IMPEP — Evaluating the NRC’s Radioactive Materials Program
David Spackman
Health Physicist
For the NRC and each of the
37 states
that regulate radioactive materials under agreements with us, a time
comes every few years when we start talking about “IMPEP.” The acronym
is spoken about as frequently as the top 10 new words added to Webster’s
Dictionary every year – that is to say a lot.
IMPEP may be very easy to say, but understanding its true value requires a closer look.
IMPEP
stands for the Integrated Materials Performance Evaluation Program.
Think of it like an audit. It is the NRC’s primary tool for assessing
how well radioactive materials programs are
performing.
Every Agreement State and NRC program is evaluated under IMPEP every
four to five years. A rotating team of experts from the Agreement States
and the NRC do the reviews. The teams focus on specific areas of a
radioactive materials program that have the potential to affect public
health and safety. The reviews are very detailed, typically lasting a
full week.
Once an IMPEP review team has looked at everything they need to see
on-site, they document their findings. They write a report and recommend
a “grade” on the program’s performance to the Management Review Board,
which is comprised of senior NRC managers and a state program manager
who keeps in touch with the other Agreement States. The board holds a
public meeting to talk about what the team saw and assigns the overall
program rating: “Satisfactory,” “Satisfactory but Needs Improvement,” or
“Unsatisfactory.”
Recently it was the NRC’s turn to undergo an IMPEP review. From Dec.
8-11, a team of experts from Ohio, Tennessee, and the NRC reviewed the
NRC’s Sealed Source and Device (
SS&D)
Evaluation Program. This program performs engineering and radiation
safety evaluations of sealed radioactive sources and the devices that
use them.
Sealed sources are just what the name says—radioactive sources sealed
in a capsule to prevent leakage or escape of the material. The devices
are used for many things, but generally they measure something, such as
soil density, fluid levels, the thickness of a pipe, and whether metal
and welds are sound. They can also help to map geologic formations from
inside a gas or oil well. The NRC needs to do adequate technical
evaluations of SS&D designs to ensure they’ll maintain their
integrity and their designs are adequate to protect public health and
safety.
During the four-day IMPEP review at NRC Headquarters, the team looked
at the NRC program’s technical quality, staffing and training, and any
defects or incidents involving SS&Ds. Most of the work was done
through in-depth staff interviews and targeted document reviews. S
Since finishing the evaluation in mid-December, the team has drafted
their report. They expect to recommend to the board that the NRC’s
SS&D program be rated Satisfactory – the highest possible rating.
Furthermore the review team commended NRC staff for performing very
competent technical SS&D reviews. Although this is an excellent
result so far, there is still one more important step to complete the
IMPEP review process – the public meeting.
This meeting allows the review team to present its findings and
formally recommend the overall program rating. While the structure of
these meetings is simple, it is very common to see a spirited discussion
of the strengths, weaknesses, innovations and shortcomings of the
program under review.
This is where the true value of IMPEP is laid bare. If all goes
right, the end result is improving a program’s ability to protect public
health and safety and the environment – even if the program gets the
highest rating.
The MRB’s public meeting to discuss NRC’s SS&D program will be
held at NRC Headquarters in Rockville, Md., on March 5, 2015. The
meeting details are available on the NRC website at
http://meetings.nrc.gov/pmns/mtg. We encourage members of the public to come or listen in by phone.