ML20056C445

Region V Realignment Study;930610. W/Comments Re Draft Rept

ML20056C445
Person / Time
Issue date:	06/10/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
References
NUDOCS 9306240107
Download: ML20056C445 (141)

Text

v ls

.ik PDR Region V Realignment Study June 10,1993 n

220077 9306240107 930610 O[

REGS SUBJ PDR

5 6.-

Reaion V Realianment Study Table of Contents Paae Executive Summary............................

1 Introduction 11 History /0verview 19 Evaluations of Options 21 Evaluation Summary.........................

21 Option 1..............................

24 Option 2..............................

44 Option 3..............................

54 Option 4..............................

61 Regional Employee Comments 67 Conclusions...............................

70 Recommendations.............................

73 Appendices

1. COMSECY-93-012 75

2. EDO Memorandum of March 30, 1993 76

3. DEDR Memorandum of April 20, 1993................

78

4. FY-95 Budget Baseline. Region V.................

80

5. FY-95 Budget Baseline: Region IV 81

6. Option 1: Region IV.......................

82

7. Summa ry FTE An alys i s.......................

83

8. Option 2: Region V 84.

9. Option 2: Region IV.......................

85.

10. Recurring and One-Time Costs Associated with Options....... 86

11. Option 3: Region IV 87

12. Option 4: Region V.......................

88

13. Option 4: Region IV 89 14.. Region IV Employee Comments 90

15. Region V Employee Comments...................

123

16. Headquarters Office and Regional Administrator Comments 129

s b

REGION V REALIGNMENT STUDY Executive Stanary At the request of the Commission, the Executive Director for Operations established a Study Group to evaluate the feasibility of realignment or elimination of the Region V office in Walnut Creek, California.

Four Options were evaluated:

(1)

Consolidation of Regions IV and V into a single regional office that would be located in Arlington, Texas.

(2)

Reducing Region V to a staff of approximately 25-30 full-time equivalent positions (FTEs) (including residents) focusing on the reactor program.

The remainder of the current reactor program, and all other functions would be. consolidated in Region IV.

(3)

Reducing Region V to a staff of approximately 25-30 FTEs, as above, but the office would be structured as a field office of Region IV, rather than a separate regional office.

(4) Maintaining a Region V office able to administer the reactor-program but transferring the materials, fuel facilities, decommissioning, investigations, and state agreement programs to Region IV.

1

c e

In all cases evaluated, maintaining an organization adequate to protect the public health and safety was the primary consideration.

Differences between Options revolve around cost effectiveness and mission enhancement or degradation issues.

A trend of reduced workload and attendant budget reductions have decreased the size of both of the NRC's two smaller regions, Regions IV and V.

These l

reductions have led to questions of the continued cost effectiveness of maintaining two separate offices. The Fiscal Year 1995 (FY-95) levels of technical resources available for NRC programs in the two regions, while adequate to protect the public health and safety, do not provide as broad a base of technical expertise as is available in the large regions. As a result, it is more difficult to provide the additional regional attention necessary when more than one plant is experiencing problems or when unforeseen events require unplanned resources.

In su.xnary, the two smaller regions lack the bench strength of the large regions to respond to certain i

i out-of-the-ordinary circumstances, and they would need to call on Headquarters l

or another region for assistance sooner than required by the large regions.

On the other hand, the small regions provide additional senior management oversight of key activities (over and above that available in the three large regions) due to a fewer number of licensees.

The table at the end of the Executive Summary summarizes the key aspects of the Options evaluated. Additionally, it should be noted that the FTE savings identified throughout this study are almost exclusively overhead savings.

FTE l

savings are related either to the FY-95 baseline or to the FY-93 allocation l

2 1

s b

level.

There is a decrease, unrelated to the study, of 30 FTE for Regions IV and V combined from the FY-93 allocation level to the FY-95 baseline.

The Study Group evaluation of the four Options is as follows.

Ontion 1 This Option would consolidate all Region V activities into Region IV in Arlington, Texas.

It offers the most straightforward, effective, and efficient management strategy of the Options in that all aspects of the mission would be administered from one location with a technical work force large enough to provide an improved flexibility to the unplanned,. and a more robust and greater depth emergency response capability.

It also offers the largest overall cost savings over the long-term. To obtain those savings requires the greatest initial dollar outlay due to one-time separation and relocation expenses.

In addition, it would have significant negative impact on the largest number of Region V employees (approximately 85-95).

This Option also has some short-and long-term disadvantages..There are-uncertainties and short-term disruptions to be anticipated during any transition.

There would be added travel and response times to sites and events, as well as time zone differences.

There would also be a loss of full-time management and external interface presence on the West Coast, with a possible reduction in Agency credibility as a result.

The exercise of this Option would ultimately result in an annual savings of 3

d i

1 about 39 FTEs (69 from the FY-93 budget) and would require a one-time cost of between $7.5 to 59.8 million.

If the Agency actually realizes this 39 FTE savings by October 1995, it is then estimated that the one-time costs would be recovered in 1.8 to 2.3 years with annual savings of $4.2 million and long-term projected dollar savings of between $7.9 and $9.3 million in 5 years and

$28.0 and $30.2 million in 10 years.

Under this Option, as with the other Options, the National Treasury Employees Union (NTEU) would be entitled to negotiate with NRC management on the impact and implementation of the Commission decision.

Such negotiations could affect the timing of some aspects of implementation depending on the bargaining issues and the parties' ability to reconcile any differences.

Option 2 This Option would maintain a regional office in Walnut Creek with limited responsibility for the power reactor program [25-30 FTEs staff including residents).

The Study Group believes Option 2 is the least desirable of the Options.

While the concept of retaining a limited scope and smaller Region V office is feasible, 25-30 FTEs appears insufficient to make this Option workable.

However, to retain consideration of what is believed to be the intent of this Option, Option 4 was added for evaluation.

Option 2 would offer less cost savings than Option 1.

The retention of a West Coast office has the advantage of management and public affairs presence while consolidating most regional functions in Arlington, Texas. One-time costs 4

b would remain high.

Cost savings would be significantly reduced, and negative personnel impact would affect a potential 65-75 personnel as opposed to the 85-95 associated with Option 1.

This Option would present a major management challenge in terms of retaining clear lines of authority, responsibility and accountability. While the Region V Regional Administrator would be responsible for regional power reactor program activities, he or she would be heavily dependent on support from Region IV.

Coordination activities and Headquarters interface as well as inspector interactions with licensees would be confused, blurred, and ripe for inefficiencies and error.

The Study Group could find few positive attributes with this Option.

The exercise of this Option would ultimately resclt in an annual savings of about 25 FTEs (55 FTE from the FY-93 budget) and would require a one-time cost of between $5.9 and $7.7 million.

If the Agency actually realizes this 25 FTE savings by October 1995, it is then estimated that the one-time costs would be recovered in 2.1 to 2.7 years with annual savings of $2.8 million and long-term projected dollar savings of between $3.6 and $5.4 million in 5 years and

$17.7 and $19.5 million in 10 years.

Under this Option, as with the other Options, the National Treasury Employees Unicn (NTEU) would be entitled to negotiate with NRC management on the impact and implementation of the Commission decision.

Such negotiations could affect the timing of some aspects of implementation depending on the bargaining issues and the parties ability to reconcile any differences.

5

o-e Option 3 This Option would establish a Region IV field office in Walnut Creek with limited responsibility for day-to-day activities of the power reactor program.

Option 3 offers greater cost savings than Option 2, but less than Option 1.

The retention of a West Coast office retains the advantage of limited management and public affairs presence while consolidating most regional functions in Arlington, Texas, under a single management.

Similar to Option 2, one-time costs would be high in that a potential 75-85 personnel would be directly affected and would be subject to relocation costs, severance pay,and/or personal hardships.

Administrative cost savings would be less than that obtained with Option 1 due to the need to continue rent of office space in Walnut Creek, California, along with associated administrative costs needed to support the field office.

This Option would eliminate most of the management and program implementation challenges inherent in Option 2 since most work responsibilities would be assigned to Region IV.

However, it poses some management and communications problems and complicates the implementation of the reactor inspection program by geographically removing field office personnel from the regional office where the majority of the inspection, management, and administrative resources needed to implement the program reside.

In spite of these potential difficulties, based on Region IV experience with the Comanche Peak and URF0 Field Offices, the Region IV Administrator believes this Option is mar geable and has the advantage of retaining a NRC limited presence on the West Coast.

6

'o~

6 The exercise of this Option would ultimately result in an annual savings of about 33 FTEs (63 FTE from the FY-93 budget) and would require a one-time cost of between $6.6 and $8.9 million.

If the Agency actually realizes this 33 FTE savings by October 1995, it is then estimated that the one-time costs would be recovered in 1.9 to 2.5 years with annual savings of $3.5 million and long-term projected dollar savings of between $5.2 and $7.4 million in 5 years and

$22.7 and $25.0 million in 10 years.

Under this Option, as with the other Options, the National Treasury Employees Union (NTEU) would be entitled to negotiate with NRC management on the impact and implementation of the Commission decision.

Such negotiations could affect the timing of some aspects of implementation depending on the bargaining issues and the parties ability to reconcile any differences.

00 tion 4 This Option would retain a separate Region V office of approximately 60 FTE dedicated to the reactor inspection program and all its support functions.

The materials, fuel facilities, decommissioning, and state' agreement. programs would be consolidated in Region IV in Arlington, Texas. Region IV would be required to manage the assigned new programs with little increase in overhead.

This Option maintains a West Coast management and public affairs presence.

The Region V organization reflects the absolute minimum number of management and administrative personnel necessary to support the power and non-power reactor programs. As such, minimal administrative support would be provided to the management and technical-staff, and some current Headquarters support 7

i a

requirements might need to be relaxed.

The FTE savings associated with this Option are about one-half that of Options 1 and 3.

Negative impact on personnel and one-time relocation costs are greatly reduced from that which would be experienced in Options 1, 2, and 3, and the management and program implementation problems inherent in Option 2 are significantly reduced. A certain amount of confusion with the public, the media, and State and local governments could occur since both Regions IV and V would be regulating licensees in the same geographic area.

The exercise of this Option would ultimately result in an annual savings of about 19 FTEs (49 FTE from the FY-93 budget) and would require a one-time cost of between $3.6 and $4.8 million.

If the Agency actually realizes this 19 FTE savings by October 1995, it is then estimated that the one-time costs would be recovered in 1.7 to 2.3 years with annual savings of $2.1 million and long-term projected dollar savings of between $3.7 and $4.8 million in 5 years and

$14.3 and $15.4 million in 10 years.

. Summary Comparison of Ootions A summary comparison of the four Options evaluated is contained in the following table and associated footnotes.

This comparison addresses program impact, initial one-time costs, long-term cost savings, and employee impact.

8

e b

SUMMARY

COMPARISON OF OPTIONS Tvoe of Imoact Option 1 Option 2 Option 3 Ootion 4 Program implementation See Note 1 See Note 2 See Note 3 See Note 4 Impact on NRC West Coast Major Moderate Moderate Minor presence Estimated FTE annual 39 25 33 19 savings Estimated one-time

$7.5-9.8

$5.8-7.7

$6.6-8.9

$3.6-4.8 cost in millions of dollars Payback time 1.8-2.3 2.1-2.7 1.9-2.5 1.7-2.3 in years i

Estimated savings at

$7.0-9.3

$3.6-5.4

$5.2-7.4

$3.7-4.8 the end of five and ten

$27.9-30.2

$17.7-19.5

$22.7-25.0

$14.3-15.5 years in millions of dollars (See Note 5)

Employee impact No. employees 88 68 79 43 affected No. employees 68 53 62 34 estimated to relocate No. employees 20 15 17 9

estimated that would leave the Agency 9

e Note 1 - This Option provides more depth and breadth of technical expertise in the expanded Region IV office; which could have a positive impact on program implementation.

Note 2 - 'This Option results in significant management and program implementation problems and would have the most adverse impact on program implementation of the four.0ptions evaluated.

Note 3 - This Option does not have many of the management and program implementation problems associated with Option 2.

There remain some management and program implementation challenges -

associated with this Option which may be balanced by the retention of a West Coast presence.

Note 4 - This Option basically retains the_ status quo for the reactor program. The impact on the materials, fuel facilities, decommissioning, and state agreements programs would be the same as discussed in Option 2.

Some confusion with the public, the media, State governments, and other agencies would result because both Region IV and Region V would be regulating NRC licensees in the same geographic area and agreement state functions would be split between the two regions.

Note 5 - These estimated-savings would. result only if the Agency reduces the total staff by the number of FTEs identified as estimated i

FTE annual savings, by October 1995.

10

o-Introduction Study Group Charter i

On March 30, 1993, the Secretary of the Commission issued COMSECY-93-012 l

(Appendix 1), directing the staff to conduct a study of possible alternatives for the realignment of Region V.

The Commission provided that the evaluation address impacts associated with the reassignment of staff and also anticipate any union contract considerations.

That same day, the Executive Director for Operations (ED0) issued a memorandum (Appendix 2) which appointed a Study Group to evaluate the feasibility of a realignment or elimination of the Region V Office.

In this memorandum, the EDO identified members of the Study Group and specified three Options to be evaluated in the Study.

On April 20, 1993, the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research (DEDR), issued a memorandum (Appendix 3) which supplemented the March 30, 1993 EDO memorandum. This memorandum directed the Study Group to provide to the National Treasury Employees Union (NTEU) and employees of Regions IV and V copies of the Study Group Draft Report, for their review and comment, as-soon-as-possible after a briefing of the EDO. The Study Group is to evaluate submitter's c'omments for consideration in the final report.

l i

11

i Study Group Members Paul E. Bird, Director, Office of Personnel Bobby H. Faulkenberry, Deputy Regional Administrator, Region V Ben B. Hayes, Director, Office of Investigations John M. Montgomery, Deputy Regional Administrator,

.agion IV James Turdici, Assistant to the Chief Financial Officer, Office of the ED0 Bobby Faulkenberry and John Montgomery were directed to share lead responsibility in the overall study effort.

Jim Horn was initially identified to be the representative on the Study Group from the Office of Personnel; however, Mr. Horn was subsequently replaced by Paul Bird.

Numerous personnel from Region IV, Region V, and NRC Headquarters, including Peter Rabideau from the Office of the Controller (0C), assisted the Study Group in the collection and analysis of the data.

12

m Ootions Evaluated Four Options were evaluated in the conduct of this Study.

In his March 30, 1993 memorandum, the EDO directed that three Options be evaluated.

The Study Group initially agreed that there were significant management problems associated with implementation of Option 2 and, therefore, requested and received authorization from the ED0 to evaluate Option 4 as a more viable Option.

Option 1 -

Consolidation of Regions IV and V into a single regional office located in Arlington, Texas.

Option 2 -

Reducing Region V to a staff of approximately 25-30 FTEs (including Residents) and limiting the mission to a portion of the Power Reactor Program.

The remainder of the current Power Reactor program, along with the Office of Investigations (01),

nonpower Reactor, decommissioning, fuel facilities, enforcement, State agreements and liaison programs, and materials programs would be consolidated in Region IV.

Option 3 -

Reducing Region V to a staff of approximately 25-30 FTEs (including Residents), as in Option 2, but structured as a field office of Region IV, rather than a separate regional office.

13

4 Option 4 Reducing Region V to a staff of approximately 60 FTEs-(including Residents) with all reactor programs remaining in Region V.

All other programs including fuel facilities, decommissioning, State agreements, materials and 01 would be consolidated in Region IV.

Acoroach Used in Conduct of Study In the course of its review, the Study Group obtained input from Region II,.

Region IV, Region V, Office of Nuclear Reactor Regulation, Office of Nuclear Material Safety and Safeguards, Office of Analysis and Evaluation of Operational Data, Office of Enforcement, Office of State Programs, Office of Information Resources Management, Office of Investigations, Office of Public Affairs, Office of Personnel, Office of-the General Counsel, and Office of the Controller.

For each Option evaluated, the Study Group addressed the following subject areas:

Impacts on mission accomplishment Interfaces with licensees, the public, the media, State and local-governments, Federal agencies, and internal NRC interfaces Incident / Emergency Response Employee Impacts - Short-term and Long-term Impact on Costs, to include travel, transportation, FTEs, relocation, and administrative support Positioning for the future 14

3 The impact on mission accomplishment, including: 1) performance of Incident / Emergency Response; 2) performance of inspection, licensing, and enforcement activities; and, 3) interfaces with licensees, the public, the media, State and local governments, Federal agencies, and internal NRC interfaces was determined by obtaining opinions from senior management officials in Region IV, Region V, and the affected Headquarters offices.

Impact on Region V personnel was made through personal contact with each Region V employee, followed up by obtaining written information from an employee survey, which was evaluated by the Study Group.

One-time and recurring costs were determined for each Option and reviewed for completeness and accuracy by the Study Group and by Peter Rabideau, Director, Division of Budget and Analysis, OC.

The amount of time allowed for the study required the Study Group to primarily focus on the Options presented and to develop assumptions to expedite data collection and analysis.

The Study was initiated on March 30, 1993. Data collection was performed during the period of April'l-23,1993, and data analysis and review was performed during the period of April 23-28, 1993. - The Draft Study Report was prepared and revised during the period of April 28 -

i May 10, 1993, in preparation for briefing the ED0 on May 13, 1993.

Assumptions Used in Conduct of Study i

The estimates of FTE staff savings from implementation of the various Options 15 j

are based upon the following assumptions:

FY-95 FTE allocations for Regions IV and V as provided for in the FY-94 budget submission provided the baseline for the study, with the exception of a five additional FTE reduction [three FTE reduction in Region IV ar.d two FTE reduction in Region V] in the NHSS materials program which is attributed to current and anticipated workload reductions.

The Region V resident inspector offices would be staffed to N+1.

The current functions and regional boundaries for Regions I, II, and III would remain unchanged with the possible exception of proposing transfer of responsibility for the Grand Gulf plant from Region II to Region IV.

FTEs associated with any such transfer are not included in the estimates used in the study.

URF0 functions would have been transferred to Region IV and Headquarters by the time of implementation of any of the Options.

No licensee facility would be regulated by more than one regional office.

The Study Group considered the Commission's direction included in COMSECY 93-012 regarding other regional boundaries and workload.

The Study Group's initial assessment was that it could anticipate significant management and interface disruptions with any of the existing Options regarding Regions IV and V, and that any attempt to significantly alter 16

other regional boundaries would result in similar disruptions in the affected regions without significant FTE savings. The Study Group defers to the June 1987 study entitled " Comprehensive Review of Regional Operations, Organizations, and Management" which evaluated regional boundaries, workloads, and office locations.

In determining estimates of FTE savings for the purpose of this study, the Study Group restricted itself to identifying-only those positions which were included in the FY-95 reaional budgets and which could be eliminated while maintaining overhead ratios similar to those which exist in the three large regions.

The exceptions are 01 and NRR as described-below.

Some number of Headquarters FTE can reasonably be expected to be used in support of individual regional offices.

Even though the study. group did not thoroughly evaluate the extent of this headquarter's support and the resulting amount of Headquarter's FTFs that could be saved through implementation of Options evaluated, NRR has stated that about four FTE could be saved with implementation of Options 1 and 3.

Except for the Region V, Option 4 organization, the constraint on maintaining a certain overhead ratio restricted the Study Group from identifying additional FTE savings which might be gained through innovative management, leaner overhead, or savings associated with modifications to Headquarters program requirements. We felt that such actions, while possibilities, are beyond the scope of this study, and if 17 i

1 pursued, should be pursued separately and for all regional programs.

We address this issue further under recommendations.

The ratio of direct labor (FTE/ power reactor facility, and FTE/ materials licensee for materials program purposes and FTE/ management and administrative overhead) for the expanded Region IV organization, would be within the range of the current ratios of Regions 1, II, and III, unless otherwise evaluated for feasibility.

While maintaining existing effice alignments (status quo) has not been explicitly identified as a separate option, it is identified both organizationally and in terms of FTEs as the baseline from which the other options were developed. The Study Group assumes that maintaining the status quo is an alternative available to the decision makers.

18

History / Overview In 1961, the Atomic Energy Commission (AEC) established the current NRC regional office boundaries.

Over the years, from the early 1960's through the late 1980's, the regional offices continued to increase in size and continued to assume additional work function responsibilities.

In the late 1980's through the present, the growth of regional offices has stabilized and in some cases the number of FTE staff years budgeted for regional office work has decreased, primarily due to the permanent shutdown of power plant facilities and the termination of materials licenses.

For example, in FY-86 Region V was budgeted 114 FTEs; while in FY-95, it is budgeted 89, a decrease of 25 FTEs or 22 percent.

