ML19219A122

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Letter to G. Perez California Impep Scheduling Letter and Questionnaire for October 2019
ML19219A122
Person / Time
Issue date: 08/07/2019
From: Lance Rakovan
NRC/NMSS/DMSST/FSTB
To: Perez G
State of CA, Dept of Health Services
Rakovan L
References
OMB 3150-0183
Download: ML19219A122 (26)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 7, 2019 Gonzalo L. Perez, Branch Chief Radiologic Health Branch Division of Food, Drug & Radiation Safety Department of Health Services P.O. Box 997414, MS-7610 Sacramento, CA 95899-7414

Dear Mr. Hyland:

The U.S. Nuclear Regulatory Commission (NRC) uses the Integrated Materials Performance Evaluation Program (IMPEP) for the evaluation of Agreement State programs. Per our previous interaction, I will be the team leader for the IMPEP review of the California Agreement State Program scheduled for October 21-25, 2019. The review team will include: Randy Erickson and Latischa Hanson, NRC Region IV; Shawn Seeley, NRC Region I; Ryan Craffey; NRC Region III; Lisa Forney, Commonwealth of Pennsylvania; and Jim Pate, State of Louisiana.

Enclosed is the Integrated Materials Performance Evaluation Program Questionnaire. The questionnaire was previously provided to you electronically on July 30, 2019. I ask that you send your responses via e-mail to lance. rakovan@nrc.gov by October 7, 2019. I previously sent the questionnaire in advance of this IMPEP review scheduling letter in order to provide time for you to allocate the staff resources necessary to complete the document by the requested date. I encourage you to use electronic documents and provide them in advance of the review to the extent possible, to allow team members to better prepare for the onsite review.

Also included with the questionnaire is the document Materials Requested to Be Available for the On-Site Portion of an IMPEP Review. We encourage States to have the items listed prepared prior to the IMPEP teams arrival.

I request that you set up an appointment with the appropriate State Senior Managers to discuss the results of the IMPEP review of the Maine Agreement State Program on October 25, 2019.

If you have any questions, please call me at 301-415-2589.

Sincerely,

/RA/

Lance J. Rakovan State, Federal & Tribal Liaison Project Manager Materials Safety and Tribal Liaison Branch Division of Materials Safety, Security, State and Tribal Programs Office of Nuclear Materials Safety and Safeguards

Enclosure:

IMPEP Questionnaire

SUBJECT:

California FY2020 IMPEP Scheduling Letter and Questionnaire Distribution:

RJohnson, NMSS LRoldan-Otero, NMSS PMichalak, NMSS RErickson, RIV LHanson, RIV SSeeley, RI RCraffey, RIII LForney, PA JPate, LA State of CA ML19219A122 OFFICE IMPEP Admin Coord TL NAME KMeyer LRakovan via email DATE 08/07/19 08/07/19 OFFICIAL COPY

Approved by OMB1 Control No. 3150-0183 Expires 01/31/2020 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE Reporting Period: October 10, 2015 - October 25, 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.

B. COMMON PERFORMANCE INDICATORS I. Technical Staffing and Training

2. Please provide the following organization charts, including names and positions:

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

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%

Enclosure 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.

4. Please provide a listing of all new professional personnel hired into your radioactive materials program since the last review, indicate the date of hire; the degree(s) they received, if applicable; additional training; and years of experience in health physics or other disciplines, as appropriate.
5. Please list all professional staff who have not yet met the qualification requirements for a radioactive materials license reviewer or inspector. For each, list the courses or equivalent training/experience they need and a tentative schedule for completion of these requirements.
6. Identify any changes to your qualification and training procedure that occurred during the review period.
7. Please identify the technical staff that left your radioactive materials program during the review period and indicate the date they left.
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.
9. For Agreement States, does your program have an oversight board or committee that 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.

II. Status of Materials Inspection Program

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

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.
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

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.
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.

