ML21173A331

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Maryland Impep Questionnaire Response
ML21173A331
Person / Time
Issue date: 06/21/2021
From:
Office of Nuclear Material Safety and Safeguards
To:
Modes K
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Download: ML21173A331 (25)
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Approved by OMB1 Control No. 3150-0183 Expires 02/28/2023 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE Maryland IMPEP Reporting Period: November 7, 2015 - June 5, 2021 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.

The 2015 IMPEP had two open recommendations:

(1) Technical Staffing and Training - The licensing training program did not contain all the essential elements to be fully compatible with NRC Inspection Manual Chapter 1248. During February 2016, the licensing supervisor revised the Maryland Licensing Procedure which incorporated the essential elements of the individual self-study guides, on the job training modules, and defined minimum training and specialized training requirements. These were incorporated into qualification journals for the license reviewers.

(2) Technical Quality of Licensing Actions - The review team found inconsistencies between licensing actions with the same codes and proof-reading errors. The licensing supervisor initiated a proof-reading checklist and in January 2017 started a root cause review of condition errors in the same type of licenses.

The review involved taking the licenses under the same code and developing a spreadsheet of the existing conditions. Common templates were developed for the six most common licenses. The proof-reading checklist and use of the common templates were discussed at a September 20, 2017 staff meeting. In 2019, a formal procedure was established for quality control incorporating this practice.

B. COMMON PERFORMANCE INDICATORS I. Technical Staffing and Training

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

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.

(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.

SEALED SOURCE AND DEVICE REVIEW Name Title Signature Authority Cheryl Nitkowski Section Head, Full Licensing Talya Langbaum HP II None Matthew Sievers HP II None

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%

Charles Cox Chief, Radioactive Administration 60 Materials Division Radioactive Materials 30 Emergency Response 10 Cheryl Nitkowski Section Head, Administration 10 Radioactive Materials Radioactive Materials 85 Licensing Emergency Response 5 Atnatiwos Meshesha Section Head, Administration 20 Radioactive Materials Radioactive Materials 75 Inspection Emergency Response 5 Talya Langbaum Health Physicist II- Administration 5 License Reviewer Radioactive Materials 90 Emergency Response 5 Matthew Sievers Health Physicist II- Administration 5 License Reviewer Radioactive Materials 90 Emergency Response 5 David Fabricante Health Physicist II - Administration 5 Inspector Radioactive Materials 90 Emergency Response 5 Joval Rama Health Physicist I - Administration 5 Inspector Radioactive Materials 90 Emergency Response 5 Tishara Stewart Administrative Administration 10 Specialist II Radioactive Materials 70 Emergency Response 5 Mary McCormick Section Head, Technical Administration 20 Planning Radioactive Materials 30 Emergency Response 5 Roger Champion Health Physicist Administration 0 Trainee-Technical Radioactive Materials 5 Planning Emergency Response 5

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.

Name Date of Hire Degree Additional Training Years of Experience Atnatiwos September MS Radiation 20 Meshesha 2016- Safety & 1. NRC G-108 Inspection Licensing Environmental Procedures, March 06-10, March 2017 Protection 2017,

- Inspection

2. NRC G-109 Licensing Practice and Procedures, March 13-17, 2017,
3. NRC H-119 Air Sampling for Radioactive Materials, April 30 - May 4, 2018,
4. DOE - Radiation Specialist class April 29-May 3, 2019, College Park, Maryland
5. Applied Radiation Physics, Graduate Certificate Program, 2015/16, University of Washington, Seattle, USA.
6. IAEA- C7-RAF-9.35- Post Graduate educational course in radiation protection and safety of Radiation, 2000, Johannesburg,Witwatersrand University, South Africa
7. KINS-2009-TC- Training course on Safety and Regulation on radioactive sources and nuclear power plants, May 4-15, 2009
8. Participated in many IAEA radiation safety and physical security training, technical meetings, and IAEA advisory missions.

