ML21250A077

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Letter to M. Navara Re Minnesota Impep Scheduling Letter and Questionnaire for December 2021
ML21250A077
Person / Time
Issue date: 09/03/2021
From: Monica Ford
Decommissioning, ISFSI, and Reactor Health Physics Branch
To: Navara M
State of MN, Dept of Health
References
Download: ML21250A077 (23)
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Text

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September 3, 2021 Mary Navara, Senior Manager Minnesota Department of Health Environmental Division Indoor Environmental and Radiation Section 625 Robert Street N P.O. Box 64975 St. Paul, MN 55164-0975

Dear Ms. Navara:

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 discussion, I will be the team leader for the IMPEP review of the Minnesota Agreement State Program scheduled for December 13-17, 2021.

Enclosed is the Integrated Materials Performance Evaluation Program Questionnaire. I ask that you send your responses to the questionnaire via e-mail to Monica.Ford@nrc.gov by November 26, 2021. I encourage you to use electronic documents and provide them in advance of the review to the extent possible. Also included with the questionnaire is the document Materials Requested to Be Available for the On-Site Portion of an IMPEP Review.

We encourage you to have these items prepared prior to the IMPEP teams arrival.

Finally, I request that you set up an appointment with the appropriate Senior Managers to discuss the preliminary results of the IMPEP review on the morning of December 17, 2021. If you have any questions, please call me at (610) 337-5214.

Sincerely, Monica Digitally signed by Monica L. Ford L. Ford Date: 2021.09.03 16:23:25 -04'00' Monica Lynn Ford Regional State Agreements Officer Division of Radiological Safety and Security U.S. NRC Region I

Enclosures:

1) IMPEP Questionnaire
2) State Regulation Summary Sheet Cc w/enclosure: Sherrie Flaherty, Supervisor Radioactive Materials Unit

Distribution:

KWilliams, NMSS TClark, NMSS RJohnson, NMSS DWhite, NMSS BAnderson, NMSS BWelling, RI TBloomer, RI DPelton, RIII JNick, RIII MFord, RI DPiccirillo, RIII DOCUMENT NAME: S:\State Agreement Files\IMPEP\Minnesota IMPEP 2021\2021 MN IMPEP Scheduling and Questionnaire Letter.docx Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available OFFICE Region I NAME MFord/mlf DATE 09/3/21 OFFICIAL RECORD COPY

Approved by OMB1 Control No.: 3150-0183 Expires: 02/28/2023 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE Reporting Period: October 8, 2016 - December 17, 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.

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.

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.

1 Enclosure 1

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%

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 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.

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 2

Enclosure 1

(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 which 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.

3 Enclosure 1

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 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.

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 4

Enclosure 1

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 5

Enclosure 1

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 6

Enclosure 1

STATE REGULATION STATUS State: Minnesota 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 Final No Comments Minnesota has adopted Final Part 34 ML050140452 03/04/2005 Regulations equivalent to RATS ID:

55 FR 843 ML050690100 1997-5.

(Superceded by 1997-5) 1991-2 ASNT Certification of Radiographers none Not Required Not Required Minnesota 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 ML050140452 03/04/2005 56 FR 23360; 56 FR 61352; 57 FR 38588; 57 FR ML050690100 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, 70 ML050140452 03/04/2005 56 FR 64980; ML050690100 1992-1 Quality Management Program and 01/27/1995 Final No Comments Minnesota has adopted Final Misadministrations ML050140452 03/04/2005 Regulations equivalent to RATS ID:

Part 35 ML050690100 2002-2.

56 FR 34104 (Superceded by 2002-2) 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 1

Enclosure 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1993-1 Decommissioning Recordkeeping and License 10/25/1996 Final No Comments Termination: Documentation Additions [Restricted ML050140452 03/04/2005 areas and spill sites] ML050690100 Parts 30, 40 58 FR 39628 1993-2 Licensing and Radiation Safety Requirements for 07/01/1996 Final No Comments Irradiators ML050140452 03/04/2005 Part 36 ML050690100 58 FR 7715 1993-3 Definition of Land Disposal and Waste Site QA 07/22/1996 Not Applicable Not Applicable Minnesota does not have authority Program to regulate this material under its Part 61 Agreement.

