ML22075A220

02-11-2022 Texas Dshs Impep Questionnaire

ML22075A220
Person / Time
Issue date:	02/11/2022
From:	Office of Nuclear Material Safety and Safeguards
To:
White D
Shared Package
ML22075A193	List: ML22075A209 ML22075A220 ML22075A250 ML22075A252
References
OMB 3150-0183
Download: ML22075A220 (64)

Text

Approved by OMB1 Control No.: 3150-0183 Expires: 02/28/2023

INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE FOR THE STATE OF TEXAS

Reporting Period: February 10, 2018 - March 4, 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;

See Appendix B-1

(b) A chart showing positions of the radiation control program, including management; and

See Appendix B-2

(c) Equivalent charts for sealed source and device evaluation, low-level radioactive waste and uranium recovery programs, if applicable.

See Appendix B-3

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%

See Appendix B-4

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.

See Appendix B-5

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.

See Appendix B-6

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

The qualifications for new license reviewers were modified by expanding the detail of the types of licenses that the reviewers need to complete for the On-The-Job signoffs. The types of licenses were tailored for the industrial and medical/academic programs to address all the types of licenses that that group processes. This has extended the initial qualification timeframe from approximately 9 months to approximately 18 months.

There were no changes to the inspector qualification and training program.

SS&D: We changed the training procedure but have not applied it yet. New SS&D reviewers have an in-house review of the SS&D workshop training to count towards SS&D reviewer qualification before attending the NRC -

sponsored SS&D workshop. The in-house SS&D workshop training will use past NRC workshop training materials with current SS&D reviewers as presenters of the information.

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

See Appendix B-7

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.

See Appendix B-8

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.

The Texas Radiation Advisory Board (TRAB) is an 18-member, governor-appointed advisory board mandated by statute (Health and Safety Code, Chapter 401). Representation on the board is specified in statute and includes:

- a representative of nuclear physics, science, or nuclear engineering;

- a representative of labor;

- a representative of agriculture;

- a representative of the insurance industry;

- a hospital administrator;

- a representative who is engaged in the use and application of nuclear physics in medicine and is certified by the American Board of Radiology or licensed by the Texas Board of Licensure for Professional Medical Physicists;

- an individual licensed by the Texas Medical Board who specializes in nuclear medicine;

- an individual licensed by the Texas Medical Board who specializes in pathology;

- an individual licensed by the Texas Medical Board who specializes in radiology;

- a representative of the nuclear utility industry;

- a representative of the radioactive waste industry;

- a representative of the petroleum industry;

- a health physicist certified by the American Board of Health Physics;

- an individual licensed by the Texas Dental Board;

- a representative of the uranium mining industry; and

- three representatives of the public.

TRAB provides recommendations and technical advice on matters relating to development, use, and regulation of sources of radiation to the three agencies with regulatory responsibility for radiation, DSHS, TCEQ and the Railroad Commission of Texas. Chapter 401 specifies the circumstances under which a person would not be eligible to serve on TRAB to avoid conflict of interest. The statute further requires that each TRAB member receive training in the appropriate statutes and rules, including conflict of interest laws. Chapter 289.130 contains rules governing the TRAB and its actions.

See Appendix B-9 for a list of current TRAB members.

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.

All categories of licensees are inspected at either the same frequency as NRC, or more frequently.

See Appendix B-10 for a list of the inspection intervals by modifier type.

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.

For inspection period 2/10/2018 through 12/31/2021:

2018 2019 2020 2021 Total Priority 1 43 51 56 74 224 Priority 2 49 78 52 95 274 Priority 3 107 84 97 74 362 Initial 46 68 58 56 228 Totals 245 281 263 299 1088

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

See Appendix B-11 for Priority 1-3 inspections conducted overdue See Appendix B-12 for initial inspections conducted overdue

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.

There are currently no 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.

1. of Companies # of Inspections % Inspected 2018 22 5 22.7%

2019 37 12 32.4%

2020 19 5 26.3%

2021 35 9 25.7%

III. Technical Quality of Inspections

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

The Texas Inspection manual is being modified to be equivalent to the NRC Chapter 2800, including the updated reciprocity procedure and appropriate adaptations for the Texas Program. Inspection guidance and report forms remain essentially the same, with minor improvements made as needed.

We have developed and implemented several information notices for licensees and enforcement notices for internal use. The Radioactive Materials Information Notice was developed as a collection of periodic notifications as important topics arise regarding inspection procedure, enforcement policy, rule clarification, administrative procedure, and essential information and this document serves as official guidance for performing inspections, training, and administrative tasks.

All useful information contained in the Work Instruction documents is being incorporated into either the updated inspection manual or the radioactive materials group information notice. Once this task is completed, the Work Instruction documents will be retired.

Once the draft NRC Inspection Procedures are final, we plan to incorporate them into our inspection procedures, possibly by reference or by creating essentially equivalent procedures with adaptations to make them unique to the Texas Program.

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

Inspector Supervisor License Category Date

See Appendix B-13

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?

The radioactive materials inspectors are provided with the following instruments at a minimum:

• Ludlum 2241 with a 1x1 scintillation probe, an energy compensated G/M probe, a G/M pancake probe, and a low energy gamma probe

• Thermo Scientific RadEye SPRD-GN spectroscopic Personal Radiation Detector

• Ludlum 2363 with 42-41L neutron probe

• BNC model 940 radiation isotope identifier See Appendix B-14 for Instrument Calibration Status See Appendix B-15 for Calibration Procedures

IV. Technical Quality of Licensing Actions

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

As of 1/18/2022:

Medical Licenses: 703 Industrial Licenses: 639 Advanced Technology Licenses: 49 RAM Reciprocity: 89

88 SS&D were issued during the review period

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.

See Appendix B-16

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

The RAM Licensing Unit migrated to using electronic document handling and storage in SharePoint instead of processing hardcopy applications and archiving hardcopy files on microfiche. Starting in August 2019, the RAM Licensing unit began dual use of electronic and paper file handling and then converted to electronic files only in December 2019 of new incoming requests.

The changes to the licensing procedures include the following:

• Starting July/August 2020, we began to use digital signatures on licenses.

• Starting Sept/Oct 2020, we began to deliver electronic copies of licenses via secure email. A follow-up letter is sent via regular mail to the licensee contact person advising them that an electronic copy was sent.

• Starting October 2020, we modified the handling of transfer of control applications to give a prior review and approval of the transfer of control.

With the review we also determine whether a new license or license amendment is appropriate for the particular action.

The RAM Licensing Unit uses a rule exemption process prior to deviating from rule requirements that includes review and approval by management.

The exemptions are classified as specific for a specific licensee, or generic for all applicable licensees. The exemptions granted during the review period for radioactive materials licenses are listed below.

• E18 rule 25 TAC §289.255(u)(4)(B) - permitted storage of radiography camera at a residential location (in separate building on the owners property) for a specific licensee

• E19 rule §289.255(u)(4)(B) - permitted storage of radiography camera at a residential location (in separate building on the owners property) for a specific licensee

• E19 rule 25 TAC §289.255(u)(4)(B) - permitted storage of radiography camera at a residential location (in separate building on the owners property) for a specific licensee

• E20 rule 25 TAC §289.255(e)(4)(B)(i) - permitted an individual to be a radiography RSO while completing his GED for a specific licensee

• E20 rule 25 TAC §289.255(u)(4)(B) - permitted storage of radiography camera at a residential location (in separate building on the owners property) for a specific licensee

• Generic exemption L020 (5-4-21) - rules 25 TAC §289.256(h), (j), (k), (l),

(gg), (jj), (nn), (oo), (pp), (qq), (zz), (aaa), and (ttt) - permitted reviewer acceptance of licensee using NRC training and experience criteria for AU for medical licensees

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

The changes made to the licensing program documentation during the review period include:

• Updating the RSRM review form to match NRC changes

• Updating the Pre-Licensing guidance to match NRC changes

• Generated internal procedures on entering license actions into the database and our SharePoint site by license reviewers as we move to electronic handling of documents.

• The Medical Licensing guidance document was updated in November 2018 to be consistent with NRC NUREG 1556 Volume 9 while still operating under the old medical rules.

• The Portable Gauge licensing guidance was updated in March 2021 to be consistent with NRC NUREG Volume 1

The revision to our rules effective January 4, 2022, incorporated changes to be more consistent with the NRC language and compatibility D regulations.

We intend to incorporate these changes by referencing many NRC NUREG guidance documents.

Changes to licensing procedures that have not been consolidated i nto formal procedures are listed above as policy and procedure variances.

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.

License number L05278 for IIA Nuclear Services Inc expired September 30, 2020 and has been in renewal for more than one year. The licensee has had complications with completing the revision to their decommissioning cost estimate. The renewal will be completed when we have received and approved the revised Decommissioning Funding Plan.

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

No additional events to report

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

The Incident Investigation Program procedure was changed to meet the reporting requirements of Texas Health and Safety Code, 501.0245. This requires the program to report certain events to local authorities as well as some emergency response groups.

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.

House Bill 2203, 86th Legislature, Regular Session (2019) added Section 501.0245 requiring the notification of each affected political subdivision of the state when a state agency received a required report of a release of a radioactive substance.

House Bill 7, 87th Legislature, Special Session 2 (2021) amended Section 401.003 of the Health and Safety Code to forbid the approval of a general construction permit or a Stormwater Pollution Prevention Plan under Section 26.040, Water Code, or a permit under the Texas Pollutant Discharge Elimination System Program under Section 26.027, 26.028, or 26.121, Water Code, for the construction or operation of a facility that is licensed for the storage of high-level radioactive waste by the United States Nuclear Regulatory Commission under 10 C.F.R. Part 72. Exceptions were given to facilities located at the site of currently or formerly operating nuclear power reactors and currently or formerly operating nuclear research and test reactors operated by a university.

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

Government Code, Chapter 2001.039 requires Texas state agencies to assess whether the reasons for adopting each rule continue to exist and to review each rule to determine whether it is obsolete, whether it reflects current legal and policy considerations, and whether it reflects current procedures of the agency. As a part of this review, each agency is required to submit notice of intent to the Texas Register for publication.

Each rule is required to be reviewed four years from the last effective date of the rule. Therefore, each section of 25 Texas Administrative Code, Chapter 289 (radiation control rules) has a different four-year review interval.

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.

See Appendix C-1

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.

Texas is compatible with all applicable NRC regulations.

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

See Appendix C-2

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

All applicable SS&D information answered above

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

III. Low-level Radioactive Waste Disposal Program

31. Please include information on the following questions in Section A, as they apply to the Low-Level Radioactive Waste Disposal Program:

Technical Staffing and Training - Questions 2-9 Status of Materials Inspection Program - Questions 10-14 Technical Quality of Inspections - Questions 15-17 Technical Quality of Licensing Actions - Questions 18-22 Technical Quality of Incident and Allegation Activities - Questions 23-24

IV. Uranium Recovery Program

32. Please include information on the following questions in Section A, as they apply to the Uranium Recovery Program:

Technical Staffing and Training - Questions 2-9 Status of Materials Inspection Program - Questions 10-14 Technical Quality of Inspections - Questions 15-17 Technical Quality of Licensing Actions - Questions 18-22 Technical Quality of Incident and Allegation Activities - Questions 23-24 MATERIALS REQUESTED TO BE AVAILABLE FOR THE ON-SITE PORTION OF AN IMPEP REVIEW

Please have the following information available for use by the IMPEP review team when they arrive at your office:

• List of open license cases, with date of original request, and dates of follow-up actions.

• List of licenses terminated during review period.

• Copy of current log or other document used to track licensing actions.

• List of all licensing actions completed during the review period (sorted by license reviewer, if possible).

• Copy of current log or other document used to track inspections.

• List of all inspections completed during the review period (sorted by inspector, if possible).

• List of inspection frequencies by license type.

• List of all allegations occurring during the review period. Show whether the allegation is open or closed and whether it was referred by NRC.

• List of all licenses that your agency has imposed additional security requirements upon.

