ML23062A725

03-06-2023 Letter to C Coan Re Alabama Impep Scheduling Letter and Questionnaire

ML23062A725
Person / Time
Issue date:	03/06/2023
From:	Ryan Craffey NRC/RGN-III/DRSS/MIB
To:	Coan C State of AL, Dept of Public Health
References
Download: ML23062A725 (27)

Text

March 6, 2023 Cason Coan, Director Office of Radiation Control Alabama Department of Public Health P.O. Box 303017 Montgomery, AL 36130-3017

Dear Cason:

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 Alabama Agreement State Program scheduled for May 22-26, 2023. The review team will include Monica Ford, U.S. NRC Region I; Jason Draper, U.S. NRC Region III; Allyce Bolger, U.S. NRC Region IV; and Joshua Daehler, Commonwealth of Massachusetts.

Enclosed is the Integrated Materials Performance Evaluation Program Questionnaire. The questionnaire was previously provided to you electronically on March 3, 2023. I ask that you provide your responses via e-mail to ryan.craffey@nrc.gov by May 8, 2023. 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 Alabama Agreement State Program on May 26, 2023.

C. Coan 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 630-829-9655.

Sincerely, Signed by Craffey, Ryan on 03/06/23 Ryan Craffey, Senior Health Physicist Materials Inspection Branch Division of Radiological Safety and Security

Enclosure:

2023 IMPEP Questionnaire cc: Jeff Smitherman, Acting Director Office of Radiation Control Alabama Emergency Management Agency Clanton, AL

ML23062A725 letter OFFICE RIII/DRSS NAME RCraffey DATE 03/06/2023 Approved by OMB1 Control No.: 3150-0183 Expires: 02/28/2023 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE Alabama Agreement State Program Review Period: May 24, 2019 - May 22, 2023 Note: If there has been no change in the response to a specific question since the last IMPEP questionnaire, the State or Region may copy the previous answer, if appropriate.

A. GENERAL

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

B. COMMON PERFORMANCE INDICATORS I. Technical Staffing and Training

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

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

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

administration, materials licensing & compliance, emergency response, low-level radioactive waste, uranium recovery, other. If these regulatory responsibilities are divided between offices, the table should be consolidated to include all personnel contributing to the radioactive materials program.

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

Enclosure

If consultants were used to carry out the program's radioactive materials responsibilities, include their efforts. The table heading should be:

Name Position Area of Effort FTE%

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

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

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

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

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

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

II. Status of Materials Inspection Program

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

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

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

At a minimum, the list should include the following information for each inspection that was conducted overdue during the review period:

(1) Licensee Name (2) License Number (3) Priority (IMC 2800)

(4) Last inspection date or license issuance date, if initial inspection (5) Date Due (6) Date Performed 2

(7) Amount of Time Overdue (8) Date inspection findings issued

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

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

III. Technical Quality of Inspections

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

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

Inspector Supervisor License Category Date

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

IV. Technical Quality of Licensing Actions

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

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

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

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

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

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V. Technical Quality of Incident and Allegation Activities

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

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

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

C. NON-COMMON PERFORMANCE INDICATORS I. Compatibility Requirements

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

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

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

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

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

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

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

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

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

Technical Staffing and Training - Questions 2-9 Technical Quality of Licensing Actions - Questions 18-22 Technical Quality of Incident and Allegation Activities - Questions 23-24 4

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, Procedures for investigating model 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: Alabama 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 Letter Package Adoption 1991-1 Safety Requirements for Radiographic Equipment 01/10/1994 Final No Comments Alabama has adopted Final Part 34 04/02/1994 Regulations equivalent to RATS ID 55 FR 843 1997-5 (Superceded by 1997-5) 1991-2 ASNT Certification of Radiographers none Not Required Not Required Alabama 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 11/19/1997 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 04/02/1994 56 FR 64980 1992-1 Quality Management Program and 01/27/1995 Final No Comments Alabama has adopted Final Misadministrations 04/02/1994 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 and 35 of Compatibility 57 FR 45566 Enclosure

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Letter Package Adoption 1993-1 Decommissioning Recordkeeping and License 10/25/1996 Final No Comments Termination: Documentation Additions [Restricted 06/05/1998 areas and spill sites]

