ML19106A430

NRC Region IV Response to 2019 Impep Questionnaire

ML19106A430
Person / Time
Issue date:	03/27/2019
From:	Rachel Browder Division of Nuclear Materials Safety IV
To:	Lance Rakovan NRC/NMSS/DMSST/FSTB
Rakovan L
References
Download: ML19106A430 (25)

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From: IMPEP Resource To: IMPEP Resource

Subject:

RIV DNMS Revised Response Letter to IMPEP Questionnaire Date: Tuesday, April 16, 2019 4:36:10 PM Attachments: RIV DNMS 2019 IMPEP Response Letter with Attachments - dated March 27, 2019.pdf From: Browder, Rachel Sent: Wednesday, March 27, 2019 1:04 PM To: Rakovan, Lance <Lance.Rakovan@nrc.gov>; Modes, Kathy <Kathy.Modes@nrc.gov>; White, Duncan <Duncan.White@nrc.gov>

Cc: Pruett, Troy <Troy.Pruett@nrc.gov>; Howell, Linda <Linda.Howell@nrc.gov>

Subject:

FYI: RIV DNMS Revised Response Letter to IMPEP Questionnaire Mr. Rakovan, Please see the attached RIV DNMS revised IMPEP Questionnaire response. Our response was revised based on several questions and clarifications requested by the IMPEP Team prior to the scheduled IMPEP review next week. Please disregard the IMPEP Questionnaire response provided on March 13, 2019.

If there are any questions, please do not hesitate to contact me. We look forward to having you and your team in our offices for the IMPEP review, scheduled April 1-5, 2019.

Sincerely, Rachel Rachel S. Browder, CHP Sr. Health Physicist US NRC, Region IV 1600 East Lamar Blvd.

Arlington, TX 76011-4511 Work: 817-200-1452 Cell: 817-946-4812 Main: 817.860.8100

2019 IMPEP Review NRC Region IV DNMS March 27, 2019

Approved by OMB 1 Control No. 3150-0183 Expires 01/31/2020 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE NRC Region IV Materials Program Reporting Period: May 3, 2014 - April 5, 2019 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.

RESPONSE

Region IV did not have any open recommendations from previous IMPEP reviews. Therefore, there is no response necessary. Region IV DNMS performed several audits during the review period and those audits and the associated corrective actions will be made available to the IMPEP Team during the review, as requested.

B. COMMON PERFORMANCE INDICATORS I. Technical Staffing and Training

2. Please provide organization charts, including names and positions for Region IV and the Division of Nuclear Materials Safety.

RESPONSE

Region IV provided the organization charts in Attachment 1.

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 and uranium recovery program by individual and position.

1Estimated burden per response to comply with this voluntary collection request: 53 hours6.134259e-4 days <br />0.0147 hours <br />8.763227e-5 weeks <br />2.01665e-5 months <br />. Forward comments regarding burden estimate to the Records Management Branch (T-5 F52), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, and to the Paperwork Reduction Project (3150-0183), Office of Management and Budget, Washington, DC 20503. If an information collection does not display a currently valid OMB control number, NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

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RESPONSE

Region IV provided the organization charts in Attachment 1. The internal budget and staffing plan will be made available to the IMPEP Team during the review.

4. Please provide a listing of all new professional personnel hired into your radioactive materials program and uranium recovery 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

Hire Qualifications Name Position Degree Comment Date IMC Date MATERIALS Allyce Health DNMS: Interim: Feb 2019 BS: Nuclear Emergency Bolger Physicist 11/26/17 1248, Engineering, Response App B Rensselaer Coordinator Polytechnic Reactor R1: 1245 May 2013 Institute, NY Allegation /

Inspector 6/19/11 App C1 Enforcement Specialist DECOMMISSIONING Stephanie Health DNMS: 1248, Aug 2018 BS: Electrical Fire Protection Anderson Physicist 7/23/17 App F Engineering, specialty Tuskegee Reactor R1: 1245 C1 May 2013 University, AL Inspector 6/19/11 1245 C2 May 2016 Austin Health DNMS: 1248, (In BA: Math, Rice Naval Nuclear Roberts Physicist 11/12/17 App F Progress) University Power (In Program Progress) MS:

