ML20330A193

1/25/2021 Letter to K. Steves Kansas Proposed Regulations to Rats Id 2015-3

ML20330A193
Person / Time
Issue date:	01/25/2021
From:	Brian Anderson NRC/NMSS/DMSST
To:	Steves K State of KS, Dept of Health & Environment
Beardsley M
Shared Package
ML20303A269	List: ML20303A281 ML20303A303 ML20303A306 ML20330A193
References
RATS ID 2015-3
Download: ML20330A193 (23)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 25, 2021 Ms. Kimberly Steves, Director Kansas Radiation Control Program Kansas Department of Health and Environment 1000 SW Jackson Suite 330 Topeka, KS 66612

Dear Ms. Steves:

We have reviewed the proposed revisions to the Kansas Administrative Regulations in various sections of §28-35-135, §28-35-196a, §28-35-221b, §28-35-282, §28-35-500, §28-35-504a, and

§28-35-505, received by our office on October 27, 2020. These regulations were reviewed by comparison to the equivalent U.S. Nuclear Regulatory Commission (NRC) rules and Regulation Amendment Tracking System Identification Number (RATS ID) 2015-3 as identified in the enclosed State Regulation Status (SRS) Data Sheet. We discussed our review of the regulations with you on January 15, 2021.

As a result of our review, we have ten comments that have been identified in the enclosure.

Please note that we have limited our review to regulations required for compatibility and/or health and safety. Under our current procedure, a finding that the Kansas regulations meet the compatibility and health and safety categories of the equivalent NRC regulation may only be made based on a review of the final Kansas regulations. However, we have determined that if your proposed regulations were adopted, incorporating our comments, and without other significant change, they would meet the compatibility and health and safety categories established in the Office of Nuclear Material Safety and Safeguards (NMSS) Procedure SA-200, Compatibility Categories and Health and Safety Identification for NRC Regulations and Other Program Elements.

We request that when the proposed regulations are adopted and published as final regulations, a copy of the as published regulations be provided to us for review. As requested in NMSS Procedure SA-201, Review of State Regulatory Requirements, please highlight the final changes, and provide a copy to Division of Materials Safety, Security, State, and Tribal Programs, NMSS.

The SRS Data Sheet summarizes our knowledge of the status of other Kansas regulations, as indicated. Please let us know if you note any inaccuracies or have any comments on the information contained in the SRS Data Sheet. This letter, including the SRS Data Sheet, is posted on the NMSS State Communication Portal: https://scp.nrc.gov/rulemaking.html.

K. Steves 2 If you have any questions regarding the review results, the compatibility and health and safety categories, or any of the NRC regulations used in the review, please contact Michelle Beardsley, State Regulation Review Coordinator, at (267) 884-2305 (Michelle.Beardsley@nrc.gov) or Joe OHara at (240) 808-0546 (Joe.OHara@nrc.gov).

Sincerely, Brian C. Digitally signed by Brian C. Anderson Anderson Date: 2021.01.25 15:10:24 -05'00' Brian C. Anderson, Chief State Agreement and Liaison Programs Branch Division of Materials Safety, Security, State and Tribal Programs Office of Nuclear Material Safety and Safeguards

Enclosures:

1. Compatibility Comments

2. Kansas SRS Data Sheet

ML20303A269 pkg and ML20330A193 letter OFFICE SALB NMSS/SALB OGC NMSS/SALB NAME JOHara MBeardsley JOlmstead BAnderson DATE 11/20/20 11/23/20 1/15/21 1/25/21 COMPATIBILITY COMMENTS ON KANSAS PROPOSED REGULATIONS STATE SECTION NRC SECTION RATS ID CATEGORY SUBJECT and COMMENTS 1 Multiple 10 CFR Part 71 2015-3 Multiple General comment As written, certain Kansas equivalent provisions to 10 CFR Part 71 contain requirements which can create conflicts, duplications, gaps, or other conditions that jeopardize an orderly pattern in the regulation of agreement material.