ALSO, PLEASE HAVE THE FOLLOWING DOCUMENTS AVAILABLE:

• All State regulations

• Documented training plan, if applicable

• Statutes affecting the regulatory authority

• Records of results of supervisory of the State program accompaniments of inspectors

• Standard license conditions

• 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 STATE REGULATION STATUS State: Texas Department of State Health Services Tracking Ticket Number: 21-36 Date: July 29, 2021

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 Texas has adopted Final Part 34 ML051520266 10/31/2005 Regulations equivalent to RATS ID:

55 FR 843 ML053050013 1997-5.

(Superceded by 1997-5)

1991-2 ASNT Certification of Radiographers none Not Required Not Required Texas 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 11/06/1997 56 FR 23360; 56 FR 61352; 57 FR 38588; 57 FR 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 ML052060129 09/29/2005 56 FR 64980; ML052720491

1992-1 Quality Management Program and 01/27/1995 Not Required Not Required Texas has adopted Final Misadministrations Regulations equivalent to RATS ID:

Part 35 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 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 Comments Termination: Documentation Additions [Restricted ML052060129 09/29/2005 areas and spill sites] ML052720491 Parts 30, 40 58 FR 39628 Revised Final No Comments ML18234A459 10/16/2018 ML18234A448

1993-2 Licensing and Radiation Safety Requirements for 07/01/1996 Final No Comments Irradiators ML051520266 08/12/2005 Part 36 ML052280032 58 FR 7715

1993-3 Definition of Land Disposal and Waste Site QA 07/22/1996 Not Applicable Not Applicable Texas DSHS does not have Program responsibility for these regulations.

Part 61 See SRS sheet for Texas CEQ.

58 FR 33886

1994-1 Self-Guarantee as an Additional Financial none Final No Comments These regulation changes are not Mechanism ML062860025 11/21/2006 required to be adopted for purposes Parts 30, 40, 70 ML063200232 of Compatibility.

58 FR 68726; 59 FR 1618

1994-2 Uranium Mill Tailings Regulations: Conforming 07/01/1997 Not Applicable Not Applicable Texas CEQ Responsibility NRC Requirements to EPA Standards Part 40 59 FR 28220

1994-3 Timeliness in Decommissioning Material Facilities 08/15/1997 Final No Comments Parts 30, 40, 70 ML052060129 09/29/2005 59 FR 36026 ML052720491

1995-1 Preparation, Transfer for Commercial Distribution, 01/01/1998 Final No Comments and Use of Byproduct Material for Medical Use 03/17/1999 Parts 30, 32, 35 59 FR 61767; 59 FR 65243; 60 FR 322 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 ML051520266 10/31/2005 Part 20 ML053050013 60 FR 7900

1995-3 Low-Level Waste Shipment Manifest Information 03/01/1998 Final No Comments and Reporting ML112510357 11/22/2011 Parts 20, 61 ML113000228 60 FR 15649; 60 FR 25983

1995-4 Performance Requirements for Radiography 06/30/1998 Final No Comments Texas has adopted Final Equipment ML051520266 10/31/2005 Regulations equivalent to RATS ID:

Part 34 ML053050013 1997-5.

60 FR 28323 (Superceded by 1997-5)

1995-5 Radiation Protection Requirements: Amended 08/14/1998 Final No Comments Definitions and Criteria 03/17/1999 Parts 19, 20 60 FR 36038

1995-6 Clarification of Decommissioning Funding 11/24/1998 Final No Comments Requirements ML052060129 09/29/2005 Parts 30, 40, 70 ML052720491 60 FR 38235

1995-7 Medical Administration of Radiation and Radioactive 10/20/1998 Final No Comments Texas has not yet adopted Final Materials ML051520266 10/31/2005 Regulations equivalent to RATS ID:

Parts 20, 35 ML053050013 2005-2.

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

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 Comments Texas has adopted Final Agency ML052060129 09/29/2005 Regulations equivalent to RATS ID:

Part 71 ML052720491 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 Part 30 only. Part 61 applies to Record keeping Requirements ML062860025 11/21/2006 TXCEQ.

Parts 20, 30, 40, 61, 70 ML063200232 61 FR 24669

1997-1 Resolution of Dual Regulation of Airborne Effluents 01/9/2000 Final No Comments of Radioactive Materials; Clean Air Act 07/07/2000 Part 20 61 FR 65120

1997-2 Recognition of Agreement State Licenses in Areas 02/27/2000 Final No Comments Under Exclusive Federal Jurisdiction Within an ML063030232 11/27/2006 Agreement State ML063200389 Part 150 62 FR 1662

1997-3 Criteria for the Release of Individuals Administered 05/29/2000 Final No Comments Radioactive Material 07/07/2000 Parts 20, 35 62 FR 4120

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)

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

1997-5 Licenses for Industrial Radiography and Radiation 06/27/2000 Final No Comments Safety Requirements for Industrial Radiography 07/07/2000 Operations 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 07/07/2000 62 FR 39057

1997-7 Exempt Distribution of a Radioactive Drug 01/02/2001 Final No Comments Containing One Micro curie of Carbon -14 Urea ML052060129 09/29/2005 Part 30 ML052720491 62 FR 63634

1998-1 Deliberate Misconduct by Unlicensed Persons 02/12/2001 Final No Comments Parts 30, 40, 61, 70, 71, 150 ML063030232 11/27/2006 63 FR 1890; 63 FR 13773 ML063200389

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

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)

Texas has adopted Final Regulations equivalent to RATS ID:

2002-2.

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

1998-4 Licenses for Industrial Radiography and Radiation 07/09/2001 Final No Comments Safety Requirements for Industrial Radiographic ML093110052 01/21/2010 Operations ML093520035 Part 34 63 FR 37059

1998-5 Minor Corrections, Clarifying Changes, and a Minor 10/26/2001 Final No Comments Policy Change 07/07/2000 Parts 20, 32, 35, 36, 39 63 FR 39477; 63 FR 45393

1998-6 Transfer for Disposal and Manifests: Minor 11/20/2001 Final No Comments Technical Conforming Amendment 07/07/2000 Part 20 63 FR 50127

1999-1 Radiological Criteria for License Termination of 06/11/2002 Not Applicable Not Applicable Texas CEQ Responsibility Uranium Recovery Facilities Part 40 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

1999-3 Respiratory Protection and Controls to Restrict 02/02/2003 Final No Comments Internal Exposure ML062750348 11/21/2006 Part 20 ML063200232 64 FR 54543; 64 FR 55524

2000-1 Energy Compensation Sources for Well Logging 05/17/2003 Final No Comments and Other Regulatory Clarifications ML051520266 11/30/2006 Part 39 ML063340007 65 FR 20337 RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package

2000-2 New Dosimetry Technology 01/08/2004 Final No Comments Parts 34, 36, 39 ML093110052 01/21/2010 65 FR 63750 ML093520035

2001-1 Requirements for Certain Generally Licensed 02/16/2004 Final No Comments Note: See RATS ID 2012-1 for the Industrial Devices Containing Byproduct Material ML120650638 04/02/2012 changes of compatibility review.

Parts 30, 31, 32 ML120660270 65 FR 79162

2002-1 Revision of the Skin Dose Limit 04/05/2005 Final No Comments Part 20 ML102240370 11/19/2010 67 FR 16298 ML102740009

2002-2 Medical Use of Byproduct Material 10/24/2005 R1 Comments Parts 20, 32, 35 ML14258B117 12/16/2014 67 FR 20249 ML14258A158

Final No Comments ML15078A299 05/26/2015 ML15078A285

2003-1 Financial Assurance for Materials Licensees 12/03/2006 Final No Comments Parts 30, 40, 70 ML112510357 11/22/2011 68 FR 57327 ML113000228

2004-1 Compatibility with IAEA Transportation Safety 10/01/2007 R1 No Comments Standards and Other Transportation Safety ML14258B117 12/16/2014 Amendments ML14258A158 Part 71 69 FR 3697 Final No Comments ML15078A299 05/26/2015 ML15078A285 RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package

2005-1 Security Requirements for Portable Gauges 07/11/2008 Final No Comments Containing Byproduct Material ML093110052 01/21/2010 Part 30 ML093520035 70 FR 2001

2005-2 Medical Use of Byproduct Material - Recognition of 04/29/2008 R1 No Comments Specialty Boards ML14258B117 12/16/2014 Part 35 ML14258A158 70 FR 16336; 71 FR 1926 Final No Comments ML15078A299 05/26/2015 ML15078A285

2005-3 Increased Controls for Risk-Significant Radioactive 12/01/2005 License No Comments Sources (NRC Order EA-05-090) Condition 12/12/2005 70 FR 72128 ML052240226 ML053420404

2006-1 Minor Amendments 03/27/2009 R1 Comments Parts 20, 30, 32, 35, 40 and 70 ML14258B117 12/16/2014 71 FR 15005 ML14258A158

Final No Comments ML15078A299 05/26/2015 ML15078A285

2006-2 National Source Tracking System - Serialization 02/06/2007 Final No Comments Requirements ML093110052 01/21/2010 Part 32 with reference to Part 20 Appendix E ML093520035 71 FR 65685

2006-3 National Source Tracking System 01/31/2009 Final No Comments Part 20 ML093110052 01/21/2010 71 FR 65685, 72 FR 59162 ML093520035 RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package

2007-1 Medical Use of Byproduct Material - Minor 10/29/2010 Final No Comments Corrections and Clarifications ML102240370 11/19/2010 Parts 32 and 35 ML102740009 72 FR 45147, 54207

2007-2 Exemptions from Licensing, General Licenses, and 12/17/2010 Final Comments Distribution of Byproduct Material: Licensing and ML15078A299 05/26/2015 Reporting Requirements ML15078A285 Parts 30, 31, 32, 150 72 FR 58473 Revised Final No Comments ML15300A187 02/08/2016 ML15300A167

Revised Final Comments ML16076A353 06/16/2016 ML16076A350

Revised Final No Comments ML18234A459 10/16/2018 ML18234A448

2007-3 Requirements for Expanded Definition of Byproduct 11/30/2010 Final Comments Material ML15078A299 05/26/2015 Parts 20, 30, 31, 32, 33, 35, 61, 150 ML15078A285 72 FR 55864 Revised Final Comments ML15300A187 02/08/2016 ML15300A167

Revised Final Comments ML16076A353 06/16/2016 ML16076A350

Revised Final Comments ML18234A459 10/16/2018 ML18234A448 RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package

2007-4 Order Imposing Fingerprinting Requirements and 06/05/2008 License No Comments Criminal History Records Check Requirements for Condition 02/13/2008 Unescorted Access to Certain Radioactive Material ML080350004 ML080440203 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 ML112510357 11/22/2011 Parts 19, 20 ML113000228 72 FR 68043

2009-1 Medical Use of Byproduct Material - Authorized 09/28/2012 Final No Comments User Clarification ML112510357 11/22/2011 Part 35 ML113000228 74 FR 33901 Proposed Comment 2011-1 Decommissioning Planning 12/17/2015 ML16218A245 09/10/2016 Parts 20, 30, 40, and 70 ML16218A244 76 FR 35512 Final Comment ML16321A333 01/18/2017 The ADAMS package and ML16321A324 associated documents incorrectly characterize this submission as Proposed Comment revised final regulations instead of ML18162A279 6/19/2018 proposed regulations.

