ML20056G559
| ML20056G559 | |
| Person / Time | |
|---|---|
| Issue date: | 08/12/1993 |
| From: | Selin I, The Chairman NRC COMMISSION (OCM) |
| To: | Wilson P CALIFORNIA, STATE OF |
| Shared Package | |
| ML20056G560 | List: |
| References | |
| NUDOCS 9309030271 | |
| Download: ML20056G559 (77) | |
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20L55 y
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August 12, 1913 CH AIRM AN The Honorable Pete Wilson Governor of California Sacramento, California 95814
Dear Governor Wilson:
You may be aware that the NRC is studying options which could reduce the size of, or eliminate, our Regional Office in Walnut Creek, California.
Budget r
pressures have caused us to look for efficiencies that would have the least impact on our ability to protect public health and safety.
Recent changes to Region V's reactor workload and the high fixed cost of maintaining a Regional Office caused us to consider potential savings and impacts.
In examining the future of the Region V office, the Commission has sought to be thorough and to consider carefully the views of, and the impact on, its i
employees. The Commission requested a special study (attached) on the options for realigning the Region V office, and the Commission was subsequently briefed on these options on June 25, 1993. After considering the study team's and senior management's views and recommendations, the Commission subsequently determined not to make a decision until we heard the views and concerns of the Region V employees.
l On behalf of the Commission, I met with the employees of Region V on July 21, 1993, to listen to their ideas and to get their views on the study.
They identified several issues and raised a number of questions that the Commission had not previously considered and that warrant further investigation. We will continue to analyze overhead and other ideas raised by the employees before making a decision, j
I want to ascure you that the Commission will carefully consider the impacts of the various options on our public health and safety mission, the need for resource efficiency, and employee morale and welfare. We have taken under i'
consideration the views expressed in a recent letter by Charles R. Imbrecht, Chairman of the California Energy Commission and California's State Liaison Officer to the NRC. We welcome any additional views you may have concerning realignment. We have considered and continue to explore a variety of cost savings and program reduction ideas. We will of course inform you when we have reached a final decision, which we expect will occur within the next few 1
months.
j Sincerely,
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9309'OdO271 930812" Mg"",
PDR COMMS NRCC I
CORRESPONDENCE PDR-Ivan Selin
Enclosure:
n Region V Realignment Study
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i Region V Realignment Study June 10,1993 i
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Reaion V Realionment Study Table of Contents Pace 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 j
- 1. COMSECY-93-012 75
- 2. EDO Hemorandum of March 30, 1993 76
- 3. DEDR Memorandum of April 20, 1993.
78 4
- 4. FY-95 Budget Baseline: Region V.................
80
- 5. FY-95 Budget Baseline: Region IV 81 l
- 6. Option 1: Region IV.......................
82
- 7. Summary FTE Analysis.......................
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
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REGION V REALIGNMENT STUDY Executive Summary At the request of the Commission, the Executive Director for Operations i
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.
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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, I
investigations, and state agreement programs to Region IV.
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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 sm:'eler regions, Regions IV and V.
These 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 summary, the two smaller regions lack the bench strength of the large regions to respond to certain out-of-the-ordinary circumstances, and they would need to call on Headquarters or another region for assistance sooner than required by the large regions.
On the other hand, the small regions provide additional senior management i
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.
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savings are related either to the FY-95 baseline or to the FY-93 allocation 2
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a 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.
Option 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 i
possible reduction in Agency credibility as a result.
The exercise of this Option would ultimately result in an annual savings of 3
o 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 implerrantation 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
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would remain high.
Cost savings would be significantly reduced, and negative personnel impact would affect a potential 65-75 personnel as opposed to the l
85-95 associated with Option 1.
l 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.
l The exercise of this Option would ultimately result in an annual savings of about 25 FTEs (55 FTE from the FY-93 budget) and would require a one-time cost of between 55.9 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 517.7 and $19.5 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 i
and implementation of the Comnlssion decision.
Such negotiations could affect the timing of some aspects of implementation depending on the bargaining issues and the parties ability to
'concile any differences.
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o Option 3 This Option would establish a Region IV field office in Walnut Creek with limited responsibility for day-to-day activities of the powe. reactor program.
Option 3 offers greater cost savir.gs 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 relccation costs, 1
severance pay,and/or personal hardships.
