ML20137A981
| ML20137A981 | |
| Person / Time | |
|---|---|
| Issue date: | 01/07/1986 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-86-008, SECY-86-8, NUDOCS 8601150013 | |
| Download: ML20137A981 (114) | |
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POLICY ISSUE srcy-86-8 January 7, 1986 (InfOrmation)
Fer:
The Commissioners From:
Victor Stello, Jr.
Acting Executive Director for Operations
Subject:
INTERNATIONAL EFFORTS TO HARMONIZE HEALTH EFFECTS MODELS AND RISK COEFFICIENTS
Purpose:
To inform the Commission of the following:
l 1.
Development of new health effects models by NRC research contractors.
2.
Staff activities toward obtaining international agreement on health effects models and risk coefficients.
3.
The background and sumary of these efforts.
Issue:
The Commission has expressed a desire (Chilk to Dircks memorandum dated February 13,1984) for uniform health effects models and risk coefficients to be used by the NRC staff in the assessment of risks from radiation exposures from normal operations and potential accidents at NRC-licensed facilities.
Staff activP
.e in this regard are described in this paper; the international effui 's especially noteworthy.
Discussion:
Background
Health Effects Models are mathematical formulas which relate the probability of occurrence of particular health effects to the radiation doses to various body organs.
From these models the risk coefficients (risk per unit dose) applicable for a specific dose and dose rate are derived.
Contacts:
S. Yaniv, RES 74581 J. Martin, RES g115g3e60107 37625 86-000
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The Commissioners 2
i The Reactor Safety Study (RSS) Risk Assessment Review Group (the Lewis Committee) reconnended that the health effects models in WASH-1400 be reviewed as new data becomes available.
In response, in 1982 RES l
initiated a critical review of the health effects models used in the i
RSS. The initial effort resulted in a critique of the RSS models in j
NUREG/CR-3185, " Critical Review of the Reactor Safety Study i
Radiological Health Effects Model," March 1983.
j i
I Based in part on this critique, but also as part of a general review I
i and improvement of severe accident models and to promote a consistent i
approach to risk assessment within NRC, the Office of Nuclear-l Regulatory Research (RES) funded the study which resulted in the new i
set of models described in a report recently published by Sandia l
National Laboratories, entitled, " Health Effects Model for Nuclear
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Power Plant Accident Consequence Analysis," NUREG/CR-4214. July 1985.
I l
The report was prepared by an e'ninent group of scientists, which j
j included physicians and epidemiologists, under management of the l
Harvard University School of Public Health.
(It is therefore often i
j referred to colloquially as "The Harvard Report.") After peer review I
L by a selected group of scientists, the report was revised to reflect i
their comments. The report was then distributed to over 800 addressees l
in August and September 1985 and a Federal Register Notice announcing r
i the report and requesting public comments was issued September 17, 1985.
On October 10, 1985, a public meeting was held in Bethesda, Maryland, at which representatives from Harvard and Sandia presented an overview l
t of the models and their import. A number of Federal agency l
representatives attended this meeting. The public comment period i
expired December 15, 1985. No comments were received in response to j
the notice.
In its review, NRC staff has identified several problems in
'i the report, principally in the early and continuing health effects l
models. However, it is expected that these problems will not t
significantly alter mean results of consequence analyses of reactor accidents, e.g., the risk estimates expected in NUREG-1150, i
" Nuclear Power Plant Risks and Regulatory Implications," scheduled to be issued in mid-summer 1986.
The staff is working with the contractor to correct the problems in NUREG/CR-_4214.
I A brief description of the principal health effects, the models used l
i in NUREG/CR-4214, and the main assumptions made in developing these j
models is provided in Enclosure l'.
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International Interest i
j In April 1985, Professor John' Evans, Harvard School of Public Health, I
j summarized the report, including the new models, at a Workshop on j
j Methods for Assessing the Offsite Radiological Consequences of Nuclear e
j Accidents (MARIA), which was sponsored by the Connission of the European Communities in Luxembourg.