ML18162A244

Final No Comments ML18319A068 12/07/2018 ML18317A175 RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package

2011-2 Licenses, Certifications, and Approvals for Materials 11/14/2014 Proposed No Comments Licensees ML14258B117 12/16/2014 Parts 30, 36, 39, 40, 70, and 150 ML14258A158 76 FR 56951 Final Comments ML15078A299 05/26/2015 ML15078A285

Revised Final Comment ML15300A187 02/08/2016 ML15300A167

Revised Final Comments ML16076A353 06/16/2016 ML16076A350

Revised Final No Comments ML18234A459 10/16/2018 ML18234A448

2012-1 Change of Compatibility of 10 CFR 31.5 and 31.6 01/25/2015 Final No Comments (See RATS ID: 2001-1 for Rule text) ML120650638 04/02/2012 77 FR 3640 ML12066270

2012-2 Advance Notification to Native American Tribes of 08/10/2015 Proposed No Comments Transportation of Certain Types of Nuclear Waste ML14258B117 12/16/2014 Part 71 ML14258A158 77 FR 34194 Final No Comments ML15078A299 05/26/2015 ML15078A285 RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package

2012-3 Technical Corrections 08/06/2015 Proposed No Comments Part 30, 34, 40 and 71 ML14258B117 12/16/2014 77 FR 39899 ML14258A158

Final No Comments ML15078A299 05/26/2015 ML15078A285

2012-4 Requirements for Distribution of Byproduct Material 10/23/2015 Proposed Comments Parts 30, 31, 32, 40 and 70 ML14258B117 12/16/2014 77 FR 43666 ML14258A158

Final Comments ML15078A299 05/26/2015 ML15078A285

Revised Final Comment ML15300A187 02/08/2016 ML15300A167

Revised Final Comments ML16076A353 06/16/2016 ML16076A350

Revised Final No Comments ML18234A459 10/16/2018 ML18234A448

2013-1 Physical Protection of Byproduct Material, 10 CFR 03/19/2016 Proposed Comments Parts 20, 30, 32, 33, 34, 35, 36, 37, 39, and 71 ML15300A238 12/01/2015 78 FR 16922 ML15300A222

Final No Comments ML16076A353 06/16/2016 ML18076A350 RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package

2013-2 Distribution of Source Material to Exempt Persons 08/27/2016 Proposed No Comments and to General Licensees and Revision of General ML15300A238 12/01/2015 License and Exemptions, 10 CFR Parts 30, 40, and ML15300A222 70 78 FR 32310 Final Comments ML16076A353 06/16/2016 ML16076A350

Revised Final No Comments ML18234A459 10/16/2018 ML18234A448

2015-1 Domestic Licensing of Special Nuclear Material - 01/26/2018 Proposed No Comments Written Reports and Clarifying Amendments ML15300A238 12/01/2015 Part 70 ML15300A222 79 FR 57721, 80 FR 143 Final No Comments ML16076A353 06/16/2016 ML16076A350

2015-2 Safeguards Information - Modified Handling 01/28/2018 Proposed No Comments Categorization, Change for Materials Facilities ML15300A238 12/01/2015 Parts 30, 37, 73, and 150 ML15300A222 79 FR 58664, 80 FR 3865 Final No Comments ML16076A353 06/16/2016 ML16076A350

• 2015-3 Revisions to Transportation Safety Requirements 07/13/2018 Proposed Comments and Harmonization with International Atomic *extended to ML18234A459 10/16/2018 Energy Agency Transportation Requirements 08/15/2020 ML18234A448 Part 71 See STC 17-060 80 FR 33987 Final No Comments ML21182A354 07/29/2021 ML21182A323 RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package

2015-4 Miscellaneous Corrections, Parts 37 and 40 09/02/2018 Proposed No Comments 80 FR 45841 ML18234A459 10/16/2018 ML18234A448

Final No Comments ML21182A354 07/29/2021 ML21182A323

2015-5 Miscellaneous Corrections 12/31/2018 Proposed Comments Parts 19, 20, 30, 32, 37, 40, 61, 70, 71, and 150 ML18234A459 10/16/2018 80 FR 74974 ML18234A448

Final No Comments ML21182A354 07/29/2021 ML21182A323

2018-1 Medical Use of Byproduct Material - Medical Event 01/14/2022 Proposed Comments Definitions, Training and Experience, and Clarifying ML21182A354 07/29/2021 Amendments ML21182A323 Parts 30, 32 and 35

2018-2 Miscellaneous Corrections - 12/21/2021 Proposed No Comments Organizational Changes ML21182A354 07/29/2021 Parts 37, 40. 70 and 71 ML21182A323

2018-3 Miscellaneous Corrections 07/30/2022 Proposed Comments Parts 1, 2, 34, 37, 50, 71, 73, and 140 ML21182A354 07/29/2021 ML21182A323

2019-1 Miscellaneous Corrections 12/18/2022 Proposed No Comments Parts 2, 21, 37, 50, 52, 73, and 110 ML21182A354 07/29/2021 ML21182A323 RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package

2019-2 Organizational Changes and Conforming 12/30/2022 Proposed No Comments Amendments ML21182A354 07/29/2021 Parts 1, 2, 37, 40, 50, 51, 52, 55, 71, 72, 73, 74, ML21182A323 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 Proposed No Comments 10 CFR Parts 9 and 35 ML21182A354 0729/2021 ML21182A323

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 10 CFR 35.11, 35.63, 35.92 and 35.204 N/A Final No Comments ML112510357 11/22/2011 ML113000228

N/A 10 CFR 34 and 39 Not Associated with a Specific N/A Final Comments RATS ML113340070 01/11/2012 ML113550343

N/A 10 CFR 20, 30, 31, 32, 35, 70 and 71 Not N/A Proposed Comments Associated with a Specific RATS ML14258B117 12/16/2014 ML14258A158

Final Comments Comments are regarding 10 CFR ML15078A299 05/26/2015 Parts 20.1403, 20.1405 and ML15078A285 31.12(c)(4).

STATE REGULATION STATUS State: Texas Commission on Environmental Quality Tracking Ticket Number: 21-13 Date: 12/11/2020

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

1991-1 Safety Requirements for Radiographic Equipment 01/10/1994 Not Applicable Not Applicable TX DSHS Responsibility Part 34 55 FR 843 (Superceded by 1997-5)

1991-2 ASNT Certification of Radiographers none Not Applicable Not Applicable TX DSHS Responsibility Part 34 56 FR 11504 (Superceded by 1997-5)

1991-3 Standards for Protection Against Radiation 01/01/1994 Final No Comments Part 20 11/06/1997 56 FR 23360; 56 FR 61352; 57 FR 38588; 57 FR 57877; 58 FR 67657; 59 FR 41641; 60 FR 20183

1991-4 Notification of Incidents 10/15/1994 Final No Comments Parts 20, 30, 31, 34, 39, 40, and 70 01/07/1998 56 FR 64980

1992-1 Quality Management Program and 01/27/1995 Not Applicable Not Applicable TX DSHS Responsibility Misadministrations Part 35 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 and 35 of Compatibility.

57 FR 45566

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

1993-1 Decommissioning Recordkeeping and License 10/25/1996 Final No Comments Termination: Documentation Additions [Restricted 01/07/1998 areas and spill sites]

Parts 30 and 40 58 FR 39628

1993-2 Licensing and Radiation Safety Requirements for 07/01/1996 Not Applicable Not Applicable TX DSHS Responsibility Irradiators Part 36 58 FR 7715

1993-3 Definition of Land Disposal and Waste Site QA 07/22/1996 Final No Comments Program 01/07/1998 Part 61 58 FR 33886

1994-1 Self-Guarantee as an Additional Financial none Final No Comments Mechanism 01/07/1998 Parts 30, 40, and 70 58 FR 68726; 59 FR 1618

1994-2 Uranium Mill Tailings Regulations: Conforming 07/01/1997 Final No Comments NRC Requirements to EPA Standards 01/07/1998 Part 40 59 FR 28220

1994-3 Timeliness in Decommissioning Material Facilities 08/15/1997 Final No Comments Parts 30, 40, and 70 01/07/1998 59 FR 36026

1995-1 Preparation, Transfer for Commercial Distribution, 01/01/1998 Not Applicable Not Applicable TX DSHS Responsibility and Use of Byproduct Material for Medical Use Parts 30, 32, and 35 59 FR 61767; 59 FR 65243; 60 FR 322

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

1995-2 Frequency of Medical Examinations for Use of 03/13/1998 Final No Comments Respiratory Protection Equipment 01/07/1998 Part 20 60 FR 7900

1995-3 Low-Level Waste Shipment Manifest Information 03/01/1998 Final No Comments and Reporting 01/07/1998 Parts 20 and 61 60 FR 15649; 60 FR 25983

1995-4 Performance Requirements for Radiography 06/30/1998 Not Applicable Not Applicable TX DSHS Responsibility Equipment Part 34 60 FR 28323 (Superceded by 1997-5)

1995-5 Radiation Protection Requirements: Amended 08/14/1998 Final No Comments Definitions and Criteria 01/07/1998 Parts 19 and 20 60 FR 36038

1995-6 Clarification of Decommissioning Funding 11/24/1998 Final No Comments Requirements 01/07/1998 Parts 30, 40, and 70 60 FR 38235

1995-7 Medical Administration of Radiation and Radioactive 10/20/1998 Not Applicable Not Applicable TX DSHS Responsibility Materials Parts 20 and 35 60 FR 48623 (Superceded by 2002-2 and 2005-2)

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

1996-1 Compatibility with the International Atomic Energy 04/01/1999 Not Applicable Not Applicable TX DSHS Responsibility Agency Part 71 60 FR 50248; 61 FR 28724 (Superceded by 2004-1)

These regulation changes are not 1996-2 One Time Extension of Certain Byproduct, Source 02/15/1999 Not Required Not Required required to be adopted for purposes and Special Nuclear Materials Licenses of Compatibility.

Parts 30, 40, and 70 61 FR 1109

1996-3 Termination or Transfer of Licensed Activities: 06/17/1999 Final No Comments Record keeping Requirements 01/07/1998 Parts 20, 30, 40, 61, and 70 61 FR 24669

1997-1 Resolution of Dual Regulation of Airborne Effluents 01/9/2000 Final No Comments of Radioactive Materials; Clean Air Act ML012610092 11/26/01 Part 20 ML013330250 61 FR 65120

1997-2 Recognition of Agreement State Licenses in Areas 02/27/2000 Not Applicable Not Applicable TX DSHS Responsibility Under Exclusive Federal Jurisdiction Within an Agreement State Part 150 62 FR 1662

1997-3 Criteria for the Release of Individuals Administered 05/29/2000 Not Applicable TX DSHS Responsibility Radioactive Material Parts 20 and 35 62 FR 4120

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 (Superceded by 2004-1) 078)

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

1997-5 Licenses for Industrial Radiography and Radiation 06/27/2000 Not Applicable Not Applicable TX DSHS Responsibility Safety Requirements for Industrial Radiography Operations 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 ML063450071 01/09/2007 62 FR 39057 ML070090204

1997-7 Exempt Distribution of a Radioactive Drug 01/02/2001 Not Applicable Not Applicable TX DSHS Responsibility Containing One Microcurie of Carbon-14 Urea Part 30 62 FR 63634

1998-1 Deliberate Misconduct by Unlicensed Persons 02/12/2001 Final No Comments Parts 30, 40, 61, 70, 71, and 150 ML063450071 1/09/07 63 FR 1890; 63 FR 13773 ML070090204

1998-2 Self-Guarantee of Decommissioning Funding by 07/01/2001 Not Required Not Required These regulation changes are not Nonprofit and Non-Bond-Issuing Licensees required to be adopted for purposes Parts 30, 40, and 70 of Compatibility.

63 FR 29535

1998-3 License Term for Medical Use Licenses 07/10/2001 Not Required Not Required These regulation changes are not Part 35 required to be adopted for purposes 63 FR 31604 of Compatibility. (See STP (Superceded by 2002-2) 074)

1998-4 Licenses for Industrial Radiography and Radiation 07/09/2001 Not Applicable Not Applicable TX DSHS Responsibility Safety Requirements for Industrial Radiographic Operations Part 34 63 FR 37059

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

1998-5 Minor Corrections, Clarifying Changes, and a Minor 10/26/2001 Final No Comments Policy Change ML012610092 11/26/2001 Parts 20, 32, 35, 36, and 39 ML013330250 63 FR 39477; 63 FR 45393

1998-6 Transfer for Disposal and Manifests: Minor 11/20/2001 Final No Comments Technical Conforming Amendment ML063450071 01/09/2007 Part 20 ML070090204 63 FR 50127

1999-1 Radiological Criteria for License Termination of 06/11/2002 Revised Final Comments Uranium Recovery Facilities ML13240A300 10/03/2013 Part 40 ML13240A299 64 FR 17506 Revised Final No Comments ML16321A333 01/18/2017 ML16321A324

1999-2 Requirements for Those Who Possess Certain 10/04/2002 Not Required Not Required These regulation changes are not Industrial Devices Containing Byproduct Material to required to be adopted for purposes Provide Requested Information of Compatibility.

