS STATE SECTION NRC SECTION RATS ID CATEGORY SUBJECT and COMMENTS 1

§ 550 A. (1-

5)

§ 34.20i (a)(1), (b), (c),

(d), & (e)

N/A B

Performance requirements of industrial radiography equipment In §550 A. (1), Louisiana states, each radiographic exposure device and all associated equipment shall meet the requirements specified in American National Standard. The phrase source assembly or sealed source needs to be included such that the phrase reads each radiographic exposure device, source assembly, or sealed source and all associated equipment shall meet the requirements specified in American National Standard.

Louisiana needs to make the change indicated above to meet the Compatibility Category B designation assigned to 10 CFR 34.20(a)(1).

2

§ 547 A, B, and F

§ 34.31 N/A C

Inspection and maintenance of radiographic exposure devices, transport and storage containers, associated equipment, source changers and survey instruments a) Louisianas regulations in §547 A.1. state the following:

The licensee or registrant shall perform visual and operability checks on radiation machines, radiographic exposure devices, transport and storage containers, source changers, and associated equipment prior to each day's use, or work shift, to ensure that:

1.

the equipment is in good condition; Lousiana needs to replace the phrase the equipment is in good condition in

§ 547 A.(1) with the phrase, the equipment is in good working

2 STATE SECTION NRC SECTION RATS ID CATEGORY SUBJECT and COMMENTS condition.

b) Louisianas regulations in §547 B.

state the following:

Each licensee or registrant shall have written procedures for and perform inspections at intervals not to exceed three months, or before first use thereafter, and routine maintenance of radiation machines, radiographic exposure devices, source changers, storage containers, and associated equipment to ensure proper functioning of components important to safety.

Lousiana needs to replace the phrase source changers, storage containers, and associated equipment in §547 B.

with the phrase, source changers, transport and storage containers, and associated equipment.

Louisiana needs to make the changes indicated above to meet the Compatibility Category C designation assigned to 10 CFR 34.31.

3 3

§ 542

§ 34.35 N/A B

Labeling, storage, and transportation In § 542 B. Louisiana omits the phrase:

and the wording CAUTION*

RADIOACTIVE MATERIAL NOTIFY CIVIL AUTHORITIES (or "NAME OF COMPANY")

• _________ or "DANGER".

§ 542 B. needs to include the above phrase to state the following:

The licensee may not use a source changer or a container to store licensed material unless the source changer or the storage container has securely attached to it a durable, legible, and clearly visible label bearing the standard trefoil radiation caution symbol conventional colors, i.e., magenta, purple or black on a yellow background, having a minimum diameter of 25 mm, and the wording CAUTION*

RADIOACTIVE MATERIAL NOTIFY CIVIL AUTHORITIES (or "NAME OF COMPANY")

• _________ or "DANGER" Louisiana needs to make the change indicated above to meet the Compatibility Category B designation assigned to 10 CFR 34.35.

4

§ 575

§34.43ii(a)

N/A B

Training Louisianas regulations in § 575 contain provisions that are not essentially identical to 10 CFR 34.43, and could result in conflicts and transboundary implications, as follows:

4

§ 575 A.1. and 2. contain provisions requiring that:

1. The individual shall be instructed by a licensed instructor for at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> in the subjects outlined in LAC 33:XV.599.Appendix A; and, The course of instruction shall be approved by the department prior to the time of instruction by submitting documentation of instructor licensure and course description.

a. The department must be notified by the licensee at least two weeks prior to presentation of the course.

b. The department must be notified of the cancellation of the course at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to its scheduled time of presentation.

These Louisiana provisions differ from 10 CFR 34.43(a)(1), which does not include the at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> provision and does not require approval or notification regarding the course of instruction. Louisianas regulations are more restrictive and could have transboundary implications.

2. The individual shall complete a minimum of two months of on-the-job training supervised by one or more radiographer instructors.

a. The instructor shall be issued a radiographer certification card with instructor status by the department.

b. The on-the-job training shall include at least:

i. 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of active participation in radioactive materials industrial radiography operations for an individual to perform industrial radiography utilizing radioactive materials; and/or

5 ii. 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> of active participation in X-ray industrial radiography operations for an individual to perform industrial radiography utilizing X-rays.

c. The hours of on-the-job training do not include safety meetings or classroom training or the use of a cabinet X-ray unit.