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~ The Commissioners 3
In September 1985, Dr. H. Rininsland Head of Project Nuclear Safety -
at the Nuclear Research Center Karlsruhe (KfK),- Germany, visited 'NRC -
to discuss proposed revision of the German Reactor Safety Study and
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the impact of NUREG/CR-4214 on their study. At that time he informed l
RES management about a workshop on this subject scheduled for late September 1985 at KfK, and RES management suggested that the models i
used in Gemany and U.S. should be coordinated. As a result, Dr.
Evans and Dr. S. Yaniv, NRC, were invited to discuss the models at l
the KfK workshop..
The workshop was attended by KfK staff members, i
other prominent German scientists and British scientists from the i
National Radiological Protection Board (NRPB). As a consequence of l
the favorable reception of the NRC-sponsored work as presented by j'
Dr. Evans, the British and German scientists agreed that it would be very desirable if the health effects models and risk coefficients used in Europe and the U.S. were "hamonized" as much as possible.
i with account being taken of any necessary regional and national peculiarities. The intent would be to enhance public confidence in risk estimates. Subsequently a letter was received from Dr. H.
j Rininsland in which he formally proposed to initiate the harmonization process. As a result, a meeting has been scheduled for January 1986 in Karlsruhe, Germany. The meeting will_be attended by.Drs. G.
i Burdick and S. Yaniv, RES; Dr. D.-Alpert, Sandia National Laboratory;
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and German and British experts.
The purpose of the meeting is to i
develop an approach, methods and schedule for harmonization of the models..
l Future Plans l
l If resources permit, in 1986 the staff plans to complete its review of NUREG/CR-4214, to evaluate the models, and to resolve.any comments.
The staff will pursue the objective of achieving international agreement on health effects models and risk coefficients. -It is anticipated that some agreement with the Gennans and the British can l
be achieved in 1986. Following that, other countries will be invited j
to harmonize their models, possibly through the Nuclear Energy Agency 1-(NEA) or the International Commission on Radiological Protection (ICRP).
j A revised version of NUREG/CR-4214 is scheduled to be published in 1987.
This report will include changes resulting from public consnents i
and the international coordination.
It will also include listings of health effects coefficients for uniform use by the NRC staff, as requested by the Commission.
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A draft regulatory guide on this subject is also scheduled for i
publication in 1987.
It is anticipated that this guide will include
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the regulatory staff position on the health effects models and I
coefficients published in the NUREG report.
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The Comissioners 4
Beyond 1987, the staff foresees a need to periodically update the health effects models. New data and information are expected. Such revisions are likely-to be necessary ev.ery 5._to 10 years thereafter.
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VictorStello,Jr[
Acting Executivd Director for Operations
Enclosure:
Health Effect Models and Risk j
Coefficients DISTRIBUTION:
Connissioners OGC OPE OI ACRS EDO SECY i
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6
HEALTH EFFECTS MODELS AND RISK COEFFICIENTS 1.
Introduction Health Effects Models are mathematical formulas which relath the probability of occurrence of particular health effects. to the radiation doses to various body organs.
From these models the risk coefficients (risk per unit dose) applicable for a specific dose and dose rate are derived.
2.
Early Occurring and Continuing Effects Early occurring and continuing effects result from relatively large doses of radiation (generally hundreds of rads) and manifest themselves within hours to months following radiation exposure.
These effects include, but are not limited to, death due to irradiation of blood forming organs, the lungs and the gastrointestinal tract; radiation induced sickness resulting from whole body irradiation; lung function impairment; functional impairment of the thyroid gland; skin burns resulting from skin contamination by radionuclides; transient and permanent sterility; and cataract induction.
All these effects are threshold effects; i.e., they would not manifest themselves below a certain dose and the severity of an effect increases with increasing dose.
It is unlikely that anyone would die from a whole body dose of 100 rad. A significant fraction of people receiving acute i
doses of 400 rads would die, and it is very unlikely that anyone could survive an acute whole body dose of 1,000 rad.