Part 31 64 FR 42269

1999-3 Respiratory Protection and Controls to Restrict 02/02/2003 Final No Comments Internal Exposure ML012610092 11/26/2001 Part 20 ML013330250 64 FR 54543; 64 FR 55524

2000-1 Energy Compensation Sources for Well Logging 05/17/2003 Not Applicable Not Applicable TX DSHS Responsibility and Other Regulatory Clarifications Part 39 65 FR 20337

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

2000-2 New Dosimetry Technology 01/08/2004 Not Applicable Not Applicable TX DSHS Responsibility Parts 34, 36, and 39 65 FR 63750

2001-1 Requirements for Certain Generally Licensed 02/16/2004 Not Applicable Not Applicable TX DSHS Responsibility Industrial Devices Containing Byproduct Material Parts 30, 31, and 32 65 FR 79162

2002-1 Revision of the Skin Dose Limit 04/05/2005 Final No Comments Part 20 ML063450071 01/09/2007 67 FR 16298 ML070090204

2002-2 Medical Use of Byproduct Material 10/24/2005 Not Applicable Not Applicable TX DSHS Responsibility Parts 20, 32, and 35 67 FR 20249

2003-1 Financial Assurance for Materials Licensees 12/03/2006 Final No Comments Parts 30, 40, and 70 ML063450071 01/09/2007 68 FR 57327 ML070090204

2004-1 Compatibility with IAEA Transportation Safety 10/01/2007 Not Applicable Not Applicable TX DSHS Responsibility Standards and Other Transportation Safety Amendments Part 71 69 FR 3697

2005-1 Security Requirements for Portable Gauges 07/11/2008 Not Applicable Not Applicable TX DSHS Responsibility Containing Byproduct Material Part 30 70 FR 2001

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

2005-2 Medical Use of Byproduct Material - Recognition of 04/29/2008 Not Applicable Not Applicable TX DSHS Responsibility Specialty Boards Part 35 70 FR 16336; 71 FR 1926

2005-3 Increased Controls for Risk-Significant Radioactive 12/01/2005 Final No Comments Sources (NRC Order EA-05-090) ML14055A034 05/03/2014 70 FR 72128 ML14055A027

License Condition No Comments ML052240226 12/12/2005 ML053420404

2006-1 Minor Amendments 03/27/2009 Final No Comments Parts 20, 30, 32, 35, 40, and 70 ML16071A117 03/30/2016 71 FR 15005 ML16071A113

2006-2 National Source Tracking System - Serialization 02/06/2007 Not Applicable Not Applicable TX DSHS Responsibility Requirements Part 32 with reference to Part 20 Appendix E 71 FR 65685

2006-3 National Source Tracking System 01/31/2009 Final No Comments Note: TCEQ adopted this provision Part 20 ML14055A034 05/13/2014 prior to the LLW site becoming 71 FR 65685, 72 FR 59162 ML14055A027 operational and receiving waste.

2007-1 Medical Use of Byproduct Material - Minor 10/29/2010 Not Applicable Not Applicable TX DSHS Responsibility Corrections and Clarifications Parts 32 and 35 72 FR 45147, 54207

2007-2 Exemptions from Licensing, General Licenses, and 12/17/2010 Not Applicable Not Applicable TX DSHS Responsibility Distribution of Byproduct Material: Licensing and Reporting Requirements Parts 30, 31, 32, and 150 72 FR 58473

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

2007-3 Requirements for Expanded Definition of Byproduct 11/30/2010 Final No Comments Material ML14055A034 05/13/2014 Parts 20, 30, 31, 32, 33, 35, 61, and 150 ML14055A027 72 FR 55864

2007-4 Order Imposing Fingerprinting Requirements and 06/05/2008 License Condition No Comments Criminal History Records Check Requirements for ML082100350 09/11/2008 Unescorted Access to Certain Radioactive Material ML082410019 NRC Order EA-07-305 72 FR 70901

2008-1 Occupational Dose Records, Labeling Containers, 02/15/2011 Final Comments and Total Effective Dose Equivalent ML14055A034 05/13/2014 Parts 19 and 20 ML14055A027 72 FR 68043 Revised Final No Comments ML16321A333 01/18/2017 ML16321A324

2009-1 Medical Use of Byproduct Material - Authorized 09/28/2012 TX DSHS Responsibility User Clarification Part 35 74 FR 33901 Proposed Comment

• 2011-1 Decommissioning Planning 12/17/2015 ML16218A245 09/10/2016 Parts 20, 30, 40, and 70 ML16218A244 76 FR 35512 Final Comment ML16321A333 01/18/2017 ML16321A324

Proposed No Comments The ADAMS package and ML18162A279 6/19/2018 associated documents incorrectly ML18162A244 characterize this submission as revised final regulations instead of proposed regulations.

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

2011-2 Licenses, Certifications, and Approvals for Materials 11/14/2014 Proposed Comments Licensees ML16140A109 6/27/2016 Parts 30, 36, 39, 40, 70, and 150 ML16140A044 76 FR 56951 Proposed No Comments ML16218A245 09/10/2016 ML16218A244

Final No Comments ML16321A333 01/18/2017 ML16321A324

2012-1 Change of Compatibility of 01/25/2015 Not Applicable Not Applicable TX DSHS Responsibility Parts 31.5 and 31.6 (See RATS ID: 2001-1 for Rule text) 77 FR 3640

2012-2 Advance Notification to Native American Tribes of 08/10/2015 Not Applicable Not Applicable TX DSHS Responsibility Transportation of Certain Types of Nuclear Waste Part 71 77 FR 34194 Proposed No Comments 2012-3 Technical Corrections 08/06/2015 ML16218A245 09/10/2016 Parts 30, 34, 40, and 71 ML16218A244 77 FR 39899 Final No Comments ML16321A333 01/18/2017 ML16321A324

2012-4 Requirements for Distribution of Byproduct Material 10/23/2015 Not Applicable Not Applicable TX DSHS Responsibility Parts 30, 31, 32, 40, and 70 77 FR 43666

10 RATS ID NRC Chronology Identification Date Due for Incoming Letter Outgoing Notes State Adoption 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 ML15323A211 01/13/2016 78 FR 16922 ML15323A207

Proposed License No Comments Condition 03/01/2016 ML16049A214 ML16049A154

Final No Comments ML16321A333 01/18/2017 ML16321A324

2013-2 Distribution of Source Material to Exempt Persons 08/27/2016 Final No Comments and to General Licensees and Revision of General ML16321A333 01/18/2017 License and Exemptions ML16321A324 Parts 30, 40 and 70 78 FR 32310

2015-1 Domestic Licensing of Special Nuclear Material - 01/26/2018 Final No Comments Written Reports and Clarifying Amendments ML16140A109 6/27/2016 Part 70 ML16140A044 79 FR 57721, 80 FR 143

2015-2 Safeguards Information - Modified Handling 01/28/2018 Final Comments Categorization, Change for Materials Facilities ML15323A211 01/13/2016 Parts 30, 37, 73, and 150 ML15323A207 79 FR 58664, 80 FR 3865 Revised Final No Comments ML16321A333 01/18/2017 ML16321A324

2015-3 Revisions to Transportation Safety Requirements 07/13/2018 Not Applicable Not Applicable TX DSHS Responsibility and Harmonization with International Atomic Energy *extended to Agency Transportation Requirements 08/15/2020 Part 71 See STC 17-060 80 FR 33987

11 RATS ID NRC Chronology Identification Date Due for Incoming Letter Outgoing Notes State Adoption Package Proposed No Comments 2015-4 Miscellaneous Corrections 09/02/2018 ML16218A245 09/10/2016 Parts 37 and 40 ML16218A244 80 FR 45841 Final No Comments ML16321A333 01/18/2017 ML16321A324 Proposed No Comments 2015-5 Miscellaneous Corrections 12/31/2018 ML16218A245 09/10/2016 Parts 19, 20, 30, 32, 37, 40, 61, 70, 71, and 150 ML16218A244 80 FR 74974 Final No Comments ML16321A333 01/18/2017 ML16321A324

2018-1 Medical Use of Byproduct Material - Medical Event 01/14/2022 Definitions, Training and Experience, and Clarifying Amendments, 10 CFR Parts 30, 32 and 35

2018-2 Miscellaneous Corrections - 12/21/2021 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 12/30/2022 ML20344A368 12/11/2020 TX DSHS RESPONSIBILITY Amendments ML20344A036 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 ML20344A368 12/11/2020 TX DSHS RESPONSIBILITY 10 CFR Parts 34, 36, and 39 ML20344A036

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

2020-2 Social Security Number Fraud Prevention 08/17/2023 ML20344A368 12/11/2020 TX DSHS RESPONSIBILITY 10 CFR Parts 9 and 35 ML20344A036

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 Compact Waste Disposal Facility and Commingling N/A Final No Comments of Waste ML121230326 06/29/2012 Part 61 ML12152A150

N/A Part 40 N/A R Comments ML13240A300 10/03/2013 ML13240A299

Revised Final No Comments ML16321A333 DATE ML16321A324

N/A Exemption for Radioactive Substances from N/A Final No Comments Disposal Requirements ML13176A107 08/15/2013 ML13176A104

N/A Legislation on Production Area Authorizations and N/A Final No Comments Compact Waste ML13178A064 08/23/2013 ML13178A059

13

Appendix B-4 Question 3

Name Position Area of Effort FTE%

Raven Alexander WIPP Contract Materials Compliance 20 Trainer Emergency Response 65 Administration 15 Chris Amaro Emergency Planner Emergency Response 95 Administration 5

Karen Blanchard Incident Materials Compliance 90 Investigator Emergency Response 7 Administration 3 Stefanie Blum License Reviewer Materials Licensing 95 Industrial Emergency Response 5

Lisa Bruedigan Director, Radiation Materials Compliance 20 Section Emergency Response 10 Administration 70 Jason Callahan Radioactive Materials Compliance 92 Materials Inspector Emergency Response 3 Administration 5 Ruben Cortez Radiation Safety Emergency Response 10 Officer Environmental Monitoring 60 Instrument Calibration 30 Shay Christian Emergency Planner Emergency Response 50 X-Ray Program 50

Vanessa Danese License Reviewer Materials Licensing 90 Medical and Emergency Response 10 Academic, Industrial Harry Drake Environmental Materials Compliance 35 Specialist Emergency Response 15 Administration 50 William Duncan Quality Assurance Materials Compliance 95 Reviewer Emergency Response 5

James Durham Radioactive Materials Compliance 92 Materials Inspector Emergency Response 3 Administration 5 Robert Fisher Emergency Planner Emergency Response 95 Administration 5

Edward Flores Radioactive Materials Compliance 92 Materials Inspector Emergency Response 3 Administration 5 Robert Free Manager Materials Compliance 40 Environmental Emergency Response 30 Monitoring Group Administration 30 Name Position Area of Effort FTE%

Shawn Garza Industrial Licensing Materials Licensing 85 Program SS&D 5 Coordinator Emergency Response 10 Tim Gibson Emergency Planner Emergency Response 50 Mammography Program 50

Tony Haynes Radioactive Materials Compliance 92 Materials Inspector Emergency Response 3 Administration 5 Justin Highland License Reviewer Materials Licensing 95 Medical and Emergency Response 5 Academic Albert Hille Program Specialist Materials Licensing 15 Emergency Response 5 Administration 80 Sonia Hille Advanced Materials Licensing 95 Technology Emergency Response 5 Licensing Program Coordinator Gabrielle Howard Radioactive Materials Compliance 92 Materials Inspector Emergency Response 3 Administration 5 Scott Kee Medical and Materials Licensing 95 Academic Emergency Response 5 Licensing Program Coordinator Matt Kennington Incident Materials Compliance 90 Investigator Emergency Response 7 Administration 3 Joyce LeRoux Industrial IR Certification 95 Radiography Emergency Response 5 Certification Specialist Eric McManus Radioactive Materials Compliance 92 Materials Inspector Emergency Response 3 Administration 5 Chris Moore Incident Materials Compliance 50 Investigator/ Emergency Response 40 Emergency Planner Administration 10 Chris Myers Lead Quality Materials Compliance 95 Assurance Emergency Response 5 Reviewer Robin Phillips Radioactive Materials Compliance 92 Materials Inspector Emergency Response 3 Administration 5

Name Position Area of Effort FTE%

Randall Redd Incident Materials Compliance 90 Investigator Emergency Response 7 Administration 3 Tiffany Rushing Radioactive Materials Compliance 92 Materials Inspector Emergency Response 3 Administration 5 Renu Selli License Reviewer Materials Licensing 95 Medical and Emergency Response 5 Academic Earlon Shirley Radioactive Materials Compliance 92 Materials Inspector Emergency Response 3 Administration 5 Eric Skotak Manager Materials Compliance 60 Radioactive Emergency Response 5 Materials Administration 35 Inspections Keith Smith License Reviewer Materials Licensing 90 Industrial & Emergency Response 5 Reciprocity SS&D 5 Bridget Stephens Industrial IR Certification 95 Radiography Emergency Response 5 Certification Program Coordinator Darwin (DD) Stiles Radioactive Materials Compliance 92 Materials Inspector Emergency Response 3 Administration 5 Craig Sutton Radioactive Materials Compliance 92 Materials Inspector Emergency Response 3 Administration 5 Art Tucker Incident Materials Compliance 90 Investigator Emergency Response 7 Administration 3 Vacant RAM Rules Rules Development 95 Coordinator Emergency Response 5