Umaru Bun- April 2018 MS Nuclear 12 Tejan and Quantum 1. NRC-G-109 Licensing Engineering Practice and Procedures, November 13-16, 2018,

2. NRC-G-108 Inspection

Procedures, March 3-8, 2019,

3. NRC-H-122S Fundamental Health Physics Self-Study, July 25, 2018,
4. IAEA- C7-RAF-9.35-009/11-Post Graduate educational course in radiation protection and safety of radiation sources, (radiation ,

transport and waste safety),

University of Ghana, Accra Ghana, November 4 2013 -

April 3 2014.

5. IAEA-SIL/9/003 Fellowship in the field of regulatory infrastructure and nuclear safety, ( Developing a National Regulatory Infrastructure and Occupational exposure control program,) May 3 -

August 3, 2010,

6. IAEA-C7-RAF-9.038-004/09- Training course for regulators on authorization and Inspection of radiation sources, October 5-30, 2009.
7. IAEA-C7-RAF-9.041-013/11- Training course on physical protection of radioactive sources, May 23-27, 2011
8. IAEA-C7-RAF/0/026-012/12-Training course for trainers in the use of ICT materials in radiation protection, February 20-24, 2012
9. IAEA-C7-RAF-9.047-001/12- Training course on public communications in radiation emergencies, June 22-29, 2012
10. World Nuclear University School on radiation technologies, May 13-June 1

2012.

11. USA-DOE and GTRI-Training on Search and Secure Operations of Radioactive sources, August 27-31, 2012,
12. KINS-2012-TC-220-Training Course on emergency preparedness and environmental Monitoring, September 17-28 2012
13. KINS-2012-TC-243-Training course on Safety and Regulation on radioactive sources and nuclear power plants, November 5-16, 2012
14. IAEA- US DOE-Emergency preparedness and response to Major public events August 11-15, 2014
15. FEMA-IS-00003 Radiological emergency management, March 26,2020
16. Attended many IAEA meetings on radiation protection and safety of radiation sources, and on radiological and nuclear emergency prepared and response as project counterparts.

David July 2019 Vocational 18 Fabricante Certificate in 1. Previous DOE Core Civil Qualifications for Radiation Engineering Controls Inspector/

and Technician at Fernald Architectural Site,Ohio, Savannah river Drafting Site, South Carolina, And Portsmouth Site, Ohio, and FUSRAP in Middlesex, NJ 2 G-108 Inspection Procedures October 21-25 2019

3. H-313 Brachytherapy Gamma knife, and other medical uses. January 13-17 2020
4. H-304 Diagnostic and Therapeutic Medicines July 27-31 2020
5. H-305 Safety Aspects of Industrial Radiography March 15-19 2021
6. FEMA IS-00100.C Basics Incident Command System June 26, 2019
7. FEMA IS-00200.C Incident Command System Initial Response June 6, 2019
8. FEMA IS-00003 Radiological Emergency Management November 4, 2019
9. The Following Communication Training Workshops Offered by National Nuclear Security Administration Office of Nuclear Incident Policy and Cooperation 10, Canned Messages and Developing Key Messages November 9,2020
11. Communication Strategies, Right Information to the right people at the right time December 3, 2020
12. Joint Information System and JIS Methodology and Strategy December 10, 2020
13. Basic Radiation Safety and Application Principles January 5,2021
14. Radiation/Nuclear in the public Consciousness and Communication Complexities January 7, 2021 Talya January BS Physics 9 Langbaum 2020 1. H-117 Intro to Health Physics
2. RASCAL/URI &

emergency response

3. H-122S Fundamental Health Physics (self study)
4. H-304 Diagnostic and Therapeutic Nuclear Medicine
5. G-116 Sealed Source and Device Evaluation Workshop
6. Basic radiation safety training
7. Various on the job training (license rev. XRF, portable gauges, medical, HDR, fixed gauge)
8. G-109 Licensing Procedures
9. H-313 Brachy, Gamma Knife and other Medical Uses

Clay January BS 1. H-201 Advanced Health 25 Years Nuquist 2016 Radiological Physics CNMT Sciences and 2. S-201 NRC Materials 3 years Administration Control & Security Materials

