ML22278A107

10-05-2022 Letter to J. Priest Re Massachusetts Impep Scheduling Letter and Questionnaire

ML22278A107
Person / Time
Issue date:	10/05/2022
From:	Jackie Cook NRC/RGN-IV/DRSS
To:	Priest J State of MA, Dept of Public Health
Cook J
References
Download: ML22278A107 (27)

Text

October 5, 2022 Jack Priest Radiation Control Program Director Massachusetts Department of Public Health Schrafft Center, Suite IM2A 529 Main Street Charlestown, MA 02129

Dear Mr. Priest:

The U.S. Nuclear Regulatory Commission (NRC) uses the Integrated Materials Performance Evaluation Program (IMPEP) for the evaluation of Agreement State programs. Per our previous discussion, I will be the team leader for the IMPEP review of the Massachusetts Agreement State Program scheduled for November 14-18, 2022. The review team will include Lisa Forney, NRC Region I; Farrah Gaskins, NRC Region I; Robert Johnson, NMSS; Stephen Poy, NMSS; Frank Tran, NRC Region III; and Stephen James, Ohio Department of Health.

Enclosed is the Integrated Materials Performance Evaluation Program Questionnaire. The questionnaire was previously provided to you electronically on September 15, 2022. I ask that you provide your responses via email to Jackie.Cook@nrc.gov by October 31, 2022. The questionnaire was sent in advance of this IMPEP review scheduling letter in order to provide time for you to allocate the staff resources necessary to complete the document by the requested date.

Also included with the questionnaire is the document Materials Requested to Be Available for the On-Site Portion of an IMPEP Review. We encourage States to have the items listed prepared and to the extent possible, uploaded with the questionnaire responses prior to the commencement of the IMPEP review.

Please set up an appointment with the appropriate State Senior Managers to discuss the results of the IMPEP review of the Massachusetts Agreement State Program on November 18, 2022.

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

If you have any questions, please call me at 817-200-1132.

Sincerely, Johnson, Robert signing on behalf signature of Cook, Jacqueline on 10/05/22 Jacqueline Jackie D. Cook Regional State Agreements Officer US Nuclear Regulatory Commission, Region IV

Enclosure:

2022 IMPEP Questionnaire cc: Joshua E. Daehler Radioactive Materials Unit Supervisor Massachusetts Radiation Control Program

ML22278A107 letter OFFICE DRSS NAME JCook DATE 10/5/2022 Approved by OMB1 Control No.: 3150-0183 Expires: 02/28/2023 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE Massachusetts Agreement State Program Reporting Period: June 16, 2018 - November 18, 2022 Note: If there has been no change in the response to a specific question since the last IMPEP questionnaire, the State or Region may copy the previous answer, if appropriate.

A. GENERAL

1. Please prepare a summary of the status of the State's or Region's actions taken in response to each of the open recommendations from previous IMPEP reviews.

B. COMMON PERFORMANCE INDICATORS I. Technical Staffing and Training

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

(a) A chart showing positions from the Governor down to the Radiation Control Program Director; (b) A chart showing positions of the radiation control program, including management; and (c) Equivalent charts for sealed source and device evaluation, low-level radioactive waste and uranium recovery programs, if applicable.

3. Please provide a staffing plan, or complete a listing using the suggested format below of the professional (technical) full-time equivalents (FTE) applied to the radioactive materials program by individual. Include the name, position, and, for Agreement States, the fraction of time spent in the following areas:

administration, materials licensing & compliance, emergency response, low-level 1Estimated burden per response to comply with this voluntary collection request: 53 hours6.134259e-4 days <br />0.0147 hours <br />8.763227e-5 weeks <br />2.01665e-5 months <br />. Forward comments regarding burden estimate to the Records Management Branch (T-5 F52), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, and to the Paperwork Reduction Project (3150-0183), Office of Management and Budget, Washington, DC 20503. If an information collection does not display a currently valid OMB control number, NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

Enclosure

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%

4. Please provide a listing of all new professional personnel hired into your radioactive materials program since the last review, indicate the date of hire; the degree(s) they received, if applicable; additional training; and years of experience in health physics or other disciplines, as appropriate.

5. Please list all professional staff who have not yet met the qualification requirements for a radioactive materials license reviewer or inspector. For each, list the courses or equivalent training/experience they need and a tentative schedule for completion of these requirements.