58 FR 33886 1994-1 Self-Guarantee as an Additional Financial none Not Required Not Required These regulation changes are not Mechanism required to be adopted for purposes Parts 30, 40, 70 of Compatibility.

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

59 FR 28220 1994-3 Timeliness in Decommissioning Material Facilities 08/15/1997 Final No Comments Parts 30, 40, 70 ML050140452 03/04/2005 59 FR 36026 ML050690100 1995-1 Preparation, Transfer for Commercial Distribution, 01/01/1998 Final No Comments and Use of Byproduct Material for Medical Use ML050140452 03/04/2005 Parts 30, 32, 35 ML050690100 59 FR 61767; 59 FR 65243; 60 FR 322 2

Enclosure 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1995-2 Frequency of Medical Examinations for Use of 03/13/1998 Final No Comments Respiratory Protection Equipment ML050140452 03/04/2005 Part 20 ML050690100 60 FR 7900 1995-3 Low-Level Waste Shipment Manifest Information 03/01/1998 Final No Comments and Reporting ML050140452 03/04/2005 Parts 20, 61 ML050690100 60 FR 15649; 60 FR 25983 1995-4 Performance Requirements for Radiography 06/30/1998 Final No Comments Minnesota has adopted Final Equipment ML050140452 03/04/2005 Regulations equivalent to RATS ID:

Part 34 ML050690100 1997-5.

60 FR 28323 (Superceded by 1997-5) 1995-5 Radiation Protection Requirements: Amended 08/14/1998 Final No Comments Definitions and Criteria ML050140452 03/04/2005 Parts 19, 20 ML050690100 60 FR 36038 1995-6 Clarification of Decommissioning Funding 11/24/1998 Final No Comments Requirements ML050140452 03/04/2005 Parts 30, 40, 70 ML050690100 60 FR 38235 1995-7 Medical Administration of Radiation and Radioactive 10/20/1998 Final No Comments Minnesota has adopted Final Materials ML050140452 03/04/2005 Regulations equivalent to RATS Parts 20, 35 ML050690100 IDs: 2002-2 and 2005-2.

60 FR 48623 (Superceded by 2002-2 and 2005-2) 3 Enclosure 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1996-1 Compatibility with the International Atomic Energy 04/01/1999 Final No Comments Minnesota has adopted Final Agency ML050140452 03/04/2005 Regulations equivalent to RATS ID:

Part 71 ML050690100 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, 70 of Compatibility.

61 FR 1109 1996-3 Termination or Transfer of Licensed Activities: 06/17/1999 Final No Comments Record keeping Requirements ML050140452 03/04/2005 Parts 20, 30, 40, 61, 70 ML050690100 61 FR 24669 1997-1 Resolution of Dual Regulation of Airborne Effluents 01/9/2000 Final No Comments of Radioactive Materials; Clean Air Act ML050140452 03/04/2005 Part 20 ML050690100 61 FR 65120 1997-2 Recognition of Agreement State Licenses in Areas 02/27/2000 Final No Comments Under Exclusive Federal Jurisdiction Within an ML050140452 03/04/2005 Agreement State ML050690100 Part 150 62 FR 1662 1997-3 Criteria for the Release of Individuals Administered 05/29/2000 Final No Comments Radioactive Material ML050140452 03/04/2005 Parts 20, 35 ML050690100 62 FR 4120 4

Enclosure 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 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)

Minnesota has adopted Final Regulations equivalent to RATS ID:

2004-1.

1997-5 Licenses for Industrial Radiography and Radiation 06/27/2000 Final No Comments Safety Requirements for Industrial Radiography ML050140452 03/04/2005 Operations ML050690100 Parts 30, 34, 71, 150 62 FR 28947 1997-6 Radiological Criteria for License Termination 08/20/2000 Final No Comments Parts 20, 30, 40, 70 ML050140452 03/04/2005 62 FR 39057 ML050690100 1997-7 Exempt Distribution of a Radioactive Drug 01/02/2001 Final No Comments Containing One Micro curie of Carbon-14 Urea ML050140452 03/04/2005 Part 30 ML050690100 62 FR 63634 1998-1 Deliberate Misconduct by Unlicensed Persons 02/12/2001 Final No Comments Parts 30, 40, 61, 70, 71, 150 ML050140452 03/04/2005 63 FR 1890; 63 FR 13773 ML050690100 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, 70 of Compatibility.

