ML21272A190

Letter to J Wood Re Washington FY2022 Impep Scheduling Letter and Questionnaire

ML21272A190
Person / Time
Issue date:	10/04/2021
From:	Kathy Modes NRC/NMSS/DMSST/ASPB
To:	Jeffery Wood State of WA, Dept of Health, Div of Radiation Protection
Modes K
References
Download: ML21272A190 (24)

Text

First UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 4, 2021 Ms. Jill Dinehart Wood, Director Office of Radiation Protection Washington Department of Health P. O. Box 47827 Olympia, WA 98504-7827

Dear Ms. Wood:

The U.S. Nuclear Regulatory Commission (NRC) uses the Integrated Materials Performance Evaluation Program (IMPEP) for the evaluation of Agreement State programs. I will be the team leader for the IMPEP review of the Washington Agreement State Program scheduled for January 10-14, 2022. Please note that the NRC typically conducts IMPEP reviews in person; however, in the event of continued travel restrictions associated with the COVID-19 public health emergency, the NRC will contact you to determine if we need to postpone. The review team will include Sherrie Flaherty, State of Minnesota; Joseph OHara, NRC Headquarters; Stephen Poy, NRC Headquarters; Randy Ragland, NRC Region I; Betsy Ullrich, NRC Region I; Latisha Hanson, NRC Region IV; Randy Erickson, NRC Region IV; Gehan Flanders, State of Texas; and Muhammadali Abbaszadeh, State of Texas.

Enclosed is the Integrated Materials Performance Evaluation Program Questionnaire. The questionnaire was previously provided to Earl Fordham, of your staff, electronically on August 11, 2021. I ask that you provide your responses via e-mail to Kathy.Modes@nrc.gov by December 27, 2021 or sooner. As discussed during a call with your Program on September 15, 2021, we are establishing a secure cloud-based data system (drop box) so that you can upload electronic documents as you develop them to allow team members sufficient time to prepare for the onsite review. The questionnaire was sent 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.

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 and to the extent possible, uploaded with the questionnaire responses prior to the commencement of the IMPEP review. I also included a copy of your latest State Regulations Status data sheet. Please let us know if this does not accurately reflect the current status of legislation and regulations required for compatibility.

Please set up an appointment with the appropriate State Senior Managers to discuss the results of the IMPEP review of the Washington Agreement State Program on January 14, 2022.

J. Wood If your Program experiences any difficulties, or delays in preparing for this IMPEP review, please let me know as soon as possible.

If you have any questions, please call me at (215) 872-5804.

Sincerely, Signed by Modes, Kathleen on 10/04/21 Kathy Dolce Modes Health Physicist State Agreement and Liaison Programs Branch Division of Materials Safety, Security, State, and Tribal Programs Office of Nuclear Material Safety and Safeguards

Enclosures:

2022 IMPEP Questionnaire State Regulation Status Data Sheet cc: Earl Fordham, Deputy Director Office of Radiation Protection Washington Department of Health PO Box 47827 Olympia, WA 98504-7827

ML21272A190 letter OFFICE NMSS/MSST NAME KDModes DATE 10/4/2021 Approved by OMB1 Control No.: 3150-0183 Expires: 02/28/2023 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE Washington Agreement State Program Reporting Period: May 5, 2018 - January 14, 2022 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.

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 (5) Date Due 3

(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 2800 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.

4

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. Legislation, Regulations and Other Program Elements (formerly 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 5

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 6

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.

7

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 Emergency plan and communications list 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 8

STATE REGULATION STATUS State: Washington Tracking Ticket Number: 19-13 Date: 01/30/2019

[ # amendment(s) reviewed identified by a *at the beginning of the equivalent NRC requirement.]

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Package Notes State Adoption Letter 1991-1 Safety Requirements for Radiographic Equipment 01/10/1994 Final No Comments Washington has adopted Final Part 34 07/14/1998 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 Washington 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 06/03/1998 56 FR 23360; 56 FR 61352; 57 FR 38588; 57 FR 57877; 12/15/1998 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 08/30/1999 56 FR 64980 1992-1 Quality Management Program and Misadministrations 01/27/1995 Final No Comments Washington has adopted Final Part 35 06/29/1999 Regulations equivalent to RATS ID:

56 FR 34104 2002-2.

(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 of Parts 30 and 35 Compatibility.