3. H-305 Safety Aspects of Inspector Industrial Radiography
4. H-308 Brachytherapy, Gamma Knife and Emerging Technologies
5. NRC - Gathering Information for Inspectors Through Interviews
6. NRC- Performance Based Inspections
7. NRC Math Refresher FEMA IS-100B and & 700A Joval Rama March 2020 MS Medical 9 Physicist 1. G-108 Inspection Procedures
2. H-304 Diagnostic and Therapeutic Medicine
3. H-122S Fundamental Health Physics Self-Study
4. FEMA IS-200.c Basic Incident Command System for Initial

Response

5. FEMA-00003 Radiological Emergency Management
6. IS-00100.c Introduction to Incident Command System
7. APNGA Portable Nuclear Gauge Safety and DOT HAZMAT Certification Class
8. APNGA Nuclear Portable Gauge Radiation Safety Officer Class H-313 Brachytherapy, Gamma Knife and Other Medical Uses Roger March 2020 BS Nuclear 3 Champion Engineering 1. H-122S Fundamental and Health Physics Self-Study Radiological Course Sciences
2. H-305 Industrial Radiography
3. H-304 Diagnostic and Therapeutic Nuclear Medicine
4. G-108 Inspection Procedures
5. FEMA IS-3 Radiological Emergency Management
6. FEMA IS-100 Introduction to Incident Command System
7. FEMA IS-200 Basic Incident Command System for Initial Response
8. FEMA IS-700 Introduction to National Incident Management System
9. FEMA IS-800 National Response Framework, An Introduction Andrei May 2020 MS Nuclear 1. H-122S Health Physics 20 Nuclear Beloousov Engineering 2. H-121S MARSSIM Engineer
3. H-312S Internal Dosimetry
4. H-308S Transportation
5. H-301S Statistics SS&D Workshop (virtual)
6. H-120S MARSSAM Matthew March 2021 BA Biology 2.5 Sievers 1. H-117 Introductory Health Physics (June 20, 2019)
2. RASCAL Training (in-class, King of Prussia) (April 22-23, 2019)
3. URI RASCAL Training (in-class, Coatsville) (May 14, 2019)
4. FEMA IS-00003 Radiological Emergency Managment (April 10, 2020)
5. FEMA IS-00100.c Introduction to Incident

Command System, ICS-100 (May 27, 2020)

6. FEMA IS-00200.c Basic Incident COmmand System for Initial Response (August 11, 2020)
7. H-122S Fundamental Health Physics Self-Study Course (April 2, 2021)

Mary April 2020 BS 30 McCormick Radiological FEMA:

Sciences, MS Health IS 003 - 4/16/18 Sciences Educ., PhD IS 100.b - 4/23/18 Education IS 200.b - 5/12/18 IS 400.a - 4/25/18

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.

Name Training Needed Tentative Date David Fabricante NRC Minimum Training As Available Talya Langbaum NRC Minimum Training As Available Joval Rama NRC Minimum Training As Available Roger Champion NRC Minimum Training As Available Matthew Sievers NRC Minimum Training As Available

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

In February 2016, the qualification and training procedure was revised to address previous IMPEP recommendations to incorporate IMC 1248 Appendices A & B.

Matched NRC minimum training and adopted the ISAs and OJTs (see response to Question 1).

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

Name Position Vacate Date Raymond Manley Chief, Radioactive Materials October 2016 Kenneth Brenneman Health Physicist III January 2016 Roland Fletcher Radiological Health Program March 2017 Manager Alan Jacobson Chief, Radioactive Materials February 2018 Clay Nuquist Health Physicist III December 2018 Nathaniel Owrutsky Health Physicist III May 2019 James Lewis Environmental Program July 2019 Manager I Alan Goldey Health Physicist Supervisor December 2019 Michael Kurman Health Physicist Supervisor December 2019

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.

A hard hiring freeze was in effect for an extended period. The freeze has been partially lifted recently, and, as a result, two exceptions to hire were sought from the Maryland Department of Budget and Management that is authorized to grant such exceptions. Hiring exceptions for C-7050 and PIN 074123 were approved on June 8, 2021. The hiring process to fill these two positions should be completed by the end of August 2021.