III. Technical Quality of Inspections

15. What, if any, changes were made to your written inspection procedures during the reporting period?
16. Prepare a table showing the number and types of supervisory accompaniments made during the review period. Include:

Inspector Supervisor License Category Date

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?

IV. Technical Quality of Licensing Actions

18. How many specific radioactive material licenses does your program regulate at this time?
19. Please identify any major, unusual, or complex licenses that were issued, received a major amendment, were terminated, decommissioned, submitted a bankruptcy notification or renewed in this period.
20. Discuss any variances in licensing policies and procedures or exemptions from the regulations granted during the review period.
21. What, if any, changes were made in your written licensing procedures (new procedures, updates, policy memoranda, etc.) during the reporting period?
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.

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). The list should be in the following format:

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

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

C. NON-COMMON PERFORMANCE INDICATORS I. Compatibility Requirements

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

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

26. Are your regulations subject to a "Sunset" or equivalent law? If so, explain and include the next expiration date for your regulations.
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.
28. If you have not adopted all amendments within 3 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.

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

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

Technical Staffing and Training - Questions 2-9 Technical Quality of Licensing Actions - Questions 18-22 Technical Quality of Incident and Allegation Activities - Questions 23-24

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 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

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
  • 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,
  • Instrument calibration records severity levels, civil penalties (as applicable)
  • Inspection procedures and guides
  • Job descriptions
  • Inspection report forms

STATE REGULATION STATUS State: California Tracking Ticket Number:

Date:

[ # 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 California 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 California 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 ML020030346 03/18/2002 56 FR 23360; 56 FR 61352; 57 FR 38588; 57 FR ML020780186 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 04/01/1998 56 FR 64980 1992-1 Quality Management Program and 01/27/1995 Final No Comments Misadministrations ML103050179 01/05/2011 Part 35 ML103340424 56 FR 34104 (Superceded by 2002-2)

Enclosure

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1992-2 Eliminating the Recordkeeping Requirements none Not Required Not Required These regulation changes are not for Departures from Manufacturer's Instructions required to be adopted for purposes Parts 30, 35 of Compatibility.

57 FR 45566 1993-1 Decommissioning Recordkeeping and License 10/25/1996 Final No Comments Termination: Documentation Additions [Restricted ML112970300 01/20/2012 areas and spill sites] ML113330808 Parts 30 and 40 58 FR 39628 1993-2 Licensing and Radiation Safety Requirements for 07/01/1996 License Condition No Comments Irradiators ML051670371 07/01/2005 Part 36 ML051810407 58 FR 7715 1993-3 Definition of Land Disposal and Waste Site QA 07/22/1996 Not Applicablei Not Applicable California 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 Final No Comments These regulation changes are not Mechanism 04/01/1998 required to be adopted for purposes Parts 30, 40 and 70 of Compatibility.

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

59 FR 28220 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package Final Comments 1994-3 Timeliness in Decommissioning Material Facilities 08/15/1997 ML16034A230 05/24/16 Parts 30, 40 and 70 ML16034A225 59 FR 36026 1995-1 Preparation, Transfer for Commercial Distribution, 01/01/1998 Final No Comments and Use of Byproduct Material for Medical Use 11/16/1999 Parts 30, 32 and 35 59 FR 61767; 59 FR 65243; 60 FR 322 1995-2 Frequency of Medical Examinations for Use of 03/13/1998 Final No Comments Respiratory Protection Equipment ML020030346 03/18/2002 Part 20 ML020780186 60 FR 7900 1995-3 Low-Level Waste Shipment Manifest Information 03/01/1998 Final No Comments and Reporting ML020030346 03/18/2002 Parts 20 and 61 ML020780186 60 FR 15649; 60 FR 25983 1995-4 Performance Requirements for Radiography 06/30/1998 Not Required Not Required California has adopted Final Equipment 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 ML020030346 03/18/2002 Parts 19 and 20 ML020780186 60 FR 36038 3

