ML19091A134

03/13/2019 NRC Region IV Response to 2019 Impep Questionnaire

ML19091A134
Person / Time
Issue date:	03/13/2019
From:	Browder R S Division of Nuclear Materials Safety IV
To:	Rakovan L J NRC/NMSS/DMSST/FSTB
Rakovan L J
References
Download: ML19091A134 (22)

Text

From: Browder, Rachel To: Rakovan, Lance Cc: Pruett, Troy

Howell, Linda

Subject:

Region IV DNMS Response to the 2019 IMPEP Questionnaire Date: Wednesday, March 13, 2019 4:52:24 PM Attachments:

RIV DNMS 2019 IMPEP Questionnaire Response with Attachments - March 13 2019.pdf Mr. Rakovan, This is in response to your memorandum dated October 16, 2018 (ADAMS Accession ML18289A538) to Mr. Kriss M. Kennedy, RIV Regional Administrator, regarding scheduling the Region IV Integrated Materials Performance Evaluation Program (IMPEP) review and requesting the completion of the IMPEP Questionnaire by March 15, 2019.

Region IV DNMS has completed the IMPEP Questionnaire, which is provided as an attachment to this email. If there are any questions, please do not hesitate to contact me.

We look forward to having you and your team in our offices for the IMPEP review, scheduled April 1-5, 2019.

Sincerely, Rachel Rachel S. Browder, CHP Sr. Health Physicist US NRC, Region IV 1600 East Lamar Blvd.

Arlington, TX 76011-4511 Work: 817-200-1452 Cell: 817-946-4812 Main: 817.860.8100

2019 IM PEP Review Regi on IV DNMS 1 Approved by OMB 1Control No. 3150-0183 Expires 01/31/2020 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE NRC Region IV Materials Program Reporting Period: May 3, 2014 - April 5, 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 tak en in response to each of the open recommendations from previous IMPEPreviews.RESPONSE:Region IV did not have any open recommendations from previous IMPEPreviews. Therefore, there is no response necessary. Region IV DNMS performed several audits during the review period and those audits and th e associated corrective actions will be made available to the IMPEP Team duri ng the review, as requested.

B.COMMON PERFORMANCE INDICATORS I.Technical Staffing and Training 2.Please provide organization charts, including names and positions for Region IVand the Division of Nuclear Materials Safety.RESPONSE:Region IV provided the organization charts in Attachment 1.3.Please provide a staffing plan, or complete a listing using the suggested formatbelow, of the professional (technical) full

-time equivalents (FTE) applied to t he radioactive materials program and uranium recovery program by individual and position.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.

2 RESPONSE: Region IV provided the organization charts in Attachment 1. The internal budget and staffing plan will be made available to the IMPEP Team during the review. 4.Please provide a listing of all new professional personnel hired into yourradioactive materials program and uranium recovery program since the lastreview, 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.RESPONSE:Name Position Hire Date Qualifications Degree Comment IMC Date MATERIALS Allyce Bolger Health Physicist DNMS: 11/26/17 Interim:

1248 App B Feb 2019 BS: Nuclear Engineering, Rensselaer Polytechnic Institute, NY Emergency Response Coordinator Allegation / Enforcement Specialist Reactor Inspector R1: 6/19/11 1245 App C1 May 2013 DECOMMISSIONING Stephanie Anderson Health Physicist DNMS: 7/23/17 1248 App F Aug 2018 BS: Electrical Engineering, Tuskegee University, AL Fire Protection specialty Reactor Inspector R1: 6/19/11 1245 C1 May 2013 1245 C2 May 2016 Austin Roberts Health Physicist DNMS: 11/12/17 1248 App F (In Progress)

BA: Math, Rice University MS: Engineering Management , Old Dominion University Naval Nuclear Power Program Rx Systems Engineer HQ: 1/25/15 Chris Steely Health Physicist DNMS: 10/1/17 1248 A pp F Oct 2018 BS: Nuclear Engineering Technology, Operations specialty 3 Name Position Hire Date Qualifications Degree Comment IMC Date Reactor Inspector R4: 7/20/08 1245, C1 May 2010 Thomas Edison State University, NJ Naval Nuclear Power Program License Examiner 1245 C10 Jan 2010 (Examiner)

Nov 2010 (Chief Examiner) Richard Kaiser Health Physicist DNMS: 12/29/2014 1248 App F On Active Military Duty: 2/3/2015 - 3/17/2016 2/23/2017 - Present BS: Physics , Northwestern State University of Louisiana.

