ML21063A525

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Annual Report on Agreement States and U.S. Nuclear Regulatory Commissions Radioactive Materials Programs for Calendar Year2020
ML21063A525
Person / Time
Issue date: 04/13/2021
From: John Lubinski
NRC/Chairman, NRC/OCM
To: Jeff Baran, Annie Caputo, Christopher Hanson, David Wright
NRC/Chairman, NRC/OCM/AXC, NRC/OCM/DAW, NRC/OCM/JMB
Johnson R
References
Download: ML21063A525 (13)


Text

April 13, 2021 MEMORANDUM TO: Chairman Hanson Commissioner Baran Commissioner Caputo Commissioner Wright Signed by Lubinski, John on 04/13/21 FROM: John W. Lubinski, Director Office of Nuclear Material Safety and Safeguards

SUBJECT:

ANNUAL REPORT ON AGREEMENT STATES AND U.S. NUCLEAR REGULATORY COMMISSIONS RADIOACTIVE MATERIALS PROGRAMS FOR CALENDAR YEAR 2020 Enclosed is the annual report to inform the Commission of the status of the Agreement States and U.S. Nuclear Regulatory Commissions radioactive materials programs. This report was developed in accordance with the June 30, 1997, Staff Requirements Memorandum on SECY-97-054, Final Recommendations on Policy Statement and Implementing Procedures for:

Statement of Principles and Policy for the Agreement State Program and Policy Statement on Adequacy and Compatibility of Agreement State Programs.

Enclosure:

Annual Report on Agreement States and U.S. Nuclear Regulatory Commissions Radioactive Materials Programs for Calendar Year 2020 cc: SECY OGC OCA OPA CFO EDO CONTACT: Robert K. Johnson, NMSS/MSST 301-415-7314

ML21063A525 (WITS199500008)

OFFICE NMSS/MSST NMSS/MSST NMSS/MSST NAME RJohnson ERaphael BAnderson DATE 03/04/21 03/04/21 03/10/21 OFFICE NMSS/MSST NMSS/TechEd NMSS NAME KWilliams WMoore JLubinski DATE 03/16/21 03/19/21 04/13/21 ANNUAL REPORT ON AGREEMENT STATES AND U.S. NUCLEAR REGULATORY COMMISSIONS RADIOACTIVE MATERIALS PROGRAMS FOR CALENDAR YEAR 2020 April 13, 2021 Enclosure

EXECUTIVE

SUMMARY

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

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

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

The NMPs performance, as measured by the IMPEP, has been consistently strong. During Calendar Year (CY) 2020, 35 of the 39 Agreement State programs had an adequacy finding of adequate to protect public health and safety. The four remaining Agreement StatesFlorida, Kansas, Mississippi, and Rhode Island had adequacy findings of adequate to protect public health and safety, but needs improvement. No States had a finding of not adequate to protect public health and safety. All NRC programs (NRC Sealed Source and Device and NRC Regions I, III, and IV materials programs) remained adequate to protect public health and safety. In January 2020, the NRC made the decision to evaluate the NRC materials programs as a single entity under the IMPEP, beginning in 2021. The first consolidated NRC IMPEP review is scheduled to take place in June 2021.

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

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

The CY 2020 IMPEP results demonstrate that the NMP remains protective of public health and safety in regulating the use of radioactive material. Agreement States continue to play a valuable role in the IMPEP, as evidenced by the increase in Agreement State participation and collaboration in the NMP activities. The NRC and its regulatory partners continue to effectively implement the program in a flexible, resilient, and innovative manner to accomplish our mission, despite challenges presented by the ongoing Coronavirus Disease 2019 Public Health Emergency. The NRC staff will continue to monitor performance through the IMPEP and work with the NMP to address any performance issues or trends.

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

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

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

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

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

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

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

The NRC, in collaboration with its Agreement State partners, updated the foundational document for IMPEP, Management Directive 5.6, Integrated Materials Performance Evaluation Program (IMPEP) (Agencywide Documents Access Management System (ADAMS) Accession No. ML19213A024), in July 2019, and subsequently revised 13 State Agreements IMPEP related procedures in September 2020. The revised procedures were implemented in the five IMPEP reviews conducted in Calendar Year (CY) 2020. In January 2020, the MRB Chair also made the determination that the NRC materials programs will be evaluated as a single entity under IMPEP, beginning in Fiscal Year 2021 (ADAMS Accession No. ML19331A856). This change stems from a recommendation from the June 2018 IMPEP self-assessment report entitled Focused Self-Assessment of the Integrated Materials Performance Evaluation Program (IMPEP) (ADAMS Accession No. ML17187A100). Currently, IMPEP assesses NRCs regional materials programs and the Sealed Source & Device Evaluation Program as separate entities.