As general guidelines:

a. Kansas should not have written equivalent regulations for those that they adopt by reference (e.g., see comment 8);

b. All regulations that are Compatibility Categories A, and B need to be written essentially identical or verbatim to NRC regulations.

If State law prohibits the use of certain language or editorial styles, the State needs to provide an explanation in their cross reference document (e.g., see comments 2, 3, 4 and 5;

c. Any references cited within the regulations should be direct and specific so that the licensee does not have to determine which apply (e.g.,

see comment 4).

Please note that the examples above are not all inclusive, therefore Kansas should review their regulations for other instances, and revise or correct them to be compatible with NRCs regulations.

2 §28 §71.4 2015-3 B Definition:

135l(p) Low Specific

STATE SECTION NRC SECTION RATS ID CATEGORY SUBJECT and COMMENTS Activity (LSA) material Kansas omitted the reference to

§71.77, in Qualification of LSA-III Material, from their regulations.

Kansas needs to reference 10 CFR 71.77 in their definition Kansas §28-35-135l(p)(1)(C) has and instead of or. Kansas needs to change the regulation to be consistent with §71.4 definition of Low Specific Activity (LSA) material.

Kansas §28-35-135l(p)(D)(2)(A) uses and instead of or. KS needs to change the regulation to be consistent with §71.4 definition of Low Specific Activity (LSA) material.

Kansas §28-35-135l(p)(D)(2)(B) has or at the end of the sentence which should be deleted to be consistent with §71.4 definition of Low Specific Activity (LSA) material.

Kansas §28-35-135l(p)(D)(3)(B) should have an and at the end of the sentence. Kansas needs to change the regulation to be consistent with

§71.4 definition of Low Specific Activity (LSA) material Kansas needs to reference 10 CFR 71.77 in their definition and change the words as noted above in order to meet the Compatibility Category B designation assigned to 10 CFR 71.4, Definition of Low Specific Activity (LSA) material.

3 §28 § 71.4 2015-3 B Definition: Special form 135s(z)(2) radioactive material Kansas proposed definition of special form radioactive material contains the words as in effect on August 19, 2020 in reference to 10 CFR 71.75.

STATE SECTION NRC SECTION RATS ID CATEGORY SUBJECT and COMMENTS This date statement is not found in the NRCs regulations and should be omitted.

Kansas needs to remove the words as in effect on August 19, 2020 from their regulations in order to meet the Compatibility Category B designation assigned to 10 CFR 71.4, Definition of Special form radioactive material.

4 §28 §71.14(a)(1) - 2015-3 B Exemption for low-level materials 196a(a)(1) (a)(3)

Kansas has omitted the following requirements of 10 CFR 71.14 (a)(1)

- (a)(3) from their regulations which states:

1) Natural material and ores containing naturally occurring radionuclides that are either in their natural state, or have only been processed for purposes other than for the extraction of the radionuclides, and which are not intended to be processed for the use of these radionuclides, provided the activity concentration of the material does not exceed 10 times the applicable radionuclide activity concentration values specified in appendix A, Table A-2, or Table A-3 of this part.

(2) Materials for which the activity concentration is not greater than the activity concentration values specified in appendix A, Table A-2, or Table A-3 of this part, or for which the consignment activity is not greater than the limit for an exempt consignment found in appendix A, Table A-2, or Table A-3 of this part.

(3) Non-radioactive solid objects with radioactive substances present on any surfaces in quantities not in excess of the levels cited in the definition of contamination in § 71.4.

Kansas states that this is covered in 28-35-196a(a)(1) which states, The

STATE SECTION NRC SECTION RATS ID CATEGORY SUBJECT and COMMENTS licensee complies with the applicable requirements of the regulations of the U.S. department of transportation and incorporated sections of 10 CFR Part 71 (relating to packaging and transportation of radioactive material) of the U.S. nuclear regulatory commission that are appropriate to the mode of transport and that are related to the packing of radioactive material, and to the monitoring, marking, and labeling of those packages, however this statement is vague and not essentially identical to 10 CFR 71.14 (a)(1) - (a)(3)

Kansas needs to submit equivalent regulations as noted above, or specify which NRC regulations are incorporated by reference in order to meet the Compatibility Category B designation assigned to 10 CFR 71.14 (a)(1) - (a)(3).

