Frequently Asked Questions About NRC Reciprocity
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What is reciprocity?
Reciprocity is the NRC recognition of applicable Agreement State licenses for work performed in areas of NRC jurisdiction. This term is also used in Agreement States with regard to Agreement State recognition of NRC licenses, as well as licenses from other Agreement States, for work performed within their jurisdiction.
Activities conducted by Agreement State licensees in non-Agreement States, areas of exclusive Federal jurisdiction, and offshore waters, must meet the general license provisions of Title 10 of the Code of Federal Regulations (10 CFR) 150.20, “Recognition of Agreement State Licenses.” The NRC has published Guidance for Agreement State Licensees About NRC Form 241 "Report of Proposed Activities in Non-Agreement States, Areas of Exclusive Federal Jurisdiction, or Offshore Waters" and Guidance for NRC Licensees Proposing to Work in Agreement State Jurisdiction (Reciprocity) in NUREG 1556, Volume 19.
Some NRC licenses, such as radiographers, well loggers, and portable gauge users, may authorize use of radioactive material at temporary jobsites. However, this authorization does not permit operations in Agreement State jurisdiction (except for licensees who are Federal agencies). Licensees working in another jurisdiction under reciprocity are subject to the regulations for that jurisdiction.
How do I know if I need to request reciprocity from the NRC?
If you are an Agreement State licensee and plan to conduct licensed activities in non-Agreement States, areas of exclusive Federal jurisdiction, or offshore waters, then you must request reciprocity from the NRC. Reciprocity is not required when licensed material is in transport. However, if licensed material is stored or used in NRC jurisdiction then reciprocity is required.
If the work location is in an Agreement State and is not an area of exclusive Federal jurisdiction nor within the protected or controlled access area of an NRC licensed facility, these activities are regulated by the Agreement State Radiation Control Program Office, not by the NRC. Each Agreement State has its own regulations that allow reciprocity activities within its State. Please see Agreement State contacts.
If I have a license for radioactive materials from an Agreement State, can I do work in Federal jurisdictions?
Agreement State licensees can conduct licensed operations in areas of exclusive Federal jurisdiction by either (i) filing NRC Form 241 for reciprocity, in accordance with 10 CFR 150.20(b), or (ii) obtaining a specific NRC license. Information about the specific NRC requirements for particular uses of licensed materials may be found in the applicable volume of the NUREG–1556 series or other appropriate guidance documents.
Is there a fee for obtaining reciprocity? How do I pay?
Reciprocity fees are based on work activities within a calendar year. Submission of an initial the U.S. Nuclear Regulatory Commission (NRC) Form 241 must be accompanied by the appropriate fee. Agreement State licensees should refer to Category 16 of Title 10 of the Code of Federal Regulations (10 CFR) 170.31, “Schedule of fees for materials licenses and other regulatory services, including inspections, and import and export licenses,” to determine the amount of the initial fee. No fee is required for changes to add or remove work/storage days and locations during the same calendar year.
Pay.gov is a secure method for making a fee payment electrically through credit card or ACH withdrawal. Please submit a copy of the Pay.gov confirmation along with the NRC Form 241 and Agreement State license. Alternatively, payment of fees can be completed by physical check or credit card. If paying by check, please send it to the respective NRC regional office and provide a copy of the check with the NRC Form 241 and Agreement State license. If using credit card, please use NRC Form 629.
How long does reciprocity approval last?
Activities conducted under the general license granted by 10 CFR 150.20 are limited to 180 days in any calendar year. An exception to this limit is that activities in offshore waters may be conducted for an unlimited period of time in the same calendar year. Throughout the year, Agreement State licensees should track work activities and storage of licensed material in NRC jurisdiction to ensure that they do not exceed the 180-day limit.
How do I know how many days I have left to work under reciprocity?
The NRC tracks reciprocity approved usage days. The NRC will not authorize any request which causes the total usage days to exceed 180 days in the same calendar year as the reciprocity application was made, except for work conducted in offshore waters. The NRC will notify the licensee when a filing proposes reciprocity activities which approach or would exceed the 180-day limit. It is important that licensees track the days of use so that they do not exceed the 180-day limit.
How do I apply for NRC approval of reciprocity?