Evaluating the NRC materials program as a single entity under IMPEP would be consistent with the IMPEP reviews of Agreement States with multiple agencies.

During CY 2020, the NRC and its Agreement State partners conducted five IMPEP reviews with the support of seven Agreement State personnel. The Kentucky IMPEP review and associated inspector accompaniments were conducted in person. Due to travel restrictions associated with the Coronavirus Disease 2019 (COVID-19) Public Health Emergency (PHE),

the Wyoming, Georgia, Virginia, and Kansas IMPEP reviews were conducted remotely.

Inspector accompaniments for all IMPEP reviews were conducted in person. Five Agreement State personnel served as representatives to the five MRB meetings conducted in CY 2020.

During CY 2020, the NRC conducted in-person MRB meetings for the California and Arizona IMPEP reviews, while the MRB meetings for the Kentucky, Wyoming, and Georgia IMPEP reviews were conducted remotely. Due to travel restrictions associated with the COVID-19 PHE, six CY 2020 IMPEP reviews were rescheduled to be conducted in CY 2021. As of the date of this report, three of those six IMPEP reviews have been completed. The three remaining IMPEP reviews are scheduled to be completed in CY 2021.

The NRC staff also developed a Temporary Instruction (TI) 003, Evaluating the Impacts of the COVID-19 Public Health Emergency as Part of the Integrated Materials Performance Evaluation Program (IMPEP) (ADAMS Accession No. ML20188A382), in coordination with the Organization of Agreement States, to provide IMPEP teams with guidance on how to review NMP performance in areas that have been adversely affected by the COVID-19 PHE. The purpose of this TI is to identify areas under IMPEP that could be impacted by the COVID-19 PHE and provide guidance on how to consistently assess performance in these areas.

AGREEMENT STATE PROGRAM PERFORMANCE This section discusses the status of materials programs on heightened oversight or monitoring, and programs that were either adequate, but needs improvement, or not compatible during CY 2020. A brief summary of recent activities related to materials programs on heightened oversight or monitoring is presented in Attachment 1, Heightened Oversight and Monitoring Status Chart.

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Agreement State Programs on Heightened Oversight or Monitoring During CY 2020 During CY 2020, the Kansas and Rhode Island Agreement State Programs were on monitoring and no programs were on heightened oversight. The Kansas Agreement State Program was subsequently removed from monitoring. Based on the results of the October 2020 IMPEP review, the MRB found Kansas to be adequate to protect public health and safety, and compatible with the NRCs regulatory program.

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

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

During CY 2020, the NRC continued conducting quarterly calls to monitor Rhode Islands performance. An IMPEP review was scheduled to be conducted in CY 2020, but was postponed due to travel restrictions associated with the COVID-19 PHE. The next IMPEP review is scheduled to be conducted in CY 2021.

Agreement State Programs that were Adequate, But Needs Improvement during CY 2020 As discussed in the section above, during CY 2020, the Kansas Agreement State Program improved from adequate to protect public health and safety, but needs improvement, to adequate to protect public health and safety and compatible with the NRCs regulatory program.

Also, Rhode Island remains on monitoring and was found to be adequate to protect public health and safety, but needs improvement, and compatible with the NRCs regulatory program following its March 2016 IMPEP review. During CY 2020, the Florida and Mississippi Agreement State Programs had overall program findings of either adequate to protect public health and safety, but needs improvement, or not compatible with the NRCs regulatory program.

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

While there were no IMPEP activities for the Mississippi Agreement State Program (Mississippi) during CY 2020, the program remained adequate to protect public health and safety, but needs improvement, for reporting purposes. Following its April 2017 IMPEP review, Mississippi was found to be adequate to protect public health and safety, but needs improvement, and 3

compatible with the NRCs regulatory program, and placed on monitoring. As a result of the April 2018 Periodic Meeting, the period of monitoring was discontinued based on Mississippis improved performance, including enhancements to staff retention, technical quality of licensing actions, response to incidents and allegations, and the adoption of NRC regulations by reference. The next IMPEP review is scheduled to be conducted in CY 2021.

Agreement State Programs that were Not Compatible during CY 2020 During CY 2020, the Florida and New York Agreement State Programs were not compatible with the NRC regulatory program.

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

While there were no IMPEP activities for New York Agreement State Program (New York) during CY 2020, the program remained not compatible for reporting purposes. Based on the results of the March 2018 IMPEP review, the MRB found New York to be adequate to protect public health and safety, but not compatible with the NRCs regulatory program. Based on New Yorks progress in making performance improvements in the areas of staffing and training and compatibility, the MRB discontinued the period of monitoring. The next IMPEP review is scheduled to be conducted in CY 2022.