Vacant Position Time Vacant Effort to Fill Vacancy RAM License Reviewer C7050 Since May 13, 2020 Approved June 8, 2021 RAM License Reviewer C7042 Since May 19, 2020 In ARA Directors Office RAM Inspector PIN 074123 March 3, 2020 Approved June 8, 2021

9. For Agreement States, does your program have an oversight board or committee which provides direction to the program and is composed of licensees and/or members of the public? If so, please describe the procedures used to avoid any potential conflict of interest. Yes.

The Radiation Control Advisory Board.

Established under the Maryland Code, Environment Article Title 8-Radiation Subtitle 2-Radiation Control Advisory Board Section 8-201-Board established.

Information for potential conflict is found under the General Provisions Article Title 5 - MD Public Ethics Law, Subtitle 5 Conflicts 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. None

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.

11/7/2015 - 6/1/2021 - Total - 372 (this number will change) re-inspections (excluding CAT 1&2 security inspections)

Priority 1 - 13 inspections Priority 2 - 124 inspections Priority 3 - 235 inspections Initials (P1, P2, P3) - 50 11/7/2015 - 12/2015 - 4 inspections

  • 1/2016 - 12/2016 - 69 inspections 1//2017 - 12/2017 - 76 inspections 1/2018 - 12/2018 - 59 inspections 1/2019 - 12/2019 - 54 inspections 1/2020 - 12/2020 - 66 inspections 1/1/2021 - 6/1/2021 - 44 inspections Initial Inspections total - 50 (P1 to P5)**

11/7/2015 - 12/2015 - 3 inspection 1/2016 - 12/2016 - 9 inspections 1/2017 - 12/2017 - 6 1/2018 - 12/2018 - 7 inspections 1/2019 - 12/2019 - 8 inspections 1/2020 - 12/2020 - 8 inspections 1/2021 to 6/1/2021 - 9 inspections

  • No Pri 1 or 2 done after Nov 2015 IMPEP
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

Licensee Licensee Priority Last Date Due Date Amount Date Name Number (IMC inspection Performed of Time inspection 2800) date or Overdue findings license Days issued issuance date, if initial inspection Team MD 1 11/1/2018 405 12/11/2019 11/1/2017 12/11/2019 Industrial 017-01 Maryland QC 1 11/5/2017 11/5/2018 400 12/10/2019 MD Laboratories, & 12/10/2019 022-01 Inc. 11/29/2017 Mistras MD 1 11/15/2018 392 12/12/2019 11/15/2017 12/12/2019 Group, Inc. 218-01 Inova Health 3 Care MD 1/28/2014 1/28/2011 9/25/2018 9/25/2018 Patuxent 009-01 1701 JPC Nuclear MD 3 8/8/2017 827 Technologies 005-01 8/8/2014 11/13/2019 11/13/2019 Siemens 3 8/10/2018 928 Medical MD 8/10/2015 2/23/2021 6/1/2021 Solutions 392-01 USA, Inc CQI Home MD 5 8/31/2018 3/24/2021 936 8/31/2017

  • Inspections 019-01 (followup)
  • CQI Home Inspections is an initial inspection. The Maryland Radiological Health Program (RHP) was not notified that the licensee had acquired the lead paint analyzer until March 2021.

RHP attempted to contact the licensee in 2019 but was unsuccessful. Due to the COVID-19 pandemic, the RHP was not able to conduct inspections at individuals home sites.

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.

No current priority 1, 2, or 3 inspections are overdue.

No initial inspections are currently overdue.

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.