Vacant License Reviewer Materials Licensing 95 Emergency Response 5

Vacant Quality Assurance Materials Compliance 95 Reviewer Emergency Response 5

Vacant Environmental NRC Training 20 Protection Coordination Specialist Administration 80

Name Position Area of Effort FTE%

Vacant Radioactive Materials Compliance 92 Materials Inspector Emergency Response 3 (Houston) Administration 5 Vacant Emergency Planner Emergency Response 95 Administration 5

Vacant WIPP Contract Materials Compliance 20 Coordinator Emergency Response 65 Administration 15 Brian Vamvakias Manager Materials Compliance 80 PSQA Radiation Rule Coordination 15 Emergency Response 5

Karl Von Ahn Manager Materials Licensing 90 Radioactive SS&D 5 Materials Licensing Emergency Response 5 Forrest Weston Radioactive Materials Compliance 92 Materials Inspector Emergency Response 3 Administration 5 Cathy Wolfe Environmental Materials Compliance 35 Specialist Emergency Response 15 Administration 50

Appendix B-5 Question 4

Name Group Degree Experience Start Date MS Public Health Craig Sutton Inspections BS Physics 6 years 2/1/2019

Tiffany Rushing Inspections BS Environmental 5 years 2/10/2020 Health

Earlon Shirley Inspections BS Engineering/Physics 22 years 9/28/2020

Eric McManus Inspections BS Chemistry 13 years 5/10/2021

Edward Flores Inspections BS Radiological Health None 11/15/2021 Engineering Brian MS Radiation Ecology Vamvakias PSQA BS Biomedical Science 30 years 2/19/2019

Stefanie Blum Licensing MS Physics 7 years 4/1/2021

MS Environmental Renu Selli Licensing Biology/Nutrition 9 years 2/1/2019 BS Biology

Justin Highland Licensing BS Physics/Engineering 2 years 7/1/2020

Sonia Hille Licensing BA Business 10 years 8/24/2021

Matthew Environmental BS Nuclear Engineering 3 years 10/15/2018 Kennington Monitoring

Randall Redd Environmental MS Health Physics 3 years 4/15/2019 Monitoring

Robert Fisher Environmental MS Physics 5 Years 2/1/2020 Monitoring

Raven Environmental MS Health Physics 1 year 7/26/2021 Alexander Monitoring

Appendix B-6 Question 5

Name Title Training Needed Expected Completion Date

Tiffany Inspector Completed All Training. Awaiting final Early 2022 Rushing approval and accompaniment by manager for full qualification H-305 Industrial Radiography Eric McManus Inspector H-308S Transportation of RAM Late 2022 H-314 Well Logging

G-108 Inspection Procedures Edward Flores Inspector H-304 Nuclear Medicine 2023 H-313 Brachytherapy & Gamma Knife G-205 Root Cause H-305 Industrial Radiography H-308S Transportation of RAM H-314 Well Logging S-201 Materials Control and Security Systems & Principles Course S-201 Materials Control and Security 2022 Stefanie Blum License Systems & Principles Course Reviewer H-308S Transportation of RAM Currently Enrolled Industrial H-314 Well Logging 2022 H122 Lab - Fundamental Health 2022 Physics Labs Course OJT license types As available S-201 Materials Control and Security 2022 Renu Selli License Systems & Principles Course Reviewer H122 Lab - Fundamental Health 2022 Medical and Physics Labs Course Academic OJT license types As Available S-201 Materials Control and Security 2022 Justin License Systems & Principles Course Highland Reviewer H-308S Transportation of RAM Currently Enrolled Medical and H122 Lab - Fundamental Health 2022 Academic Physics Labs Course H122S Fundamental Health Physics Currently Enrolled Self-Study

Matthew Incident H-308S Transportation of RAM 2022 Kennington Investigator

Randall Redd Incident G-108 Inspection Procedures 2022 Investigator H-308S Transportation of RAM 2022

Appendix B-7 Question 7

Name Position Date Departed Steven Fernandez Radioactive Materials Inspector 7/20/2018 Chuck Flynn Manager 10/31/2018 Radiation PSQA Group Paul Sanford License Reviewer Medical and 12/31/2018 Academic Roger Sawyer Advanced Technology Licensing 3/31/2021 Program Coordinator Stephen Guetersloh License Reviewer Medical and 4/25/2019 Academic Marina Pulley Radioactive Materials Inspector 10/11/2019

Farrar Stewart Radioactive Materials Inspector 10/24/2019 Helen Watkins License Reviewer Medical and 4/30/2020 Academic Timothy Sanchez Radioactive Materials Inspector 7/24/2020

Rick Croy Radioactive Materials Inspector 2/28/2021

Israel Chavarria Radioactive Materials Inspector 5/11/2021

Michael Green Radioactive Materials Inspector 5/19/2021

Greg Gurnee Radioactive Materials Inspector 8/31/2021

Richard Lamboi Quality Assurance Specialist 2/28/2021

Elizabeth Speights Environmental Protection Specialist 9/30/2021

Peggy Westlund RAM Rules Coordinator 4/30/2021 Syed Naeem License Reviewer Medical and 1/11/2021 Academic Amber Bolen Emergency Planner/ Grant Coordinator 11/30/2018

Irene Casares Incident Investigator 1/31/2019

Glenn Corbin Emergency Planner 12/31/2021

Gentry Hearn Incident Investigator 6/30/2018

Name Position Date Departed Mike Rutherford WIPP Contract Coordinator 10/31/2021

Rae Walker Emergency Planner 4/22/2019

Jose Trevino Emergency Planner 8/30/2020

Lauren McGuire Environmental Protection Specialist 4/1/2019

Brad Britten Emergency Planner 10/1/2020

Appendix B-8 Question 8

Position Date Vacated Attempts to Fill

License Reviewer 9/1/2021 Position is currently posted.

Expected Hire date 3/1/2022

Radioactive Materials 5/21/2021 Position posted twice with 4 offers Inspector (Houston) declined. Position posted a 3rd time

Quality Assurance 2/28/2021 Position posted in April 2021 with no Reviewer applicants meeting initial qualifications.

Position description is being revised and will repost

RAM Rules Coordinator 4/30/2021 Position was posted in January and applications are being reviewed now

Environmental 9/30/2021 Position to be audited for potential Protection Specialist move to the Mammography program

Emergency Planner 12/31/2021 Position has not yet been posted.

Position should be posted in first quarter of 2022.

WIPP Contract 10/31/2021 Position has posted and closed.

Coordinator Expected Hire to be made February 2022.

Appendix B-9 Question 9

Texas Radiation Advisory Board 1100 West 49th Street Austin, Texas 78756-3189

Charles Cavnor Ken Peters Labor Nuclear Utility 2025 2025

Lynn Silguero Lisa Masters, D.D.S.

Public Dentist 2025 2027

Michael Britt Darlene Metter, M.D.

Insurance Nuclear Medicine 2027 2025

Darshan J. Sachde, Ph.D. Doug Posey, D.V.M.

Public Agriculture 2025 2023

Sanjay Narayan Bob Redweik Public Petroleum Well Service Industry 2027 2025

John P. Hageman, C.H.P. Simon Trubek, M.D.

Health Physics Radiology 2023 2027

Gerald (Tim) Powell Kevin L. Raabe Radioactive Waste Uranium 2027 2023

Ronald Benke, Ph.D. Mark A. Silberman, M.D.

Industry Pathology 2027 2023

Mark C. Harvey, Ph.D. William Pate, Dr.PH.

Nuclear Physics in Medicine Hospital Administration 2027 2023

Appendix B-10 Question 10 DSHS

& NRC NRC DSHS NRC Initial NRC Routine Routine IMPEP License Type Authorization Interval Priority Interval Interval Interval 3101 - General License Acknowledgement G - 031 GLA In-Vitro Testing 365 5 1825 1825 2190 3101 - General License Acknowledgement G - 061 GLA Gauge 365 5 1825 1825 2190 3102 - Radioactive Materials L - 001 Accelerator 365 2 730 730 1095 3102 - Radioactive Materials L - 003 Broad License 335 2 730 730 1095 3102 - Radioactive Materials L - 004 Civil Defense 365 5 1825 1825 2190 3102 - Radioactive Materials L - 006 Demonstration/Sales 365 5 1825 1825 2190 L - 013 Neutron Generator Target-3102 - Radioactive Materials Sealed 365 5 1825 1825 2190 L - 015 Manufacturing &

3102 - Radioactive Materials Commercial Distributor 365 2 730 730 1095 3102 - Radioactive Materials L - 017 Eye Applicator 365 3 1095 1095 1460 3102 - Radioactive Materials L - 019 X-Ray Fluorescence 365 5 1825 1825 2190 3102 - Radioactive Materials L - 021 Gas Chromatograph 365 5 1825 1825 2190 3102 - Radioactive Materials L - 022 Gauge-Fixed 365 5 1825 1825 2190 L - 024 Gauge-Spinning Pipe-3102 - Radioactive Materials Thickness/Portable 365 5 1825 1095 2190 L - 027 Industrial Radiography 3102 - Radioactive Materials (Fixed Facility) 365 2 730 730 1095 L - 028 Industrial Radiography 3102 - Radioactive Materials (Temporary Field 365 1 365 365 547 L - 029 Calibration of Survey and 3102 - Radioactive Materials Measurement Ins 365 5 1825 1825 2190 3102 - Radioactive Materials L - 030 Irradiator-Self Contained 365 5 1825 1095 2190 3102 - Radioactive Materials L - 033 Leak Test Service 365 5 1825 1825 2190 3102 - Radioactive Materials L - 035 Mobile Scanning Service 365 2 730 730 1095 L - 036 Written Directive Not 3102 - Radioactive Materials Required 365 5 1825 1095 2190 3102 - Radioactive Materials L - 037 Nuclear Pharmacy 365 2 730 730 1095 L - 040 Processor of Loose 3102 - Radioactive Materials Radioactive Material 365 1 365 365 547 L - 042 Research And/or 3102 - Radioactive Materials Development 365 3 1095 1095 1460 3102 - Radioactive Materials L - 043 Source Material 365 5 1825 1825 2190 3102 - Radioactive Materials L - 045 Special Nuclear Material 365 3 1095 1095 1460 3102 - Radioactive Materials L - 046 Teletherapy 365 5 1825 1825 2190 L - 048 Teachingl Trainingl &

3102 - Radioactive Materials Education (Not Use 365 5 1825 1825 2190 L - 049 Written Directive-Sealed 3102 - Radioactive Materials Source 365 3 1095 1095 1460 L - 050 Tracer Studies (Non-Oil 3102 - Radioactive Materials Well) 365 3 1095 1095 1460 3102 - Radioactive Materials L - 051 Tracer Studies (Oil Well) 365 3 1095 1095 1460 DSHS