57 FR 45566

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Package Notes State Adoption Letter 1993-1 Decommissioning Recordkeeping and License 10/25/1996 Final No Comments Termination: Documentation Additions [Restricted areas 05/28/1997 and spill sites]

Parts 30 and 40 58 FR 39628 1993-2 Licensing and Radiation Safety Requirements for 07/01/1996 Proposed No Comments Irradiators ML18044A469 03/16/2018 Part 36 ML18044A467 58 FR 7715 License Condition No Comments ML18124A092 5/24/2018 ML18124A091 Final No Comments ML18228A702 09/07/2018 ML18228A699 1993-3 Definition of Land Disposal and Waste Site QA Program 07/22/1996 Final No Comments Part 61 10/13/1998 58 FR 33886 1994-1 Self-Guarantee as an Additional Financial Mechanism none Not Required Not Required These regulation changes are not Parts 30, 40 and 70 required to be adopted for purposes of 58 FR 68726; 59 FR 1618 Compatibility.

1994-2 Uranium Mill Tailings Regulations: Conforming NRC 07/01/1997 Final No Comments Requirements to EPA Standards 10/13/1998 Part 40 59 FR 28220 1994-3 Timeliness in Decommissioning Material Facilities 08/15/1997 Final No Comments Parts 30, 40 and 70 05/28/1997 59 FR 36026 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Package Notes State Adoption Letter 1995-1 Preparation, Transfer for Commercial Distribution, and 01/01/1998 Final No Comments Use of Byproduct Material for Medical Use 06/29/1999 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 06/29/1999 Part 20 60 FR 7900 1995-3 Low-Level Waste Shipment Manifest Information and 03/01/1998 Final No Comments Reporting 10/13/1998 Parts 20 and 61 60 FR 15649; 60 FR 25983 1995-4 Performance Requirements for Radiography Equipment 06/30/1998 Final No Comments Washington has adopted Final Part 34 07/26/1999 Regulations equivalent to RATS ID:

60 FR 28323 1997-5.

(Superceded by 1997-5) 1995-5 Radiation Protection Requirements: Amended 08/14/1998 Final No Comments Definitions and Criteria 06/15/2000 Parts 19 and 20 60 FR 36038 1995-6 Clarification of Decommissioning Funding Requirements 11/24/1998 Final No Comments Parts 30, 40 and 70 07/26/1999 60 FR 38235 1995-7 Medical Administration of Radiation and Radioactive 10/20/1998 Final No Comments Washington has adopted Final Materials 06/29/1999 Regulations equivalent to RATS IDs:

Parts 20 and 35 2002-2 and 2005-2.

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

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Package Notes State Adoption Letter 1996-1 Compatibility with the International Atomic Energy 04/01/1999 Final No Comments Washington has adopted Final Agency 10/25/1999 Regulations equivalent to RATS ID:

Part 71 2004-1.

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

61 FR 1109 1996-3 Termination or Transfer of Licensed Activities: 06/17/1999 Final No Comments Recordkeeping Requirements 10/25/1999 Parts 20, 30, 40, 61 and 70 61 FR 24669 1997-1 Resolution of Dual Regulation of Airborne Effluents of 01/9/2000 Final No Comments Radioactive Materials; Clean Air Act ML062960292 11/28/2006 Part 20 ML063250177 61 FR 65120 1997-2 Recognition of Agreement State Licenses in Areas Under 02/27/2000 Final No Comments Exclusive Federal Jurisdiction Within an Agreement 10/25/1999 State Part 150 62 FR 1662 1997-3 Criteria for the Release of Individuals Administered 05/29/2000 Final No Comments Radioactive Material 06/29/1999 Parts 20 and 35 62 FR 4120 4

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Package Notes State Adoption Letter 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 of 62 FR 5907 Compatibility. (See STP-97-078)