Year Candidates for Inspection Number of Reciprocity (Pool) Inspections 2015 4 2 2016 23 9 2017 17 4 2018 24 4 2019 24 2 2020 23 5 2021 18 1 III. Technical Quality of Inspections

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

The Inspector Qualification Procedure was modified in February 2016 at the same time as the License Reviewer Qualification Procedure (see response to Question

1) for a matter of consistency, not as a response to a recommendation. Also, as noted in the response to Question 1, a Quality Assurance Procedure was developed for both Licensing and Inspection in 2020. The inspection portion requires generation of quarterly statistics reports on reciprocity inspections and Priority 1,2, 3 overdue inspections to ensure the Program is made aware of any slippage and can institute measures in a timely manner to allow the IMPEP metrics to be met.
16. Prepare a table showing the number and types of supervisory accompaniments made during the review period. Include:

Inspector Supervisor License Date Category Clay Nuquist Alan Jacobson 02200 12/02/2016 Alan Goldey Alan Jacobson 03225 12/15/2016 Alan Goldey Alan Jacobson 03521 1/12/2016 Clay Nuquist Alan Goldey 02200 08/31/2017 Clay Nuquist Alan Goldey 02110 2/15/2018 Atna Meshesha Alan Goldey 03121 3/31/2017 Atna Meshesha Alan Goldey 03121 4/10/2017 Atna Meshesha Alan Goldey 02201 10/11/2017 Atna Meshesha Alan Goldey 02302 11/3/2017 Atna Meshesha Alan Goldey 02302 12/12/2017 Atna Meshesha Alan Goldey 03320 11/28/2017 Atna Meshesha Alan Goldey 03320 12/5/2017 Atna Meshesha Alan Goldey 02304 3/5/2019 Atna Meshesha Alan Goldey 02305 5/15/2018 Atna Meshesha Charlie Cox 02302 6/2/2021 David Fabricante Alan Goldey 03121 8/5/2019 David Fabricante Atna Meshesha 02201 9/30/2019 David Fabricante Atna Meshesha 02201 10/2/2019 David Fabricante Atna Meshesha 02120 10/4/2019 David Fabricante Atna Meshesha 03620 11/7/2019

David Fabricante Atna Meshesha 03521 6/15/2020 David Fabricante Atna Meshesha 03521 6/19/2020 David Fabricante Atna Meshesha 03124 10/16/2019 David Fabricante Atna Meshesha 03225 6/17/2020 David Fabricante Atna Meshesha 03232 7/7/2020 David Fabricante Atna Meshesha 03232 7/17/2020 David Fabricante Atna Meshesha 03232 9/30/2020 David Fabricante Atna Meshesha 03511 10/16&17/2019 David Fabricante Atna Meshesha 02305 6/26/2020 David Fabricante Atna Meshesha 02110 2/14/2020 David Fabricante Atna Meshesha 02302 10/1/2019 David Fabricante Atna Meshesha 02302 4/5/2021 Joval Rama Atna Meshesha 03121 8/11/2020 Joval Rama Atna Meshesha 03121 8/14/2020 Joval Rama Atna Meshesha 03121 8/21/2020 Joval Rama Atna Meshesha 03120 3/4/2021 Joval Rama Atna Meshesha 02201 2/10/2021 Joval Rama Atna Meshesha 02120 12/2/2020 Joval Rama Atna Meshesha 02120 12/10/2020 Joval Rama Atna Meshesha 02120 1/22/2021 Joval Rama Atna Meshesha 02120 2/23/2021 Joval Rama Atna Meshesha 02200 3/12/2021 Joval Rama Atna Meshesha 02301 8/18/2020 Joval Rama Atna Meshesha 02302 3/9/2021 Joval Rama Atna Meshesha 02302 10/13/2020 Joval Rama Atna Meshesha 02302 10/15/2020 Joval Rama Atna Meshesha 02302 12/15/2020 Joval Rama Atna Meshesha 03320 12/17/2020 Joval Rama Atna Meshesha 03320 12/18/2020 Joval Rama Atna Meshesha 03320 1/12/2021 Joval Rama Atna Meshesha 03320 (REC) 2/17/2021

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?

Radiation meters are calibrated under a contract with Radiation Service Organization, Inc (RSO).

All radiation samples are processed by the Department of Health Radiation Laboratory under a Contract/Memorandum of Understanding.

Sufficient calibrated instruments were available throughout the review period. A list of all instrumentation will be available during the audit.