5 28 § 71.15(d) 2015-3 B Exemption from classification as 196a(a)(1) fissile material Kansas has omitted the following requirements of 10 CFR 71.15(d) from their regulations which states:

d) Uranium enriched in uranium-235 to a maximum of 1 percent by weight, and with total plutonium and uranium-233 content of up to 1 percent of the mass of uranium-235, provided that the mass of any beryllium, graphite, and hydrogenous material enriched in deuterium constitutes less than 5 percent of the uranium mass, and that the fissile material is distributed homogeneously and does not form a lattice arrangement within the package.

Kansas omits equivalent regulations to 10 CFR 71.15(d). Kansas states that this is covered in 28 196a(a)(1) which states, The

STATE SECTION NRC SECTION RATS ID CATEGORY SUBJECT and COMMENTS licensee complies with the applicable requirements of the regulations of the U.S. department of transportation and incorporated sections of 10 CFR Part 71 (relating to packaging and transportation of radioactive material) of the U.S. nuclear regulatory commission that are appropriate to the mode of transport and that are related to the packing of radioactive material, and to the monitoring, marking, and labeling of those packages, however this statement is vague and not essentially identical to 10 CFR 71.15(d).

Kansas needs to submit equivalent regulations as noted above, or specify which NRC regulations are incorporated by reference in order to meet the Compatibility Category B designation assigned to 10 CFR 71.15(d) 6 §28-35-500 §71.17 2015-3 B General license: NRC approved package

§28-35-500a §71.21 2015-3 B General license: Use of foreign approved package Kansas states that their licensees QAPs can be approved by the NRC or the department. Kansas needs to delete, the NRC since their licensees QAPs should be approved by their department, not the NRC.

Regarding Kansas equivalent provisions to 10 CFR 71.17(c)(3):

In section 28-35-500(c)(3), Kansas needs to add the following:

Submit in writing before the first use of the package to: ATTN: Document Control Desk, Director, Division of Spent Fuel Storage and Transportation, Office of Nuclear Material Safety and Safeguards, using an appropriate method listed in

§ 71.1(a), the licensee's name and

STATE SECTION NRC SECTION RATS ID CATEGORY SUBJECT and COMMENTS license number and the package identification number specified in the package approval.

In addition, Kansas references part 15 of their regulations in §28 500(c)(2) and §28-35-500a(d)(2) rather than 10 CFR Part 71 subparts A, G, and H. Kansas did not provide part 15 as part of the review so it is unclear what is contained in part 15.

The review notes that 10 CFR Part 71 subpart H has been adopted by reference but there is no mention of 10 CFR Part 71 subparts A and G.

Kansas needs to either adopt the applicable sections of 10 CFR 71 subparts A and G by reference, or submit equivalent regulations.

Kansas needs to make the above changes in order to meet the Compatibility Category B designation assigned to 10 CFR 71.17 and 71.21.

7 28 §71.85(a) - (c) 2015-3 NRC Preliminary determinations 504a(c)(1)

Kansas adopts by reference 10 CFR 71.85(a) - c in section 28 504a(c)(1). Since this is designated as Comptibility Category NRC, Kansas cannot adopt this regulation by reference.

Kansas needs to remove the adoption by reference of this regulation in section 28-35-504a(c)(1) in order to meet the Compatiblility Category NRC designation assigned to 10 CFR 71.85(a) - (c).

8 §28 § 71.85(d) 2015-3 NRC Preliminary determinations 504a(c)(1)

Kansas states in section §28 196a(a)(4)) that, (4) The licensee has ascertained, before the first use of any packaging for the shipment of licensed radioactive material, that the determinations in 10 C.F.R. 71.85(a)

STATE SECTION NRC SECTION RATS ID CATEGORY SUBJECT and COMMENTS through (c), as adopted in K.A.R. 28-35-504a, have been made. 10 CFR 71.85(a)-(c) is a Compatibility Category NRC and should not be adopted by Kansas.