Region IV in FY-86 was budgeted 142 FTEs; while in Fi-95 it is budgeted 125, a decrease of 17 FTEs or 12 percent.

A significant increase in regional responsibilities occurred during the period of 1982 through 1984 with the implementation of the Commission's Regionalization Policy.

This policy was placed into effect to -improve coordination of licensing, inspection, and enforcement actions; place NRC activities closer to State and local governments and the public; strengthen incident response capability; and, upgrade the status of regional administrators. Among the more important functions that were delegated to the regions dering this period were reactor operator licensing, materials licensing, evaluating licensee emergency preparedness, carrying out the Agreement States Program, performing quality assurance (QA) licensing reviews, performing safety evaluations of emergency preparedness (EP) and safeguards licensing actions, and reviews of physical security plans.

19

In general, over the years, the regionalization of work functions has proved to be cost effective and has significantly improved relationships with State and local government officials and with licensees.

In addition, it has significantly improved the Agency's capability to respond to events and to assist States in their handling of events.

Also, regionalization has resulted in significant improvement in the Agency's capability to handle public affairs activities.

However, as previously stated, both of the small regions would have lost enough workload and FTEs by FY-95 that the original concept of two geographical locations with small regional office staffs to cover the western half of the United States has been called into question.

i 20

f Evaluations of Options Evaluation Summary The following summarizes the Study Group's evaluation of the four Options.

For coinplete details on each Option, see the discussion under the respective Option.

Option I would provide the most straightforward, effective and efficient organizational alignment.

The new alignment would regulate 12 power reactor sites (19 units) and approximately 970 materials licensees. This compares to the 20 plus power reactor sites regulated by each of the large regions and in the materials area is approximately equal to the workload of Region II, which has the smallest workload of the large regions. This Option would provide a broader base of technical resources to accomplish various aspects of the mission.

Headquarters would have one less region to deal with programmatically, resulting in some benefit to consistency. On the other hand, this Option requires additional travel time on the-part of NRC personnel and would require an adjustment by most Region V licensees to dealing with a regional management located in another time zone. There would be a loss of NRC management and public affairs presence on the West Coast which could-have a negative effect on.the NRC mission.

Option 2 would provide the most complex and. confusing organizational

-1 alignment.

Responsibility for the power reactor program would remain in Walnut Creek, under the management of a Regional Administrator, but all other program responsibility would be transferred to the Region IV Administrator in 21

)

)

Arlington, Texas.

In addition, The Region V-administrator would have to rely on Region IV to provide at least half of the ' resources necessary to fulfill-the power reactor program responsibilities.

Communication and' coordination difficulties could be significant.

In addition, external. confusion over the assignment of responsibility for any given aspect of mission. accomplishment-could be high.

Like Option 1, Option 3 would assign all mission responsibility to the Region l IV Regional Administrator. However, a field office in Walnut Creek. headed by an SES manager would be retained to provide day-to-day. oversight of.the power reactors presently regulated by Region V.

Implementation of this Option would retain some of the broad base depth of technical resource benefits of Option 1, but would increase the' management challenge of maintaining smooth communication and coordination. - Region IV's Regional Administrator believes these potential difficulties are manageable. Most of the negative mission-t impact associated with loss of management and public affairs presence, as -

would occur with implementation of Option 1, would be eliminated.

-t Like Option 2, Option 4 would retain a regional office and' Regional l

Administrator in Walnut Creek. The Walnut Creek region would retain the responsibility for and the resources necessary to accomplish'the power-

-reactor, nonpower reactor, and state liaison functions.

The other programs.

would be transferred to the Region IV Arlington location. There-should tue no-impact on the power reactor program, and the pros-and cons regarding'the materials program are identical to Options 1 and 3. : As with Option-2, there i

could' be external confusion ovar responsibility issues since two regions.would

[

i 22 a

~

4 7.-

share regulatory responsibility for parts of the NRC mission within the same

.. geographical area. -In particular,.the NRC states program function would be-split between two regions, with attendant communication and coordination difficulties.

i l

1 i

t l

i 23 1

00 tion _1 -

Consolidation of Reaions IV and V into a Sinale Reaional Office loca':ed in Arlinoton. Texas.

The implementation cf this Option would result in the greatest amount of FTE and dollar savings.

The combined Region IV/V organizational structure is the most effective and efficient as compared to the other three Options. On the other hand, implementation of this Option results in the most severe personnel impact, and would deprive the Agency of NRC management presence in.the far western states.

This Option involves taking the Region V FY-95 budget baseline organization (Appendix 4), merging it with the Region IV FY-95 budget baseline organization (Appendix 5), resulting in a Region IV organization as shown in Appendix 6.

The exercise of this Option would result in an annual Agency savings of about 39 FTEs [69 FTE from the FY-93 budget).

Impact on Mission Accomplishment Under this Option, Region IV would be aligned and staffed similar to the three large regional offices but would be somewhat smaller. The overall ratio of power reactor sites to regional SES managers would be somewhat reduced, bringing the combined Region IV organization more in line with the ratio in the large regions, but still providing a greater ratio than the large regions.

24

~

The degree of senior regional management involvement in individual plant issues may decrease, and meetings with senior licensee personnel would l

decrease. These have always been the principal benefits of a small region.

i l

Off-hours communications with licensees about plant issues are likely to increase between the regional office and Region V licensees due to the time zone change.

Experience indicates that licensees often make these notifications late in the work day.

There would be an increase of management and inspector travel under this Option.

On the other hand, having a larger, consolidated inspection staff presents a-significant positive benefit to the reactor inspection program.. The benefits are derived from the broad base depth of technical expertise available to address issues and flexibility in inspection planning and event and emergency response and more assurance of consistent application of the program.

Having a larger licensee population provides benefits to a combined Region IV/V.

For example, the regional staff would experience a broader spectrum of licensees, providing a better rounded view of licensee performance overall.

In addition, having a larger number of sites within the region provides a greater flexibility in implementing the NRC's rotation policy. for the _ resident inspector staff.

The time zones change would negatively impact regional interactions with 25

Q licensees but would provide a positive impact with Headquarters and other regions interactions.

Specific management actions such as adjusting the resident inspector first 40-hour work schedule could minimize this time zone impact.

Short-term safety benefits could result from inspectors having a " fresh look" at the plants from the other region and by the cross-fertilization of inspection techniques and experiences between the combined regions.

During the same 2-year period, however, there would be some significant startup costs associated with dislocation of employees from physical moves, establishing new relationships with licensees, and establishing inspector familiarity with licensed facilities.

NRR currently has to interact with five regions; under this Option, that number is reduced to four regions of approximately equal size with obvious benefits accrued in terms of policy and program development, management time, travel time, communications, and program support.

In addition, NRR Projects is already aligned to support a combined region.

The disadvantages associated with implementing the power reactor inspection program under this Option primarily relate to the loss of NRC management presence on the West Coast, employee dislocation, the time zone change, impact I

on licensees and others, and increased management / supervisory travel.

Conversely, some significant positive benefits may accrue from implementing.

this Option, including reduced overhead to support the inspection staff.

FTEs have been included under this Option to offset the estimated increase in i

26

~

reactor inspection travel time.

With regard to the materials, fuel facilities, nonpower reactors, 01, state agreement and liaison, and decommissioning programs, these can be managed as well from either the Region IV Arlington, Texas office or from the Region V Walnut Creek, California office.

However, there are a number of both positive and negative program implementation impacts that could occur as described below.

The current Region V materials program includes seven States and the Pacific Trust Territories.

Five of the States are agreement States.

Region V has 260 active licensees.

The region has typically processed about 200 licensing actions each year, and conducts about 115 inspections each year.

The combined Region IV - Region V program would have approximately the same workload as Region II.

Consolidation of the Region V materials program in Region IV would provide more assurance of consistent application of the materials program throughout the combined Region IV.

In addition, the program offices would have one less region to communicate with.

The coordination and planning of inspections should not be affected and the interface with NRC Headquarters should be improved with the Region IV location-because of travel and time zone considerations.

Some additional travel time H

between the NRC regulators and licensees would be experienced.

27 i

I

l The review and evaluation of inspection results and development of enforcement actions would not be affected; however, management attention and oversight of activities would be affected with the expanded scope of activities and travel requirements for the DRSS Director.

This would make the need for a SES-level deputy an important consideration and would be consistent with the three large i

I Regions.

The internal management and communication issues are not expected to be significantly affected other_ than the increased scope of responsibilities which would be similar to the large regions.

Direct inspection effort could have been affected by increased travel time in a similar manner as the power reactor program.

To ensure there would be no impact to the direct inspection effort, FTEs have been included under this Option to offset the estimated increased travel time.

The larger base of employees would be a positive impact with more expertise available and more opportunity for cross training and development.

The ability to respond to changing organizational challenges should be enhanced with the increased depth / breath of personnel.

i Interfaces with licensees. the Public. the Media. State and local Governments.

Federal Aaencies. and Internal NRC Interfaces A disadvantage of consolidation is elimination of an NRC presence in the western states with closer' proximity to the licensees and the general public.

The resident inspectors would remain the one exception.

Exercise of this Option would mean that one regional office would cover over one-half the area.

28

o s

of the contiguous United States, plus Alaska, Hawaii, and Guam, and would be by far the largest region.

Also, the Region IV Arlington, Texas office is two time zones away from the West Coast states, three time zones away from Alaska and five time zones from Hawaii.

The degree of regional interface with licensees, the public, the media, State and local governments, and regional Federal agencies would in some cases decrease.

Because of the large land area involved, and because of the long.

travel distances to some of the States (Hawaii 3800 miles and Alaska 3100 miles) and some of the power reactor sites (WNP-2 and Diablo Canyon 1700 miles), some States and some licensees may perceive a lack of local NRC management presence. Also, with the large number of States contained within the region it would be more difficult for senior NRC managers to maintain as frequent contact with State and county officials and maintain the current level of interface that now exists.

Conversely, internal NRC communication and interface activities would be enhanced in that Headquarters program offices would have one less regional i

office to coordinate with and the time zone difference would improve.

Also, since all:of the Regional Offices would be more' equal in size (number of licensees-and number of regional staff), it should be easier to maintain uniformity in the way regional work activities are performed.

29

4 Incident /Emeraency Resnonse The impact on emergency response functions of a consolidated Region IV are as follows.

First, there would be some additional travel time required to provide initial site team response to three of the Region V reactor sites (Palo Verde is approximately equidistant from Regions IV and V).

However, if charter jets are used, as currently provided for, that time is estimated to be within the Agency acceptability guidance of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and is not significantly different from the Region IV estimates for response to Wolf Creek or Cooper.

Therefore under emergency response conditions, it is anticipated that Headquarters would have to remain in the initial activation mode for San Onofre, Diablo Canyon, and WNP-2 for up to 2-3 hours longer than is the case today, but no longer than is already expected for several other plants nationwide which have response times in the 5-6 hour timeframe.

In addition, as is already part of Agency practice, in any significant reactor event, the staff would call upon the residents from the other West Coast sites for an immediate limited response to any site that had a major problem.

Response to WNP-2 and Diablo Canyon from Region IV would be unique, however, in that the use of charter jets would be the only way the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> guidance could be accomplished.

For all other plants nationwide, the use of charter jets would be considered on a case-by-case basis if conditions were such that use of commercial transportation would significantly delay response.

Second, there'may be some short-term degradation in knowledge and familiarity with the four Region V sites from an emergency response perspective, depending upon the actual number. of' key technical personnel and managers that accepted a 30

o

=

transfer to Region IV.

There would be two less senior SES managers in the Agency qualified to serve as a Director of Site Operations, thereby reducing the overall Agency capability in this area from 13 to 11.

Event response at a level below activation of the formal Agency procedures would also be adversely affected by the additional travel time required, although time sensitivity is not as important for events of this type.

Response to materials events might take somewhat longer or more reliance might need to be placed on assistance from the agreement States in response activities for Federal facilities located in those States or nearby.

In a combined Region, emergency response interface activities would increase in number from those handled by Region IV today due to the additional Federal regional offices and State and local authorities to deal with.

The combined region would interact with four of the ten FEMA regions.

However, the amount of time and personnel that the combined region would be able to devote to each FEMA regional assistance committee in evaluation of biennial exercises, review i

of State and local emergency plans, State and licensee. meetings, and special workshops would remain unchanged.

f A combined larger region would provide a broader base of technical expertise and management experience to draw upon in any given emergency. The larger overall number of personnel provides a greater probability that adequate numbers of the right people are always available to fill all emergency response positions at any given time.

31 c

Em_pjovee Impacts - Short-term and Lona-term Information on employee impacts has been developed from a number of sources:

an employee survey conducted in Region V; comments by employees at the periodic staff meetings on this subject; and unsolicited written and verbal comments by individual staff members.

In short, nearly all Region V employees have expressed strong concerns about the possibility of an Agency decision which would result in their relocation.

Financial concerns regarding relocation are almost universal.

Nearly all Region V staff have expressed a concern about the hardship associated with potential moving expenses that are not reimbursable.

Employees have also expressed concerns related to the San Francisco east bay area housing and real estate market.

For most employees, the single largest investment is their home.

It is widely recognized that the economy in California has been in a recession for the past few years. As a consequence, real estate values in some areas have fallen.

For example, in Contra Costa County where 71 percent of Region V employees reside, the average price of homes sold in 1993, year to date, is 4 percent less than the average price during the same period in 1992.

Real estate values in other parts of the San Francisco bay area have also been significantly affected by the announced military base closings.

Any adverse financial impact will be the greatest for employees who have not owned their homes for more than a few years.

32 1

a l

Even though Region V is relatively small, rather significant attrition has occurred in the recent past.

Seventeen employees, or 18 percent of the work force, have been hired in the past 15 months (ten of these in the past six months.) All but three of these new employees required geographic moves.

They would be particularly hard hit by another relocation.

Out-of-pocket expenses associated with the recent refinancing of homes may.

also present a significant hardship.

Refinancing can cost several thousands of dollars and is estimated to take two to four years to recoup the one-time costs.

Leaving the Walnut Creek area results in a loss of the 8 percent high cost of living pay adjustment for employees, and a resultant perception of loss of real income.

The most significant employee impact occurs under Option I where all 88 of the employees assigned to Region V in Walnut Creek would be offered transfers.

Under this Option, 22 percent, or 20 employees assigned to Region V in Walnut Creek, indicate that the negative. personal impacts would be so severe that they would opt to leave the Agency.

Another major area of concern among Region V employees relates to family responsibilities.

In responding to the survey, 22. percent of the Region V staff indicated that they have responsibility for caring for elderly family a

members who have long-term ties to the bay area.

Geographic relocation would make execution of these responsibilities problematic for some and impossible for others.

Other staff have-joint custody of children.

Geographic relocation of these employees would obviously cause a major upheaval in these 33

4 arrangements.

Some staff have children who are college age and are either in California universities or are about to enter them.

These employees have expressed concern about potential additional financial burden, or having to change decisions concerning college location.

In addition, a large percentage of the Region V staff have spouses who also have careers.

In responding to the survey, nearly 50 percent of the employees indicated that problems associated with two-career families would represent significant challenges for them.

In a number of instances employees' spouses have a long tenure and are heavily vested with another local employer's retirement system. Geographic relocation would mean loss of this security and investment. Other employees have spouses who own local businesses or spouses with a California professional accreditation or license which is not transferable.

In some cases, the financial hardships are such that the family unit would have to be separated for an extended period of time.

There are also at least four employees for whom health care would be the most j

significant personal hardship.

Continuity of care-for those who require unusual medical attention (whether it be for the employee personally, or a parent, spouse, or child) is a major concern for these employees.

t p

Another concern came from supervisory GG-15s, who were concerned that there might not be comparable positions. available to them at whatever new location.

they might be assigned.

A broader spectrum of employees was concerned about 34

o the nature of equivalent jobs they might be offered at a new location.

The study group evaluated the employee comments and attempted to provide some reasonable estimates of the financial hardships associated with forced geographical relocation.

Because of the large uncertainties associated with such estimates, primarily due to the fact that actual expenses are so individualized and dependent on residence and family idiosyncrasies, the group has provided ranges or in some cases recent examples as the best information available. What is clear is that geographical moves involving the sale of a personal residence and the physical move of a family result in out-of-pocket expenses that are never reimbursed.

These amounts may vary from a couple of thousand dollars to many thousands of dollars, depending on the individual circumstances. These expenses remain one of, if not the most, significant hurdle for many people, in making a judgment whether to move or not.

There is also a significant emotional and stress-related factor associated with geographical relocation, particularly when it is unwanted. The family disruptions of leaving community and friends, uprooting children from schools, spouses from their jobs, parents or other family members from long-term health care, and the uncertainties associated with a new job and new expectations, all-takes a toll on the employee and the family.

1 In summary, the closure of the Region V office requiring the. relocation of i

significant numbers of regional personnel, would have a significant negative impact, both personally and financially, for these individuals.

35 i

... m

4 Impact on Costs. to Include T*avel. Transoortation. FTE. Relocation. and Administrative Support.

FTE FTE savings were calculated by comparing the baseline FY-95 budgets and organization charts for the existing Regions IV and V against the-proposed FTE alignment for a combined region as shown in Appendix 6.

Final FTE savings were adjusted to reflect the offset required to compensate for lost time associated with inspector and management travel. -In most Options, an additional reactor and materials inspector was added to compensate for the 1

I travel distances.

The summary of this analysis is shown in Appendix 7.

Salaries and Benefits l

The FTE savings estimated were then converted to annual dollar savings by multiplying the estimated number of FTEs saved (discussed above) by the average value of salary and benefits provided by the Office of the Controller I

for Region V staff.

This average value is $80,000.

Thus, under Option 1, the estimated 39 FTE equates to approximately-$3.1 million in salaries and benefits savings. The FTE salary and benefit savings is the most dominant figure in deriving net recurring savings, i

36 i

i u _ _. _ _ _ _ _. _ _ _...

o-Travel Additional travel costs would be incurred with implementation of any of the consolidation Options. The increased costs generally fall into one of three categories:

reactor inspection; materials inspection; and management and support trips associated with licensee activities. The additional travel dollars were calculated by identifying the number of trips typically made to each destination and multiplying this by the cost increase due to traveling from Region IV instead of Region V.

Lost staff time associated with the increased length of travel is addressed under FTE considerations above.

The increased costs under Option 1 are estimated as:

2 Reactor inspection

$291,000 Materials inspection

$37,000 Management trips

$35,000 Cost subtotal

$363,000 These increased costs, however, are offset by savings resulting from travel by Headquarters employees to Region V (for such purposes as program. reviews, mandatory training, administrative and management travel) as a result of the elimination of redundant functions through consolidation. These savings are estimated as:

Headquarters savings

$ 85,000 Regional redundant functions 1 61.000 Savings subtotal

$146,000 37 1

o 4

The net travel cost increase if Option 1 is implemented is estimated as

$217,000.

Similar computations were made for each Option.

Administrative Costs and Savinos The consolidation of Regions IV and V under Option 1 in Arlington would affect administrative costs on both a one-time and recurring basis. The one-time administrative costs would be associated with preparation of new space in Region IV and transportation of furniture and equipment from Region V.

These items are estimated at $45,000 and $50,000, respectively, for a total of

$95,000.

)

Recurring administrative support savings generally fall into two categories:

1) rent and 2) services and supplies.

Under Option 1, all rent expenditures in Region V would be saved and additional square footage for office space in l

Region IV would be required at 120 square feet per person (based on FTEs transferred from Region V less the projected available space in Region IV).

44 Region V positions would transfer.

There are currently 27 available offices in Region IV.

Office space would have to be acquired for the 17 remaining positions at 120 square-feet per person.

The resultant 2040 square il feet at $16 per square foot would cost $32,640.

The final result is a net j

annual savings for rent under Option 1 of $711,360, i

It should be noted, however, that the General Services Administration (GSA) anticipates _that the buy-out for the remainder of the Region V lease would cost $476,000 annually until December 1998.

Thus, although NRC would achieve 38

e savings, the government would continue to incur these costs through 1998 if GSA could not find other government tenants to use the space.

This would be true to one degree or another for any of the Options considered.

These potential costs to GSA have not been reduced from the Agency projected savings as displayed throughout the study.

Calculation of the long-term savings for other administrative support such as supplies and services involved calculation of the Agency-wide average figure for these types of support services.

The amount of administrative support per person was computed to be $5,300 and is consistent with regional experience and covers a vast array of services, supplies, equipment, etc. The increased cost to Region IV for absorbing the additional 44 FTEs in the region and 13 resident staff is estimated at $302,100. Thus, the overall' savings from administrative support if Option I were to be implemented is estimated a't

$1,010,000 or roughly $1 million.