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

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

8. List any vacant positions in your radioactive materials program, the length of time each position has been vacant, and a brief summary of efforts to fill the vacancy.

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

II. Status of Materials Inspection Program

10. Please identify individual licensees or categories of licensees the State is inspecting less frequently than called for in NRCs Inspection Manual Chapter (IMC) 2800 and explain the reason for the difference. The list only needs to include the following information: license category or licensee name and license number, your inspection interval, and rationale for the difference.

11. Please provide the number of routine inspections of Priority 1, 2, and 3 licensees, as defined in IMC 2800 and the number of initial inspections that were completed during each year of the review period.

12. Please submit a table, or a computer printout, that identifies inspections of Priority 1, 2, and 3 licensees and initial inspections that were conducted overdue.

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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

13. Please submit a table or computer printout that identifies any Priority 1, 2, and 3 licensees and initial inspections that are currently overdue, per IMC 2800. At a minimum, the list should include the same information for each overdue inspection provided for Question 12 plus your action plan for completing the inspection. Also include your plan for completing the overdue inspections.

14. Please provide the number of reciprocity licensees that were candidates for inspection per year as described in IMC 1220 and indicate the number of reciprocity inspections of candidate licensees that were completed each year during the review period.

III. Technical Quality of Inspections

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

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

Inspector Supervisor License Category Date

17. Describe or provide an update on your instrumentation, methods of calibration, and laboratory capabilities. Are all instruments properly calibrated at the present time? Were there sufficient calibrated instruments available throughout the review period?

IV. Technical Quality of Licensing Actions

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

19. Please identify any major, unusual, or complex licenses which were issued, received a major amendment, were terminated, decommissioned, submitted a bankruptcy notification or renewed in this period.

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

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

22. Identify by licensee name and license number any renewal applications that have been pending for one year or more. Please indicate why these reviews have been delayed and describe your action plan to reduce the backlog.

V. Technical Quality of Incident and Allegation Activities

23. For Agreement States, please provide a list of any reportable incidents not previously submitted to NRC (See Procedure SA-300, Reporting Material Events, for additional guidance, OMB clearance number 3150-0178). The list should be in the following format:

Licensee Name License # Date of Incident/Report Type of Incident

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

C. NON-COMMON PERFORMANCE INDICATORS I. Compatibility Requirements

25. Please list all currently effective legislation that affects the radiation control program. Denote any legislation that was enacted or amended during the review period.

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

27. Please review and verify that the information in the enclosed State Regulation Status (SRS) sheet is correct. For those regulations that have not been adopted by the State, explain why they were not adopted, and discuss actions being taken to adopt them. If legally binding requirements were used in lieu of regulations and they have not been reviewed by NRC for compatibility, please describe their use.

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

II. Sealed Source and Device (SS&D) Evaluation Program 4

29. Prepare a table listing new and amended (including transfers to inactive status)

SS&D registrations of sources and devices issued during the review period. The table heading should be:

SS&D Manufacturer, Registry Distributor or Product Type Date Type of Number Custom User or Use Issued Action

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

Technical Staffing and Training - Questions 2-9 Technical Quality of Licensing Actions - Questions 18-22 Technical Quality of Incident and Allegation Activities - Questions 23-24 III. Low-level Radioactive Waste Disposal Program

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

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

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

Technical Staffing and Training - Questions 2-9 Status of Materials Inspection Program - Questions 10-14 Technical Quality of Inspections - Questions 15-17 Technical Quality of Licensing Actions - Questions 18-22 Technical Quality of Incident and Allegation Activities - Questions 23-24 5

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.

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PLEASE HAVE THE FOLLOWING DOCUMENTS AVAILABLE All State regulations Documented training plan, if applicable Statutes affecting the regulatory Records of results of supervisory authority of the State program accompaniments of inspectors Standard license conditions Emergency plan and communications list Technical procedures for licensing, model Procedures for investigating licenses, review guides allegations SS&D review procedures, guides, and Procedures for investigating incidents standards Instrument calibration records Enforcement procedures, including procedures for escalated enforcement, severity levels, civil penalties (as applicable)

Inspection procedures and guides Job descriptions Inspection report forms 7

STATE REGULATION STATUS State: Massachusetts Tracking Ticket Number:

Date:

[ # amendment(s) reviewed identified by a

• at the beginning of the equivalent NRC requirement.]