MS: Physics, University of Texas at Arlington 5.Please list all professional staff who have not yet met the qualificati on requirements for a radioactive materials license reviewer, inspector, or uraniumrecovery inspector. For each, list the courses or equivalent training/experienc e they need and a tentative schedule for completion of these requirements.

RESPONSE: Following is a summary of the staff who are in progress of the irqualification requirements.Allyce Bolger started in Region IV DNMS on November 26, 2017. She startedher Manual Chapter 1248, Appendix F, Decommissioning qualification an d changed to Appendix B, Materials Inspector qualification program, based on staffresources in the Division. On February 22, 2019, she obtained her interimqualification under Appendix B, for certain program codes. She lacks severalOJTs for other program code modalities. It is anticipated that once thos e inspections are completed, she'll obtain her full qualification in March 2020.Austin Roberts started Region IV DNMS on November 12, 2017. He startedManual Chapter 1248, Appendix F, Decommissioning qualification. Threetraining courses remain, along with an inspector accompaniment of a complexmaterials facility and some ISA's. Tentative completion of his full qualification isexpected by July 2019.Martha Poston

-Brown has been in the Region IV DNMS office and is qualified asan inspector in multiple areas. Her most recent cross-qualification is IMC 1248,Appendix F, Decommissioning. She plans to perform her OJT at Ft. Cal houn Station (Reactor Decommissioning) in May 2019. Once completed, she'll obtai n her full qualification.

4 Richard Kaiser started in Region IV DNMS on December 29, 2014. He started his Manual Chapter 1248 training; however, he was called to active military duty from 2/3/2015 - 3/17/2016 and again from 2/23/2017

- Present. He was extended for another year starting January 2019. It is unknown when he will return to the office.

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

RESPONSE: Region IV implements the NRC qualification program, which is available under the respective manual chapter on the NRC public website. No action is required by the Region IV office.

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

RESPONSE: Region IV provided the technical staff that left the program in the organization charts in Attachment

1. In addition, a summary is provided below.

Name, Title Date Left DNMS Tony Vegal, Division Director July 27, 2014 Mark Shaffer, Division Director October 14, 2018 Jack Whitten, Branch Chief October 14, 2017 Vivian Campbell, Branch Chief April 28, 2018 Michael Vasquez, Branch Chief January 8, 2018 Mike Hay, Branch Chief October 1, 2018 Ray Kellar, Branch Chief July 2018 Tony Gaines, Sr. HP, Materials Inspector May 30, 2015 Rick Munoz, HP, Materials Inspector January 9, 2016 Pete Hernandez, HP, Materials Inspector in training April 2018 Casey Alldredge, HP, License Reviewer in training October 2016

5 Name, Title Date Left DNMS Gerry Schlapper, HP, Decommissioning March 31, 2017 Don Stearns, HP, Decommissioning April 29, 2017 Bernadette Baca, HP, Uranium Recovery October 1, 2018 Colleen Murnahan, Licensing Assist ant September 26, 2014 Jennifer Bridges, Licensing Assistant March 2017

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.

RESPONSE: Region IV provided the organizational charts in Attachment 1, which captures the vacancies during the review period.

II. Status of Materials Inspection Program

10. Please identify individual licensees or categories of licensees the Region is inspecting less frequently than called for in NRC's Inspection Manual Chapter (IMC) 2800 and for uranium recovery, 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.

RESPONSE: For Materials Program under IMC 2800, Region IV inspects facilities at the frequency described in the manual and has not modified the frequency.

For Uranium Program under IMC 2641 for in

-situ leach facilities, and IMC 2801 for decommissioning uranium sites, Region IV currently inspects at the frequency described in the manual and has implemented a process to document any changes to the inspection frequency. In addition, th e Division is pursuing further clarifications for certain types of facilities described in the manual.