Relocation One-time costs can be divided into four categories:

Relocation, Severance Pay, Transfer of Equipment, and Administrative Costs.

Relocation costs are the dominant' cost of the study and are the most difficult to determine because of the uncertainty of employees' decisions when making a move. A range of costs is provided due to this uncertainty.

The estimation of relocation costs involves a number of variables.

The first variable relates to the number of people who will accept transfers.

Region V j

39

4 conducted a personnel survey which in part addressed this issue.

The results of the survey were used as one of the data points in the evaluation.

The survey results indicate that 78 percent of the staff would transfer.

However, Appendix 10 reflects a range of costs from 65 percent to 80 percent of the staff transferring.

Under Option 1 the entire staff would be offered transfers.

Thus, the number of employees who would move ranges from 58-71.

It was assumed that 5 percent of the staff do not own real estate, and costs for their relocation were estimated at $52,000 per employee.

$250,000 was l

identified as the average price of homes in the Contra Costa and Solano county areas.

l The second significant variable concerning relocation estimates relates to the 1

percentage of employees who would use the relocation service versus handling the real estate transactions independently.

It was again decided a range was appropriate for this factor.

The range presented assumes from 50 percent to 80 percent of the employees would use the relocation service.

Based on all of i

these assumptions, it is estimated that the one-time employee relocation costs j

i if Option 1 is implemented would range from approximately $7.1 million to- $9.1 million.

Severance pay Estimates for costs associated with severance pay are directly linked to the variables discussed above related to relocation.

Survey results indicated that 22 percent of the Region V staff would not transfer.

However, to be consistent with the ranges estimated for relocation transfers (65%-80%), 35 40

.u e

percent to 20 percent were considered for leaving the Agency.

A number of these employees who would not accept transfers are eligible for Optional or early retirement.

Based on the survey, 8 of the 20 could retire.

The percentage of the retirement eligibles was used as a constant for all Options.

The remaining staff, ranging from 7-12, would be entitled to severance pay.

The average severance pay used in the calculation was $32,000 (based on a recent analysis by the Office of Personnel).

This yielded a severance pay range estimate if Option 1 is implemented of $352,000 to $608,000.

Cost Summarv In summary, estimated one-time costs consist of personnel relocation, severance pay, transfer of furniture and equipment and rather minor administrative items. The vast majority of the one-time costs stem from personnel relocation. The estimate for recurring savings is primarily driven by the salaries and benefits associated with FTE savings and savings in leasing office space. These are offset to a limited extent by increased travel and ongoing administrative support.

The exercise of this Option would ultimately result in an annual savings of about 39 FTEs (69 FTE from the FY-93 budget) and would require a one-time cost of between $7.5 and $9.8 million.

If the Agency actually realizes this 39 FTE savings by October 1995, it is then estimated that the one-time costs would be recovered in 1.8 to 2.3 years with recurring savings of $4.2 million and long-term projected dollar savings of $7.0 and $9.3 million in 5 years and $27.9 and $30.2 million in 10 years.

41 I

e

l Positionina for the Future This Option provides the least flexibility and highest future cost if workload were to unexpectedly change and increase to the extent that a West Coast NRC regional office could otherwise be justified.

It is difficult to postulate such an increase in the reactor program over the next 10 years.

Even if one were to speculate that additional power reactor construction would occur, the number of such plants would have to exceed 8-10 before the consolidated Region IV's workload reached or exceeded that of the three existing large regions.

It is similarly difficult to imagine a large enough increase in materials licensees to anticipate such a workload increase that would justify moving the material inspection or licensing programs back to the West Coast unless the NRC assumes additional responsibilities; such as the regulation of non-reactor produced isotopes. The Study Group did consider the possibility that added attention to the State agreement program regulation of materials licensees might be required; however, we do not believe any reasonably anticipated changes would alter our conclusion that the program could still be administered from the Region IV Arlington, Texas location. At worst, travel costs would increase some amount due to this possibility.

Last, we considered the potential need for a West Coast office to support construction of the proposed high-level-waste storage site at Yucca Mountain.

Such an office could, of course, be located at the existing Region V Walnut Creek location, if it were available. Alternatively, however, such an office might better be located at or nearer Yucca Mountain or in space on the West Coast where the Department of Energy (DOE) is or would be administering the 42

.. 6 4

repository program.

I h

6 9

6 f

2 I

i

'?

1 i

1 43 i

c.

a 00 tion 2 -

Reducina Reaion V to a Staff of Acoroximately 25-30 FTEs (includino Residents) and limitino the mission to a nortion of the Power Reactor Proaram.

The remainder of the current Power Reactor Proaram, alona with the 01. Nonoower Reactor.

decommissionina. fuel facilities. enforcement. State aareements and liaison. and materials oroarams would be consolidated in Reaion IV.

The Study Group believes that this Option would result in significant management and program implementation problems and.as a consequence is not considered viable.

The most serious problem involves assigning the Region V Regional Administrator the responsibility for conducting the Power Reactor Inspection Program, but not providing management control over a large portion of resources needed to implement the program.

This Option involves taking the Region V budget baseline organization (Appendix 4), reducing it to the minimum staff required to manage a portion of the Power Reactor Inspection Program, and expanding the Region IV baseline organization (Appendix 5) to provide the resources needed to perform all other current Region V work functions, including the remainder of the Power Reactor Inspection Program.

Implementation of this Option results in a Region V' organization as shown in Appendix 8, and a Region IV organization as shown in Appendix 9.

l l

The exercise of this Option would ultimately result in an annual savings of about 25 FTEs.

44 j

1

6 m

1 i

]

J_moact on Mission Accomplishment Option 2 presents considerable program management challenges which are likely to result in a noticeable negative impact on the Power Reactor Inspection Program. The overall difficulty arises from the fact that responsibility for management and implementation of the Power Reactor Inspection Program would remain in Region V, while roughly half of the inspection resources to conduct '

the program would reside in Region IV. The coordination required to plan and implement the inspection program, and to fulfill other program responsibilities, such as the Systematic Assessment of Licensee Performance (SALP), enforcement actions, plant performance reviews, licensee meetings, allegations, and MIPS would be significant.

Coordination and communication difficulties would undoubtedly occur, which would result in an overall weaker implementation of the Power Reactor Inspection Program at Region V sites.

The time zone differences and the geographic distances between Region IV and Region V would make it more difficult to meet the greater need for effective coordination and communication activities.

Region IV would provide significam. staff support necessary for specific inspection activities, while Region V would retain primary responsibility for the oversight and quality of the inspection program.- While long-range planning of routine inspection activities could probably be accomplished with a reasonable degree of effort, the conduct of reactive inspections would be much more difficult.

For emerging issues, Region V would have to rely almost exclusively on Region IV resources in the operator licensing, emergency planning (EP), radiation protection (RP), and security areas.

In the 45 i

O 6

engineering area, Region V would have a very limited capability beyond the resident staff to focus on emerging issues.

In responding to Region V short lead-time requests for resources, Region IV's response would likely be heavily influenced by the need to fully implement the inspection program at Region IV sites, for which Region IV is directly accountable.

For larger reactive l

efforts, such as Augmented Inspection Teams, Region V would have to rely heavily on Region IV resources on short notice.

The implementation of the SALP process in Region V would require considerable effort on Region IV's part, and a significant degree of coordination.

While the overall SALP effort would remain the responsibility of Region V, Region IV would provide all of the input in the operator licensing, EP, RP, and security areas, and a significant portion of the input in the engineering area.

The results of team inspections led by Region IV personnel would need to be factored into SALPs.

Region IV would have to provide at least a DRSS manager to be a SALP Board member and more likely other Region IV personnel would travel to Region V to participate on the Board.

Likewise, Region IV personnel might also be requested to attend the SALP meetings with licensees.

The overall quality and timeliness of SALP reports would be difficult to maintain due to the regional division of resources and oversight personnel that contribute to the SALP process.

I Under this Option, all inspection reports for Region V sites would be signed out by Region V managers, however, with 50 percent of the inspection resources in Region IV, Region IV first-line supervisors would be required to do the first-level reviews of the work of their inspectors. The review and q

46

1 r

resolution of comments on draft reports would be complicated by the I

geographical separation of the inspector and the manager signing out the report.

Likewise, specific preparations for inspections would require additional effort between Region V managers and Region IV managers and inspectors to review and approve inspection plans.

Processing of routine allegations requires that allegation boards be held to assess the allegation and to determine a course of-action.

Region V would have to depend on the Region IV Attorney, Allegation Coordinator, and/or Enforcement Officer to telephonically support all allegation boards, estimated to be roughly 200 boards per year.

In many instancis, Region IV technical staff would be requested to support allegation boards and to provide inspection followup of allegations.

Virtually all EP, RP, and security allegations would require Region IV inspection effort.

Region IV would also have to support drafting of correspondence that relates to allegations.

The absence of an Allegation Coordinator in Region V would require each Region V branch chief to assume that function in his/her Branch, with a corresponding decrease in efficiency and continuity.

The overall quality of allegation files and the timeliness of allegation followup would likely decline.

Routine enforcement items would remain the responsibility of Region V.

Escalated enforcement could either be coordinated through'the Region IV l

enforcement officer or directly addressed by Region V with the Office of Enforcement (OE).

If the Region IV enforcement officer's participation is included, the coordination efforts would'be increased over that needed with an

~

enforcement officer located in Region V.

If Region V dealt directly with OE, 47 e

a 6

the interface would probably occur at the branch chief luel in Region-V, resulting in a decrease in continuity in dealing with escalated actions in that there would not be a single point of contact.

Region IV personnel would be required to travel to Region V for enforcement conferences and to coordinate enforcement package preparations for actions resulting from their inspection activities.

Under this Option, Region V would not have a Team Leader or the capability _to plan and execute team inspections.

Region V management would define team inspection schedules and focus, but would rely heavily on Region IV to staff the teams and to often provide the Team Leader.

Likewise, specific team planning and report writing would often occur in Region IV, although in all cases Region V management would be the final approval authority for team reports.

Finalizing team reports, in particular, would require substantial coordination between the regions and would likely require Region IV team leaders to travel to Region V for several days to finalize the report before issuance.

Regional Resident inspector meetings usually occur about three times per year.

The meetings have been an opportunity for the staff to be trained in various areas, usually requiring presentation support from Headquarters.

The meetings have also been an opportunity for the resident and projects inspectors to meet

-with the EP, RP, and security inspectors.

Based on the small Region V size with this Option and the limited Region V resources available to coordinate -

the meetings, it may no longer be efficient to hold them in Region V.

An alternative would be to have Region V participate in Region IV resident 48

i

+,

e meetings; however, this would require virtually.the entire Region V technical staff to travel to Region IV for each meeting to accomplish-the same training previvusly completed in Region V.

In either case, additional inefficiencies would be introduced.

This Option would maintain Region V as the sole NRC region having inspection authority and responsibility over Region V power reactor sites.

Region V would remain the licensaes' point of contact on all inspection issues.

Region V's ability to promptly interact with lic.ensees on certain technical -issues on a daily basis would be significantly complicated by having 50 percent of the Region's technical resources in Region IV. While these difficulties could be overcome, it is likely that routine discussions with licensees would often be

~

delayed because Region V managers would not possess the level of knowledge of-issues that comes from interacting daily and directly with Region IV-inspection personnel.

Regardless of the degree of coordination between the regions, routine interactions with Region V licensees would be less efficient, less informed, and may result in a level of dissatisfaction on the part of the licensees.

An added point of confusion for licensees would be that licensees would find that they frequently speak to Region IV personnel at the inspector /first-line supervisor level, and to Region V at the management level.

Communications with Headquarters personnel would also be complicated for the same reasons.

There would also be some negative impact on implementation of programs other than the power reactor program, which would be fully performed and managed by Region IV personnel. The principal effects on the implementation of these P

49

.s programs would be the additional travel time to licensee sites, and more difficult communications with licensees and State officials because of time differences, as has been discussed in Option 1.

1 r

The impact upon the emergency response / event response program is discussed in the paragraph er: titled Incident / Emergency Response.

Interface with Licensees. the Public. the Media. ' State and local Governments.

Federal Agencies. and Internal NRC Interfaces For the reasons discussed in Option I, the degree of interface with licensees (especially materials licensees), the public, the media, State and local governments, and Federal agencies would be affected.

In addition, this Option would result in confusion with the public, the media, State and local governments, and possibly some Federal agencies because both Regions IV and V would be regulating NRC licensees in the same geographical area.

It would be particularly difficult for States and counties in that they would have to i

coordinate with Region V on power reactor matters including power reactor emergency response programs, and would have to coordinate with Region IV on materials and agreement state matters including materials and fuel facilities emergency / event issues.

j Internal NRC communication and interface activities would be complicated, especially in the area of power reactor enforcement, in that both Region IV

.and Region V personnel would probably be involved in significant enforcement issues.

Headquarters counterparts would probably need to coordinate with both 50

w Regions IV and V with attendant time zone limitations on those issues involving both region's personnel.

Incident /Emeraency Response This Option would create major problems in incident / emergency response as related to power reactor events.

Region V would be responsible for the power reactor program, however, with only about 33 total staff, including the resident inspection staff. There would be one less senior SES manager in the Agency qualified to serve as a Director of Site Operations, thereby reducing the overall Agency capability in this area from 13 to 12.

Region V-would not have the capability to perform regional emergency response functions as defined by the current NRC plan. The full response capability (base and site teams) would have to be the responsibility of Region IV.

Region IV pers~onnel would have some degree of familiarity with Region V power reactor facilities since the EP, RP, security and engineering inspections would be performed by Region IV staff.

However, the day-to-day knowledge of Region V. power reactor facilities (both management and inspector) would be located in Region V, and would not be available to Region IV except through telephone communications.

The Region IV Incident Response Center would keep up-to-date information related to Region V power reactor facilities, which would also be kept in Region V.

The small technical and management staff located in Region V could assist the base team in Region IV-via telephone communications, or be sent to the power i

51

O O

reactor site to assist the resident inspectors until the site team could respond from Region IV. All health physics and security responders would.be dispatched from Region IV.

The Region IV emergency response coordinator would include these concepts into the Region IV emergency response plans and-training.

The Region IV emergency response coordinator would also be responsible for Region V staff training.

In total, this would require added coordination and result in confusion.

Employee Imoacts - Short-term and Lona-term As discussed under.0ption 1, employee impacts associated with this Option are considered significant. While these impacts are estimated to be the greatest-under Option 1 because the largest number of employees would be affected, these same types of concerns and hardships would be felt under Option 2; Under Option 2 the small Region V office would consist of 33 staff,13 of whom are at the resident sites. This means that 20 of the 88 staff currently-assigned to the Walnut Creek office would' remain in Walnut Creek.

The remainir-staff would be offered reassignments and it is expected that I

roughly 76

_ ant of these, or 53 staff, would transfer.

It is estimated that the remaining 15 staff members would either retire or leave the Agency.

Imoact on Costs. to Include Travel. Transportation. FTE. Relocation. and Administrative Support.

The methodology used for estimating the savings and costs associated with Option 2 is basically the same as described for Option 1.

The principal 52

differences in costs are mainly attributable to two factors:

1) the number of people transferred from Region V and 2) the number of positions increased in Region IV. Appendices 7 and 10 reflect the changes associated.with these factors and the associated savings and costs.

The exercise of this Option would ultimately result in an annual savings of about 25 FTE (55 FTE from the FY-93 budget) and would require a one-time cost of between $5.9 and $7.7 million.

If the Agency actually realizes this 25 FTE savings by October 1995, it is then estimated that the one-time costs would be recovered in 2.1 to 2.7 years with recurring savings of $2.8 million and long-term projected dollar savings of $3.6 and $5.4 million in 5 years and $17.7 and $19.4 million in 10 years.

Positionina for the Future In contrast to Option 1, this Option could allow for expansion of an NRC West t

Coast office to accommodate any new power reactor construction and operations, as well as other program additions including an increase in the materials program and support of the proposed Yucca Mountain facility.

b 53

00 tion'3 -

Reducina Reaion V to a Staff of Acoroximately 25-30 FTE (includina Residents) as in Option 2. but Structured as a Field Office of Reaion IV. Rather Than a Separate Reaional Office.

Option 3 is a variation on Option 1 in which an NRC management and reactor program office presence is maintained on the West Coast through the maintenance of an NRC field office in Walnut Creek, California.

Implementation of this Option would retain most of the technical resource benefits c' Option 1, but would result in some additional management and program implementation challenges.

In this Option, the field office would be manned by an SES-level director reporting to Region IV.

This manager would be supported by two project-section chiefs, four project engineers / reactor engineers, two administrative support personnel, and a public affairs officer.

The field office would_be responsible for the-day-to-day oversight of the resident inspection program at Palo Verde, San Onofre, Diablo Canyon, and WNP-2 sites. The approach would be to minimize program support and administrative functions retained in the field office, avoid duplication of functions, and maximize dependence on Region IV while maintaining those administrative and program support functions necessary to support the field office. The models used for this approach include the r

Uranium Recovery Field Office and the former Office of Special Projects, Comanche Peak Projects Division Field Office.

Each of these field offices was headed by an SES field office director with program and administrative support provided by Region IV and/or Headquarters.

54

This Option involves taking the Region V FY-95 budget baseline organization (Appendix 4), merging it with the Region-IV FY-95 budget baseline organization (Appendix 5), resulting in.a Region IV organization as shown-in' Appendix 11.

The field office portion of the organization as shown in Appendix 11 would be located in Walnut Creek, California.

The total FTE savings that are estimated with-the exercise of this Option 'is 33 FTE (63 FTE from the FY-93 budget).

Impact on Mission Accomolishment Option 3 provides many of the advantages associated with Option 1.

Some of these include a broader base of technical expertise and added flexibility-in -

resident rotations and inspection planning. Some of the time zone concerns associated with Option 1 are reduced, particularly regarding day-to-day oversight of the power reactor facilities.

However, communications and coordination of inspection program functions would be more difficult under this Option. Much of the communication and coordination activities between the field office personnel and the regional office would be via telephone. The need for additional communication and coordination could also extend to the State liaison function when day-to-day oversight of power reactor facilities would lie in the field office while the State counterpart function for reactors resides in Region IV.

As with Option 2, roughly half of the inspection resources to conduct the 55

-o Region V site program would reside in the Region IV Arlington office. The amount of coordination required to plan and implement the inspection program, and to fulfill other program responsibilities, such as SALP, enforcement actions, plant performance reviews, licensee meetings, allegations, and MIPS would be increased.

Some coordination and communication difficulties could be expected, at least during transition.

The time zone differences and the geographic distances between Region IV and the field office would make it more difficult to meet the greater need for effective communication efforts and Headquarters communication would be further complicated.

s Coordination and scheduling of inspections between the Region, and the field office would require additional management effort.

For emerging issues, the field office would have to rely on resources in Arlington, Texas for the engineering, operator licensing, EP, RP, and security activities.

Extensive participation of field office and Region IV personnel would be required to conduct plant performance reviews.

In order to effectively rank the plants in the region and the field office together, the comparison would be made at the Director, Division of Reactor Projects (DRP) level with input from the Division of Reactor Safety and the Division of Radiological Safety and Safeguards, as well as from DRP personnel in Arlington, Texas and the field office.

The implementation of the SALP process would require some additional coordination.

The overall SALP effort would be conducted in the _ Region IV Arlington office.

56

e e

Under Option 3, inspection reports would be handled similar to the way they are currently handled in Region IV.

Reports initiated by the projects staff would be signed out by the Field Office Director or the region.

Reports initiated by the other divisions would be signed by the cognizant Division Director and would require concurrence by Field Office personnel.

This concurrence process may involve a minor delay to accommodate the time zone and geographical factors but the NRC's Wide Area Network should minimize any such del ays.

Inspection plans would be handled in much the same manner.

Required interface activities with the field office and/or residents would be handled by telephone.

Processing of allegations would be performed in the Region IV Arlington office.

The same would apply to enforcement activities with the additional complication that field office personnel would be required to travel to Arlington to attend escalated enforcement conferences.

Enforcement coordination would be conducted by telephone with resident and Field Office personnel.

Interface with Licensees. the Public. the Media. State and local Governments.

Federal Aaencies. and Internal NRC Interfaces Under this Option, day-to-day interface with licensees should be minimally affected.

Retaining a public affairs presence and SES manager on the West Coast should minimize any impact on NRC interface with the public or the media.

Some effects may be felt by Federal, State, and local agencies since the State liaison and agreement program personnel, who provide the day-to-day contact, would reside in Arlington.

Internal interfaces would be less complex with four, rather than five regions to deal with, with the exception of 57

Le day-to-day power reactor issues, which would require increased coordination due to the need for coordination with both the Arlington regional office and the Walnut Creek field office.

