ML23143A242
| ML23143A242 | |
| Person / Time | |
|---|---|
| Issue date: | 06/02/2023 |
| From: | Adelaide Giantelli NRC/NMSS/DMSST/ASPB |
| To: | Khayyat A State of IL, Emergency Management Agency |
| References | |
| Download: ML23143A242 (29) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Adnan Khayyat, Chief Bureau of Radiation Safety Illinois Emergency Management Agency 1035 Outer Park Dr.
Springfield, IL 62704
Dear Mr. Khayyat:
The U.S. Nuclear Regulatory Commission (NRC) uses the Integrated Materials Performance Evaluation Program (IMPEP) in the review of Agreement State and NRC radiation control programs. Enclosed is the draft IMPEP report which documents the results of the Illinois Agreement State review conducted on April 24-28, 2023. The teams preliminary findings were discussed with you and your staff on the last day of the review. The teams proposed recommendations are that the Illinois Agreement State Program be found adequate to protect public health and safety and compatible with the NRCs program.
The NRC conducts periodic reviews of radiation control programs 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 the NRCs program. The IMPEP process uses a team comprised of Agreement State and NRC staff to perform the reviews. All reviews use common criteria in the assessment and place primary emphasis on performance. The final determination of adequacy and compatibility of each program, based on the teams report, is made by the Chair of the Management Review Board (MRB) after receiving input from the MRB members. The MRB is composed of NRC senior managers and an Agreement State program manager.
In accordance with the procedures for implementation of IMPEP, we are providing you with a copy of the draft report for your review and comment prior to submitting the report to the MRB.
Comments are requested within 28 days from the date of this letter. This schedule will permit the issuance of the final report in a timely manner. If there are no comments to the IMPEP report, the MRB will receive the draft IMPEP report. If there are comments to the report, the team will review your response, make the necessary changes, and issue a proposed final report to the MRB.
The MRB meeting is scheduled to be conducted on August 3, 2023, at 1:00 pm ET via Microsoft Teams. The NRC will provide you with a Microsoft Teams connection information prior to the meeting. The NRC will also provide invitational travel for you or your designee to attend the MRB meeting at the NRC Headquarters in Rockville, Maryland. Because the team has recommended all indicators be rated satisfactory, you have the option to attend the MRB meeting remotely and do not need to travel. June 2, 2023 If you have any questions regarding the enclosed report, please contact me at (301) 415-3521 or Randy Erickson at (817) 676-4024.
Thank you for your cooperation.
Sincerely, Adelaide S. Giantelli, Chief State Agreement and Liaison Programs Branch Division of Materials Safety, Security, State, and Tribal Programs Office of Nuclear Material Safety and Safeguards
Enclosure:
2023 Illinois Draft IMPEP Report cc: Gary Forsee, Chief Radioactive Materials Branch Bureau of Radiation Safety Illinois Emergency Management Agency 1035 Outer Park Dr.
Springfield, IL 62704 Signed by Giantelli, Adelaide on 06/02/23
ML23143A242 OFFICE R-IV/DRSS NMSS/MSST NMSS/MSST NAME RErickson KModes AGiantelli DATE 05/23/2023 05/23/2023 06/02/2023 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM
REVIEW OF THE ILLINOIS AGREEMENT STATE PROGRAM
APRIL 24-28, 2023
DRAFT REPORT
Enclosure EXECUTIVE
SUMMARY
The results of the Integrated Materials Performance Evaluation Program (IMPEP) review of the Illinois Agreement State Program (Illinois) are contained in this report. The review was conducted from April 24-28, 2023. Ten in-person inspector accompaniments were conducted between September 20, 2022, and April 6, 2023. The team found Illinois performance to be satisfactory for all performance indicators. The team did not make any new recommendations for Illinois but did identify two good practices involving an innovative approach to the tracking of licensing actions and the development of modality specific licensing applications. Both were designed to streamline and track the licensing process, better apply resources, and reduce the workload on the licensing staff. These good practices are described in Section 3.4 of this report.
Accordingly, the team recommends that the Illinois Agreement State Program be found adequate to protect public health and safety and compatible with the NRCs program. The team recommends that a periodic meeting take place in approximately 2.5 years, with the next IMPEP review take place in approximately 5 years.
Illinois Draft IMPEP Report Page 1
1.0 INTRODUCTION
The Illinois Agreement State Program (Illinois) review was conducted from April 24-28, 2023, by a team of technical staff members from the U.S. Nuclear Regulatory Commission (NRC) and the States of Texas, Tennessee, Ohio, and New Jersey. Team members are identified in Appendix A. Ten in-person inspector accompaniments were conducted between September 20, 2022, and April 6, 2023. The inspector accompaniments are identified in Appendix B. The review was conducted in accordance with the Agreement State Program Policy Statement, published in the Federal Register on October 18, 2017 (82 FR 48535), and NRC Management Directive (MD) 5.6, Integrated Materials Performance Evaluation Program (IMPEP), dated July 24, 2019. Preliminary results of the review, which covered the period of April 21, 2018, to April 28, 2023, were discussed with the Illinois managers on the last day of the review.
In preparation for the review, a questionnaire addressing the common performance indicators and applicable non-common performance indicators was sent to Illinois on January 6, 2023. Illinois provided its response to the questionnaire by electronic mail on April 7, 2023. A copy of the questionnaire response is available in the NRCs Agencywide Documents Access and Management System (ADAMS) using the Accession Number ML23101A047.
The Illinois Agreement State Program is administered by the Radioactive Materials Branch (RAM Branch) and the Radiation Protection Services Branch (RPS Branch),
which are located within the Division of Nuclear Safety (the Division). The RAM Branch performs the licensing, inspection, decommissioning, and sealed source and device (SS&D) evaluations for the Division. The RPS Branch regulates low-level radioactive waste (LLRW) disposal and uranium recovery for the Division. In addition, since 2014, the RPS Branch has been the lead for responses to triggered alarms for radioactive material at scrap yards and orphan radioactive sources. The Division is part of the Illinois Emergency Management Agency (the Agency). Organization charts for Illinois are available in ADAMS ML23101A046.
At the time of the review, Illinois regulated 521 specific licenses authorizing possession and use of radioactive materials. The review focused on the radiation control program as it is carried out under Section 274b. (of the Atomic Energy Act of 1954, as amended)
Agreement between the NRC and the State of Illinois.
The team evaluated the information gathered against the established criteria for each common and applicable non-common performance indicators and made a preliminary assessment of Illinois performance.
