ML22080A218

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Cy 2021 Annual Report on Agreement States and U.S. NRCs Radioactive Materials Programs
ML22080A218
Person / Time
Issue date: 04/13/2022
From: John Lubinski
Office of Nuclear Material Safety and Safeguards
To: Jeff Baran, Christopher Hanson, David Wright
NRC/OCM/DAW, NRC/OCM/JMB, NRC/Chairman
Johnson R
References
Download: ML22080A218 (14)


Text

April 13, 2022 MEMORANDUM TO: Chairman Hanson Commissioner Baran Commissioner Wright Signed by Lubinski, John FROM: John W. Lubinski, Director on 04/13/22 Office of Nuclear Material Safety and Safeguards

SUBJECT:

ANNUAL REPORT ON AGREEMENT STATES AND U.S.

NUCLEAR REGULATORY COMMISSIONS RADIOACTIVE MATERIALS PROGRAMS FOR CALENDAR YEAR 2021 Enclosed is the Calendar Year 2021 annual report to inform the Commission of the status of the Agreement States and U.S. Nuclear Regulatory Commissions radioactive materials programs. This report was developed in accordance with the June 30, 1997, Staff Requirements Memorandum on SECY-97-054, Final Recommendations on Policy Statement and Implementing Procedures for: Statement of Principles and Policy for the Agreement State Program and Policy Statement on Adequacy and Compatibility of Agreement State Programs.

Enclosure:

Annual Report on Agreement States and U.S. Nuclear Regulatory Commissions Radioactive Materials Programs for Calendar Year 2021 cc: SECY OGC OCA OPA CFO EDO CONTACT: Robert K. Johnson, NMSS/MSST 301-415-7314

ML22080A218 (WITS199500008)

OFFICE NMSS/MSST NMSS/MSST NMSS/MSST NMSS/TechEd NMSS NAME RJohnson BAnderson KWilliams PMenefee-Buzdygon JLubinski 03/21/2022 3/22/022 3/28/2022 3/28/2022 4/13/2022 DATE ANNUAL REPORT ON AGREEMENT STATES AND U.S. NUCLEAR REGULATORY COMMISSIONS RADIOACTIVE MATERIALS PROGRAMS FOR CALENDAR YEAR 2021 April 13, 2022 Enclosure

EXECUTIVE

SUMMARY

The Calendar Year (CY) 2021 report is a summary of the Agreement State and U.S. Nuclear Regulatory Commission (NRC) radioactive materials program performance, including the ability to: (1) provide reasonable assurance of adequate protection of public health and safety for the safe and secure use of nuclear materials; medical, industrial, and academic applications; uranium recovery activities, low-level radioactive waste sites, and (2) maintain Agreement State programs that are compatible with the NRCs regulatory program.

The NRC verifies the program performance using the Integrated Materials Performance Evaluation Program (IMPEP). Agreement State and NRC programs are determined to be adequate to protect public health and safety if the administration of these programs ensures adequate protection of public health and safety in regulating the use of radioactive material.

Overall, the Agreement State and NRC programs (referred to as the National Materials Program (NMP)) continue to provide reasonable assurance of adequate protection of public health and safety.

The NMPs performance, as measured by the IMPEP, has been consistently strong. During CY 2021, 35 of the 39 Agreement State programs had an adequacy finding of adequate to protect public health and safety. The four remaining Agreement StatesFlorida, Kansas, Mississippi, and Rhode Islandhad adequacy findings of adequate to protect public health and safety but needs improvement. For CY 2021, no States had a finding of not adequate to protect public health and safety. The first consolidated NRC IMPEP review including the first IMPEP review of the NRC materials program that considered licensing activities for complex decommissioning and uranium recovery sites was held June 7-11, 2021. All NRC programs (NRC Sealed Source and Device, Uranium Recovery, and NRC Regions I, III, and IV materials programs) remained adequate to protect public health and safety.

Regarding Agreement State compatibility, 37 of the 39 programs had a compatibility finding of compatible with the NRCs regulatory program. The two remaining Agreement StatesFlorida and New York had compatibility findings of not compatible with the NRCs regulatory program.

All programs that have IMPEP findings are taking actions to address the issues and the effectiveness of those actions will be reviewed through the IMPEP process.