63 FR 29535 5

Enclosure 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 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)

Minnesota has adopted Final Regulations equivalent to RATS ID:

2002-2.

1998-4 Licenses for Industrial Radiography and Radiation 07/09/2001 Final No Comments Safety Requirements for Industrial Radiographic ML050140452 03/04/2005 Operations ML050690100 Part 34 63 FR 37059 1998-5 Minor Corrections, Clarifying Changes, and a Minor 10/26/2001 Final No Comments Policy Change ML050140452 03/04/2005 Parts 20, 32, 35, 36, 39 ML050690100 63 FR 39477; 63 FR 45393 1998-6 Transfer for Disposal and Manifests: Minor 11/20/2001 Final No Comments Technical Conforming Amendment ML050140452 03/04/2005 Part 20 ML050690100 63 FR 50127 1999-1 Radiological Criteria for License Termination of 06/11/2002 Not Applicable Not Applicable Minnesota does not have the Uranium Recovery Facilities authority to regulate this material Part 40 under its Agreement.

64 FR 17506 1999-2 Requirements for Those Who Possess Certain 10/04/2002 Not Required Not Required These 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 6

Enclosure 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1999-3 Respiratory Protection and Controls to Restrict 02/02/2003 Final No Comments Internal Exposure ML050140452 03/04/2005 Part 20 ML050690100 64 FR 54543; 64 FR 55524 2000-1 Energy Compensation Sources for Well Logging 05/17/2003 Final No Comments and Other Regulatory Clarifications ML050140452 03/04/2005 Part 39 ML050690100 65 FR 20337 2000-2 New Dosimetry Technology 01/08/2004 Final No Comments Parts 34, 36, 39 ML050140452 03/04/2005 65 FR 63750 ML050690100 2001-1 Requirements for Certain Generally Licensed 02/16/2004 Final No Comments Industrial Devices Containing Byproduct Material ML050140452 03/04/2005 Parts 30, 31, 32 ML050690100 65 FR 79162 2002-1 Revision of the Skin Dose Limit 04/05/2005 Final No Comments Part 20 ML050140452 03/04/2005 67 FR 16298 ML050690100 2002-2 Medical Use of Byproduct Material 10/24/2005 Final No Comments Parts 20, 32, 35 ML050140452 03/04/2005 67 FR 20249 ML050690100 2003-1 Financial Assurance for Materials Licensees 12/03/2006 Final No Comments Parts 30, 40, 70 ML073201223 12/14/2007 68 FR 57327 ML073470558 7

Enclosure 2

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 ML073201223 12/14/2007 Amendments ML073470558 Part 71 69 FR 3697 2005-1 Security Requirements for Portable Gauges 07/11/2008 Final No Comments Containing Byproduct Material ML073201223 12/14/2007 Part 30 ML073470558 70 FR 2001 2005-2 Medical Use of Byproduct Material - Recognition of 04/29/2008 Final No Comments Specialty Boards ML073201223 12/14/2007 Part 35 ML073470558 70 FR 16336; 71 FR 1926 2005-3 Increased Controls for Risk-Significant Radioactive 12/01/2005 License No Comments Sources (NRC Order EA-05-090) Condition 11/18/2005 70 FR 72128 ML053220236 ML053220444 2006-1 Minor Amendments 03/27/2009 Final No Comments Parts 20, 30, 32, 35, 40 and 70 ML073201223 12/14/2007 71 FR 15005 ML073470558 2006-2 National Source Tracking System - Serialization 02/06/2007 Final No Comments Requirements ML090550203 03/23/2009 Part 32 with reference to Part 20 Appendix E ML090760101 71 FR 65685 8