Further specifics are provided below.

Facilities that have licenses but have not started any construction activities, have not been inspected and the IMC 2641 does not specify when pre-operation or initial inspections must be performed. Going forward, the Region IV Divisional office will contact the licensee annually and document the status of the facility in order to determine when to start inspection activities. In addition, feedback form for IMC 2641 will be provided to the Program Office to further clarify this process

.

6 The decision to reschedule or postpone inspections for operating and decommissioning uranium facilities due to the status of licensee activities, weather, Region IV Divisional office staffing and workload, will be documented in an internal Memo approved by management, as specified in each of the IMCs.

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.

RESPONSE: Th e information for materials licensees is available in WBL. No action required by Region IV.

Please see the following summary for Uranium recover y data. The detailed inspection information will be made available during the review. In addition, the master inspection plans (MIPs) generated for each year, will be made available during the IMPEP review

. URANIUM RECOVERY DATA FISCAL YEAR Total number of inspection s Number of overdue reports 2014 (since May 2014) 7 5 2015 7 3 2016 18 0 2017 11 2 2018 14 1 TOTAL 57 11 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

7 RESPONSE: The information for materials licensees is available in WBL. No action required by Region IV.

The summary of Uranium Recovery inspections conducted overdue is available in Attachment

2. 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.

RESPONSE: The information for materials licensees is available in WBL. There are no specific licensees that are overdue for routine inspections based on the criteria under IMC 2800. In addition, there are no overdue field office inspections based solely on the calculation criteria under IMC 2800. However, Region IV is making a concerted effort to inspect permanent field office(s) authorized on licenses, starting with Priority 1s, which have never been inspected. Therefore, these inspections could be considered overdue based on I MC 2800 criteria that "Inspection of various field offices should be rotated to assess the licensee's entire program over several inspection cycles.

" Some of the permanent field offices have not been inspected over several inspection cycles. More detailed information on the proposed permanent field office inspections will be available during the INPEP review, as requested.

The information for each Uranium Recovery license will be made available during the IMPEP review. In addition, a summary of the overdue inspections is provided in Attachment

2. During 2018 and 2019, Region IV made a concerted effort to perform all overdue inspections at operating and decommissioning uranium facilities.

For those facilities that have a license and have not yet started construction activities, the Region IV Divisional office will contact the licensee annually and document the status of the facility in order to determine when to start inspection activities. This activity is being tracked in a Branch Action Item tracker. In addition, the Region has developed a more detailed Master Inspection Plan to track required inspections under the Uranium and Decommissioning programs.

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.

RESPONSE: During the past five calendar years, DNMS has only met the required inspection metric of 20% of reciprocity candidates once, in calendar year 2017, and only then by the then

-Director instructing that a non

-candidate whose inspection 8 resulted in escalated enforcement will be counted towards the 20%. The table below summarizes the Region IV's performance with respect to reciprocity.

CY Total Inspections (Candidates and Attempts) Inspections of Pri-5 Inspections of Candidates Failed Attempted Inspections Total Candidates

% of Candidates (Inspections & Attempts) 2014 4 1 3 1 44 9.0 2015 5 2 5 0 40 12.5 2016 6 1 7* 0 46 13.0 2017 12 5 8 4 37 32.4 2018 thru Oct. 7 2 5 2 36 19.4 2018** 8 2 5 3 41 19.5

• Did not count one of the inspections as a candidate due to previous inspection performed during 2015.

• • Updated data for 2018 after the Audit was completed.

III. Technical Quality of Inspections

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

RESPONSE: Region IV uses the NRC inspection procedures available on the public website. No action required by Region IV.

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

Inspector Supervisor License Category Date RESPONSE: The information for Branch Chief accompaniments of inspectors is available in Attachment

3. In addition, the Region IV Policy Guide s applicable to accompaniments will be made available to the IMPEP Team during the review.

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?

RESPONSE: Region IV maintains an inventory list of instruments available to staff. The Project Manager (Eric Simpson, CHP) for the instrument program has been proactive in ensuring the number and types of instruments are available and calibrated for the nature of radioactive materials encountered in the region to support the reactor, materials, and uranium programs. The inventory list is substantial and will be made available to the IMPEP Team during the review. In 9 addition, the procedures that govern the instrumentation program will also be made available to the IMPEP Team during the review.

