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.

J. Schuerman 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

J. Schuerman

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 PMichalak PMichalak for:

via email 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- § 34.20i N/A B Performance requirements of

5) (a)(1), (b), (c), industrial radiography equipment (d), & (e)

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, § 34.31 N/A C Inspection and maintenance of and F 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 Enclosure 1

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.

2

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:

3

• § 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 4

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.

5

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 NA NA NA [None]

§ 588 A. (7)

§ 590 E. (3) 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 6

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.

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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 Incoming Outgoing Notes State Adoption Letter Package 1991-1 Safety Requirements for Radiographic Equipment 01/10/1994 Not Required Not Required Louisiana has adopted Final Part 34 Regulations equivalent to RATS ID:

55 FR 843 1997-5.

(Superceded by 1997-5) 1991-2 ASNT Certification of Radiographers none Not Required Not Required Louisiana has adopted Final Part 34 Regulations equivalent to RATS ID:

56 FR 11504 1997-5.

(Superceded by 1997-5) 1991-3 Standards for Protection Against Radiation 01/01/1994 Final No Comments Part 20 ML14266A408 11/19/2014 56 FR 23360; 56 FR 61352; 57 FR 38588; 57 FR ML14266A336 57877; 58 FR 67657; 59 FR 41641; 60 FR 20183; 1991-4 Notification of Incidents 10/15/1994 Final No Comments Parts 20, 30, 31, 34, 39, 40 and 70 ML12361A157 03/29/2013 56 FR 64980; ML13044A340 1992-1 Quality Management Program and 01/27/1995 Not Required Not Required Louisiana has adopted Final Misadministrations Regulations equivalent to RATS ID:

Part 35 2002-2.

56 FR 34104 (Superceded by 2002-2) 1992-2 Eliminating the Recordkeeping Requirements none Not Required Not Required These regulations are not required for Departures from Manufacturer's Instructions to be adopted for purposes of Parts 30 and 35 Compatibility.

57 FR 45566 Enclosure 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1993-1 Decommissioning Recordkeeping and License 10/25/1996 Final No Comments Termination: Documentation Additions [Restricted ML12361A157 03/29/2013 areas and spill sites] ML13044A340 Parts 30 and 40 58 FR 39628 1993-2 Licensing and Radiation Safety Requirements for 07/01/1996 Not Applicable1 Not Applicable Louisiana does not have any Irradiators licensees subject to these Part 36 regulations. (See SECY-95-112) 58 FR 7715 1993-3 Definition of Land Disposal and Waste Site QA 07/22/1996 Not Applicable1 Not Applicable Louisiana does not have any Program licensees subject to these Part 61 regulations. (See SECY-95-112) 58 FR 33886 1994-1 Self-Guarantee as an Additional Financial none Not Required Not Required These regulations are not required Mechanism to be adopted for purposes of Parts 30, 40 and 70 Compatibility.

58 FR 68726; 59 FR 1618 1994-2 Uranium Mill Tailings Regulations: Conforming 07/01/1997 Not Applicable Not Applicable Louisiana does not have authority NRC Requirements to EPA Standards to regulate this material under its Part 40 Agreement.

59 FR 28220 1994-3 Timeliness in Decommissioning Material Facilities 08/15/1997 Final No Comments Parts 30, 40 and 70 01/06/1999 59 FR 36026 1995-1 Preparation, Transfer for Commercial Distribution, 01/01/1998 Final No Comments and Use of Byproduct Material for Medical Use 01/06/1999 Parts 30, 32 and 35 59 FR 61767; 59 FR 65243; 60 FR 322 2

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

Part 34 1997-5.

60 FR 28323 (Superceded by 1997-5) 1995-5 Radiation Protection Requirements: Amended 08/14/1998 Final No Comments Definitions and Criteria 01/06/1999 Parts 19 and 20 60 FR 36038 1995-6 Clarification of Decommissioning Funding 11/24/1998 Final No Comments Requirements 01/06/1999 Parts 30, 40 and 70 60 FR 38235 1995-7 Medical Administration of Radiation and Radioactive 10/20/1998 Final No Comments Louisiana has not yet adopted Final Materials 01/06/1999 Regulations equivalent to RATS ID:

Parts 20 and 35 2005-2.

60 FR 48623 (Superceded by 2002-2 and 2005-2) 1996-1 Compatibility with the International Atomic Energy 04/01/1999 Final No Comments Louisiana has not yet adopted Final Agency ML020280299 02/15/2002 Regulations equivalent to RATS ID:

Part 71 ML020460125 2004-1.