Parts 30 and 40 58 FR 39628 1993-2 Licensing and Radiation Safety Requirements for 07/01/1996 Final No Comments Irradiators 06/05/1998 Part 36 58 FR 7715 1993-3 Definition of Land Disposal and Waste Site QA 07/22/1996 Not Applicablei Not Applicable Alabama does not have any Program licensees subject to these Part 61 regulations. (See SECY-95-112) 58 FR 33886 1994-1 Self-Guarantee as an Additional Financial none Final No Comments These regulation changes are not Mechanism 06/05/1998 required to be adopted for purposes Parts 30, 40 and 70 of Compatibility 58 FR 68726; 59 FR 1618 1994-2 Uranium Mill Tailings Regulations: Conforming NRC 07/01/1997 Not Applicable Not Applicable Alabama does not have authority to Requirements to EPA Standards regulate this material under its Part 40 Agreement 59 FR 28220 1994-3 Timeliness in Decommissioning Material Facilities 08/15/1997 Final No Comments Parts 30, 40 and 70 06/05/1998 59 FR 36026 1995-1 Preparation, Transfer for Commercial Distribution, 01/01/1998 Final No Comments and Use of Byproduct Material for Medical Use 06/05/1998 Parts 30, 32 and 35 59 FR 61767; 59 FR 65243; 60 FR 322 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Letter Package Adoption 1995-2 Frequency of Medical Examinations for Use of 03/13/1998 Final No Comments Respiratory Protection Equipment 06/05/1998 Part 20 60 FR 7900 1995-3 Low-Level Waste Shipment Manifest Information 03/01/1998 Final No Comments and Reporting 06/05/1998 Parts 20 and 61 60 FR 15649; 60 FR 25983 1995-4 Performance Requirements for Radiography 06/30/1998 Not Required Not required Alabama has adopted Final Equipment Regulations equivalent to RATS ID Part 34 1997-5 60 FR 28323 (Superceded by 1997-5) 1995-5 Radiation Protection Requirements: Amended 08/14/1998 Final No Comments Definitions and Criteria 06/05/1998 Parts 19 and 20 60 FR 36038 1995-6 Clarification of Decommissioning Funding 11/24/1998 Final No Comments Requirements 06/05/1998 Parts 30, 40 and 70 60 FR 38235 1995-7 Medical Administration of Radiation and Radioactive 10/20/1998 Final No Comments Alabama has adopted Final Materials 08/29/2000 Regulations equivalent to RATS IDs Parts 20 and 35 2002-2 and 2005-2 60 FR 48623 (Superceded by 2002-2 and 2005-2) 3

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Letter Package Adoption 1996-1 Compatibility with the International Atomic Energy 04/01/1999 Final No Comments Alabama has not yet adopted RATS Agency 08/29/2000 ID 2004-1 in final Part 71 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 and 70 of Compatibility 61 FR 1109 1996-3 Termination or Transfer of Licensed Activities: 06/17/1999 Final No Comments Recordkeeping Requirements 08/29/2000 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 08/29/2000 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 08/29/2000 Agreement State Part 150 62 FR 1662 1997-3 Criteria for the Release of Individuals Administered 05/29/2000 Final No Comments Radioactive Material 08/29/2000 Parts 20 and 35 62 FR 4120 4

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Letter Package Adoption 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) 1997-5 Licenses for Industrial Radiography and Radiation 06/27/2000 Final No Comments Safety Requirements for Industrial Radiography 08/29/2000 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 08/29/2000 62 FR 39057 1997-7 Exempt Distribution of a Radioactive Drug 01/02/2001 Final No Comments Containing One Microcurie of Carbon-14 Urea 06/05/1998 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 10/01/2001 63 FR 1890; 63 FR 13773 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-98-074)

(Superceded by 2002-2) Alabama has adopted Final Regulations equivalent to RATS IDs 2002-2 5