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1991-1 Safety Requirements for Radiographic 01/10/1994 Final No Comments Massachusetts has adopted Equipment 03/03/1997 Final Regulations equivalent to Part 34 RATS ID: 1997-5.

55 FR 843 (Superceded by 1997-5) 1991-2 ASNT Certification of Radiographers none Not Required Not Required Massachusetts has adopted Part 34 Final Regulations equivalent to 56 FR 11504 RATS ID: 1997-5.

(Superceded by 1997-5) 1991-3 Standards for Protection Against Radiation 01/01/1994 Final No Comments Part 20 03/03/1997 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 03/03/1997 56 FR 64980 1992-1 Quality Management Program and 01/27/1995 Final No Comments Massachusetts has adopted Misadministrations 03/03/1997 Final Regulations equivalent to Part 35 RATS ID: 2002-2.

56 FR 34104 (Superceded by 2002-2)

Enclosure

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1992-2 Eliminating the Recordkeeping Requirements none Not Required Not Required These regulation changes are for Departures from Manufacturer's Instructions not required to be adopted for Parts 30 and 35 purposes of Compatibility.

57 FR 45566 1993-1 Decommissioning Recordkeeping and License 10/25/1996 Final No Comments Termination: Documentation Additions 03/03/1997

[Restricted areas and spill sites]

Parts 30 and 40 58 FR 39628 1993-2 Licensing and Radiation Safety Requirements 07/01/1996 Final No Comments for Irradiators 03/03/1997 Part 36 58 FR 7715 1993-3 Definition of Land Disposal and Waste Site QA 07/22/1996 Final No Comments Program 03/03/1997 Part 61 58 FR 33886 1994-1 Self-Guarantee as an Additional Financial none Final No Comments These regulation changes are Mechanism 03/03/1997 not required to be adopted for Parts 30, 40, and 70 purposes of Compatibility.

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

59 FR 28220 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1994-3 Timeliness in Decommissioning Material 08/15/1997 Final No Comments Facilities ML062980638 11/30/2006 Parts 30, 40, and 70 ML063380019 59 FR 36026 1995-1 Preparation, Transfer for Commercial 01/01/1998 Final No Comments Distribution, and Use of Byproduct Material for 09/21/1999 Medical Use Parts 30, 32, and 35 59 FR 61767; 59 FR 65243; 60 FR 322 1995-2 Frequency of Medical Examinations for Use of 03/13/1998 Final No Comments Respiratory Protection Equipment ML062980638 11/30/2006 Part 20 ML063380019 60 FR 7900 1995-3 Low-Level Waste Shipment Manifest 03/01/1998 Final No Comments Information and Reporting ML062980638 11/30/2006 Parts 20 and 61 ML063380019 60 FR 15649; 60 FR 25983 1995-4 Performance Requirements for Radiography 06/30/1998 Not Required Not Required Massachusetts has adopted Equipment Final Regulations equivalent to Part 34 RATS ID: 1997-5.

60 FR 28323 (Superceded by 1997-5) 3

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1995-5 Radiation Protection Requirements: Amended 08/14/1998 Final No Comments Definitions and Criteria ML062980638 11/30/2006 Parts 19 and 20 ML063380019 60 FR 36038 1995-6 Clarification of Decommissioning Funding 11/24/1998 Final No Comments Requirements ML062980638 11/30/2006 Parts 30, 40, and 70 ML063380019 60 FR 38235 1995-7 Medical Administration of Radiation and 10/20/1998 Final No Comments Massachusetts has not yet Radioactive Materials 09/21/1999 adopted Final Regulations Parts 20 and 35 equivalent to RATS ID: 2005-2.

60 FR 48623 (Superceded by 2002-2 and 2005-2) 1996-1 Compatibility with the International Atomic 04/01/1999 Final No Comments Massachusetts has not yet Energy Agency 09/21/1999 adopted Final Regulations Part 71 equivalent to RATS ID: 2004-1.