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1995-6 Clarification of Decommissioning Funding 11/24/1998 Final No Comments Requirements 04/01/1998 Parts 30, 40 and 70 60 FR 38235 1995-7 Medical Administration of Radiation and Radioactive 10/20/1998 Final No Comments Part 35 only Materials ML103050179 01/05/2011 Parts 20 and 35 ML103340411 60 FR 48623 (Superceded by 2002-2 and 2005-2) Final No Comments Part 20 only ML103550423 02/14/2011 ML110120070 1996-1 Compatibility with the International Atomic Energy 04/01/1999 Final No Comments California has adopted Final Agency ML091240053 06/11/2009 Regulations equivalent to RATS ID:

Part 71 ML091470300 2004-1 60 FR 50248; 61 FR 28724 (Superceded by 2004-1) 1996-2 One Time Extension of Certain Byproduct, Source 02/15/1999 Not Required Not Required These regulation changes are not and Special Nuclear Materials Licenses required to be adopted for purposes Parts 30, 40 and 70 of Compatibility.

61 FR 1109 1996-3 Termination or Transfer of Licensed Activities: 06/17/1999 Final No Comments Record keeping Requirements ML020030346 03/18/2002 Parts 20, 30, 40, 61 and 70 ML020780186 61 FR 24669 4

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1997-1 Resolution of Dual Regulation of Airborne Effluents 01/9/2000 Final No Comments of Radioactive Materials; Clean Air Act ML020030346 03/18/2002 Part 20 ML020780186 61 FR 65120 1997-2 Recognition of Agreement State Licenses in Areas 02/27/2000 Final No Comments Under Exclusive Federal Jurisdiction Within an ML111740220 08/24/2011 Agreement State ML112130149 Part 150 62 FR 1662 1997-3 Criteria for the Release of Individuals Administered 05/29/2000 Final No Comments Part 35 only Radioactive Material ML103050179 01/05/2011 Parts 20 and 35 ML103340411 62 FR 4120 Final No Comments Part 20 only ML103550423 02/14/2011 ML110120070 1997-4 Fissile Material Shipments and Exemptions 02/10/2000 Not Required Not Required These regulation changes are not Part 71 required to be adopted for purposes 62 FR 5907 of Compatibility. (See STP-97-078)

(Superceded by 2004-1) 1997-5 Licenses for Industrial Radiography and Radiation 06/27/2000 Comments Safety Requirements for Industrial Radiography Rii 08/06/2014 Operations ML14139A065 ML14139A060 Parts 30, 34, 71 and 150 62 FR 28947 Final No Comments ML15012A519 02/09/2015 ML15012A465 5

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1997-6 Radiological Criteria for License Termination 08/20/2000 Final Comments This regulation was previously Parts 20, 30, 40 and 70 ML16034A230 05/24/16 reviewed and found acceptable 62 FR 39057 ML16034A225 (See NRC letter ML020780186),

however it was repealed on August 8, 2002, and CA is currently terminating licenses on a case by case basis 1997-7 Exempt Distribution of a Radioactive Drug 01/02/2001 Final No Comments Containing One Micro curie of Carbon-14 Urea ML081080140 05/13/2008 Part 30 ML081340266 62 FR 63634 1998-1 Deliberate Misconduct by Unlicensed Persons 02/12/2001 Final No Comments Parts 30, 40, 61, 70, 71 and 150 ML060340073 03/09/2006 63 FR 1890; 63 FR 13773 ML060670437 1998-2 Self-Guarantee of Decommissioning Funding by 07/01/2001 Not Required Not Required These regulation changes are not Nonprofit and Non-Bond-Issuing Licensees required to be adopted for purposes Parts 30, 40 and 70 of Compatibility.

