ML19150A419

05/29/2019 Letter to P. Schmidt Wisconsin Impep Scheduling Letter and Questionnaire for July 2019

ML19150A419
Person / Time
Issue date:	05/29/2019
From:	Randy Erickson Division of Nuclear Materials Safety IV
To:	Schmidt P State of WI, Dept of Health Services
Erickson R
References
OMB1 3150-0183
Download: ML19150A419 (22)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 29, 2019 Paul S. Schmidt, Manager Radiation Protection Section Division of Public Health Wisconsin Department of Health Services P.O. Box 2659 Madison, WI 53701-2659

Dear Mr. Schmidt:

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 Wisconsin Agreement State Program scheduled for July 8-12, 2019. The review team will also include Darren Piccirillo from NRCs Region III Office, Robin Elliott and Michael Reichard from NRCs Region I Office, Stephen Poy from NRCs Office of Nuclear Materials Safety and Safeguards (NMSS), and Leo Bakersmith from the State of Florida.

Enclosed is the Integrated Materials Performance Evaluation Program Questionnaire. The questionnaire was previously provided to Mark Paulson of your staff electronically on February 6, 2019. I ask that you send your responses via e-mail to Randy.Erickson@nrc.gov by June 24, 2019. I previously sent the questionnaire in advance of this IMPEP scheduling letter, to provide time to allocate the staff resources necessary to complete the document by the requested date. I encourage you to use electronic documents and provide them in advance of the review to the extent possible, to allow team members to better prepare for the onsite review.

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 prior to the IMPEP teams arrival.

I request that you set up an appointment with the appropriate state senior managers to discuss the results of the IMPEP review of the Wisconsin Agreement State Program on July 12, 2019.

If you have any questions, please call me at (817) 200-1143.

Sincerely,

/RA/

Randy R. Erickson State Agreements Officer Division of Nuclear Materials Safety

Enclosure:

2019 IMPEP Questionnaire

Distribution: (SP07)

Paul Michalak, NMSS Duncan White, NMSS Robert Johnson, NMSS Lizette Roldan-Otero, NMSS Stephen Poy, NMSS Darren Piccirillo, RIII Robin Elliott, RI Michael Reichard, RI Leo Bakersmith, State of Florida ML19150A419 OFFICE SALB TL NAME KMeyer RErickson DATE 05/29/19 5/29/19 OFFICIAL COPY

Approved by OMB1 Control No. 3150-0183 Expires 01/31/2020 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE Wisconsin Agreement State Program Reporting Period: July 19, 2014 to July 12, 2019 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.

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%

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.

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 (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.

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 III. Low-level Radioactive Waste Disposal Program

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

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

IV. Uranium Recovery Program

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

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

MATERIALS REQUESTED TO BE AVAILABLE FOR THE ON-SITE PORTION OF AN IMPEP REVIEW Please have the following information available for use by the IMPEP review team when they arrive at your office:

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

• List of licenses terminated during review period.

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

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

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

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

• List of inspection frequencies by license type.

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

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

ALSO, PLEASE HAVE THE FOLLOWING DOCUMENTS AVAILABLE:

• All State regulations

• Documented training plan, if applicable

• Statutes affecting the regulatory authority

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

• Standard license conditions

• Emergency plan and communications list

• Technical procedures for licensing,

• Procedures for investigating allegations model licenses, review guides

• Procedures for investigating incidents

• SS&D review procedures, guides, and standards

• Enforcement procedures, including procedures for escalated enforcement,

• Instrument calibration records severity levels, civil penalties (as applicable)

• Inspection procedures and guides

• Job descriptions

• Inspection report forms

STATE REGULATION STATUS State: Wisconsin 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 Not Required Not Required Wisconsin has adopted Final Equipment Regulations equivalent to RATS Part 34 ID: 1997-5.

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

(Superceded by 1997-5) 1991-3 Standards for Protection Against Radiation 01/01/1994 Final 08/01/02 Regulations adopted with the Part 20 package including Wisconsins 56 FR 23360; 56 FR 61352; 57 FR 38588; 57 application to become an FR 57877; 58 FR 67657; 59 FR 41641; 60 FR Agreement State.

20183 1991-4 Notification of Incidents 10/15/1994 Final 08/01/02 Regulations adopted with the Parts 20, 30, 31, 34, 39, 40 and 70 package including Wisconsins 56 FR 64980 application to become an Agreement State.

1992-1 Quality Management Program and 01/27/1995 Final 08/01/02 Wisconsin has adopted Final Misadministrations Regulations equivalent to RATS Part 35 ID: 2002-2.

56 FR 34104 (Superceded by 2002-2)

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 08/01/02 Regulations adopted with the Termination: Documentation Additions package including Wisconsins

[Restricted areas and spill sites] application to become an Parts 30 and 40 Agreement State.