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

61 FR 1109 4

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1996-3 Termination or Transfer of Licensed Activities: 06/17/1999 Final No Comments Record keeping Requirements 09/21/1999 Parts 20, 30, 40, 61, and 70 61 FR 24669 1997-1 Resolution of Dual Regulation of Airborne 01/9/2000 Final No Comments Effluents of Radioactive Materials; Clean Air 09/21/1999 Act Part 20 61 FR 65120 1997-2 Recognition of Agreement State Licenses in 02/27/2000 Final No Comments Areas Under Exclusive Federal Jurisdiction ML062980638 11/30/2006 Within an Agreement State ML063380019 Part 150 62 FR 1662 1997-3 Criteria for the Release of Individuals 05/29/2000 Final No Comments Administered Radioactive Material ML062980638 11/30/2006 Parts 20 and 35 ML063380019 62 FR 4120 1997-4 Fissile Material Shipments and Exemptions 02/10/2000 Not Required Not Required These regulation changes are Part 71 not required to be adopted for 62 FR 5907 purposes of Compatibility. (See (Superceded by 2004-1) STP-97-078) 5

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1997-5 Licenses for Industrial Radiography and 06/27/2000 Final No Comments Radiation Safety Requirements for Industrial 09/21/1999 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 ML062980638 11/30/2006 62 FR 39057 ML063380019 1997-7 Exempt Distribution of a Radioactive Drug 01/02/2001 Final No Comments Containing One Microcurie of Carbon-14 Urea 09/21/1999 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 ML062980638 11/30/2006 63 FR 1890; 63 FR 13773 ML063380019 1998-2 Self-Guarantee of Decommissioning Funding 07/01/2001 Not Required Not Required These regulation changes are by Nonprofit and Non-Bond-Issuing Licensees not required to be adopted for Parts 30, 40, and 70 purposes of Compatibility.

63 FR 29535 6

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1998-3 License Term for Medical Use Licenses 07/10/2001 Not Required Not Required These regulation changes are Part 35 not required to be adopted for 63 FR 31604 purposes of Compatibility. (See (Superceded by 2002-2) STP-98-074)

Massachusetts has adopted Final Regulations equivalent to RATS ID: 2002-2.

1998-4 Licenses for Industrial Radiography and 07/09/2001 Final No Comments Radiation Safety Requirements for Industrial ML062980638 11/30/2006 Radiographic Operations ML063380019 Part 34 63 FR 37059 1998-5 Minor Corrections, Clarifying Changes, and a 10/26/2001 Final No Comments Minor Policy Change ML062980638 11/30/2006 Parts 20, 32, 35, 36, and 39 ML063380019 63 FR 39477; 63 FR 45393 1998-6 Transfer for Disposal and Manifests: Minor 11/20/2001 Final No Comments Technical Conforming Amendment ML062980638 11/30/2006 Part 20 ML063380019 63 FR 50127 1999-1 Radiological Criteria for License Termination of 06/11/2002 Not Applicable Not Applicable Massachusetts does not have Uranium Recovery Facilities authority to regulate this material Part 40 under its Agreement.

64 FR 17506 7

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1999-2 Requirements for Those Who Possess Certain 10/04/2002 Not Required Not Required These regulation changes are Industrial Devices Containing Byproduct not required to be adopted for Material to Provide Requested Information purposes of Compatibility.

Part 31 64 FR 42269 1999-3 Respiratory Protection and Controls to Restrict 02/02/2003 Final No Comments Internal Exposure ML062980638 11/30/2006 Part 20 ML063380019 64 FR 54543; 64 FR 55524 2000-1 Energy Compensation Sources for Well 05/17/2003 Final No Comments Logging and Other Regulatory Clarifications ML062980638 11/30/2006 Part 39 ML063380019 65 FR 20337 No Comments 2000-2 New Dosimetry Technology 01/08/2004 Final 11/30/2006 Parts 34, 36, and 39 ML062980638 ML063380019 65 FR 63750 2001-1 Requirements for Certain Generally Licensed 02/16/2004 Final No Comments Industrial Devices Containing Byproduct ML062980638 11/30/2006 Material ML063380019 Parts 30, 31, and 32 65 FR 79162 2002-1 Revision of the Skin Dose Limit 04/05/2005 Final No Comments Part 20 ML062980638 11/30/2006 67 FR 16298 ML063380019 8

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2002-2 Medical Use of Byproduct Material 10/24/2005 Final No Comments Parts 20, 32, and 35 ML062980638 11/30/2006 67 FR 20249 ML063380019 2003-1 Financial Assurance for Materials Licensees 12/03/2006 Final No Comments Parts 30, 40, and 70 ML14007A051 03/06/2014 68 FR 57327 ML140070502004-1 Compatibility With IAEA Transportation Safety 10/01/2007 Final Comments Standards and Other Transportation Safety ML14007A051 03/06/2014 Amendments ML14007050 Part 71 69 FR 3697 Revised Final No Comments (not all 01/16/2015 previous ML14343A367 comments were addressed)