The time of manifestation of the effect is also dose dependent, and within certain limits, medical intervention could affect the outcome.
In general, much higher doses are required to produce the above effects if the radiation doses are delivered over days and weeks rather than minutes and hours.
Very limited human data are available for these early effects. Thus, quantitative risk estimates have to be based largely on animal data and general radiobiological knowledge.
The important parameters in risk estimates for early effects are the threshold dose for each effect, the dose which would be lethal to 50% of exposed people (LDthat would affect 50%
ED5n), and the minimal dose that would produce the,effect in everyone exposed {LD or In assessing risk of deati. ' r injury, multiple insults to 99e y
EDtno).
o san individual must also be considered (e.g., irradiation of blood forming organs by external radiation combined with irradiation of the lung by inhaled radionuclides).
The models presented in NUREG/CR-4214 take into consideration these 3
variables. Although the models are based essentially on the same data as those in WASH-1400, they differ in their mathematical presentation, which is more suitable for risk assessment and include estimates for several possible effects not included in WASH-1400.
1
4 3.
Late Somatic Effects Exposure to ionizing radiation is also associated with risk of future somatic and genetic effects, somatic (mainly cancer) being those affecting the irradiated individual and genetic being those affecting the offspring i
of the irradiated individual.
Both of these effects are random in nature i
and only the probability of occurrence increases with increased dose, not the severity.
Radiation induced cancers and genetic effects are indistinguishable from those occurring from other causes and can only be inferred on the basis of increased incidence in irradiated populations.
People who recover from early effects or have received radiation doses below the threshold for early effects have an elevated risk of developing cancer sometime in the future. The chapter titled Late Somatic Effects in i
NUREG/CR-4214 provides models and risk coefficients for quantitative i
estimates of such latent cancer risks. The risk estimates are based primarily on the 1980 Report of the Committee on the Biological Effects of Ionizing Radiation of the National Academy of Sciences entitled, "The Effects on Populations of Exposure to Low Levels of Ionizing Radiation,"
(BEIR III).
In estimating the somatic health effects, the BEIR III report utilized epidemiological data obtained from studies of survivors of Hiroshima and Nagasaki and, to a lesser extent, other irradiated populations.
In BEIR III there are variations in risk estimates which are due to factors other than just uncertainties in the Japanese and-other epidemiological data bases. Excess cancers have been observed mostly following relatively large doses delivered at high dose rates. Moreover, the. observation time of the exposed populations does not extend yet through the lifetimes of the irradiated individuals. Therefore, assumptions must be made about how observations at high doses and dose rates should be applied at low doses and low dose rates for radiation of a given type and how risks from radiation might vary long after-the time of exposure.
1 The BEIR III report examined three dose response functions in detail:
(1) linear, in which effects are directly proportional to dose at all doses; (2) linear-quadratic, in which effects are very nearly proportional to dose at very low doses and proportional to the square of the dose at high doses; and (3) quadratic, in which the risk varies as the square of the dose at all dose levels. All mathematical functions in BEIR III assume that there is ne dose below which there is no excess health risk.
For. low LET radiations, BEIR III recommended the use of a linear-quadratic dose response function. To estimate the risk of radiation exposure beyond the years of observations, either a relative risk or an absolute risk projection model (or suitable variations) must be used.
The relative risk-projection model projects the currently observed percentage increase in cancer risk per unit dose into future years. An absolute risk model 4
projects the average observed number of excess cancers per. unit dose into the future years at risk. Because the baseline rate of cancer incidence rises dramatically with ' age, the relative risk projection model predicts a larger number of radiation induced cancers in an aging population for years beyond the periods of observation; consequently, the average lifetime risk calculated according to the relative risk model is higher.
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The BEIR Committee did not specify which projection model is the appropriate choice for most radiogenic cancers.