(Superceded by 2004-1) 1997-5 Licenses for Industrial Radiography and Radiation Safety 06/27/2000 Final No Comments Requirements for Industrial Radiography Operations 06/15/2000 Parts 30, 34, 71 and 150 62 FR 28947 1997-6 Radiological Criteria for License Termination 08/20/2000 Final No Comments Parts 20, 30, 40 and 70 06/09/2000 62 FR 39057 1997-7 Exempt Distribution of a Radioactive Drug Containing 01/02/2001 Final No Comments One Microcurie of Carbon-14 Urea ML012770299 02/22/2002 Part 30 ML020570410 62 FR 63634 1998-1 Deliberate Misconduct by Unlicensed Persons 02/12/2001 Final No Comments Parts 30, 40, 61, 70, 71 and 150 ML012770299 02/22/2002 63 FR 1890; 63 FR 13773 ML020570410 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 of Parts 30, 40 and 70 Compatibility.

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

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

2002-2.

5

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Package Notes State Adoption Letter 1998-4 Licenses for Industrial Radiography and Radiation Safety 07/09/2001 Final No Comments Requirements for Industrial Radiographic Operations 06/15/2000 Part 34 63 FR 37059 1998-5 Minor Corrections, Clarifying Changes, and a Minor 10/26/2001 Final No Comments Policy Change ML012770291 02/22/2002 Parts 20, 32, 35, 36 and 39 ML020570410 63 FR 39477; 63 FR 45393 1998-6 Transfer for Disposal and Manifests: Minor Technical 11/20/2001 Final No Comments Conforming Amendment 07/28/1999 Part 20 63 FR 50127 1999-1 Radiological Criteria for License Termination of 06/11/2002 Final No Comments Uranium Recovery Facilities ML022410086 09/17/2002 Part 40 ML022630066 64 FR 17506 1999-2 Requirements for Those Who Possess Certain Industrial 10/04/2002 Not Required Not Required These regulation changes are not Devices Containing Byproduct Material to Provide required to be adopted for purposes of Requested Information Compatibility.

Part 31 64 FR 42269 1999-3 Respiratory Protection and Controls to Restrict Internal 02/02/2003 Final No Comments Exposure ML012770291 02/22/2002 Part 20 ML020570410 64 FR 54543; 64 FR 55524 2000-1 Energy Compensation Sources for Well Logging and 05/17/2003 Final No Comments Other Regulatory Clarifications ML030830470 04/18/2003 Part 39 ML031110100 65 FR 20337 6

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Package Notes State Adoption Letter 2000-2 New Dosimetry Technology 01/08/2004 Final No Comments Parts 34, 36 and 39 ML030830470 04/18/2003 65 FR 63750 ML031110100 2001-1 Requirements for Certain Generally Licensed Industrial 02/16/2004 Final No Comments Devices Containing Byproduct Material ML13345A414 02/20/2014 Parts 30, 31 and 32 ML13345A370 65 FR 79162 2002-1 Revision of the Skin Dose Limit 04/05/2005 Final No Comments Part 20 ML043510236 12/29/2004 67 FR 16298 ML043650051 2002-2 Medical Use of Byproduct Material 10/24/2005 Final No Comments Parts 20, 32 and 35 ML061790303 07/17/2006 67 FR 20249 ML061990221 2003-1 Financial Assurance for Materials Licensees 12/03/2006 Final No Comments Parts 30, 40 and 70 ML0707170180 02/01/2007 68 FR 57327 ML070310005 2004-1 Compatibility With IAEA Transportation Safety 10/01/2007 Final No Comments Standards and Other Transportation Safety Amendments ML101930066 08/05/2010 Part 71 ML102010129 69 FR 3697 2005-1 Security Requirements for Portable Gauges Containing 07/11/2008 Final No Comments Byproduct Material ML071580618 01/23/2008 Part 30 ML080230413 70 FR 2001 2005-2 Medical Use of Byproduct Material - Recognition of 04/29/2008 Final No Comments Specialty Boards ML061790303 07/17/2006 Part 35 ML061990221 70 FR 16336; 71 FR 1926 7