ML14344A254 2005-1 Security Requirements for Portable Gauges 07/11/2008 Final No Comments Containing Byproduct Material ML120860009 05/03/2012 Part 30 ML120960551 70 FR 2001 2005-2 Medical Use of Byproduct Material - 04/29/2008 Final No Comments Recognition of Specialty Boards ML14007A051 03/06/2014 Part 35 ML1400705070 FR 16336; 71 FR 1926 9

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2005-3 Increased Controls for Risk-Significant 12/01/2005 License No Comments Radioactive Sources (NRC Order EA-05-090) Condition 10/04/2005 70 FR 72128 ML080110677 ML052780024 2006-1 Minor Amendments 03/27/2009 Final No Comments Parts 20, 30, 32, 35, 40, and 70 ML14007A051 03/06/2014 71 FR 15005 ML140070502006-2 National Source Tracking System - 02/06/2007 License No Comments Serialization Requirements Condition 02/16/2007 Part 32 with reference to Part 20 Appendix E ML070360500 ML070470063 71 FR 65685 2006-3 National Source Tracking System 01/31/2009 Final No Comments Part 20 ML102850241 11/10/2010 71 FR 65685, 72 FR 59162 ML102990077 License No Comments Condition 10/20/2008 ML082760641 ML082800024 2007-1 Medical Use of Byproduct Material - Minor 10/29/2010 Final No Comments Corrections and Clarifications ML14007A051 03/06/2014 Parts 32 and 35 ML1400705072 FR 45147, 54207 10

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2007-2 Exemptions From Licensing, General Licenses, 12/17/2010 Final Comments and Distribution of Byproduct Material: ML14007A051 03/06/2014 Licensing and Reporting Requirements ML14007050 Parts 30, 31, 32, and 150 72 FR 58473 Revised Final No Comments (not all 01/16/2015 previous ML14343A367 comments were addressed)

ML14344A254 2007-3 Requirements for Expanded Definition of 11/30/2010 Final Comments Byproduct Material ML14007A051 03/06/2014 Parts 20, 30, 31, 32, 33, 35, 61, and 150 ML1400705072 FR 55864 Revised Final No Comments (not all 1/16/2015 previous ML14343A367 comments were addressed)

ML14344A254 11

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2007-4 Order Imposing Fingerprinting Requirements 06/05/2008 License No Comments and Criminal History Records Check Condition 04/14/2008 Requirements for Unescorted Access to ML080800501 ML081050505 Certain Radioactive Material NRC Order EA-07-305 72 FR 70901 2008-1 Occupational Dose Records, Labeling 02/15/2011 Final No Comments Containers, and Total Effective Dose ML120860009 05/03/2012 Equivalent ML120960551 Parts 19 and 20 72 FR 68043 2009-1 Medical Use of Byproduct Material - 09/28/2012 Final No Comments Authorized User Clarification ML14007A051 03/06/2014 Part 35 ML1400705074 FR 33901 2011-1 Decommissioning Planning 12/17/2015 Proposed No Comments Parts 20, 30, 40, and 70 ML16285A473 10/26/2016 76 FR 35512 ML16285A472 Final No Comments ML18264A253 11/02/2018 ML18264A222 12

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2011-2 Licenses, Certifications, and Approvals for 11/14/2014 Proposed No Comments Materials Licensees ML14344A254 01/16/2015 Parts 30, 36, 39, 40, 70, and 150 ML14343A367 76 FR 56951 Final ML16070A231 No Comments 04/11/2016 ML16070A227 2012-1 Change of Compatibility of 10 CFR 31.5 and 01/25/2015 Final No Comments 31.6 ML14007A051 03/06/2014 (See RATS ID: 2001-1 for Rule text) ML1400705077 FR 3640 2012-2 Advance Notification to Native American Tribes 08/10/2015 Proposed Comments of Transportation of Certain Types of Nuclear ML14344A254 1/16/2015 Waste ML14343A367 Part 71 Final 77 FR 34194 ML16070A231 No Comments 04/11/2016 ML160702272012-3 Technical Corrections 08/06/2015 Proposed No Comments Parts 30, 34, 40, and 71 ML14344A254 01/16/2015 77 FR 39899 ML14343A367 Final ML16070A231 No Comments 04/11/2016 ML1607022713