Since the publication of BEIR III, new radioepidemiological data have become available. This additional information has been used to supplement BEIR III in developing health effects models described in NUREG/CR-4214.
NUREG/CR-4214 provides upper, " central" and lower risk estimation models for leukemia and cancers of the bone, breast, lung, gastrointestinal tract, thyroid, skin and "other" organs.
Models for cancers due to prenatal irradiation are also given.
For the " central" estimates, considered most realistic by the Advisory Group, linear-quadratic dose response models were used for all cancers except those of the breast, thyroid and those due to prenatal irradiation. The linear dose response model was used for these cancers.
The relative projection model is used to estimate the risk of breast, lung, gastrointestinal and "other" cancers.
The use of the relative projection model, justified by the latest radioepidemiological data, represents the major difference between the risk estimates in NUREG/CR-4214 and those in WASH-1400. This difference, combined with higher numerical risk coefficients for certain cancers, results in about three fold higher cancer risk estimates over those given in WASH-1400.
4.
Genotic Effects Irradiation of the reproductive organs can cause increased incidence of disorders of genetic origin among the offspring of irradiated people.
Such disorders can manifest themselves in the first generation following parental irradiation and/or in future generations.
Risk estimates for genetic effects are based on experimental animal data, since no suitable human data is available.
NUREG/CR-4214 provides genetic risk estimates which take into consideration the demographic structure and birth rates of the U.S. population. Although they do not differ significantly from those presented in BEIR III and WASH-1400, they are in i
a format which is more suitable for risk assessment.
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into the DCS. An advanced has been sent to the Public Document Room.
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December 19, 1985 cum man The Honorable John S. Herrington Secretary U.S. Department of Energy Washington, D. C.
20585
Dear Mr. Secretary:
As you know, the Department of Energy (DOE) has recently initiated an upgrade of physical protection measures at its facilities possessing special nuclear material.
In this connection, our respective agencies have had a long standing goal of maintaining comparable levels of protection for facilities possessing weapons-usable special nuclear material.
2 This coordination effort between DOE and the Nuclear Regulatory Commission (NRC) had its origins in working agreements developed in 1976 between DOE (then ERDA) and NRC.
These agreements were formalized in several documents.
For example, in a join't letter to the Chairman, Committee on Interior and Insular Affairs, U.S.
House of Representatives, signed by the NRC Chairman and the Acting ERDA Administrator on February 16, 1977, it was stated that the NRC and ERDA would maintain close-coordination of safeguards program requirements for mixed facilities and comparable government-owned facilities which possessed strategic quantities of special nuclear material.
The subject of comparability and the basis for it has been a matter of continuing interest.
For example, in 1980 at the request of the National Security Council (NSC), the Departments of Defense and Energy, along with the NRC, conducted a joint review of threat guidelines used in the development of safeguards measures for nuclear weapons and weapons-usable material by each agency.
This action was in response to a February 1980 recommendation of the U.S. Comptroller General that the NSC coordinate the nuclear threat definition policies of 000, DOE and NRC to ensure that similar types of weapons-usable nuclear materials get comparable levels of protection regardless of which government agency controls them.
In view of the new DOE threat guidance and recent upgraded DOE security measures, the NRC believes it necessary to revisit the subject of comparability at this time to assure continued consistency in the level of protection.
The Commission believes that this can best be accomplished through a joint DOE /NRC l
effort, similar to that conducted in 1977, to identify DOE facilities that possess strategic special nuclear material and that are comparable to NRC licensed facilities possessing such material.
Once representative facilities have been identified, NRC will need the assistance of DOE in characterizing i
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Your early~ response to this proposed joint effort would be very much appreciated.
Sincerely, fm~2eaiiadino A
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The Honorable William V. Roth, Jr.
Chairman, Committee on Governmental Affairs United States Senate Washington, D.C.
20510
Dear Mr. Chairman:
In accordance with the statutory obligation to respond to recommendations by the General Accounting Office (GA0) within 60 days of publication, we hereby submit our responses to the recommendations made by the GA0 in their report entitled
" Implementing the Small Business Innovation Development Act --
The First 2 Years."