These Louisiana provisions differ from 10 CFR 34.43(a) and (b), which do not establish requirements for radiographer instructor certification cards, and which do not specify certain hours and types of on-the-job training. Louisianas regulations are more restrictive and could have transboundary implications.

• § 575 B. 2. contains provisions requiring

a. (§ 575 B.2.(a)) that the instructor shall be issued a radiographer certification card with instructor status by the department;

b. (§ 575.B.8) that each radiographer trainee I.D.

card does not expire, unless revoked or suspended in accordance with LAC 33:XV.579.

10 CFR 34.43 does not contain the above provisions which makes the Louisiana regulations more restrictive.

Since 10 CFR 34.43(a) is designated as a Compatiblity Category B, Louisianas regulations needs to be essentially identical in order to be compatible with 10 CFR 34.43.

Louisiana needs to submit regulations that are essentially identical to 10 CFR 34.43, to meet the Compatibility Category B designation assigned to 10 CFR 34.43.

6 5

§ 575 C.

§ 34.79 NA C

Records of training and certification Louisianas regulations in § 575 C.

require that records be maintained until disposition is authorized by the department. 10 CFR 34.79 requires that records be maintained for 3 years. This could result in the Louisiana regulations being more or less restrictive, i.e., if the department authorizes the maintenance of records for more or less than 3 years.

Louisiana needs to revise § 575 C. as indicated above to meet the Compatibility Category C designation assigned to 10 CFR 34.79.

6

§ 579

§ 588 A. (7)

§ 590 E. (3)

NA NA NA

[None]

Louisianas regulations in § 579

§ 588 A.(7), and § 590 E.(3) contain provisions that require certification cards for radiographers and radiographer trainees in lieu of being named as authorized users on the license.

10 CFR 34.43(a) and (b) contain the training and experience requirements that the licensee needs to follow in authorizing individuals to operate as radiographers under their license. In addition, 10 CFR 34 Appendix B contains the requirements to be a certifying entity. Louisianas regulations do not allow the licensee to authorize individuals as radiographers under their license; and they give the State the authority to be the certifying entity, therefore making the Louisiana regulations more restrictive which could have transboundary implications.

Louisiana needs to remove these requirements in order to be compatible with 10 CFR 34.43.

i See CR-02-01 for additional information

7 ii If a State wishes to clearly specify the number of hours of formal classroom training as specified in the SSR§s, this would be considered compatible. Also in 34.43 (b)(1) and (c)(1) references to 10 CFR 30.7 and 30.9 are not required for adoption by an Agreement State because these sections are assigned Compatibility Category D.

REGULATION STATUS State: Louisiana Tracking Ticket Number: 19-03 Date: January 18, 2019

[ # amendment(s) reviewed identified by a

• at the beginning of the equivalent NRC requirement.]

RATS ID NRC Chronology Identification Date Due for State Adoption Incoming Letter Outgoing Package Notes 1991-1 Safety Requirements for Radiographic Equipment Part 34 55 FR 843 (Superceded by 1997-5) 01/10/1994 Not Required Not Required Louisiana has adopted Final Regulations equivalent to RATS ID:

1997-5.

1991-2 ASNT Certification of Radiographers Part 34 56 FR 11504 (Superceded by 1997-5) none Not Required Not Required Louisiana has adopted Final Regulations equivalent to RATS ID:

1997-5.

1991-3 Standards for Protection Against Radiation Part 20 56 FR 23360; 56 FR 61352; 57 FR 38588; 57 FR 57877; 58 FR 67657; 59 FR 41641; 60 FR 20183; 01/01/1994 Final ML14266A408 No Comments 11/19/2014 ML14266A336 1991-4 Notification of Incidents Parts 20, 30, 31, 34, 39, 40 and 70 56 FR 64980; 10/15/1994 Final ML12361A157 No Comments 03/29/2013 ML13044A340 1992-1 Quality Management Program and Misadministrations Part 35 56 FR 34104 (Superceded by 2002-2) 01/27/1995 Not Required Not Required Louisiana has adopted Final Regulations equivalent to RATS ID:

2002-2.