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

(Superceded by 2002-2) 6

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 ML081160234 06/19/2008 Operations ML081710246 Part 34 63 FR 37059 1998-5 Minor Corrections, Clarifying Changes, and a Minor 10/26/2001 R2 No Comments Policy Change ML14139A065 08/06/2014 Parts 20, 32, 35, 36 and 39 ML14139A060 63 FR 39477; 63 FR 45393 License Condition No Comments Part 36 ML051580164 07/18/2006 ML061790298 ML061990575 Final No Comments ML15012A519 02/09/2015 ML15012A465 1998-6 Transfer for Disposal and Manifests: Minor 11/20/2001 Final No Comments Technical Conforming Amendment ML020030346 03/18/2002 Part 20 ML020780186 63 FR 50127 1999-1 Radiological Criteria for License Termination of 06/11/2002 Not Applicable Not Applicable California does not have authority to Uranium Recovery Facilities regulate this material under its Part 40 Agreement.

64 FR 17506 7

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1999-2 Requirements for Those Who Possess Certain 10/04/2002 Not Required Not Required These regulation changes are not Industrial Devices Containing Byproduct Material to required to be adopted for purposes Provide Requested Information of Compatibility.

Part 31 64 FR 42269 1999-3 Respiratory Protection and Controls to Restrict 02/02/2003 Final No Comments Internal Exposure ML062210438 08/31/2006 Part 20 ML062490010 64 FR 54543; 64 FR 55524 2000-1 Energy Compensation Sources for Well Logging 05/17/2003 Final No Comments and Other Regulatory Clarifications ML070920384 04/23/2007 Part 39 ML071140038 65 FR 20337 2000-2 New Dosimetry Technology 01/08/2004 Final No Comments Part 34 Parts 34, 36 and 39 ML081160234 06/19/2008 65 FR 63750 ML081710246 Final No Comments Part 39 ML070920384 04/23/2007 ML071140038 License Condition No Comments Part 36 adopted by reference ML051580164 07/18/2006 ML061790298 ML061990575 8

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package No Comments 2001-1 Requirements for Certain Generally Licensed 02/16/2004 R2 08/06/2014 Industrial Devices Containing Byproduct Material ML14139A065 ML14139A060 Parts 30, 31 and 32 65 FR 79162 License Condition No Comments for 32.52 (a) & (b) 03/10/2004 ML040500440 ML040700191 Final No Comments ML15012A519 02/09/2015 ML15012A465 2002-1 Revision of the Skin Dose Limit 04/05/2005 Final No Comments Part 20 ML062210438 08/31/2006 67 FR 16298 ML062490010 2002-2 Medical Use of Byproduct Material 10/24/2005 R2 No Comments Parts 20, 32 and 35 ML14139A065 08/06/2014 67 FR 20249 ML14139A060 Final No Comments ML15012A516 02/09/2015 ML15012A465 2003-1 Financial Assurance for Materials Licensees 12/03/2006 Final No Comments Parts 30, 40 and 70 ML090210714 02/06/2009 68 FR 57327 ML090260305 9

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2004-1 Compatibility With IAEA Transportation Safety 10/01/2007 Final No Comments Standards and Other Transportation Safety ML091240053 06/11/2009 Amendments ML091470300 Part 71 69 FR 3697 2005-1 Security Requirements for Portable Gauges 07/11/2008 License Condition No Comments Containing Byproduct Material ML062920179 11/09/2006 Part 30 ML063130004 70 FR 2001 2005-2 Medical Use of Byproduct Material - Recognition of 04/29/2008 R2 No Comments Specialty Boards ML14139A065 08/06/2014 Part 35 ML14139A060 70 FR 16336; 71 FR 1926 Final No Comments ML15012A519 02/09/2015 ML15012A465 2005-3 Increased Controls for Risk-Significant Radioactive 12/01/2005 License Condition No Comments California chose to revise its IC Sources (NRC Order EA-05-090) ML081280851 05/13/2008 License Condition at the time of the 70 FR 72128 ML081340260 Fingerprinting Order EA-07-305 License Condition Implementation.