Administrative cost savings would be l
less than that obtained with Option 1 due to the need to continue rent of i
i 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 anr' arogram 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 Coman.:he Peak and URF0 Field Offices, the Region IV Administrator believes this Option is manageable and has the advantage of retaining a NRC limited presence on the West Coast.
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r 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.
Option 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
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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 i
about 19 FTEs (49 FTE from the FY-93 budget) and would require a one-time cost i
of between $3.6 and 54.8 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 53.7 and $4.8 million in 5 years and t
$14.3 and $15.4 million in 10 years.
Summary Comoarison of Options A summary comparison of the four Options evaluated is contained in the i
following table and associated footnotes. This comparison addresses program impact, initial one-time costs, long-term cost savings, and employee impact.
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SUMMARY
COMPARISON OF OPTIONS Tvoe of Impact Option 1 Option 2 Option 3 Option 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 j
in years 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 l
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 2
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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 Options 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.
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Introduction Study Group Charter On March 30, 1993, the Secretary of the Commission issued COMSECY-93-012 (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.
l 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
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briefing of the EDO.
The Study Group is to evaluate submitter's comments for
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consideration in the final report.
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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, Region IV James Turdici, Assistant to the Chief Financial Officer, Office of the EDO 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.
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'4 Options Evaluated Four Options were evaluated in the conduct of this Study.
In his March 30, i
1993 memorandum, the EDO directed that three Options be evaluated.
The Study d
I 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.
Optier 1 -
Consolidation of Regions IV and V into a single regional office located in Arlington, Texas.
P 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, 4
enforcement, State agreements and liaison programs, and materials programs would be consolidated in Region IV.
f Option 3 -
Reducing Region V to a staff of approximately 25-30 FTEs
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(including Residents), as in Option 2, but structured as a l
field office of Region IV, rather than a separate regional i
office.
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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.
Approach 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 l
following subject areas:
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Impacts on mission accomplishment Interf aces with licensees, the public, the media, State and local governments, Federal agencies, and internal NRC interfaces Incident / Emergency Response 6
Employee Impacts - Short-term and Long-term Impact on Costs, to include travel, transportation, FTEs, relocation, and i
administrative support Positioning for the future 14 9
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t The impact or 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.
I 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.
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L One-time and recurring costs were determined for each Option and reviewed for I
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 j
collection and analysis. The Study was initiated on March 30, 1993. Data e
collection was performed during the period of April 1-23, 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 -
May 10, 1993, in preparation for briefing the ED0 on May 13, 1993.
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Assumptions Used in Conduct of Study The estimates of FTE staff savings from implementation of the various Options i
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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 and two FTE reduction in Region V] in the NMSS materials program which is attributed to current and anticipated workload reductions.
s The Region V resident inspector offices would be staffed to N+I.
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.
t FTEs associated with any such transfer are not included in the estimates used in the study.
URF0 functinns would have been transferred to Region IV and Headquarters by the time of implementation of any of the Options.
i 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
F 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 FTEs 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.
l Except for the Region V, Option 4 organization, the constraint on i
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 i
modifications to Headquarters program requirements.
We felt that such actions, while possibilities, are beyond the scope of this study, and if 17
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t pursued, should be pursued separately and for all regional programs. We address this issue further under recommendations.
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The ratio of direct labor (FTE/ power reactor facility, and FTE/ materials licensee for materials program purposes and FTE/ management and i
administrative overhead) for the expanded Region IV organization, would i
be within the range of the current ratios of Regions I, II, and III, unless otherwise evaluated for feasibility.
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While maintaining existing office alignments (status quo) has not been l
explicitly identified as a separate option, it is identified both organizationally and in terms of FTEs as the baseline from which the i
other options were developed.
The Study Group assumes that maintaining j
the status quo is an alternative available to the decision makers.
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e 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 FY-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, ir.spection, 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.
Amonn the more important functions that were delegated to the regions during 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.
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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.
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r Evaluations of Options Evaluation Summary The following summarizes the Study Group's evaluation of the four Options.
For complete details on each Option, see the discussion under the respective Option.
L Option I would provide the most straightforward, effective and efficient organizational alignment. The new alignment would regulate 12 power reactor sites (19 units) and approxiuately 970 materials licensees. This compares to the 20 plus power reactor sites regulated by each of the large regions and in the materials arch 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.
t Option 2 would provide the most complex and confusing organizational 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 o.