Rx Systems HQ: Engineering Engineer 1/25/15 Management, Old Dominion University Chris DNMS: BS: Nuclear Operations Steely Health 10/1/17 1248, Engineering specialty Oct 2018 Physicist App F Technology, 2

Hire Qualifications Name Position Degree Comment Date IMC Date R4: Thomas Edison Reactor 7/20/08 1245, C1 May 2010 State Inspector University, NJ License 1245, Examiner C10 Jan 2010 Naval Nuclear (Examiner) Power Nov 2010 Program (Chief Examiner)

Richard Health DNMS: 1248, On Active BS: Physics, Kaiser Physicist 12/29/2014 App F Military Northwestern Duty: State University of 2/3/2015 - Louisiana.

3/17/2016 MS: Physics, 2/23/2017 - University of Present Texas at Arlington

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

RESPONSE: Following is a summary of the staff who are in progress of their qualification requirements.

Allyce Bolger started in Region IV DNMS on November 26, 2017. She started her Manual Chapter 1248, Appendix F, Decommissioning qualification and changed to Appendix B, Materials Inspector qualification program, based on staff resources in the Division. On February 22, 2019, she obtained her interim qualification under Appendix B, for certain program codes. She lacks several OJTs for other program code modalities. It is anticipated that once those inspections are completed, shell obtain her full qualification in March 2020.

Austin Roberts started Region IV DNMS on November 12, 2017. He started Manual Chapter 1248, Appendix F, Decommissioning qualification. Two training courses remain, along with an inspector accompaniment of a complex materials facility and some ISAs. The two courses include the following:

• Gathering Information through Inspections (Course 135) - scheduled for April 15-16 at PDC

• Environmental Monitoring for Radioactivity (H-111) - scheduled for April 29-May 3 at ORAU Tentative completion of his full qualification is expected by July 2019.

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Martha Poston-Brown has been in the Region IV DNMS office and is qualified as an inspector in multiple areas. Her most recent cross-qualification is IMC 1248, Appendix F, Decommissioning. She plans to perform her OJT at Ft. Calhoun Station (Reactor Decommissioning) in May 2019. Once completed, shell obtain her full qualification.

Richard Kaiser started in Region IV DNMS on December 29, 2014. He started his Manual Chapter 1248 training; however, he was called to active military duty from 2/3/2015 - 3/17/2016 and again from 2/23/2017 - Present. He was extended for another year starting January 2019. It is unknown when he will return to the office.

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

RESPONSE

Region IV implements the NRC qualification program, which is available under the respective manual chapter on the NRC public website. No action is required by the Region IV office.

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

RESPONSE

Region IV provided the technical staff that left the program in the organization charts in Attachment 1. In addition, a summary is provided below.

Name, Title Date Left DNMS Tony Gaines, Sr. HP, Materials Inspector May 30, 2015 Lizette, Roldan, Health Physicist May 2015 Rick Munoz, HP, Materials Inspector January 9, 2016 Pete Hernandez, HP, Materials Inspector in training April 2018 Casey Alldredge, HP, License Reviewer in training October 2016 Gerry Schlapper, HP, Decommissioning March 31, 2017 Don Stearns, HP, Decommissioning April 29, 2017 Bernadette Baca, HP, Uranium Recovery October 1, 2018 On rotation for 1 year Binesh Tharakan, Health Physicist (SAO)

(Oct 2018 - Oct 2019) 4

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.

RESPONSE

Region IV provided the organizational charts in Attachment 1, which captures the vacancies during the review period. In addition, the budgeted FTE and staffing levels for RIV DNMS will be made available to the Team during the IMPEP review, along with a brief synopsis of the vacancies between 2014-2019.

II. Status of Materials Inspection Program

10. Please identify individual licensees or categories of licensees the Region is inspecting less frequently than called for in NRCs Inspection Manual Chapter (IMC) 2800 and for uranium recovery, 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

For Materials Program under IMC 2800, Region IV inspects facilities at the frequency described in the manual and has not modified the frequency.

For Uranium Program under IMC 2641 for in-situ leach facilities, and IMC 2801 for decommissioning uranium sites, Region IV currently inspects at the frequency described in the manual and has implemented a process to document any changes to the inspection frequency. In addition, the Division is pursuing further clarifications for certain types of facilities described in the manual. Further specifics are provided below.