The original license condition can be seen at ML053060120. The response letter sent 11/04/2005 can be seen at ML053080246.

10

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2006-1 Minor Amendments 03/27/2009 R2 No Comments Parts 20, 30, 32, 35, 40 and 70 ML14139A065 08/06/2014 Note: changes to Part 40 and 70 71 FR 15005 ML14139A060 are not required for compatibility.

Final No Comments ML15012A519 02/09/2015 ML15012A465 2006-2 National Source Tracking System - Serialization 02/06/2007 License Condition No Comments Requirements ML070360575 02/16/2007 Part 32 with reference to Part 20 Appendix E ML070470007 71 FR 65685 2006-3 National Source Tracking System 01/31/2009 Final No Comments Part 20 ML103550423 02/14/2011 71 FR 65685, 72 FR 59162 ML110120070 2007-1 Medical Use of Byproduct Material - Minor 10/29/2010 R2 No Comments Corrections and Clarifications ML14139A065 08/06/2014 Parts 32 and 35 ML14139A060 72 FR 45147, 54207 Final No Comments ML15012A519 02/09/2015 ML15012A465 11

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2007-2 Exemptions From Licensing, General Licenses, and 12/17/2010 R2 No Comments Distribution of Byproduct Material: Licensing and ML14139A065 08/06/2014 Reporting Requirements ML14139A060 Parts 30, 31, 32 and 150 72 FR 58473 Final No Comments ML15012A519 02/09/2015 ML15012A465 2007-3 Requirements for Expanded Definition of Byproduct 11/30/2010 R2 No Comments Material ML14139A065 08/06/2014 Parts 20, 30, 31, 32, 33, 35, 61 and 150 ML14139A060 72 FR 55864 Final No Comments ML15012A519 02/09/2015 ML15012A465 2007-4 Order Imposing Fingerprinting Requirements and 06/05/2008 License Condition No Comments Criminal History Records Check Requirements for ML081280851 05/13/2008 Unescorted Access to Certain Radioactive Material ML081340260 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 ML103550423 02/14/2011 Parts 19 and 20 ML110120070 72 FR 68043 12

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2009-1 Medical Use of Byproduct Material - Authorized 09/28/2012 Proposed No Comments User Clarification ML14139A0652 08/06/2014 Part 35 ML14139A060 74 FR 33901 Final No Comments ML15012A519 02/09/2015 ML15012A465 12/17/2015 2011-1 Decommissioning Planning Proposed No Comments Parts 20, 30, 40 and 70 ML18067A028 04/13/2018 76 FR 35512 ML18067A027 Final No Comments ML19066A324 03/28/2019 ML19066A318 2011-2 Licenses, Certifications, and Approvals for Materials 11/14/2014 Final No Comments Licensees ML13144A735 07/03/2013 Parts 30, 36, 39, 40, 70 and 150 ML13162A553 76 FR 56951 License Condition No Comments Part 36 adopted by reference ML13196A091 08/21/2013 ML13196A080 2012-1 Change of Compatibility of 01/25/2015 R2 No Comments Parts 31.5 and 31.6 ML14139A0652 08/06/2014 (See RATS ID: 2001-1 for Rule text) ML14139A060 77 FR 3640 Final No Comments ML15012A519 02/09/2015 ML15012A465 13

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2012-2 Advance Notification to Native American Tribes of 08/10/2015 Proposed No Comments Transportation of Certain Types of Nuclear Waste ML18065B098 04/19/2018 Part 71 ML18065B082 77 FR 34194 Final No Comments ML19085A266 05/20/2019 ML19085A252 2012-3 Technical Corrections 08/06/2015 Proposed No Comments Parts 30, 34, 40 and 71 ML18065B098 04/19/2018 77 FR 39899 ML18065B082 Final No Comments ML19085A266 05/20/2019 ML19085A252 2012-4 Requirements for Distribution of Byproduct Material 10/23/2015 Proposed No Comments Parts 30, 31, 32, 40 and 70 ML14139A0652 08/06/2014 77 FR 43666 ML14139A060 Final No Comments ML15012A519 02/09/2015 ML15012A465 14

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2013-1 Physical Protection of Byproduct Material, 10 CFR 03/19/2016 Proposed License Comments Part 37 only.