2.0 PREVIOUS IMPEP REVIEW AND STATUS OF RECOMMENDATIONS
The previous IMPEP review concluded on April 20, 2018. The final report is available in ADAMS ML18207A322. The results of the review are as follows:
Technical Staffing and Training: Satisfactory Recommendation: None
Status of Materials Inspection Program: Satisfactory Recommendation: None Illinois Draft IMPEP Report Page 2
Technical Quality of Inspections: Satisfactory Recommendation: None
Technical Quality of Licensing Actions: Satisfactory Recommendation: None
Technical Quality of Incident and Allegation Activities: Satisfactory Recommendation: None
Legislation, Regulations, and Other Program Elements: Satisfactory Recommendation: None
SS&D Evaluation Program: Satisfactory Recommendation: None
LLRW Program: Not Reviewed Recommendation: None
Uranium Recovery: Satisfactory Recommendation: None
Overall finding: Adequate to protect public health and safety and compatible with the NRCs program
3.0 COMMON PERFORMANCE INDICATORS
Five common performance indicators are used to review the NRC and Agreement State radiation control programs. These indicators are: (1) Technical Staffing and Training, (2) Status of Materials Inspection Program, (3) Technical Quality of Inspections, (4) Technical Quality of Licensing Actions, and (5) Technical Quality of Incident and Allegation Activities.
3.1 Technical Staffing and Training
The ability to conduct effective licensing and inspection programs is largely dependent on having a sufficient number of experienced, knowledgeable, well-trained technical personnel. Under certain conditions, staff turnover could have an adverse effect on the implementation of these programs and could affect public health and safety. Apparent trends in staffing must be assessed. Review of staffing also requires consideration and evaluation of the levels of training and qualification. The evaluation standard measures the overall quality of training available to, and taken by, materials program personnel.
- a. Scope
The team used the guidance in State Agreements (SA) procedure SA-103, Reviewing the Common Performance Indicator: Technical Staffing and Training, and evaluated Illinois performance with respect to the following performance indicator objectives:
A well-conceived and balanced staffing strategy has been implemented throughout the review period.
Any vacancies, especially senior-level positions, are filled in a timely manner.
There is a balance in staffing of the licensing and inspection programs.
Illinois Draft IMPEP Report Page 3
Management is committed to training and staff qualification.
Agreement State training and qualification program is equivalent to NRC Inspection Manual Chapter (IMC) 1248, Formal Qualifications Program for Federal and State Material and Environmental Management Programs.
Qualification criteria for new technical staff are established and are followed, or qualification criteria will be established if new staff members are hired.
Individuals performing materials licensing and inspection activities are adequately qualified and trained to perform their duties.
License reviewers and inspectors are trained and qualified in a reasonable period of time.
- b. Discussion
The Illinois radiation control program (Illinois) is comprised of 18 technical and 1 administrative staff member equaling 19 full-time equivalents (FTE). For the first two years of the review period, there were staffing transitions. At the time of the review, Illinois had three recent vacancies. Illinois obtained approval to post these three vacancies and submitted the paperwork to fill the positions. During the review period, 8 staff members left the program for various reasons and 11 staff members were hired.
Of the eight staff who left, three retired and each accepted limited contracts to continue working while replacements were trained, three other staff did not advance through their training and ultimately left the program, and two staff transferred to other positions within the Illinois Emergency Management Agency. Most vacant positions were vacant for 30 days or less before being posted. The team confirmed that even with the departures, and due in part to the ability to contract with retiring employees, there was minimal impact to their ability to train staff and maintain work activities.
The team found that Illinois had a training and qualification program compatible with the NRCs IMC 1248. The team also confirmed that licensing and inspection staff were completing and documenting at a minimum 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of refresher training every 2 years, and in most cases refresher training far exceeded the required hours.
- c. Evaluation
The team determined that, during the review period, Illinois met the performance indicator objectives listed in Section 3.1.a. Based on the criteria in MD 5.6, the team recommends that Illinois performance with respect to the indicator, Technical Staffing and Training, be found satisfactory.
- d. MRB Chairs Determination
The final report will present the MRB Chairs determination regarding this indicator.
3.2 Status of Materials Inspection Program
Inspections of licensed operations are essential to ensure that activities are being conducted in compliance with regulatory requirements and consistent with good safety and security practices. The frequency of inspections is specified in IMC 2800, Materials Inspection Program, and is dependent on the amount and type of radioactive material, the type of operation licensed, and the results of previous inspections. There must be a capability for maintaining and retrieving statistical data on the status of the inspection program.
Illinois Draft IMPEP Report Page 4
- a. Scope
The team used the guidance in SA-101, Reviewing the Common Performance Indicator:
Status of the Materials Inspection Program, and evaluated Illinois performance with respect to the following performance indicator objectives:
Initial inspections and inspections of Priority 1, 2, and 3 licensees are performed at the prescribed frequencies (https://www.nrc.gov/materials/miau/mat-toolkits.html).
Deviations from inspection schedules are normally coordinated between technical staff and management.
There is a plan to perform any overdue inspections and reschedule any missed or deferred inspections or a basis has been established for not performing any overdue inspections or rescheduling any missed or deferred inspections.
Candidate licensees working under reciprocity are inspected in accordance with the criteria prescribed in IMC 2800 and other applicable guidance or compatible Agreement State Procedure.
Inspection findings are communicated to licensees in a timely manner (30 calendar days, or 45 days for a team inspection), as specified in IMC 0610, Nuclear Material Safety and Safeguards Inspection Reports.
- b. Discussion
Illinois performed a total of 392 inspections during the review period, of which 357 were Priority 1, 2, 3, and 35 were initial inspections. Of the 392 total inspections, 37 or 9.7 percent were performed overdue. The team found that the overdue inspections were directly related to staffing challenges in the first two years of the review period. It took Illinois time to hire staff, get them fully trained and catch up on inspections that went overdue during that time. The team found that 34 of the 37 inspections performed overdue during this review period occurred during those first two years and those numbers have dramatically declined once new inspectors were hired and staffing was stabilized. The team noted that in 2020, there were no overdue inspections, one overdue inspection in 2021, and two overdue inspections in 2022. The overdue inspections in 2022 were directly related to a change in use codes for two licensees which caused them to immediately go overdue once applied. At the time of review, there were no overdue inspections. The team found that Illinois inspection frequencies were the same or more frequent for similar license types in IMC 2800. The team evaluated a sampling of 22 inspection reports and found that no inspection findings were communicated past the 30-day goal.
During this review period, Illinois focused available staffing resources on performing Priority 1, 2, and 3 inspections. During the beginning of this review period when staffing was in transition, Illinois developed a blended procedure requiring the inspection of 10 percent of all candidates eligible for inspection, with an emphasis of inspecting risk-significant licensees. Illinois performed 11 percent of reciprocity inspections in 2018, 10 percent in 2019, 15 percent in 2020, 15 percent in 2021, and 23 percent in 2022. The team confirmed that Illinois complied with their reciprocity procedure.
The pandemic had negligible impact on Illinois ability to perform inspections. In March of 2020, at the beginning of the pandemic, Illinois developed a blended procedure combining the use of virtual and on-site inspections. On-site inspections were completed within 30-60 days following the virtual portion of the inspection. Using this method, Illinois completed 28 blended inspections during this period with no inspections performed overdue.