• Facilities that have licenses but have not started any construction activities, have not been inspected and the IMC 2641 does not specify when pre-operation or initial inspections must be performed. Going forward, the Region IV Divisional office will contact the licensee annually and document the status of the facility in order to determine when to start inspection activities. In addition, feedback form for IMC 2641 will be provided to the Program Office to further clarify this process.

• The decision to reschedule or postpone inspections for operating and decommissioning uranium facilities due to the status of licensee activities, weather, Region IV Divisional office staffing and workload, will be documented in an internal Memo approved by management, as specified in each of the IMCs.

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.

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RESPONSE

The information for materials licensees is available in WBL. No action required by Region IV.

Please see the following summary for Uranium recovery data. The detailed inspection information will be made available during the review. In addition, the master inspection plans (MIPs) generated for each year, will be made available during the IMPEP review.

URANIUM RECOVERY DATA FISCAL YEAR Total number of Number of overdue inspections reports 2014 (since May 2014) 7 5 2015 7 3 2016 18 0 2017 11 2 2018 14 1 TOTAL 57 11

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

RESPONSE

The information for materials licensees is available in WBL. No action required by Region IV.

The summary of Uranium Recovery inspections conducted overdue is available in Attachment 2.

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.

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RESPONSE

The information for materials licensees is available in WBL. There are no specific licensees that are overdue for routine inspections based on the criteria under IMC 2800. In addition, there are no overdue field office inspections based solely on the calculation criteria under IMC 2800. However, Region IV is making a concerted effort to inspect permanent field office(s) authorized on licenses, starting with Priority 1s, which have never been inspected. Therefore, these inspections could be considered overdue based on IMC 2800 criteria that Inspection of various field offices should be rotated to assess the licensee's entire program over several inspection cycles. Some of the permanent field offices have not been inspected over several inspection cycles. More detailed information on the proposed permanent field office inspections will be available during the INPEP review, as requested.

The information for each Uranium Recovery license will be made available during the IMPEP review. In addition, a summary of the overdue inspections is provided in Attachment 2. During 2018 and 2019, Region IV made a concerted effort to perform all overdue inspections at operating and decommissioning uranium facilities. For those facilities that have a license and have not yet started construction activities, the Region IV Divisional office will contact the licensee annually and document the status of the facility in order to determine when to start inspection activities. This activity is being tracked in a Branch Action Item tracker. In addition, the Region has developed a more detailed Master Inspection Plan to track required inspections under the Uranium and Decommissioning programs.

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

During the past five calendar years, DNMS has only met the required inspection metric of 20% of reciprocity candidates once, in calendar year 2017, and only then by the then-Director instructing that a non-candidate whose inspection resulted in escalated enforcement will be counted towards the 20%. The table below summarizes the Region IVs performance with respect to reciprocity.

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CY Total Inspections Inspections Failed Total  % of Inspections of Pri-5 of Attempted Candidates Candidates (Candidates Candidates Inspections (Inspections and Attempts) (1, 2, 3) (1, 2, 3) & Attempts) 2014 4 1 3 1 44 9.0 2015 5 2 5 0 40 12.5 2016 6 1 7* 0 46 13.0 2017 12 5 8 4 37 32.4 2018 7 2 5 2 36 19.4 thru Oct.

2018** 8 2 5 3 41 19.5

• Did not count one of the inspections as a candidate due to previous inspection performed during 2015.

• • Updated data for 2018 after the Audit was completed.

III. Technical Quality of Inspections

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

RESPONSE

Region IV uses the NRC inspection procedures available on the public website.

No action required by Region IV.

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

Inspector Supervisor License Category Date

RESPONSE

The information for Branch Chief accompaniments of inspectors is available in Attachment 3. In addition, the Region IV Policy Guides applicable to accompaniments will be made available to the IMPEP Team during the review.

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

Region IV maintains an inventory list of instruments available to staff. The Project Manager (Eric Simpson, CHP) for the instrument program has been proactive in ensuring the number and types of instruments are available and calibrated for the nature of radioactive materials encountered in the region to support the reactor, materials, and uranium programs. The inventory list is substantial and will be made available to the IMPEP Team during the review. In addition, the procedures that govern the instrumentation program will also be made available to the IMPEP Team during the review.