IV. Technical Quality of Licensing Actions

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

RESPONSE: Region IV uses WBL to maintain the specific radioactive material licenses. No action required by Region IV. 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.

RESPONSE: Please see the following Table for the actions that Region IV identified as major, unusual, or complex. Please note that Headquarters processes all bankruptcy notifications; therefore, those cases are not provided in the following table.

Action Type Licensee Request License Number Docket Number Control Number Complex (Amendment)

EPA, Region 8 Decommissioning 05-14892-02 030-08754 609555 Complex (Amendment)

University of Alaska , Fairbanks Decommissioning 50-02430-07 030-01179 610951 Complex (New) CH2M Hill , Inc. New License (D&D) 43-35500-01 030-39123 609565 Complex (New) Adanta, Inc.

New License (D&D) Suspended for first time 04-35485-01 030-39106 602775 Complex (New) Adanta, Inc.

New D&D license

Suspended for second time 04-35485-01 030-39135 610270 Complex (Amendment)

Radiation Solutions, LLC other service sources less than or equal to 100 C i 11-35111-01 030-38691 591864 Complex (Amendment)

Dept of the Army, William Beaumont Army Medical Center Medical Broad Scope changing to limited specific 42-05255-07 030-03260 591759 Complex (MML) Hill AFB, US Air Force Decommissioning 42-23539-01AF 030-28641 584307 TAR Acuren USA Instadose 50-32443-01 030-38596 594399 10 Action Type Licensee Request License Number Docket Number Control Number TAR DBI, Inc. Instadose 15-29301-02 030-38754 592504 TAR Core Laboratories, Inc. 10 CFR 20.2002 alternate waste disposal method (ML16020A283) 42-26928-01 030-30429 609095 and 588388 TAR University of Alaska Fairbanks Decommissioning 50-02430-07 030-01179 590694 TAR Providence Alaska HDR 50-17838-01 0 30-13426 609722 20. Discuss any variances in licensing policies and procedures or exemptions from the regulations granted during the review period.

RESPONSE: Region IV Division did not issue any variances in licensing policies and procedures during the review period. The exemptions granted during the review period were under 10 CFR 30.12 exemption requests. Following are the total number of 10 CFR 30.12 exemptions processed in accordance with the guidance provided by the Program Office. Further details are available upon request.

Fiscal Year Total Number of Exemptions Processed FY 2014 10 FY 2015 14 FY 2016 17 FY 2017 35 FY 2018 38 FY 2019 until 1/31/19 13 TOTAL 127 21. What, if any, changes were made in your written licensing procedures (new procedures, updates, policy memoranda, etc.) during the reporting period?

RESPONSE: Region IV utilizes the guidance provided in the NUREG

-1556 series and the information provided on the Materials Licensees Toolkits on the NRC website. 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.

11 RESPONSE: Region IV summarized the renewals that exceeded one year or more in the Table below.

In addition, the Region reviewed and summarized all licensing actions that exceeded the internal processing metric, and will provide the information to the IMPEP Team during the review, as requested.

FY, Action Type Control Number Process Time Licensee License Number Docket Number Reason For Delay FY16, Renewal 585345 454 days Providence Alaska Medical Center 50-17838-01 030-13426 There were a large number of renewals during the year in combination with working groups that contributed to the license reviewer's workload. FY16, Renewal 584286 585 days Calumet Montana Refining 25-27488-01 030-33433 There were a large number of renewals during the year in combination with working groups that contributed to the license reviewer's workload. 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). RESPONSE: Question #23 is not applicable to Region IV.

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

RESPONSE: Region IV made changes to its procedures for responding to incidents and allegations. The procedures are identified below and will be made available to the IMPEP Team during the review.

PG 9007B, "Reactor Inspection and Licensee Event Report (LER) Guidance for DNMS Staff, dated January 3, 2019 PG 9007B, " Handling of Materials Licensee Event Reports (LERs) by DNM S Staff" dated August 26, 2009.