1992-2 Eliminating the Recordkeeping Requirements for Departures from Manufacturer's Instructions Parts 30 and 35 57 FR 45566 none Not Required Not Required These regulations are not required to be adopted for purposes of Compatibility.

2 RATS ID NRC Chronology Identification Date Due for State Adoption Incoming Letter Outgoing Package Notes 1993-1 Decommissioning Recordkeeping and License Termination: Documentation Additions [Restricted areas and spill sites]

Parts 30 and 40 58 FR 39628 10/25/1996 Final ML12361A157 No Comments 03/29/2013 ML13044A340 1993-2 Licensing and Radiation Safety Requirements for Irradiators Part 36 58 FR 7715 07/01/1996 Not Applicable1 Not Applicable Louisiana does not have any licensees subject to these regulations. (See SECY-95-112) 1993-3 Definition of Land Disposal and Waste Site QA Program Part 61 58 FR 33886 07/22/1996 Not Applicable1 Not Applicable Louisiana does not have any licensees subject to these regulations. (See SECY-95-112) 1994-1 Self-Guarantee as an Additional Financial Mechanism Parts 30, 40 and 70 58 FR 68726; 59 FR 1618 none Not Required Not Required These regulations are not required to be adopted for purposes of Compatibility.

1994-2 Uranium Mill Tailings Regulations: Conforming NRC Requirements to EPA Standards Part 40 59 FR 28220 07/01/1997 Not Applicable Not Applicable Louisiana does not have authority to regulate this material under its Agreement.

1994-3 Timeliness in Decommissioning Material Facilities Parts 30, 40 and 70 59 FR 36026 08/15/1997 Final No Comments 01/06/1999 1995-1 Preparation, Transfer for Commercial Distribution, and Use of Byproduct Material for Medical Use Parts 30, 32 and 35 59 FR 61767; 59 FR 65243; 60 FR 322 01/01/1998 Final No Comments 01/06/1999

3 RATS ID NRC Chronology Identification Date Due for State Adoption Incoming Letter Outgoing Package Notes 1995-2 Frequency of Medical Examinations for Use of Respiratory Protection Equipment Part 20 60 FR 7900 03/13/1998 Final No Comments 01/06/1999 1995-3 Low-Level Waste Shipment Manifest Information and Reporting Parts 20 and 61 60 FR 15649; 60 FR 25983 03/01/1998 Final No Comments 01/06/1999 1995-4 Performance Requirements for Radiography Equipment Part 34 60 FR 28323 (Superceded by 1997-5) 06/30/1998 Final No Comments 01/06/1999 Louisiana has adopted Final Regulations equivalent to RATS ID:

1997-5.

1995-5 Radiation Protection Requirements: Amended Definitions and Criteria Parts 19 and 20 60 FR 36038 08/14/1998 Final No Comments 01/06/1999 1995-6 Clarification of Decommissioning Funding Requirements Parts 30, 40 and 70 60 FR 38235 11/24/1998 Final No Comments 01/06/1999 1995-7 Medical Administration of Radiation and Radioactive Materials Parts 20 and 35 60 FR 48623 (Superceded by 2002-2 and 2005-2) 10/20/1998 Final No Comments 01/06/1999 Louisiana has not yet adopted Final Regulations equivalent to RATS ID:

2005-2.

1996-1 Compatibility with the International Atomic Energy Agency Part 71 60 FR 50248; 61 FR 28724 (Superceded by 2004-1) 04/01/1999 Final ML020280299 No Comments 02/15/2002 ML020460125 Louisiana has not yet adopted Final Regulations equivalent to RATS ID:

2004-1.

4 RATS ID NRC Chronology Identification Date Due for State Adoption Incoming Letter Outgoing Package Notes 1996-2 One Time Extension of Certain Byproduct, Source and Special Nuclear Materials Licenses Parts 30, 40 and 70 61 FR 1109 02/15/1999 Not Required Not Required These regulations are not required to be adopted for purposes of Compatibility.