Agreement State licensees requesting reciprocity should do the following:
- Complete the NRC Form 241 Items 1 through 20. Please see a link to the form.
- If additional space is needed to complete NRC Form 241, provide information in Items 8 through 18 on supplementary pages.
- For each separate sheet that is submitted with NRC Form 241, identify and cross-reference submitted information to the item number on the form or the topic to which it refers.
- Submit all supplementary pages on 8½ × 11-inch paper.
- At least 3 calendar days before beginning activities, file an original NRC Form 241, one copy of the licensee’s current Agreement State license, and the appropriate fee with the appropriate NRC regional office where the Agreement State licensee is located, not where they intend to perform work.
- Retain one copy of NRC Form 241 for future reference.
- Submit an application by direct mail, facsimile or email to the electronic mailbox submitted by each office, if available.
How long in advance do I need to apply before scheduled work under reciprocity?
NRC Form 241 shall be filed at least 3 calendar days before engaging in the proposed activity for the first time in a calendar year.
If a submittal cannot be filed 3 calendar days before the proposed activity because of an unusual circumstance, such as an emergency, the Regional Administrator may waive the 3-day time requirement, provided that the remaining provisions of 10 CFR 150.20(b)(1) are satisfied. Emergency requests should be directed to the appropriate regional office by telephone before initiation of the activity and will be reviewed on a case-by-case basis.
Where do I send an application for NRC reciprocity?
Reciprocity applications shall be sent to the appropriate regional office.
For Region I reciprocity requests, send the application and fee payment to R1Reciprocity.Resource@nrc.gov or to the address listed below.
Regional Administrator
Division of Radiological Safety and Security
ATTN: Reciprocity Request
U.S. NRC Region I
475 Allendale Rd., Suite 102
King of Prussia, PA 19406-1415
Telephone Number 610-337-5000
Toll Free: 1-800-432-1156
Facsimile Number 610-337-5349
For Region III reciprocity requests, send the application and fee payment to R3.Reciprocity@nrc.gov or to the address listed below.
Regional Administrator
Division of Radiological Safety and Security
ATTN: Reciprocity Request
U.S. NRC Region III
2443 Warrenville Road
Suite 210
Lisle, Illinois 60532-4352
Telephone Number 630-829-9500
Facsimile Number 630-515-1078
For Region IV reciprocity requests, send the application and fee payment to R4_Reciprocity.Resource@nrc.gov or to the address listed below.
Regional Administrator
Division of Radiological Safety and Security
ATTN: Reciprocity Request
U.S. Nuclear Regulatory Commission, Region IV
1600 E. Lamar Boulevard
Arlington, TX 76011-412
Telephone Number (817) 200-1100
Facsimile Number (817) 200-1188
What counts as a day under reciprocity rules?
Under the general license, reciprocity activities, including work and storage, conducted in non-Agreement States and areas of exclusive Federal jurisdiction are limited to a total of 180 days in any calendar year except for work conducted in offshore waters, which is authorized for an unlimited period of time in a calendar year.
A “calendar day of use” is one on which you store or use licensed material in NRC jurisdiction. Licensed activities conducted on the same day at different locations within NRC jurisdiction count as one calendar day of use.
The NRC tracks reciprocity usage on the basis of approved usage days. If fewer days than requested are actually used, a licensee may submit a change using the Form 241 to correct the record. The NRC will not authorize any request which causes the total usage days to exceed 180 days, except for work conducted in offshore waters. The NRC will notify the licensee that a filing proposes reciprocity activities which approach or would exceed the 180-day limit. It is important that licensees track the days of use and clarify or delete dates of work when applicable.
On NRC Form 241, Item 13 should reflect the proposed beginning and ending dates of work for each work location and indicate if work or storage will be performed on weekends, with the total number of days worked recorded in Item 14. Item 15 should be completed to show additional work dates different from those provided on the initial NRC Form 241 and Item 16 should indicate dates when work/storage was not performed, as initially requested, that need to be deleted from the total work/storage days.
Do Agreement States offer reciprocity for NRC licensees? Who should I contact in an Agreement State to ask about reciprocity?
Agreement States have reciprocity provisions that permit NRC licensees to perform work using NRC-licensed radioactive materials in their States. To ensure compliance with the Agreement State’s reciprocity requirements, licensees are advised to request authorization from the appropriate regulatory authority well in advance of the scheduled use of licensed material. Please see a current list of Agreement States (including names, addresses, and telephone numbers of responsible officials).