Illinois Draft IMPEP Report Page 5
- c. Evaluation
The team determined that, during the review period, Illinois met the performance indicator objectives listed in Section 3.2.a. Based on the criteria in MD 5.6, the team recommends that Illinoiss performance with respect to the indicator, Status of Materials Inspection Program, be found satisfactory.
- d. MRB Chairs Determination
The final report will present the MRB Chairs determination regarding this indicator.
3.3 Technical Quality of Inspections
Inspections, both routine and reactive, provide reasonable assurance that licensee activities are carried out in a safe and secure manner. Accompaniments of inspectors performing inspections and the critical evaluation of inspection records are used to assess the technical quality of an inspection program.
- a. Scope
The team used the guidance in SA-102, Reviewing the Common Performance Indicator:
Technical Quality of Inspections, and evaluated Illinois performance with respect to the following performance indicator objectives:
Inspections of licensed activities focus on health, safety, and security.
Inspection findings are well-founded and properly documented in reports.
Management promptly reviews inspection results.
Procedures are in place and used to help identify root causes and poor licensee performance.
Inspections address previously identified open items and violations.
Inspection findings lead to appropriate and prompt regulatory action.
Supervisors, or senior staff as appropriate, conduct annual accompaniments of each inspector to assess performance and assure consistent application of inspection policies.
For Programs with separate licensing and inspection staffs, procedures are established and followed to provide feedback information to license reviewers.
Inspection guides are compatible with NRC guidance.
An adequate supply of calibrated survey instruments is available to support the inspection program.
- b. Discussion
The team evaluated 22 inspection reports, enforcement documentation, and interviewed inspectors involved in materials inspections conducted during the review period. The team reviewed casework for inspections conducted by 11 current and former Illinois inspectors and covered medical, industrial, commercial, academic, research, and service provider licenses.
The team completed seven in-person materials inspector accompaniments between September 2022 and January 2023. The team found that the seven inspectors were well-prepared, thorough in their evaluation of each licensee, and assessed the impact of licensed activities on health, safety, and security. Inspectors observed the use of Illinois Draft IMPEP Report Page 6
radioactive materials whenever possible. During interviews of licensee staff, inspectors used open-ended questions, and were able to develop a basis of confidence that radioactive materials were being used safely and securely. Any findings observed were brought to the licensee staff members attention at the time of the inspection and again to the licensees management during the inspection exit meeting. All findings and conclusions were well-founded and appropriately documented. The inspector accompaniments are identified in Appendix B.
The team also found that supervisory accompaniments were performed annually for all qualified inspectors, who performed inspections during each year of the review period.
The team identified that Illinois inspection results were well documented, and violations were well supported. Illinois followed its own documented inspection and enforcement procedures. The team reviewed the Illinois inspection procedures and found them to be compatible with NRC inspection procedures.
The team noted that Illinois maintained sufficient radiation survey meters such as Geiger-Mueller meters, scintillation detectors, ion chambers, micro-R meters, and neutron detectors to support itss inspection program. The portable instruments used during the inspector accompaniments were operational, calibrated, and were appropriate for the types of licensed activities inspected.
- c. Evaluation
The team determined that, during the review period, Illinois met the performance indicator objectives listed in Section 3.3.a. Based on the criteria in MD 5.6, the team recommends that Illinois performance with respect to the indicator, Technical Quality of Inspections be found satisfactory.
- d. MRB Chairs Determination
The final report will present the MRB Chairs determination regarding this indicator.
3.4 Technical Quality of Licensing Actions
The quality, thoroughness, and timeliness of licensing actions can have a direct bearing on public health and safety, as well as security. An assessment of licensing procedures, implementation of those procedures, and documentation of communications and associated actions between the Illinois licensing staff and regulated community is a significant indicator of the overall quality of the licensing program.
- a. Scope
The team used the guidance in SA-104, Reviewing the Common Performance Indicator:
Technical Quality of Licensing Actions, and evaluated Illinois performance with respect to the following performance indicator objectives:
Licensing action reviews are thorough, complete, consistent, and of acceptable technical quality with health, safety, and security issues properly addressed.
Essential elements of license applications have been submitted and elements are consistent with current regulatory guidance (e.g., pre-licensing guidance, Title 10 of the Code of Federal Regulation (10 CFR) Part 37, financial assurance, etc.).
License reviewers, if applicable, have the proper signature authority for the cases Illinois Draft IMPEP Report Page 7
they review independently.
License conditions are stated clearly and can be inspected.
Deficiency letters clearly state regulatory positions and are used at the proper time.
Reviews of renewal applications demonstrate a thorough analysis of a licensees inspection and enforcement history.
Applicable guidance documents are available to reviewers and are followed (e.g., NUREG-1556 series, pre-licensing guidance, regulatory guides, etc.).
Licensing practices for risk-significant radioactive materials are appropriately implemented including the physical protection of Category 1 and Category 2 quantities of radioactive material (10 CFR Part 37 equivalent).
Documents containing sensitive security information are properly marked, handled, controlled, and secured.
- b. Discussion
During the review period, Illinois completed 3,307 radioactive materials licensing actions.
The team evaluated 26 actions including 4 new applications, 11 amendments, 7 renewals, and 4 terminations. The team evaluated the casework of 11 current and former license reviewers which included broad scope, medical diagnostic and therapeutic, accelerator, commercial manufacturing and distribution, industrial radiography, research and development, academic, nuclear pharmacy, gauges, both panoramic and self-shielded irradiators, service providers, financial assurance, and bankruptcy actions.
The team reviewed Illinois procedures, license templates, standard conditions, licensing checklists, and use of databases. Illinois uses the NUREG-1556 series and additional guidance for all license reviews. The Pre-Licensing Guidance and Risk-Significant Radioactive Materials (RSRM) checklists were used for new license requests, change of control, and renewals. The team determined that Illinois completed on-site security reviews for all new license applications, new locations of use authorizations, and possession limit increases that would be identified using the NRCs RSRM checklist and was compatible with the NRCs requirements. The team noted that Illinois performed pre-licensing visits on all new licenses and transfers of control. The team found that all documents containing sensitive security related or protected information were properly marked and secured in accordance with their procedures for controlling sensitive information.
The team observed that Illinois use of comprehensive checklists for its licensing actions assured that licensing decisions were well-documented, and properly addressed health, safety, and security issues. The team observed that Illinois adequately considered the licensees inspection and enforcement history in completing renewals. For all actions, secondary level reviews were performed by the Licensing Unit Supervisor. Peer reviews of licensing actions and the consistent use of checklists helped ensure the technical quality of the actions.
In response to the pre-IMPEP questionnaire, Illinois identified 25 renewal applications that were pending for more than a year. The team found that the backlog of renewals was due to the staffing issues experienced by the program at the beginning of the review period. The backlog has been declining and Illinois has made eliminating the outstanding license renewals a priority.
