ML20056D400
| ML20056D400 | |
| Person / Time | |
|---|---|
| Issue date: | 07/26/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-93-207, NUDOCS 9308130149 | |
| Download: ML20056D400 (3) | |
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POLICY ISSUE
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July 26, 1993 (In Ormation)
SECY-93-207 FOR:
The Commissioners FROM:
James M. Taylor Executive Director for Operations
SUBJECT:
STAFF EVALUATION OF RELOCATING THE ENTIRE URANIUM RECOVERY FIELD OFFICE OPERATION TO REGION IV PURPOSE:
To provide the Commission information on the staff's evaluation of the option of relocating the entire Uranium Recovery Field Office (URFC) operation, including the inspection and licensing functions, to Region IV. This action is in response to the Staff Requirements Memorandum (SRM) for SECY-93-150, dealing with the plan of action for closure of URF0.
BACKGROUND:
SECY-93-078 outlined the broad plan for closing URF0 pursuant to the Commission's decision to consolidate the activities and staff of the uranium recovery licensing and inspection program in Headquarters and Region IV, respectively.
Based on the Commission's April 24, 1993, discussion and vote, the staff was requested to provide a more detailed plan of action to carry out the closure.
This was accomplished by issuance of SECY-93-150, on May 28, 1993.
The Commission approved the plan and schedule, as noted in the SRM for SECY 150, dated June 28, 1993.
NOTE:
TO BE MADE PUBLICLY AVAILABLE
Contact:
Dwight D. Chamberlain, NMSS IN 10 WORKING DAYS FROM THE 504-3439 DATE OF THIS PAPER 17000G
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The Commissioners DISCUSSION:
The staff solicited and evaluated views from the Office of Nuclear Material Safety and Safeguards (NMSS), Region IV, the Office of Personnel, and individual members of the Transition Oversight Team, regarding the positive and negative aspects of relocating the entire URF0 operation to Region IV, instead of relocating the licensing function to Headquarters and the inspection function to Region IV, as planned.
In addition, the numerous comments received from industry and States expressing concern about URF0 closure were reviewed. The staff concluded that greater efficiency and consistency would be realized by relocating the licensing function to Headquarters as planned.
While manageable, the present alignment with Title I and Title II licensing actions split between Headquarters and URF0 has resulted in inefficiencies.
The uranium recovery licensing program inefficiencies would continue by having two small licensing staffs; one for Title I in Headquarters and one for Title II programs in Region IV. The Title I and Title 11 programs are very similar with regard to technical requirements, with some minor differences in groundwater standards.
The majority of the reviewers are geoscience and hydrology specialists and the need for such specialists in each location for licensing reviews would tend to increase the full-time equivalent (FTE) needs. A small licensing staff in Region IV for Title II licensing actions would continue to require Headquarters resources for oversight and guidance to ensure consistency between Region IV and Headquarters on Title I and Title II actions.
The total uranium recovery program is relatively small. The current budget for FY94 includes 5.8 direct FTE for Headquarters Title I review activities and 3.6 direct FTE for Title II licensing activities.
The budget for FY95 includes 5.9 direct FTE for Headquarters Title I review activities and a decrease to 2.6 direct FTE for Title II licensing activities.
Some potential for future FTE savings exist with the plan to relocate the URF0 licensing function to Headquarters. This potential for savings would be reduced if the URF0 licensing function were relocated to Region IV, because of the need to maintain a viable review staff in each location and maintain Headquarters oversight.
Locating the entire licensing staff in Headquarters would not only promote efficiency by maintaining staff specialists in one location, it would also allow for better interaction with other groups within NMSS on technical and policy issues.
Policy issues could be dealt with more efficiently and consistently with all licensing functions located in Headquarters.
The types of specialists needed for uranium recovery licensing activities would have a broad potential for use in other areas in Headquarters, such as technical reviews of geoscience issues associated with the low-level waste management program, Site Decommissioning Management Plan site remediation, and the high-level waste management program.
Such opportunities would be limited in Region IV.
This broader potential in Headquarters for specialist use would be L
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The Commissioners important to ensure effective utilization of personnel as the Title II licensing workload declines over the next few years.
The principal positive aspect of relocating the entire URF0 operation to Region IV appears to deal with the perception that industry interactions would be more readily accessible and therefore enhanced.
Although it is true that location in Region IV would result in smaller travel distances for the licensees in some instances, accessibility for issue resolution would only be marginally affected. Headquarters oversight and involvement would be required regardless of the location and would likely require meetings in Headquarters, in some instances.
The regulatory impact associated with the travel distance issue and the accessibility of reviewers could be addressed on a case-by-case basis, with possible adjustments in meeting locations.
The other potential positive aspects of relocating URF0 operations to Region IV included the greater potential for staff retention because of the lower cost of living in Region IV and potential benefits to licensing actions based on perspectives gained from field inspection with the use of technical specialists and project managers for inspection activities. Management perception of individual employee preferences indicate that little if any increased potential for staff retention would result from relocating URF0 operations to Region IV.
Also, the field inspection perspective could be gained regardless of the location of the licensing function, since licensing project managers could also visit sites periodically and accompany inspectors on some inspections.
In conclusion, the staff believes that the gains in efficiency and consistency i
of actions and the improved flexibility with staff utilization provide sufficient incentive to move the URF0 licensing functions to Headquarters and to move the URF0 inspection function to Region IV as planned.
COORDINATION:
The Office of the General Counsel has reviewed this paper and has no legal objection.
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