The CY 2021 IMPEP results demonstrate that the NMP remains protective of public health and safety in regulating the use of radioactive material. Agreement States continue to play a valuable role in the IMPEP as evidenced by the increase in Agreement State participation and collaboration in the NMP activities. The NRC and its regulatory partners continued to effectively implement the program in a flexible, resilient, and innovative manner to accomplish our mission, despite challenges presented by the ongoing COVID-19 pandemic. The NRC staff will continue to monitor performance through the IMPEP and work with the NMP to address any performance issues or trends.

BACKGROUND ON THE NRC AGREEMENT STATE PROGRAM Section 274 of the Atomic Energy Act of 1954, as amended (AEA), provides broad authority for the U.S. Nuclear Regulatory Commission (NRC) to establish a unique Federal and State relationship in the administration of regulatory programs to provide reasonable assurance of adequate protection of public health and safety in the industrial, medical, commercial, and research uses of agreement material (source, byproduct, and small quantities of special nuclear material as identified by Section 274b. of the AEA). Subsection 274b. of the AEA authorizes the NRC to enter into an agreement by which the NRC relinquishes its regulatory authority and the State assumes regulatory authority over some or all of these materials. In order to discontinue its authority, the NRC must find that the State program is adequate to protect public health and safety and compatible with the NRC program for the regulation of agreement material. The NRC also has an obligation, pursuant to Subsection 274j. of the AEA, to periodically review existing Agreement State program performance to ensure continued adequacy and compatibility.

PERFORMANCE MONITORING The NRC uses the Integrated Materials Performance Evaluation Program (IMPEP) to periodically review Agreement State and NRC programs (collectively referred to as the National Material Program (NMP)) to verify that these programs are adequate to protect public health and safety, and verify that Agreement State programs are compatible with the areas of the NRCs regulatory program.

Programs are determined to be adequate to protect public health and safety if the administration of these programs provides reasonable assurance of the protection of public health and safety in regulating the use of radioactive material. Adequacy findings under IMPEP result in one of three conclusions: (1) adequate to protect public health and safety, (2) adequate to protect public health and safety but needs improvement, or (3) not adequate to protect public health and safety.

When the NRC promulgates regulations, it determines the degree to which Agreement States regulations must be compatible with the NRCs regulations. Agreement State programs are determined to be compatible with the NRC's regulatory program when Agreement State programs regulations align with this determination, and therefore do not create conflicts, duplications, gaps, or other conditions that jeopardize an orderly pattern in the regulation of agreement material. The IMPEP review compatibility findings for Agreement State programs are either compatible or not compatible.

The frequency of IMPEP reviews range from 1 to 5 years, based on the programs performance.

All reviews are conducted in accordance with the NRC Management Directive 5.6, Integrated Materials Performance Evaluation Program (IMPEP), and are conducted by teams of NRC and Agreement State staff members. A Management Review Board (MRB), composed of senior NRC managers and an Organization of Agreement States representative, convenes to deliberate the adequacy and compatibility findings and the frequency and type of the next IMPEP review. The MRB Chair will provide the final NRC findings with respect to the radiation control program based on input from the IMPEP review team, MRB members, and the program being reviewed. The NRC also conducts Periodic Meetings between the IMPEP reviews to remain knowledgeable of the status of Agreement State and NRC programs.

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The NRC takes a graded approach to address programmatic weaknesses in Agreement State programs. Program improvement measures may include monitoring, heightened oversight, probation, or suspension. Under these processes, the NRC staff works collaboratively with the Agreement States to ensure that they have a full understanding of the issues that need to be addressed, and that appropriate corrective actions are implemented in order to progress toward reestablishing satisfactory program performance.

During Calendar Year (CY) 2021, the NRC and its Agreement State partners conducted 11 IMPEP reviews with the support of 19 Agreement State personnel. The Louisiana, Nebraska, New Hampshire, Tennessee, NRC, and Maryland IMPEP reviews were conducted remotely due to travel restrictions associated with the COVID-19 pandemic (pandemic). The Oregon, New Mexico, Vermont, Rhode Island and Nevada IMPEP reviews were conducted in person. In-person inspector accompaniments were conducted for all CY 2021 IMPEP reviews. In addition to the in-person inspector accompaniments, teams conducted remote inspector accompaniments for the NRC and Tennessee IMPEP reviews.1 During CY 2021, the NRC conducted all eight MRB meetings remotely for the Kansas, Louisiana, Nebraska, New Hampshire, Tennessee, NRC, Maryland and Oregon IMPEP reviews, due to travel restrictions associated with the pandemic. Eight Agreement State personnel served as representatives to the eight MRB meetings conducted in CY 2021.