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Letter Package Adoption 1998-4 Licenses for Industrial Radiography and Radiation 07/09/2001 Final No Comments Safety Requirements for Industrial Radiographic 08/29/2000 Operations Part 34 63 FR 37059 1998-5 Minor Corrections, Clarifying Changes, and a Minor 10/26/2001 Final No Comments Policy Change 08/29/2000 Parts 20, 32, 35, 36 and 39 63 FR 39477; 63 FR 45393 1998-6 Transfer for Disposal and Manifests: Minor 11/20/2001 Final No Comments Technical Conforming Amendment 08/29/2000 Part 20 63 FR 50127 1999-1 Radiological Criteria for License Termination of 06/11/2002 Not Applicable Not Applicable Alabama does not have authority to Uranium Recovery Facilities regulate this material under its Part 40 Agreement 64 FR 17506 1999-2 Requirements for Those Who Possess Certain 10/04/2002 Not Required Not Required These regulation changes are not Industrial Devices Containing Byproduct Material to required to be adopted for purposes Provide Requested Information of Compatibility Part 31 64 FR 42269 1999-3 Respiratory Protection and Controls to Restrict 02/02/2003 Final No Comments Internal Exposure ML021090092 04/25/2002 Part 20 ML021160517 64 FR 54543; 64 FR 55524 6

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Letter Package Adoption 2000-1 Energy Compensation Sources for Well Logging 05/17/2003 Final No Comments and Other Regulatory Clarifications ML062000076 08/10/2006 Part 39 ML062220014 65 FR 20337 2000-2 New Dosimetry Technology 01/08/2004 Final No Comments Parts 34, 36 and 39 ML062000076 08/10/2006 65 FR 63750 ML062220014 2001-1 Requirements for Certain Generally Licensed 02/16/2004 Final No Comments Industrial Devices Containing Byproduct Material ML062000076 08/10/2006 Parts 30, 31 and 32 ML062220014 65 FR 79162 2002-1 Revision of the Skin Dose Limit 04/05/2005 Final No Comments Part 20 ML052940420 11/08/2005 67 FR 16298 ML053120389 2002-2 Medical Use of Byproduct Material 10/24/2005 Final No Comments Parts 20, 32 and 35 ML062000076 08/10/2006 67 FR 20249 ML062220014 2003-1 Financial Assurance for Materials Licensees 12/03/2006 Final No Comments Parts 30, 40 and 70 ML062000076 08/10/2006 68 FR 57327 ML062220014 2004-1 Compatibility With IAEA Transportation Safety 10/01/2007 Final Comments Standards and Other Transportation Safety ML14293A397 12/16/2014 Amendments ML14290A377 Part 71 69 FR 3697 Revised Final No Comments ML16203A187 08/19/2016 ML16203A174 7

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Letter Package Adoption 2005-1 Security Requirements for Portable Gauges 07/11/2008 Final No Comments Containing Byproduct Material ML13176A135 09/18/2013 Part 30 ML13176A123 70 FR 2001 License Condition Comments ML081960176 07/28/2008 ML082100083 2005-2 Medical Use of Byproduct Material - Recognition of 04/29/2008 Final No Comments Specialty Boards ML062000076 08/10/2006 Part 35 ML062220014 70 FR 16336; 71 FR 1926 2005-3 Increased Controls for Risk-Significant Radioactive 12/01/2005 License Condition No Comments Sources (NRC Order EA-05-090) ML052570218 09/15/2005 70 FR 72128 ML052620319 2006-1 Minor Amendments 03/27/2009 Final Comments Parts 20, 30, 32, 35 40 and 70 ML13176A135 09/18/2013 71 FR 15005 ML13176A123 Revised Final Comments ML21131A090 06/04/2021 ML21131A077 Revised Final No Comments ML21265A515 10/12/2021 ML21265A500 8

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Letter Package Adoption 2006-2 National Source Tracking System - Serialization 02/06/2007 Final Comments Requirements ML13176A135 09/18/2013 Part 32 with reference to Part 20 Appendix E ML13176A123 71 FR 65685 Revised Final No Comments ML21131A090 06/04/2021 ML21131A077 Revised Final No Comments ML21265A515 10/12/2021 ML21265A500 2006-3 National Source Tracking System 01/31/2009 Final No Comments Part 20 ML13176A135 09/18/2013 71 FR 65685, 72 FR 59162 ML13176A123 License Condition No Comments ML082820556 10/21/2008 ML082820596 9