1996-3 Termination or Transfer of Licensed Activities:

Recordkeeping Requirements Parts 20, 30, 40, 61 and 70 61 FR 24669 06/17/1999 Final ML12361A157 No Comments 03/29/2013 ML13044A340 1997-1 Resolution of Dual Regulation of Airborne Effluents of Radioactive Materials; Clean Air Act Part 20 61 FR 65120 01/9/2000 Final ML011510385 No Comments 11/15/2001 ML013100191 1997-2 Recognition of Agreement State Licenses in Areas Under Exclusive Federal Jurisdiction Within an Agreement State Part 150 62 FR 1662 02/27/2000 Final ML011510385 No Comments 11/15/2001 ML013100191 1997-3 Criteria for the Release of Individuals Administered Radioactive Material Parts 20 and 35 62 FR 4120 05/29/2000 Final No Comments 01/06/1999 1997-4 Fissile Material Shipments and Exemptions Part 71 62 FR 5907 (Superceded by 2004-1) 02/10/2000 Not Required Not Required These regulations are not required to be adopted for purposes of Compatibility. (See STP-97-078)

5 RATS ID NRC Chronology Identification Date Due for State Adoption Incoming Letter Outgoing Package Notes 1997-5 Licenses for Industrial Radiography and Radiation Safety Requirements for Industrial Radiography Operations Parts 30, 34, 71 and 150 62 FR 28947 06/27/2000 Final ML14266A408 Revised Final ML14364A230 Revised Final ML15212A809 Comments 11/19/2014 ML14266A336 No Comments 01/29/2015 ML14364A226 No Comments 08/31/2015 ML15212A806 1997-6 Radiological Criteria for License Termination Parts 20, 30, 40 and 70 62 FR 39057 08/20/2000 Final ML011510385 No Comments 11/15/2001 ML013100191 1997-7 Exempt Distribution of a Radioactive Drug Containing One Microcurie of Carbon-14 Urea Part 30 62 FR 63634 01/02/2001 Final No Comments 01/06/1999 1998-1 Deliberate Misconduct by Unlicensed Persons Parts 30, 40, 61, 70, 71 and 150 63 FR 1890; 63 FR 13773 02/12/2001 Final ML011510385 No Comments 11/15/2001 ML013100191 1998-2 Self-Guarantee of Decommissioning Funding by Nonprofit and Non-Bond-Issuing Licensees Parts 30, 40 and 70 63 FR 29535 07/01/2001 Not Required Not Required These regulations are not required to be adopted for purposes of Compatibility.

1998-3 License Term for Medical Use Licenses Part 35 63 FR 31604 (Superceded by 2002-2) 07/10/2001 Not Required Not Required These regulations are not required to be adopted for purposes of Compatibility. (See STP-98-074)

Louisiana has adopted Final Regulations equivalent to RATS ID:

2002-2.

6 RATS ID NRC Chronology Identification Date Due for State Adoption Incoming Letter Outgoing Package Notes 1998-4 Licenses for Industrial Radiography and Radiation Safety Requirements for Industrial Radiographic Operations Part 34 63 FR 37059 07/09/2001 Final ML062480284 No Comments 10/23/2006 ML062960278 1998-5 Minor Corrections, Clarifying Changes, and a Minor Policy Change Parts 20, 32, 35, 36 and 39 63 FR 39477; 63 FR 45393 10/26/2001 Final ML14266A408 No Comments 11/19/2014 ML14266A336 1998-6 Transfer for Disposal and Manifests: Minor Technical Conforming Amendment Part 20 63 FR 50127 11/20/2001 Final ML062480284 No Comments 10/23/2006 ML062960278 1999-1 Radiological Criteria for License Termination of Uranium Recovery Facilities Part 40 64 FR 17506 06/11/2002 Not Applicable Not Applicable Louisiana does not have the authority to regulate this material under its Agreement.

1999-2 Requirements for Those Who Possess Certain Industrial Devices Containing Byproduct Material to Provide Requested Information Part 31 64 FR 42269 10/04/2002 Not Required Not Required These regulations are not required to be adopted for purposes of Compatibility.