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2012-4 Requirements for Distribution of Byproduct 10/23/2015 Proposed Comments Material ML16285A473 10/26/2016 Parts 30, 31, 32, 40, and 70 ML16285A4777 FR 43666 Final No Comments ML18264A253 11/02/2018 ML18264A222 2013-1 Physical Protection of Byproduct Material, 10 03/19/2016 Proposed No Comments CFR Parts 20, 30, 32, 33, 34, 35, 36, 37, 39, ML15127A416 06/29/2015 and 71 ML15127A375 78 FR 16922 Final ML16070A231 No Comments 04/11/2016 ML16070A227 2013-2 Distribution of Source Material to Exempt 08/27/2016 Proposed Comments Persons and to General Licensees and ML16285A473 10/26/2016 Revision of ML16285A472 General License and Exemptions, Parts 30, 40, and 70 Final No Comments 78 FR 32310 ML18264A253 11/02/2018 ML18264A222 2015-1 Domestic Licensing of Special Nuclear Material 01/26/2018 Final No Comments

- Written Reports and Clarifying Amendments ML16285A473 10/26/2016 Part 70 ML16285A472 79 FR 57721, 80 FR 143 14

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2015-2 Safeguards Information - Modified Handling 01/28/2018 Proposed No Comments Categorization, Change for Materials Facilities ML15127A416 06/29/2015 Parts 30, 37, 73, and 150 ML15127A375 79 FR 58664, 80 FR 3865 Final ML16070A231 No Comments 04/11/2016 ML16070A227 2015-3 Revisions to Transportation Safety 07/13/2018 Proposed Comments Requirements and Harmonization with *extended to ML17059D085 03/28/2017 International Atomic Energy Agency ML17059D084 08/15/2020 Transportation Requirements Part 71 See STC 17- Final Comments 80 FR 33987 060 ML18264A253 11/02/2018 ML18264A222 Final No Comments 2015-4 Miscellaneous Corrections 09/02/2018 ML16070A231 04/11/2016 Parts 37 and 40 ML1607022780 FR 45841 2015-5 Miscellaneous Corrections 12/31/2018 Final No Comments Parts 19, 20, 30, 32, 37, 40, 61, 70, 71, and ML16070A231 04/11/2016 150 ML1607022780 FR 74974 2018-1 Medical Use of Byproduct Material - Medical 01/14/2022 Proposed Comment Event Definitions, Training and Experience, ML20010D538 02/07/2020 and Clarifying Amendments ML20010D439 Parts 30, 32 and 35 15

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2018-2 Miscellaneous Corrections - 12/21/2021 Proposed No Comments Organizational Changes ML20010D538 02/07/2020 Parts 37, 40. 70 and 71 ML20010D439 2018-3 Miscellaneous Corrections 07/30/2022 Proposed No Comments Parts 1, 2, 34, 37, 50, 71, 73, and 140 ML20010D538 02/07/2020 ML20010D439 2019-1 Miscellaneous Corrections 12/18/2022 Proposed No Comments Parts 2, 21, 37, 50, 52, 73, and 110 ML20010D538 02/07/2020 ML20010D439 2019-2 Organizational Changes and Conforming 12/30/2022 Proposed No Comments Amendments ML20010D538 02/07/2020 Parts 1, 2, 37, 40, 50, 51, 52, 55, 71, 72, 73, ML20010D439 74, 100, 140, and 150 2020-1 Individual Monitoring Devices 06/16/2023 10 CFR Parts 34, 36, and 39 2020-2 Social Security Number Fraud Prevention 08/17/2023 10 CFR Parts 9 and 35 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 2021-1 Miscellaneous Corrections 09/08/2024 10 CFR Parts 2, 11, 20, 25, 32, 35, 37, 50, 52,55, 70, 72, 73, 95, and 110 16

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2021-2 Miscellaneous Corrections 12/30/2024 10 CFR Parts 9, 37, 40, 50, 51, 52, 55, 71, 73, and 110 2022-1 Miscellaneous Corrections none Provisions are not required for 10 CFR 1, 2, 20, 30, 40, 50, 55, 70, 73, and compatibility.

170 17