Parts 20, 30, 32, 33, 34, 35, 36, 37, 39 and 71 Condition 08/31/2015 78 FR 16922 ML15216A474 ML15216A443 Revised License No Comments Part 37 only.

Condition 11/03/2015 ML15281A285 ML15281A277 Proposed Comments ML18065B098 04/19/2018 ML18065B082 Final No Comments ML19085A266 05/20/2019 ML19085A252 2013-2 Distribution of Source Material to Exempt Persons 08/27/2016 Proposed Comments and to General Licensees and Revision of ML19015A163 01/28/2019 General License and Exemptions, ML19015A145 Parts 30, 40 and 70 78 FR 32310 Revised Proposed No Comments ML19100A330 04/15/2019 ML19100A318 2015-1 Domestic Licensing of Special Nuclear Material - 01/26/2018 Proposed No Comments Written Reports and Clarifying Amendments ML18065B098 04/19/2018 Part 70 ML18065B082 79 FR 57721, 80 FR 143 Final No Comments ML19085A266 05/20/2019 ML19085A252 15

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 Proposed Categorization, Change for Materials Facilities ML15216A474 08/31/2015 ML15216A474 Parts 30, 37, 73 and 150 ML15216A443 79 FR 58664, 80 FR 3865 Revised License No Comments Revised License Condition Condition 11/03/2015 ML15281A285 ML15281A285 ML15281A277 Proposed No Comments ML18065B098 04/19/2018 ML18065B082 Revised Proposed No Comments ML18324A655 01/03/2019 ML18324A651 Final No Comments ML19085A266 05/20/2019 ML19085A252 16

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package Proposed Comments 2015-3 Revisions to Transportation Safety Requirements 07/13/2018 ML18065B098 04/19/2018 and Harmonization with International Atomic *extended to ML18065B082 Energy Agency Transportation Requirements 08/15/2020 Part 71 See STC 17-060 Revised Proposed No Comments 80 FR 33987 ML18324A655 01/03/2019 ML18324A651 Final No Comments ML19085A266 05/20/2019 ML19085A252 License Condition Comment The LC contained requirements for ML19193A047 07/19/2019 10 CFR 71.101(c) and 71.106(b)

ML19193A045 only.

2015-4 Miscellaneous Corrections, 09/02/2018 Proposed Comments Parts 37 and 40 ML18065B098 04/19/2018 80 FR 45841 ML18065B082 Revised Proposed No Comments ML18324A655 01/03/2019 ML18324A651 Final No Comments ML19085A266 05/20/2019 ML19085A252 17

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2015-5 Miscellaneous Corrections, 12/31/2018 Proposed No Comments Parts 19, 20, 30, 32, 37, 40, 61, 70, 71 and 150 ML18065B098 04/19/2018 80 FR 74974 ML18065B082 Revised Proposed No Comments ML18324A655 01/03/2019 ML18324A651 Final No Comments ML19085A266 05/20/2019 ML19085A252 2018-1 Medical Use of Byproduct Material - Medical Event 01/14/2022 Definitions, Training and Experience, and Clarifying Amendments, 10 CFR Parts 30, 32 and 35 2018-2 Miscellaneous Corrections - 12/21/2021 Final No Comments Organizational Changes ML19085A266 05/20/2019 10 CFR Parts 37, 40. 70 and 71 ML19085A252 N/A Parts 35.13, 35.14, 35.24, 35.27, 35.57 and 35.2024 License Condition No Comments ML111400455 07/11/2011 ML111740678 i

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

ii R stands for revisions to final rule.

18