1999-3 Respiratory Protection and Controls to Restrict Internal Exposure Part 20 64 FR 54543; 64 FR 55524 02/02/2003 Final ML061720127 No Comments 07/27/2006 ML062120471 2000-1 Energy Compensation Sources for Well Logging and Other Regulatory Clarifications Part 39 65 FR 20337 05/17/2003 Final ML080800500 No Comments 04/14/2008 ML081050467

7 RATS ID NRC Chronology Identification Date Due for State Adoption Incoming Letter Outgoing Package Notes 2000-2 New Dosimetry Technology Parts 34, 36 and 39 65 FR 63750 01/08/2004 Final ML041880305 No Comments 08/26/2004 ML042390322 2001-1 Requirements for Certain Generally Licensed Industrial Devices Containing Byproduct Material Parts 30, 31 and 32 65 FR 79162 02/16/2004 Final ML14083A568 No Comments 06/12/2014 ML14083A554 2002-1 Revision of the Skin Dose Limit Part 20 67 FR 16298 04/05/2005 Final ML062480284 No Comments 11/27/2006 ML063180075 2002-2 Medical Use of Byproduct Material Parts 20, 32 and 35 67 FR 20249 10/24/2005 Final ML061720127 No Comments 07/27/2006 ML062120471 2003-1 Financial Assurance for Materials Licensees Parts 30, 40 and 70 68 FR 57327 12/03/2006 Final ML062480284 No Comments 10/23/2006 ML062960278 2004-1 Compatibility With IAEA Transportation Safety Standards and Other Transportation Safety Amendments Part 71 69 FR 3697 10/01/2007 Final ML090480013 No Comments 04/01/2009 ML090710728 2005-1 Security Requirements for Portable Gauges Containing Byproduct Material Part 30 70 FR 2001 07/11/2008 Final ML081080146 No Comments 05/29/2008 ML081500119 2005-2 Medical Use of Byproduct Material - Recognition of Specialty Boards Part 35 70 FR 16336; 71 FR 1926 04/29/2008 Final ML090480013 No Comments 04/01/2009 ML090710728

8 RATS ID NRC Chronology Identification Date Due for State Adoption Incoming Letter Outgoing Package Notes 2005-3 Increased Controls for Risk-Significant Radioactive Sources (NRC Order EA-05-090) 70 FR 72128 12/01/2005 License Condition ML052900105 No Comments 10/20/2005 ML052930327 2006-1 Minor Amendments Parts 20, 30, 32, 35, 40 and 70 71 FR 15005 03/27/2009 Final ML14266A408 No Comments 11/19/2014 ML14266A336 2006-2 National Source Tracking System - Serialization Requirements Part 32 with reference to Part 20 Appendix E 71 FR 65685 02/06/2007 Final ML080800500 No Comments 04/14/2008 ML081050467 2006-3 National Source Tracking System Part 20 71 FR 65685, 72 FR 59162 01/31/2009 Final ML080800500 No Comments 04/14/2008 ML081050467 2007-1 Medical Use of Byproduct Material - Minor Corrections and Clarifications Parts 32 and 35 72 FR 45147, 54207 10/29/2010 Final ML14083A603 No Comments 07/29/2014 ML14083A595 2007-2 Exemptions From Licensing, General Licenses, and Distribution of Byproduct Material: Licensing and Reporting Requirements Parts 30, 31, 32 and 150 72 FR 58473 12/17/2010 Final ML14266A408 No Comments 11/19/2014 ML14266A336

9 RATS ID NRC Chronology Identification Date Due for State Adoption Incoming Letter Outgoing Package Notes 2007-3 Requirements for Expanded Definition of Byproduct Material Parts 20, 30, 31, 32, 33, 35, 61 and 150 72 FR 55864 11/30/2010 Final ML14083A603 Proposed Revision to Final ML14364A230 Revised Final ML15212A809 Comments 07/29/2014 ML14083A595 Comments 01/29/2015 ML14364A226 No Comments 08/31/2015 ML15212A806 2007-4 Order Imposing Fingerprinting Requirements and Criminal History Records Check Requirements for Unescorted Access to Certain Radioactive Material NRC Order EA-07-305 72 FR 70901 06/05/2008 License Condition ML080800499 No Comments 03/27/2008 Ml080870350 2008-1 Occupational Dose Records, Labeling Containers, and Total Effective Dose Equivalent Parts 19 and 20 72 FR 68043 02/15/2011 Final ML14266A408 No Comments 11/19/2014 ML14266A336 2009-1 Medical Use of Byproduct Material - Authorized User Clarification Part 35 74 FR 33901 09/28/2012 Final ML14266A408 No Comments 11/19/2014 ML14266A336 2011-1 Decommissioning Planning Parts 20, 30, 40 and 70 76 FR 35512 12/17/2015 Proposed ML15054A380 Final ML15300A512 No Comments 03/12/2015 ML15054A372 No Comments 11/18/2015 ML15300A511