Incident /Emeraency Response As in Option E, the proposed staffing levels within the field office would not support full response capabilities. Therefore, formal emergency response would be directed from the Region IV Arlington office. Additionally, the Study Group does not believe that reliance should be placed on the field office for more than partial first-line response functions, which is already otherwise available from the resident inspectors at other Region V sites.

In an emergency, some staff of the field office would be available to support regional office response activities and, under ideal conditions, could dispatch 2-3 inspectors and 1 supervisor to the affected site while maintaining some office coverage for the unaffected plants.

While this' Option would increase the breadth of technical expertise for emergency response as in Option 1, Base Team depth at Region IV would not be as enhanced because critical regional office functions (i.e., the cognizant section chief and project engineer) would be located in a remote field office. There would be two less senior SES managers in the Agency qualified to serve as a Director of Site Operations, thereby reducing the'overall Agency capability in this area from 13 to 11.

Response times to potential incident sites (current Region V power reactors) i 58

A eA would be the same as discussed in Option 1.

However, since the focus of the field office activities _ is on reactor projects, there would be some small number of management and technical staff available in the field office that could be dispatched to an incident site to assist the resident inspectors during the early phases of event response, fmoloyee Impacts - Short-term and Lona-term Exercise of this Option would result in impact on 79 employees versus 88 employees for Option 1.

Under this Option the field office would consist of about 22 people, 13 of whom would be located at power reactor sites.

This means that 9 of the 88 currently assigned to the Walnut Creek office would remain in Walnut Creek.

The remaining 79 staff would be offered reassignments and it is estimated that 78 percent of these, or 62 staff, would move.

It is-estimated that 17 staff members would either retire or leave the Agency.

Impact on Costs. to Include Travel. Transportation. FTE. Relocation. and Administrative Suocort.

The methodology used for estimating the savings and costs associated with Option 3 is basically the same as described for Option 1.

The principal differences in costs are mainly attributable to two factors:

1) the number of people transferred 'from Region V and 2) the number of positions increased in Region IV. Appendices 7 and 10 reflect the changes associated with these 59

1, factors and the associated savings and costs.

The exercise of this Option would ultimately result in an annual savings of about 33 FTE (63 FTE from the FY-93 budget) and would require a one-time cost of between $6.6 and $8.9 million.

If the Agency actually realizes this 33 FTE savings by October 1995, it is then estimated that the one-time' costs would be recovered in 1.9 to 2.5 years with recurring savings of $3.5 million and long-f term projected dollar savings of $5.2 and $7.4 million in 5 years and $22.7 and $25.0 million in 10 years.

Positionina for the Future The impact for this Option is the same as stated in Option 2.

60

2

,4 00 tion 4 -

Peducino Reaion V to a staff of accroximately 60 FTE (includina residents) with all reactor orocrams remainino in Recion V.

All other orocrams includina 01. fuel facilities.

decommissionino. State acreements. and materials would be consolidated in Reaion IV.

This Option involves the transfer of all Region V programs to Region IV, with the exception of the power, nonpower reactor, and state liaison programs which would remain in Region V.

The 01 field office would be located in Region IV with a smaller satellite office in Region V.

The resulting Region V organization would be as shown in Appendix 12, and_the resulting Region IV organization would be as shown in Appendix 13. The Region V organization reflects the absolute minimum number of management and administrative personnel necessary to support the power and non-power reactor programs. As such, minimal administrative supporc would be provided to the management and technical staff, and some current Headquarters support requirements might need to be relaxed. With the exercise of this Option there would be a net FTE savings of approximately 19 FTE (49 FTE from the FY-93 budget).

This Option provides for a Region V office to be maintained in Walnut Creek,-

California, as is the case in the previously discussed Option 2.

However, by maintaining a larger staff and retaining all of the reactor program implementation capability within Region V, many of the management and program implementation problems inherent in Opt'on 2, would not exist.

Imoact on Mission Accomolishment 61

s' -.

6 This Option maintains a significant NRC presence in the western United States, with the resources necessary to fully and independently conduct the reactor inspection and operator licensing programs, and provides the ability to maintain present response capability to reactor events and emergencies at western facilities.

Program activities such as SALP, inspection planning, enforcement, allegations, management meetings, and team inspections, as related to power and nonpower reactors, would all continue to be carried out as they are currently being performed.

The total number of supervisors in the Region V organization decreases to reflect the reduced level of administrative support and the transfer of the materials, fuel facilities, decommissioning, and State agreements programs.

Also, the number of supervisors involved in the oversight of the power reactor program would decrease slightly with the loss of a deputy SES administrator.

~

The impact on the materials, fuel facilities, decommissioning and state agreement programs would be the same as that discussed under Options 1, 2 and 3.

Under this Option, with the overall reduced management sts.ff, the region's ability to meet all existing Headquarters support requirements, such as attending sponsored workshops and counterpart meetings, would decrease. As an example, one Region V section chief would be responsible for EP, RP, and security, while in the larger regions a separate section chief is assigned to each area.

Because of this reduced management staff, some existing programmatic guidance and requirements might have to be modified.

62

\\

r n

This Option retains the ability to perform all anticipated reactive inspection.

efforts, including AITs.

As has been the case in the past, Region V would continue to request specific technical support from Headquarters for detailed folicwup of significant events.

Interface with licensees. the Public. the Media. State and local Governments.

Federal Aaencies. and Internal NRC Interfaces The degree of interface with licensees, the public, the media, State and local-governments, and regional Federal agencies would remain the same as that which currently exists for all activities associated with power and nonpower reactors.

The degree of interface with licensees, the public, the media, State and local governments, and regional Federal agencies, for all activities associated with materials, fuel facilities, decommissioning, and State agreement programs',

would be affected as discussed in Options 1, 2 and 3.

Also, as discussed in Option 2, this Option would result in confusion with the public, the media, and State and local governments since both Regions IV and V would be regulating NRC licensees in the same geographical area and the state agreement and liaison functions would be split between the two regions.

Incident /Emeroency Response This Option provides sufficient resources to maintain the current' Region V 63

.1 j

r,-

o incident response center, to support an emergency response coordinator,.and to provide for staff training.

For reactor events all base team and site team functions could be supported by Region V under this Option. The requirements for a regional Base Team and those for a site team could be met, but because of. the reduced size of the Region the depth at each position would be limited.

The reduced Region V would have no problem handling minor or less complex events with available

\\

l.

resources. However, for those events in which the Agency goes to expanded activation for a sustained period of time, i.e., more than one shift, the reduced number of staff and managers would become limiting.

This limitation would be particularly notable in protective measures and the health physics expertise, and would eventually affect senior management and other technical staff. The result would be that the reduced region would need to call on Headquarters or another region for support earlier than would a larger region.

i There would be one less senior SES manager in the Agency qualified to serve as a Director of Site Operations, thereby reducing the overall Agency capability in this area from 13 to 12.

Region V, under this Option, could support Region IV's response to materials and fuel facility incidents.

Emolovee Imoacts - Short-term and Lono-term This Option would result in a negative impact on the least number of employees of the four Options evaluated.

64

r.-

o Under this Option, the Region V office would consist of about 58 people, 13 of whom would be located at power reactor sites.

This means that 45 of the.88 staff currently assigned to the Walnut Creek office would remain in Walnut Creek. The remaining 43 staff would be offered reassignments and it is expected that roughly 78 percent of these, or 34 staff, would transfer.

It is.

estimated that the remaining 9 staff members would either retire or leave the Agency.

Impact on Costs. to Include Travel. Transoortation. FTE. Relocation. and Administrative Support.

The methodology used for estimating the savings and costs associated with Option 4 is basically the same as described for Option 1.

The principal differences in costs are mainly attributable to two factors:

1) the number of people transferred from Region V and 2) the number of positions increased in Region IV.

Appendices 7 and 10 reflect the changes associated with these factors and the associated savings and costs.

The exercise of this Option would ultimately result in an annual savings of about 19 FTE (49 FTE from the FY-93 budget) and would require a one-time cost of between $3.6 and $4.8 million.

If the Agency actually realizes this 19 FTE-t savings by October 1995, it is then estimated that the one-time costs would be recovered in 1.7 to 2.3 years with recurring savings of $2.1 million and long-term projected dollar savings of $3.7 and 4.8 million in 5 years and $14.3 and

$15.4 million in 10 years.

65

,s

'o Positionina for the Future The impact of.this Option is the same as stated for Option 2.

~

66

o Regional Employee Comments in accordance with the DEDR memorandum of April 20, 1993 (Appendix 3), the Study Group requested and received comments from the Region IV and Region V employees regarding the May 24, 1993 Draft Report.

These comments are included as Appendices 14 and 15 to this rep rt.

The Study Group reviewed these comments and made selected changes to the report.

Additionally, the Study Group determined that there were a number of common concerns that can be summarized as follows.

Limited Scope of Realionment Study A number of employees expressed concern that the study did not encompass other potential areas of savings such as FTE reductions in other Headquarters programs, program overlaps, redefining regional boundaries, etc.

Their concern was that other options for achieving savings exist and are not currently being investigated, that could trim the Agency in small. increments without the necessity to close Region V.

The closing of a region is considered a radical approach to achieve an FTE savings versus a general trimming of other Agency programs such as overhead.

The Study Group did not address the above defined issues in its study because they were not a part of the EDO Study Charter (Appendix 2), and because of time constraints, however, we have recommended further study of Agency-wide 67

r e

overhead.

Geoarachic Imbalance l

Some employees expressed concern that there is an obvious geographic area F

imbalance, relative to the number of states per region, if Region V is consolidated within Region IV.

l The Study Group agrees that a consolidation of Region V within Region IV would result in a significant geographic imbalance, and believes this concern is expressed in the discussion of Option I under the heading of " Interfaces with Licensees, the Public, the Media, State and Local Governments, Federal Agencies, and Internal NRC Interfaces."

Status Quo Consideration Some employees were concerned that the " Status Quo" was not addressed and evaluated as a separate option in the report.

il l

l The Study Group explained to the employees, during the two staff meetings that the Study Group held with Region V employees, that the Status Quo will be considered in the decision making process and that it is a bona fide option which could be selected.

In addition the Study Group revised the report, as a result of these concerns, and added statements under the sections " Assumptions used in Conduct of Study", and " Conclusions and Recommendations."

68

n Lack of NRC Presence on the West Coast Several employees believe that for Options 1, 2, and 3 the lack of significant NRC presence on the West Coast is not given sufficient weight in the draft report.

Even though the Study Group did not revise the report because of this expressed concern, the Study Group believes that NRC West _ Coast presence is a significant issue which should be recognized by the EDO and Commission. The Study Group believes that this issue is addressed in.the discussion of each Option under the heading of " Interfaces with Licensees, the Public, the Media, State and Local Governments, Federal Agencies, and Internal NRC Interfaces."

69 J

o 4

Conclusions-As summarized in the Summary Comparison of Options (Page 9), adoption of any of the four identified options results in FTE and dollar savings. We believe that retaining the status quo, as well as _ adopting any of. 0ptions 1, 3, or 4 would accomplish our mission of adequate protection of the public health and safety.

The Study Group believes that only Option 2 would result in such negative mission and management impacts as to be excluded from further consideration.

Any decision to depart from the status quo should be based on a weighing of factors that includes 1) the necessity of such a step in lieu of possible alternate cost cutting measures that don't entail extensive employee relocations 2) the pros and cons associated with mission accomplishment '3) the loss of NRC presence on the West Coast 4) the effect on our people including the potential long term morale and human relations impact, and 5) the efficiencies to be gained from the option, and the probability that those efficiencies would actually be realized.

While the Study Group has done its best to evaluate these factors, we are not in a position to effectively evalutte the first factor, which we believe is a significant decision consideration.

A recommendation to adopt any of the study options should depend on the necessity that the EDO and Commission feel exists in a tightening budget climate where existing and possible additional pressures to downsize and become more efficient may dictate precedent setting management measures. The 70

e e

Study Group is not in a position to make an informed evaluation of this issue and therefore has concluded to qualify our recommendations and to identify the most significant considerations we believe should go into a decision.

Another important issue, developed after publication of the draft report, is the overall long-term employee reaction to the prospect of the NRC adopting a practice of large scale employee relocation. We do not believe it should be viewed necessarily as a stumbling block to taking needed actions, but we do believe this is a concern that should be considered. This comment is made with the recognition that during the early 1970's the AEC did relocate Region IV from Denver to Arlington and Region I from Newark to King of Prussia.

The Study Group further concludes that any decision consider the following.

o Option 1 would provide the greatest. potential savings from the standpoint of efficiency.

It represents a straightforward management approach with clear lines of authority and responsibility. Some mission enhancements could result. This is the preferred option of the Region IV administrator.

However, it represents the most radical change, with the greatest initial cost, greatest number of affected employees, and a potential decrease of credibility and public satisfaction through loss of West Coast presence.

If this became the preferred option, we believe it would be particularly important to quickly communicate with other governmental entities, licensees, and the public to provide assurances that the NRC has no intention of letting the mission suffer and to solicit views of what actions we could take under the new organization to 71

a continue smooth interactions and communications.

o Option 3 would provide the second highest potential savings and second j

highest cost and personnel impact consequences.

Its pros and cons are similar to Option 1 with the following differences.

It provides a middle ground in terms of maintaining a management presence on the West Coast.

It presents an additional management challenge in overseeing a field office, but the Region IV Regional Administrator believes this option is manageable.

o Option 4 would provide the least potential cost savings with the least cost and personnel impact. It maintains the largest NRC presence on the West Coast.

It would present some external relation challenges in that both Region IV and V would regulate in the present Region V geograrihical area, although in different functional areas, and the state program would be split between the two regions, resulting in some possible external confusion over responsibility and accountability.

The Study Group conclusions are consistent with responses received from the staff as contained in Appendix 16.

72

e a

Recommendations o

If it is determined that the status quo should not be maintained for budgetary reasons, and FTE savings is the dominant consideration, the Study Group recommends that Option 1 be implemented since it results in (1) the highest potential FTE and long term cost savings; and (2) the most straight forward, simplest organizational approach which would result in the fewest number of management and program implementation problems.

If Option 1 is considered to be unacceptable, the Study Group believes that both Options 3 and 4 are viable options with cost saving benefits and either could be successfully implemented.

It is extremely important to provide a prompt decision so that people can o

eliminate the continuing uncertainty in their lives. We believe this is an important issue regarding the effective implementation of any decision. We also believe it important to have a clear, equitable, and prompt plan, with appropriate agreement by NTEU, as to how assignments would be made to all bargaining-unit personnel, o

The Study group was asked to identify any other areas for likely cost savings.

While we felt it was beyond the scope of our study and time constraints to look at the rest of the Agency, clearly a study of overhead in other parts of the Agency is a logical next step if additional FTE and cost savings are necessary. This may also be 73

a important as a fairness issue with many employees.

If the decision is made to adopt any option, we believe it extremely o

important to provide a comprehensive transition plan to include temporary mechanisms to maintain program delivery as people move, support services to employees, active outreach to external constituents to maintain services and allay concerns, and management attention to address affected employee trust, confidence and resultant teamwork and morale.

o lastly, we recommend that any decision adopting other than the status quo, address the Agency necessity underlining the decision.

At present, Region V employees do not fully understand why they seem to have been singled out.

They feel the narrow scoping of the study effectively eliminated other potential cost savings options that would have less impact on people.

74 4

___________________________________.___.____-___________________.__________._________.______._______________w

[*'*%,h, J

UNITED STATES APPENDIX 1.

j NUCLEAR REGULATORY COMMISSION j

j wasMseeoTose,oAseems Y

G 3 C 3 3 1 !;g y 3 3

=>..*

"' ' Nav"'

March 30, 1993 sacas MEMORANDUM FOR:

James M. Taylor Executive Director for Oq ations FROM:

Samuel J. Chilk, Secretad

-l

SUBJECT:

c0MsECY-93-012 - PROPOSE!'E TUDY OF REGION.V REALIGNMENT

[

The commission (with all commissioners agreeing) has agreed' that the staff should conduct a detailed study of possible alternatives for the realignment of Region V._ The evaluation should address any impacts associated with the reassignment of staff-(includin considerations.g SES) and'also anticipate any Union contract The study should include.a-discussion-of other alternatives such as:-

consolidating the' Region IV and V offices-in Arlington, o

Texas, but.hava a deputy run a small satellite office (such like the URF0 office), in California which would report to_the Regional Administrator in Region IV, and' consider a possible realignment of-regional:

o responsibilities to provide a better workload balance.

among the regions.

The staff has forwarded SECY-93-078-dealing with plans to close the Uranium Recovery Field Office (URPO)..The alternatives' considered during the proposed study should take.into account the plans for closure of the URFO.

.ggyjggy)-

9300056-1 1

1

-I cc:

The chairman

' commissioner Rogers l

commissioner'curtiss commissioner Remick

~ commissioner de Planque OGC OIG q

4 75

__-____---___-______-_-_____________f____-___-__-

6-s.

- APPENDIX 2

\\f UNITED STATES

. [

A NUCLEAR REGULATORY COMMISSION 5

wasumoton. o.c.ammian U313 3i f*\\ O 32 March 30, Igg 3 MEMORANDUN FOR: John Montgomery, Region IV Bobby Faulkenberry, Region V Ben Hayes, 0!

Jim Turdici, OED0 Jim Horn, OP FRON:

James E Taylor Executive Director for Operations

SUBJECT:

REGION V REALIGl9 TENT STUDY.SR0UP CHARTER You have been: selected to conduct a review of.several proposed options for the realignment or elimination of the Region. V Office. John Montgomery and Bobby Faulkenberry have the lead for this effort.

The Commission is considering-1 several measures to. achieve efficiencies, and the Cosnission needs additional-1 information regarding these options..Your review should emphasize cost and-FTE savings, the ability to carry out our mission objectives, and internal and '

external interface concerns.-- The study group will solicit input from the.

affacted regional and program. offices.

The suidelines for the conduct of the review are as follows:

1.

The following three options are to be evaluated in the' study:

Consolidation of Region IV and V. into a single regional office that will be located in Arlington,~ TX.

Reducing Region V to a staff of approximatel residents) focusing on the reactor, program. y 25-30 FTE-(including The. remainder of the.

current reactor and the OI and material functions would be

-consolidated in Region IV.

Reducing Region V to a staff of approximately 25-30 FTE, as above.;

but the office would be structured as a field office of Region IV,:

rather than a separate regional office..

2.

The following areas, as a minimum, are to be considered forfeach opt' ion.

during the review:

Overall impact on mission accomplishment Interfaces with licensees, public, media,' state & local government, federal agencies, and internal NRC interfaces Incident /EmergencyResponse Employee impacts /short ters/long ters

-76 e

,e.

.m

APPENDIX 2 Multiple Addressees

. March 30, 1993 Cost savings: Travel, transportation FTE, relocation, administrative support 3.

The following assumptions should be used in the evaluation:

The ratio of direct FTE/ facility for the realigned Region IV should be stallar to the current ratio in Regions I-III.

The ratto of direct FTE/ overhead for the realigned Region IV should be similar to the current ratio in Regions I-III The Region Y resident offices will be staffed to bl.

The current functions and regional boundaries for Regions I-I!!

will remain unchanged.

The realignment will be completed by October 1994.

4.

Provide me with a status briefing approximately two weeks prior to your final report.

5.

The final report, including your conclusions and recommendations as to which of the three options should be implemented and the phasing of the steps to implement the option, should be submitted to me by May 30, 1993.

6.

If the study group needs additional guidance or reconnends changes to the guidance noted above, contact Jim Sniezek.

/

mes or ecutive Director for Operations cc:

J. Sniezek H. Thompson T. Murley R. Bernero E. Jordan P. Norry P. Bird Regional Administrators 77

=.,

i.

1. p ese g APPENDIX 3';

k

[

]

NUCLEAR REGULATORY COMMISSION UNITED STATa8 8

wAsNwoTom. o.c.amuHoot APR 20 gg3

\\

MEMORANDLM FOR:

John M. Montgomery.

Deputy Regional Administrator Region IV Bobby H. Faulkenberry Deputy Regiona1 Ada1nistrator Region V FROM:

James H. Sniezek-Deputy Executive Director.

for Nuclear Reactor. Regulation, Regional Operations and Research

SUBJECT:

REGION Y REALIGNMENT STUDY EMPLOYEE ComfENTS Study of Region V Realignment," I believe that it is e obtain potentially affected emplo of the task group's work in a morlelse's views of the accuracy and comp 1steness 1

formal.way than initially considered..