Enclosure 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2006-3 National Source Tracking System 01/31/2009 Final No Comments Part 20 ML090260708 03/23/2009 71 FR 65685, 72 FR 59162 ML090760101 License No Comment Condition 02/06/2009 ML090260708 ML090290322 2007-1 Medical Use of Byproduct Material - Minor 10/29/2010 Final No Comments Corrections and Clarifications ML090550203 03/23/2009 Parts 32 and 35 ML090760101 72 FR 45147, 54207 2007-2 Exemptions From Licensing, General Licenses, and 12/17/2010 Final No Comments Distribution of Byproduct Material: Licensing and ML090550203 03/23/2009 Reporting Requirements ML090760101 Parts 30, 31, 32, 150 72 FR 58473 2007-3 Requirements for Expanded Definition of Byproduct 11/30/2010 Final No Comments Material ML090550203 03/23/2009 Parts 20, 30, 31, 32, 33, 35, 61, 150 ML090760101 72 FR 55864 2007-4 Order Imposing Fingerprinting Requirements and 06/05/2008 License No Comments Criminal History Records Check Requirements for Condition 03/12/2008 Unescorted Access to Certain Radioactive Material ML080530108 ML080720050 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 ML090550203 03/23/2009 Parts 19, 20 ML090760101 72 FR 68043 9

Enclosure 2

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 Final No Comments User Clarification ML113202693 12/21/2011 Part 35 ML113400191 74 FR 33901 2011-1 Decommissioning Planning 12/17/2015 Proposed No Comments Parts 20, 30, 40, 70 ML14234A134 10/21/2014 76 FR 35512 ML14232A319 Final No Comments ML15237A085 10/15/2015 ML15236A292 2011-2 Licenses, Certifications, and Approvals for Materials 11/14/2014 Proposed No Comments Licensees ML14234A134 10/21/2014 Parts 30, 36, 39, 40, 70, and 150 ML14232A319 76 FR 56951 Final No Comments ML15237A085 10/15/2015 ML15236A292 2012-1 Change of Compatibility of 10 CFR 31.5 and 31.6 01/25/2015 Proposed No Comments (See RATS ID: 2001-1 for Rule text) ML14234A134 10/21/2014 77 FR 3640 ML14232A319 Final No Comments ML15237A085 10/15/2015 ML15236A292 10 Enclosure 2