The team would like to highlight and acknowledge the following two efforts as good practices which will be shared with the NMP, if the MRB Chair agrees:
Illinois Draft IMPEP Report Page 8
To better track and streamline licensing actions, Illinois implemented a licensing process to better apply resources and reduce the workload on the licensing staff.
The team noted that Illinois leveraged newer Microsoft applications (TEAMS, Power BI, and Power Query) to integrate with existing databases and display a live-time dashboard of outstanding licensing actions. Succinct information could be displayed on the days in house, assigned reviewer, status, as well as the nature and date of last contact with the licensee. This affords not only a caseload management tool for reviewers, but a dynamic supervisory tool to instantly assess progress on aging actions. This effort is being expanded to several other performance indicators allowing Illinois to better manage its program.
Illinois has begun to develop state-specific versions of the NUREG-1556 series volumes. Specifically, Illinois license reviewers used license applications and authorized user forms specific to these areas of authorized use (i.e., medical, portable gauges, radiography, etc.). The tailored applications clearly request the needed information identified in the Illinois-specific guidance from the licensee. Staff and program performance metrics indicated the quality of submittals has improved as a result. Additionally, it was noted that the amount of correspondence required decreased, and the average completion time of licensing actions steeply declined.
- c. Evaluation
The team determined that, during the review period, Illinois met the performance indicator objectives listed in Section 3.4.a. Based on the criteria in MD 5.6, the team recommends that Illinoiss performance with respect to the indicator, Technical Quality of Licensing Actions, be found satisfactory.
- d. MRB Chairs Determination
The final report will present the MRB Chairs determination regarding this indicator.
3.5 Technical Quality of Incident and Allegation Activities
The quality, thoroughness, and timeliness of response to incidents and allegations of safety concerns can have a direct bearing on public health, safety, and security. An assessment of incident response and allegation investigation procedures, actual implementation of these procedures internal and external coordination, timely incident reporting, and investigative and follow-up actions, are a significant indicator of the overall quality of the incident response and allegation programs.
- a. Scope
The team used the guidance in SA-105, Reviewing the Common Performance Indicator:
Technical Quality of Incident and Allegation Activities, and evaluated Illinois performance with respect to the following performance indicator objectives:
Incident response and allegation procedures are in place and followed.
Response actions are appropriate, well-coordinated, and timely.
On-site responses are performed when incidents have potential health, safety, or security significance.
Appropriate follow-up actions are taken to ensure prompt compliance by licensees.
Follow-up inspections are scheduled and completed, as necessary.
Illinois Draft IMPEP Report Page 9
Notifications are made to the NRC Headquarters Operations Center for incidents requiring a 24-hour or immediate notification to the Agreement State or NRC.
Incidents are reported to the Nuclear Material Events Database (NMED) and closed when all required information has been obtained.
Allegations are investigated in a prompt, appropriate manner.
Concerned individuals are notified within 30 days of investigation conclusions.
Concerned individuals identities are protected, as allowed by law.
- b. Discussion
During the review period, 104 incidents were reported to the NMED database by Illinois.
The team evaluated 20 of the more RSRM incidents which included pool irradiator mechanical issues, lost packages, radiography source disconnects, damaged equipment, medical events, and potential personnel exposures. Illinois dispatched inspectors for on-site follow-up for each of the cases reviewed. The team found that Illinois evaluation of incidents and their response to those incidents was timely, thorough, well balanced, complete, and comprehensive. The team found that Illinois procedures for incident and allegation reviews were compatible with NRC procedures.
The team evaluated Illinois reporting of incidents to the NRCs Headquarters Operations Center (HOC). The team noted that in each case requiring HOC notification, Illinois reported the incidents within the required time frame. The team also evaluated whether Illinois missed making a required report to the HOC. The team did not identify any missed reporting requirements.
During the review period, 16 allegations were received by Illinois. The team evaluated all 16 allegations, including 12 allegations received directly and 4 referred by the NRC. The team found that Illinois took prompt and appropriate action in response to the concerns raised. Documentation for each allegation reviewed was complete, concise, and thorough. Concerned individuals were notified within 30 days of the conclusion of the investigation whenever possible. Individuals identities were protected in accordance with state law.
- c. Evaluation
The team determined that, during the review period, Illinois met the performance indicator objectives listed in Section 3.5.a. Based on the criteria in MD 5.6, the team recommends that Illinois performance with respect to the indicator, Technical Quality of Incident and Allegation Activities, be found satisfactory.
- d. MRB Chairs Determination
The final report will present the MRB Chairs determination regarding this indicator.
4.0 NON-COMMON PERFORMANCE INDICATORS
Four non-common performance indicators are used to review Agreement State programs: (1) Legislation, Regulations, and Other Program Elements; (2) SS&D Evaluation Program; (3) LLRW Disposal Program; and (4) Uranium Recovery Program.
The NRC relinquished regulatory authority for these non-common performance indicators and all four were reviewed by the IMPEP team.
Illinois Draft IMPEP Report Page 10
4.1 Legislation, Regulations, and Other Program Elements
State statutes should authorize the State to establish a program for the regulation of agreement material and provide authority for the assumption of regulatory responsibility under the States agreement with the NRC. The statutes must authorize the State to promulgate regulatory requirements necessary to provide reasonable assurance of adequate protection of public health, safety, and security. The State must be authorized through its legal authority to license, inspect, and enforce legally binding requirements, such as regulations and licenses. The NRC regulations that should be adopted by an Agreement State for purposes of compatibility or health and safety should be adopted in a time frame so that the effective date of the State requirement is not later than 3 years after the effective date of the NRC's final rule. Other program elements that have been designated as necessary for maintenance of an adequate and compatible program should be adopted and implemented by an Agreement State within 6 months following NRC designation. A Program Element Table indicating the Compatibility Categories for those program elements other than regulations can be found on the NRC Web site at the following address: https://scp.nrc.gov/regtoolbox.html.
- a. Scope
The team used the guidance in SA-107, Reviewing the Non-Common Performance Indicator: Legislation, Regulations, and Other Program Elements, and evaluated Illinois performance with respect to the following performance indicator objectives. A complete list of regulation amendments can be found on the NRC website at the following address: https://scp.nrc.gov/regtoolbox.html.
The Agreement State program does not create conflicts, duplications, gaps, or other conditions that jeopardize an orderly pattern in the regulation of radioactive materials under the Atomic Energy Act of 1954, as amended.
Regulations adopted by the Agreement State for purposes of compatibility or health and safety were adopted no later than 3 years after the effective date of the NRC regulation.
Other program elements, as defined in SA-200, Compatibility Categories and Health and Safety Identification for NRC Regulations and Other Program Elements that have been designated as necessary for maintenance of an adequate and compatible program, have been adopted and implemented within 6 months of NRC designation.
The State statutes authorize the State to establish a program for the regulation of agreement material and provide authority for the assumption of regulatory responsibility under the agreement.
The State is authorized through its legal authority to license, inspect, and enforce legally binding requirements such as regulations and licenses.