Kansas needs to remove their equivalent regulations to 71.85(a)-(c) along with the phrase, adopted in K.A.R. 28-35-504a from their regulations.

Kansas needs to make the above changes in order to meet the Compatibility Category NRC designation assigned to 10 CFR 10 CFR 71.85(d).

9 § 28 § 71.91(c) and 2015-3 C Records 504(a)(b) (d)

Kansas needs to replace the

§ 28 references in § 28-35-504(a)(b) to the 504(a)(c) NRC/Commission with their Agency information.

Kansas need to make these changes in order to meet Compatibility Category C designation assigned to 10 CFR 71.91(c) and (d).

10 § 28 § 71.101(g) 2015-3 C Quality assurance requirements 505(d)(3)

§ 34.31(b) C Kansas references § 28-35-282(d) in

§ 28 § 28-35-505(d)(3). § 28-35-282(d) is 282(d)(3) essentially the equivalent of NRC

§34.31(b).

Kansas omitted the sentence Replacement components shall meet design specifications or equivalent statement in § 28-35-282(d).

Kansas needs to add the sentence Replacement components shall meet design specifications or an equivalent statement in § 28 282(d) in order to meet the Compatibility Category C designation assigned to 10 CFR 71.101(g).

STATE REGULATION STATUS State: Kansas Tracking Ticket Number: 21-06 Date: 1/25/2021

[ # 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 Equipment 01/10/1994 Final No Comments Kansas has adopted Final Part 34 ML060940369 05/18/2006 Regulations equivalent to RATS ID:

55 FR 843 ML061370535 1997-5.

(Superceded by 1997-5) 1991-2 ASNT Certification of Radiographers none Final No Comments Kansas has adopted Final Part 34 ML060940369 05/18/2006 Regulations equivalent to RATS ID:

56 FR 11504 ML061370535 1997-5.

(Superceded by 1997-5) 1991-3 Standards for Protection Against Radiation 01/01/1994 Final No Comments Part 20 12/30/1997 56 FR 23360; 56 FR 61352; 57 FR 38588; 57 FR 57877; 58 FR 67657; 59 FR 41641; 60 FR 20183 1991-4 Notification of Incidents 10/15/1994 Final No Comments Parts 20, 30, 31, 34, 39, 40 and 70 ML060940369 05/18/2006 56 FR 64980; ML061370535 1992-1 Quality Management Program and 01/27/1995 Not Required Not Required Kansas has adopted Final Misadministrations Regulations equivalent to RATS ID:

Part 35 2002-2.

56 FR 34104 (Superceded by 2002-2)

These regulation changes are not 1992-2 Eliminating the Recordkeeping Requirements none Not Required Not Required required to be adopted for purposes for Departures from Manufacturer's Instructions of Compatibility.

Parts 30 and 35 57 FR 45566

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1993-1 Decommissioning Recordkeeping and License 10/25/1996 Final No Comments Termination: Documentation Additions [Restricted 01/03/1997 areas and spill sites]

Parts 30 and 40 58 FR 39628 1993-2 Licensing and Radiation Safety Requirements for 07/01/1996 Final No Comments Irradiators ML060940369 05/18/2006 Part 36 ML061370535 58 FR 7715 1993-3 Definition of Land Disposal and Waste Site QA 07/22/1996 Not Applicable 1 0F Not Applicable Kansas does not have any licensees Program subject to these regulations. (See Part 61 SECY-95-112) 58 FR 33886 1994-1 Self-Guarantee as an Additional Financial none Not Required Not Required These regulation changes are not Mechanism required to be adopted for purposes Parts 30, 40 and 70 of Compatibility.

58 FR 68726; 59 FR 1618 1994-2 Uranium Mill Tailings Regulations: Conforming 07/01/1997 Not Applicable Not Applicable Kansas does not have authority to NRC Requirements to EPA Standards regulate this material under its Part 40 Agreement.