During the pandemic, eight IMPEP reviews were rescheduled due to travel restrictions associated with the pandemic (including the Kansas, Louisiana, Nebraska, New Hampshire, Maryland, Vermont, Rhode Island, and Mississippi IMPEP reviews). As of the date of this report, all eight IMPEP reviews have been completed.

AGREEMENT STATE PROGRAM PERFORMANCE This section discusses the status of materials programs on heightened oversight or monitoring, and programs that were either adequate, but needs improvement, or not compatible during CY 2021. A brief summary of recent activities related to materials programs on heightened oversight or monitoring is presented in Attachment 1, Heightened Oversight and Monitoring Status Chart.

Agreement State Programs on Heightened Oversight or Monitoring During CY 2021 During CY 2021, the Rhode Island Agreement State Program (Rhode Island) was the only Agreement State on monitoring or heightened oversight.

The Rhode Island Agreement State Program (Rhode Island) was placed on monitoring after the October 2011 IMPEP review, and remained on monitoring after the March 2016 IMPEP review.

Based on the results of the 2016 IMPEP review, Rhode Island was found to be adequate to protect public health and safety, but needs improvement, and compatible with the NRCs regulatory program. Following the October 2018 Periodic Meeting, the MRB determined that while Rhode Island continued to make progress in addressing weaknesses, it had not demonstrated a period of sustained performance, and therefore should remain on monitoring.

1 Remote inspector accompaniments allowed review teams to observe, and as appropriate, interact with, Program inspectors conducting performance-based inspection activities.

2

During CY 2021, the NRC continued conducting quarterly calls to monitor Rhode Islands performance. Based in the results of the 2021 IMPEP review, Rhode Island was found to be adequate to protect public health and safety, but needs improvement, and compatible with the NRCs regulatory program. The MRB found Rhode Islands performance satisfactory but needs improvement (SBNI) for the performance indicator Technical Staffing and Training, which remains unchanged from the previous IMPEP review. The MRB found Rhode Islands performance Unsatisfactory (UNSAT) for the performance indicator Technical Quality of Licensing Actions. Because of the significance of the findings, the MRB determined that the Rhode Island Agreement State Program should enter a period of Heightened Oversight2. The next IMPEP review is scheduled to be conducted in CY 2023.

Agreement State Programs that were Adequate, But Needs Improvement during CY 2021 During CY 2021, the Florida and Mississippi Agreement State Programs remained with an overall program finding of either adequate to protect public health and safety, but needs improvement, or not compatible with the NRCs regulatory program.

Following its June 2019 IMPEP review, the Florida Agreement State Program (Florida) was found to be adequate to protect public health and safety, but needs improvement, and not compatible with the NRCs regulatory program. The team determined that the declining performance was mainly due to a loss of institutional knowledge and training issues. Although Florida hired staff in a timely manner, the lack of knowledge transfer affected the areas of inspections, reporting of incidents to the Nuclear Material Events Database, and the promulgation of regulations required for compatibility. As a result of the July 2020 Periodic Meeting, NRC staff determined that Florida made progress in addressing corrective actions regarding concerns identified during the 2019 IMPEP review. Staff also determined that Florida is effectively managing its licensing and inspection activities and responding to incidents and allegations, as appropriate. Florida also developed a plan to review regulations on a monthly basis and to prioritize addressing overdue regulations. A second Periodic Meeting is scheduled to be conducted in June 2022, to continue to track the Floridas progress and the next IMPEP review is scheduled to be conducted in CY 2023.

While there were no IMPEP activities for the Mississippi Agreement State Program (Mississippi) during CY 2021, the program remained adequate to protect public health and safety, but needs improvement, for reporting purposes. Following its April 2017 IMPEP review, Mississippi was found to be adequate to protect public health and safety, but needs improvement, and compatible with the NRCs regulatory program, and placed on monitoring. As a result of the April 2018 Periodic Meeting, the period of monitoring was discontinued based on Mississippis improved performance, including enhancements to staff retention, technical quality of licensing actions, response to incidents and allegations, and the adoption of NRC regulations by reference. The Mississippi IMPEP review was conducted in person in February 2022 and the IMPEP team noted a significant decline in performance. The MRB meeting is scheduled to be conducted on May 26, 2022. Based on the MRBs determination of the adequacy and compatibility of the Mississippi Agreement State Program, additional IMPEP activities and communication to the Commission could occur in CY 2022.

