ML20056G606
| ML20056G606 | |
| Person / Time | |
|---|---|
| Issue date: | 06/04/1993 |
| From: | Yuhas G NRC |
| To: | Faulkenberry B NRC |
| Shared Package | |
| ML20056G560 | List: |
| References | |
| NUDOCS 9309030321 | |
| Download: ML20056G606 (5) | |
Text
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o June 4, 1993 Note to : B. F. Faulkenberry, Regional Administrator i
from:
G. P. Yuhas, Chief Radioactive Materials Safety Branch
SUBJECT:
COMMENTS ON DRAFT REGION V REALIGNMENT STUDY Thank you for the opportunity to comment on this important study. The following comments have been grouped in accordance with your memorandum dated May 24, 1993.
3.
SIGNIFICANT ISSUES NOT ADDRESSED i
- The March 30, 1993 memorandum for Mr. Taylor from Mr. Chilk stated "The study should include a discussion of other alternatives such as:
i consider a possible realignment of regional responsibilities to provide a better work load balance among the regions."
The draft study seems to have ignored this direction.
The regional offices have been clearly advantageous to achieving the mission of the agency. Why isn't there a discussion of transferring responsibilities for materials, fuel fabrication and decommissioning activities in Idaho and Utah to Region V?
If we are serious about FTE reduction and improved consistency why sren't we evaluating consolidation of Region I in White Flynt II?
- Region V has in the last two years spent a large amount of the tax-payer's money upgrading the Region V office, like installation of a local i
area network, yet no mention is made of this potential loss to the public i
if Region V is abandoned.
- Page 15 The options a; ivated did not consider status quo.
To compare the four optiora presented without consideration of no change to Region V (as it would be in the future considering expected decreases in work load) results in an inaccurate picture of the true options.
For example, as the work load decreases one could expect a reduction in staff, reorganizations within the region to reduce the amount of management overhead, reduction in overhead expenses, and perhaps movement of the office to a local Federal building when the existing lease expires.
Failure to consider the realistic fluctuations in a Region V as currently established results in an invalid and inaccurate assessment of the four options.
One could realistically envision a 1998 Region V with the same scope and responsibilities but with a work-force and organization tied directly to the existing workload. How would the proposed four options compare to a i
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1998 Region V consisting of an SES Regional Administrator and Deputy, three Branch Chiefs (Reactors, Safety, and Support), with two Section Chiefs in each branch, relocated to the Oakland Federal Building? This sort of realistic projection would provide for a fair comparison of not 4
only FTE savings but cost and impact on the mission. Note: $1.9 million dollars in penalties would be saved if Region V fulfills its office lease through 1998.
None of the options considered truly address the impact on our mission because the PUBLIC and the LICENSEES have not been given a chance to offer their views. We don't seem to have learned much from the BELOW REGULATORY CONCERN (BRC) experience.
It seems illogical that a decision effecting one fourth of the nation would be made behind closed doors.
- Page 4 The options do not imagine a need to re-open a Western regional office.
It appears that the GA0 report of NRC oversight of nuclear medicine and the Agreement State Programs may result in the need for more materials involvement in the western states.
California's materials program (about 3000 licensees) may require additional NRC support and oversight in the future.
Should the NRC respond to Senator Glenn's concern about the inadequate regulation of radiation medicine with legislative changes that expand our role, California could present a huge workload.
- Finally, California has long been a center of advanced research and technology development.
Region V might be a better location from which to monitor future development at facilities such as General Electric, EPRI, and Stanford.
Any decision to change Region V should consider future developments in the field.
- Page 42 The impact on Region IV employees is not addressed.
Consolidation of the Region V function in Region IV will result in great stress to those Region IV employees that will then have to compete for their jobs.
This stress and possible chain reaction of personnel actions will be very disruptive and costly.
The Region IV employees will also lose confidence in NRC management when they realize that they were misinformed concerning the security of their jobs. This point might also result in legal action against the NRC.
Page 75 The impact of relocating materials licensing and inspection, fuel facilities, and decommissioning to Region IV is assumed to have no impact on the agency mission.
The evaluation does not address the impact on the public of not having a i
group of experts readily available to deal with their questions and problems.
The public or licensees contacting the option-4 Region V are likely to feel like they are getting the run-a ound when they're told to 97
4 call Texas with their question. The public will be outraged if the local Region V office is not capable of responding to the frequent materials incidents.
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2.
IMPACT ON THE MISSION t
- Page 3 Option I provides one sentence to address the public impact of consolidation in Texas: "There would also be a loss of full time management and external interface presence on the West Coast, with a possible reduction in
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agency credibility as a result."
Relocation of Region V to Texas would negatively impact the public and our customers (licensees). The public in Region V will have less access to the agency and that access will cost more.