60 FR 50248; 61 FR 28724 (Superceded by 2004-1) 3

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

61 FR 1109 1996-3 Termination or Transfer of Licensed Activities: 06/17/1999 Final No Comments Recordkeeping Requirements ML12361A157 03/29/2013 Parts 20, 30, 40, 61 and 70 ML13044A340 61 FR 24669 1997-1 Resolution of Dual Regulation of Airborne Effluents 01/9/2000 Final No Comments of Radioactive Materials; Clean Air Act ML011510385 11/15/2001 Part 20 ML013100191 61 FR 65120 1997-2 Recognition of Agreement State Licenses in Areas 02/27/2000 Final No Comments Under Exclusive Federal Jurisdiction Within an ML011510385 11/15/2001 Agreement State ML013100191 Part 150 62 FR 1662 1997-3 Criteria for the Release of Individuals Administered 05/29/2000 Final No Comments Radioactive Material 01/06/1999 Parts 20 and 35 62 FR 4120 1997-4 Fissile Material Shipments and Exemptions 02/10/2000 Not Required Not Required These regulations are not required Part 71 to be adopted for purposes of 62 FR 5907 Compatibility. (See STP-97-078)

(Superceded by 2004-1) 4

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

63 FR 29535 1998-3 License Term for Medical Use Licenses 07/10/2001 Not Required Not Required These regulations are not required Part 35 to be adopted for purposes of 63 FR 31604 Compatibility. (See STP-98-074)

(Superceded by 2002-2) Louisiana has adopted Final Regulations equivalent to RATS ID:

2002-2.

5

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

64 FR 17506 1999-2 Requirements for Those Who Possess Certain 10/04/2002 Not Required Not Required These regulations are not required Industrial Devices Containing Byproduct Material to to be adopted for purposes of Provide Requested Information Compatibility.

Part 31 64 FR 42269 1999-3 Respiratory Protection and Controls to Restrict 02/02/2003 Final No Comments Internal Exposure ML061720127 07/27/2006 Part 20 ML062120471 64 FR 54543; 64 FR 55524 2000-1 Energy Compensation Sources for Well Logging 05/17/2003 Final No Comments and Other Regulatory Clarifications ML080800500 04/14/2008 Part 39 ML081050467 65 FR 20337 6

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

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

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

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

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2013-1 Physical Protection of Byproduct Material, 03/19/2016 Proposed No Comments Parts 20, 30, 32, 33, 34, 35, 36, 37, 39 and 71 ML15126A361 06/11/2015 78 FR 16922 ML15124A889 Final Comment ML16012A155 02/05/2016 ML16012A148 Revised Final No Comments ML18183A438 08/03/2018 ML18183A434 2013-2 Distribution of Source Material to Exempt Persons 08/27/2016 Proposed No Comments and to General Licensees and Revision of ML15126A361 06/11/2015 General License and Exemptions ML15124A889 Parts 30, 40 and 70 78 FR 32310 Final No Comments ML16012A155 02/05/2016 ML16012A148 2015-1 Domestic Licensing of Special Nuclear Material - 01/26/2018 Proposed No Comments Written Reports and Clarifying Amendments ML15126A361 06/11/2015 Part 70 ML15124A889 79 FR 57721, 80 FR 143 Final No Comments ML16012A155 02/05/16 ML16012A148 11

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2015-2 Safeguards Information - Modified Handling 01/28/2018 Proposed No Comments Categorization, Change for Materials Facilities ML15126A361 06/11/2015 Parts 30, 37, 73 and 150 ML15124A889 79 FR 58664, 80 FR 3865 Final Comment ML16012A155 02/05/16 ML16012A148 Revised Final No Comments ML18183A438 08/03/2018 ML18183A434 2015-3 Revisions to Transportation Safety Requirements 07/13/2018 and Harmonization with International Atomic *extended to Energy Agency Transportation Requirements 08/15/2020 Part 71 See STC 17-060 80 FR 33987 2015-4 Miscellaneous Corrections 09/02/2018 Proposed No Comments Parts 37 and 40 ML18183A438 08/03/2018 80 FR 45841 ML18183A434 2015-5 Miscellaneous Corrections 12/31/2018 Proposed No Comments Parts 19, 20, 30, 32, 37, 40, 61, 70, 71 and 150 ML18183A438 08/03/2018 80 FR 74974 ML18183A434 2018-1 Medical Use of Byproduct Material - Medical Event 01/14/2022 Definitions, Training and Experience, and Clarifying Amendments, Parts 30, 32 and 35

• NA 10 CFR Part 34 NA Proposed Comments ML18324A731 01/18/2019 ML18324A728 12

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

13