Employees from Region IV and V should have an adequate opportunity to both understand and comment on tho' study group's analysis. -Employee feedback to 1

the group will also serve as a realit

- your fact-finding and analysis work. y check and additional quality. control on Therefore, please modify the scope of the Rarch 30, 1993, study group charI to include the following additional tasks:

1.

As soon as possible after your May 13 briefin_ q of the ED0 on the draft Regions IV and V. report, make your analysis available to the N"EU and emp 2.

Solicit comment from NTEU and Region IV'and V. employees on-both the accuracy of the facts ~and completeness of the draft report. Coordinate' l

this aspect with the Office of Personnel's Labor Relations' component.

do not expect the study group to solicit or respond to' specific commentsI or opinions supporting or opposing any of the consolidation options, or solicit or respond to requests for the study of additional consolidation options. -While I expect the final report to consider employee tapact the EDO~and Commission will consider individual or Union positions as, part of the decisionmaking process. The request for comment should ask.

3 that connents be focused on significant' issues that may not have been addressed, significant issues regarding the impact on agency alssion, or major cost issues.-

78

APPENDIX 3.

John M. Montgomery Bobby H. Faulkenberry

-2 APR 2 01933 3.

You should modify the rsport as the task group believes is required to reflect the cocnents received.

Since the affected employees and the Union will be kept abreast of the group's work as it is ongoing, I don't expect an extensive cocment period to be necessary, nor do I axpect the task group to provide an item by ites response. All responses received can be included as background to the report and can stand on their own merit.

I expect that this process would add no more than one to two weeks to your schedule.

If you have any questions, please let me know.

)

')

r

% ik XWp J ees H. Snitzek puty Executive Director for Nuclear Reactor Regulation, Regional Operations and Research cc:

J. M. Taylor, EDO P. E. Bird, OP B. B. Hayes, 0!

J. Turdici, OEDO P. J. Rabideau, CCA

3. F. Scinto, OGC 79

g-5g

-1....

lilll$

tit 1,

I r1L-ill

~

.=

'lg,'_l_

- i 51 II~

ijl li j.i jj g

1 J

9

}g reg it:

lit

{_li_ !!! -f i l

llI,l

~h

!I !I !I lI lI 3-I i e

m a a_ t il 1

I g

1 43 11221 I -alI![=!!!!!!

l

~},I Ie

t., g.

1; t

==

t

~!!I- !.,I

(

2 i

ii i

li IL

[lif g

i,Lt- !L!!!I I

I.

tgl.,t t

4-I,;

~h-II!I'I it, Ejji-lililI 11,

{I D I-8 m

.y i

ri r, i r li t..

t e

i i

n u i.

,1qjh I' l b;E vliin

!,,ii ire in i

l jt ilj E,

1 s,girl 1

II II 11 1 t

1 1

n 4l!

.b l

ii i1 t

3 L, !l [ll I

3 5

r s,l I(-]::i-lliija:

y V

5

-e i-f gii i 'i: H ligig

}i II J

, il L-g-

l II

(([Ili[IlIli

.ll!lIllllff

~

l

!..i

. ii

' r !..i r

li

'll b b

vi i

i

,i;lgljb;[d[1-lA1

.f:

b[S[

1 Ir.

1 81 l

l k

k r..i. r iI I

i i,. ii io,,a i y li !.

Ig'ggl

=111 I.111-s j,_!!!d's-!!

I

.!!8

,[

ili,t il _111il

>! L g.i....

2!!.i LlI il nu i;

p_ si i 7 k

k k

_[,l[l l

~

"l i ii i

it i

ci

]L i

tii p I

lib i'p!!

I lll 111111{11 i

b

~

$j d1111 {jl1b-j!!

jr I

1111 y q

.i[

illlj{il

~

['-

r!} I t

__ir!_iiEi..!

11 11 ll illi!

'I!!i i.

InIi'lAiit a.

Li,idi)Lr i a

,ir Li,,t lt

!!!5 I!

t q

82

SUMMARY

FTE ANALYSIS Appendix 7 FrkhJsquo(o oFHON 1 Ol'MD!4 2

. OPI1GN3

,. OmON 4 FY -95

~

+

.c FY -Si

-RIV RV RTV (Combined)

' RIV

'RVF

~RIV'

^RIV

' RV NRR FTE '

47 29 60 18 47 29

.. y..

.,. e..

Tote /:

76 76

-78

'p g_...m,q- _,w.,y. :y-:.e 3

f f79i

& 176:(y:.j f

NMSS FTE (2) 16 8

p

2.,

3y,+

7+

_, -.g,.gyg.

-~

.- mp;,

.pyg,,?

.:.e.14;?.

.r,,;#~Nb.0<

Total: b ~

T 24 '

-24.

-24 L 0 ]-

s.

~

J 24.i %

m s %

OTHER DfRECT 6

6 7

.,.m yy.g y w

s-,

mym.qyg.sg.g mgyg;7my

,

• 9.T I

Totat:

.C 12 '

S~

9-O '-

J, hr,,w'%.,. E 4I.

zs n -

• y OVERHEAD POSITIONS 56 46 69 62 15 72 59 25

.,7

. m.p.ygyy

pw,,

Tote / a P

102' -

69

'77"

.r ' '_ s.:%. - u? ?2 i n~?.3 e a A.-~A '

284?,7 3 < <

.o e

ceN m

INCREASED FTE DUE *ID LOST TIME IN TRAVEL

'2 2

2

-1 FTF/OpdoreWepion

.125 89 180 157 33 186 138 58

r ry-;

mmn;ngy m; ; 3 mq:pp:yy,::

ggy:pmq

?-

'.m /.1.214? '

'180,

..?.190 t.

4...

4198,,-.S. :%... @ m.i b K.190 $ !j

Totaff, e

s

~

m Non-Regional FTE sewings:

m 1

1 1

1 NRR 4

.4 lSAVNYGS FN04f FY-95 39 '-

25' 33!

19

- l t

Aass. anal savings from FY n 30

-30 30 30 l TOTAL SAVnVGSFR04f FY-93 69 55<

63:

A 49: ' l Note 1: The basehne for the studyis the FY95 en6catens based on the FY34 budget submessen l

Note 2: NMSS decreased the FYS5 sR6 cations (-5 FTQ based on decreased workkad for the FY95 budget devekpment

- Note 3: Overheadpositens include section chefs, whech are normeWy carned as direct labor Note 4:FTEsavings are pennerHy from ue.%:l

~

^~

.j t.

s

-I 3:3l I

3' gli$$

~

~

!$ l

!k l,1 l l

t i1i 1

! :n:u

, t.,.;

e E

E g,

-}.lillil' i

jf$

I l li..-

.g

}ijn M[ ]

l

.11y.

3:

lji hI((lt i

i

!liIi

}l}

i N, I..I.

~

84

_.u.

1s.

s

_a

_s

.*s

.a-g a.-

. -n I

g 1

.,a 4,

~

nap 3

~

hp i

%c,a-us\\-

O{~%\\

3 5((}

q4qp1gpr t

2 j

M N, k

b La <ji d

3 3 b

{.

j tgyg: t 4

85

e _

00 0

3 0

0 0

00 0

0 0

0 2

0 0, 0, 0,

0, 0,

0, 1

38 5

7 3

2 08 2

6 1

8 ix 2

8, 6,

9, 2,

d 4

5, $

n n

4 4

3 7

4 p

i 1

e o

t p

p A

O

)

000 00 0 0

0000 0

7 0 0 0

000 00 0

0 0000 0

0 0

0 1

0, 0, 0, 0, 0, 0,

0, 0,0,0,0, 0,

0, 0,

0, E 084 E35 7

3 9040 3

9 5

4 T 464 T82 3

2 4621 4

4 9

6 F

8, 8,

0, 4,

4, $ 5 F$$

1, 4, $

1 $$

(

8 1

1 2

3 3

4 9

5 1

1 00 0

5 0 0 0

00 0

0 0

0 2

0, 0, 0,

0, 0,

0, 54 3

5 9

5 1 4 7

7 9

3 3

2$

8, 1,

1 7,

5 S

n 8

8 5

2 2

N o

1 2

O i

tp I

T O

P 000 00

)

0 0000 0

9 0

0 0

0 O

000 00 0

0 0000 0

0 0

0 1

0,0 0 0, 0, 0,

0, 0,0,0,0, 0,

0, 0,

0, H

E 036 EE57 9

2 7040 1

7 1

7 T

T 4O5 TT1 3 3

1 7247 1

3 6

9 F

I

2. $ $

FF4$

2 5,

1, $

6, 4,

4 9,

28 3$$

W 8

4 2

41 3

6 6

7 4

4

(

1 2

2 D

r E

e T

fs A

I n

C 00 0

7 0

0 0

a r

00 0

0 0

0 t

O 0, 0, 0,

0, 0,

0, o'

2 S

48 1

9 9

4 h

S 24 7

8 1

6 w

A 2

14 6,

5, 2

6, le 4

S n

7 7

3 9

7 n

o 1

n T

it o

e S

p s

s O

O

)

e r

a C

000 00 0

0 0000 0

1 0

0 0

p le E

000 00 0

0 0000 0

0 0

0 f

g 2

M 0, 0, 0, 0, 0, 0,

0, 0,0,0,0, 0,

0, 0,

0, o

in d.,

E 054 E37 4

5 8681 3

7 7

2 er I

T 281 T83 2

1 0536 6

9 2

7 b

u T

F 2$$

8, 3,

0, 4

m b

9.$ $

1 8 F$$

2 8

5, $

-E 4

2 5

5 5

1 9

u V 1

1

(

N 2

n5 1

1 O

9 n e9 o D

h ig 1

t N

e n rR A

00 0

3 0

0 0

oe 00 0

0 0

0 b e 2

d G

0, 0 0

0, 0,

0, et oh t

N s c I

08 3

5 9

5 f

aOo R

00 0

6 4

2 b

1, $

8, 9,

3, 9,

yn 6

R 1

e U

n 9

9 6

5 7

sb C

io E

io 1

2 adt e

a e

t r

u p

cin z

R O

)

0 0000 0

8 0

0 0

inl i at 000 00 0

en 000 00 0

0 0000 0

0 0

0 yr o 1

a 0, 0, 0, 0, 0, 0,

0 0,0,0,0, 0,

0, 0,

0, mr ec E 01 0 EE53 7

2 9205 6

2 6

2 a o r

T 221 TT1 4 1

9 6554 1

5 3

1 IVsf F 7$20, FF4$

2 1,

0, $

3$$

5 2,

6, 2

gA nn 4

2 1

4 7

7 9

7 0

oiS 3

41

(

4 1

3 iga vG eso R

t E

rT s oFs t

f f o t i c n

edl r ea vi r

t oen f i e h

t s

s sc o e

t r

s ap S

it it f

f s

s e

oye r

r T

e e

a a

e clnh n

n S

e e

y e

e y

y eot O

B C

B 0

i r v

e n

s 6

7 1

e t

t d

S io s

s aau

/

r r

r G

s s g

s s

t o

g r

l e

e e

t sc ess e

es g

n n

t t

t g

n e s C

iv a

a a

sgn N

nigt R

ir f

f f

i t

nni_

I s

ior V

g gf i o n

lan iv S

ms e

a iimvo an s e

m t

av c o

a v a

T po i

s d

d d

c e

e e

A iv S e S

n e

an S

R Sa n

Se S

S iu T

e v

v v

d s y

qe z

a

- d v

d g

O a

v e

R ie gmd a

o e

e G

s eyi s

ey n

C P E it n

s ih h

h S

t N

gt aa g

t a i

E neo a O

nr s f

e c

c c

r sie a

n a

r r

R n

iniPr i

iP r

l o

r t g a

a s

I g

u M oc t

er n

t R

ir a o yis v

c c

I in v c r

s a

s s

e t ugi a

oy t

ei t

l n

t e

T a ef n g

g g

ocnv t

t r

s si i S

sh l

R U

si o

s n

n n

ne oa r

e c e u

s s a v

E le e ad u

e a

a a

o C

c EAcam E R o v nm b

a v

iv i

t t

r i

RLS Ac e

v o

te N

E e

T od TRf o

r r

R R

F LA FNO L

T N O RSTA S

Y S

S S

F

o S

N

[?I!!Ei' l

i 7 r,

r,,

.littj) s i

13 1-t 11 33 4 in n g

.i,j 8! 4! 4!!

ii g".-

la

[ (("il Il s

g it 11 Lll F l' f liitti a

1,_!l!j!ll!!!!'

I.

i llll

]

1 r, f 773-8 "la

!~

i li ji[:

[l l t[s i

i l,

i

! L a[

le 1 f

[Il t N!!

l' g

111,,Illijtjlf ',,l!

I p 2 i li 1

I:

f3l1 Lj-Illi,jjjll ]Ijhp

'1)

D-l.

1'

.. lj l

jlf III~

i sill!lllll C

h IlliillrIllij!! jujirb I

11j

!iG!

i iik' i..

ir!I Ln!!t 8Aji!ijid f

i 1

.l 87

.l

REGION V OPTION 4 Ap,.m 12 Regional L.;.

..;v.

(SES)

State Lisenon 1 Secre.ory e

Ofer. (GG-14)

(GG-10)

Eri Ofer>Attomey Branch CNef GG-15 Admin. (GG 15) 1 Secretary G G-7 Ofc. Aset. GG4--Ref. Aset OG4 Travel Clerk OG.7 -- Pur. Prop. Aset. 0G-9.

Pers. Aset. OG-9--Computer Ansp st OG-11 y

2 Mgmt. Analyste GG - Pers. Ofer. (.5) GG-14 e

Of Se Ofc.

s ePubuc Affairs Ofer.

L(GG-15,2 GG-14, GG_7)J' L' ___(_GG-15)______.1' co en DMelon Director (SES)

Deputy DMelon Director (SES)

Technical Aseti 2 Secretartes Team f * (OG 15)

(OG4, GG-7)

Brnnch CNef Branch CNef Reactor Profede Reactor Sofoly & Plant SW (GG-15)

(OG-15)

SecSon CNef SecWon CNef Sedian CNef W CNet Pmpacts 1 Projects 2 EngJoper.

EP., RP., & SEC.

(GG-15) '

(GG-15)

(GG-15).

(0 0-15) 5 Rrs

' 1 P.L (OG-14) 7 Rrs

' 1 P.L (GG-14) 3 Lic. Exam.

4 Engr. Insp.

1 Nor@oever 3 EP Insp.

4 RP Insp.

SEC Insp.

- WNP-2/D.C 0.5 Ofc. Aest (OG-5)

SONGS 4MtOS 0.5 Ofc Aset. (GG-5)

(2 0G-14)(1 OG-13) 2 (GG-14)

Reactor inop.

GG-14/2 0G-13 2 00-14/2 0G-13 OG-14 2 00-14/3 GG-13 2 OG-14/5 OG-13 1 OL Aest_ (OG-9) 2 (GG-13)

(OG-13).

Region V Stoff Other Staff '

Explanatkn ORA =4 Of = 4 ^

- Removes Materiale, FuelFeeluttes, State Agreements Reactor Dev. = 43 PA = 1

- Redumd administratfwe staff Admin. = 10.5 TOTAL = 5

-- Resident Program unchanged (N+1).

TOTAL = 57.5 '

a

. ~ + - - -

a s

j qa g !!i' i li i

i

~

I Il r

a, 1 i 1

ti l1E 1 E,b j

I j

gur li!

[1!!!!!

i r [i t g"I

~

1

.iilli!!!JWl!!!

L L

tiljj l,

!!flI lI II

,!j f !!

Ll((I 1

a1 l

4p, P.

a.i.

s e

1 li !t

[

t~

L!.d r

a gl jilI

~ lij

)!

'l iIIiqrtlim!il'ilr

! s i

1 I!lli!

~l ll i

t II[! !il!!

II c !!ii n i!

i 11 11 l'

llf!b b

r 8

E

!r!~!I E

Wi #; !

1 i

l.

.o 4

APPENDIX 14 REGION V EMPLOYEE COMMENTS REGARDING THE REGION V REALIGNMENT STUDY DRAFT REPORT DATED MAY 24,1993 P

90

h

,?

/

UNITED STATES p*

~,,

NUCLEAR REGULATC4RY COMMISSION g

y REGIOttV

\\o

/

1450 MARIA LANE WALNtJT CREEK, CAUF ORNIA 94596-5368 June 4, 1993 HEMORANDUM FOR:

B. H. Faulkenberry Regional Administrator FROM:

G. N. Cook Senior Public Affairs Officer

SUBJECT:

COMMENTS ON THE DRAFT REGION V REALIGNMENT STUDY Within the scope of the study, I believe the study group has done a good job of encompassing the issues to be considered in a realignment of Region V.

I do wish to comment in three areas:

public affairs presence under Option 1; projected FTE reductions, cost savings, and cost recovery times under all options; and underlying assumptions about the materials and Agreement States programs.

Under Option 1 there would be no public affairs presence on the west coast.

Proximity to a source and availability of that source are common considerations when local news reporters and editors decide whether to seek other input, comment, background or a local angle to a story. Without a west coast presence, NRC's perceived accessibility will decline, contact with local media will deteriorate, and we will have fewer chances to communicate with the public through the press.

Forced to cover half of the United States, the Region IV PA0 will not be able to maintain the degree of familiarity with local reporters that is typical today, and the trust necessary for clear and open communication will be impacted. Reduced familiarity with local reporters and licensee public affairs people undercuts crises communications, when we most need to be effective to assure clear communication with the public.

Additionally, the time zone difference presents image problems with the' press and the public in day-to-day contacts; inevitably, we would be perceived as hav4ng "gone home early" by closing shop when the west coast is in the middle of the workday afternoon.

Regarding FTE reductions, the study notes on page 48 that under Option I the entire Region V staff would be offered transfers. The number of employees who would move is estimated at 58 to 71..

Yet the FTE savings for Option 1 appear to be based on positions in the realigned organization, not on actual employees retained. The additional office space. required in Region IV also does not appear to account for the additional transferred staff. ' These factors would appear to increase the payback time, as may be seen'in the phrase "If the Agency actually realizes this 39 FTE savings by October 1995, (Page 4).

Similar problems exists with the FTE savings, cost savings and payback time projections of the other options.

91

r o

In the area of the materials and Agreement States programs, my personal experience in Region V over the last eight years leads me to believe that presence on-the west coast is more than a nicety.

State personnel rely on our proximity, our availability, and our expertise.

Leaving the west coast will inevitably cause a sense of abandonment, which will be replaced by resentment when we ask the state to help us with a problem at our licensee's facility!

The further away we are, the less we will be perceived as understanding the state's concerns.

Time zones become very significant when discussing regulation in Hawaii and Alaska, in particular.

If we are willing to regulate materials licensees in Hawaii on a five hour time difference and Alaska on a three hour difference, I fail to understand why we would not handle all materials licensees from Headquarters.

This is, in fact, the crux of the question.

Is the Agency willing to spend money and FTE to maintain regional presence, or have we reached a point at which, for cost considerations, we are willing to accept the attendant risks and inherent criticism certain to come with a withdrawal from the western half of the nation?

cc:

J. Fouchard I

l 92

'4 UNITED STATES f"

NUCLEAR RE*ULATORY COMMISSION OFFICE OF INVESTIGATIONS FIELD OFFICE REGloN V WAL T CRE K C AFO IA June 4, 1993 MEMORANDUM FOR:

B. H. Faulkenberry Regional Administrator j

FROM:

William J. McNulty, Director Office of Investigations Field Off' ice,

! ion V (1

SUBJECT:

REVIEW 0F THE DRAFT REGION V REALIGNMENT STUDY The Office of Investigations (01), Region V, is presenting a consolidated comment on the Region V Realignment Study draft report. The following comment applies to Option 4:

Page 74 indicates the 01 field office will be consolidated with Region IV, however, the organizational charts for Region IV and V, Option 4, show an 01 field office in Region V with augmentation to Region IV field office. Which version is correct?

f 93

From:

Philip H. Johnson (PHJ)

To:

BFF Date:

Friday, June 4, 1993 4:41 pm

Subject:

COMMENTS ON CONSOLIDATION The following comments are provided on the Regional Consolidation Study:

1.

Regarding Option 1 or 3, the problem of a region spanning three time zones (even more when the Pacific areas are considered) appears to have.been minimized.

Regional office personnel who want morning status or resident contact will find the two-hour time difference to be a problem.

On the other end, residents will find themselves being asked to come into work very early to support activities which occur early in the regional office's working day.

2.

Regarding Option 1, the decrease in NRC presence on the West Coast will be striking.

The states, utilities, and other licensees will find travel to Dallas for normal interface to be a significant burden.

The two-hour time difference will also be a significant disadvantage for normal telephone interface, since less than 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of common working hours will remain (9:30 to 4:00, Dallas time, minus lunch periods at each location, which occur at different times).