Sunset requirements, if any, do not negatively impact the effectiveness of the States regulations.
- b. Discussion
Illinois became an Agreement State on May 14, 1987. The Illinois Agreement State statutory authority is contained in the Radiation Protection Act of 1990, of the Illinois Statutes. The Office of Nuclear Safety within the Illinois Emergency Management Agency and Office of Homeland Security is designated as the States radiation control agency. The following legislation affecting the radiation control program was passed during the review period.
Illinois Draft IMPEP Report Page 11
Illinois Emergency Management Agency Act [20 ILCS 3305/] -- AMENDED.
Nuclear Safety Law of 2004 [20 ILCS 3310/] -- AMENDED.
Radiation Protection Act of 1990 [420 ILCS 40/] -- AMENDED.
Uranium and Thorium Mill Tailings Control Act [420 ILCS 42/]
Illinois LLRW Management Act [420 ILCS 20/]
Radioactive Waste Compact Enforcement Act [45 ILCS 141/]
Radioactive Waste Tracking and Permitting Act [420 ILCS 37/]
Radioactive Waste Storage Act [420 ILCS 35/]
Illinois Administrative Procedure Act [5 ILCS 100/] -- AMENDED.
Freedom of Information Act [5 ILCS 140/] - AMENDED.
The amendments were to meet compatibility requirements and address technical issues.
None had a negative impact on the program.
Illinois administrative rulemaking process takes approximately 18 months from drafting to finalizing a rule. The public, NRC, other agencies, and potentially impacted licensees and registrants are offered an opportunity to comment during the process. Comments are considered and incorporated, as appropriate, before the regulations are finalized and approved by the Joint Commission on Administrative Rules. The team noted that the States rules and regulations are subject to sunset laws.
During the review period, Illinois submitted 11 proposed regulation amendments, 8 final regulation amendments, and no legally binding requirements or license conditions to the NRC for a compatibility review. The team noted that during the review period, none of the proposed regulations were submitted late and no amendments were overdue for State adoption at the time of the review.
- c. Evaluation
The team determined that, during the review period, Illinois met the performance indicator objectives listed in Section 4.1.a. Based on the criteria in MD 5.6, the team recommends that Illinois performance with respect to the indicator, Legislation, Regulations, and Other Program Elements, be found satisfactory.
- d. MRB Chairs Determination
The final report will present the MRB Chairs determination regarding this indicator.
4.2 SS&D Evaluation Program
Adequate technical evaluations of SS&D designs are essential to ensure that SS&Ds will maintain their integrity and that the design is adequate to protect public health and safety. NUREG-1556, Volume 3, Consolidated Guidance about Materials Licenses:
Applications for Sealed Source and Device Evaluation and Registration, provides information on conducting the SS&D reviews and establishes useful guidance for teams.
In accordance with MD 5.6, three sub-elements: Technical Staffing and Training, Technical Quality of the Product Evaluation Program, and Evaluation of Defects and Incidents Regarding SS&Ds, are evaluated to determine if the SS&D program is satisfactory. Agreement States with authority for SS&D evaluation programs who are not performing SS&D reviews are required to commit in writing to having an SS&D evaluation program in place before performing evaluations.
Illinois Draft IMPEP Report Page 12
- a. Scope
The team used the guidance in SA-108, Reviewing the Non-Common Performance Indicator: Sealed Source and Device Evaluation Program, and evaluated Illinois performance with respect to the following performance indicator objectives:
Technical Staffing and Training
A well-conceived and balanced staffing strategy has been implemented throughout the review period.
Qualification criteria for new technical staff are established and are being followed or qualification criteria will be established if new staff members are hired.
Any vacancies, especially senior-level positions, are filled in a timely manner.
Management is committed to training and staff qualification.
Individuals performing SS&D evaluation activities are adequately qualified and trained to perform their duties.
SS&D reviewers are trained and qualified in a reasonable period of time.
Technical Quality of the Product Evaluation Program
SS&D evaluations are adequate, accurate, complete, clear, specific, and consistent with the guidance in NUREG-1556, Volume 3.
Evaluation of Defects and Incidents
SS&D incidents are reviewed to identify possible manufacturing defects and the root causes of these incidents.
Incidents are evaluated to determine if other products may be affected by similar problems. Appropriate action and notifications to the NRC, Agreement States, and others, as appropriate, occur in a timely manner.
- b. Discussion
Technical Staffing and Training
Illinois had four staff qualified to perform primary SS&D reviews with two of these staff members in training to perform concurrence reviews. During the review period, two SS&D staff members left the program, and two staff members were hired. When a vacancy did occur, Illinois had a license reviewer begin training to become an SS&D reviewer. Illinois does have a training program equivalent to NRCs IMC 1248, Appendix D.
Technical Quality of the Product Evaluation
Illinois had seven SS&D licensees and two custom registrations. The team evaluated 8 of 12 SS&D actions processed during the review period. These actions included amendments, new applications, and inactivations. The team noted that evaluations were adequate, accurate, complete, clear, specific, and consistent with the guidance in NUREG-1556, Volume 3.
Illinois Draft IMPEP Report Page 13
Evaluation of Defects and Incidents Regarding SS&Ds
The team evaluated the only incident involving SS&D registered products during the review period. The incident was related to devices manufactured overseas and distributed by a licensee with a SS&D registered by Illinois. The overseas manufacturer began placing sealed sources that were not authorized by the SS&D registration into the devices without notifying the Illinois distributor. The distributors quality assurance program did not catch the mistake for eight years. The overseas manufacturer also compressed the lead source holder so that it would flow around the sealed source holder. This was done because neither the sealed source authorized by the registration, nor the sources used by the manufacturer, would fit into the source holder. Once notified, Illinois performed a thorough investigation of the event and worked to determine whether this situation could also affect other devices distributed by other companies.
After consultation with the overseas manufacturer, it was determined that this situation was limited to these models distributed by the Illinois distributor. There were no safety impacts on these devices. The radiation profiles of both sealed source models were compared and were the same. From a functional standpoint, there was no difference between these sealed source models. There were three corrective actions: 1) The manufacturer implemented a new procedure to screen the sources placed in the device so that all sealed sources installed into these devices would fit into the source holder. 2)
The Illinois distributors Quality Assurance and Control Program had been updated to ensure more oversight for potential changes to the device by the foreign manufacturers and 3) Illinois updated the SS&D registration to include the new sealed source.
- c. Evaluation
The team determined that, during the review period, Illinois met the performance indicator objectives listed in Section 4.2.a. Based on the criteria in MD 5.6, the team recommends that Illinois performance with respect to the indicator, SS&D Evaluation Program, be found satisfactory.
- d. MRB Chairs Determination
The final report will present the MRB Chairs determination regarding this indicator.