0858.16, "Management of Allegations," January 14, 2015 0858.15, "Management of Allegations," May 26, 2014

12 C. NON-COMMON PERFORMANCE INDICATORS I. Compatibility Requirements (Questions 25

-28) II. Sealed Source and Device (SS&D) Evaluation Program (Questions 29

-30) III. Low-Level Radioactive Waste Disposal Program (Question 31)

RESPONSE: The above indicators and associated Questions 25 through 31 are not applicable to Region IV.

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 RESPONSE: The information regarding the Uranium Recovery program data is provided with the above responses.

13 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. (Located in WBL)

List of licenses terminated during review period.

(Located in WBL)

Copy of current log or other document used to track licensing actions. (Located in WBL)

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

Copy of current log or other document used to track inspections. (Located in WBL)

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

List of inspection frequencies by license type. (Located in WBL and NRC procedures)

List of all allegations occurring during the review period. Show whether the allegation is open or closed and whether it was referred by NRC. (Region to provide)

List of all licenses that your agency has imposed additional security requirements upon. (All licensees with Category II or greater quantities have security requirements consistent with 10 CFR Part 37. No additional information to be provided). ALSO, PLEASE HAVE THE FOLLOWING DOCUMENTS AVAILABLE:

Standard license conditions (WBL) Technical procedures for licensing, model licenses, review guides (NRC website)

SS&D review procedures, guides, and standards (NRC website)

Instrument calibration records (Available as requested in the Regional Office)

Inspection procedures and guides (NRC website) Inspection report forms (NRC website)

Records of results of supervisory accompaniments of inspectors (Available as requested in the Regional Office) Emergency plan and communications list (Region IV will provide Telephone List of staff) Procedures for investigating allegations (NRC website) Procedures for investigating incidents (NRC website and Regional Policy Guide 9007B) Enforcement procedures, including procedures for escalated enforcement, severity levels, civil penalties (as applicable)

(NRC website)

Job description (Position Descriptions are available as requested in the Regional Office)

