ML20056G646
| ML20056G646 | |
| Person / Time | |
|---|---|
| Issue date: | 06/03/1993 |
| From: | Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Faulkenberry B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20056G560 | List: |
| References | |
| NUDOCS 9309070010 | |
| Download: ML20056G646 (2) | |
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4 UNITED STATES g
NUCLEAR REGULATORY COMMISSON g
i REGION V
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1450 MARIA LANE WALNUT CREEF, CAUFORNIA 94596-5368 June 3, 1993 MEMORANDUM FOR:
B. H. Faulkenberry, Regional Administrator FROM:
L. F. Miller Jr., Chief Reactor Safety Branch
SUBJECT:
COMMENT ON THE DRAFT REGION V REALIGNMENT STUDY I offer these observations on the study:
1.
Some potentially superior options have not been analyzed.
Consequently, the study is too narrowly constrained and focused.
In particular, I suggest two more options be fully considered.
Option 5 would continue the present alignment of responsibilities and staff.
The impetus for pushing through one of the Options I through 4, apparently, is to reduce FTE beyond the already gaunt FY 85 budget for Regions 4 and 5.
The reason for this goal is not clearly stated in the study.
It is known that Regions 4 and 5 are currently effective; they probably can remain effective under the FY 95 budget. The' reductions proposed under Options I through 4 are at best an untried estimation that the missions can still be effectively performed with many fewer personnel. This claim seems too optimistic and subjective.
Option 6 would redistribute the regional work evenly among all five regions.
In particular, under Option 6, such functions as ERF0, high level waste, non-power reactors, operator licensing and materials would be shifted to Region V preferentially as necessary to level the staffing among all five regions.
If necessary, power licensee assignments could be realigned slightly as well.
Other federal agencies have designated certain regions as lead for certain activities. This concept could likewise be applied to the NRC.
This would permit a levelling of regional administrative and management overhead based on an equality of workload.
Personnel disruption would still occur, but it would be spread more equitably across the NRC, rather than targeted at Region V.
The NRC's West Coast presence would be enhanced.
2.
All of the options assume a trarisfer of some responsibility to Region IV from Region V.
However, many functions, such as non-power reactors, operator licensing, and materials, could be centralized as well in either location.
The preference for transferring functions to Region IV, rather than to Region V, is not explained, and makes the study seem less objective.
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i 3.
All of the' options which are studied increase the ratio of workers to
- 1o supervisors. This change will reduce the effectivaness of the combined Region IV/V effort.
Supervisors are, on average, more effective and harder working.
personnel.
Reducing their numbers will decrease overall performance, nn age 4.
All of the cost-benefit analyses assume that Region V personnel will be ;e relocated, but Region IV or other regional personnel will not be. This beggar-thy-neighbor approach weakens all of the options.
If moves are
--.n e necessary, they should be made based on competition in the reduced Region.IV/L, organizations for the available positions. Assuming an equal distribution of v talent in Region IV and V, slightly fewer than half of the persons in Region n IV should expect to be moved. This approach would increase the cost of asr.
reorganization by requiring more relocation, but it would result in a strongerne regional organization.
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I-5.
The study does not analyze how many personnel will be left without a
.e position in Region IV or V under each option. That number will vary with each 1 option, and should be explicitly calculated and discussed.
In particular, thew impacts of forced transfers of GG-I5' supervisors to a non-supervisory
.ci Headquarters position should be analyzed.
Such a transfer is, functionally, m demotion, and would reduce the agency's capabilities.
Reductions elsewhere in Headquarters to compensate for the increase in staffing by these forced transfers is implied and should be analyzed.
I hope that these observations will be considered in the decision-making which will occur concerning realignment.
1 l
. F. Miller Jr., Chief I
l Reactor Safety Branch l
l 116
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