10 RATS ID NRC Chronology Identification Date Due for State Adoption Incoming Letter Outgoing Package Notes 2011-2 Licenses, Certifications, and Approvals for Materials Licensees Parts 30, 36, 39, 40, 70 and 150 76 FR 56951 11/14/2014 Final ML15021A524 No Comments 02/19/2015 ML15021A520 2012-1 Change of Compatibility Parts 31.5 and 31.6 (See RATS ID: 2001-1 for Rule text) 77 FR 3640 01/25/2015 Final ML14083A568 No Comments 06/12/2014 ML14083A554 2012-2 Advance Notification to Native American Tribes of Transportation of Certain Types of Nuclear Waste Part 71 77 FR 34194 08/10/2015 Final ML15021A524 No Comments 02/19/2015 ML15021A520 2012-3 Technical Corrections Parts 30, 34, 40 and 71 77 FR 39899 08/06/2015 Final ML15021A524 No Comments 02/19/2015 ML15021A520 2012-4 Requirements for Distribution of Byproduct Material Parts 30, 31, 32, 40 and 70 77 FR 43666 10/23/2015 Proposed ML14364A230 Final ML15212A809 Comments 01/29/2015 ML14364A226 No Comments 08/31/2015 ML15212A806

11 RATS ID NRC Chronology Identification Date Due for State Adoption Incoming Letter Outgoing Package Notes 2013-1 Physical Protection of Byproduct Material, Parts 20, 30, 32, 33, 34, 35, 36, 37, 39 and 71 78 FR 16922 03/19/2016 Proposed ML15126A361 Final ML16012A155 Revised Final ML18183A438 No Comments 06/11/2015 ML15124A889 Comment 02/05/2016 ML16012A148 No Comments 08/03/2018 ML18183A434 2013-2 Distribution of Source Material to Exempt Persons and to General Licensees and Revision of General License and Exemptions Parts 30, 40 and 70 78 FR 32310 08/27/2016 Proposed ML15126A361 Final ML16012A155 No Comments 06/11/2015 ML15124A889 No Comments 02/05/2016 ML16012A148 2015-1 Domestic Licensing of Special Nuclear Material -

Written Reports and Clarifying Amendments Part 70 79 FR 57721, 80 FR 143 01/26/2018 Proposed ML15126A361 Final ML16012A155 No Comments 06/11/2015 ML15124A889 No Comments 02/05/16 ML16012A148

12 RATS ID NRC Chronology Identification Date Due for State Adoption Incoming Letter Outgoing Package Notes 2015-2 Safeguards Information - Modified Handling Categorization, Change for Materials Facilities Parts 30, 37, 73 and 150 79 FR 58664, 80 FR 3865 01/28/2018 Proposed ML15126A361 Final ML16012A155 Revised Final ML18183A438 No Comments 06/11/2015 ML15124A889 Comment 02/05/16 ML16012A148 No Comments 08/03/2018 ML18183A434 2015-3 Revisions to Transportation Safety Requirements and Harmonization with International Atomic Energy Agency Transportation Requirements Part 71 80 FR 33987 07/13/2018

• extended to 08/15/2020 See STC 17-060 2015-4 Miscellaneous Corrections Parts 37 and 40 80 FR 45841 09/02/2018 Proposed ML18183A438 No Comments 08/03/2018 ML18183A434 2015-5 Miscellaneous Corrections Parts 19, 20, 30, 32, 37, 40, 61, 70, 71 and 150 80 FR 74974 12/31/2018 Proposed ML18183A438 No Comments 08/03/2018 ML18183A434 2018-1 Medical Use of Byproduct Material - Medical Event Definitions, Training and Experience, and Clarifying Amendments, Parts 30, 32 and 35 01/14/2022

• NA 10 CFR Part 34 NA Proposed ML18324A731 Comments 01/18/2019 ML18324A728

13 1 IMPEP Team: verify that Louisiana does not have any licensees subject to these regulations during each review.