59 FR 28220 1994-3 Timeliness in Decommissioning Material Facilities 08/15/1997 Final No Comments Parts 30, 40 and 70 ML060940369 05/18/2006 59 FR 36026 ML061370535 1995-1 Preparation, Transfer for Commercial Distribution, 01/01/1998 Final No Comments and Use of Byproduct Material for Medical Use ML060940369 05/18/2006 Parts 30, 32 and 35 ML061370535 59 FR 61767; 59 FR 65243; 60 FR 322 2

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1995-2 Frequency of Medical Examinations for Use of 03/13/1998 Final No Comments Respiratory Protection Equipment ML060940369 05/18/2006 Part 20 ML061370535 60 FR 7900 1995-3 Low-Level Waste Shipment Manifest Information 03/01/1998 Final No Comments and Reporting ML060940369 05/18/2006 Parts 20 and 61 ML061370535 60 FR 15649; 60 FR 25983 1995-4 Performance Requirements for Radiography 06/30/1998 Final No Comments Kansas has adopted Final Equipment ML060940369 05/18/2006 Regulations equivalent to RATS ID:

Part 34 ML061370535 1997-5.

60 FR 28323 (Superceded by 1997-5) 1995-5 Radiation Protection Requirements: Amended 08/14/1998 Final No Comments Definitions and Criteria ML060940369 05/18/2006 Parts 19 and 20 ML061370535 60 FR 36038 1995-6 Clarification of Decommissioning Funding 11/24/1998 Final No Comments Requirements ML060940369 05/18/2006 Parts 30, 40 and 70 ML061370535 60 FR 38235 1995-7 Medical Administration of Radiation and Radioactive 10/20/1998 Final No Comments Kansas has adopted Final Materials ML060940369 05/18/2006 Regulations equivalent to RATS IDs:

Parts 20 and 35 ML061370535 2002-2 and 2005-2.

60 FR 48623 (Superceded by 2002-2 and 2005-2) 1996-1 Compatibility with the International Atomic Energy 04/01/1999 Not Required Not Required Kansas has adopted Final Agency Regulations equivalent to RATS ID:

Part 71 2004-1.

60 FR 50248; 61 FR 28724 (Superceded by 2004-1) 3

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1996-2 One Time Extension of Certain Byproduct, Source 02/15/1999 Not Required Not Required These regulation changes are not and Special Nuclear Materials Licenses required to be adopted for purposes Parts 30, 40 and 70 of Compatibility.

61 FR 1109 1996-3 Termination or Transfer of Licensed Activities: 06/17/1999 Final No Comments Record keeping Requirements ML060940369 05/18/2006 Parts 20, 30, 40, 61 and 70 ML061370535 61 FR 24669 1997-1 Resolution of Dual Regulation of Airborne Effluents 01/9/2000 Final No Comments of Radioactive Materials; Clean Air Act ML060940369 05/18/2006 Part 20 ML061370535 61 FR 65120 1997-2 Recognition of Agreement State Licenses in Areas 02/27/2000 Final No Comments Under Exclusive Federal Jurisdiction Within an ML060940369 05/18/2006 Agreement State ML061370535 Part 150 62 FR 1662 1997-3 Criteria for the Release of Individuals Administered 05/29/2000 Final No Comments Radioactive Material ML060940369 05/18/2006 Parts 20 and 35 ML061370535 62 FR 4120 1997-4 Fissile Material Shipments and Exemptions 02/10/2000 Not Required Not Required These regulation changes are not Part 71 required to be adopted for purposes 62 FR 5907 of Compatibility. (See STP-97-078)

(Superceded by 2004-1) Kansas has adopted Final Regulations equivalent to RATS ID:

2004-1.