'iculties 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 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 impact associated with loss of management and public affairs presence, as would occur with implementatio:. of Option 1, would be eliminated.
Like Option 2, Option 4 would retain a regional office and Regional 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 be 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 could be external confusion over responsibility issues since two regions would 22 l
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share regulatory responsibility for parts of the NRC mission within the same i
geographical area.
In particular, the NRC states program function would be split between two regions, with attendant communication and coordination difficulties.
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00 tion 1 -
Consolidation of Reaions IV and V into a Sinale Reaional Office Q
located in Arlinaton. Texas.
The implementation of 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.
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1 This Option involves taking the Region V FY-95 budget baseline organization I
(Appendix 4), merging it with the Region IV FY-95 budget baseline organizatior.
(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.
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The degree of senior regional management involvement in individual plant issues may decrease, and meetings with senior licensee personnel would decrease. These have always been the principal benefits of a small region.
l Off-hours communications with licensees about plant issues are likely to
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increase between the regional office and Region V licensees due to the time r
zone change.
Experience indicates that licensees often make these notifications late in the work day.
There would be an increase of management and insper. tor 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.
i The time zones change would negatively impact regional interactions with
[
25
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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 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 26
o 3
reactor inspection travel time.
i 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 i'
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.
i i
i I
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 I
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 between the NRC regulators and licensees would be experienced.
l i
27 i
4 l
1
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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 Regions.
The internal management and communication issues are not expected to be significantly affected other than the increased scope of responsibilities 3
which would be similar to the large regions.
i l
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 ba:e of employees would be a positive impact with more expertise available and more opportunity for cross training and development. The l
ability to respond to changing organizational challenges should be enhanced with the increased depth / breath of personnel.
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
]
e 5
i 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 j
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, wi'
- ge 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 Headquarter <, program offices would have one less regional 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 f
licensees and number of regional staff), it should be easier to maintain uniformity in the way regional work activities are performed.
P e
29
Incident /Emeraency Resoonse 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 havo 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 1
30 i
s e
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 aret 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, e
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 of State and local emergency plans, State and licensee meetings, and special workshops would remain unchanged.
i 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 i'
response positions at any given time.
{
i 31 i
s 4
Employee Impacts - Short-term and lona-term Information on employee impacts has been developed from a number of sources:
j 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.
s i
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 peice 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
e Even though Region V is relatively small, rather significant attriticn 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.
Oat-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 ia a loss of the 8 percent high cost of living pay adjustment for employees, and a resultant perception of loss of i
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 members who have long-term ties to the bay area.
Geographic relocation would make execution of these responsibilities problematic for some and inpossible for others.
Other staff have joint custody of children.
Geographic relocation of these employees would obviously cause a major upheaval in these 33
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 i
I 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 t ransferable.
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 l
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.
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
e e
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 j
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 l
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 geagraphical 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.
i In summary, the closure of the Region V office requiring the relocation of significant numbers of regional personnel, would have a significant negative impact, both personally and financially, f u these individuals.
35
e s
l Impact on Costs. to Include Travel. Transportation. FTE. Relocation. and Administrative Support, Elf 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 cnd materials inspector was added to compensate for the travel distances. The summary of this analysis is shown in Appendix 7.
Salaries and Benefits The FTE savings estimated were then converted to annual dollar savings by multiplying the estimated number of FTEs saved (discussed above) by the i
average value of salary and benefits provided by the Office of the Controller P
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.
36 i
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; iaterials inspection; and management and support trips associated with licensee activities. The additional travel c
2 dollars were calculated by identifying the number of trips typically made to each destination and multiplying this by the cost increase due to traveling j
from Region IV instead of Region V.
Lost staff time associated with the increased length of travel is addressed under FTE considerations above.
1 The increased costs under Option 1 are estimated as:
Reactor inspection
$291,000 Haterials inspection
$37,000 Management trips
$35,000 Cost subotal
$363,000 These increased costs, however, are offset by savings resulting from travel by i
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 i
estimated as:
Headquarters savings
$ 85,000 Regional redundant functions 1 61.000 Savings subtotal
$146,000 37
e
=
i 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 Savinas 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 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 feet at $16 per square foot would cost $32,640.