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

Performance Indicator Results In CY 2020, the NRC and its Agreement State partners conducted 5 IMPEP reviews, evaluating a total of 32 performance indicators. During CY 2020, 31 of the performance indicators reviewed were found to be satisfactory and one performance indicator was found to be satisfactory, but needs improvement. No performance indicators were found to be unsatisfactory.

During the last 5 years, the NRC and its Agreement State partners have conducted 43 IMPEP reviews, evaluating 274 performance indicators. Based on the most recent IMPEP review results for each of the Agreement States and NRC programs that constitute the NMP, 254 performance indicators evaluated were found to be satisfactory, 17 performance indicators were found to be satisfactory, but needs improvement. Only three of the performance indicators were found to be unsatisfactory.

4 provides a summary of the most recent IMPEP findings and associated adequacy and compatibility results for the NMP. As shown in this attachment, the most challenged performance indicator is the non-common performance indicator Legislation, Regulations, and Other Program Elements. This performance indicator assesses whether Agreement State programs create conflicts, duplications, gaps, or other conditions that jeopardize an orderly pattern in the regulation of radioactive materials under the AEA. While there were six programs with a rating of satisfactory, but needs improvement, in CY 2019 and CY 2020, the number of unsatisfactory ratings dropped from three programs in CY 2019 to two programs in CY 2020.

Adequacy and Compatibility Status in the National Materials Program Over the last 5 years, 93 percent of the NMP (36 Agreement State programs and the 4 NRC programs1) were adequate to protect public health and safety. Regarding compatibility, 95 percent of Agreement State programs were compatible with the NRCs regulatory program.

Table 1 provides a summary of the adequacy and compatibility results for the Agreement States and NRC programs for the last 5 years. The IMPEP results continue to provide evidence that the NMP provides for reasonable assurance of adequate protection of public health and safety.

Table 1. Adequacy and Compatibility Results CY 2016 - CY 2020 2016 2017 2018 2019 2020 National Materials Programs 41 41 42 43 43 (Number of NRC and Agreement State Programs)

Agreement State Programs 37 37 38 39 39 Adequate to Protect Public 38 36 38 39 40 Health and Safety Adequate to Protect Public Health and Safety, But 3 5 4 4 3 Needs Improvement Compatible with the NRCs Regulatory Program 33 34 36 36 37 Not Compatible with the NRCs Regulatory 4 3 2 3 2 Program CONCLUSION The NMP continues to provide reasonable assurance of adequate protection of public health and safety. The IMPEP continues to be an effective tool to verify that NRC and Agreement State programs are evaluated in consistent and integrated manner, that public health and safety is being adequately maintained, and that Agreement State programs are compatible with the NRCs regulatory program. The NRC and its regulatory partners continue to effectively implement the program in a flexible, resilient, and innovative manner to accomplish our mission, despite challenges presented by the ongoing COVID-19 PHE. The Agreement States continue 1 In January 2020, the NRC made the decision to evaluate the NRC materials programs as a single entity under the IMPEP, beginning in 2021.

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to play a valuable role with respect to ensuring consistent implementation of the NMP in protecting the public health and safety with respect to the safe and secure use of radioactive materials.

Attachments:

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

HEIGHTENED OVERSIGHT AND MONITORING STATUS CHART (As of April 13, 2021)

LAST IMPEP LAST NEXT STATE ACTION(S) DUE REVIEW CONTACT CONTACT HEIGHTENED OVERSIGHT None MONITORING Quarterly Call CY 2021 IMPEP CY 2021 IMPEP Rhode Island Mar. 7-10, 2016 Feb. 3, 2021 May 2021 CY 2021 Attachment 1

Summary of National Materials Programs Performance Indicators Findings and Adequacy and Compatibility (As of April 13, 2021)

