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IMPEP — Evaluating the NRC’s Radioactive Materials Program

David Spackman
Health Physicist

For the NRC and each of the 37 states that regulate radioactive materials under agreements with us, a time comes every few years when we start talking about “IMPEP.” The acronym is spoken about as frequently as the top 10 new words added to Webster’s Dictionary every year – that is to say a lot.

IMPEP may be very easy to say, but understanding its true value requires a closer look.

IMPEP stands for the Integrated Materials Performance Evaluation Program. Think of it like an audit. It is the NRC’s primary tool for assessing how well radioactive materials programs are agreementstatenesperforming. Every Agreement State and NRC program is evaluated under IMPEP every four to five years. A rotating team of experts from the Agreement States and the NRC do the reviews. The teams focus on specific areas of a radioactive materials program that have the potential to affect public health and safety. The reviews are very detailed, typically lasting a full week.

Once an IMPEP review team has looked at everything they need to see on-site, they document their findings. They write a report and recommend a “grade” on the program’s performance to the Management Review Board, which is comprised of senior NRC managers and a state program manager who keeps in touch with the other Agreement States. The board holds a public meeting to talk about what the team saw and assigns the overall program rating: “Satisfactory,” “Satisfactory but Needs Improvement,” or “Unsatisfactory.”

Recently it was the NRC’s turn to undergo an IMPEP review. From Dec. 8-11, a team of experts from Ohio, Tennessee, and the NRC reviewed the NRC’s Sealed Source and Device (SS&D) Evaluation Program. This program performs engineering and radiation safety evaluations of sealed radioactive sources and the devices that use them.

Sealed sources are just what the name says—radioactive sources sealed in a capsule to prevent leakage or escape of the material. The devices are used for many things, but generally they measure something, such as soil density, fluid levels, the thickness of a pipe, and whether metal and welds are sound. They can also help to map geologic formations from inside a gas or oil well. The NRC needs to do adequate technical evaluations of SS&D designs to ensure they’ll maintain their integrity and their designs are adequate to protect public health and safety.

During the four-day IMPEP review at NRC Headquarters, the team looked at the NRC program’s technical quality, staffing and training, and any defects or incidents involving SS&Ds. Most of the work was done through in-depth staff interviews and targeted document reviews. S

Since finishing the evaluation in mid-December, the team has drafted their report. They expect to recommend to the board that the NRC’s SS&D program be rated Satisfactory – the highest possible rating. Furthermore the review team commended NRC staff for performing very competent technical SS&D reviews. Although this is an excellent result so far, there is still one more important step to complete the IMPEP review process – the public meeting.

This meeting allows the review team to present its findings and formally recommend the overall program rating. While the structure of these meetings is simple, it is very common to see a spirited discussion of the strengths, weaknesses, innovations and shortcomings of the program under review.

This is where the true value of IMPEP is laid bare. If all goes right, the end result is improving a program’s ability to protect public health and safety and the environment – even if the program gets the highest rating.

The MRB’s public meeting to discuss NRC’s SS&D program will be held at NRC Headquarters in Rockville, Md., on March 5, 2015. The meeting details are available on the NRC website at http://meetings.nrc.gov/pmns/mtg. We encourage members of the public to come or listen in by phone.

Q & A with Joanne Savoy in Recognition of Black History Month

Joanne Savoy works in the NRC’s Office of International Programs as a licensing assistant for the Exports Controls and Nonproliferation Branch. She has also been the chair of the agency’s Advisory Committee for African Americans (ACAA) for the past three years.

What is the ACAA?

joanneThe ACAA is one of eight Equal Employment Opportunity Advisory Committees here at the NRC. It reports to the Office of Small Business and Civil Rights and its goal is to assist in identifying issues that may impact African American employees. We also make recommendations to address those issues.

Why does diversity matter in the NRC workplace?

Diversity matters because everyone is able to bring different points of view to the table. Many of us come from different backgrounds, and we are able to take what we have experienced — and learned in our own diversified cultures — to add value to our everyday work life. Diversity at the NRC means a new way of thinking, and a new way for all of us to interact with each other and learn from each other.

How does diversity in the workforce help the NRC meet its mission?

There are many studies that prove that when workers are ethnically and racially diverse, are educated in different parts of the country, represent multiple generations, and come from various socio-economic backgrounds they collaborate and contribute in a way that makes an organization more successful and productive in accomplishing its mission.

The NRC permanent staff is made up of:

15% African Americans
10% Asians
6% Hispanics
1% Native Americans
67% White

We come from all parts of the country; we have been educated in many different colleges and universities, and in many different disciplines (both technical and non-technical). We represent every generation across every age group. We practice many different religions and beliefs and nearly 1% of our work force is employees with disabilities. This is the diversity that makes the NRC great.

Why is Black History Month important?

Black History Month is important because it is a time to reflect on how far we have come. Black History Month is a time for EVERYONE to celebrate ALL who have fought for African American rights and freedom. Judge Alan Rosenthal, a member of the NRC’s ASLPB, was the keynote speaker at the agency’s African American History month dinner in 2013. I was surprised to learn the agency had someone who played a vital role in the historic Brown vs Board of Education of Topeka, Kansas. I remember thinking how amazing it was to have met this man who had fought so hard for someone like me, so I would have the opportunities that I have today. I will never forget that moment. It made me realize how the NRC has heroes like Judge Rosenthal, who fought the fight for equal rights.