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Letter Package Adoption 2007-1 Medical Use of Byproduct Material - Minor 10/29/2010 Final Comments Corrections and Clarifications ML14293A397 12/16/2014 Parts 32 and 35 ML14290A377 72 FR 45147, 54207 Revised Final Comments ML16203A187 08/19/2016 ML16203A174 Revised Final Comment ML16314E173 12/27/2016 ML16314D996 Revised Final Comment ML18236A301 10/16/2018 ML18236A295 Revised Final No Comments ML19043A789 02/25/2019 ML19043A788 2007-2 Exemptions From Licensing, General Licenses, and 12/17/2010 Final Comments Distribution of Byproduct Material: Licensing and ML14293A397 12/16/2014 Reporting Requirements ML14290A377 Parts 30, 31, 32 and 150 72 FR 58473 Revised Final No Comments ML16203A187 08/19/2016 ML16203A174 10

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Letter Package Adoption 2007-3 Requirements for Expanded Definition of Byproduct 11/30/2010 Final Comments Material ML14293A397 12/16/2014 Parts 20, 30, 31, 32, 33, 35, 61 and 150 ML14290A377 72 FR 55864 Revised Final Comments ML16203A187 08/19/2016 ML16203A174 Revised Final Comments ML16314E173 12/27/2016 ML16314D996 Revised Final Comments ML18236A301 10/16/2018 ML18236A295 Revised Final Comment ML19043A789 02/25/2019 ML19043A788 Revised Final No Comments ML21131A090 06/04/2021 ML21131A077 Revised Final No Comments ML21265A515 10/12/2021 ML21265A500 2007-4 Order Imposing Fingerprinting Requirements and 06/05/2008 License Condition No Comments Criminal History Records Check Requirements for ML081090443 05/01/2008 Unescorted Access to Certain Radioactive Material ML081220314 NRC Order EA-07-305 72 FR 70901 11

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Letter Package Adoption 2008-1 Occupational Dose Records, Labeling Containers, 02/15/2011 Final No Comments and Total Effective Dose Equivalent ML13176A135 09/18/2013 Parts 19 and 20 ML13176A123 72 FR 68043 2009-1 Medical Use of Byproduct Material - Authorized 09/28/2012 Final No Comments User Clarification ML14293A397 12/16/2014 Part 35 ML14290A377 74 FR 33901 2011-1 Decommissioning Planning 12/17/2015 Final No Comments Parts 20, 30, 40 and 70 ML14293A397 12/16/2014 76 FR 35512 ML14290A377 2011-2 Licenses, Certifications, and Approvals for Materials 11/14/2014 Final No Comments Licensees ML15127A281 06/11/2015 Parts 30, 36, 39, 40, 70 and 150 ML15127A276 76 FR 56951 2012-1 Change of Compatibility of 01/25/2015 Final Comments Parts 31.5 and 31.6 ML15127A281 06/11/2015 (See RATS ID: 2001-1 for Rule text) ML15127A276 77 FR 3640 Revised Final No Comments ML16203A187 08/19/2016 ML16203A174 2012-2 Advance Notification to Native American Tribes of 08/10/2015 Final Comments Transportation of Certain Types of Nuclear Waste ML16076A374 04/22/2016 Part 71 ML16076A369 77 FR 34194 Revised Final No Comments ML16203A187 08/19/2016 ML16203A174 12

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Letter Package Adoption 2012-3 Technical Corrections 08/06/2015 Final Comments Parts 30, 34, 40 and 71 ML14293A397 12/16/2014 77 FR 39899 ML14290A377 Revised Final Comments ML16203A187 08/19/2016 ML16203A174 2012-4 Requirements for Distribution of Byproduct Material 10/23/2015 Final Comments Parts 30, 31, 32, 40 and 70 ML14293A397 12/16/2014 77 FR 43666 ML14290A377 Revised Final Comments ML16203A187 08/19/2016 ML16203A174 Revised Final No Comments ML16314E173 12/27/2016 ML16314D996 2013-1 Physical Protection of Byproduct Material 03/19/2016 Proposed Comments Parts 20, 30, 32, 33, 34, 35, 36, 37, 39 and 71 ML15252A268 10/15/2015 78 FR 16922 ML15252A240 Final Comment Comment is regarding 30.13 ML15323A029 12/16/2015 ML15323A030 Revised Final No Comments ML16203A187 08/19/2016 ML16203A174 13