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Package Notes State Adoption Letter 2005-3 Increased Controls for Risk-Significant Radioactive 12/01/2005 License Condition No Comments Sources (NRC Order EA-05-090) ML053220233 11/18/2005 70 FR 72128 ML053220464 2006-1 Minor Amendments 03/27/2009 Final No Comments Parts 20, 30, 32, 35, 40 and 70 ML101930066 08/05/2010 71 FR 15005 ML102010129 2006-2 National Source Tracking System - Serialization 02/06/2007 Final No Comments Requirements ML090680060 04/28/2009 Part 32 with reference to Part 20 Appendix E ML090970038 71 FR 65685 2006-3 National Source Tracking System 01/31/2009 Final No Comments Part 20 ML090680060 04/28/2009 71 FR 65685, 72 FR 59162 ML090970038 2007-1 Medical Use of Byproduct Material - Minor Corrections 10/29/2010 Final No Comments and Clarifications ML090680060 04/28/2009 Parts 32 and 35 ML090970038 72 FR 45147, 54207 2007-2 Exemptions From Licensing, General Licenses, and 12/17/2010 Final Comments Distribution of Byproduct Material: Licensing and ML13345A414 02/20/2014 Reporting Requirements ML13345A370 Parts 30, 31, 32 and 150 72 FR 58473 Revised Final No Comments ML14316A422 12/19/2014 ML14316A106 Revised Final No Comments ML15037A538 03/06/2015 ML15037A522 8

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Package Notes State Adoption Letter 2007-3 Requirements for Expanded Definition of Byproduct 11/30/2010 Final No Comments Material ML12216A122 09/05/2012 Parts 20, 30, 31, 32, 33, 35, 61 and 150 ML12228A415 72 FR 55864 2007-4 Order Imposing Fingerprinting Requirements and 06/05/2008 License Condition No Comments Criminal History Records Check Requirements for ML080430011 02/26/2008 Unescorted Access to Certain Radioactive Material ML080560453 NRC Order EA-07-305 72 FR 70901 2008-1 Occupational Dose Records, Labeling Containers, and 02/15/2011 Final No Comments Total Effective Dose Equivalent ML13352A110 01/23/2014 Parts 19 and 20 ML13352A103 72 FR 68043 2009-1 Medical Use of Byproduct Material - Authorized User 09/28/2012 Final No Comments Clarification ML14062A117 04/14/2014 Part 35 ML14062A109 74 FR 33901 2011-1 Decommissioning Planning 12/17/2015 Proposed No Comments Parts 20, 30, 40 and 70 ML14316A422 12/19/14 76 FR 35512 ML14316A106 Final No Comments ML15037A538 03/06/2015 ML15037A522 9

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Package Notes State Adoption Letter 2011-2 Licenses, Certifications, and Approvals for Materials 11/14/2014 Proposed No Comments Licensees ML14316A422 12/19/14 Parts 30, 36, 39, 40, 70 and 150 ML14316A106 76 FR 56951 Final No Comments ML15037A538 03/06/2015 ML15037A522 2012-1 Change of Compatibility 01/25/2015 Final No Comments Parts 31.5 and 31.6 ML13345A414 02/20/2014 (See RATS ID: 2001-1 for Rule text) ML13345A370 77 FR 3640 2012-2 Advance Notification to Native American Tribes of 08/10/2015 Final No Comments Transportation of Certain Types of Nuclear Waste ML14062A117 04/14/2014 Part 71 ML14062A109 77 FR 34194 2012-3 Technical Corrections 08/06/2015 Proposed No Comments Parts 30, 34, 40 and 71 ML16125A484 6/13/2016 77 FR 39899 ML16125A478 Final No Comments ML17089A298 04/11/2017 ML17088A647 2012-4 Requirements for Distribution of Byproduct Material 10/23/2015 Proposed Comments Parts 30, 31, 32, 40 and 70 ML16125A484 6/13/2016 77 FR 43666 ML16125A478 Final No Comments ML17040A466 03/22/2017 ML17040A444 10