2 Heightened Oversight is an increased monitoring process used by the NRC to follow the progress of improvement needed in an Agreement State program. Being placed on Heightened Oversight involves preparation of a Program Improvement Plan, bimonthly conference calls, and submission of status reports prior to each call.

3

As discussed in the section above, Rhode Island was found to be adequate to protect public health and safety, but needs improvement, and compatible with the NRCs regulatory program following its October 2021 IMPEP review and moved from monitoring to a period of heightened oversight.

Agreement State Programs that were Not Compatible during CY 2021 During CY 2021, the Florida and New York Agreement State Programs were not compatible with the NRC regulatory program.

As noted in the section above, Florida was found to be not compatible with the NRCs regulatory program following its June 2019 IMPEP review. Florida was found to be UNSAT for the performance indicator Legislation, Regulations, and Other Program Elements. The IMPEP team determined that the declining performance was mainly due to a loss of institutional knowledge and inadequate training of new staff. Although Florida hired staff in a timely manner, the lack of knowledge transfer affected the promulgation to regulations required for compatibility. As a result of the July 2020 Periodic Meeting, NRC staff determined that Florida had developed a plan to review regulations on a monthly basis and to prioritize addressing overdue regulations. A second Periodic Meeting is scheduled to be conducted in July 2022 to continue to tracking Floridas progress. The next IMPEP review is scheduled to be conducted in CY 2023.

While there were no IMPEP activities for New York Agreement State Program (New York) during CY 2021, the program remained not compatible for reporting purposes. Based on the results of the March 2018 IMPEP review, the June 2018 MRB found New York to be adequate to protect public health and safety, but not compatible with the NRCs regulatory program.

Based on New Yorks progress in making performance improvements in the areas of staffing and training and compatibility, the MRB also discontinued the period of monitoring. The next IMPEP review is scheduled to be conducted in July 2022.

STATUS OF THE NATIONAL MATERIALS PROGRAM The performance of the NMP may be assessed through IMPEP findings, primarily through a review of performance indicator results and adequacy and compatibility status.

Performance Indicator Results In CY 2021, the NRC and its Agreement State partners conducted 11 IMPEP reviews, evaluating a total of 72 performance indicators. During CY 2021, 68 of the performance indicators reviewed were found to be satisfactory, 3 performance indicators were found to be SBNI, and 1 performance indicator was found to be UNSAT.

During the last 5 years, the NRC and its Agreement State partners have conducted 42 IMPEP reviews, evaluating 281 performance indicators. Based on the most recent IMPEP review results for each of the Agreement States and NRC programs that constitute the NMP, 262 performance indicators evaluated were found to be satisfactory, 16 performance indicators were found to be SBNI. Only three of the performance indicators were found to be UNSAT. provides a summary of the most recent IMPEP findings and associated adequacy and compatibility results for the NMP. As shown in this attachment, the most challenged performance indicator is the non-common performance indicator Legislation, Regulations, and 4

Other Program Elements. This performance indicator assesses whether Agreement State programs create conflicts, duplications, gaps, or other conditions that jeopardize an orderly pattern in the regulation of radioactive materials under the AEA. The number of programs with a SBNI rating, for this performance indicator declined from six programs in CY 2020 to four programs in CY 2021. The number of programs with an UNSAT rating for this performance indicator remained the same.

Adequacy and Compatibility Status in the National Materials Program Over the last 5 years, 93 percent of the NMP were adequate to protect public health and safety (36 Agreement State programs and the NRC program3). Regarding compatibility, 95 percent of Agreement State programs were compatible with the NRCs regulatory program. Table 1, on the following page, provides a summary of the adequacy and compatibility results for the Agreement States and NRC program over the last 5 years. The IMPEP results continue to provide evidence that the NMP provides for reasonable assurance of adequate protection of public health and safety.