4

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1997-5 Licenses for Industrial Radiography and Radiation 06/27/2000 Final No Comments Safety Requirements for Industrial Radiography ML060940369 05/18/2006 Operations ML061370535 Parts 30, 34, 71 and 150 62 FR 28947 1997-6 Radiological Criteria for License Termination 08/20/2000 Final No Comments Parts 20, 30, 40 and 70 ML072010244 08/30/2007 62 FR 39057 ML072390354 1997-7 Exempt Distribution of a Radioactive Drug 01/02/2001 Final No Comments Containing One Microcurie of Carbon-14 Urea ML060940369 05/18/2006 Part 30 ML061370535 62 FR 63634 1998-1 Deliberate Misconduct by Unlicensed Persons 02/12/2001 Final No Comments Parts 30, 40, 61, 70, 71 and 150 ML060940369 05/18/2006 63 FR 1890; 63 FR 13773 ML061370535 1998-2 Self-Guarantee of Decommissioning Funding by 07/01/2001 Not Required Not Required These regulation changes are not Nonprofit and Non-Bond-Issuing Licensees required to be adopted for purposes Parts 30, 40 and 70 of Compatibility.

63 FR 29535 1998-3 License Term for Medical Use Licenses 07/10/2001 Not Required Not Required These regulation changes are not Part 35 required to be adopted for purposes 63 FR 31604 of Compatibility. (See STP-98-074)

(Superceded by 2002-2) Kansas has adopted Final Regulations equivalent to RATS ID:

1997-5.

1998-4 Licenses for Industrial Radiography and Radiation 07/09/2001 Final No Comments Safety Requirements for Industrial Radiographic ML060940369 05/18/2006 Operations ML061370535 Part 34 63 FR 37059 5

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 1998-5 Minor Corrections, Clarifying Changes, and a Minor 10/26/2001 Final No Comments Policy Change ML060940369 05/18/2006 Parts 20, 32, 35, 36 and 39 ML061370535 63 FR 39477; 63 FR 45393 1998-6 Transfer for Disposal and Manifests: Minor 11/20/2001 Final No Comments Technical Conforming Amendment ML060940369 05/18/2006 Part 20 ML061370535 63 FR 50127 1999-1 Radiological Criteria for License Termination of 06/11/2002 Not Applicable Not Applicable Kansas does not have the authority Uranium Recovery Facilities to regulate this material under its Part 40 Agreement.

64 FR 17506 1999-2 Requirements for Those Who Possess Certain 10/04/2002 Not Required Not Required These regulation changes are not Industrial Devices Containing Byproduct Material to required to be adopted for purposes Provide Requested Information of Compatibility.

Part 31 64 FR 42269 1999-3 Respiratory Protection and Controls to Restrict 02/02/2003 License Condition No Comments Internal Exposure ML052510063 09/22/2005 Part 20 ML052660291 64 FR 54543; 64 FR 55524 2000-1 Energy Compensation Sources for Well Logging 05/17/2003 Final No Comments and Other Regulatory Clarifications ML072010244 08/30/2007 Part 39 ML072390354 65 FR 20337 2000-2 New Dosimetry Technology 01/08/2004 Final No Comments Parts 34, 36 and 39 ML060940369 05/18/2006 65 FR 63750 ML061370535 6

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2001-1 Requirements for Certain Generally Licensed 02/16/2004 Final No Comments Industrial Devices Containing Byproduct Material ML14164A208 07/29/2014 Parts 30, 31 and 32 ML14162A452 65 FR 79162 2002-1 Revision of the Skin Dose Limit 04/05/2005 Final No Comments Part 20 ML060940369 05/18/2006 67 FR 16298 ML061370535 2002-2 Medical Use of Byproduct Material 10/24/2005 Final No Comments Parts 20, 32 and 35 ML070851184 04/23/2007 67 FR 20249 ML071140120 2003-1 Financial Assurance for Materials Licensees 12/03/2006 Final No Comments Parts 30, 40 and 70 ML060940369 05/18/2006 68 FR 57327 ML061370535 2004-1 Compatibility With IAEA Transportation Safety 10/01/2007 Final No Comments Standards and Other Transportation Safety ML060940369 05/18/2006 Amendments ML061370535 Part 71 69 FR 3697 2005-1 Security Requirements for Portable Gauges 07/11/2008 Final No Comments Containing Byproduct Material ML072010244 08/30/2007 Part 30 ML072390358 70 FR 2001 2005-2 Medical Use of Byproduct Material - Recognition of 04/29/2008 Final No Comments Specialty Boards ML060940369 05/18/2006 Part 35 ML061370535 70 FR 16336; 71 FR 1926 2005-3 Increased Controls for Risk-Significant Radioactive 12/01/2005 License Condition No Comments Sources (NRC Order EA-05-090) ML052650212 09/27/2005 70 FR 72128 ML052650327 7