IV. Technical Quality of Licensing Actions

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

528

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 Licensee Action Date Reviewer Description Versa Bankruptcy/termination 5/29/2019 Charles Paper Mill Cox Fixed Gauge
20. Discuss any variances in licensing policies and procedures or exemptions from the regulations granted during the review period.

Due to the COVID-19 pandemic, Governor Hogan declared a state of emergency. A number of executive orders followed. A March 12, 2020 order extended the expiration date of certain licenses, permits, registrations, and other government authorizations to 30 days following the lifting of the state of emergency. A subsequent order declared that the extension will expire on June 30, 2021.

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

Developed a Quality Assurance Procedure for both Licensing and Inspections.

The licensing portion was in response to a previous IMPEP incorporating findings from a root cause review establishing standard license conditions for license codes and a proofreading checklist for the most common editing errors.

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.

None 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 None

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

None

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.

All laws are pertaining to Radiation are established under the Maryland Code, Environment Article Title 8-Radiation. No legislation was enacted or amended during the review period.

Current effective regulation Code of Maryland Regulations 26.12.01.01 Adopted September 9, 1995 Effective October 9, 1995.

Supplement 28 effective November 24, 2016 RATS 2015-1, 2015-2, 2015-3, 2015-4, and 2015-5.

Supplement 29 effective May 21, 2018 Supplement 30 effective February 22, 2021 Supplement 31 is being reviewed by the Attorney Generals Office and will contain RATS 2018-1, 2018-2

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

No

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.

SRS sheet is correct as listed

28. If you have not adopted all amendments within three years from the date of NRC rule promulgation, briefly describe your State's procedures for amending regulations in order to maintain compatibility with the NRC, showing the normal length of time anticipated to complete each step.

Amendment adoption procedure is located in the Box Approximate time to adopt amendments is 7 months 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 Registry Manufacturer Product Type Date Issued Type of Action Number Distributor or or Use Custom User MD-1362-D-101- Xcision Breast Cancer 1/8/2016 Issued S

MD-1362-D-101- Xcision Breast Cancer 3/7/2018 Amendment S

MD-0600-D-101- Shimadzu Electron Under Review Amendment B Capture MD-8324-D-101- Conco Electron 9/27/2019 Inactivated Capture

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 Questions 2-9 Question 2 Name Date of SSD Course SSD Evaluation Experience Cheryl Nitkowski March 31-April 4, 2014 7 years SEALED SOURCE AND DEVICE REVIEW Name Title Signature Authority Cheryl Nitkowski Section Head, Full Licensing Talya Langbaum HP II None Matthew Sievers HP II None Question 3 same as above Question 4 same as above Question 5 Of the licensing staff, Matthew Sievers has not yet attended the SS&D Workshop.

Question 6 No changes in qualification and training procedure for SS&D Question 7 same as above Key SSD reviewer lost when Nate Owrutsky retired from State service Question 8

Vacant Position Time Vacant Effort to Fill Vacancy RAM License Reviewer C7050 Since May 13, 2020 Approved June 8, 2021 RAM License Reviewer C7042 Since May 19, 2020 In ARA Directors Office Question 9 same as above Technical Quality of Licensing Actions - Questions 18-22 Question 18 ? How many active SS&D sheets do we have?

Question 19 Licensee Action Date Reviewer Description Gammapod Amendment 3/17/2018 Cheryl Reducing # of Nitkowski sources Question 20 No variances in SSD licensing policies and procedures or any exemptions issued.

Question 21 No new SSD procedures during this reporting period Question 22 - None Technical Quality of Incident and Allegation Activities - Questions 23-24 Question 23 - No reportabe incidents Question 24 - No change to procedure II. Low-level Radioactive Waste Disposal Program None

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 NA III. Uranium Recovery Program None

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 NA

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
  • Inspection report forms
  • Documented training plan, if applicable
  • Statutes affecting the regulatory authority of the State program
  • Records of results of supervisory 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, severity levels, civil penalties
  • Instrument calibration records (as applicable)
  • Inspection procedures and guides
  • Job descriptions
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