& NRC NRC DSHS NRC Initial NRC Routine Routine IMPEP License Type Authorization Interval Priority Interval Interval Interval 3102 - Radioactive Materials L - 053 Well Logging 365 3 1095 1095 1460 L - 054 Handheld Light Intensifying 3102 - Radioactive Materials Imaging Dev 365 5 1825 1825 2190 L - 057 Limited Manufacturing 3102 - Radioactive Materials (Loose Material) 365 5 1825 1825 2190 L - 058 Calibration and Reference 3102 - Radioactive Materials Source 365 5 1825 1825 2190 3102 - Radioactive Materials L - 061 GLA Gauge 365 5 1825 1825 2190 3102 - Radioactive Materials L - 062 Fine Leak Testing Device 365 5 1825 1825 2190 3102 - Radioactive Materials L - 065 Storage Only 365 3 1095 1095 1460 L - 070 Agency-Accepted Training 3102 - Radioactive Materials Course 365 5 1825 1825 2190 L - 071 In-Vitro Test Kit-3102 - Radioactive Materials Manufacturer 365 5 1825 1825 2190 L - 072 Installerl Repairl Or 3102 - Radioactive Materials Maintenance 365 2 730 730 1095 3102 - Radioactive Materials L - 073 Pipe Joint Collar Marker 365 3 1095 1095 1460 L - 074 Radiopharmaceutical 3102 - Radioactive Materials Manufacturing 365 2 730 730 1095 3102 - Radioactive Materials L - 075 Irradiator (Unshielded) 365 2 730 730 1095 L - 076 Written Directive-Unsealed 3102 - Radioactive Materials Source 365 3 1095 1095 1460 L - 080 Mineral Recovery 3102 - Radioactive Materials (Byproduct Material) 365 5 1825 1825 2190 L - 081 256(q) Therapeutic 3102 - Radioactive Materials Emerging Tech 365 2 730 730 1095 L - 082 Mobile Medical Services 3102 - Radioactive Materials WD Not Required 365 3 1095 1095 1460 3102 - Radioactive Materials L - 085 Bone Mineral Analyzer 365 3 1095 1095 1460 L - 086 Mobile Medical Services 3102 - Radioactive Materials WD-Sealed Source 365 2 730 730 1095 L - 087 Mobile Medical Services 3102 - Radioactive Materials WD-Unsealed Src 365 2 730 730 1095 L - 092 Commercial Distribution 3102 - Radioactive Materials Only 365 5 1825 1825 2190 3102 - Radioactive Materials L - 093 Environmental Laboratory 365 5 1825 1825 2190 L - 094 Decontamination Service-3102 - Radioactive Materials Mobile 365 3 1095 1095 1460 3102 - Radioactive Materials L - 098 Other Specific License 365 5 1825 1095 2190 L - 099 Decontamination Service-3102 - Radioactive Materials Fixed Site 365 3 1095 1095 1460 L - 100 Fixed Multi-Beam-3102 - Radioactive Materials Teletherapy 365 2 730 730 1095 L - 101 Remote Controlled 3102 - Radioactive Materials Brachytherapy Device 365 2 730 730 1095 3102 - Radioactive Materials L - 105 Depleted Uranium 365 5 1825 1825 2190 L - 283 In-Vitro Use of Radioactive 3102 - Radioactive Materials Material 365 5 1825 1825 2190 L - 857 NORM-Commercial 3102 - Radioactive Materials Processing 365 3 1095 1095 1460

Appendix B-11 Question 12

Date Previous Routine Inspection License-NRC Inspection Due Inspection Days Findings site Licensee Name Priority Date Date Date Overdue Issued L01575-000 BERRY GP INC 1 06/07/2018 12/6/2019 12/17/2019 10 1/15/2020 NUCLEAR SOURCES L02991-000 AND SERVICES INC 1 06/13/2019 12/11/2020 02/10/2021 60 3/10/2021 TURNER SPECIALTY L05417-000 SERVICES LLC 1 12/03/2018 6/2/2020 06/30/2020 27 7/21/2020 L05956-000 QC LABORATORIES INC 1 11/28/2018 5/28/2020 07/01/2020 33 7/27/2020 TANK AND VESSEL L06168-000 BUILDERS LP 1 11/26/2018 5/26/2020 06/25/2020 29 7/7/2020 CRITICAL RESPONSE INSPECTION SERVICE L06497-000 LLC 1 12/18/2018 6/17/2020 06/23/2020 5 6/30/2020 ARC INSPECTION L06864-000 SERVICES LLC 1 10/23/2018 4/22/2020 07/09/2020 77 7/30/2020 SCHLUMBERGER TECHNOLOGY L06880-000 CORPORATION 1 01/08/2019 7/8/2020 07/23/2020 14 8/4/2020 L06896-000 SQS NDT LP 1 01/15/2019 7/15/2020 07/30/2020 14 8/13/2020 SOUND NDT SOLUTIONS L06925-000 LLC 1 06/22/2018 12/21/2019 01/09/2020 19 1/27/2020 L00154-000 TEXAS ONCOLOGY PA 2 05/23/2017 5/22/2020 07/01/2020 40 7/27/2020 L01186-000 THERMO FINNIGAN LLC 2 02/16/2017 2/16/2020 02/25/2020 9 3/6/2020 UNIVERSITY OF HOUSTON ENVIRONMENTAL HEALTH AND LIFE L01886-003 SAFETY DEPT 2 06/22/2017 6/21/2020 08/05/2020 45 8/13/2020 TEXAS CHILDRENS L04612-000 HOSPITAL 2 07/21/2017 7/20/2020 07/30/2020 10 8/25/2020 BAY AREA HEALTHCARE L04723-000 GROUP LTD 2 05/05/2016 5/5/2019 12/19/2019 228 1/22/2020 METHODIST HEALTH L05788-000 CENTERS 2 06/08/2016 6/8/2019 08/19/2019 72 8/21/2019 L06465-000 TEXAS ONCOLOGY PA 2 12/07/2016 12/7/2019 08/04/2020 241 8/6/2020 METHODIST HOSPITALS L06475-002 OF DALLAS 2 07/11/2018 7/10/2021 10/26/2021 107 11/16/2021 CHI ST LUKES HEALTH BAYLOR COLLEGE OF MEDICINE MEDICAL L06661-000 CENTER 2 11/20/2017 11/19/2020 04/22/2021 154 5/17/2021 BAKER HUGHES OILFIELD OPERATIONS L00446-060 LLC 3 07/15/2016 7/14/2020 07/29/2020 15 8/19/2020 GREAT GUNS L01990-002 INCORPORATED 3 02/15/2017 2/14/2021 05/06/2021 81 5/10/2021

Appendix B-12 Question 12

Date Site Initial Inspection NRC Licensed Inspection Inspection Days Findings License-site Licensee Name Priority Date Due Date Date Overdue Issued ALS MAVERICK TESTING L06608-004 LABORATORIES INC 1 7/16/2019 7/16/2020 9/30/2020 77 10/12/2020 L06966-000 MED FUSION LLC 5 11/28/2018 11/28/2019 12/4/2019 6 12/20/2019 WOODLANDS ELITE L07022-000 CARDIOLOGY PLLC 5 09/05/2019 9/5/2020 9/23/2020 19 10/8/2020 THE DOW CHEMICAL L07026-000 COMPANY 5 10/07/2019 10/7/2020 11/6/2020 31 11/25/2020

Appendix B-14 Question 17

Name Instrument Calibration Date Jason Callahan Ludlum 2241 3/12/2021 Ludlum Model 2363 9/12/2021 Thermo RadEye SPRD-GN 8/16/2021 James Durham Ludlum 2241 3/12/2021 Ludlum Model 2363 9/12/2021 Thermo RadEye SPRD-GN 9/24/2021 Eddie Flores Ludlum 2241 8/31/2021 Ludlum Model 2363 10/5/2021 Thermo RadEye SPRD-GN 9/27/2021 Eric McManus Ludlum 2241 5/11/2021 Ludlum Model 2363 In Training/Not required Thermo RadEye SPRD-GN 8/17/2021 Tony Haynes Ludlum 2241 3/12/2021 Ludlum Model 2363 10/11/2021 Thermo RadEye SPRD-GN 9/24/2021 Gabrielle Howard Ludlum 2241 8/31/2021 Ludlum Model 2363 10/11/2021 Thermo RadEye SPRD-GN 8/16/2021 Robin Phillips Ludlum 2241 3/12/2021 Ludlum Model 2363 9/29/2021 Thermo RadEye SPRD-GN 9/24/2021 Craig Sutton Ludlum 2241 4/07/2021 Ludlum Model 2363 9/12/2021 Thermo RadEye SPRD-GN 8/17/2021 Tiffany Rushing Ludlum 2241 1/29/2021 Ludlum Model 2363 9/12/2021 Thermo RadEye SPRD-GN 8/16/2021 Earlon Shirley Ludlum 2241 3/12/2021 Ludlum Model 2363 10/05/2021 Thermo RadEye SPRD-GN 8/17/2021 Eric Skotak Ludlum 2241 3/12/2021 Ludlum Model 2363 Checks out as needed Thermo RadEye SPRD-GN 9/24/2021 Darwin (DD) Stiles Ludlum 2241 3/12/2021 Ludlum Model 2363 10/15/2021 Thermo RadEye SPRD-GN 9/24/2021 Forrest Weston Ludlum 2241 4/7/2021 Ludlum Model 2363 9/12/2021 Thermo RadEye SPRD-GN 9/24/2021

Appendix B-15 Question 17

RADIATION SURVEY INSTRUMENT CALIBRATION AND MAINTENANCE PROCEDURES TEXAS DEPARTMENT OF STATE HEALTH SERVICES

BACKGROUND Calibration of portable radiation survey instruments is a process which may be conducted with varying degrees of accuracy and precision. Both are a function of the facilities and equipment, time, personnel and financial resources available to perform the calibration. The object of calibrating an instrument intended for routine use is to ensure that its accuracy is adequate under the conditions in which it is used (ICRU 1976). The following set of procedures has been written in order to document the conditions under which portable survey instruments are currently being calibrated at the Texas Department of State Health Services, and to establish the procedures for users of portable survey instruments which assure that a minimum set of precautions are observed in the field to verify that the instruments function properly and that the calibration is valid.

Proper care of radiation detection and measuring equipment, as with all equipment, is the primary mechanism for insuring its proper functioning. Each individual to whom an instrument is assigned also has assigned the responsibility to perform frequent checks on the equipment to assure its proper functioning and to report immediately any problem which, based on their experience and familiarity with their survey instrumentation indicates a particular instrument is not functioning reliably. Further discussion of these responsibilities will be presented later in the text.

In order to facilitate communications regarding any problems encountered with portable radiation detection and measuring equipment, when practicable, a copy of the manufacturers manual for each instrument and detector commonly used will be included as part of this manual. Additionally, familiarity with the operational characteristics of each instrument an inspector uses should enhance his abilities to perform surveys. Whenever possible, the manufacturers calibration procedures will be followed. Significant deviations from manufacturers suggested procedures will be verified with the manufacturer, prior to implementation or have a rationale developed and in both cases documented in the manual.

CONSTANCY CHECKS AND MAINTENANCE

As soon after calibration as possible each inspector should check his/her instrument against a small check source, such as those provided in the check source kits. One should use the same source each time the instrument is checked and one should also be sure to position the source at the same location on or near the detector.

This check should be made on all detectors, not just those that are calibrated as a means of assuring oneself that the operating characteristics of the detectors and the rate meter have not changed. The GM detectors should be checked daily, since they are used routinely to determine compliance. Other detectors may be checked less frequently. Each region should have an appropriate source of radiation for each of the common types of radiation except, of course, neutrons. Neutron detectors will be Operationally checked at Central Office before being sent to Inspectors, if inspector feels that detector may have issue it can be sent to Central Office to check and evaluate.

Sodium iodide detectors should be checked regularly for changes in response in established radiation fields. Crystals which have been fractured or which have begun to swell and discolor (they will 1

Appendix B-15 Question 17

become yellow as iodine is released) will demonstrate significantly lower count rates than normal.

Although less frequent a problem photomultiplier tubes may also go bad. Generally, a bad photomultiplier tube will be manifested by a sudden rise in count rate with no apparent cause. A damaged photomultiplier tube, however, might demonstrate a decreased count rate if one of the dynodes were displaced.

As well as checking the detectors frequently, each inspector should also check batteries and battery contacts frequently. Also, if the instrument is to be stored for more than thirty days the batteries should be removed1. In humid climates the indicator/desiccant should be checked every month at a minimum and dried as described in Preparation for Calibration when necessary. Cleaning battery contacts every three months will also prevent unexpected losses of power and provide an opportunity to check the condition of the batteries periodically2.

One should be mindful that the calibration of an instrument takes place under a fairly stringently defined set of conditions. Although one would like for these conditions to match those encountered in the field, they rarely do. When making measurements to determine compliance one should to the degree possible use the detector or instrument in the same orientation to the source of radiation as it had during calibration. One should be aware of significant differences in the energy or distribution of energies of the radiations which he is measuring compared to those used during calibration. Note should be made of whether radiation is being measured under broad or narrow beam conditions and whether or not other types of radiation may be present which might interfere with the measurement.

PREPARATION FOR CALIBRATION

Prior to bringing a survey instrument in for calibration each inspector should determine that the batteries are good or, if necessary, replace them. Additionally, in the case of ionization chamber instruments each inspector shall make sure that the indicator/desiccant is dry. If not, it may be dried by pouring it into a dish and heating it in a microwave oven until it turns dark blue or by placing it in a conventional oven and heating it for twelve hours at 250°F or one hour at 400°F3. Always allow sufficient time for the indicator/desiccant to cool before replacing it in its holder.