3.

Regarding Option 4, the disadvantages appear to have been overly emphasized in the report. The line of demarcation between reactor and non-reactor issues and licensees should not be difficul; to define.

A smaller Region V which covers all reactors would work well.

Providing oversight for non-reactor licensees from another location would appear to offer minimum confusion -- in a manner similar to the way OSHA or agreement state issues are handled now.

4.

Concerns regarding emergency response and dispatch of inspectors will definitely increase.

Travel time to WNP-2 from Region V is often over 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and this (ant the attendant expense) would worsen significantly for travel from Dallas.

The problems associated with this concern also appear to have been minimized, assuming optimal travel conditions will prevail.

5.

I know a lot of thought has gone into the cost-benefit aspects of the study, and it is difficult for me, without significant thought, to comment intelligently.

I have an nagging concern, however, that the costs of inspection travel from a consolidated Dallas office have been based on optimal travel and scheduling assumptions, and will in actuality be somewhat higher.

6.

While it's obviously outside the targeted scope of the study, it is painful to consider that many more obvious methods of reducing positions and.

trimming FTE (e.g., consolidate the functions performed by AEOD and NRR Events Assessment Branch) without massive geographic relocations have apparently been rejected by the Commission and the EDO without significant thought.

7.

I hope I'm wrong, but the sense I get from the rumor mill is that consolidation is coming -- perhaps has already been decided -- and that the severe personal and financial impact which will be felt by 80 to 90 people, along with the drastic reduction of NRC presence west of the Rockies, will be less important than a painless (to HQ personnel) method of saving 25 or 30 i

FTE.

94

.b

.s e.

4 h

Thank you for the opportunity to comment.

Phil Johnson l

CC:

.CAV, KEP, SAR i

4 i

r f

5 i

,'l i

?

f

.i s

95-

.-;-. -..~.-. -

e o

June 4, 1993 Note to : B. F. Faulkenberry, Regional Administrator From:

G. P. Yuhas, Chief Radioactive Materials Safety Branch

SUBJECT:

COMMENTS ON DRAFT REGION V REALIGNMENT STUDY Thank you for the opportunity to comment on this important study. The following comments have been grouped in accordance with your memorandum dated May 24, 1993.

1.

SIGNIFICANT ISSUES NOT ADDRESSED

- The March 30, 1993 memorandum for Mr. Taylor from Mr. Chilk stated "The study should include a discussion of other alternatives such as:

consider a possible realignment of regional responsibilities to provide a better work load balance among the regions."

The draft study seems to have ignored this direction.

The regional offices have been clearly advantageous to achieving the mission of the agency.

Why isn't there a discussion of transferring responsibilities for materials, fuel fabrication and decommissioning activities in Idaho a_nd Utah to Region V?

If we are serious about FTE reduction and improved consistency why aren't we evaluating consolidation of Region I in White Flynt II?

Region. V has in the last two years spent a large amount of the tax-payer's money upgrading the Region V office, like install: tion of a local area network, yet no mention is made of this potential loss to the public if Region V is abandoned.

- Page 15 The options evaluated did not consider status quo.

To compare the four options presented without consideration of no change to Region V (as it would be in the future considering. expected decreases in work load) results in an inaccurate picture of the true options.

For example, as the work load decreases one.could expect a reduction in staff, reorganizations within the region'to reduce-the amount of management overhead, reduction in overhead expenses, and perhaps movement of the office to a local Federal building when the existing lease expires.

Failure to consider _ the realistic fluctuations in a Region V as currently established results in an invalid and inaccurate assessment of the four options.

One could realistically envision a 1998 Region V with the same scope and responsibilities but with a work-force and organization _ tied directly to.

the existing workload.

How would the proposed four options compare to a 96

1998 Region V consisting of an SES Regional Administrator and Deputy, three Branch Chiefs (Reactors, Safety, and Support), with two Section Chiefs in 'each branch, relocated to the Oakland Federal Building? This sort of realistic projection would provide for a fair comparison of not only FTE savings but cost and impact on the mission.

Note: $1.9 million dollars in penalties would be saved if Region V fulfills its office lease through 1998.

None of the options considered truly address the impact on our mission because the PUBLIC and the LICENSEES have not been given a chance to offer their views. We don't seem to have learned much from the BELOW REGULATORY CONCERN (BRC) experience.

It seems illogical that a decision effecting one fourth of the nation would be made behind closed doors.

- Page 4 The options do not imagine a need to re-open a Western regional office.

It appears that the GA0 report of NRC oversight of nuclear medicine and the Agreement State Programs may result in the need for more materials involvement in the western states. California's materials program '(about 3000 licensees) may require additional NRC support and oversight in the future.

Should the NRC respond to Senator Glenn's concern about the inadequate regulation of radiation medicine with legislative changes that e.xpand our role, California could present a huge workload.

Finally, California has long been a center of advanced research and technology development.

Region V might be a better location from which to monitor future development at facilities such as General Electric, EPRI, and Stanford.

Any decision to change Region V should consider. future developments in the field.

- Page 42 The impact on Region IV employees is not addressed.

Consolidation of the Region V function in Region IV will result in great stress to those Region IV employees that will then have to compete for their jobs.

This stress and possible chain reaction of personnel actions will be very disruptive and costly. The Region IV employees will,also' lose confidence in NRC management when they realize that they were misinformed concerning the security of their jobs.

This point might also result in legal action against the NRC.

Page 75 The impact of relocating materials licensing and inspection, fuel facilities, and decommissioning to Region-IV is assumed to have no impact on the agency mission.

The evaluation does not address the impact on the public of not having a-group of experts readily available to deal with their questions and problems. The public or licensees contacting the option-4 Region V are likely to feel like they are getting the run-around when they're told to 97 8

call Texas with their question. The public will_ be outraged if the local Region V office is not capable of responding to the frequent materials incidents.

2.

IMPACT ON THE MISSION

- Page 3 Option 1 provides one sentence to add:

,s the public impact of consolidation in Texas: "There would also be a loss of full time management and external interface presence on the West Coast, with a possible reduction in agency credibility as a result."

Relocation of Region V to Texas would negatively impact the public and our customers (licensees). The public in Region V will have less access to the agency ~and that access will cost more, Region V handles many calls each day from members of the public.

Many of these calls are directed to Agreement States when appropriate. The extra cost and hassle of finding our telephone number in Texas will serve as a deterrent to seekir; advice. The Region V materials staff has developed a close workiag relationship with representatives in each state and many other loca" and federal representatives. These relationships will be disturbed and nay never be fully reestablished due to the lack of proximity.

Region V health physics and emergency planning personnel serve as a pool of expertise and equipment to support the Federal Radiological Emergency Response effort and States on the West Coast. Our ability to provide the same quality of support is unlikely if these health physicists are located in Texas.

Finally, the public and the media want to interact with agency representatives that have a vested interest in their community.

An NRC office in Texas will never satisfy this criteria.

One look at the attached map showing the proposed geographic impact-of consolidation in Region IV immediately causes the viewer to question the merits of this option.

- Page 5 Option 2 does not include adequate health physics expertise.

With an NRC Region V, the public will expect that the office will be able to address health and ' safety.

The states and the public will also expect local NRC officials to represent the NRC position regarding any event that might occur in.the region.

- Page 24 The evaluation of Option 1 contains the following comment:

" Headquarters wo'uld have one less region to deal with programmatically, resulting in some benefit to consistency."

This comment evokes the obvious question; if we really want to save money, reduce FTE, and improve consistency why aren't we studying consolidation of Region I and 11 in headquarters and Region III, IV, and V in a midwest or western location?

98

Page 35 The incident / emergency' response discussion does'not-address the negative impact associated with loss of the t

NRC Mobile Laboratory.

The-NRC-Mobile Laboratory played a major role in the early days of the Three Mile-Island accident.

The ability of the Region IV Mobile Laboratory to respond to an event in much of Region V is not discussed.

I suspect that it would require at least-one additional day ~for the Ragion IV Mobile Laboratory to reach most of the Region V reactor sites.-

3.

MAJOR COST ISSUES Page 4 No net FTE will be saved by the closure of Region V and yet this consolidation will cost millions.

It is our understanding that all Region.V-personnel will be offered positions with the agency.

If the NRC stands by this promise, how can 39 FTE be saved'?

If the move will cost between 57.5 and.59.3 million what have we saved the taxpayers?

It would seem far more logical to steadily l right size the agency as work load decreases. -For example, when a power.

reactor like Rancho Seco enters Safstore, its assigned NRC FTE.should be reduced to one part of one materials inspector's time after one year.

The regions should shrink proportional to work load-in real. time.

When.

the existing. Region V lease runs oat perhaps the regional office should t

be. moved into.the local Federal Building.

- Page 43 The evaluation'used an average value of $80,000 per year to calculate salary and benefits cost savings.

Using an average value may be easier, but in reality most_ of the FTE saved by consolidation in Texas will come from lower graded employees.'

The study should have attempted to more accurately calculate this savings.

Page 49

-There are about eight individuals-who could retire and are not expected to relocate.

The study-did not recognize that these' individuals may not retire to.

convenience t_he agency.

Perhaps the cost of their relocation'should have.

been considered.

4.

INCORRECT INFORMATION Page 2

- The comment is m'ade that the smaller regions,"...do not provide the degree of depth and breath of technical expertise. available in the large regions."

Region V has significant' depth and technical expertise in the field of ~

health physics. Of the twenty five professionals in the Division of Radiation Safety and Safeguards that have radiation safety responsibilities, five currently have Masters of Science Degrees in 99

Health Physics, three have Masters in Physics, two have Masters in Nuclear Engineering, one has a Masters in Medical Physics, one has completed her course work for a Masters in Health Physics, the remainder also hold degrees in related fields, or in two cases, each has over thirty years of experience.

In addition, two individuals are certified by the American Board of-Health Physics.

Region.V has cross trained many of its Health Physicists such that they can support reactor, materials, or fuel facility health physics problems.

Two individuals are also fully qualified resident inspectors and another Health Physicist has qualified as a reactor inspector.

Region V has never called on another region to provide health physics support to complete the inspection program or assist in emergency response.

Region V has on occasion, and is always ready to assist the larger regions in their efforts to complete the inspeGion program.and respond to emergencies.

Region V has a strong bench of versatile players that has consistently met every challenge.

We do recognize that in a serious event, we like any other region, would count on the support of the entire agency.

- Page 22 The History /0verview fails to address the pre 1982 success of small regions.

The regions were not always large.

No facts are presented to substantiate that larger regions have a more positive impact on safety or public service than smaller regions.

Page 38 The evaluation placed the greatest emphasis on loss of the 8% locality pay by putting that paragraph first.

It is not correct to create the impression that employees are more concerned about locality pay than they are with losing their. jobs, their homes, and their sense of community.

In conclusion, I fully support your efforts to right size the agency; however if we don't think that regions are important why are we not considering consolidation of all the regions in headquarters?

i b.h

• k G. P.

as i

i attachment:

as stated 100

~.

4, i

MAY 28, 1993 HDS3HNDGt RR:

B. H. FAIFJGNBIIRRY FRCH:

DEE AC3GR SUEL71CP -

3GVI1!N OF 'IHE DRAFT RB3ICH V RDLIGOGNP SILIft Attached are my ocsiments to the study._ I also plan to. write to the h4==ioners ocncerning the 2Do's getmand rules fcr the study, sinos that is my main concern.

1 y

?

e C. Adcar ion V Reactor Inspector

+

9 1

101 TOTAL P.04.

i Study % = dA Page 28, last' paragraph discusses the benefits of a larger inspection 1.

staff in a largar region. Mille the listed benefits appear true, it is also true (but not stated) that the irdividual inspector's ovarall knowle&ys of each site's unagement, design and operation will be raw =4 in a large regien with nors sitas.

R*---r d so noting.

2.

Page 29, firsh ocrplete paragraph, last sentenos.

I don't see this as a benefit unles* Pagions IV ard V have a history of rcir v-T-w tion.

a 3.

Page 35, this' analysis seens wrcerJ. Flight times for a charter plane fita Dallas to Lincoln, Nebr. plus drive time to 0:cper is cartainly less than the flight / drive to Diablo Canyon or RG2 frtn Dallas. Unlaan we irurd to pay scnecne to raintain a standby jet in Dallas, response teams frcn Dallas will not mke the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> time....and the airports near DC are often fogged in (maionally at RIP 2).

May doesn't the study say honestly that you ray not mke the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> time limit frcn Dallas and let the M maion deal with it?

i Also this section says the staff would call upon the residents frem the other West Coast sites for immediate limitad resp;mse to any site that had a rajor problem. Please add that R G2 is excluded frcn this statement, since there will be no nearby residents.

4.

Page 37, eeoced paragraph. 'lhis, in my mird, is entirely iluu.4.

In an ecaiuncy the entire NRC staff would (and should) respcod.

I disagree that regicnsl'bcundaries would bloi any combined response. 'Ihe overall lens of 70 people in regions IV/V is what will have a negative i@act on ernamgancy response, by reducing the overall pool of talented people.

W argument that 180 people in Dallas can respond to a west coast e-vurcy better than 80 people in WC and 100 in Dallas says that Rsgiens IV ard V renagement would let Regional kcundaries interfare with an F & vorcy response. With separate Regions, initial people would get there earlier, ard the pool of badup people is still there, as rW.

i Raquest this pagra#2 be reworded.

5.

Page 44. Does the travel costs include the extra trips inspectors will have to make trun Dallas to West Coast plants to mintain the same inspection effort? To get 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> of DIE, a typtoal inspector a:xnirg

- to West Coast plants frtn Dallas will have to rake two rcre trips than he/she would have had to make frca WC.

ht amounts to 2 nors rtund trip air fares, cat rentals and 10 days per diem. 'Ihis cost will occur.

I Please insure jyour study includes it, i

6.

Page 45.

(Question only) Since the cost of travel to WC frun NDC is only 60 dollars rete for a round trip, ard per diem about 40 dollars a day rare, the avutage }Q exployee ccning to RV on site spoolfic bus 2 ness, will cost arourd 200 dollars rcre for a short stay,100 of these trips would be 20,0$0.

)

Trips taken to RV on regional business would ocet about 800 dollars rare for abort trips.

150 of these trips would be 120,000 dollars.

102

m-p3..

L Do we really have that many visita/rwiews per year?

7.

Option 4.

Ne67 math? Region V Ft95 staffing shows 6 materials ir%%.. the Region IV Option 4 staffing shows an increase of 11

. positions'in tRSS, an increase of 1 in CRA fce the state agreement position, and'an increase of 1 in 139R to sqEport the new people., '!he study indientes that 1 ailitional inspector will be required, &an to travel tias....so if you transfer 6 positions and add 1 you should have an incesass of 7 positions, not 11.

I don't understand 2ere the other 4-positians cuan frtas. Planas resolve.

8.

Q:mment.. If ophians 2 cr 3 were to be' chosen, the mmm4== ion, rm1d allow additicmal reacter inspectors to week out of the MC offios, iWdng Wok coast plants and ooomsionally plants closer to Dallas.

This would be'no acre expensive than flying people frtan Dallas, assuming "noadditiona) cost"officespaceisavailableinWC. This would be only for existing qualified i;w%. and only until they retired, were gen or fm office space beamme unavailable. This option would be.

especially iq:cetant to Bill Magnar, with his wife's medical condition.

I'd appreciato it if you oculd put this option in the study, as it oculd save the hhien moving expenses, pnmelude personal hardships, and potentially ainst nothing.

9.

Comnent. 1hane are several places in the study'Which die $na the;1imited overview that iMm. in a small Regien V would have, &as to a-amall aanple of si to inspect. This oculd be easily taken care of throuq$

more exchange inspections with other Regions and doesn't appear to take servirxJ to Dalkas to resolve.

atW xW ncrted that scre ana:hanges could cover without acrving.

L t

u 1

[

-i 103

_ _2

June 4, 1993 Memorandum For:

B. Faulkenberry, Regional Administrator From:

H. Wong

Subject:

Comments on Draft Region V Realignment Study I have comments on the Draft Study for your consideration:

I.

In the discussion of various options there does not exist an explanation of the method which would be used to select the people that would fill the existing positions. Would Region V people be in the position to fill only the available (open) positions that exist or would the Region V people be able to " compete" for positions now filled by Region IV personnel? This seems important in defining the expected costs of any realignment in that " competition" for positions would mean multiple moves by Region V and Region IV personnel.

2.

In the discussion of Option 1 (page 29, last paragraph), a significant startup cost that was not mentioned is related to licensee /NRC communication difficulties which would occur during the transition phase.

Also in that paragraph, in addition to " establishing inspector familiarity with licensed facilities" as a startup cost, I would include "NRC manager familiarity" as an issue also.

3.

In the discussion of Option 1 (page 38, middle paragraph), hardships related to " potential moving expenses which are not reimbursable" are discussed. However, these expenses can be substantial as evidenced by several employees in recent moves to Region V and some expenses are not just related to " moving." Some expenses can include those pre,sously not necessary while employed in the Walnut Creek area, such as new child care expenses.

I would suggest changing the sentence to

"... hardship associated with potential expenses related to a move to a new aeoaraphical area that are not reimbursable.

Based on personal experiences with recent moves.

unreimbursed expenses related directly to movino and travel to the new work location may be substantial (several thousands of dollars).

Similarly, I would suggest a sentence be added to the end of the first paragraph on page 40 "An additional concern is for child care currently provided by relatives (grandparents, sisters, cousins, etc.) by choice or financial necessity would be eliminated."

I appreciate the opportunity to provide my comments.

.H Howard Wong 104

.e c

MEMORANDUM FOR:

B.H. Faulkenberry Regional Administrator FROM:

James L. Montgomery Senior Materials Specialist

SUBJECT:

COMMENTS ON DRAFT REGION V REALIGNMENT STUDY I have completed my review of the subject draft study. While I do not have all of the background information and data that was used to arrive at the conclusions presented, I do not see obvious errors in the factual information the study group has prepared within the study group's charter.

On pages 33 and 34, a comment is made that some States and licensees may perceive a lack of _ local NRC management presence and that senior NRC managers will encounter difficulty in maintaining frequent contact with State and county officials.

The study report should also emphasize that the materials technical staff engages in frequent contacts with state, local and licensee personnel. Many persons contact our branch daily requesting information and assistance on a multitude of materials licensing and inspection issues.

In my area, materials licensing, I receive 10-15 calls daily and some people merely

" drop by" the office to discuss matters because of convenience. Most callers, have indicated to me that a Texas office and long distance number would inhibit or eliminate many of these contacts.

On pages 50 and 51, I believe you may have significantly underestimated the future workload impacts which may occur in the materials program. As a result of the'recent Congressional Hearings in Washington,- D.C. and other publicity and radiation incidents,' the NRC medical radiation protection program appears to be headed for significant changes.

It is too early for me to know the impact this will have on the NRC but the May 17, 1993 memorandum from James Taylor to the Commissioners gives some early indications.

Region V is programs in the United States (greatest concentration of medical radiation literally in the middle of the i.e. Cali fornia). California will _ soon approach 3000 materials licensees. At the very least, the decision on regional consolidation should be delayed until the Comission and Congress (7) are able to make decisions affecting medical regulatory activities.

I realize my latter comment may be out of the scope of your study charter.

However, I believe the comment to be vital to the final decision making process and urge you and the study group to seriously consider this information for inclusion in your report.

Sincerely,

/[5 James L. Montgomery 105

June 9. 1993 Note To:

-B. F. Faulkenberry Regional Administrator From:

G. R. Yuhas, Chief Radioactive Materials Safety Branch

SUBJECT:

ADDITIONAL COMMENTS ON NUCLEAR MATERIALS PROGRAM TREATMENT IN THE-DRAFT REGION Y REALIGNMENT STUDY Since the relocation of nuclear materials safety. function appears to be the.

-i only option considered in all cases, I feel it. appropriate to offer several-additional comments.

Relocation of the materials function to Region IV will

~

reduce the service provided to the Western United States and Pacific Territories.

OPTION 1 MATERIALS IMPACT:

1 Comment: The draft fails to adequately describe the' impact on our mission in-the area of nuclear materials safety _ area.

