June 16, 2009 

MEMORANDUM TO: Samuel J. Collins, Administrator 

Region I 

FROM: Robert J. Lewis, Director /RA/

 Division of Materials Safety 

 and State Agreements 

Office of Federal and State Materials 

 and Environmental Management Programs 

SUBJECT: MAY 13, 2009 PERIODIC MEETING UNDER THE INTEGRATED 

MATERIALS PERFORMANCE EVALUATION PROGRAM 

(IMPEP) 

A periodic meeting with Region I was held on May 13, 2009. The purpose of the meeting was to 

review and discuss the status of the Region I Radioactive Materials Program. The Office of 

Federal and State Materials and Environmental Management Programs (FSME) was 

represented by Leira Cuadrado and me. 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: 

1. Periodic Meeting Summary for Region I 

cc w/ encl: John Kinneman, Director 

 Division of Nuclear Materials Safety 
MEMORANDUM TO: Samuel J. Collins, Administrator 

Region I 

FROM: Robert J. Lewis, Director /RA/

 Division of Materials Safety 

 and State Agreements 

Office of Federal and State Materials 

 and Environmental Management Programs 

SUBJECT: MAY 13, 2009 PERIODIC MEETING UNDER THE INTEGRATED 

MATERIALS PERFORMANCE EVALUATION PROGRAM 

(IMPEP) 

A periodic meeting with Region I was held on May 13, 2009. The purpose of the meeting was to 

review and discuss the status of the Region I Radioactive Materials Program. The Office of 

Federal and State Materials and Environmental Management Programs (FSME) was 

represented by Leira Cuadrado and me. 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: 

1. Periodic Meeting Summary for Region I 

cc w/ encl: John Kinneman, Director 

 Division of Nuclear Materials Safety 

Distribution: 

DMSSA RF DCD (SP01) 

MDapas, RI 

JKinneman, RI 

DCollins, RI 

AMcCraw, FSME/MSSA 

MOrendi, FSME/MSSA 

MBeardsley, FSME/MSSA 

TReis, FSME/MSSA 

DWhite, FSME/MSSA 

ML091670279 

OFC FSME/MSSA 

NAME RJLewis:knm1 

DATE 06/16/09 

OFFICIAL RECORD COPY 
PERIODIC MEETING SUMMARY FOR THE REGION I 

RADIOACTIVE MATERIALS PROGRAM 

MEETING DATE: May 13, 2009 

ATTENDEES: FSME Region I

 Robert Lewis John Kinneman 

 Leira Cuadrado Daniel Collins 

 Joe Nick 

 Mark Dapas (entrance and exit only) 

DISCUSSION: 

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

Safety (the Division). The Division is composed of four branches: the Commercial and 

Research and Development Branch, the Decommissioning Branch, the Medical Branch, and the 

Material Security and Industrial Branch. 

The previous IMPEP review was conducted the week of April 4-8, 2005. The review team found 

Region I’s performance to be satisfactory for all performance indicators reviewed. Accordingly, 

the review team recommended, and the MRB agreed, that the Region I 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. 

Staffing and training: 

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

license reviewer qualifications. The Division is experiencing a changing workload due to 

new Agreement States decreasing the number of NRC licensees. Resources and 

vacancies are being closely and appropriately managed by Division management. The 

Division is investigating strategies to take on new work (e.g, research reactor 

environmental reviews); it was confirmed that this will not adversely impact the materials 

program. No concerns with staffing 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 in all 

areas of the materials program. All staff is currently qualified or partially qualified. The 

Division plans to do a self-assessment which will include review of qualification 

documentation before the next IMPEP. The attendees discussed the importance of 

knowledge management of specialty skills, such as dosimetry and security, when staff 

are qualified in multiple disciplines. The attendees discussed that as the number of 

licensees decreases, it will be harder to qualify people under current IMC1246 for each 

type of license due to fewer on-the-job training opportunities. Training and qualifications 

of remote workers, an issue to watch from the last IMPEP, has not been an issue, in part 

because the Division’s remote workers are very experienced and independent. The 

Division is employing technology to involve the remote workers in Division training and 

meetings. 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 process for budgeting for new Agreement States was examined. 

Materials inspection program: 

The Division had 4 overdue inspections of the 276 inspections performed. This equates 

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

NRC's performance goal of greater than or equal to 98 percent of scheduled inspections 

being completed within timeliness requirements, and meets the IMPEP criteria for a 

“satisfactory” rating for this indicator. The Division performed a self assessment 

regarding the late inspections, implemented recommendations, and has carefully 

planned work through the Fiscal Year (FY) to ensure the metrics will continue to be met. 

The attendees discussed NRC revisiting this metric, because it may become 

disproportionately more difficult to meet given the lower denominator (total number of 

inspections) resulting from fewer licensees as more States become Agreement States. 

In terms of the operating plans, the attendees discussed a possible difference between 

the Division and FSME involving tracking time to 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. 

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, for example to further communicate key activities 

and milestones. 
Review of Regional self-assessments: 

The attendees discussed three Regional self-assessments. The self-assessments can 

be found in NRC’s Agencywide Document Access and Management System (ADAMS) 

using the Accession Numbers ML082760706, ML090910019, ML090050459. 

New or potential FSME initiatives that may impact the Regions: 

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

working group participation. The Division has begun re-inspection of irradiator and 

manufacturer and distributor security orders consistent with recent guidance. The 

Division will rely upon some Agreement States to conduct additional inspections under 

274i. Agreements. The Division can accommodate these inspections if the Agreements 

are not executed. The Division is complying with pre-licensing 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. The Region should consider 

sharing this system with other Regions and the Agreement States. Currently, the 

Division is participating in a working group to standardize master materials licenses. 

CONCLUSIONS: 

 No performance concerns with respect to the IMPEP criteria were identified. 

Schedule for the next IMPEP review: 

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

FY 2010, as currently scheduled. 

Action items: 

None.