How is offshore work handled under reciprocity?
Agreement State licensees who wish to conduct licensed activities in offshore waters should contact NRC regional office for the Agreement State that issued their license.
Agreement State licensees who wish to conduct licensed activities in a non-Agreement State, in an area of exclusive Federal jurisdiction within an Agreement State, or in offshore waters should contact NRC regional office for the Agreement State that issued their license.
Section 2.7 of NUREG-1556 Volume 19, Rev. 1. discusses information pertinent to the mechanics of reciprocity in offshore waters.
If I have a contract for licensed work in NRC jurisdiction that lasts longer than 180 days, what are my options?
A licensee conducting reciprocity activities is limited to a total of 180 days in the same calendar year as a reciprocity application is made. Reciprocity activities conducted in offshore waters are not subject to the 180‑day limit. The NRC tracks reciprocity usage on the basis of approved usage days. The NRC will not authorize any request that would exceed the 180‑day limit. It is important that you track the days of use and submit changes to dates of work, when applicable. Storage of material in NRC jurisdiction is considered a reciprocity activity; days when material is stored in NRC jurisdiction count toward the 180‑day limit.
How do I find out if a state is an Agreement State or federal jurisdiction?
Please see a current list of Agreement States (including names, addresses, and telephone numbers of responsible officials). Federal jurisdiction would include an area over which the Federal government exercises legal control, without interference from the jurisdiction and administration of State law.
If I need to perform licensed work at a federal property or a military base in an Agreement State, do I need to apply for reciprocity?
If the license is not issued by the NRC and work is being performed at a federal property or a military base, the licensee will need to file for reciprocity with the NRC. Agreement State licensees cannot conduct licensed activities in areas of exclusive Federal jurisdiction without either (i) filing NRC Form 241 for reciprocity, in accordance with 10 CFR 150.20(b), or (ii) obtaining a specific NRC license. Information about the specific NRC requirements for particular uses of licensed materials may be found in the applicable volume of the NUREG–1556 series or other appropriate guidance documents.
Some areas on military bases may not be exclusive federal jurisdiction. To be sure, contact the base contracting or legal group to ask the jurisdiction of the planned work/storage location. In some cases, more than one jurisdiction may exist. You must have a license or reciprocity for each jurisdiction involved.
Can my Agreement State license prevent me from getting NRC reciprocity?
Reciprocity requires licensees maintain an active license with the Agreement State that issued the license. Also, your Agreement State license must authorize work at temporary jobsites and the licensed activities to be performed under reciprocity must be allowed under the Agreement State license.
Does the NRC conduct inspections of work being done under reciprocity in NRC jurisdiction?
Yes, the NRC may conduct inspections while a licensee is working under reciprocity in NRC jurisdiction.
If I was approved under NRC reciprocity to work more days than I actually worked, can I get those days back to use them later?
The NRC tracks reciprocity usage based on approved usage days. To remove days that were not used, submit a change using the Form 241. When submitting a change, if the dates specified in Item 13 (“Dates Scheduled”) are to be deleted for a specified work location, indicate in this field the number of deleted days. You may provide a list of deleted work/storage days.
If I want to add days of work in the same or different location, what is the process to inform the NRC?
To add days to a specified work location, submit a change using the Form 241. When submitting a change, if the dates specified in Item 13 (“Dates Scheduled”) are to be added for a specified work location, indicate in this field the number of added days.
If my company does work in more than one location on the same day, does each location count separately as a day used?
No. Working at multiple locations on the same day count as a single day.
For ongoing jobs, can I leave licensed material stored and properly secured at that the temporary job site until a later date.
Each day that the licensed material is stored at the temporary job site will count toward the allotted total of 180 days.
I have multiple Agreement State licenses authorizing the same activities. Can I file for reciprocity under more than one Agreement State license in a given calendar year?
No, the NRC treats each company as a single entity. Each entity may conduct no more than 180 days of licensed activities in NRC jurisdiction per calendar year, except for off-shore work which has no limit. If you wish to conduct more than 180 days of licensed activities, then you must apply for an NRC specific license.