CALIBRATION PROCEDURES

CALIBRATION FACILITIES

At present all portable survey instruments, except the Raysafe X2s, Ludlum Models 77-3, 9DP, and 2363 are calibrated at the Radiation Controls calibration range. The calibration range is located at the Health and Human Services Warehouse on Technology Blvd in Austin. The range is in a 40ft by 40ft room off the main warehouse floor and currently implements the use of two J.L. Shepherd model 28-6A collimated beam calibrators.

One calibrator originally contained a Cesium-137 source of 120 mCi (4.44 GBq). Source output was verified by the manufacturer to be 40.9 mR hr-1 (1.055E-5 C kg-1hr-1) on August 31, 1989 utilizing the 45° collimator. This reading was taken using an MDH Industries model 2025 X-ray Monitor, calibrated by National Institute of Standards and Technology (NIST), report no. DG8640/87. This is in close agreement (3.2%) with a calculated exposure rate of 39.6 mR hr-1 (1.022E-5 C kg-1hr-1) from a 120 mCi source.

2

Appendix B-15 Question 17

Subsequent measurements made by the DSHSs personnel on October 3, 1991, using Victoreen R chambers (traceable to NIST test no DG8953/89), produced an average, measured exposure rate 37.9 mR hr-1 (9.78E-6 C kg-1hr-1) with the 45° collimator. The calculated field based on the activity of source as of 10/8/91 would be 37.72 mR hr-1 (9.73E-6 C kg-1hr-1). The difference between the calculated and measured numbers is 0.5%. The expose rate is checked at least bi annually using Fluke electrometer calibrated to NISR standards.

The other calibrator originally contained a Cesium-137 source of 1.2 Ci (44.4 GBq). Source output was verified by the manufacturer to be 312 mR hr-1 (8.05 C kg-1hr-1) on December 6, 1998, utilizing the 30° collimator. This reading was taken using an MDH Industries model 2025 X-ray Monitor, calibrated by NIST, report no. DB917/114. This is in agreement with a calculated exposure rate of 396 mR hr-1 (1.022E-4 C kg-1hr-1) from a 1.2 Ci source. Since the source is 10 times stronger than the previous source the beam edges for the 10 and 30 degree collimators are marked on the floor.

In 2021 the CDV-784 calibrator that originally contained a Cesium-137 source of 130 Ci. Source output was verified by Civil Defense program to be 130 Ci on October 25, 1983 was transferred to Bionomics for disposal.

CALIBRATION PERSONNEL

The individual who will supervise the instrument calibration will have experience in general health physics, the handling of sealed sources, operation of calibrators, operation of test equipment and the use and maintenance of the survey meters to be calibrated.

CONDITIONS OF CALIBRATION

Calibrations may be carried out in several ways:

(1) By national standards laboratories using calibration standards of the highest possible accuracy.

(2) By major government, academic, research or industrial laboratories using institutional standards established by careful comparison with a national standard.

(3) By other groups using working standards (reference instruments) of lesser accuracy that are periodically calibrated by comparison with one of the above-mentioned national or institutional standards (ICRU 1976).

The calibration method described in this procedure falls into the third category.

All calibrations will be conducted within the temperature range 25+/-10°C (ANSI 1978). Additionally, no correction will be made for temperature or air pressure when calibrating ionization chamber instruments which operate at atmospheric pressure. The temperature and air pressure at the time of calibration will be noted on each calibration record and can be used by the inspectors in order to determine actual exposure rates when making measurements in the field (see attached air density correction table). Each inspector may apply this correction factor to normalize the reading to the standard conditions of calibration, then apply the correction factor appropriate for the temperature and air pressure to the corrected reading obtained at the time and date of his survey in order to obtain a more accurate measurement. Or the inspector may choose to apply the actual reading without making adjustments for variations over a reasonable range in temperature and air pressure.

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Appendix B-15 Question 17

Although free space geometry should be achieved for photon... instrument calibration (ANSI 1978), some contribution from scatter will occur due to the physical constraints imposed by available facilities and equipment. Tests have been conducted at DSHS in order to ascertain the effects of scatter from collimation, surrounding surfaces and supporting materials. No discernible effects were noted4.

The current activity of the source is calculated as a minimum semiannually. Using the inverse square relationship distances are then calculated in order to obtain a one quarter and three quarter scale reading on each scale of each instrument. Some scales may not be calibrated or may only have a single calibration point. The calibration reports will be annotated accordingly5. Remote GM detectors will be calibrated with the long axis of the detector perpendicular to the central axis of the beam.

If the detector has a window, the window will be closed during calibration. Other GM detectors such as end window or pancake types will not routinely be calibrated for photon radiation fields.

Instruments with internal detectors or chambers will be calibrated with the instrument facing the source of radiation, and the chambers or detectors center at the distance from the source designated as the calibration point and with the center of the detector or chamber within a few centimeters of the central axis of the beam in the vertical and horizontal planes. In all cases calibrations will be performed in such a manner that the sensitive volume of the detector or chamber is fully encompassed by the beam6.

A calibration shall consist of a comparison of the instruments response to a known radiation field at two points on each scale. If an adjustment to the instrument is needed, it will only be made at one of these points. Should the instrument not respond to within +/-10% of the second reading on that scale when checked in the appropriate radiation field, it will be replaced and scheduled for maintenance and/or repair. It should be noted that the error in the reading only relates to the error allowed between the calculated radiation field and the response of the instrument. It does not include the error in the calculation, the error in measurement of the distance, the error in any instrument used to measure the exposure rate or the error in the primary standard. If care is taken, however, the sum of these unexpressed errors should not exceed 10% (IAEA 1971).

The high voltage will not be checked; modern power supplies should generally be capable of providing stable high voltages to within a few per cent or better (IAEA 1971). Nor will an electronic calibration (a check of the linearity of the scale of the rate meter) be performed as part of routine calibration procedures. If an instrument cannot be calibrated within specification in the appropriate radiation fields, then in will be replaced and sent for maintenance and/or repair.

1 Ludlum Measurements, Instruction Manual Model 12s Miro R Meter, Section 6-Maintenance, 1999 2 Eberline, RO-20 Ion chamber Technical Manual, Section 4-Maintenance, 1995 3 Eberline, RO-20 Ion chamber Technical Manual, Section 4-Maintenance, 1995 4 Meyer, R. 2nd Correction to Memo re: Estimate of Error for Calibration Procedures, Internal Memo from Russ Meyer to Richard Ratliff, Texas Department of Health, Bureau of Radiation Control, dated November 20, 1991 5 Texas Department of Health, Bureau of Radiation Control. Regulatory Guide 5.2, Guide for the Preparation of Survey Instrument Calibration Applications, 1982 6 Texas Department of Health, Bureau of Radiation Control, Regulatory Guide 5.2, Guide for the Preparation of Survey Instrument Calibration Applications, 1982

4

Appendix B-15 Question 17

PROCEDURES FOR SPECIFIC INSTRUMENTS

LUDLUM MODEL 14-C GEIGER COUNTER

This instrument will be calibrated only with the remote GM detector Models 44-6 or 44-38 series.

The calibration will be carried out in the manner specified in the general section entitled Conditions of Calibration. Only one point will be checked on the x0.1 and x1000 (internal detector) scales.

Ludlum model 14Cs currently in use by the Bureau come with three different meter faces. Meter faces can be distinguished by the location of the x100 scale in comparison with the other two scales.

There are two Calibration Record sheets available to document the calibration of the instrument, one sheet is use if the x100 scale is in the middle of the face plate and the second is used otherwise.

LUDLUM MODEL 12S or 19 MICRO METER

This instruments calibration will be carried out in the manner specified in the general section entitled Conditions of Calibration. Contrary to recommendations by the manufacturer no attempt will be made during routine calibration procedures to calibrate each range with a pulser or establish a voltage plateau.

LUDLUM MODEL 2241 SCALER AND RATEMETER

This instrument will be calibrated with the remote GM detector Models 44-38 series. The calibration will be carried out in the manner specified in the general section entitled Conditions of Calibration. A minimum of three decades will be checked covering a range of 5 to 500 Roentgens per hour. The high range detector will be calibrated over a range of 3 decades and will have at least one of the reading be greater than one Roentgen per hour. The 1x1 sodium iodide detector will be calibrated at a minimum of three points over a range of 20 to 2000 micro-Roentgens per hour.

RADeCO MODEL H809 LOW VOLUME AIR SAMPLERS

Calibration only occurs at a flow rate of two cubic feet per minute. All samples will be collected at this flow rate. The instruments used to calibrate the RADeCO model H810 air samplers are either the RADeCO model 812 and/or 828 calibrators. These are returned to the manufacturer once a year for calibration.

RADeCO MODEL H810 LOW VOLUME AIR SAMPLERS

Routine calibration verifies a flow rate of two to four cubic feet per minute. If routine calibration is not with ten percent of the calibrators value, the sampler with be calibrated in accordance with technical manual to low value of up to one cubic foot per minute and a high value not to exceed ten cubic feet per minute. The instruments used to calibrate the RADeCO model H810 air samplers are either the RADeCO model 812 or 828 calibrators. These are returned to the manufacturer once a year for calibration.

LUDLUM MODEL 77-3

This instruments calibration will be carried out by manufacturer or other certified calibration vender since CDV-784 is no longer available for use.

5

Appendix B-15 Question 17

LUDLUM 9DP

Calibration and maintenance procedures for the Ludlum pressurized ion chambers are currently in the process of being developed. At the present time instruments should be sent to manufacturer for calibration and maintenance. Prior to shipping ion chamber should be depressurized using manufacturers procedure.

EBERLINE RO-20 & RO-2

Calibration and maintenance of the Eberline Ion chambers should be performed as outline in the instruments Technical manual with the exception that two points will be check on each scale when possible

E-600 SCALER AND RATEMETER WITH SPA-8 PROBE

The E-600 is entirely controlled by its microprocessor, its probe voltage and detection thresholds are directly set by output of the processor chip. Calibrating and configuring this instrument is accomplished from a program which runs on a host computer and communicates with the E-600 via a serial data link. Refer to the technical manuals supplied with the host program and instrument for detailed information on calibration.

American National Standard Institute(ANSI), Radiation Protection Instrumentation Test and Calibration, ANSI N323-1978, The Institute of Electrical and Electronics Engineers, Inc., New York, NY, 1978 American National Standard Institute(ANSI), Performance Specifications for Health Physics Instrumentation, ANSI N42.17A, 1989 International Atomic Energy Agency (IAEA), Handbook on the Calibration of Radiation Protection Monitoring Instruments, Technical Reports Series No. 133, Vienna, Austria, 1971 International Atomic Energy Agency (IAEA), Calibration of Radiation Protection Monitoring Instruments, Safety Reports Series No. 16, Vienna, Austria, 2000 International Commission on Radiation Units and Measurements (ICRU), Radiation Protection Instrumentation and Its Application, ICRU report 20, Washington, DC, 1976 Knoll, G. F., Radiation Detection and Measurement, 2nd edition, Wiley, New York, NY, 1989

6

Appendix B-16 Question 19

License Name Action Number

L05284 ISORX Texas Add authorization for production cyclotron

L04274 Allens Nutech Inc Add authorization for the NorthStar RadioGenix System. Add authorization for the Eckert &

Ziegler GalliaPharm Ge-68/Ga-68 generator

L05077 Red River Pharmacy Services Inc Add authorization for NorthStar RadioGenix System

L05947 UT Southwestern Med Center at Add GammaPod Dallas

L06973 Tyler Regional Hospital Add GammaTile

L02807 Solvay Complex multiyear decommissioning with revised decommissioning plan

L05436 Trace Life Sciences Decommissioning plan review.