Table 1. Adequacy and Compatibility Results CY 2017 - CY 2021 2017 2018 2019 2020 2021 National Materials Programs 41 42 43 43 40 (Number of NRC and Agreement State Programs)

Agreement State Programs 37 38 39 39 39 Adequate to Protect Public 36 38 39 40 37 Health and Safety Adequate to Protect Public Health and Safety, 5 4 4 3 3 But Needs Improvement Not Adequate to Protect Public Health and Safety 0 0 0 0 0 Compatible with the NRCs Regulatory Program 34 36 36 37 37 Not Compatible with the NRCs Regulatory 3 2 3 2 2 Program CONCLUSION The NMP continues to provide reasonable assurance of adequate protection of public health and safety. The IMPEP continues to be an effective tool to verify that NRC and Agreement State programs are evaluated in consistent and integrated manner, that public health and safety is being adequately maintained, and that Agreement State programs are compatible with the NRCs regulatory program. The NRC and its regulatory partners continue to effectively implement the program in a flexible, resilient, and innovative manner to accomplish our mission, 3 In January 2020, the NRC made the decision to evaluate the NRC materials programs as a single entity under the IMPEP (rather than reviewing the NRC regions and Headquarters individually), which began June 2021.

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despite challenges presented by the ongoing pandemic. The Agreement States continue to play a valuable role with respect to ensuring consistent implementation of the NMP in protecting the public health and safety with respect to the safe and secure use of radioactive materials.

Attachments:

1. Heightened Oversight and Monitoring Status Chart
2. Summary of National Materials Programs Performance Indicator Findings and Adequacy and Compatibility 6

HEIGHTENED OVERSIGHT AND MONITORING STATUS CHART (As of April 13, 2022)

LAST IMPEP LAST NEXT STATE ACTION(S) DUE REVIEW CONTACT CONTACT HEIGHTENED OVERSIGHT Periodic Meeting Bimonthly Bimonthly October 2022 Heightened Heightened Rhode Island Oct. 19-22, 2021 Oversight Call Oversight Call CY 2023 IMPEP March 2022 May 2022 October 2023 MONITORING None Attachment 1

Summary of National Materials Programs Performance Indicators Findings and Adequacy and Compatibility (As of April 13, 2022)

NON-COMMON COMMON OVERALL CALENDAR YEAR OF LAST FULL PERFORMANCE PERFORMANCE INDICATORS PROGRAM RATING INDICATORS AGREEMENT STATE/NRC Status of Material Inspection Technical Quality of Incident Legislation, Regulations, and Uranium Recovery Program Technical Staffing and Sealed Source and Device NEXT IMPEP REVIEW Technical Quality of Technical Quality of Low-Level Waste COMPATIBILITY ADEQUACY MATERIALS PROGRAM IMPEP REVIEW CONDUCTED Inspections Licensing Actions Disposal Program Training Program and Allegation Activities Evaluation Program Other Program Elements Alabama 2019 SAT SAT SAT SAT SAT SAT - - - Adequate1 Compatible2 2023 Arizona 2019 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2024 Arkansas 2017 SAT SAT SAT SBNI 3,4 SAT SAT - - - Adequate Compatible 20225 California 2019 SAT SAT SAT SAT SAT SAT SAT - - Adequate Compatible 2024 Colorado 2018 SAT SAT SAT SAT SAT SAT SAT SAT - Adequate Compatible 20226 Not Florida 2019 SAT SAT SBNI SAT SAT UNSAT7 SAT - - ABNI8 2023 Compatible9 Georgia 2020 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2024 Illinois 2018 SAT SAT SAT SAT SAT SAT SAT SAT - Adequate Compatible 2023 Iowa 2018 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 202210 Kansas 2021 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2025 Kentucky 2020 SAT SAT SAT SAT SAT SBNI SAT - SAT Adequate Compatible 2024 Louisiana 2021 SAT SAT SAT SAT SAT SAT SAT - - Adequate Compatible 2025 Maine 2019 SAT SAT SAT SAT SAT SBNI SAT - - Adequate Compatible 2023 Maryland 2021 SAT SAT SAT SBNI SAT SAT SAT - - Adequate Compatible 202211 Massachusetts 2018 SAT SAT SAT SAT SAT SAT SAT - - Adequate Compatible 202212 Minnesota 2021 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2025 Mississippi 2017 SAT SAT SAT SBNI SBNI SBNI - - - ABNI Compatible 202213 Nebraska 2021 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2025 1 Adequate to protect public health and safety (Adequate).

2 Compatible with NRCs regulatory program (Compatible).

3 Satisfactory, but needs improvement (SBNI).

4 Indicator changed as a result of the 2019 Follow-Up IMPEP.

5 The Arkansas IMPEP review was conducted on January 24-28, 2022, and the MRB is scheduled to be conducted on April 28, 2022.