Region V handles many calls each day from members of the public. Many of these calls are directed to Agreement States when appropriate.
The extra cost and hassle
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of finding our telepnone number in Texas will serve as a deterrent to seeking advice.
The Region V materials staff has developed a close working relationship with representatives in each state and many other local and federal representatives. These relationships will be disturbed and may never be fully reestablished due to the lack of proximity.
Region V health physics and emergency planning personnel serve as a pool of expertise and equipment to support the Federal Radiological Emergency Response effort and States on the West Coast.
Our ability to provide the same quality of support is unlikely if these health physicists are i
located in Texas.
Finally, the public and the media want to interact with agency representatives that have a vested interest in their community. An NRC office in Texas will never satisfy this criteria.
One look at the attached map showing the proposed geographic impact of consolidation in Region IV immediately causes the viewer to question the merits of this option.
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- Page 5 Option 2 does not include adequate health physics expertise.
With an NRC Region V, the public will expect that the office will be able to address health and safety. The states and the public will also expect local NRC officials to represent the NRC position regarding any event i
that might occur in the region.
- Page 24 The evaluation of Option I contains the following comment:
" Headquarters wo'uld have one less region to deal with programmatically, resulting in some benefit to consistency."
i This comment evokes the obvious question; if we really want to save money, reduce FTE, and improve consistency why aren't we studying consolidation of Region I and II in headquarters and Region III, IV, and i
V in a midwest or western location?
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t Page 35 The incident / emergency response discussion does not address the negative impact associated with loss of the NRC Mobile Laboratory.
The NRC Mobile Laboratory played a major role in the early days of the Three Mile Island accident. The ability of the Region IV Mobile Laboratory to respond to an event in much of Region V is not discussed.
I suspect that it would require at least one additional day for the Region IV Mobile Laboratory to reach most of the Region V reactor sites.
3.
MAJOR COST ISSUES
- Page 4 No net FTE will be saved by the closure of Region V and yet this conso'idation will cost millions, i
It is our understanding that a.
Region V personnel will be offered positions with the agency.
If the NRC stands by this promise, how can 39 FTE be saved ?
If the move will cost between 57.5 and 59.3 million what have we saved the taxpayers?
It would seem far more logical to steadily right size the agency as work load decreases.
For example, when a power reactor like Rancho Seco enters Safstore, its assigned NRC FTE should be t
reduced to one part of one materials inspector's time after one year.
The regions should shrink proportional to work load in real time. When the existing Region V lease runs out perhaps the regional office should be moved into the local Federal Building.
- Page 43 The evaluation used an average value of $80,000 per year to calculate salary and benefits cost savings.
Using an average value may be easier, but in reality most of the FTE saved by consolidation in Texas will come from lower graded employees.
The study should have attempted to more accurately calculate this savings.
- Page 49 There are about eight individuals who could retire and are not expected to relocate.
The study did not recognize that these individuals may not retire to convenience the agency.
Perhaps the cost of their relocation should have been considered.
c 4.
INCORRECT INFORMATION
- Page 2 The comment is made that the smaller regions,"...do not provide the degree of depth and breath of technical expertise available in the large regions."
Region V has significant depth and technical expertise in the field of health physics. Of the twenty five professionals in the Division of
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Radiation Safety and Safeguards that have radiation safety r
responsibilities, five currently have Masters of Science Degrees in 99
Health Physics, three have Masters in Physics, two have Masters in Nuclear Engineering, one has a Masters in Medical Physics, one has completed her course work for a Masters in Health Physics, the remainder also hold degrees in related fields, or in two cases, each has over thirty years of experience.
In addition, two individuals are certified by the American Board of Health Physics.
Region V has cross trained many of its Health Physicists such that they can support reactor, materials, or fuel facility health physics problems. Two individuals are also fully qualified resident inspectors and another Health Physicist has qualified as a reactor inspector.
Region V has never called on another region to provide health physics support to complete the inspection program or assist in emergency response.
Region V has on occasion, and is always ready to assist the larger regions in their efforts to complete the inspection program and respond to emergencies.
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Region V has a strong bench of versatile players that has consistently met every challenge.
We do recognize that in a serious event, we like any other region, would count on the support of the entire agency.
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- Page 22 The History /0verview fails to address the pre 1982 success of small regions.
The regions were not always large. No facts are presented to substantiate that larger regions have a more positive impact on safety or public service than smaller regions.
- Page 38 The evaluation placed the greatest emphasis on loss of the l
8% locality pay by putting that paragraph first.
t It is not correct to create the impression that employees are more concerned about locality pay than they are with losing their jobs, their homes, and their sense of community.
In conclusion, I fully support your efforts to right size the agency; however if we don't think that regions are important why are we not considering consolidation of all the regions in headquarters?
GP A G. P.
as attachment:
as stated
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