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IV. Technical Quality of Licensing Actions

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

RESPONSE

Region IV uses WBL to maintain the specific radioactive material licenses. No action required by Region IV.

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

Please see the following Table for the actions that Region IV identified as major, unusual, or complex. Please note that Headquarters processes all bankruptcy notifications; therefore, those cases are not provided in the following table.

License Docket Control Action Type Licensee Request Number Number Number Complex EPA, Decommissioning 05-14892-02 030-08754 609555 (Amendment) Region 8 University of Complex Alaska, Decommissioning 50-02430-07 030-01179 610951 (Amendment)

Fairbanks Complex CH2M Hill, Inc. New License (D&D) 43-35500-01 030-39123 609565 (New)

New License Complex Adanta, Inc. (D&D) Suspended 04-35485-01 030-39106 602775 (New) for first time New D&D license; Complex Adanta, Inc. Suspended for 04-35509-01 030-39135 610270 (New) second time other service Complex Radiation sources less than 11-35111-01 030-38691 591864 (Amendment) Solutions, LLC or equal to 100 Ci Dept of the Medical Broad Complex Army, William Scope changing to 42-05255-07 030-03260 591759 (Amendment) Beaumont Army limited specific Medical Center Complex Hill AFB, US Air Decommissioning 42-23539-01AF 030-28641 584307 (MML) Force TAR Acuren USA Instadose 50-32443-01 030-38596 594399 TAR DBI, Inc. Instadose 15-29301-02 030-38754 592504 9

License Docket Control Action Type Licensee Request Number Number Number 10 CFR 20.2002 Core 609095 alternate waste TAR Laboratories, 42-26928-01 030-30429 and disposal method Inc. 588388 (ML16020A283)

University of TAR Alaska Decommissioning 50-02430-07 030-01179 590694 Fairbanks Providence TAR HDR 50-17838-01 030-13426 609722 Alaska

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

RESPONSE

Region IV Division did not issue any variances in licensing policies and procedures during the review period. In following the agency's policy under 10 CFR 20.2002, alternate disposal, RIV DNMS licensing issued two exemption letters in 2018 (ML18200A034 and ML18036A715). These two exemptions grant permission to two separate entities to accept for disposal well-logging sandouts and well returns containing residual radioactive materials regulated by the NRC, without requiring an NRC license, based on the 10 CFR 20.2002 authorization granted to ProTechnics Division of Core Laboratories LP (ML18205A454).

The remaining exemptions granted during the review period were under 10 CFR 30.12 exemption requests. Following are the total number of 10 CFR 30.12 exemptions processed in accordance with the guidance provided by the Program Office. Further details are available upon request.

Fiscal Year Total Number of Exemptions Processed FY 2014 10 FY 2015 14 FY 2016 17 FY 2017 35 FY 2018 38 FY 2019 until 1/31/19 13 TOTAL 127

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

RESPONSE

Region IV utilizes the guidance provided in the NUREG-1556 series and the information provided on the Materials Licensees Toolkits on the NRC website.

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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

Region IV summarized the renewals that exceeded one year or more in the Table below. In addition, the Region reviewed and summarized all licensing actions that exceeded the internal processing metric, and will provide the information to the IMPEP Team during the review, as requested.

FY, Action Type Control Number License Docket Licensee Reason For Delay Process Time Number Number There were 72 renewals during FY16, which is a significantly large number of renewals to be performed by 4 fully qualified license reviewers. In addition, the license reviewer was working on FY16, Renewal Providence several working groups throughout 585345 Alaska Medical 50-17838-01 030-13426 the year to support the licensing 454 days Center program.

For this particular renewal, the initial application was incomplete and had to be resubmitted, along with several additional requests for information that delayed the issuance of the license.

There were 72 renewals during FY16, which is a significantly large number of renewals to be performed by 4 fully qualified license reviewers. In addition, the license reviewer was working FY16, Renewal Calumet several working groups throughout 584286 Montana 25-27488-01 030-33433 the year to support the licensing 585 days Refining program.

For this particular renewal, there were a number of requests for additional information and inadequate or delayed responses from the licensee.