58 FR 39628 1993-2 Licensing and Radiation Safety Requirements 07/01/1996 Final 08/01/02 Regulations adopted with the for Irradiators package including Wisconsins Part 36 application to become an 58 FR 7715 Agreement State.

1993-3 Definition of Land Disposal and Waste Site QA 07/22/1996 Not Applicable Not Applicable Wisconsin does not have Program authority to regulate this material Part 61 under its Agreement.

58 FR 33886 1994-1 Self-Guarantee as an Additional Financial none Not Required Not Required These regulation changes are Mechanism 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 Wisconsin 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 08/01/02 Regulations adopted with the Facilities package including Wisconsins Parts 30, 40 and 70 application to become an 59 FR 36026 Agreement State.

1995-1 Preparation, Transfer for Commercial 01/01/1998 Final 08/01/02 Regulations adopted with the Distribution, and Use of Byproduct Material for package including Wisconsins Medical Use application to become an Parts 30, 32 and 35 Agreement State.

59 FR 61767; 59 FR 65243; 60 FR 322 1995-2 Frequency of Medical Examinations for Use of 03/13/1998 Final 08/01/02 Regulations adopted with the Respiratory Protection Equipment package including Wisconsins Part 20 application to become an 60 FR 7900 Agreement State.

1995-3 Low-Level Waste Shipment Manifest 03/01/1998 Final 08/01/02 Regulations adopted with the Information and Reporting package including Wisconsins Parts 20 and 61 application to become an 60 FR 15649; 60 FR 25983 Agreement State.

1995-4 Performance Requirements for Radiography 06/30/1998 Not Required Not Required Wisconsin has adopted Final Equipment Regulations equivalent to RATS Part 34 ID: 1997-5.

60 FR 28323 (Superceded by 1997-5) 1995-5 Radiation Protection Requirements: Amended 08/14/1998 Final 08/01/02 Regulations adopted with the Definitions and Criteria package including Wisconsins Parts 19 and 20 application to become an 60 FR 36038 Agreement State.

3

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1995-6 Clarification of Decommissioning Funding 11/24/1998 Final 08/01/02 Regulations adopted with the Requirements package including Wisconsins Parts 30, 40 and 70 application to become an 60 FR 38235 Agreement State.

1995-7 Medical Administration of Radiation and 10/20/1998 Final 08/01/02 Wisconsin has adopted Final Radioactive Materials Regulations equivalent to RATS Parts 20 and 35 IDs: 2002-2 and 2005-2.

60 FR 48623 (Superceded by 2002-2 and 2005-2) 1996-1 Compatibility with the International Atomic 04/01/1999 Final 08/01/02 Wisconsin has adopted Final Energy Agency Regulations equivalent to RATS Part 71 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 1996-3 Termination or Transfer of Licensed Activities: 06/17/1999 Final 08/01/02 Regulations adopted with the Record keeping Requirements package including Wisconsins Parts 20, 30, 40, 61 and70 application to become an 61 FR 24669 Agreement State.

1997-1 Resolution of Dual Regulation of Airborne 01/9/2000 Final 08/01/02 Regulations adopted with the Effluents of Radioactive Materials; Clean Air package including Wisconsins Act application to become an Part 20 Agreement State.

61 FR 65120 4

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1997-2 Recognition of Agreement State Licenses in 02/27/2000 Final 08/01/02 Regulations adopted with the Areas Under Exclusive Federal Jurisdiction package including Wisconsins Within an Agreement State application to become an Part 150 Agreement State.

62 FR 1662 1997-3 Criteria for the Release of Individuals 05/29/2000 Final 08/01/02 Regulations adopted with the Administered Radioactive Material package including Wisconsins Parts 20 and 35 application to become an 62 FR 4120 Agreement State.

1997-4 Fissile Material Shipments and Exemptions 02/10/2000 Final 08/01/02 Wisconsin has adopted Final Part 71 Regulations equivalent to RATS 62 FR 5907 ID: 2004-1. (See STP-97-078)

(Superceded by 2004-1) 1997-5 Licenses for Industrial Radiography and 06/27/2000 Final 08/01/02 Regulations adopted with the Radiation Safety Requirements for Industrial package including Wisconsins Radiography Operations application to become an Parts 30, 34, 71 and 150 Agreement State.

62 FR 28947 1997-6 Radiological Criteria for License Termination 08/20/2000 Final 08/01/02 Regulations adopted with the Parts 20, 30, 40 and 70 package including Wisconsins 62 FR 39057 application to become an Agreement State.

1997-7 Exempt Distribution of a Radioactive Drug 01/02/2001 Final 08/01/02 Regulations adopted with the Containing One Micro curie of Carbon-14 Urea package including Wisconsins Part 30 application to become an 62 FR 63634 Agreement State.