The final result is a net annual savings for rent under Option 1 of $711,360.
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 5476,000 annually until Occcmber 1998.
Thu:, :lthough NRC would achieve 1
38 f
s.
I savings, the government would continue to incur these costs through 1998 if i
l GSA could not find other government tenants to use the space.
This would be true to one degree or esother for any of the Optinns considered.
These potential costs to GSA have not been reduced from the Agency projected savings as displayed throughout the study.
P Calculation of the long-term sav'.ngs 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 l
and covers a vast array of services, supplies, equipment, etc.
The increased I
cost to Region IV for absorbing the additional 44 FTEs in the region and 13 l
f resident staff is estimated at $302,100. Thus, the overall savings from administrative support if Option 1 were to be implemented is estimated at
$1,010,000 or roughly $1 million.
Relocation One-time costs can be divided into four categorie3: 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 i
costs is provided due to this uncertainty.
The estimation of relocation costs involves a number of variables. The first var ia'ule relates to liie number of people who will accept trdnsfers.
Region V 39 i
i s
e
r 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 identified as the average price of homes in the Contra Costa and Solano county areas.
The second significant variable concerning relocation estimates relates to the percentage of employees who would use the relocation service versus handiing 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 these assumptions, it is estimated that the one-time employee relocation costs 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 l
consistent with the ranges estimated for relocation transfers (65%-80%), 35 40
o 3
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 l
percentage of the retirement eligibles was used as a constant for all Options.
i The remaining staff, ranging from 7-12, would be entitled to severance pay.
The average severance pay used in the calculation wts $32,000 (based on a i
i 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.
i Cost Summary In summary, estimated one-time costs consist of personnel relocation, severance pay, cransfer of furniture and equipment and rather minor i
i administrative items. The vast majority of the one-time costs stem from l
personnel relocation. The estimate for recurring savings is primarily driven
}
by the salaries and benefits associated with FTE savings and savings in j
leasing office space. These are offset to a limited extent by increased travel and ongoing administrative support.
t 1
i The exercise of this Option would ultimately result in an annual savings of i'
about 39 FTEs (69 FTE from the FY-93 budget) and would require a one-time cost of between $7.5 and 59.8 million.
If the Agency actually realizes this 39 FTE j
savings by October 1995, it is then estimated that the one-time costs would be l
recovered in 1.8 to 2.3 years with recurring savings of $4.2 million and long-l l
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
e Positionina for the Future This Option provides the least flexibility and highest future cost if workload were to unexpectedly change an* 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 (DGE) is or would be administering the 42
e repository program.
b o
43
s Option 2 -
Reducina Reaion V to a Staff of Aooroximately 25-30 FTEs (includina Residents) and limitina the mission to a cortion 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 Ty1 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 It baseline organization (Appendix 5) to provide the resources needed to perf orm 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.
The exercise of this Option would ultimately result in an annual savings of about 25 FTEs.
44 I
s I
l Impact on Mission Accomolishment 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 r
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 i
time zone differences and the geographic distances between Regicn IV and Region V would makt it more difficult to meet the greater need for effective i
coordination and communication activities.
I i
Region IV would provide significant 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 j
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 i
45 i
1
)
c l
l 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 efforts, such as Augmented Inspection Teams, Region V would have to rely i
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 1
overall quality and timeliness of SALP reports would be difficult to maintain 4
due to the regional division of resources and oversight personnel that contribute to the SALP process.
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 :nd 46 I
a S
resolution of comments on draft reports would be complicated by the 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 instances, 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 t
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 s
the interface would probably occur at the branch chief level 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 I
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 w"tb 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 meetings; however, this would require virtually the entire Region V technical l
staff to travel to Region IV for each meeting to accomplish the same training l
l previously 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 licensees' point of contact on all inspection issues.
Region V's ability to pr:mptly interact with licensees 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 l
l 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 i
inspector /first-line supervisor level, and to Region V at the management l evel.
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 powar reactor program, which would be fully performed and managed by Region IV personnel.
The principal effects on the implementation of these 49
e programs would be the additional travel time to licensee sites, and more
{
difficult communications with licensees and State officials because of time i
differences, as has been discussed in Option 1.
f The impact upon the emergency response / event response program is discussed in-the paragraph entitled Incident / Emergency Response.