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 ML14234A134 10/21/2014 Part 71 ML14232A319 77 FR 34194 Final No Comments ML15237A085 10/15/2015 ML15236A292 2012-3 Technical Corrections 08/06/2015 Proposed No Comments Part 30, 34, 40 and 71 ML14234A134 10/21/2014 77 FR 39899 ML14232A319 Final Comment ML15237A085 10/15/2015 ML15236A292 Revised Final No Comments ML18032A474 03/16/2018 ML18032A473 2012-4 Requirements for Distribution of Byproduct Material 10/23/2015 Proposed No Comments Parts 30, 31, 32, 40 and 70 ML14234A134 10/21/2014 77 FR 43666 ML14232A319 Final No Comments ML15237A085 10/15/2015 ML15236A292 11 Enclosure 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2013-1 Physical Protection of Byproduct Material 03/19/2016 Proposed Comments Parts 20, 30, 32, 33, 34, 35, 36, 37, 39, and 71 ML14234A134 10/21/2014 78 FR 16922 ML14232A319 Final Comments ML15237A085 10/15/2015 ML15236A292 Revised Final No Comments ML18032A474 03/16/2018 ML18032A473 Final No Comments ML19260G060 10/03/2019 ML19256B601 2013-2 Distribution of Source Material to Exempt Persons 08/27/2016 Proposed No Comments and to General Licensees and Revision of ML14234A134 10/21/2014 General License and Exemptions ML14232A319 Parts 30, 40, and 70 78 FR 32310 Final No Comments ML15237A085 10/15/2015 ML15236A292 2015-1 Domestic Licensing of Special Nuclear Material - 01/26/2018 Proposed No Comments Written Reports and Clarifying Amendments ML18032A474 03/16/2018 Part 70 ML18032A473 79 FR 57721, 80 FR 143 Final No Comments ML19260G060 10/03/2019 ML19256B601 12 Enclosure 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2015-2 Safeguards Information - Modified Handling 01/28/2018 Proposed No Comments Categorization, Change for Materials Facilities ML18032A474 03/16/2018 Parts 30, 37, 73, and 150 ML18032A473 79 FR 58664, 80 FR 3865 Final No Comments ML19260G060 10/03/2019 ML19256B601 2015-3 Revisions to Transportation Safety Requirements 07/13/2018 Proposed Comments and Harmonization with International Atomic Energy *extended to ML18032A474 03/16/2018 Agency Transportation Requirements 08/15/2020 ML18032A473 Part 71 See STC 17-060 80 FR 33987 Final No Comments ML19260G060 10/03/2019 ML19256B601 09/02/2018 2015-4 Miscellaneous Corrections Proposed No Comments Parts 37 and 40 ML18032A474 03/16/2018 80 FR 45841 ML18032A473 Final No Comments ML19260G060 10/03/2019 ML19256B601 2015-5 Miscellaneous Corrections, 10 CFR Parts 19, 20, 12/31/2018 Proposed Comments 30, 32, 37, 40, 61, 70, 71, and 150 ML18032A474 03/16/2018 80 FR 74974 ML18032A473 Final No Comments ML19260G060 10/03/2019 ML19256B601 13 Enclosure 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2018-1 Medical Use of Byproduct Material - Medical Event 01/14/2022 Proposed No Comments Definitions, Training and Experience, and Clarifying ML21140A398 07/01/2021 Amendments ML21140A391 Parts 30, 32 and 35 2018-2 Miscellaneous Corrections - 12/21/2021 Proposed No Comments Organizational Changes ML21140A398 07/01/2021 Parts 37, 40. 70 and 71 ML21140A391 2018-3 Miscellaneous Corrections 07/30/2022 Proposed No Comments Parts 1, 2, 34, 37, 50, 71, 73, and 140 ML21140A398 07/01/2021 ML21140A391 2019-1 Miscellaneous Corrections 12/18/2022 Proposed No Comments Parts 2, 21, 37, 50, 52, 73, and 110 ML21140A398 07/01/2021 ML21140A391 2019-2 Organizational Changes and Conforming 12/30/2022 Proposed No Comments Amendments ML21140A398 07/01/2021 Parts 1, 2, 37, 40, 50, 51, 52, 55, 71, 72, 73, 74, ML21140A391 100, 140, and 150 2020-1 Individual Monitoring Devices 06/16/2023 Proposed No Comments 10 CFR Parts 34, 36, and 39 ML21140A398 07/01/2021 ML21140A391 2020-2 Social Security Number Fraud Prevention 08/17/2023 Proposed No Comments 10 CFR Parts 9 and 35 ML21140A398 07/01/2021 ML21140A391 14 Enclosure 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2020-3 Miscellaneous Corrections 11/16/2023 Proposed No Comments 10 CFR Parts 1, 2, 19, 20, 21, 30, 34, 35, 40, 50, ML21140A398 07/01/2021 51, 52, 60, 61, 62, 63, 70, 71, 72, 73, 74, 75, 76, ML21140A391 110, and 140 N/A Provision corresponding to Parts 19, 20, 30, 31, 35 N/A Proposed Comments not associated with specific RATS IDs ML14234A134 10/21/2014 ML14232A319 Final No Comments ML15237A085 10/15/2015 ML15236A292 N/A Provisions corresponding to N/A Proposed Comment Comment re: 71.97(a)

Parts 30, 35, 70, 71 150 not associated with specific ML18032A474 03/16/2018 RATS IDs ML18032A473 Final No Comments ML19260G060 10/03/2019 ML19256B601 N/A Provisions corresponding to Parts 30.32(a)&(d), N/A Proposed No Comments 30.36, 40.31, 40.42, 70.21, 70.25, 70.38, 71.0, ML19260G060 10/03/2019 71.101, and 150.20 ML19256B601 N/A Provisions corresponding to Part 20, Appendix B, Proposed No Comments Parts 32.51a(a)(2), 35.12 b(1) and c(1), 35.13(i), ML21140A398 07/01/2021 35.14(a), ML21140A391 15 Enclosure 2

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