March 15, 2013 

MEMORANDUM TO: William M. Dean, Administrator 

Region I 

FROM: Brian J. McDermott, Director R/A

 Division of Materials Safety and State Agreements 

 Office of Federal and State Materials 

 and Environmental Management Programs 

SUBJECT: FEBRUARY 6, 2013, PERIODIC MEETING UNDER THE 

INTEGRATED MATERIALS PERFORMANCE EVALUATION 

PROGRAM 

A periodic meeting with Region I was held on February 6, 2013. 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 was represented by 

Michelle Beardsley and me. Specific topics and issues of importance discussed at the meeting 

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

licensing and inspection activities, and a review of regional self-assessments.

No performance concerns with respect to the Integrated Materials Performance Evaluation 

Program criteria were identified. A summary of the meeting is enclosed. I appreciate the support 

and preparation for this periodic meeting from the Region l management and staff. 

Enclosure:

Periodic Meeting Summary for Region I

cc: Raymond Lorson, Director 

 Division of Nuclear Materials Safety 

 
MEMORANDUM TO: William M. Dean, Administrator 

Region I 

FROM: Brian J. McDermott, Director R/A 

 Division of Materials Safety and State Agreements 

 Office of Federal and State Materials 

 and Environmental Management Programs 

SUBJECT: FEBRUARY 6, 2013, PERIODIC MEETING UNDER THE 

INTEGRATED MATERIALS PERFORMANCE EVALUATION 

PROGRAM 

A periodic meeting with Region I was held on February 6, 2013. 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 was represented by 

Michelle Beardsley and me. Specific topics and issues of importance discussed at the meeting 

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

licensing and inspection activities, and a review of regional self-assessments.

No performance concerns with respect to the Integrated Materials Performance Evaluation 

Program criteria were identified. A summary of the meeting is enclosed. I appreciate the support 

and preparation for this periodic meeting from the Region l management and staff. 

Enclosure:

Periodic Meeting Summary for Region I

cc: Raymond Lorson, Director 

 Division of Nuclear Materials Safety 

DISTRIBUTION: SP05 

DIR RF 

DJanda, RI/RSAO 

MOrendi, RI/RSAO 

LDimmick, ASPB 

DWhite, ASPB 

ML13070A036 

OFFICE ASPB MSSA:D 

NAME MBeardsley BMcDermott 

DATE 03/13/13 03/15/13 

OFFICIAL RECORD COPY 
ATTENDEES: 

FSME REGION I 

Brian McDermott, Director 

Division of Materials Safety and State 

Agreements 

Raymond Lorson, Director 

Division of Nuclear Materials Safety 

Michelle Beardsley, Health Physicist 

Agreement State Programs Branch 

Division of Materials Safety and State 

Agreements 

Daniel Collins, Deputy Director 

Division of Nuclear Materials Safety 

 James Dwyer, Chief 

Medical Branch 

 Marc Ferdas, Chief 

Decommissioning Branch 

 Judy Joustra, Chief 

Commercial and R&D Branch 

 David Lew, Deputy Regional Administrator 

Region I (exit meeting) 

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 26-30, 2010. 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. 

The following topics were discussed during this meeting: 

1) 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. 

2) 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. 

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

open recommendations:

There are no open recommendations from the previous IMPEP review. 

4) Status of the Region’s Program:

a) Staffing and training:

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

license reviewer qualifications. The Division reports a total of 42.0 FTE for Fiscal Year 

(FY) 2013; 30.0 FTE are technical staff positions and 12.0 FTE are 

management/administrative staff. They report that 87% of the technical FTE are 

dedicated to safety and security activities and the remainder to Interim Spent Fuel 

Storage Installations (ISFSI) and decommissioning activities. Since the 2010 IMPEP 

review, the Division has been able to hire and/or replace staff to fill all vacated positions 

and are therefore, fully staffed. 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,” along with DNMS Directive 0400/1, “DNMS Training and Qualification 