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 ML111470461 06/14/2011 71 FR 15005 ML111390397 2006-2 National Source Tracking System - Serialization 02/06/2007 Final No Comments Requirements ML072010244 08/30/2007 Part 32 with reference to Part 20 Appendix E ML072390354 71 FR 65685 2006-3 National Source Tracking System 01/31/2009 Final No Comments Part 20 ML072820581 10/30/2007 71 FR 65685, 72 FR 59162 ML073040008 2007-1 Medical Use of Byproduct Material - Minor 10/29/2010 Final No Comments Corrections and Clarifications ML111470461 06/14/2011 Parts 32 and 35 ML111390397 72 FR 45147, 54207 2007-2 Exemptions From Licensing, General Licenses, and 12/17/2010 Final Comments Distribution of Byproduct Material: Licensing and ML111470461 06/14/2011 Reporting Requirements ML111390397 Parts 30, 31, 32 and 150 72 FR 58473 Revised Final No Comments ML20017A246 02/07/2020 ML20017A243 2007-3 Requirements for Expanded Definition of Byproduct 11/30/2010 Final & License Comments Material Condition 06/14/2011 Parts 20, 30, 31, 32, 33, 35, 61 and 150 ML111470461 ML111390397 72 FR 55864 Revised Final Comments ML20017A246 02/07/2020 ML20017A243 8

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2007-4 Order Imposing Fingerprinting Requirements and 06/05/2008 License Condition No Comments Criminal History Records Check Requirements for ML081270294 05/14/2008 Unescorted Access to Certain Radioactive Material ML081350450 NRC Order EA-07-305 72 FR 70901 2008-1 Occupational Dose Records, Labeling Containers, 02/15/2011 Final No Comments and Total Effective Dose Equivalent ML111470461 06/14/2011 Parts 19 and 20 ML111390397 72 FR 68043 2009-1 Medical Use of Byproduct Material - Authorized 09/28/2012 Final No Comments User Clarification ML111470461 06/14/2011 Part 35 ML111390397 74 FR 33901 2011-1 Decommissioning Planning 12/17/2015 Final No Comments Parts 20, 30, 40 and 70 ML17244A482 11/13/2017 76 FR 35512 ML17244A478 2011-2 Licenses, Certifications, and Approvals for Materials 11/14/2014 Final No Comments Licensees ML17244A482 11/13/2017 Parts 30, 36, 39, 40, 70 and 150 ML17244A478 76 FR 56951 2012-1 Change of Compatibility of 01/25/2015 Final No Comments Parts 31.5 and 31.6 ML14164A208 07/29/2014 (See RATS ID: 2001-1 for Rule text) ML14162A452 77 FR 3640 9

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2012-2 Advance Notification to Native American Tribes of 08/10/2015 Final Comments Transportation of Certain Types of Nuclear Waste ML17244A482 11/13/2017 Part 71 ML17244A478 77 FR 34194 Revised Final Comments ML18162A266 07/31/2018 ML18162A252 Revised Final No Comments ML19350B289 03/30/2020 ML19350A858 2012-3 Technical Corrections 08/06/2015 Final Comments Parts 30, 34, 40 and 71 ML17244A482 11/13/2017 77 FR 39899 ML17244A478 Revised Final Comments ML18162A266 07/31/2018 ML18162A252 Revised Final No Comments ML19350B289 03/30/2020 ML19350A858 2012-4 Requirements for Distribution of Byproduct Material 10/23/2015 Final Comments Parts 30, 31, 32, 40 and 70 ML17244A482 11/13/2017 77 FR 43666 ML17244A478 Revised Final Comments ML18162A266 07/31/2018 ML18162A252 Revised Final Comments ML19350B289 03/30/2020 ML19350A858 10

