Integrated Materials Performance Evaluation Program (IMPEP)

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:

1. Adequate to protect the public health and safety and compatible/not compatible
2. Adequate, but needs improvement and compatible/not compatible
3. 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.