In 1994, NRC designed
and piloted a review process for Agreement State and NRC Regional
radioactive materials programs called the Integrated Materials
Performance Evaluation Program (IMPEP). Common performance indicators
were established to obtain comparable information on the performance
of each program. In 1996, NRC began full implementation of IMPEP
to ensure that public health and safety are adequately protected
from the potential hazards associated with the use of radioactive
materials and that Agreement State programs are compatible with
NRC's program.
The IMPEP process employs
a team of NRC and Agreement State staff to assess both Agreement
State and NRC Regional radioactive materials licensing and inspection
programs. IMPEP reviews are currently conducted in accordance with
the "Implementation of the Integrated Materials Performance
Evaluation Program and Recission of Final General Statement of Policy,"
published in the Federal Register on October 16, 1997, and NRC Management
Directive (MD) 5.6, "Integrated Materials Performance Evaluation
Program."
All reviews use the
following common indicators in the assessment and place primary
emphasis on performance:
- Technical Staffing
and Training
- Status of Materials
Inspection Program
- Technical Quality
of Inspections
- Technical Quality
of Licensing Actions
- Technical Quality
of Incident and Allegation Activities
Additional areas
are identified as non-common performance indicators (Compatibility
Requirements, Sealed Source and Device Evaluation Program, Low
Level Radioactive Waste Disposal Program, and Uranium Recovery
Program) and may also be addressed in the assessment.
The Office of Federal
and State Materials and Environmental Management Programs (FSME)
is the lead office responsible for the implementation of IMPEP.
Approximately 10-12 reviews are scheduled each year. Regions
and Agreement States are routinely reviewed every 4 years, although
the timeline may be adjusted based on performance.
The final determination
of adequacy of each NRC Regional program and both adequacy and
compatibility of each Agreement State program is made by a Management
Review Board (MRB) composed of NRC managers and an Agreement
State program manager who serves as an Agreement State liaison
to the MRB. The MRB membership includes the:
- Deputy Executive
Director for Materials, Waste, Research, State, Tribal, and
Compliance Programs;
- General Counsel;
- Director, FSME;
- Regional Administrator,
NRC Region; and
- Organization
of Agreement States Liaison.
The Organization
of Agreement States is invited to nominate liaisons to participate
in MRB meetings, as non-voting participants. The State representatives
receive all relevant documents and engage in all MRB discussions
except those that might involve the Agreement State liaison's
own State.
Agreement States and
Regional representatives are also invited to attend their individual
MRB meetings to discuss the IMPEP team's findings with the MRB.
The range of possible findings for an Agreement State program is as follows:
- Adequate to protect the public health and safety and compatible/not compatible
- Adequate, but needs improvement and compatible/not compatible
- Inadequate to protect public health and safety and compatible/not compatible
NRC Regions are rated
in the same manner, but without the additional compatibility finding.