6 The Colorado IMPEP review is scheduled to be conducted May 2-6, 2022, and the MRB is scheduled to conducted August 9, 2022.

7 Unsatisfactory (UNSAT).

8 Adequate to protect public health and safety but needs improvement (ABNI).

9 Not compatible with NRCs regulatory program (Not Compatible).

10 The Iowa IMPEP review is scheduled to be conducted on June 27-July 1, 2022, and the MRB is scheduled to be conducted October 6, 2022.

11 The Maryland follow-up IMPEP review is scheduled to be conducted in August, 2022.

12 The Massachusetts IMPEP review is scheduled to be conducted in November 2022.

13 The Mississippi IMPEP review was conducted on February 7-11, 2022, and the MRB is scheduled to be conducted on May 26, 2022.

Attachment 2

Summary of National Materials Programs Performance Indicators Findings and Adequacy and Compatibility (As of April 13, 2022)

NON-COMMON COMMON OVERALL CALENDAR YEAR OF LAST FULL PERFORMANCE PERFORMANCE INDICATORS PROGRAM RATING INDICATORS AGREEMENT STATE/NRC Status of Material Inspection Technical Quality of Incident Legislation, Regulations, and Uranium Recovery Program Technical Staffing and Sealed Source and Device NEXT IMPEP REVIEW Technical Quality of Technical Quality of Low-Level Waste COMPATIBILITY ADEQUACY MATERIALS PROGRAM IMPEP REVIEW CONDUCTED Inspections Licensing Actions Disposal Program Training Program and Allegation Activities Evaluation Program Other Program Elements Nevada 2021 SAT SAT SAT SAT SAT SAT - - SAT Adequate Compatible 2026 New Hampshire 2021 SAT SAT SAT SAT SAT SAT SAT Adequate Compatible 2026 New Jersey 2019 SAT SAT SAT SAT SAT SAT - Adequate Compatible 2024 New Mexico 2021 SAT SAT SAT SBNI SAT SAT - - - Adequate Compatible 2025 Not New York 2018 SBNI SAT SAT SAT SAT UNSAT SAT - SAT Adequate 202214 Compatible North Carolina 2018 SAT SAT SAT SAT SAT SAT SBNI - - Adequate Compatible 202215 North Dakota 2019 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2024 Ohio 2019 SAT SAT SAT SAT SAT SAT SAT - - Adequate Compatible 2024 Oklahoma 2018 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2023 Oregon 2021 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2026 Pennsylvania 2019 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2024 Rhode Island 2021 SBNI UNSAT SAT SAT SAT SAT - - - ABNI Compatible 2023 South Carolina 2017 SAT SAT SAT SAT SAT SAT SAT - SAT Adequate Compatible 202216 Tennessee 2021 SAT SAT SAT SAT SAT SAT SAT - - Adequate Compatible 2026 Texas 2018 SAT SAT SAT SBNI SAT SAT SAT SBNI SAT Adequate Compatible 202217 Utah 2019 SAT SAT SAT SAT SAT SAT - SAT SAT Adequate Compatible 2023 Vermont 2021 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2025 Virginia 2020 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2024 Washington 2018 SAT SAT SAT SBNI SAT SBNI SAT SAT SAT Adequate Compatible 202218 Wisconsin 2019 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2024 Wyoming 2020 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2024 NRC 2021 SAT SAT SAT SAT SAT NA SAT SAT - Adequate NA 202619 14 The New York IMPEP review is scheduled to be conducted on July 18-29,2022, and the MRB is scheduled to be conducted in November 2022.

15 The North Carolina IMPEP review is scheduled to be conducted May 2-6, 2022, and the MRB is scheduled to conducted August 11, 2022.

16 The South Carolina IMPEP review is scheduled to be conducted in October 2022.

17 The Texas IMPEP review was conducted on February 28- March 4, 2022, and the MRB is scheduled to be conducted on June 9, 2022.

18 The Washington IMPEP review was conducted on March 28-April 1, 2022, and the MRB is scheduled to be conducted on July 14, 2022.

19 NRCs most recent IMPEP review conducted on June 7-11, 2021, consolidated all headquarter and regional materials programs into a single integrated review. The consolidate NRC IMPEP report may be found at the following ADAMS Accession No. ML21260A075.

Attachment 2

NRC and Agreement State Radioactive Materials Programs Findings for Performance Indicators and Adequacy and Compatibility (As of April XX, 2022) 2