What should people make a point to do/think/reflect on during Black History Month?

We should make a point to volunteer and give back to our communities. There are people and children who need us to guide them and help them make their lives better. I also think we should continue to educate not only ourselves but our children about our history. There are so many great movies like Selma, Roots, 12 Years A Slave, Glory, The Butler, Malcom X, Road to Memphis, American Black Journal and so many more that can help the education process. We should be watching these movies and talking to our children, family and friends about what Black History Month means to us.

I am who I am because of the people — black and white — who have fought the fight for equal rights. Because of them, a woman like me is able to work here at the NRC and to have the freedom to do whatever I want. It is up to me and you to give back and continue the legacy and remember we have come a long way, but there is always more that we can do to continue with the our legacy.

Throwback Thursday — Dresden Takes Shape

DresdenVesselIndicative of private industry’s growing participation in the atomic energy field was this new $20 million Babcock and Wilcox Company plant in Mt. Vernon, Indiana. The first job for the plant was the fabrication of the 800-ton vessel for the Dresden Unit No. 2 reactor. (Photo courtesy of the Department of Energy.)

So, you nuclear historians, what year was this?

Back To Where We Were For North Anna New Reactor Environmental Review

Tamsen Dozier
Project Manager
Office of New Reactors

It’s not often we have to say “never mind,” but that applies to what had been potential changes to our environmental review for a new reactor in Virginia. Multiple changes in the proposed design for the North Anna application have eliminated one reason to supplement our work.

naDominion Virginia applied in November 2007 to build and operate a new reactor at the company’s North Anna site, northwest of Richmond. This would be the third North Anna reactor, co-located with the two that have operated safely since 1978 and 1980. Dominion’s original application proposed building General Electric-Hitachi’s Economic Simplified Boiling Water Reactor.

The NRC’s review includes examining issues as required by the National Environmental Policy Act. Dominion had addressed many of these environmental questions by successfully obtaining an Early Site Permit for the North Anna site before applying for a reactor license. The NRC does an additional review when considering a reactor license application. We held meetings with the local community and also got input from state officials and other federal agencies. We examined all this information before publishing a supplement to the permit’s environmental review, evaluating the possible construction and operation of the GE design at North Anna.

In 2011, Dominion amended its application to reflect the company’s change to a different reactor design. At that point we decided we’d need another supplement to the EIS to evaluate any changes in the previously evaluated impacts. In 2013 Dominion changed course again, returning to GE’s design. Since we’ve already documented our environmental review for the GE design, there’s no longer a need for a supplement for any design changes. We just published a notice to this effect in the Federal Register (Jan. 29, 2015).

Beyond these design changes, NRC regulations require more reviews for additional substantial application changes or if significant new environmental information comes to light. We’ll keep looking for project changes or new information and we’ll prepare a supplement if one’s needed.

The Yucca Mountain Safety Evaluation Report: One Step of a Long Journey

David McIntyre
Public Affairs Officer

The NRC staff has now completed its safety evaluation report (SER) on the proposed nuclear waste repository at Yucca Mountain in Nevada, with the publication of Volume 2 and Volume 5. This is an important milestone – however, completion of the SER neither finishes the review process nor represents a licensing decision.

yucca

To recap: The NRC closed its review of the application in fiscal year 2011. (The full story is here.) The NRC staff published Volume 1 of its five-volume SER in August 2010. Volume 1 covered general information about the application. The NRC staff subsequently published three technical evaluation reports to capture the work it had already done on volumes 2, 3 and 4, though without any regulatory conclusions.

In August 2013, the U.S. Court of Appeals for the District of Columbia Circuit ordered the NRC to resume the licensing process using leftover money appropriated from the Nuclear Waste Fund. So the agency resumed its work on the formal safety evaluation report. We published Volume 3, covering repository safety after permanent closure, in October 2013. Volume 4, on administrative and programmatic requirements, was published in December. Volume 2, repository safety before permanent closure, and Volume 5, license specifications, complete the SER and the technical part of the licensing review.

That technical review concluded DOE’s application meets the safety and regulatory requirements in NRC’s regulations, except for DOE’s failure to secure certain land and water rights needed for construction and operation of the repository. These issues were identified in Volume 4.

Bottom line: the SER recommends that the Commission should not issue a construction authorization until DOE secures those land and water rights, and a supplement to DOE’s environmental impact statement (EIS) is completed.

The land DOE still needs to acquire is owned by three federal agencies: DOE’s National Nuclear Security Administration, the Department of the Interior and the Department of Defense. Legislation was introduced in Congress in 2007 to appropriate the land for the repository, but it did not pass. The water rights DOE needs are owned by the state of Nevada, which refused to appropriate the water in 1997. Litigation challenging that refusal is stayed.

yuccatunnelWhen the NRC resumed its licensing review in response to the appeals court, the agency asked DOE to supplement the EIS to cover certain groundwater-related issues. DOE declined to do so. The NRC staff is prepared to develop the supplement if the Commission tells it to.

Even if the EIS is completed, two more steps are needed before a licensing decision can be made. The adjudication of nearly 300 contentions filed by Nevada and other parties challenging the repository was also suspended in 2011. Reviving and completing this hearing will require more funding from Congress. Finally, the Commission must review issues outside of the adjudicatory context. Only then would the Commission decide whether to authorize construction.

So yes, completion of the SER is a major step, but there are many more ahead before the NRC can say yea or nay to Yucca Mountain.

 

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