Program“ that outlines the implementation of IMC 1246, for the inspection and licensing 

staff. Generally, staff receives qualification in all areas of the materials program. All 

staff is currently qualified, partially qualified or going through the process. No concerns 

with staff qualifications and training were identified. 

b) Program reorganizations: 

The Division acknowledged the challenges with meeting the Agency’s supervisory ratio 

goal (i.e. 9.2 staff: 1 manager) with their current organizational structure of four 

branches. They noted that their proposed 2016 organizational plan contains three 

branches, with the potential to have a project manager dedicated to the implementation 

of the new 10 CFR Part 37 activities. The Region I staffing plan also includes a 

dedicated Licensing Assistance Team (LAT) to assist the technical staff with the 

administrative processing of documents. 

c) Changes in program budget/funding: 

No changes were noted, except that the funding of 1.0 FTE for the NUREG-1556 

revision activities will be eliminated in FY2014. 

d) Materials inspection and licensing programs: 

Staff reviewed the quarterly Operating Plan (Op plan) metrics issued by FSME since 

the last IMPEP review. The Division noted that they review the status of inspection and 

licensing activities at a biweekly management meeting. The Division explained that 

while the Op plan report summaries indicate that there were no overdue inspections 

performed in FY 2010, 2011 and 2012, they identified six inspections that had been 

initiated and kept open (not closed) for an extended period due to technical or 

regulatory issues and are overdue. To prevent recurrence of this issue, the inspection 

tracking reports have been modified to improve visibility of these open inspections. 
The Division has issued 81 new licenses since the last IMPEP review and all have 

been inspected on time. The Division has exceeded the criteria for inspecting 

reciprocity activities (i.e. at least 20% of candidate licensees) in each year since the 

last IMPEP review. The Division discussed the unique challenges associated with 

inspection activities in the Commonwealth of Puerto Rico including issues with travel, 

communication, regulatory culture and waste disposal. 

The Division reported that 32 out of 1839 total licensing actions completed since the 

last IMPEP review (1.7%) were overdue. Some reasons for the overdue actions 

included higher complexity license activities, newer staff needing additional time for 

review, and some actions that required the submission of a Technical Assistance 

Request (TAR). 

e) Response to incidents and allegations: 

Attendees discussed the Division’s program for incident response including the 

completeness and timeliness of NMED reporting. FSME staff provided to the Division a 

list of records dating back to 2011 categorized in NMED as “not complete” or “request for 

additional information”. The Division committed to investigating these cases and 

supplying what is needed for closure. They requested assistance with some type of 

“tickler” report from the NMED contractor or inclusion of these cases in the quarterly 

operating plan data issued by FSME, for better management oversight of these cases to 

completion. FSME staff will take this item for action. 

The Division provided a summary report of the annual Regional Enforcement and 

Allegations Self-Assessment and Lessons Learned audits performed since June 2010. 

The report showed that the Division took prompt and comprehensive actions on all 

findings. 

5) Review of Regional self-assessments: 

The Division provided their reports of self-assessments performed since the 2010 IMPEP 

review. These included an examination of: Financial Assurance documents, Licensing and 

Inspection Activities, Record Transfer for Material License Terminations, Response to Notices of 

Violations and NRC Acknowledgement and Changes in Next Inspection Date as a Result of 

Significant Licensing Actions. The self-assessments identified minor issues for which the 

Division implemented prompt and appropriate corrective actions. 

6) New or potential FSME initiatives that may impact the Regions: 

FSME discussed ongoing initiatives including their plan to focus resources on the completion of 

the NUREG-1556 guidance revisions, Part 37 implementation activities, use of new technology 

(one-time password devices) for ISMP (NSTS, WBL, and LVS), and the work with federal 

partners on the IAEA’s draft Code of Conduct for scrap metals. 

SUMMARY: 

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

Schedule for the next IMPEP review: 

Staff will recommend to the MRB that, in accordance with current IMPEP policy, the next IMPEP 

review of the Region I radioactive materials program be held in FY 2015.