5

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1998-1 Deliberate Misconduct by Unlicensed Persons 02/12/2001 Final 08/01/02 Regulations adopted with the Parts 30, 40, 61, 70, 71 and 150 package including Wisconsins 63 FR 1890; 63 FR 13773 application to become an Agreement State.

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 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)

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

1998-4 Licenses for Industrial Radiography and 07/09/2001 Final 08/01/02 Regulations adopted with the Radiation Safety Requirements for Industrial package including Wisconsins Radiographic Operations application to become an Part 34 Agreement State.

63 FR 37059 1998-5 Minor Corrections, Clarifying Changes, and a 10/26/2001 Final 08/01/02 Regulations adopted with the Minor Policy Change package including Wisconsins Parts 20, 32, 35, 36 and 39 application to become an 63 FR 39477; 63 FR 45393 Agreement State.

1998-6 Transfer for Disposal and Manifests: Minor 11/20/2001 Final 08/01/02 Regulations adopted with the Technical Conforming Amendment package including Wisconsins Part 20 application to become an 63 FR 50127 Agreement State.

6

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1999-1 Radiological Criteria for License Termination of 06/11/2002 Not Applicable Not Applicable Wisconsin does not have Uranium Recovery Facilities authority to regulate this material Part 40 under its Agreement.

64 FR 17506 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 08/01/02 Regulations adopted with the Internal Exposure package including Wisconsins Part 20 application to become an 64 FR 54543; 64 FR 55524 Agreement State.

2000-1 Energy Compensation Sources for Well 05/17/2003 Final 08/01/02 Regulations adopted with the Logging and Other Regulatory Clarifications package including Wisconsins Part 39 application to become an 65 FR 20337 Agreement State.

2000-2 New Dosimetry Technology 01/08/2004 Final 08/01/02 Regulations adopted with the Parts 34, 36 and 39 package including Wisconsins 65 FR 63750 application to become an Agreement State.

2001-1 Requirements for Certain Generally Licensed 02/16/2004 Final No Comments Industrial Devices Containing Byproduct ML101400048 07/14/2010 Material ML101580437 Parts 30, 31 and 32 65 FR 79162 7

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2002-1 Revision of the Skin Dose Limit 04/05/2005 Final No Comments Part 20 ML063120323 01/09/2007 67 FR 16298 ML070090076 2002-2 Medical Use of Byproduct Material 10/24/2005 Final No Comments Parts 20, 32 and 35 ML070530037 03/13/2007 67 FR 20249 ML070720431 2003-1 Financial Assurance for Materials Licensees 12/03/2006 Final No Comments Parts 30, 40 and 70 ML063120323 01/09/2007 68 FR 57327 ML070090076 2004-1 Compatibility With IAEA Transportation Safety 10/01/2007 Final No Comments Standards and Other Transportation Safety ML101400048 07/14/2010 Amendments ML101580437 Part 71 69 FR 3697 2005-1 Security Requirements for Portable Gauges 07/11/2008 Final No Comments Containing Byproduct Material ML063120323 01/09/2007 Part 30 ML070090076 70 FR 2001 2005-2 Medical Use of Byproduct Material - 04/29/2008 Final No Comments Recognition of Specialty Boards ML101400048 07/14/2010 Part 35 ML101580437 70 FR 16336; 71 FR 1926 License Condition No Comments 2005-3 Increased Controls for Risk-Significant 12/01/2005 ML052560315 09/14/2005 Radioactive Sources (NRC Order EA-05-090) ML052580010 70 FR 72128 8

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2006-1 Minor Amendments 03/27/2009 Final No Comments Parts 20, 30, 32, 35, 40 and 70 ML101400048 07/14/2010 71 FR 15005 ML101580437 2006-2 National Source Tracking System - 02/06/2007 Final No Comments Serialization Requirements ML101400048 07/14/2010 Part 32 with reference to Part 20 Appendix E ML101580437 71 FR 65685 2006-3 National Source Tracking System 01/31/2009 Final No Comments Part 20 ML101400048 07/14/2010 71 FR 65685, 72 FR 59162 ML101580437 License Condition No Comments ML082600587 09/29/2008 ML082620071 2007-1 Medical Use of Byproduct Material - Minor 10/29/2010 Final No Comments Corrections and Clarifications ML101400048 07/14/2010 Parts 32 and 35 ML101580437 72 FR 45147, 54207 2007-2 Exemptions From Licensing, General Licenses, 12/17/2010 Final No Comments and Distribution of Byproduct Material: ML101400048 07/14/2010 Licensing and Reporting Requirements ML101580437 Parts 30, 31, 32 and 150 72 FR 58473 2007-3 Requirements for Expanded Definition of 11/30/2010 Final No Comments Byproduct Material ML101400048 07/14/2010 Parts 20, 30, 31, 32, 33, 35, 61 and 150 ML101580437 72 FR 55864 9