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 number 3150-0178).

RESPONSE

Question #23 is not applicable to Region IV.

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

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RESPONSE

Region IV made changes to its procedures for responding to incidents and allegations. The procedures are identified below and will be made available to the IMPEP Team during the review.

• PG 9007B, Reactor Inspection and Licensee Event Report (LER) Guidance for DNMS Staff, dated January 3, 2019

• PG 9007B, Handling of Materials Licensee Event Reports (LERs) by DNMS Staff dated August 26, 2009.

• 0858.16, Management of Allegations, January 14, 2015

• 0858.15, Management of Allegations, May 26, 2014 12

C. NON-COMMON PERFORMANCE INDICATORS I. Compatibility Requirements (Questions 25-28)

II. Sealed Source and Device (SS&D) Evaluation Program (Questions 29-30)

III. Low-Level Radioactive Waste Disposal Program (Question 31)

RESPONSE

The above indicators and associated Questions 25 through 31 are not applicable to Region IV.

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

RESPONSE

The information regarding the Uranium Recovery program data is provided with the above responses.

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ATTACHMENT 2 Uranium Recovery Overdue Inspections

RIV DNMS URANIUM RECOVERY Inspections Overdue Licensee Name License Docket Frequenc Start Date Exit Report Report Report Due Days to Report Date, Last Inspection Due Due Date Inspection Days >30 days for >60 days from Number y (mos.) Meeting Issued Time Date issue Number inspection/ Date (includes Overdue? Inspection Report Issued (or Onsite Date to Date Requir report license grace period) was 45 days for Team Report Issued ement issuance Overdue statement)?

Power Resources, SUA-1548 040-08964 6 05/20/14 05/22/14 08/01/14 30 06/21/14 71 2014-001 09/09/13 03/09/14 04/09/14 YES 41 YES YES Inc. Smith Ranch Uranerz Energy SUA-1597 040-09067 6 06/23/14 06/24/14 09/26/14 30 07/24/14 94 2014-001 11/18/13 05/18/14 06/18/14 YES 5 YES YES Corp. Nichols Ranch Ur-Energy USA Lost SUA-1598 040-09068 6 01/27/15 08/20/15 09/11/15 45 10/04/15 22 2015-001 06/25/14 12/25/14 01/25/15 YES 2 NO YES Creek ISR, LLC Uranerz Energy SUA-1597 040-09067 6 03/17/15 03/18/15 09/29/15 45 05/02/15 195 2015-001 06/23/14 12/23/14 01/23/15 YES 53 YES YES Corp. Nichols Ranch Power Resources, SUA-1548 040-08964 6 04/14/15 04/16/15 07/14/15 45 05/31/15 89 2015-001 05/20/14 11/20/14 12/20/14 YES 115 YES YES Inc. Smith Ranch Uranium One-Willow SUA-1341 040-08502 6 05/27/15 07/13/15 08/07/15 30 08/12/15 25 2015-001 09/23/14 03/23/15 04/23/15 YES 34 NO YES Creek Ur-Energy USA Lost SUA-1598 040-09068 6 12/01/15 12/29/15 01/07/16 30 01/28/16 9 2015-002 01/27/15 07/27/15 08/27/15 YES 96 NO NO Creek ISR, LLC Uranerz Energy SUA-1597 040-09067 6 01/25/16 01/28/16 02/26/16 45 03/13/16 29 2016-001 03/17/15 09/17/15 10/17/15 YES 100 NO NO Corp. Nichols Ranch Cameco Crow Butte SUA-1534 040-08943 12 03/08/16 03/17/16 04/12/16 30 04/16/16 26 2016-001 06/03/14 06/03/15 09/03/15 YES 187 NO NO Resources Power Resources, SUA-1548 040-08964 6 06/21/16 10/25/16 11/23/16 30 11/24/16 29 2016-001 04/14/15 10/14/15 11/14/15 YES 220 NO YES Inc. Smith Ranch Uranium One-Willow SUA-1341 040-08502 6 07/26/16 07/28/16 08/26/16 30 08/27/16 29 2016-001 05/27/15 11/27/15 12/27/15 YES 212 NO NO Creek UNC Church Rock SUA-1475 040-08907 24 08/16/16 08/16/16 09/07/16 30 09/15/16 22 2016-001 07/18/13 07/18/15 01/18/16 YES 211 NO NO Kennecott Energy-SUA-1350 040-08584 24 09/20/16 09/20/16 10/03/16 30 10/20/16 13 2016-001 08/28/13 08/28/15 02/28/16 YES 205 NO NO Sweetwater