Specifically, the daily H

contact with users and potential users of nuclear materials ~ will be-exacerbated,.Siemens Power-Corporation which employees.about 900,-

operates 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, and' currently is rated to produce ~700'-

~

metric tons of fuel par year is_ planning a $20 million-dollar-i expansion and-needs.significant NRC' oversight; General. Atomics while currently decommissioning its HTGR fuel fabrication facility,.

continues to sell'TRIGA reactors to. produce fueliand to. pursue- _

q development of advanced reactor. technologies;. major _ decommissioning activities like'the San Francisco Presidio and the Sacramento Army Depot require extensive contact not only.with the. licensees but also -

~

with the public; the States rely on frequent'NRC response to ti radiological events to assuage public concern; and finally, RegiontV-generated 12 enforcement actions, including four o.rdersiin the last -

year, which required considerable NRC. management involvement.- While the number of licensees located in Regi~on.V is; small (260),. Region V inspects another 360 permittees of_ master materials licensees from other regions and actively seek out field inspections'of State.

licensees operating.in the Bay Area, Alaska, Hawaii and other -

federal jurisdictions.

~

The proposed Region-IV organization that would assimilate the Region-V work load lacks adequate management oversight.. Region II~ is

' described as having a similar caseload as the. proposed Option 1,-ye.t Region -IV would rather elevate the' 3eputy Director to SES rather than' create a Branch Chief to-match-thetRegion II' organization. The nuclear materials -area' rep' resents the-most -realistic opportunity for growth in:the NRC. As reactors enter the end of.their.useful111fe:

1 they will-create; aL significant work load for NRC health' physics '

staff. The oversight _of State Programs-and the potential: increase in scope to include accelerators also looms on the~ horizon. The' purpose of the Branch Chief-~is to provide the technical l oversight and direction to the staff and input to the SES-so1that they can z

106

focus on policy development and direction.

Comment: Option I states that " Consolidation of the Region V materials program in Region IV would provide more assurance of consistent application of the materials program throughout the combined Region V."

Consistency is a small reward for the lack of defense. in depth, loss of talent, experience, and representation in a large part of the nation.

Comment: Option I states that "The review and evaluation of inspection results and development of enforcement actions would not be affected,"

How can adding another 200 licensing cases to one Section Chief and another 115 inspections to the other Section Chief, including one

^

escalated enforcement action per month not adversely affect quality?

Oversight of fuel facilities alone requires at least half of a Section Chief's time.

Comment: Option I states that "To ensure that there would be no impact to direct inspection effort, FTEs have been included under this option to offset the estimated increased travel time."

No mention is made of how this option will assure a reasonable amount of direct Section Chief oversight of inspection, pre-licensing visits, and enforcement actions in the field considering their additional work load.

Comment: Option I states that "The larger base of employees would be a positive impact with more expertise available and more opportunity for cross training and development."

This opinion is not supported by fact.

Region V in part because of-its smallness, has historically trained its health physicists and rotated its personnel to achieve the broadest base of. technical expertise to support the agency mission.

Nothing described in Option 1 presents a better approach to personnel development.

Comment: Option 4 indicates that 19 FTE will be saved by relocating materials to Region IV.

If all my present branch, including our licensing assistant were totally eliminated nine FTE would be saved. My question is where did the other ten FTE savings come from.

Recognizing-the outstanding productivity of the Region V materials effort it is does not seem reasonable that ten overhead FTE could be eliminated if we.

were moved to Region V.

==

Conclusion:==

The assessment of impact on the agency mission by consolidation of the nuclear materials function in Region IV appears superficial. We suggest that consolidation of the nuclear materials function in I

107

4 4

p.

Region IV will = result in 'overlcaded Sect' ion Chiefs,'less-direction effort per FTE, -less management oversight of field activities,.

-reduced support to the States, less communication with the public and the licensees,- decreased NRC' response to' minor. incidents,.and limit:our. ability to respond to future ch;4ges in regulatory scope.

6. r,'

-G. P. Yuh s i

t l

'l

'I i

~!

i

.108

9 OPTION 1 l:.

Alaska REGION IV REGION 111 WA

(

MN g

MT W)

ME ND

)

REGION I c

N h

J, OR WI 1

3 ID MI MA SD i

NY

/

WY IA e

RI

^

NV

. NE j

lt IN NJ UT C0 L

MD DE

,MD CA A

KS

+

IN,

D.C.

=

L VA KY OK AZ NM AR-a NC g

b-2 o_*

e sC M

guaware MS Al GA i

REGION 11

• o J pt i

.* Regional 0ffice B TechnicalTrainingCenter i UraniumRecoveryFieldOffice

• Headquarters I

109

RIV/RV Materials Licencees and Permittees 8P 64 L p

p.,,g g g,,,

40 P g4 g, 7L L - Licensees 36 L Y

\\

47 P i 47 L 16 L 81 L i

RI L 4L

' )--

4 Guam 11 P go L 8P L

O 6L 18 L I

i 191 P

/

46 L 26 P 261 L 9L 17 L t

• ~,.

.] Ril 0L 66 L-RV Totals -

Permittees Licenesee 361 260 b

Alaska 1

REGION IV REGION lli REGION V WA MT ND

)

REGION I OR WI I

N ID SD hMI NY MA f) 4 WY

(

IA R1

\\

OH CT NV 4 NE j

IL IN PA

• NJ UT C0 1

M0 fE gD CA A

KS J

W D.C.

VA AZ NM M

TN "

a.

e SC g Hawal8

~

U MS Al GA L

i REGl0 Nil A

.a

, FL e Regional 0lfice R TechnicalTraining Center A Uranium Recovery Field Office

• Headquarters 111

o..

e From:

Terry L.' McNally - (TLM)

To:.

HMS2 Date:

Friday, June 4, 1993 2:35 pm

Subject:

Comments on Realignment Study I've attached my comments on the draft report.

Files:

p: study 4

4 4

4 1

.)

I u

112

'i 1)

Although it is not addressed in the SECY memo or the charter from Mr. Taylor, I believe that maintaining Region V status quo should be addressed as a positive option in this study.

There is no doubt it is the most expensive, however I believe it can also be proved to be effective in terms of mission accomplishment.

Any mission'has associated costs.

If there were no regional offices at all, the NRC could save quite a lot of money and FTE, but those Regional offices serve a purpose, one best served by being in close proximity to our licensees and to the citizens we serve.

This purpose should be emphasized.

2)

Nowhere in this study did I see the mention of double moves.

The assumption seems to be that Region V employees would be moved and that would be the end of that.

However, the meeting with the committee in Region V pointed out the distinct possibility that Region V personnel might displace Region IV personnel who would have to be moved elsewhere.

Double moves would increase the estimated cost, and should be considered.

3)

Page 4 indicates a "possible reduction of agency-credibility".

I don't believe a reduction in our credibility is possible; I'believe it is certain.

Our credibility with the public, the press, and the licensees does not seem to be seriously addressed.

This is a significant impact since it is one of the primary reasons for the existence of regional office.

It should not be under-played.

4)

Page 46 mentions the continuing obligation of the' government to pay for this office space even if these offices are vacated.

It should be noted that the San Francisco Bay Area is one hardest hit by the closures in military bases.

It may be much more difficult for GSA to fill this space than it was in the past and it should not simply be assumed that it will happen.

This study seems to take the approach that this. expenditure of $476,000 per year is just someone else's problem.

I don't believe that is in the spirit of this study or in the interest of the public to down-play this expense.

5)

Option 3 reduces support staff to two positions.

This is simply not enough.

The Field Office would have about the same scope and span of' control.as a Division in. Region V has now.

Each Division now has 2 secretaries.

However those secretaries do not perform any of the following functions:

receiving visitors, mail distribution, supply maintenance, purchasing, cashier, travel, building management and.

security, telecommunications, vehicle maintenance, and property management.

Although these functions will be significantly diminished, they certainly will not disappear entirely, and they will not be effectively covered from a Regional-Office so'far away.

And while secretaries can 113

e certainly take over the word processing function, it will also be a duty which they do not perform now.

6)

Several times, it is mentioned that a certain number of employees would either " retire or leave the agency".

For some, " leaving the agency might mean becoming employed with another government agency.

However, for many, if not most,

" leaving the agency" means leaving the government, giving up retirement, life and health insurance benefits, seniority, and security.

It should be noted in the study that the economy of the Bay Area and the future military base closings will make it highly unlikely that people from this agency will become employed with other government agencies in this area.

The language of this report makes it appear to be an element of choice.

Stating that employees are not able to move and therefore would have to leave government employment might do a better job of conveying the situation that the statement that they would simply choose to " leave the agency".

I believe the gravity of this decision needs to be portrayed when considering the impact on employees.

114

4 w

f

%g UNITED STATES p_'

NUCLEAR REGULATORY COMMISSION

{

,E REGION V

• g,,

g 1450 MARIA LANE WALNUT CREEK, CAUFORNIA 94596-5368 June 3, 1993 MEMORANDUM FOR:

B. H. Faulkenberry, Regional Administrator FROM:

L. F. Miller Jr., Chief Reactor Safety Branch

SUBJECT:

COMMENT ON THE DRAFT REGION V REALIGNMENT STUDY I offer these observations on the study:

1.

Some potentially superior options have not been analyzed.

Consequently, the study is too narrowly constrained and focused.

In particular, I suggest two more options be fully considered.

Option 5 would continue the present alignment of responsibilities and staff.

The impetus for pushing through one of the Options 1 through 4, apparently, is to reduce FTE beyond the already gaunt FY 85 budget for Regions 4 and 5.

The reason for this goal is not clearly stated in the study.

It is known that Regions 4 and 5 are currently effective; they probably can remain effective under the FY 95 budget.

The reductions proposed under Options I through 4 are at best an untried estimation that the missions can still be effectively performed with many fewer personnel.

This claim seems too optimistic and subjective.

Option 6 would redistribute the regional work evenly among all five regions.

In particular, under Option 6, such functions as ERF0, high level waste, non-power reactors, operator licensing and materials would be shifted to Region V preferentially as necessary to level the staffing among all five regions.

If necessary, power licensee assignments could be realigned slightly as well.

Other federal agencies have designated certain regions as lead for certain activities. This concept could likewise be applied to the NRC. This would permit a levelling of regional administrative and mr.nagement overhead based on an equality of workload.

Personnel disruption would still-occur, but it would be spread more equitably across the NRC, rather than targeted at Region V.

The NRC's West Coast presence would be enhanced.

2.

All of the options assume a-trarisfer of some responsibility to Region.IV from Region V.

However, many functions, such as non-power reactors, operator licensing, and materials, could be centralized as well.in either location.

The preference for transferring functions to Region IV, rather than to Region V, is not explained, and makes the study seem less objective.

115

~

3.

All of the options which are studied increase the ratio of workers to tio supervisors. This change will reduce the effectiveness of the combined Region IV/V effort. Supervisors are, on average, more effective and harder working personnel. Reducing their numbers will decrease overall performance.

r. n age 4.

All of the cost-benefit analyses assume that Region V personnel will be ;e relocated, but Region IV or other regional personnel will not be.

This beggar-thy-neighbor approach weakens all of the options.

If moves are

.-.ne necessary, they should be made based on competition in the reduced Region.IV/1, organizations for the available positions. Assuming an equal distribution ofm talent in Region IV and V, slightly fewer than half of the persons in Region n IV should expect to be moved. This approach would increase the cost of

or reorganization by requiring more relocation, but it would result in a strongerm regional organization.

u

.a 5.

The study does not analyze how many personnel will be left without a

<e position in Region IV or V under each option. That number will vary with each 1 option, and should be explicitly calculated and discussed.

In ~ particular, thaw impacts of forced transfers of GG-15 supervisors to a non-supervisory

.c' Headquarters position should be analyzed.

Such a transfer is, functionally,can demotion, and would reduce the agency's capabilities.

Reductions elsewhere in Headquarters to compensate for the increase in staffing by these forced transfers is implied and should be analyzed.

I hope that these observations will be considered in the decision-making which will occur concerning realignment.

. F. Miller Jr., Chief Reactor Safety Branch 116

h.

A p 0'l 1993 HEMORANDUM FOR:

Bobby Faulkenberry, Regional Administrator Region V NRC Commissioners FROM:

W. P. Ang, Chief Engineering Section Division of Reactor Safety and Projects

SUBJECT:

COMMENTS ON CONSOLIDATION STUDY REPORT A review of the Regions IV and V consolidation study has resulted in several concerns and comments and recommendations for your consideration. All options provided by the consolidation study result in a decrease of inspection effort and a decrease in inspectors that are needed for power reactors..'At a time-when power reactors are aging, many existing technical issues continue'and new problems are developing. These problems necessitate a continued' level, if not an increase, of inspections. Definitely not a decrease, if the agency mission of protecting the health and safety of the public is to be accomplished.

Some pf the problems that I am sure you are well aware of are as-follows:

e Steam Generator (SG) tube degradation - The recent Palo Verde SG tube rupture has necessitated expanded licensee tube inspections.

These inspections have identified free span axial cracks, intergranular attack, outside diameter (0.D.) intergranular stress corrosion cracking.

associated with. linear deposits on the 0.D. of a significant number of tubes.

Free span axial cracks have recently been reported in two other United States reactors.

Free span axial cracks associated with linear deposits have not been previously reported. This is a problem that has-potential generic implications and needs increased inspection effort.

Motor Operated Valve (MOV) failures - Palo Verde and San Onofre recently e

experienced failures to operate auxiliary feedwater motor operated. valves despite performance of required inspections and tests of those valves.

These are but two examples of many similar: problems nationwide. 'In. San Onofre's experience, the valve-could also not be opened with the manual handwheel and a (4 inch wrench was needed to get the valve to open. NRC inspections of licensee actions for assurance of design adequacy and operability of MOVs needs to be increased.

Weaknesses of licensee engineering activities - A core power oscillation e

occurred at a BWR, WNP-2, in-August of 1992 due to weaknesses in engineering actions associated with the core reload design and weaknesses in engineering interface with operations to avoid or minimize power-operations using plant parameters susceptible to core power oscillations.

117

o At the same plant, potential inaccuracy of reactor water level instruments during a down power were not sufficiently technically recognized.

These are also only two examples of many other licensee engineering weaknesses. A continued, if not increased, level of inspection of licensee engineering activities is needed.

These are but a few of a litany of issues / problems (i.e. maintenance, station blackout, fire protection, thermolag, etc) that confirm a need. for increased inspection effort at power reactors rather than a decrease. While budget and manpower cuts may be mandated for the agency, these cuts should not and cannot be made at the expense of the inspection staff if the public health and safety is to be protected.

A review of all options provided by the consolidation study will show that the engineering inspection staff will decrease.

Furthermore, management and control of the engineering inspection staff will be reduced.

Implementation of any of the options has a direct impact in the agency's ability to protect the pubic health and safety.

I recommend that all options of the consolidation study be re.iected, the inspection staff be increased or left at the current level, and that mandated cuts be made in areas where licenses have not been issued or applied for (ex. advanced reactor projects).

b W. P. Ang, Ch ef Engineering Section cc:

Congr. George Miller, D. CA

~l 4

i 118

f' From:

hilip J. Morrill (PJM)

To:

BF ; MMS 2 Date:

M nesday, June 2, 1993 1:21 pm

Subject:

COMMENT ON DRAFT REGION V REALIGNMENT IN REVIEWING THE SUBJECT STUDY, BILL ANG AND I OBSERVED THAT THE REGION V OPTION 4 ORGANIZATION HAD ONE SECTION CHIEF SUPERVISING OPERATOR LICENSING, ENGINEERING INSPECTORS, AND A NON-POWER REACTOR INSPECTOR.

WE THINK THIS IS T00 BROAD A RANGE OF FUNCTIONS FOR ONE PERSON TO ADEQUATELY SUPERVISE. WE RECOMMEND THAT THE GG-15 TECHNICAL ASSISTANT / TEAM LEADER BE ELIMINATED AND THAT POSITION USED AS A SECTION CHIEF OVER AN OPERATOR LICENSING /NON-POWER REACTOR SECTION. THE OTHER RD&PS SECTION CHIEF WOULD SUPERVISE ENGINEERING.

V/R PHIL MORRILL CC:

WPA i

119

f 9

Thomas R. Meadows

~

Senior Licensing Examiner Region V, USNRC J

Chairman Ivan Selin U.S. Nuclear Regulatory Commission Washington D.C.

Dear Chairman Selin:

The information that a study has been commissioned to explore options for the consolidation of Region V and Region-IV has dropped like a stone on the hearts of Region V personnel. The nature of that study is very disturbing to us. On reviewing the charter that the study group has been given by Mr. Taylor, it appears that several options have been left off the list. Most' notably consideration for remaining with the status quo or realignment of Region IV with other regions.

The purposeful appearance of the charter leaves loyal Region V personnel with the impression of abandonment by NRC management. The reason for our-impression lies in the charter of the study group which appears:strongly-biased toward two options.

First, the total consolidation of Region V with Region IV in' Arlington, Texas. Secondly, a field office arrangement, managed by Region IV, or as a drastically reduced region.

The failure to consider other options, and the bias that Region ~V personnel j

see in the makeup of the study group > leads us to believe that a decision has'-

already been made and that the study group is left to merely recommend a fait accompli. The bias we see is in the selection of Mr. Montgomery, whose interest in consolidation is high; and the selection of Mr. Nayes, who has voiced his view in the past favoring consolidation of 01 in Headquarters.

W.e-1 don't view the other parties'as effective in offsetting their bias.

We believe that NRC management at least should consider the unvarnished facts q

before proceeding.

l l

The human cost to Region Y personnel in any case will cause great: personal pain.- As an example I personally would be left with an agonizing decision to abandon a long and fruitful career of 7 years.

I'm married to atloving-California born wife and 3 California wonderful-boys. My wife's immediate family are.all Bay' Area and my wife and I are necessary for providing nursing care for her elderly parents. -We must provide them care-in this economy -~we.

have no options, but to stay lin the-. Bay Area.

Obviously if;I cannot find employment in the local-area I will.have to consider a mo,ve.. Early on in my -

4 cr.reers as a Navy, Lt.

Operator Certification),(USN Submarines), Nuclear Industry (Senior Reactor:

and finally the NRC, I made many moves over a f3urteen year span-with severa1Lextended assignments. My family:and I just do 4

not feel.like moving.again. Many others would face painful movesLaway from-long friendships and family. Further, our faithful administrative staff would have to compete to find employment in the already weak California economy that 120.

'i

i is facing the loss of thousands of local federal jobs. Obviously, long government service could not be continued in most cases resulting in the very real loss of benefits accrued from that service.-

The analysis of cost savings in these cases usually involves showing the long term gains offsetting the short term costs.

Analyses such as these are usually artificial, a savings can always be shown by a reduction in staffing or realignment of responsibilities.

What cannot be shown is the real truth.

We understand that pressure is being applied to the NRC to reduce staffing and to find cost savings.

Region V personnel cannot help but feel that we are a convenient target for advancing that effort.

We are not asking to be treated differently, we cierely seek equitable treatment and consideration.

Analyses done by some of our compatriots in Region V indicate'that the short term costs and some long term costs may be very high. Moves, retraining, early retirements, severance pay, increased travel costs, breaking the Region V lease are just some costs.

Just as an example, the extra travel time to Region V facilities from Arlington, Texas could impose the need to pick up an additional 2 weeks of travel per ins goals (as much as $15,000 per year c:pector per site to meet the onsite time ore in costs).

The loss of intangibles such as close proximity to state governments, the public, and the utilities home offices are very real.

The ability to respond to a site incident could be impacted by the time factors of travel and time zones.

Responding to an incident from a consolidated Region IV-V in Arlington, Texas to a site means covering three time zones. The point could be made that if a region has to go, it might as well be Region IV.

A look at the map and the boundaries of the NRC regional offices begs a question.

close to Region II and Region III.Most of the Region IV facilities are located very Waterford, R.iver Bend, and ANO to Region II. Cooper and Fort Calhoun, to Region It should be noted that responding to WNP-2 and Diablo Canyon from Arlington, Texas would take mxh longer than responding to Comanche Peak and South Texas from Walnut Creex.

I do not like presenting these arguments because they point out an obvious concern that Region IV could be posed with the same uncertainty ar. is Region V.

But in fairness I feel they should be argued.-

The length of this letter is I believe indicative of the depth of the concerns that are gnawing at many of us.

The NRC has not in the past taken such a drastic proposal to the point of implementation.

I sincerely hope that some other accommodation can be made.

Very rampectfully, "W - A

• y _ _ 4 j

v r-93 Thomas R. Headows cc:

Commissioner Remick Commissioner De Planque Commissioner Rodgers Commissioner Curtiss i

121

3 From:

Kenneth E. Johnston (KEJ)

To:

BFF Date:

Friday, June 4, 1993 6:20 pm

Subject:

Comments on Realignment Study The numbers don't make sense to me.

I only looked at Option 1.

I-i-

Let's look at the FTE from '93 compared to '95.

The combined staff (excluding resident sites) today is approximately 210' FTE.

