ML20056G599
| ML20056G599 | |
| Person / Time | |
|---|---|
| Issue date: | 06/04/1993 |
| From: | Johnson P NRC |
| To: | Faulkenberry B NRC |
| Shared Package | |
| ML20056G560 | List: |
| References | |
| NUDOCS 9309030310 | |
| Download: ML20056G599 (2) | |
Text
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From:
Philip H. Johnson (PHJ)
To:
BFF l
Date:
Friday, June 4, 1993 4:41 pm
Subject:
COMMENTS ON CONSOLIDATION The following comments are provided on the Regional Consolidation Study:
1.
Regarding Option 1 or 3, the problem of a region spanning three time zones (even more when the Pacific areas are considered) appears to have been minimized.
Regional office personnel who want morning status or resident contact will find the two-hour time difference to be a problem. On the other end, residents will find themselves being asked to come into work very early to support activities which occur early in the regional office's working day.
2.
Regarding Option 1, the decrease in NRC presence on the West Coast will be striking.
The states, utilities, and other licensees will find travel to Dallas for normal interface to be a significant burden.
The two-hour time difference will also be a significant disadvantage for normal telephone interface, since less than 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of common working hours will remain (9:30 to 4:00, Dallas time, minus lunch periods at each location, which occur at different times).
l 3.
Regarding Option 4, the disadvantages appear to have been overly emphasized in the report.
The line of demarcation between reactor and non-reactor issues and licensees should not be difficult to define.
A smaller Region V which covers all reactors would work well.
Providing oversight for non-reactor licensees from another location would appear to offer minimum confusion -- in a manner similar to the way OSHA or agreement state issues are handled now.
4.
Concerns regarding emergency response and dispatch of inspectors will definitely increase.
Travel time to WNP-2 from Region V is often over 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and this (ant the attendant expense) would worsen significantly for travel from Dallas.
The problems associated with this concern also appear to have been minimized, assuming optimal travel conditions will prevail.
5.
I know a lot of thought has gone into the cost-benefit aspects of the study, and it is difficult for me, without significant thought, to concent intelligently.
I have an nagging concern, however, that the costs of inspection travel from a consolidated Dallas office have been based on optimal travel and scheduling assumptions, and will in actuality be somewhat higher.
6.
While it's obviously outside the targeted scope of the study, it is painful to consider that many more obvious methods of reducing positions and trimming FTE (e.g., consolidate the functions performed by AEOD and NRR Events Assessment Branch) without massive geographic relocations have apparently been rejected by the Commission and the EDO without significant thought.
7.
I hope I'm wrong, but the sense I get from the rumor mill is that consolidation is coming -- perhaps has already been decided -- and that the severe per m ai and financial impact which will be felt by 80 to 90 people, along with the drastic reduction of NRC presence west of the Rockies, will be less important than a painless (to HQ personnel) method of saving 25 or 30 FTE.
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Thank you for the opportunity to comment.
Phil Johnson CC:
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