Text

Louisiana Response to Impep Questionnaire
	ML21007A214
Person / Time
Issue date:	01/05/2021
From:	Kathy Modes; NRC/NMSS/DMSST
To:	;
	Modes K
References
	Download: ML21007A214 (22)
	v • d • e

Approved by OMB1 Control No.:

3150-0183 Expires:

02/28/2023 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE Reporting Period: April 2016-January 2021 Note: If there has been no change in the response to a specific question since the last IMPEP questionnaire, the State or Region may copy the previous answer, if appropriate.

A.

GENERAL

1.

Please prepare a summary of the status of the State's or Region's actions taken in response to each of the open recommendations from previous IMPEP reviews.

2016 IMPEP Recommendation: The review team recommends that the Division perform an evaluation to determine the causes for the low staff retention rate and implement corrective actions to mitigate the causes.

During the periodic review, we addressed this recommendation. We conducted interviews and evaluated the statewide salary structure in consultation with human resources to determine the causes for the low staff retention rate. Although we did not produce a written report of their evaluation; ultimately, we reported that the main cause for the low staff retention rate was the staff was overworked and underpaid. We are working to mitigate both aspects of the main cause by trying to increase salaries and reduce workload. The review of the statewide salary structure indicated that we had not taken advantage of the current salary structure such that it benefitted our technical staff. As a result, our staff received a pay raises in January 2018, July 2018, July 2019 and July 2020. We also modified the career ladder by creating two Environmental Scientist 4 (ES-4) positions. Previously, the highest Environmental Scientist position was an ES-3. Two ES-3 staff members were promoted into ES-4 positions. We believe this provides more opportunities for staff to advance and receive higher salaries.

We have decreased workload by reducing the number of internal metrics applied to the licensing and inspection programs. Also, we continued offering workplace flexibilities like telecommuting/work-at-home for one or two days a week to help alleviate the stress of traveling to work every day and allowing staff to focus on the work products without the distractions of the workplace, as well as, helping us attract and retain staff.

Since the periodic review, we have continued to look for ways to reduce unnecessary workload.

Checklists, in place of narratives, have been implemented for several types of inspections. These checklists reduce the time spent on post-inspection workload. Also, peer reviews of licenses and inspections have been eliminated and replaced with manager review, which tremendously cut down on workload. We also funded and filled a Senior Staff Scientist position, which will ensure there is an opportunity for continued advancement for Technical Staff in the future.

2016 IMPEP Recommendation: The review team recommends that the Division implement a procedure that addresses at a minimum, the means for controlling access to documents that contain sensitive information, within the limits of Louisiana regulations.

To address the recommendation, we initially blocke everyones access to license fill except for a few qualified licensing staff immediately after the 2016 IMPEP. Subsequently, the online access to all of the licensing files are blocked. After further discussions with records management and legal staff, access to non-sensitive licensing information was restored to additional Radiation staff. The licensing staff was working with the Departments records management staff to develop a procedure to better control and monitor access to licensee information. Access will be granted to members of the public, as allowed by law, with specific limitations and controls, which includes detailed contact information about the requester.

Sensitive information is not released. Radiation management staff monitors what is released.

Since the periodic review, no Radiation Records are accessible to the public or non-radiation LDEQ employees. The Emergency & Radiological Services Division Administrator, in conjunction with the Agency Records Management Director, maintains a list of approved Agency Staff that have a need for Radiation records access. This list is periodically reviewed for accuracy and modified for permissions as appropriate. The Manager or Licensing Supervisor manages all radiation public records requests. Each record is reviewed and sensitive information, such has inventory, site radioactive materials map, etc. is redacted from the files. For Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material (PPQRM) files, we have created an

electronic filing system called On-Base. On-Base is not available to the public or non-radiation employees within Louisiana Department of Environmental Quality (LDEQ) and therefore cannot have a public records request.

2016 IMPEP Recommendation: The review team recommends that the Division develops and implements a comprehensive incident and allegation procedure, provides incident and allegations training to the staff, and ensures adequate management supervision in the incident and allegation program.

During the periodic review, to address the recommendation, a senior staff scientist reviewed and updated the standard operating procedures (SOPs) for complaints, allegations, and incidents (CAIs). Training was provided to all staff on the SOPs and the expectations for responding to CAIs. In general, when a CAI comes in, it is reviewed for significance by a supervisor, manager, or staff scientist and then dispatched or assigned to an inspector for follow-up and investigation, as appropriate. Once the inspector has completed the investigation, a report is generated and reviewed by our supervisors and management, as well as, the senior staff scientist responsible for closing out the event in NMED. To ensure adequate management oversight of CAIs, ongoing investigations are routinely discussed during inspector huddles to ensure that any issues identified during an investigation are communicated to management, supervisors, and senior staff scientists in a timely manner.

Since the periodic review, the SOP for CAIs has been revised on November 6, 2019, and every two years after, to make it easier for staff to receive and respond to CAIs. Training has been given and continues to be given to staff on updated SOPs. An Online reporting form has been created for anyone that receives a CAIs. Once the on-line form is completed, it is automatically sent to Senior Staff, Manager, Licensing Supervisor, Inspections Supervisor, and LDEQs Single Point of Contact. Senior Staff and Manager review for NRC reporting requirements and Supervisors assign to inspector for investigation.

B.

COMMON PERFORMANCE INDICATORS I.

Technical Staffing and Training

2.

Please provide the following organization charts, including names and positions:

(a)

A chart showing positions from the Governor down to the Radiation Control Program Director; (b)

A chart showing positions of the radiation control program, including management; and (c)

Equivalent charts for sealed source and device evaluation, low-level radioactive waste and uranium recovery programs, if applicable.

See attached organization charts.

Our SSD writers are Jim Pate, Gilberto Cuadra, and Ziad Fahd.

1.)

Jim Pate - can write and review sources and devices.

2.)

Gilberto - he has not been signed off for SSDs. His work is reviewed by Jim Pate and Ziad Fahd.

3.)

Ziad Fahd - he can write and review sources and devices.

3.

Please provide a staffing plan, or complete a listing using the suggested format below, of the professional (technical) full-time equivalents (FTE) applied to the radioactive materials program by individual. Include the name, position, and, for Agreement States, the fraction of time spent in the following areas: administration, materials licensing &

compliance, emergency response, low-level radioactive waste, uranium recovery, other.

If these regulatory responsibilities are divided between offices, the table should be consolidated to include all personnel contributing to the radioactive materials program.

If consultants were used to carry out the program's radioactive materials responsibilities, include their efforts. The table heading should be:

Name Position Area of Effort FTE%

Adminstration:

Jeff Dauzat Administrator 100%

Administration Karen Burgard Manager 75% Admin,20%

Compl, 5% REPR Judy Schuerman Environmental Scientist Senior Regulation Development, Special Projects 80% Regs, 15%

Special Projects, 5% REPR James Pate Environmental Scientist Staff 50%Compl, 20%

Admin, 25%

Hazwpr, 5% REPR Ashley Menard Environmental Scientist Staff 70%Compl,20%

MQSA, 5%Admin, 5% REPR Richard Scott Blackwell Supervisor Licensing &

Registrations, Surveillance, LLW 40% Admin, 20%

Lic & Reg, 20%

Compl, 10% MQSA, 5% REPR, 5% LLW Dwayne Stepter Supervisor Surveillance 50% Compl, 45%

Admin, 5% REPR Licensing &

Registration:

Tiffany White Environmental Scientist 4 Licensing &