4.3 LLRW Disposal Program
The objective is to determine if Illinois LLRW disposal program is adequate to protect public health and safety, and the environment. Five sub-elements are used to make this determination: (1) Technical Staffing and Training; (2) Status of LLRW Inspection Program; (3) Technical Quality of Inspections; (4) Technical Quality of Licensing Actions; and (5) Technical Quality of Incident and Allegation Activities.
- a. Scope
The team used the guidance in SA-109, Reviewing the Non-Common Performance Indicator: Low-Level Radioactive Waste Disposal Program, and evaluated Illinois performance with respect to the following performance indicator objectives:
Technical Staffing and Training
Qualified and trained technical staff are available to license, regulate, control, inspect, and assess the operation and performance of the LLRW disposal facility.
Illinois Draft IMPEP Report Page 14
Qualification criteria for new LLRW technical staff are established and are followed or qualification criteria will be established if new staff members are hired.
Any vacancies, especially senior-level positions, are filled in a timely manner.
There is a balance in staffing the LLRW licensing and inspection programs.
Management is committed to training and staff qualification.
Individuals performing LLRW licensing and inspection activities are adequately qualified and trained to perform their duties.
LLRW license reviewers and inspectors are trained and qualified in a reasonable period of time.
Status of LLRW Inspection Program
The LLRW facility is inspected at prescribed frequencies.
Statistical data on the status of the inspection program are maintained and can be retrieved.
Deviations from inspection schedules are coordinated between LLRW technical staff and management.
There is a plan to perform any overdue inspections and reschedule any missed or deferred inspections; or a basis has been established for not performing any overdue inspections or rescheduling any missed or deferred inspections.
Inspection findings are communicated to licensees in a timely manner.
Technical Quality of Inspections
Inspections of LLRW licensed activities focus on health, safety, and security.
Inspection findings are well-founded and properly documented in reports.
Management promptly reviews inspection results.
Procedures are in place and used to help identify root causes and poor licensee performance.
Inspections address previously identified open items, non-compliances, and violations.
Inspection findings lead to appropriate and prompt regulatory action.
Supervisors, or senior staff as appropriate, conduct annual accompaniments of each LLRW inspector to assess performance and assure consistent application of inspection policies.
Inspection guides are consistent with NRC guidance.
An adequate supply of calibrated survey instruments is available to support the inspection program.
Technical Quality of Licensing Actions
Licensing action reviews are thorough, complete, consistent, and of acceptable technical quality with health, safety, and security issues properly addressed.
Applicable LLRW guidance documents are available to reviewers and are followed.
Essential elements of license applications have been submitted and elements are consistent with current NRC or Agreement State regulatory guidance for describing the isotopes and quantities used, qualifications of authorized users, facilities, equipment, locations of use, operating and emergency procedures, and any other requirements necessary to ensure an adequate basis for the licensing action.
LLRW license reviewers, if applicable, have the proper signature authority for the cases they review independently.
License tie-down conditions are stated clearly and can be inspected.
Illinois Draft IMPEP Report Page 15
Deficiency letters clearly state regulatory positions and are used at the proper time.
Reviews of renewal applications demonstrate a thorough analysis of a licensees inspection and enforcement history.
Licensing practices for risk-significant radioactive materials are appropriately implemented including fingerprinting orders (10 CFR Part 37 equivalent).
Documents containing sensitive security information are properly marked, handled, controlled, and secured.
Technical Quality of Incident and Allegation Activities
LLRW incident response, and allegation procedures are in place and followed.
Response actions are appropriate, well-coordinated, and timely.
On-site responses are performed when incidents have potential health, safety, or security significance.
Appropriate follow-up actions are taken to ensure prompt compliance by licensees.
Follow-up inspections are scheduled and completed, as necessary.
Notifications are made to the NRC HOC for incidents requiring a 24-hour or immediate notification to the Agreement State or NRC.
Incidents are reported to the NMED and closed when required information is obtained.
Allegations are investigated in a prompt, appropriate manner.
Concerned individuals are notified of investigation conclusions.
Concerned individuals identities are protected, as allowed by law.
- b. Discussion
Historical Background Information
The Sheffield LLRW disposal site is located approximately three miles southwest of the town of Sheffield in Bureau County, Illinois. The facility began disposing LLRW in 1967 and closed in 1978 upon reaching capacity. The Sheffield LLRW disposal site includes 3.2 million cubic feet of LLRW buried in 21 shallow earthen trenches on 20.4 acres.
Illinois began conducting an environmental monitoring program at the LLRW site in 1967. Between 1967 and 1980, the Illinois Department of Public Health (IDPH) was responsible. Since October 1980, Illinois Emergency Management Agency (IEMA);
formerly the Illinois Department of Nuclear Safety (IDNS), managed the monitoring program. Results of monitoring conducted between 1967 and 1988 were reported by IDNS in February 1991 (IDNS 1991), and the results of monitoring during 1989 and 1990 were reported in June 1992 (IDNS 1992). The June 1992 report also described features of the site, including meteorological and hydrological factors, which control the concentrations of radioactive contaminants in ground and surface water.
Since disposal of LLRW took place in earthen trenches, the major monitoring effort had been directed toward detecting radioactive contamination of groundwater. Samples were analyzed for a variety of radionuclides. These radionuclides may emit alpha particles, beta particles, and/or gamma rays. The type of radioactive emission determines the type of analysis required to detect a radionuclide.
The performance of a LLRW disposal site has been measured by its ability to isolate the radioactive waste from the surrounding environment. The environmental monitoring program at the Sheffield LLRW disposal site was designed to evaluate the sites performance as defined above by monitoring radionuclide movement, or lack thereof, Illinois Draft IMPEP Report Page 16
away from the site and into pathways of possible human exposure.
The LLRW disposal site regulated by IEMA is unique because in 1979, the site operator, US Ecology, attempted to abandon the LLRW disposal site, unilaterally terminating its NRC and IDPH licenses and state lease. This led to investigations which revealed that there were faulty trench caps. Both state and federal regulators objected to the unilateral terminations, arguing that the site operator must first safely close the site before terminating either of the licenses. This resulted in both federal and state litigation. The federal litigation was administratively argued before the Atomic Safety and Licensing Board, which eventually ruled against the operator on all counts. Illinoiss complaint was argued before the Bureau County Circuit Court. After ten years of negotiations, in May 1988, Illinois and US Ecology came to an agreement and the litigation was resolved in the form of a settlement agreement known as the Sheffield Agreed Order. The Sheffield Agreed Order sets the provisions for the regulatory oversight at the Sheffield LLRW disposal site.
Technical Staffing and Training
Illinois had six qualified LLRW inspectors. However, two weeks prior to the IMPEP review, one inspector transferred to another division within the agency resulting in one new current vacancy. Illinois began recruiting for a replacement.
The team found that Illinois training and qualification program was compatible with the NRCs IMC 1248. The team evaluated the training program and found an organized and well documented program. Each inspector had an individual training and development plan similar to IMC1248 Appendix E.