Interface with Licensees. the Public. the Media. State and Local Governmentst Federal Aaencies, and Internal NRC Interfaces For the reasons discussed in Option 1, 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 i
would be regulating NRC licensees in the same geographical area.
It would be particularly difficult for States and counties in that they would have +o 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.
laternal 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 botn 50
Regions IV and V with attendant time zone limitations on those issues involving both region's personnel.
Incident /Emeraency Response l
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 Ager,cy 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 personnel
^
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 a
would not be available to Region IV except through telephone communications.
s 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 51 l
I
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 Impacts - Short-term and Lona-term As discussed under Option 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 remaining 68 staff would be offered reassignments and it is expected that roughly 78 percent of these, or 53 staff, would transfer.
It is estimated that the remaining 15 staff members would either retire or leave the Agency.
Impact on Costs. to Include Travel. Transportation. FTE. Relocation. and j
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
1 I
+
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 i
)
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 l
aboct 25 FTE (55 FTE from the FY-93 budget) and would require a one-time cost i
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-L term projected dollar savings of $3.6 and $5.4 million in 5 years and $17.7 l
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 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.
53 a
Option 3 -
Reducina Reaion V to a Staff of Approximately 25-30 FTE (includino Residents) as in Option 2. but Structured as a Field i
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 i
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 r
benefits of 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 t
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 i
office, avoid duplication of functions, and maximize dependence on Region IV i
while maintaining those administrative and program support functions necessary to support the field office.
The models used for this approach include the Uranium Recovery rield Office and the former Office of Special Projects, t
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
i i
r This Option involves taking the Region V FY-95 budget baseline organization l
(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).
i Impact on Mission Accomplishment i
i Option 3 provides many of the advantages associated with Option 1.
Some of t
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 j
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 j
State counterpart function for reactors resides in Region IV.
As with Option 2, roughly half of the inspection resources to conduct the 1
55
Region V site program would reside in the Region IV Arlington office. The i
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.
Coordination and scheduling of inspections between the Region, and the field i
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 l
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.
i The implementation
' the SALP process would require me additional coordination.
The overall SALP effort would be conducted in the Region IV Arlington office.
56 i
J
Under Option 3, inspection reports would be handled similar to the way they are currently handled in Region IV.
,<eports 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 j
Director and would require concurrence by Field Office personnel. This i
concurrence process may inv>lve a minor delay to accommodate the time zone and l
l geographical factors but the NRr's Wide Area Network should minimize any such delays.
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 i
Region IV Arlington office.
The same would apply to enforcement activities with the additional complication that field office personnel would be required
[
t 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 Acencies. 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 minim 12e 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.
Interr,al interfaces would be less complex with four, rather than five regions to deal with, with the exception of 57 i
i
I 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 /Emeroency Response As in Option 2, the proposed staffing levels within the field office wauld 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.
i 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 l
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 i
Site Operations, thereby reducing the overall Agency capability in this area from 13 to 11.
l Response times to potential incident sites (current Region V power reactors) 58
4 1
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.
Employee Imoacts - Short-term and Lona-term Exercise of this Option would result in impact on 79 employees versus 88 employees for Option 1.
i 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 j
78 percent of these, or 62 staff, would move.
It is estimated that 17 staff members would either retire or leave the Agency.
f E
Impact on Costs. to Include Travel. Transportation. FTE. Relocation. and Administrative Support.
The methodology used for estimating the savings and costs associated with i
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 l
59 i
l
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 I
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 year with recurring savings of $3.5 million and long-term projected dollar savings of $5.2 and $7.4 million in 5 years and $22.7 and $25.0 million in 10 years.
l Positionina for the Future l
The impact for this Option is the same as stated in Option 2.
60
4 Dotion 4 -
Reducina Reaion V to a staff of acoroximately 60 FTE (includina residents) with all reactor orocrams remainino in Reaion V.
All other oroarams includina 01. fuel facilities.
decommissionino. State aareements. 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 support 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, l
t California, as is the case in the previously discussed Option 2.
However, by I
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 Option 2, would not exist.
i impact on Mission Accomplishment 61
s o
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, i
enforcement, allegations, management meetings, and team inspections, as I
related to power and nonpower reactors, would all continue to be carried out as they are currently being performed.
l The total number of supervisors in the Region V organization decreases to reflect the reduced level of administrative support and the transfer of the l
materials, fuel facilities, decommissioning, and State agree.nents programs.