L The '95 Option 1 regional staff FTE is approximately 145, a difference of 65 FTE. That's a 31% reduction in combined regional office staff.

l To put it bluntly, the study says that 1 out of every.3 people who showed up in the Regions IV and V offices today was not needed.

That just doesn't make sense.

I Let's look at it another way.

Presently there are approx. 90 FTE in the Region V office.

The study says that Option I will save 65 FTE over the '93 staffing level (excluding RI staff at Trojan and Songsl).

What-this equates to is that the Region IV office needs only 25 FTE in addition to their present staff to accomplish the RV mission.

How can a Region IV staff augmented by 25 people accomplish the Region ~V mission? The answer is it can't.

l From a common sense approach, the study does not make sense.

l 1

l 122

w

_c APPENDIX 15 REGION IV EMPLOYEE COMMENTS REGARDING THE REGION V REALIGNMENT STUDY DRAFT REPORT DATED MAY 24,1993 123

T-3 DATE:

June 3, 1993 TO:

J. Montgomer FROM:

P. Ha

SUBJECT:

COMBINIfG OF REGIONS IV AND V Comments regarding the results of the Study Group report on combining Regions IV and V are provided below:

The study does not address, with respect to the financial burden on e

Region V personnel, that " Texas has no Taxes". This constitutes a significant financial gain for the individuals being transferred.

Option 3 does not address the startup costs of having a field office e

with respect to the extensive documentation changes that will be required. Many of the Region IV R0PGs and RONs will have to be revised, and/or new R0PGs created, to explicitly define the responsibilities of the field office and to define the interfaces for the wide variety of functions that will be performed in the field office.

It is estimated that this effort will require about 1 FTE for writing, editing, review, comment consolidation, and approval.

Option 1 also will have startup costs associated with the addition of e

additional sections in DRP; however, the costs should be minimal.

In Options 1 and 3, it is not obvious why 2 enforcement officers are needed.

Do we anticipate an increase in the number of escalated enforcement actions that would warrant the additional person?

With respect to the addition of additional FTE for traveling to Region V e

sites by Region IV based personnel, does the study take into account the significantly reduced frequency of the core inspections that will be performed under the upcoming, revised inspection program? This may be a factor that will change the number of FTE assigned to this activity.

With respect to Option 3, it is recommended that consideration be given e

to removing the Technical Assistant (GG-14) position assigned to the Region IV Technical Support Staff and assigned this position to the Region V field office as a Technical Assistant to the Field Office Director (GG-14) or as a Field Office Depu.y Director (GG-15). This position could be of significant importance for the following reasons:

Provide continuity for operation of the office when the Field Office Director is absent.

Provide a point of contact for Region IV to handle items such as input into the various committees that currently exist to ensure the committee decisions consider the field office needs, provide 124

5 an additional individual for emergency response, provide additional backup for the Office Director and DRP Section Chiefs.

Provide an interface to handle inspection program changes, FOIA, regional action items, QPPR inputs, etc.

The first full paragraph on Page 36 discusses the loss of two SES positions to serve as Director of Site Operations. This is true of Options 2 and 3 also; however, this factor is not discussed in the options.

First paragraph on Page 66 discusses how the Region V field office would e

be similar to past experiences in operating URF0 and OSP.

The situation created by the field office does not appear to parallel the experiences of operating URF0 and OSP since these offices were entities in themselves with respect to implementation of the technical requirements such as the inspection program.

Because the offices operated independently in this area, little communication between URF0 and OSP was required.

Establishment of a field office will require extensive communications and will be a new experience for the Region IV office.

M e

125

3

[

UNITED STATES y

NUCLEAR REGULATORY COMMISSION ci REGION V 1450 MARIA LANE o

WALNUT CREEK. CAUFORNIA 94596-5368 g

MEMORANDUM FOR:

John M. Montgomery Deputy Regional Administrator-FROM:

Michael Runyan Reactor Inspector, Engineering Branch Division of Reactor Projects

SUBJECT:

COMMENTS ON THE DRAFT REGION V REALIGNMENT' STUDY-(1)

Additional benefits of Option 2 not mentioned in the report:

(a)

This option would result in all four NRC regions and headquarters being within one time zone difference, resulting in better communications and coordination.

~

-(b)

Region-based inspector objectivity would be improved because inspectors would be travelling to 12 reactor sites.as opposed to 4-or 8 under the current alignment.

(c)

This option best anticipates the impending shutdown of WNP-2.

(2)

Additional consideration for Option 4:

(a)

Loss of geographical 8% pay for Region V employees will be substantially offset by lack of a Texas state income tax.

Michael Runyan Reactor Inspector, Engineering Branch Division of Reactor Projects 126

=.

A.

e-y,h k

UNITED STATES J

NUCLEAR REGULATORY COMMISSION

{

,i REGION V 6

8 1450 MARIA 1.ANE

,8 WALNUT CREEK, CAUFORNIA 94596-5368 MEMORANDUM FOR:

John M.' Montgomery Deputy Regional Administrator FROM:

Anthony Gaines, Radiation Specialist.

Facilities Inspection Programs Section Division of Radiation Safety and Safeguards

SUBJECT:

COMMENTS ON THE DRAFT REGION V REALIGNMENT STUDY i

1 At.the top of page 76, in the section discussing the impact'on mission accomplishment of option 4, an example is used to support the-contention that -

with the overall reduced management staff, the region's ability to meet _all-existing Headquarters support requirements would decrease. The. example is that one' Region V 'section chief would be' responsible for EP, RP, and security.

This is how Region IV has been' staffed for quite some time'and even.in the Region IV FY-95 Budget Baseline we will be staffed that way. ~Therefore, this example may not be a-good example to use.

Does Region IV have any problems-associated with the way.it is staffed in this area? The~ committee may want to think about using this' example or if they decide to use this example be ready to answer the questions which may be raised.

Anthony Gaines, Radiation Specialist

-Facilities Inspection Programs Section-Division of Radiation Safety and Safeguards I

i 127

n f

4 UNITED STATES y

NUCLEAR REGULATORY COMMISSION o

{

,1 -

REGION V g

1450 MARIA LANE o

WALNUT CREEK, CAUFORNIA 94596-5368

' MEMORANDUM FOR:

John M. Montgomery Deputy Regional Administrator FROM:

Paula A. Goldberg Reactor Inspector, Engineering Branch-Division of Reactor Projects

SUBJECT:

COMMENTS ON THE DRAFT REGION V REALIGNMENT STUDY

.On page 29 of the draft realignment for Option 1, an additional advantage for a combined Region IV/V should be included.

That is, for both Regions IV and V personnel there would bean increase in. inspector objectivity due to increasing the number of plants from 8 to 12.

t I

On page 30, the Region V staff express a concern about loosing the 8% high cost of living pay adjustment by moving to Arlington The study: should. point 1

out that the loss of this 8% cost of living adjustment would be more than compensated for by the fact that Texas has no state income: tax and that'the.

-cost of housing would be significantly lower than in California.

i Paula A. Goldberg Reactor Inspector, Engineering Branch Division of Reactor Projects f

1

?

128

4 --

c.

-j APPENDIX 16 1

NRC HEADQUARTERS OFFICE AND REGIONAL ADMINISTRATOR COMMENTS REGARDING THE REGION V REALIGNMENT STUDY DRAFT REPORT DATED MAY 24,1993-129

4.

k UNITED STATES (i(M i E i

NUCLEAR REGULATORY COMMISSION I

p WASHINGTON, D.C. 20565-0001 April 27,1993 MEMORANDUM FOR:

John M. Montgomery, Deputy Regional Administrator Region IV FROM:

Frank J. Miraglia, Deputy Director Office of Nuclear Reactor Regulation

SUBJECT:

REGION V REALIGNMENT STUDY Per your April 2,1993 request, NRR has reviewed the Region V realignment study options for impacts on implementation on NRR Program activities.

.Upon review of the pros and cons of each of the three options presented, we believe that the selection of option 1, the consolidation of Regions IV and V in Arlington, would have the most positive impact'on NRR programs.

Specifically, the consolidation would sustain sufficient management and technical personnel to continue inspections, technical assessments, and event response, and would facilitate planning of NRC activities involving facilities on the West Coast.

We found that none of the three options would have a significant negative impact on the reactor inspection program.

However, option 1 appears to have the most positive impact.

For example, the pooling of inspectors from both Regions would result in such benefits as better support to major team inspections, increased flexibility and efficiency in the safeguards program, and increased availability of BWR inspectors to support WNP-2.

Consolidation in Arlington would also increase administrative efficiency.

The consolidation would reduce the time zone offset from three hours to one hour, allowing more overlap of core work hours.

Consolidation would also. ease the travel burden on Headquarters staff by reducing the travel. time to and from i

Region IV. Headquarters staff members typically require two travel days for a one day meeting in Walnut Creek.

Consolidation saves at least one day per i

trip. Options 2 and 3 will not reduce this burden.

In. addition, options 2 and 3 would complicate scheduling of conference calls on' inspection findings, and on events between headquarters and regional staffs.

In summary, NRR has considered each option and supports option 1, the consolidation of Regions.IV and V into a single office. We appreciate the-opportunity to comment on the realignment study options. If you have any questions, the NRR point of contact for realignment activities is Anthony T.

Gody, Acting Director, Program Management, Policy Development, and Analysis Staff. He can be reached on (301) 504-1275.

t 4

Frank J.

ag ia, puty Director Office of Nuclear Reactor Regulation 130

p muy

+

UNITED STATES 3

[)..:

n E

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20665 o,s,...../

APR 2 31993 MEMORANDUM FOR:

John M. Montgomery Deputy Regional Administrator, Region IV FROM:

Robert M. Bernero, Director Office of Nuclear Material Safety and Safeguards-

SUBJECT:

REGION V REALIGNMENT STUDY In response to your April 2, 1993 request, NMSS has assessed the programmatic impact of the Region V realignment.

In general, there are no F

significant programmatic impacts due to the relocation.

A specific discussion of the positive and negative impacts i attache. ((N b

Office $ Bernero, Director Ro t

of Nuclear Material Safety and Safeguards

Attachment:

As stated 131

• ^

~

ATTACHMENT l

l IMPACT OF REGION V ALIGNMENT ON NMSS PROGRAMS Assumotions:

NMSS assumes that the three options under study are essentially the same as far as NMSS programs are concerned (i.e., NMSS activities will be conducted from Region IV-under all three options), and that the differences between the options relate only to the reactor program.

Backaround:

Currently Region V conducts the following NMSS activities:

Licensing and inspection of. approximately 250 byproduct materials licenses (this is the major NMSS activity in Region V)

Inspection of 2 uranium fuel fabrication facilities:

Siemens Nuclear Power Corporation, Richland, Washington General Atomics, San Diego, California Reactor decommissioning Inspection of the SNM license at Hanford Inspection of Part 61 LLW activities at reactors and materia's licensees The following comments are limited to the impact on direct NMSS programmatic activities.

The primary impacts discussed below address materials licensing and inspection since this represents the majority of the NMSS workload in Region V; however, the " negative" comments regarding travel time, emergency response time, and interaction with State and local governments also apply to fuel facility. inspection, LLW inspection, and reactor. decommissioning activities.

Resource impacts due to items such.as overhead and rent are being addressed separately by.the study group.

Positive:

Combining the relatively small number of NRC materials licenses resident in P.egion V (245 as of 3/31/93) with those in Region IV (731) would result in a total of 976' licensees and resultant economies of scale. The new Region would contain about 80 more materials licenses'than Region II, although as noted below, the geographic extent of the' new Region would be significantly greater than.any existing Region.

Neoative:

The negative impacts will primarily be in terms of. greater distances to our current Region V licensees.

Travel times to inspect licensees in Alaska and Hawaii (which together 132

~~ ----

I WI

.E 2

comprise about 50% of the licensees in Region V) would' be incrementally increased. However, because the-travel times to these. licensees is already significant, the impact would not be as great as it would for. licensees in California, o

particularly, which account for 25% of'the licensees in the Region. -The net effect of this is'that labor _ rates for-inspections-to licensees located in Region V,.which are already higher than those for any other Region, would likely increase.

Distance would also be a real impact for licensees who have to travel to the Regional office for management meetings or enforcement-conferences. Again, the greatest impact would 1

be for California. licensees who at present are relatively '

close to the. Regional office..

There could also be real and perceived: impacts in terms-of.

our ability to interact with State. and local governments and the media-in routine and emergency response situations, although these are difficult to quantify.

h i

133

1 7

N p,Q [EQ

/

o,,

UNITED STATES NUCLEAR REGULATORY COMMISSION n

{

WASHINGTON, D. C. 20555 I

April 23, 1993 1

MEMORANDUM FOR:

John M. Montgomery, Deputy Administrator, Region IV Bobby H. Faulkenberry, Deputy Administrator, Region V FROM:

Gerald F. Cranford, Director Office of Information Resources Management

SUBJECT:

REGION V REALIGNMENT STUDY We have reviewed the four options being considered for realigning Region V.

I Although evaluating certain aspects of the four options is straightforward and easy to accomplish, other considerations are more subtle and will require more time for a complete evaluation than was available given the project's time constraints.

However, none of the items that require future analysis are show stoppers or quite expensive.

At this junction, we will point them out as concerns and when a final decision is made, we will make the adjustments necessary prior to the time that the actual consolidation takes place.

Following are the concerns raised by the Office of Information Resources Management.

They are broken out by branch within the Division of Computer and Telecommunications Services and the Division of Information Support Services.

Division of Computer and Telecommunications Services Systems Development Branch (SDB) - There are a number of systems supported by SDB that would be affected by a consolidation of Region IV and V.

Some of these systems are:

1.

Master Inspection Progr:m Plan (MIPS) 2.

Inspection Followup System (IFS) 3.

Enforcement Action Tracking System (EATS) 4.

Technical Assignment Control System (TACS) 5.

Manpower System (HPS) 6.

Licensing Fee Reporting System (Inspection Fees) 7.

Regulatory Information Tracking System-(RITS)

Any of the four consolidation options (1, 2, 2A and 3) will cause significant analysis and programming changes to the above mentioned systems, as well as other systems that may not be identified.

However, if option-I were selected, the changes would be less critical than if one of the other options were selected.

For example:

1.

Extensive analysis.would need to be done, as well as the major programming effort, but it'would not be time critical (see 2 below).

2.

Most of the changes would be cosmetic, meaning that the programs would operate more efficiently if modified.

Most of the programs

}

operate on the Region parameter and if a conversion moved the 134

p.

Multiple Addressees !APR 2 3 1993 licensees to the proper location, the programs would function normally.

3.

A major conversion effort would have to be put into place for the databases. An extensive analysis needs to be done in order to determine if data should or should not be converted.

Withoa

,ignificant amount of analysis and programming, the same cannot nea w

.ey be said for options 2, 2A, and 3.

The full impact of selecting on- ;f hese options cannot be determined without a thorough analysis.

On the surface it appears that any of these three options could have a measurable impact on our systems processing.

For example, option 2A splits the Power Reactor Program. Where is the line drawn? Residents would be in Region V but what part of the program is moved to Region IV? There are too many unknowns at this time to be more specific. More information is needed to comment other than that the consolidation would have a major impact on our systems.

Division of Computer and Telecommunications Services Telecommunications Branch (TB) - The following telecommunications concerns would have to be handled prior to realigning Region V.

Continue Centrex services (will require a delegation of procurement authority from GSA to continue use of Centrex services).

Decide on the Switch installation in Region V.

Determine Region IV Switch capability.

(Possible solution is to install the Region V Switch to provide required capability.)

Determine the effect of the consolidation on the WAN expansion / upgrade.

Determine the effect of the consolidation on ANS.

Determine the effect of the consolidation on IRC within Region IV and V.

Division of Comouter and Telecommunications Services Office Automation and Network Development Branch (OANDB) - Regarding the options identified for the Region IV/V realignment, OANDB should be able to-support any of the options specified.

Basically, each of the options willL involve the scaling-down of the Region V network environment and expansion of the Region IV environment to accorunodate the people being relocated. We will have to determine the degree of scale-down or expansion depending upon the option selected.

In any case, we will need contractor resources to help with the relocation / consolidation. We may be able to use an existing contract to support this effort, but we will need to discuss this with contractor to confirm.

135

^

s

~

Multiple Addressees The major concern for 0ANDB is whether the existing Region IV people will have to move to a new building to accommodate the people coming from Region V.

This would be a new installation coupled with a move.

It would be a major undertaking to have to relocate both Region IV and Region V.

Division of Information Sucoort Services Document Manaaement Branch (DNB) - Following are the changes that would be required to support option 1.

There would be no changes in DMB if options 2, 2A, or 3 are chosen.

The realignment of Regions IV and V will require changes to the Regulatory Infomation Distribution System (RIDS) distribution patterns no matter which option is chosen.

There could be reduction in the hours of operation for the NUDOCS system due to the one hour Region IV and V time difference. This would t,a true so long as the Resident Inspectors do not increase their NUDOCS usage.

Division of Information Sucoort Services Information and Records Manaaement Branch (IRMB) - Following are the changes that would result if option 1 were selected:

The separate libraries maintained at Regions IV and V can be consolidated into one library.

This would result in approximately

$5,000.00 in annual savings by discontinuing duplicate periodical subscriptions, newsletters, industrial standards and codes, and books.

If option 2, 2A, or 3 were chosen, the following changes would result:

The separate libraries maintained in Regions IV and V could be consolidated into one. library located in Region'IV..This would.

result in approximately $2,000.00 annual savings by discontinuation of some duplicate periodical. subscriptions, newsletters, and books.

Staff remaining in California would still require separate industrial codes and standards and some periodicals and newsletters.

Division of Information Sunoort Services Infomation Technoloav Succort Branch (ITSB) - If option I were selected the l

following changes would occur:

136

E3 1-Multiple Addressees i Fewer communications links to Headquarters and-less Remote Job Entry (RJE) printing will be required.

There will be minor cost reductions at NIH by eliminating the RJE port (approximately $1200.00 annually).

(

I There would be no changes in ITSB if option 2, 2A,.or 3 were selected.

We understand the need to be as clear as possible when presenting IRM's

[

concerns regarding the Region V realignment options. However, there are questions that must be answered for IRM to assess the final impact of choosing one option over the others. We will continue to assess the realignment options and forward any substantive issues that we uncover.

Please direct any questions you have concerning this memora um to me at 301-492-7585.

/

2 1,

Gerald F.

ranford, rector Office of Informatio Resources Management cc:

P. G. Kruzic, DCTS G. H. Messenger, DISS l

i l.-

l l

l l'

i l

137

w

@ 0820 UNITEO STATES NUCLEAR REGULATORY COMMISSION p

g

(

E REGION IV l

611 RYAN PLAZAbHIVE, SulTE 400

• b{* *S4[

ARLINGTON, T EXAS 760118064 i

MAY 20 23 i

MEMORANDUM FOR:

Bobby Faulkenberry, Deputy Regional Administrator, RV John M. Montgomery, Deputy Regional Administrator, RIV FROM:

James L. Milhoan, Regional Administrator, RIV l

SUBJECT:

REGION V REALIGNMENT STUDY l

o l

This provides my views on the options considered by the Study Group regarding Region V realignment.

I have restricted my comments to the implementation consequences of the options if any were to be adopted by the Commission.

Option 1 - This option would provide economies of scale and a more conservative emergency response capability.

From a purely administrative viewpoint, it appears to be the most advantageous and would be my preference.

However, it represents the most radical change, particularly in removing

• a major NRC presence from the west.

Option 2 - This option would place the greatest communication and coordination burden on both regions and would clearly result in respr;nsibility and accountability difficulties.

It would also present the most confusion to those outside the agency.

Of the four options, I wou.'d be most concerned about having to implement Option 2.

Option 3 - This option would include many of the pros and cons associated with Option 1.

It might present some additional coordination challenges, but is, in my view, manageable and can be effectively implemented.

If West Coast presence were to become a significant consideration, it would offer a major advantage over Option 1.

Option 4 - This option would present an improvement over Option 2 as most of my concerns regarding responsibility and accountability in the reactor program area would be eliminated.

However, there would still be a confusion issue over responsibility to those outside the agency since Region IV would be responsible for the materials and agreement state programs.

I have less concern about implementing this option than Option 2, but I believe our mission would be better served by not having two regions regulate in the same geographical area.

C

(

[.

Milhoan Legional Administrator cc:

J. M. Taylor, ED0 J. H. Sniezek, DEDR 138

9, 1,1 ry,.

e*

4,

e 6

e r

1 h

e 5

1 L

5 s.

f 1

P

,E 1

e

., 7 l

h i

h e

I 4

'i

- t t

, i

' f

?

l 4

-,I 4

0

' iI i

1 l

/

i I

. I

. I

,=;

... ~,

,, - ~,

,