(Kensington/USR) Current decommissioning is stalled in litigation

L00248 University of Texas at Arlington Renewal

L00448 Texas A&M University Renewal

L00466 The University of Texas MD Renewal Anderson Cancer Center

L00485 The University of Texas at Austin Renewal

L00650 Memorial Hermann Hospital Renewal System

L00680 Baylor College of Medicine Renewal

L01536 Texas Tech University Renewal License Name Action Number

L01586 Texas Health Presbyterian Hospital Renewal of Dallas

L06331 The Methodist Hospital Research Renewal Institute

L06949 The University of Texas at Austin Renewal Dell Medical School

L06551 Circle Z Pressure Pumping Chapter 7 Bankruptcy

L06440 Texas General Hospital Chapter 7 Bankruptcy

L06859 BJ Services Chapter 11 Bankruptcy

L06130 Crossroads Health Center Chapter 11 Bankruptcy

L05323 Hexion Inc Chapter 11 Bankruptcy

Appendix C-1 Question 27

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

2007-3 Requirements for Expanded 11/30/2010 Final Comments Language from Definition of Byproduct Material ML15078A29 05/26/2015 10CFR31.5(c)(13)(i)

Parts 20, 30, 31, 32, 33, 35, 61, 9 ML15078A285 concerning one address 150 per registration was added as 289.251(g)(4) 72 FR 55864 Revised Final Comments on 9/21/2018 ML15300A18 02/08/2016 7 ML15300A167

Revised Final Comments ML16076A35 06/16/2016 3 ML16076A350

Revised Final Comments ML18234A45 10/16/2018 9 ML18234A448

2018-1 Medical Use of Byproduct Material 01/14/2022 Proposed Comments The comments were

- Medical Event Definitions, ML21182A35 07/29/2021 addressed in the Training and Experience, and 4 ML21182A323 January 2022 Adopted Clarifying Amendments version of §289.256.

Parts 30, 32 and 35 2018-3 Miscellaneous Corrections 07/30/2022 Proposed Comments The comments were Parts 1, 2, 34, 37, 50, 71, 73, and ML21182A35 07/29/2021 addressed in the March 140 4 ML21182A323 2015 version of

§289.255 and the January 2022 version of

§289.257.

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

N/A 10 CFR 34 and 39 Not N/A Final Comments The comments were Associated with a Specific ML11334007 01/11/2012 addressed in the March RATS 0 ML113550343 2015 version of

§289.255

N/A 10 CFR 20, 30, 31, 32, 35, 70 and N/A Proposed Comments Comments are 71 Not ML14258B11 12/16/2014 regarding 10 CFR Parts Associated with a Specific 7 ML14258A158 20.1403, 20.1405 and RATS 31.12(c)(4).

Comments Final 05/26/2015 §289.202(ddd) and ML15078A29 ML15078A285 (ddd)(3) is compatible 9 with 10 CFR Parts 20.1403.

§289.202(ddd) has paragraph (5) that is compatible with the requirements of 10 CFR 20.1405.

§289.251(f)(4)(K)(iii)(V) is compatible with 10 CFR 31.12(c)(4).

Appendix C-2 Question 29

SSD number Manufacturer Product type or use Date issued Type of action N Ion Generator TX-0642-D-104-B THERMO FINNIGAN LLC Chromatography 3/7/2018 amendment SCHLUMBERGER TECHNOLOGY TX-0586-D-114-G CORPORATION D Gamma Gauge 4/23/2018 amendment TX-1422-D-101-G NEOTEK ENERGY INC D Gamma Gauge 5/17/2018 amendment TX-0634-D-900-B THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 5/18/2018 amendment TX-0634-D-906-B THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 5/25/2018 Inactivate SSD TX-1488-D-101-G HAIMO AMERICA INC D Gamma Gauge 5/30/2018 Initial SSD Registration TX-0634-S-109-S THERMO PROCESS INSTRUMENTS LP H General Neutron Source 6/5/2018 amendment TX-0634-S-907-S THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 6/5/2018 Inactivate SSD TX-0167-S-102-S BRK BRANDS INC P Ion Generator 6/26/2018 amendment TX-0634-D-908-B THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 8/10/2018 Inactivate SSD TX-0634-D-909-S THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 9/11/2018 Inactivate SSD TX-0634-S-910-S THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 9/11/2018 Inactivate SSD TX-0634-D-911-S THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 9/14/2018 Inactivate SSD TX-0634-D-912-B THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 9/19/2018 Inactivate SSD TX-0634-D-913-B THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 10/19/2018 Inactivate SSD SCHLUMBERGER TECHNOLOGY TX-0586-D-114-G CORPORATION D Gamma Gauge 10/29/2018 amendment TX-1351-D-101-B FMC TECHNOLOGIES INC D Gamma Gauge 11/28/2018 amendment SCHLUMBERGER TECHNOLOGY TX-0586-S-107-S CORPORATION F Well logging 2/5/2019 amendment TX-1492-D-101-S GEOTEK CORING INC D Gamma Gauge 2/11/2019 Initial SSD Registration TX-0634-D-914-B THERMO PROCESS INSTRUMENTS LP U X-ray Fluorescence 2/28/2019 Inactivate SSD TX-0634-D-915-B THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 4/25/2019 Inactivate SSD TX-0634-D-918-S THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 4/25/2019 Inactivate SSD TX-0634-D-917-B THERMO PROCESS INSTRUMENTS LP U X-ray Fluorescence 5/6/2019 Inactivate SSD TX-0634-D-919-B THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 5/23/2019 Inactivate SSD TX-1176-D-102-G MICRO MOTION INC D Gamma Gauge 5/25/2019 amendment TX-0634-D-920-B THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 6/6/2019 Inactivate SSD TX-0634-D-921-B THERMO PROCESS INSTRUMENTS LP T Other 6/11/2019 Inactivate SSD TX-0634-D-922-S THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 6/18/2019 Inactivate SSD SCHLUMBERGER TECHNOLOGY TX-0586-D-114-G CORPORATION D Gamma Gauge 8/1/2019 amendment TX-0634-D-923-S THERMO PROCESS INSTRUMENTS LP G Portable Moisture Density 9/3/2019 Inactivate SSD TX-0634-D-924-S THERMO PROCESS INSTRUMENTS LP G Portable Moisture Density 9/3/2019 Inactivate SSD TX-0634-D-925-S THERMO PROCESS INSTRUMENTS LP U X-ray Fluorescence 9/4/2019 Inactivate SSD TX-0634-D-926-B THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 9/5/2019 amendment TX-0634-D-927-B THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 9/5/2019 Inactivate SSD TX-0634-D-928-B THERMO PROCESS INSTRUMENTS LP H General Neutron Source 9/9/2019 Inactivate SSD TX-0628-D-898-B THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 9/11/2019 Inactivate SSD TX-0634-D-929-S THERMO PROCESS INSTRUMENTS LP U X-ray Fluorescence 9/12/2019 Inactivate SSD TX-0634-D-930-B THERMO PROCESS INSTRUMENTS LP E Beta Gauge 9/12/2019 Inactivate SSD SSD number Manufacturer Product type or use Date issued Type of action TX-1488-D-101-G HAIMO AMERICA INC D Gamma Gauge 10/7/2019 amendment TX-1328-D-101-S NUCLEAR SCANNING SERVICES INC T Other 11/25/2019 amendment TX-1247-D-103-G ONESUBSEA PROCESSING INC D Gamma Gauge 12/17/2019 Initial SSD Registration TX-1328-D-101-S NUCLEAR SCANNING SERVICES INC T Other 12/19/2019 Correct Error TX-0508-D-814-S NUCLEAR SOURCES AND SERVICES INC D Gamma Gauge 2/14/2020 Inactivate SSD TX-0508-S-813-S NUCLEAR SOURCES AND SERVICES INC F Well logging 2/14/2020 Inactivate SSD TX-0634-D-900-B THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 2/26/2020 Correct Error TX-1488-D-101-G HAIMO AMERICA INC D Gamma Gauge 3/17/2020 amendment TX-1198-D-801-S SUPERIOR ENERGY SERVICES LLC F Well logging 3/23/2020 Inactivate SSD TX-1363-D-101-S PROBETECHNOLOGY SERVICES INC F Well logging 3/30/2020 Initial SSD Registration SCHLUMBERGER TECHNOLOGY TX-0586-D-805-G CORPORATION D Gamma Gauge 4/13/2020 Inactivate SSD TX-8328-S-801-S ECKERT & ZIEGLER ISOTOPE PRODUCTS X Medical Reference Source 4/20/2020 Inactivate SSD TX-8328-S-802-S ECKERT & ZIEGLER ISOTOPE PRODUCTS X Medical Reference Source 4/20/2020 Inactivate SSD TX-8328-S-803-S ECKERT & ZIEGLER ISOTOPE PRODUCTS X Medical Reference Source 4/20/2020 Inactivate SSD TX-1020-D-101-S PERFORMANCE MATERIALS NA INC D Gamma Gauge 5/7/2020 amendment SCHLUMBERGER TECHNOLOGY TX-0586-D-805-G CORPORATION D Gamma Gauge 5/14/2020 Correct Error TX-8328-S-801-S ECKERT & ZIEGLER ISOTOPE PRODUCTS X Medical Reference Source 5/28/2020 Correct Error TX-8328-S-802-S ECKERT & ZIEGLER ISOTOPE PRODUCTS X Medical Reference Source 5/28/2020 Correct Error TX-8329-S-801-S ISOSTAR TEXAS INC V General Medical Use 6/11/2020 Inactivate SSD TX-8330-D-801-S SOUTHWEST BIO-MEDICAL SYSTEMS V General Medical Use 8/24/2020 Inactivate SSD TX-1176-D-102-G MICRO MOTION INC D Gamma Gauge 9/8/2020 amendment TX-0734-D-105-G TRACERCO D Gamma Gauge 10/15/2020 amendment TX-0634-D-900-B THERMO PROCESS INSTRUMENTS LP D Gamma Gauge 10/21/2020 Correct Error TX-0734-D-104-S JOHNSON MATTHEY INC D Gamma Gauge 10/26/2020 amendment TX-1247-D-103-G ONESUBSEA PROCESSING INC D Gamma Gauge 1/21/2021 Correct Error TX-0303-S-804-S GAMMATRON INC T Other 3/10/2021 Inactivate SSD SCHLUMBERGER TECHNOLOGY TX-0586-D-115-S CORPORATION F Well logging 4/23/2021 amendment SCHLUMBERGER TECHNOLOGY TX-0586-D-114-G CORPORATION D Gamma Gauge 5/2/2021 amendment TX-0303-S-805-S GAMMATRON INC T Other 6/7/2021 Inactivate SSD TX-1328-D-101-S NUCLEAR SCANNING SERVICES INC T Other 6/17/2021 amendment TX-1247-D-102-G ONESUBSEA PROCESSING INC D Gamma Gauge 10/8/2021 amendment TX-0734-D-104-S JOHNSON MATTHEY INC D Gamma Gauge 10/21/2021 amendment TX-1247-D-103-G ONESUBSEA PROCESSING INC D Gamma Gauge 10/27/2021 Correct Error TX-0426-D-108-G LUDLUM MEASUREMENTS INC D Gamma Gauge 10/28/2021 Initial SSD Registration D Gamma Gauge, F Well TX-0303-S-102-S GAMMATRON INC logging, H General Neutron 11/9/2021 amendment TX-0303-S-806-S GAMMATRON INC F Well logging 11/9/2021 Inactivate SSD TX-0303-S-807-S GAMMATRON INC F Well logging 11/9/2021 Inactivate SSD D Gamma Gauge, F Well TX-0303-S-102-S GAMMATRON INC logging, H General Neutron 11/17/2021 Correct Error TX-8260-S-803-S GNI INCORPORATED T Other 12/2/2021 Inactivate SSD SSD number Manufacturer Product type or use Date issued Type of action TX-8260-S-804-S GNI INCORPORATED T Other 12/7/2021 Inactivate SSD TX-8260-S-805-S GNI INCORPORATED T Other, I Calibration 12/7/2021 Inactivate SSD TX-8260-D-806-S GNI INCORPORATED A Industrial Radiography 12/10/2021 Inactivate SSD TX-8260-S-807-S GNI INCORPORATED T Other 12/21/2021 Inactivate SSD TX-8260-S-808-S GNI INCORPORATED T Other 12/16/2021 Inactivate SSD TX-8260-S-809-S GNI INCORPORATED F Well logging 12/21/2021 Inactivate SSD TX-8260-S-807-S GNI INCORPORATED A Industrial Radiography 12/22/2021 Inactivate SSD TX-8260-S-808-S GNI INCORPORATED T Other 12/16/2021 Inactivate SSD TX-8260-S-809-S GNI INCORPORATED F Well logging 12/21/2021 Inactivate SSD TX-8260-S-810-S GNI INCORPORATED A Industrial Radiography 12/22/2021 Inactivate SSD TX-8260-S-811-S GNI INCORPORATED A Industrial Radiography 1/12/2022 Inactivate SSD