1 I
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.
l The impact on the materials, fuel facilities, decommissioning and state agreement programs would be the same as that discussed under Options 1, 2 and l
3.
Under this Option, with the overall reduced management staff, 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
This Option retains the ability to perform all anticipated reactive inspection efforts, including Alis. As has been the case in the past, Region V would continue to request specific technical support from Headquarters for detailed followup 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 ali activities associated with power and nonpower reactors.
I d
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.
l 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 /Emeraency Response This Option provides sufficient resources to maintain the current Region V 63 l
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 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 i
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.
There would be one less senior SES manager in the Agency qualified to serve as I
a Director of Site Operations, thereby reducing the overall Agency capability in this area from 13 to 12.
t Region V, under this Option, could support Region IV's response to materials and fuel facility incidents.
Employee Imoacts - Short-term and Lona-term l
This Option would result in a negative impact on the least number of employees i
of the four Options evaluated.
64
'vv-m
4 Under this Option, the Region V office would consist of about 58 people,13 of i
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.
i Impact on Costs. to Include Travel. Transportation. FTE. Relocation. and Administrative Support, l
The methodology used for estimating the savings and costs associated with l
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 I
people transferred from Region V and 2) the number of positions increased in l
Region IV. Appendices 7 and 10 reflect the changes associated with these j
factors and the associated savings and costs.
l l
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 savings by October 1995, it is then estimated that the one-time costs would be i
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
= " * -
W e
m m
e o
Positionina for the Future The impact of this Option is the same as stated for Option 2.
1
'I i
l 66
s s
Regional Employee Comments e
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 report.
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 Score of Realianment 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 i
trimming of other Agency programs such as overhead.
The Study Group did not address the above defined issues in its studv because e
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 i
67 5
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O l
1 i
i overhead.
Geoaraphic Imbalance Some employees expressed concern that there is an obvious geographic area imbalance, relative to the number of states per region, if Region V is consolidated within Region IV.
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 1 under the heading of " Interfaces with Licensees, the Public, the Media, State and Local Governments, Federal Agencies, and Internal NRC Interfaces."
Status Quo Consideration i
Some employees were concerned that the " Status Quo" was not addressed and evaluated as a separate option in the report.
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 i
used in Conduct of Study", and " Conclusions and Recommendations."
t
[
68 t
f I
~2 a
lack of NRC Presence on the West Coast i
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.
1 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."
F
- l 69 J
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 Options 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 4
consideration.
Any decision to depart from the status quo should be based on a weigning 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 i
relocations 2) the pros and cons associated with mission accomplishment 3) the l
loss of NRC presence on the West Coast 4) the effect on our pecple 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 i
evaluate the first factor, which we believe is a significant decision consideration.
l A recommendation to adopt any of the study options should depend on the i
necessity that the ED0 and Commission feel exists in a tightening budget climate where existing and possible additional pressures to downsize and I
l become more efficient may dictate precedent setting management measures. The i
1 70 l
t
a 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 i
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 I 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 i
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 i
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 I
t a-
,n
1 continue smooth interactions and communications.
o Option 3 would provide the second highest potential savings and second
)
highest cost and personnel impact consequences.
Its pros and cons are similar to Option I 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 j
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 geographical t
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.
t The Study Group conclusions are consistent with responses received from the staff as contained in Appendix 16.
t
)
i 72
.m Recommendations l
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 i
that both Options 3 and 4 are viable options with cost saving benefits j
and either could be successfully implemented.
1 It is extremely important to provide a prompt decision so that people can o
I eliminate the continuing uncertainty in their lives. We believe this is l
an important issue regarding the effective implementation of any i
decision.
We also believe it important to have a clear, equitable, and j
prompt plan, with appropriate agreement by NTEU, as to how assignments would be made to all bargaining-unit personnel.
I 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 t
constraints.to look at the rest of the Agency, clearly a study of j
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
t e
i important as a fairness issue with many employees.
i i
o If the decision is made to adopt any option, we believe it extremely important to provide a comprehensive transition plan to include temporary i
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 i
employee trust, confidence and resultant teamwork and morale.
o Lastly, we recommend that any decision adopting other than the status i
quo, address the Agency necessity underlining the decision.
At present, i
i 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 les's i
impact on people.
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