Status of LLRW Disposal Inspection Program
Illinois performed four quarterly inspections each year of the review period for the Sheffield LLRW disposal site. Each of the inspections were performed timely and the reports were well documented. Additionally, Illinois also had a site contractor who performed daily inspections at the Sheffield LLRW disposal site. The team reviewed each of the inspection reports as well as each annual radiological environmental monitoring report. The quarterly reports were used to develop the annual Radiological Environmental Monitoring Report for Sheffield LLRW disposal site.
The team found that Illinois performed LLRW inspections more frequently than the NRCs inspection frequency. Although this is not a typical licensee regulatory relationship, Illinois makes the Sheffield annual reports publicly available for all stakeholders.
Technical Quality of Inspections
On April 6, 2023, the team accompanied two inspectors at the Sheffield LLRW disposal site. Under the Sheffield Agreed Order, the inspection involved site security, environmental monitoring, well sampling, postings, and radiation monitoring. The team found that the inspectors were well-prepared, thorough in their evaluation, and assessed the impact of licensed activities with respect to public health and safety, as well as protection of the environment. Inspectors were observed collecting air and environmental samples, touring well locations, and visually inspecting the cap. All findings and conclusions were well-founded and appropriately documented. The inspector accompaniments are identified in Appendix B.
Illinois Draft IMPEP Report Page 17
The team evaluated five inspection files and four radiological environmental monitoring reports which included, hydrogeological, radiological, security, and environmental hazards. The team determined that the inspection reports were thorough, complete, consistent, and had sufficient documentation to ensure that the site performance with respect to health, safety and security was acceptable. The findings were well-founded, supported by regulations, and were appropriately documented.
Technical Quality of Licensing Actions
There were no licensing actions during the review period. There were no changes made to the Sheffield Agreed Order since it was issued.
Technical Quality of Incident and Allegation Activities
There were no incidents or allegations that occurred during the review period or for several years prior to the review period, including any referred by the NRC involving the Illinois LLRW program. The team noted that Illinois LLRW staff follows the procedures established by the radioactive materials program for the handling, review, analysis, response and follow-up of incidents and allegations.
- c. Evaluation
The team determined that, during the review period, Illinois met the performance indicator objectives listed in Section 4.3.a. Based on the criteria in MD 5.6, the team recommends that Illinois performance with respect to the indicator, LLRW Disposal Program, be found satisfactory.
- d. MRB Chairs Determination
The final report will present the MRB Chairs determination regarding this indicator.
4.4 Uranium Recovery Program
The objective is to determine if Illinois uranium recovery Program is adequate to protect public health and safety, and the environment. Five sub-elements are used to make this determination: (1) Technical Staffing and Training; (2) Status of Uranium Recovery Inspection Program; (3) Technical Quality of Inspections; (4) Technical Quality of Licensing Actions; and (5) Technical Quality of Incident and Allegation Activities.
- a. Scope
The team used the guidance in SA-110, Reviewing the Non-Common Performance Indicator: Uranium Recovery Program, and evaluated Illinois performance with respect to the following performance indicator objectives:
Technical Staffing and Training
Qualified and trained technical staff are available to license, regulate, control, inspect, and assess the operation and performance of the uranium recovery program.
Qualification criteria for new uranium recovery technical staff are established and are being followed or qualification criteria will be established if new staff members are Illinois Draft IMPEP Report Page 18
hired.
Any vacancies, especially senior-level positions, are filled in a timely manner.
There is a balance in staffing the uranium recovery licensing and inspection programs.
Management is committed to training and staff qualification.
Individuals performing uranium recovery licensing and inspection activities are adequately qualified and trained to perform their duties.
Uranium recovery license reviewers and inspectors are trained and qualified in a reasonable period of time.
Status of Uranium Recovery Inspection Program
The uranium recovery facility is inspected at prescribed frequencies.
Statistical data on the status of the inspection program are maintained and can be retrieved.
Deviations from inspection schedules are coordinated between uranium recovery technical staff and management.
There is a plan to perform any overdue inspections and reschedule any missed or deferred inspections; or a basis has been established for not performing overdue inspections or rescheduling any missed or deferred inspections.
Inspection findings are communicated to licensees in a timely manner.
Technical Quality of Inspections
Inspections of uranium recovery licensed activities focus on health, safety, and security.
Inspection findings are well-founded and properly documented in reports.
Management promptly reviews inspection results.
Procedures are in place and used to help identify root causes and poor licensee performance.
Inspections address previously identified open items, non-compliance, and violations.
Inspection findings lead to appropriate and prompt regulatory action.
Supervisors, or senior staff as appropriate, conduct annual accompaniments of each uranium recovery inspector to assess performance and assure consistent application of inspection policies.
Inspection guides are consistent with NRC guidance.
An adequate supply of calibrated survey instruments is available to support the inspection program.
Technical Quality of Licensing Actions
Licensing action reviews are thorough, complete, consistent, and of acceptable technical quality with health, safety, and security issues properly addressed.
Applicable uranium recovery guidance documents are available to reviewers and are followed.
Essential elements of license applications have been submitted and meet current NRC or Agreement State regulatory guidance (e.g., financial assurance, etc.).
Uranium recovery license reviewers, if applicable, have the proper signature authority for the cases they review independently.
License conditions are stated clearly and can be inspected.
Deficiency letters clearly state regulatory positions and are used at the proper time.
Illinois Draft IMPEP Report Page 19
Reviews of renewal applications demonstrate a thorough analysis of a licensees inspection and enforcement history.
Licensing practices for risk-significant radioactive materials are appropriately implemented including fingerprinting orders (10 CFR Part 37 equivalent).
Documents containing sensitive security information are properly marked, handled, controlled, and secured.
Technical Quality of Incident and Allegation Activities
Uranium recovery incident response, investigation, and allegation procedures are in place and followed.
Response actions are appropriate, well-coordinated, and timely.
On-site responses are performed when incidents have potential health, safety, or security significance.
Appropriate follow-up actions are taken to ensure prompt compliance by licensees.
Follow-up inspections are scheduled and completed, as necessary.
Notifications are made to the NRC HOC for incidents requiring a 24-hour or immediate notification to the Agreement State or the NRC.
Incidents are reported to the NMED and closed when required information is obtained.
Allegations are investigated in a prompt, appropriate manner.
Concerned individuals are notified of investigation conclusions.
Concerned individuals identities are protected, as allowed by law.