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Package Notes State Adoption Letter 2013-1 Physical Protection of Byproduct Material, 03/19/2016 Proposed Comments Part 37 only Parts 20, 30, 32, 33, 34, 35, 36, 37, 39 and 71 ML15252A335 11/02/2015 78 FR 16922 ML15252A322 Proposed Comments All Parts ML16125A484 6/13/2016 ML16125A478 Final No Comments All Parts ML17040A466 03/22/2017 ML17040A444 2013-2 Distribution of Source Material to Exempt Persons and to 08/27/2016 Proposed Comments General Licensees and Revision of ML16125A484 6/13/2016 General License and Exemptions, ML16125A478 Parts 30, 40 and 70 78 FR 32310 Final No Comments ML17040A466 03/22/2017 ML17040A444 2015-1 Domestic Licensing of Special Nuclear Material - 01/26/2018 Proposed No Comments Written Reports and Clarifying Amendments ML16125A484 6/13/2016 Part 70 ML16125A478 79 FR 57721, 80 FR 143 Final No Comments ML17089A298 04/11/2017 ML17088A647 11

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Package Notes State Adoption Letter 2015-2 Safeguards Information - Modified Handling 01/28/2018 Proposed Comments Part 37 only Categorization, Change for Materials Facilities ML15273A326 11/02/2015 Parts 30, 37, 73 and 150 ML15252A322 79 FR 58664, 80 FR 3865 Proposed No Comments All Parts ML16125A484 6/13/2016 ML16125A478 Final No Comments All Parts ML17089A298 04/11/2017 ML17088A647 2015-3 Revisions to Transportation Safety Requirements and 07/13/2018 Proposed Comments Harmonization with International Atomic Energy Agency *extended to ML16230A482 09/16/2016 Transportation Requirements 08/15/2020 ML16230A481 Part 71 See STC 17-060 80 FR 33987 Final No Comments ML16363A140 1/31/2017 ML16363A131 2015-4 Miscellaneous Corrections, 09/02/2018 Proposed No Comments Part 37 only Parts 37 and 40 ML15273A326 11/02/2015 80 FR 45841 ML15252A322 Proposed Comment All Parts ML16125A484 6/13/2016 ML16125A478 Final No Comments All Parts ML17040A466 03/22/2017 ML17040A444 12

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Package Notes State Adoption Letter 2015-5 Miscellaneous Corrections, 12/31/2018 Proposed No Comments Parts 19, 20, 30, 32, 37, 40, 61, 70, 71 and 150 ML16230A482 09/16/2016 80 FR 74974 ML16230A481 Final No Comments ML16363A140 1/31/2017 ML16363A131 2018-1 Medical Use of Byproduct Material - Medical Event 01/14/2022 Definitions, Training and Experience, and Clarifying Amendments, Parts 30, 32 and 35 2018-2 Miscellaneous Corrections - 12/21/2021 Organizational Changes 10 CFR Parts 37, 40. 70 and 71 2018-3 Miscellaneous Corrections 07/30/2022 10 CFR Parts 1, 2, 34, 37, 50, 71, 73, and 140 2019-1 Miscellaneous Corrections 12/18/2022 10 CFR Parts 2, 21, 37, 50, 52, 73, and 110 2019-2 Organizational Changes and Conforming Amendments 12/30/2022 10 CFR Parts 1, 2, 37, 40, 50, 51, 52, 55, 71, 72, 73, 74, 100, 140, and 150 2020-1 Individual Monitoring Devices 06/16/2023 10 CFR Parts 34, 36, and 39 2020-2 Social Security Number Fraud Prevention 08/17/2023 10 CFR Parts 9 and 35 13

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Package Notes State Adoption Letter 2020-3 Miscellaneous Corrections 11/16/2023 10 CFR Parts 1, 2, 19, 20, 21, 30, 34, 35, 40, 50, 51, 52, 60, 61, 62, 63, 70, 71, 72, 73, 74, 75, 76, 110, and 140 N/A Part 20.1003 N/A Proposed No Comments ML13122A287 01/12/2015 ML15007A232

• N/A Part 20.1201(a)(1)(ii) N/A Final No Comments ML19017A149 01/30/2019 ML19017A148 14