ATTACHMENT 2 Uranium Recovery Overdue Inspections

RIV DNMS URANIUM RECOVERYInspections Overdue 1Licensee NameLicense NumberDocketFrequency (mos.)Start DateExit Meeting DateReport IssuedReport Time RequirementReport Due DateDays to issue reportReport NumberDate, Last inspection/ license issuanceInspection Due DateDue Date (includes grace period)Inspection Overdue?Days Inspection was Overdue>30 days for Report Issued (or 45 days for Team statement)?>60 days from Onsite Date to Report IssuedPower Resources, Inc. Smith RanchSUA-1548040-08964 605/20/1405/22/1408/01/14 3006/21/14 712014-00109/09/1303/09/1404/09/14YES 41YESYESUranerz Energy Corp. Nichols RanchSUA-1597040-09067 606/23/1406/24/1409/26/14 3007/24/14 942014-00111/18/1305/18/1406/18/14YES 5YESYESUr-Energy USA Lost Creek ISR, LLCSUA-1598040-09068 601/27/1508/20/1509/11/15 4510/04/15 222015-00106/25/1412/25/1401/25/15YES 2 NOYESUranerz Energy Corp. Nichols RanchSUA-1597040-09067 603/17/1503/18/1509/29/15 4505/02/15 1952015-00106/23/1412/23/1401/23/15YES 53YESYESPower Resources, Inc. Smith RanchSUA-1548040-08964 604/14/1504/16/1507/14/15 4505/31/15 892015-00105/20/1411/20/1412/20/14YES 115YESYESUranium One-Willow CreekSUA-1341040-08502 605/27/1507/13/1508/07/15 3008/12/15 252015-00109/23/1403/23/1504/23/15YES 34 NOYESUr-Energy USA Lost Creek ISR, LLCSUA-1598040-09068 612/01/1512/29/1501/07/16 3001/28/16 92015-00201/27/1507/27/1508/27/15YES 96 NO NOUranerz Energy Corp. Nichols RanchSUA-1597040-09067 601/25/1601/28/1602/26/16 4503/13/16 292016-00103/17/1509/17/1510/17/15YES 100 NO NOCameco Crow Butte ResourcesSUA-1534040-08943 1203/08/1603/17/1604/12/16 3004/16/16 262016-00106/03/1406/03/1509/03/15YES 187 NO NOPower Resources, Inc. Smith RanchSUA-1548040-08964 606/21/1610/25/1611/23/16 3011/24/16 292016-00104/14/1510/14/1511/14/15YES 220 NOYESUranium One-Willow CreekSUA-1341040-08502 607/26/1607/28/1608/26/16 3008/27/16 292016-00105/27/1511/27/1512/27/15YES 212 NO NOUNC Church RockSUA-1475040-08907 2408/16/1608/16/1609/07/16 3009/15/16 222016-00107/18/1307/18/1501/18/16YES 211 NO NOKennecott Energy-SweetwaterSUA-1350040-08584 2409/20/1609/20/1610/03/16 3010/20/16 132016-00108/28/1308/28/1502/28/16YES 205 NO NO RIV DNMS URANIUM RECOVERYInspections Overdue 2Licensee NameLicense NumberDocketFrequency (mos.)Start DateExit Meeting DateReport IssuedReport Time RequirementReport Due DateDays to issue reportReport NumberDate, Last inspection/ license issuanceInspection Due DateDue Date (includes grace period)Inspection Overdue?Days Inspection was Overdue>30 days for Report Issued (or 45 days for Team statement)?>60 days from Onsite Date to Report IssuedPathfinder Shirley BasinSUA-442040-06622 2409/21/1609/21/1610/19/16 3010/21/16 282016-00109/25/1309/25/1503/25/16YES 180 NO NOExxonMobil HighlandSUA-1139040-08102 2409/22/1609/22/1610/21/16 3010/22/16 292016-00109/24/1309/24/1503/24/16YES 182 NO NOUr-Energy USA Lost Creek ISR, LLCSUA-1598040-09068 609/27/1611/22/1612/21/16 4501/06/17 292016-00112/01/1506/01/1607/01/16YES 88 NOYESStrata Energy, Inc. RossSUA-1601040-09091 601/31/1702/02/1703/02/17 3003/04/17 282017-00206/07/1612/07/1601/07/17YES 24 NO NOHomestake MiningSUA-1471040-08903 604/24/1706/12/1707/07/17 3007/12/17 252017-00108/24/1602/24/1703/24/17YES 31 NOYESUr-Energy USA Lost Creek ISR, LLCSUA-1598040-09068 605/23/1707/06/1708/04/17 3008/05/17 292017-00109/27/1603/27/1704/27/17YES 26 NOYESCameco Crow Butte ResourcesSUA-1534040-08943 1206/20/1706/22/1707/19/17 3007/22/17 272017-00103/08/1603/08/1706/08/17YES 12 NO NOUr-Energy USA Lost Creek ISR, LLCSUA-1598040-09068 605/22/1805/24/1806/22/18 3006/23/18 292018-00110/17/1704/17/1805/17/18YES 5 NO NOPower Resources, Inc. Smith RanchSUA-1548040-08964 606/25/1806/28/1807/27/18 3007/28/18 292018-00111/14/1705/14/1806/14/18YES 11 NO NOUMETCO - Gas HillsSUA-648040-00299 2408/28/1808/28/1809/21/18 3009/27/18 242018-00106/05/1206/05/1412/05/14YES 1362 NOWestern Nuclear - Split RockSUA-56040-01162 2408/28/1808/28/1809/18/18 3009/27/18 212018-00105/05/1005/05/1211/05/12YES 2122 NOPathfinder Lucky MCSUA-672040-02259 2408/28/1808/28/1809/19/18 3009/27/18 222018-00105/04/1005/04/1211/04/12YES 2123 NO NOAnadarko Bear CreekSUA-1310040-08452 2408/31/1808/31/1809/26/18 3009/30/18 262018-00109/22/0809/22/1003/22/11YES 2719 NO RIV DNMS URANIUM RECOVERYInspections Overdue 3Licensee NameLicense NumberDocketFrequency (mos.)Start DateExit Meeting DateReport IssuedReport Time RequirementReport Due DateDays to issue reportReport NumberDate, Last inspection/ license issuanceInspection Due DateDue Date (includes grace period)Inspection Overdue?Days Inspection was Overdue>30 days for Report Issued (or 45 days for Team statement)?>60 days from Onsite Date to Report IssuedCameco Crow Butte ResourcesSUA-1534040-08943 1211/05/1811/08/1812/06/18 3012/08/18 282018-00106/20/1706/20/1809/20/18YES 46 NO NOANC-Gas Hills SUA-667040-04492 2401/22/1903/01/19 3003/31/1905/02/0705/02/0911/02/09YES 3368n/a NOHydro Resources CrownpointSUA-1580040-08968 1201/00/0001/05/9801/05/9904/05/99n/a NOUranium One- Moore RanchSUA-1596040-09073 1201/00/0009/30/1009/30/1112/30/11n/a NOPowertech Dewey BurdockSUA-1600040-09075 1201/00/0004/08/1404/08/1507/08/15n/a NOAUC Reno CreekSUA-1602040-09092 1201/00/0002/17/1702/17/1805/17/18n/an/a NO ATTACHMENT 3 Branch Chief Accompaniments

