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.

NRC’s Materials and Waste Management Programs Coming Back Under One Roof

Chris Miller
Merge Coordinator and Director of Intergovernmental Liaison and Rulemaking

 

When Congress created the NRC in 1974, it established three specific offices within the agency. One of them was the Office of Nuclear Material Safety and Safeguards, or “NMSS” in NRC shorthand. This office was charged with regulating nuclear materials and the facilities associated with processing, transporting and handling them.

fuelcyclediagramThis charge was, and is, broad. The NRC’s materials and waste management programs cover facilities that use radioisotopes to diagnose and treat illnesses; devices such as radiography cameras and nuclear gauges; and decommissioning and environmental remediation. It also includes nuclear waste disposal and all phases of the nuclear fuel cycle, from uranium recovery to enrichment to fuel manufacture to spent fuel storage and transportation.

And there’s more. The program also does environmental reviews and oversees 37 Agreement States, which have assumed regulatory authority over nuclear materials, and maintains relationships with states, local governments, federal agencies and Native American Tribal organizations.

As with all organizations, the NRC’s workload has ebbed and flowed in response to a multitude of factors. Over the years, NMSS went through several structural changes to address its workload changes. In 2006, NMSS was gearing up for an increase in licensing activity related to the processing, storage and disposal of spent nuclear fuel. At the same time, the Agreement State program was growing, requiring additional coordination with the states—a function then housed in a separate Office of State and Tribal Programs.

To meet these changes and ensure effectiveness, the NRC restructured NMSS. Some of its programs were moved, including the state and tribal programs, into the new Office of Federal and State Materials and Environmental Management Programs (FSME). NMSS retained fuel cycle facilities, high-level waste disposal, spent fuel storage, and radioactive material transportation. FSME was responsible for regulating industrial, commercial, and medical uses of radioactive materials and uranium recovery activities. It also handled the decommissioning of previously operating nuclear facilities and power plants.

The NRC’s materials and waste management workload has now shifted again. At the same time, the agency is exploring ways to reduce overhead costs and improve the ratio of staff to management.

So, NRC staff launched a working group last fall to review the organizational structure of the NRC’s materials and waste management programs. With the focus shifting to long-term waste storage and disposal strategies, and an increasing number of nuclear plants moving to decommissioning, the group recommended merging FSME’s programs back into NMSS.

NRC’s Commissioners approved that proposal last week, and the merger of the two offices will be effective October 5. We think this new structure will better enable us to meet future challenges. It will improve internal coordination, balance our workload and provide greater flexibility to respond to a dynamic environment.

Current work, functions and responsibilities at the staff level will be largely unchanged. The management structure will realign into fewer divisions, with fewer managers.

In their direction to the staff, the Commissioners asked for careful monitoring of the changes and a full review after one year. We fully expect these changes to improve our communications both inside and outside of the agency, and provide for greater efficiency and flexibility going forward.