RIV DNMS URANIUM RECOVERY Inspections Overdue Licensee Name License Docket Frequenc Start Date Exit Report Report Report Due Days to Report Date, Last Inspection Due Due Date Inspection Days >30 days for >60 days from Number y (mos.) Meeting Issued Time Date issue Number inspection/ Date (includes Overdue? Inspection Report Issued (or Onsite Date to Date Requir report license grace period) was 45 days for Team Report Issued ement issuance Overdue statement)?

Pathfinder Shirley SUA-442 040-06622 24 09/21/16 09/21/16 10/19/16 30 10/21/16 28 2016-001 09/25/13 09/25/15 03/25/16 YES 180 NO NO Basin ExxonMobil SUA-1139 040-08102 24 09/22/16 09/22/16 10/21/16 30 10/22/16 29 2016-001 09/24/13 09/24/15 03/24/16 YES 182 NO NO Highland Ur-Energy USA Lost SUA-1598 040-09068 6 09/27/16 11/22/16 12/21/16 45 01/06/17 29 2016-001 12/01/15 06/01/16 07/01/16 YES 88 NO YES Creek ISR, LLC Strata Energy, Inc.

SUA-1601 040-09091 6 01/31/17 02/02/17 03/02/17 30 03/04/17 28 2017-002 06/07/16 12/07/16 01/07/17 YES 24 NO NO Ross Homestake Mining SUA-1471 040-08903 6 04/24/17 06/12/17 07/07/17 30 07/12/17 25 2017-001 08/24/16 02/24/17 03/24/17 YES 31 NO YES Ur-Energy USA Lost SUA-1598 040-09068 6 05/23/17 07/06/17 08/04/17 30 08/05/17 29 2017-001 09/27/16 03/27/17 04/27/17 YES 26 NO YES Creek ISR, LLC Cameco Crow Butte SUA-1534 040-08943 12 06/20/17 06/22/17 07/19/17 30 07/22/17 27 2017-001 03/08/16 03/08/17 06/08/17 YES 12 NO NO Resources Ur-Energy USA Lost SUA-1598 040-09068 6 05/22/18 05/24/18 06/22/18 30 06/23/18 29 2018-001 10/17/17 04/17/18 05/17/18 YES 5 NO NO Creek ISR, LLC Power Resources, SUA-1548 040-08964 6 06/25/18 06/28/18 07/27/18 30 07/28/18 29 2018-001 11/14/17 05/14/18 06/14/18 YES 11 NO NO Inc. Smith Ranch UMETCO - Gas Hills SUA-648 040-00299 24 08/28/18 08/28/18 09/21/18 30 09/27/18 24 2018-001 06/05/12 06/05/14 12/05/14 YES 1362 NO Western Nuclear -

SUA-56 040-01162 24 08/28/18 08/28/18 09/18/18 30 09/27/18 21 2018-001 05/05/10 05/05/12 11/05/12 YES 2122 NO Split Rock Pathfinder Lucky SUA-672 040-02259 24 08/28/18 08/28/18 09/19/18 30 09/27/18 22 2018-001 05/04/10 05/04/12 11/04/12 YES 2123 NO NO MC Anadarko Bear SUA-1310 040-08452 24 08/31/18 08/31/18 09/26/18 30 09/30/18 26 2018-001 09/22/08 09/22/10 03/22/11 YES 2719 NO Creek

RIV DNMS URANIUM RECOVERY Inspections Overdue Licensee Name License Docket Frequenc Start Date Exit Report Report Report Due Days to Report Date, Last Inspection Due Due Date Inspection Days >30 days for >60 days from Number y (mos.) Meeting Issued Time Date issue Number inspection/ Date (includes Overdue? Inspection Report Issued (or Onsite Date to Date Requir report license grace period) was 45 days for Team Report Issued ement issuance Overdue statement)?