- b. Discussion
The Kerr-McGee West Chicago Rare Earth facility located approximately 30 miles west of Chicago, Illinois, conducted manufacturing operations involving radioactive materials from 1932 to 1973. During its operational period, various chemical processes were used to extract thorium and rare earth compounds from monazite ore. During late 1930s and early 1940s radium-228 was produced at the facility and used in the production of luminous dials. Under contract with the U.S. Atomic Energy Commission, thorium nitrate was produced from 1954 through 1963 at the site. In 1964, monazite operations were resumed and for a short period of time the site also processed bastnaesite, a rare earth fluorocarbonate, a material which contained no thorium. Kerr-McGee operated the site for a short period between 1967 and 1973 under license from the NRC, previously the Atomic Energy Commission. From 1932 to 1973, thorium was produced at the facility for commercial purposes and for the U.S. Department of Energy. In September 1993, Kerr-McGee submitted a license application to the IEMA to decommission the facility. In February of 1994, IEMA approved Kerr-McGees license application for decommissioning of the facility. In 2004, Kerr-McGee created Tronox, LLC, as a subsidiary company. Tronox, LLC subsequently filed for bankruptcy in 2009. As the result of this bankruptcy, the settlement agreement created the West Chicago Environmental Response Trust. Weston Solutions Inc. was chosen by the trust beneficiaries as the Trustee. IEMA then issued a radioactive material license to Weston Solutions Inc. The soil remediation/surface cleanup at the facility was completed at the end of 2015. All waste from the site has been shipped for disposal and no waste was disposed of at the facility. IEMAs primary focus is on groundwater remediation.
In May 2021, IEMA discussed facility license termination options with the NRC. A subsequent meeting was conducted in June 2021. IEMA provided the NRC with a detailed license and facility status report which summarized all contaminated structures and soil had been remediated to meet site cleanup criteria, that all contaminated soils Illinois Draft IMPEP Report Page 20
had been shipped off-site for disposal, and that the only remaining issue was groundwater contamination. NRC informed IEMA that since the facility had been completely remediated and the resulting waste had been shipped for disposal, the site should now be considered a complex material decommissioning facility and the license should be terminated in accordance with 10 CFR 20.1403, Criteria for License Termination Under Restricted Conditions. Furthermore, the NRC also required IEMA to submit a Completion Report Review to the NRC for review prior to license termination with restricted conditions.
Because of this NRC determination, the team recommends that this facility no longer be reviewed as a uranium recovery site and be reviewed as a complex decommissioning facility under the Technical Quality of Licensing Actions performance indicator for future IMPEP reviews until final closure of the site has occurred.
The team completed one in-person uranium recovery inspector accompaniment on April 20, 2023. The team found that the inspector was well-prepared and provided a presentation on the sites history including the surface clean up and the current status of the site. The inspector was thorough in his evaluation of the license and assessed the impact of licensed activities on health, safety, and security. The inspector accompaniments are identified in Appendix B.
- c. Evaluation
The team determined that, during the review period, Illinois met the performance indicator objectives listed in Section 4.4.a. Based on the criteria in MD 5.6, the team recommends that Illinois performance with respect to the indicator, Uranium Recovery Program, be found satisfactory.
- d. MRB Chairs Determination
The final report will present the MRB Chairs determination regarding this indicator.
5.0
SUMMARY
As noted in Sections 3.0 and 4.0 above, Illinois performance was found to be satisfactory for all performance indicators reviewed. The team would like to highlight and acknowledge the following two efforts as good practices which will be shared with the NMP, if the MRB Chair agrees:
Illinois leveraged newer Microsoft applications (TEAMS, Power BI, and Power Query) to integrate with existing databases and display a live-time dashboard of outstanding licensing actions. Succinct information could be displayed that afforded not only a caseload management tool for reviewers, but a dynamic supervisory tool to instantly assess progress on aging actions.
Illinois has begun to develop state-specific versions of the NUREG-1556 series volumes. Specifically, Illinois license reviewers used license applications and authorized user forms specific to these areas of authorized use (i.e., medical, portable gauges, radiography, etc.). The tailored applications clearly request the needed information identified in the Illinois-specific guidance from the licensee. Staff and program performance metrics indicated the quality of submittals has improved as a result. Additionally, it was noted that the amount of correspondence required decreased, and the average completion time of licensing actions steeply declined.
Illinois Draft IMPEP Report Page 21
Accordingly, the team recommends that Illinois be found adequate to protect public health and safety and compatible with NRCs program. Based on the results of the current IMPEP review, and this was Illinois fourth consecutive IMPEP review with all indicators rated as satisfactory, the team recommends that the next full IMPEP review take place in approximately 5 years, with a periodic meeting in approximately 2.5 years.
LIST OF APPENDICES
Appendix A IMPEP Review Team Members
Appendix B Inspector Accompaniments APPENDIX A
IMPEP REVIEW TEAM MEMBERS
Name Areas of Responsibility
Randy Erickson, Region IV Team Leader Technical Quality of Incident and Allegation Activities Inspector Accompaniments
Darren Piccirillo, Region III Technical Staffing and Training Legislation, Regulations, and Other Program Elements
Craig Sutton, Texas Status of the Materials Inspection Program
Steve Seeger, Tennessee Technical Quality of Inspections
Nancy Stanley, New Jersey Technical Quality of Licensing Actions
Shannon Dettmer, Ohio Sealed Source and Device Evaluation Program
Maurice Heath, NMSS Low-Level Radioactive Waste Disposal Program Inspector Accompaniments
Muhammadali Abbaszadeh, Texas Uranium Recovery Program Inspector Accompaniment APPENDIX B
INSPECTOR ACCOMPANIMENTS
The following inspector accompaniments were performed prior to the on-site IMPEP review:
Accompaniment No.: 1 License No.: IL-02168-01 License Type: Industrial Radiography Priority: 1 Inspection Date: 9/20/2022 Inspectors initials: ZM
Accompaniment No.: 2 License No.: IL-01874-01 License Type: Nuclear Pharmacy Priority: 2 Inspection Date: 10/19/2022 Inspectors initials: TD
Accompaniment No.: 3 License No.: IL-01123-02 License Type: Pool Irradiator Priority: 2 Inspection Date: 11/2/2022 Inspectors initials: JH
Accompaniment No.: 4 License No.: IL-02344-01 License Type: Medical written directive required Priority: 2 Inspection Date: 11/9/2022 Inspectors initials: TL
Accompaniment No.: 5 License No.: IL-01224-02 License Type: Medical written directive required Priority: 3 Inspection Date: 12/1/2022 Inspectors initials: KDV
Accompaniment No.: 6 License No.: IL-01951-01 License Type: Medical no written directive required Priority: 5 Inspection Date: 1/10/2023 Inspectors initials: IG
Accompaniment No.: 7 License No.: IL-01322-01 License Type: Medical written directive required Priority: 3 Inspection Date: 1/12/2023 Inspectors initials: BR
Accompaniment No.: 8 License No.: STA-583 License Type: Complex Decommissioning Site Priority: 5 Inspection Date: 4/20/2023 Inspectors initials: KG
Accompaniment No.: 9 License No.: Agreed Order License Type: LLRW Disposal Site Priority: 1 Inspection Date: 4/6/2023 Inspectors initials: TH
Accompaniment No.: 10 License No.: Agreed Order License Type: LLRW Disposal Site Priority: 1 Inspection Date: 4/6/2023 Inspectors initials: RP