BRANCH CHIEF ACCOMPANIMENT FOR INSPECTORSInspector NameBranchCY 2014CY 2015CY 2016CY 2017CY 2018CY 20192020Anderson, Stephanie FCDBPruett-JulyBaca, Bernadette FCDB(In-Training)(In-Training)Kellar-August(Transferred to DRS)Brookhart, Lee FCDBVegel-JanuarySpitzberg-FebruaryKellar-JulyKellar-DecemberKellar-DecemberPruett-MayKatanic-JanuaryBrowder, Rachel FCDBKellar-OctoberKellar-MarchKellar-MayPruett-JulyDykert, JasonMLIBVasquez / SeptemberShaffer - JuneHay / NovemberHay / JanuaryErickson, RandyDNMSShaffer / JuneCampbell - SeptemberThompson / NovemberEvans, Rob FCDBVegel - JanuaryKellar-SeptemberKellar - NovemberKellar-FebruaryNot Performed(Inspected 1/2 year)Katanic-NovemberGaines, TonyMLIBVasquez / SeptemberGersey, Linda FCDBSpitzberg-FebruaryKellar-NovemberNot Performed(Inspected 1/2 year)Kellar-NovemberNot PerformedThompson-FebruaryHammond, MichelleMLIB (Part-time Inspector)Whitten / DecemberWhitten - March(Inspection March '16)Hay / MayHanson, LatischaMLIB (Part-time Inspector)Whitten / AugustWhitten - June(Inspection March '16)Pruett-MayKatanic, JanineMLIBShaffer - MayKellar /SeptemberHay / Nov 2017Pruett-SeptemberMunoz, RickMLIBVasquez / SeptemberVasquez - JunePoston, Marti FCDB(Rotation to ACES)Vasquez - MarchKellar / AugustKellar-AugustHowell-NovemberKatanic-NovemberSchlapper, Gerry FCDBKellar-JuneKellar-JulyWhitten - JulySimmons, MichelleMLIB (Part-time Inspector)Whitten / December 2013 (tracked by FY)Whitten - MarchThompson / DecemberSimpson, Eric FCDBSpitzberg-FebruaryVegel-JanuaryKellar-JulyKellar-December(tracked by FY)Howell - NovemberKellar - DecemberPruett/MayPruett/SeptemberKatanic-JanuarySmith, Chris FCDBPruett/SeptemberKatanic-JanuaryStearns, Don FCDBVasquez / AugustKellar/MarchWhitten - JulySteely, Chris FCDBKatanic-NovemberPruett-OctoberThompson, JamesMLIBVasquez / OctoberShaffer-JanuaryKellar / June Hay / NovemberHay / JulyTorres, RobertoMLIB (Part-time Inspector)Whitten / JuneWhitten - FebruaryWhitten - MarchCampbell / September Page 2 of 2Inspector NameBranchCY 2014CY 2015CY 2016CY 2017CY 2018CY 20192020vonEhr, JasonMLIBShaffer / AprilPruett / JulyNote: PG 1038 specifies that part-time inspectors should be accompanied every 18 months.Note: Grey - means not required