Cameco Crow Butte SUA-1534 040-08943 12 11/05/18 11/08/18 12/06/18 30 12/08/18 28 2018-001 06/20/17 06/20/18 09/20/18 YES 46 NO NO Resources ANC-Gas Hills SUA-667 040-04492 24 01/22/19 03/01/19 30 03/31/19 05/02/07 05/02/09 11/02/09 YES 3368 n/a NO Hydro Resources SUA-1580 040-08968 12 01/00/00 01/05/98 01/05/99 04/05/99 n/a NO Crownpoint Uranium One-SUA-1596 040-09073 12 01/00/00 09/30/10 09/30/11 12/30/11 n/a NO Moore Ranch Powertech Dewey SUA-1600 040-09075 12 01/00/00 04/08/14 04/08/15 07/08/15 n/a NO Burdock AUC Reno Creek SUA-1602 040-09092 12 01/00/00 02/17/17 02/17/18 05/17/18 n/a n/a NO

ATTACHMENT 3 Branch Chief Accompaniments

BC Accompaniments of Qualified Inspectors (5 Year Summary)

Inspector Branch Supervisor License Category Date Anderson FCDB Pruett Rx Decomm 7/12/18 Baca FCDB Kellar UR 8/28/17 Browder FCDB Kellar SNM 10/27/15 Browder FCDB Kellar Rx Decomm 3/21/16 Browder FCDB Kellar Rx Decomm 5/9/17 Browder FCDB Pruett Rx Decomm 7/12/18 Dykert MLIB Vasquez Materials 9/14-18/15 Dykert MLIB Shaffer Materials June 2016 Dykert MLIB Hay Materials Nov 2017 Dykert MLIB Hay Materials Jan 2018 Dykert MLIB Pruett Materials 9/27/18 Erickson SAO Shaffer Materials June 2015 Erickson SAO Campbell Materials September 2016 Erickson SAO Thompson Materials 11/14/18 Evans FCDB Vegel Rx Decomm 1/14/14 Evans FCDB Kellar Rx Decomm 9/15/14 Evans FCDB Kellar UR 11/3/15 Evans FCDB Kellar Rx Decomm 2/10/16 Not Evans FCDB Limited inspections - out on sick leave in 2017 Performed Evans FCDB Katanic Complex Decommissioning 11/27/18 Gaines MLIB Vasquez Materials 9/3/14 Gersey FCDB Spitzberg UR 2/27/14 Gersey FCDB Shaffer UR 9/23/14 Gersey FCDB Kellar UR 11/3/15 Not Gersey FCDB Limited Inspections & site visits in 2016 Performed Gersey FCDB Kellar Rx Decomm 11/13/17 Hammond MLIB Whitten Materials 12/8-10/14 Hammond MLIB Whitten Materials Mar 2015 Not Hammond MLIB Only performed one inspection in March 2016 Required Not Hammond MLIB Did not perform any inspections Required Hammond MLIB Hay Materials May 2018 1

BC Accompaniments of Qualified Inspectors (5 Year Summary)

Hanson MLIB Whitten Materials 8/6/14 Hanson MLIB Whitten Materials 6/16/15 Not Hanson MLIB Only performed one inspection in March 2016 Required Not Hanson MLIB Did not perform any inspections in 2017 Required Hanson MLIB Pruett Materials 5/23/18 Katanic MLIB Shaffer Materials 5/12-14/15 Katanic MLIB Kellar Materials 9/6/16 Katanic MLIB Hay Materials Nov 2017 Katanic FCDB Pruett ISFSI / Special 9/10/18 Munoz MLIB Vasquez Materials 9/23/14 Munoz MLIB Vasquez Materials 6/9-10/15 Poston FCDB Vasquez Materials 3/9-13/15 Poston FCDB Kellar Materials 8/15/16 Poston FCDB Kellar UR 8/28/17 Poston FCDB Howell UR 11/5-6/18 Poston FCDB Katanic Complex Decommissioning 11/27/18 Not Roldan MLIB Started performing inspections in June 2014 Performed Not Performed inspections and transferred Roldan MLIB Performed to NMSS in May 2015 Schlapper FCDB Kellar Reactor decom 6/24/14 Schlapper FCDB Kellar ISFSI 7/15/15 Schlapper FCDB Whitten Complex Decommissioning July 2016 Dec 2013 Simmons MLIB Whitten Materials (tracked by FY)