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2013-1 Physical Protection of Byproduct Material 03/19/2016 Proposed Comments Parts 20, 30, 32, 33, 34, 35, 36, 37, 39 and 71 ML15324A433 12/16/2015 78 FR 16922 ML15324A430 Proposed Comments Part 37 only License Condition 02/22/2016 ML16021A424 ML16021A394 Final Comments ML17244A482 11/13/2017 ML17244A478 Revised Final No Comments ML18162A266 07/31/2018 ML18162A252 Revised Final No Comments ML19350B289 03/30/2020 ML19350A858 2013-2 Distribution of Source Material to Exempt Persons 08/27/2016 Final Comments and to General Licensees and Revision of ML17244A482 11/13/2017 General License and Exemptions ML17244A478 Parts 30, 40 and 70 78 FR 32310 Revised Final No Comments ML18162A266 07/31/2018 ML18162A252 2015-1 Domestic Licensing of Special Nuclear Material - 01/26/2018 Proposed No Comments Written Reports and Clarifying Amendments ML19350B289 03/30/2020 Part 70 ML19350A858 79 FR 57721, 80 FR 143 2015-2 Safeguards Information - Modified Handling 01/28/2018 Proposed No Comments Categorization, Change for Materials Facilities ML19350B289 03/30/2020 Parts 30, 37, 73 and 150 ML19350A858 79 FR 58664, 80 FR 3865 11

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package

• 2015-3 Revisions to Transportation Safety Requirements 07/13/2018 Proposed Comments and Harmonization with International Atomic Energy *extended to ML20303A276 01/25/2021 Agency Transportation Requirements 08/15/2020 ML20303A269 Part 71 See STC 17-060 80 FR 33987 2015-4 Miscellaneous Corrections 09/02/2018 Proposed Comment Parts 37 and 40 ML19350B289 03/30/2020 80 FR 45841 ML19350A858 2015-5 Miscellaneous Corrections 12/31/2018 Proposed No Comments Parts 19, 20, 30, 32, 37, 40, 61, 70, 71 and 150 ML19350B289 03/30/2020 80 FR 74974 ML19350A858 2018-1 Medical Use of Byproduct Material - Medical Event 01/14/2022 Proposed No Comments Definitions, Training and Experience, and Clarifying ML19350B289 03/30/2020 Amendments ML19350A858 Parts 30, 32 and 35 2018-2 Miscellaneous Corrections - 12/21/2021 Proposed No Comments Organizational Changes ML19350B289 03/30/2020 ML19350A858 Parts 37, 40. 70 and 71 2018-3 Miscellaneous Corrections 07/30/2022 Parts 1, 2, 34, 37, 50, 71, 73, and 140 2019-1 Miscellaneous Corrections 12/18/2022 Parts 2, 21, 37, 50, 52, 73, and 110 2019-2 Organizational Changes and Conforming 12/30/2022 Amendments Parts 1, 2, 37, 40, 50, 51, 52, 55, 71, 72, 73, 74, 100, 140, and 150 12

RATS ID NRC Chronology Identification Date Due for Incoming Outgoing Notes State Adoption Letter Package 2020-1 Individual Monitoring Devices 06/16/2023 10 CFR Parts 34, 36, and 39 2020-2 Social Security Number Fraud Prevention 08/17/2023 10 CFR Parts 9 and 35 2020-3 Miscellaneous Corrections 11/16/2023 10 CFR Parts 1, 2, 19, 20, 21, 30, 34, 35, 40, 50, 51, 52, 60, 61, 62, 63, 70, 71, 72, 73, 74, 75, 76, 110, and 140 1 IMPEP Team: verify that Kansas does not have any licensees subject to these regulations during each review.

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