NON-COMMON OVERALL COMMON CALENDAR YEAR OF LAST FULL PERFORMANCE PROGRAM PERFORMANCE INDICATORS INDICATORS RATING AGREEMENT STATE/NRC Status of Material Inspection Technical Quality of Incident Legislation, Regulations, and Uranium Recovery Program Technical Staffing and Sealed Source and Device NEXT IMPEP REVIEW Technical Quality of Technical Quality of Low-Level Waste COMPATIBILITY ADEQUACY MATERIALS PROGRAM IMPEP REVIEW CONDUCTED Inspections Licensing Actions Disposal Program Training Program and Allegation Activities Evaluation Program Other Program Elements Alabama CY 2019 SAT SAT SAT SAT SAT SAT - - - Adequate1 Compatible2 2023 Arizona CY 2019 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2024 Arkansas CY 2017 SAT SAT SAT SBNI 3,4 SAT SAT - - - Adequate Compatible 2022 California CY 2019 SAT SAT SAT SAT SAT SAT SAT - - Adequate Compatible 2024 Colorado CY 2018 SAT SAT SAT SAT SAT SAT SAT SAT - Adequate Compatible 2022 Not Florida CY 2019 SAT SAT SBNI SAT SAT UNSAT5 SAT - - ABNI6 2023 Compatible7 Georgia CY 2020 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2024 Illinois CY 2018 SAT SAT SAT SAT SAT SAT SAT SAT - Adequate Compatible 2023 Iowa CY 2018 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2022 Kansas CY 2021 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2025 Kentucky CY 2020 SAT SAT SAT SAT SAT SBNI SAT - SAT Adequate Compatible 2024 Louisiana CY 2016 SAT SAT SAT SAT SBNI SAT SAT - - Adequate Compatible 2021 Maine CY 2019 SAT SAT SAT SAT SAT SBNI SAT - - Adequate Compatible 2023 Maryland CY 2015 SAT SAT SAT SAT SAT SAT SAT - - Adequate Compatible 2021 Massachusetts CY 2018 SAT SAT SAT SAT SAT SAT SAT - - Adequate Compatible 2022 Minnesota CY 2016 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2022 Mississippi CY 2017 SAT SAT SAT SBNI SBNI SBNI - - - ABNI Compatible 2021 Nebraska CY 2016 SAT SAT SAT SAT SAT SBNI - - - Adequate Compatible 2021 Nevada CY 2017 SAT SAT SAT SAT SAT SAT - - SAT Adequate Compatible 2021 New Hampshire CY 2016 SAT SAT SAT SAT SAT SAT SAT - - Adequate Compatible 2021 New Jersey CY 2019 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2024 New Mexico CY 2017 SAT SAT SAT SAT SAT SBNI - - - Adequate Compatible 2021 Not New York CY 2018 SBNI SAT SAT SAT SAT UNSAT SAT - SAT Adequate 2022 Compatible North Carolina CY 2018 SAT SAT SAT SAT SAT SAT SBNI - - Adequate Compatible 2022 1 Adequate to protect public health and safety (Adequate).

2 Compatible with NRCs regulatory program (Compatible).

3 Satisfactory, but needs improvement (SBNI).

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

5 Unsatisfactory (UNSAT).

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

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

Attachment 2

NRC and Agreement State Radioactive Materials Programs Findings for Performance Indicators and Adequacy and Compatibility (As of April 13, 2021)

NON-COMMON COMMON OVERALL PERFORMANCE Calendar Year of Last Full IMPEP PERFORMANCE INDICATORS PROGRAM RATING INDICATORS Agreement State/NRC Technical Quality of Incident Legislation, Regulations, and Uranium Recovery Program Sealed Source and Device NEXT IMPEP REVIEW Technical Staffing Status of Material Technical Quality of Technical Quality of Low-Level Waste COMPATIBILITY ADEQUACY Materials Program Review Conducted and Training Inspection Program Inspections Licensing Actions Disposal Program and Allegation Activities Evaluation Program Other Program Elements North Dakota CY 2019 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2024 Ohio CY 2019 SAT SAT SAT SAT SAT SAT SAT - - Adequate Compatible 2024 Oklahoma CY 2018 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2023 Oregon CY 2017 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2021 Pennsylvania CY 2019 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2024 Rhode Island CY 2016 SBNI UNSAT SAT SAT SAT SAT - - - ABNI Compatible 2021 South Carolina CY 2017 SAT SAT SAT SAT SAT SAT SAT - SAT Adequate Compatible 2022 Tennessee CY 2016 SAT SAT SAT SAT SAT SAT SAT - - Adequate Compatible 2021 Texas CY 2018 SAT SAT SAT SBNI SAT SAT SAT SBNI SAT Adequate Compatible 2022 Utah CY 2019 SAT SAT SAT SAT SAT SAT - SAT SAT Adequate Compatible 2023 Vermont 9 - - - - - - - - - Adequate Compatible 2021 Virginia CY 2020 SBNI SAT SAT SAT SAT SAT - - - Adequate Compatible 2024 Washington CY 2018 SAT SAT SAT SBNI SAT SBNI SAT SAT SAT Adequate Compatible 2022 Wisconsin CY 2019 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2024 Wyoming CY 2020 SAT SAT SAT SAT SAT SAT - - - Adequate Compatible 2024 NRC HQ-SSD CY 2014 - - - - - - SAT - - Adequate NA 202110 NRC Region I CY 2015 SAT SAT SAT SAT SAT - - - - Adequate NA 2021 NRC Region III CY 2017 SAT SAT SAT SAT SAT - - - - Adequate NA 2021 NRC Region IV CY 2019 SAT SAT SAT SAT SAT - - SAT - Adequate NA 2021 9 Vermont Agreement signed September 30, 2019, with the first IMPEP review scheduled in 2021.

10 NRCs next IMPEP review will consolidate all headquarters and regional materials programs into a single integrated review scheduled in CY 2021.

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