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 Condition No Comments and Criminal History Records Check ML081080577 05/02/2008 Requirements for Unescorted Access to ML081230699 ML081221031 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 ML101400048 07/14/2010 Equivalent ML101580437 Parts 19 and 20 72 FR 68043 2009-1 Medical Use of Byproduct Material - 09/28/2012 Final Comments Authorized User Clarification ML101400048 07/14/2010 Part 35 ML101580437 74 FR 33901 Revised Final No Comments ML16357A322 02/14/2017 ML16357A306 2011-1 Decommissioning Planning 12/17/2015 Proposed No Comments Parts 20, 30, 40 and 70 ML16357A322 02/14/2017 76 FR 35512 ML16357A306 Final No Comments ML18262A221 11/08/2018 ML18262A201 10

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 ML16357A322 02/14/2017 Parts 30, 36, 39, 40, 70 and 150 ML16357A306 76 FR 56951 Final No Comments ML18262A221 11/08/2018 ML18262A201 2012-1 Change of Compatibility of 10 CFR 31.5 and 01/25/2015 Proposed No Comments 31.6 ML16357A322 02/14/2017 (See RATS ID: 2001-1 for Rule text) ML16357A306 77 FR 3640 Final No Comments ML18262A221 11/08/2018 ML18262A201 2012-2 Advance Notification to Native American Tribes 08/10/2015 Proposed Comments of Transportation of Certain Types of Nuclear ML16358A462 01/27/2017 Waste ML16358A452 Part 71 77 FR 34194 Final No Comments ML18262A221 11/08/2018 ML18262A201 2012-3 Technical Corrections 08/06/2015 Proposed Comments Parts 30, 34, 40 and 71 ML16358A462 01/27/2017 77 FR 39899 ML16358A452 Final No Comments ML18262A221 11/08/2018 ML18262A201 11

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 ML16358A462 01/27/2017 Parts 30, 31, 32, 40 and 70 ML16358A452 77 FR 43666 Final No Comments ML18262A221 11/08/2018 ML18262A201 2013-1 Physical Protection of Byproduct Material, 03/19/2016 License Condition No Comments Parts 20, 30, 32, 33, 34, 35, 36, 37, 39 and 71 ML14028A018 02/20/2014 78 FR 16922 ML14028A016 Proposed Comments ML16358A568 02/02/2017 ML16358A451 Final No Comments ML18262A221 11/08/2018 ML18262A201 12

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2013-2 Distribution of Source Material to Exempt 08/27/2016 License Condition Comments Persons and to General Licensees and ML16153A311 6/27/2016 Revision of General License and Exemptions, ML16153A228 Parts 30, 40 and 70 78 FR 32310 Revised License No Comments Condition 08/15/2016 ML16221A414 ML16222A345 Proposed Comments ML16358A462 01/27/2017 ML16358A452 Final No Comments ML18262A221 11/08/2018 ML18262A201 2015-1 Domestic Licensing of Special Nuclear Material 01/26/2018 Proposed No Comments

- Written Reports and Clarifying Amendments ML16358A568 02/02/2017 Part 70 ML16358A451 79 FR 57721, 80 FR 143 2015-2 Safeguards Information - Modified Handling 01/28/2018 Proposed No Comments Categorization, Change for Materials Facilities ML16358A568 02/02/2017 Parts 30, 37, 73 and 150 ML16358A451 79 FR 58664, 80 FR 3865 2015-3 Revisions to Transportation Safety 07/13/2018 Proposed Comments Requirements and Harmonization with *extended to ML16358A462 01/27/2017 International Atomic Energy Agency 08/15/2020 ML16358A452 Transportation Requirements See STC 17-Part 71 060 Final No Comments 80 FR 33987 ML18262A221 11/08/2018 ML18262A201 13

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2015-4 Miscellaneous Corrections, 09/02/2018 Proposed No Comments Parts 37 and 40 ML16358A568 02/02/2017 80 FR 45841 ML16358A451 Final No Comments ML18262A221 11/08/2018 ML18262A201 2015-5 Miscellaneous Corrections, 12/31/2018 Proposed Comments Parts 19, 20, 30, 32, 37, 40, 61, 70, 71 and 150 ML16358A568 02/02/2017 80 FR 74974 ML16358A451 Final No Comments ML18262A221 11/08/2018 ML18262A201 2018-1 Medical Use of Byproduct Material - Medical 01/14/2022 Event Definitions, Training and Experience, and Clarifying Amendments, 10 CFR Parts 30, 32 and 35 2018-2 Miscellaneous Corrections - 12/21/2021 Organizational Changes 10 CFR Parts 37, 40. 70 and 71

• 1 R Means proposed revisions to a final rule 14