Simmons MLIB Whitten Materials 3/9/15 Simmons MLIB N/A No inspections performed in 2016 Simmons MLIB N/A No inspections performed in 2017 Simmons MLIB Thompson Materials Dec 2018 Stearns MLIB Vasquez Materials 8/5/14 Stearns FCDB Kellar Complex Decommissioning 3/24/15 Stearns FCDB Whitten Complex Decommissioning July 2016 Steely FCDB Katanic Complex Decommissioning 11/27/18 Steely FCDB Pruett Rx Decomm 10/24/18 Thompson MLIB Vasquez Materials 10/3/14 Thompson MLIB Shaffer Materials 1/26-30/15 2

BC Accompaniments of Qualified Inspectors (5 Year Summary)

Thompson MLIB Kellar Materials 6/20-23/16 Thompson MLIB Hay Materials Nov 2017 Thompson MLIB Hay Materials July 2018 Torres MLIB Whitten Materials June 2014 Torres MLIB Whitten Materials - 30.12 3/9-11/15 Torres MLIB Campbell Materials Sept 2016 Not Torres MLIB No inspections performed in 2017 Required Not Torres MLIB No inspections performed in 2018 Required vonEhr MLIB Shaffer Materials April 2017 vonEhr MLIB Pruett Materials July 2018 3

BRANCH CHIEF ACCOMPANIMENT FOR INSPECTORS Inspector Name Branch CY 2014 CY 2015 CY 2016 CY 2017 CY 2018 CY 2019 2020 Anderson, Stephanie FCDB Pruett-July Baca, Bernadette FCDB (In-Training) (In-Training) Kellar-August (Transferred to DRS)

Vegel-January Brookhart, Lee FCDB Spitzberg-February Kellar-July Kellar-December Kellar-December Pruett-May Katanic-January Browder, Rachel FCDB Kellar-October Kellar-March Kellar-May Pruett-July Dykert, Jason MLIB Vasquez / September Shaffer - June Hay / November Hay / January Erickson, Randy DNMS Shaffer / June Campbell - September Thompson / November Vegel - January Not Performed Evans, Rob FCDB Kellar-September Kellar - November Kellar-February (Inspected 1/2 year) Katanic-November Gaines, Tony MLIB Vasquez / September Not Performed Gersey, Linda FCDB Spitzberg-February Kellar-November (Inspected 1/2 year) Kellar-November Not Performed Thompson-February MLIB (Part-time Hammond, Michelle Inspector) Whitten / December Whitten - March (Inspection March '16) Hay / May MLIB (Part-time Hanson, Latischa Inspector) Whitten / August Whitten - June (Inspection March '16) Pruett-May Katanic, Janine MLIB Shaffer - May Kellar /September Hay / Nov 2017 Pruett-September Munoz, Rick MLIB Vasquez / September Vasquez - June Howell-November Poston, Marti FCDB (Rotation to ACES) Vasquez - March Kellar / August Kellar-August Katanic-November Schlapper, Gerry FCDB Kellar-June Kellar-July Whitten - July MLIB (Part-time Whitten / December Simmons, Michelle Inspector) 2013 (tracked by FY) Whitten - March Thompson / December Spitzberg-February Kellar-December Howell - November Pruett/May Simpson, Eric FCDB Vegel-January Kellar-July (tracked by FY) Kellar - December Pruett/September Katanic-January Smith, Chris FCDB Pruett/September Katanic-January Stearns, Don FCDB Vasquez / August Kellar/March Whitten - July Katanic-November Steely, Chris FCDB Pruett-October Thompson, James MLIB Vasquez / October Shaffer-January Kellar / June Hay / November Hay / July MLIB (Part-time Whitten - February Torres, Roberto Inspector) Whitten / June Whitten - March Campbell / September

Inspector Name Branch CY 2014 CY 2015 CY 2016 CY 2017 CY 2018 CY 2019 2020 vonEhr, Jason MLIB Shaffer / April Pruett / July Note: PG 1038 specifies that part-time inspectors should be accompanied every 18 months.

Note: Grey - means not required Page 2 of 2