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Letter Package Adoption 2013-2 Distribution of Source Material to Exempt Persons 08/27/2016 Proposed No Comments and to General Licensees and Revision of ML16203A187 08/19/2016 General License and Exemptions ML16203A174 Parts 30, 40 and 70 78 FR 32310 Final Comment ML16314E173 12/27/2016 ML16314D996 Revised Final Comment ML18236A301 10/16/2018 ML18236A295 Revised Final No Comment ML19043A789 02/25/2019 ML19043A788 2015-1 Domestic Licensing of Special Nuclear Material - 01/26/2018 Proposed No Comments Written Reports and Clarifying Amendments ML18052B061 03/16/2018 Part 70 ML18052B059 79 FR 57721, 80 FR 143 2015-2 Safeguards Information - Modified Handling 01/28/2018 Proposed No Comments Categorization, Change for Materials Facilities ML18095A804 4/27/2018 Parts 30, 37, 73 and 150 ML18095A803 79 FR 58664, 80 FR 3865 Final No Comments ML18186A523 07/17/2018 ML18186A519 14

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Letter Package Adoption 2015-3 Revisions to Transportation Safety Requirements 07/13/2018 Proposed Comments and Harmonization with International Atomic Energy *extended to ML18236A301 10/16/2018 Agency Transportation Requirements 08/15/2020 ML18236A295 Part 71 See STC 17-80 FR 33987 060 Final No Comments ML19043A789 02/25/2019 ML19043A788 2015-4 Miscellaneous Corrections, 09/02/2018 Proposed No Comments Parts 37 and 40 ML18236A301 10/16/2018 80 FR 45841 ML18236A295 Final No Comments ML19043A789 02/25/2019 ML19043A788 2015-5 Miscellaneous Corrections, 12/31/2018 Proposed Comments Parts 19, 20, 30, 32, 37, 40, 61, 70, 71 and 150 ML18095A804 4/27/2018 80 FR 74974 ML18095A803 Final Comment ML18186A523 07/17/2018 ML18186A519 2018-1 Medical Use of Byproduct Material - Medical Event 01/14/2022 Proposed Comments Definitions, Training and Experience, and Clarifying ML21131A090 06/04/2021 Amendments, ML21131A077 Parts 30, 32 and 35 Final No Comments ML21265A515 10/12/2021 ML21265A500 15

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Letter Package Adoption 2018-2 Miscellaneous Corrections - 12/21/2021 Proposed No Comments Organizational Changes ML21131A090 06/04/2021 Parts 37, 40, 70 and 71 ML21131A077 Final No Comments ML21265A515 10/12/2021 ML21265A500 2018-3 Miscellaneous Corrections - Organizational 07/30/2022 Proposed No Comments Changes ML21131A090 06/04/2021 Parts 1, 2,34, 37, 50, 71, 73, and 140 ML21131A077 Final No Comments ML21265A515 10/12/2021 ML21265A500 2019-1 Miscellaneous Corrections 12/18/2022 Proposed No Comments Parts 2, 21, 37, 50, 52, 73, and 110 ML21131A090 06/04/2021 ML21131A077 Final No Comments ML21265A515 10/21/2021 ML21265A500 2019-2 Organization Changes and Conforming 12/30/2022 Amendments Parts 1, 2, 37, 40, 50, 51, 52, 55, 71, 72, 73, 74 100, 140, and 150 2020-1 Individual Monitoring Devices 06/16/2023 10 CFR Parts 34, 36, and 39 16

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Letter Package Adoption 2020-2 Social Security Number Fraud Prevention 08/17/2023 Proposed No Comments 10 CFR Parts 9 and 35 ML21131A090 06/04/2021 ML21131A077 Final No Comments ML21265A515 10/21/2021 ML21265A500 2020-3 Miscellaneous Corrections 11/16/2023 Proposed No Comments 10 CFR Parts 1, 2, 19, 20, 21, 30, 34, 35, 40, 50, ML21131A090 06/04/2021 51, 52, 60, 61, 62, 63, 70, 71, 72, 73, 74, 75, 76, ML21131A077 110, and 140 Revised Final No Comments ML21265A515 10/21/2021 ML21265A500 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 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 170 compatibility.

2022-2 Miscellaneous Corrections none Provisions are not required for 10 CFR Parts 20, 35, 50, 51, 52, 72, 73, 110, and compatibility.

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