December 16, 2009 

MEMORANDUM TO: Mark A. Satorius, Administrator 

Region III 

FROM: Robert J. Lewis, Director /RA/

 Division of Materials Safety and State Agreements 

Office of Federal and State Materials 

 and Environmental Management Programs 

SUBJECT: NOVEMBER 9-10, 2009 PERIODIC MEETING UNDER THE 

INTEGRATED MATERIALS PERFORMANCE EVALUATION 

PROGRAM (IMPEP) 

A periodic meeting with Region III was held on November 9-10, 2009. The purpose of the 

meeting was to review and discuss the status of the Region III radioactive materials program. 

The Office of Federal and State Materials and Environmental Management Programs (FSME) 

was represented by me and Shirley Xu. Specific topics and issues of importance discussed at 

the meeting included status of operating plan and performance metrics, status of staffing and 

training, licensing and inspection program changes since the last IMPEP, and a review of 

regional self assessments. I have enclosed a meeting summary. 

Enclosure: 

Periodic Meeting Summary for Region III 

cc w/ encl: Steven A. Reynolds, Director 

Division of Nuclear Materials Safety
December 16, 2009 

MEMORANDUM TO: Mark A. Satorius, Administrator 

Region III 

FROM: Robert J. Lewis, Director /RA/

 Division of Materials Safety and State Agreements 

Office of Federal and State Materials 

 and Environmental Management Programs 

SUBJECT: NOVEMBER 9-10, 2009 PERIODIC MEETING UNDER THE 

INTEGRATED MATERIALS PERFORMANCE EVALUATION 

PROGRAM (IMPEP) 

A periodic meeting with Region III was held on November 9-10, 2009. The purpose of the 

meeting was to review and discuss the status of the Region III radioactive materials program. 

The Office of Federal and State Materials and Environmental Management Programs (FSME) 

was represented by me and Shirley Xu. Specific topics and issues of importance discussed at 

the meeting included status of operating plan and performance metrics, status of staffing and 

training, licensing and inspection program changes since the last IMPEP, and a review of 

regional self assessments. I have enclosed a meeting summary. 

Enclosure: 

Periodic Meeting Summary for Region III 

cc w/ encl: Steven A. Reynolds, Director 

 Division of Nuclear Materials Safety 

Distribution: 

DMSSA RF DCD (SP01) 

SXu, FSME/MSSA 

AMcGraw, FSME/MSSA 

TReis, FSME/MSSA 

DWhite, FSME/MSSA 

ML093490392 

OFC FSME/MSSA 

NAME RJLewis:knm1 

DATE 12/16/09 

OFFICIAL RECORD COPY 
Enclosure 

PERIODIC MEETING SUMMARY FOR THE REGION III 

RADIOACTIVE MATERIALS PROGRAM 

MEETING DATE: November 9–10, 2009 

ATTENDEES: FSME Region III

 Robert Lewis Steven Reynolds 

 Shirley Xu Patrick Louden 

 Mark Satorius (entrance and exit only) 

 Cynthia Pederson (entrance only) 

 Christine Lipa 

 Tamara Bloomer 

 Patricia Pelke 

 James Lynch 

 James Clay 

DISCUSSION: 

The Region III radioactive materials program is administered by the Division of Nuclear 

Materials Safety (the Division). The Division is composed of three branches: the Materials 

control, ISFSI, and Decommissioning Branch, the Materials Inspection Branch, and the 

Materials Licensing Branch. 

The previous IMPEP review was conducted the week of August 27, 2007. The review the team 

found Region III’s performance to be satisfactory for all performance indicators reviewed. 

Accordingly, the review team recommended, and the MRB agreed, that the Region III program 

is adequate to protect public health and safety. 

Status of operating plan metrics: 

No issues were identified with respect to operating plan metrics. Specific areas relating 

to the status of operating plan metrics are discussed under other headings in this 

summary. 

Review of strategic plan metrics and an assessment of the quality of the data contained in the 

monthly reports on material statistics: 

No issues were identified with respect to strategic plan metrics. The quality of data 

contained in the monthly reports has been adequate. 

Status of the Region’s actions to address all open IMPEP review findings and/or open 

recommendations: 

 There are no open recommendations from previous IMPEP reviews. 
Region III Periodic Meeting Summary - 2 - 

Staffing and training: 

The attendees reviewed the Division’s staffing plan, along with status of inspector and 

license reviewer qualifications. The Division has had a relatively stable and full staffing 

since the last IMPEP. The attendees verified that the Division has sufficient technical 

expertise in two topical areas new to the program in recent years: accelerator produced 

radioactive materials and gamma knife radiosurgery. No concerns with staffing levels 

were identified. 

The Division uses the qualification program outlined in Inspection Manual Chapter (IMC) 

1246, “Formal Qualification Programs in the Nuclear Material Safety and Safeguards 

Program Area,” for the inspection and licensing staff. Generally, staff gets qualified 

across all areas of the materials program. For example, 8 of the licensing staff are 

inspector qualified. During the review period, no staff completed the IMC1246 

qualification program, but 3 staff members that are new to the program since the 2007 

IMPEP and 2 are cross-qualifying under IMC 1246. Both sets of staff are undergoing the 

program. The Division is also providing extensive training to a supervisor that is new to 

the program. Division management was clearly committed to staff training. No concerns 

with qualifications and training were identified. 

Program reorganizations: 

 The Division has not reorganized since the last IMPEP review. 

Changes in program budget/funding: 

The regions materials program budget of 26.2 FTE has increased by approximately 2 

FTE since the 2007 IMPEP to reflect increased materials security work and regional 

contributions to necessary program infrastructure investments. 

Materials inspection program: 

For 2009 the Division had 3 overdue inspections of the 360 inspections performed. This 

equates to less than 2 percent of the inspections being performed overdue, which 

exceeds NRC’s performance goal of 98 percent and meets the IMPEP criteria for a 

“satisfactory” rating for this indicator. The number of inspections in the grace period 

(due date plus 25 percent) has risen steadily throughout 2009 due to significant reactive 

inspection effort and inspection assists. However, the Division management plans to 

complete 525 inspections in 2010 which would reduce this rising backlog. 

In 2009, over 99% of inspection reports had been issued within 30 days of the exit 

meeting, which exceeds the goal of 90%. In terms of the operating plans, the attendees 

discussed possible differences between the Division and FSME involving tracking time 

from the exit (30 days for an inspection or 45 days for a team inspection). Division and 

FSME management will discuss this issue further at the next Regional Counterpart 

Meeting. 

The Division’s operational management information documents required annual 

accompaniments of qualified inspectors by supervisors. In three cases the 
Region III Periodic Meeting Summary - 3 - 

documentation of the accompaniments was not complete for 2008 and 2009, although 

the actual accompaniments were believed to have occurred. The Division agreed to 

review the documentation prior to the next IMPEP review. 

The participants discussed the Division’s broad scope inspection initiative, in which 

inspection time on–site for broad scope licensees is broken into several visits over the 

course of the inspection interval. Compliance with IMC2800 is achieved, perhaps more 

effectively, for approximately equivalent level of effort. The Division offered to discuss 

further with the program office. 

Materials Licensing Program

Materials licensing casework for new, amended, and renewal applications all complied 

with NRC operating plan and IMPEP performance indicator timeliness targets. Major 

materials licensees are assigned a project manager for effective communications. No 

concerns with the licensing program were identified. 

Response to incidents and allegations: 

Response to incidents and allegations was not discussed in detail, as FSME and the 

Division coordinate closely on these areas daily. The attendees discussed incremental 

improvements to the daily events call. 

Review of Regional self-assessments: 

Regional self-assessments were provided prior to the review. Audit topics cover several 

mandatory areas, plus additional topics selected by a consensus of management. No 

concerns with self assessments were identified. 

New or potential FSME initiatives that may impact the Regions: 

Discussions on ongoing initiatives included security inspections, pre-licensing visits, 

processing of NRC Inspection Form 591, and working group participation. The Division 

has begun re-inspection of irradiator and manufacturer and distributor security orders 

consistent with recent inspection guidance. There is only one affected facility in NRC 

territories in Region III. The Division will rely upon some Agreement States to conduct 

additional inspections under 274i Agreements. The Division is complying with prelicensing guidance for site visits and background checks. The Division has instituted a 

system to track and document these activities, beyond the requirements of the guidance. 

Form 591 are signed by supervisors and closed when entered into Agencywide 

Document Access and Management System (ADAMS). 

CONCLUSIONS: 

 No performance concerns with respect to the IMPEP criteria were identified. 
Region III Periodic Meeting Summary - 4 - 

Schedule for the next IMPEP review: 

The next IMPEP review of the Region III radioactive materials program should be held in 

FY 2011, as currently scheduled. 

Action items: 

None.