The Commission agrees with the three GA0 recommendations and shall initiate the action necessary to comply with those recommendations.
Specific comments on the GA0 recommendations are presented in the enclosure.
Sincerely,
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Thomas M. Roberts 5
Acting Chairman 4
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Enclosure:
i Responses to GA0 recommendat},ons cc:
Sen. Thomas F. Eagleton l
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December 24, 1985 CHAIRMAN The Honorable Alan Simpson, Chairman Subcommittee on Nuclear Regulation Committee on Environment and Public Works United States Senate Washington, D.C.
20510
Dear Mr. Chai rman,
In accordance with the statutory obligation to respond to recommendations by the General Accounting Office (GAO) within 60 days of publication, we hereby submit our responses to the recommendations made by the GA0 in their report entitled
" Implementing the Small Business Innovation Development Act --
The First 2 Years."
The Commission agrees with the three GA0 recommendations and shall initiate the action necessary to comply with those recommendations.
Specific comments on the GA0 recommendations are presented in the enclosure.
Sincerely, b
Thomas M. Roberts Acting Chairman
Enclosure:
Responses to GA0 Recommendations l
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Sen. Gary Hart 1
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December 24, 1985 CHAIRMAN The Honorable Jack Brooks, Chairman Committee on Government Operations United States House of Representatives Washington, D.C.
20515
Dear Mr. Chairman,
In accordance with the statutory obligation to respond to recommendations by the General Accounting Office (GAO) within 60 days of publication, we hereby submit our responses to the recommendations made by the GA0 in their report entitled
" Implementing the Small Business Innovation Development Act --
The First 2 Years."
The Commission agrees with the three GA0 recommendations and shall initiate the action necessary to comply with those recommendations.
Specific comments on the GA0 recommendations are presented in the enclosure.
Sincerely, Thomas M. Roberts Acting Chairman
Enclosure:
Responses to GA0 Recommendations cc:
Rep. Frank Horton l
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pl December 24, 1985 CHAIRMAN The Honorable Morris K. Udall, Chairman Subcommittee on Energy and the Environment Committee on Interior and Insular Affairs United States House of Representatives Washington, D.C.
20515
Dear Mr. Chairman:
In accordance with the statutory obligation to respond to recommendations by the General Accounting Office (GA0) within 60 days of publication, we hereby submit our responses to the recommendations made by the GA0 in their report entitled
" Implementing the Small Business Innovation Development Act --
The First 2 Years."
The Commission agrees with the three GA0 recommendations and shall initiate the action necessary to comply with those recommendations.
Specific comments on the GA0 recommendations are presented in the enclosure.
Sin rely I
i Thomas M. Roberts Acting Chairman
Enclosure:
Responses to GA0 Recommendations cc:
Rep. Manual Lujan
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December 24, 1985 CHAIRMAN The Honorable Edward J. Markey, Chairman Subcommittee on Energy Conservation and Power Committee on Energy and Commerce United States House of Representatives Washington, D.C.
20515
Dear Mr. Chairman:
In accordance with the statutory obligation to respond to recommendations by the General Accounting Office (GAO) within 60 days of publication, we hereby submit our responses to the recommendations made by the GA0 in their report entitled
" Implementing the Small Business Innovation Development Act --
The First 2 Years."
The Commission agrees with the threc GA0 recommendatio'ns and shall initiate the action necessary to comply with those recommendations.
Specific comments on the GA0 recommendations are presented in the enclosure.
Sincerely,
{f py) mas M. Roberts Acting Chairman
Enclosure:
Responses to GAO Recommendations cc:
Rep. Carlos Moorhead
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December 24, 1985 CHAIRMAN The Honorable Charles A. Bowsher Comptroller General of the United States General Accounting Office Washington, D.C.
20548
Dear Mr. Bowsher:
In accordance with the statutory obligation to respond to recommendations by the General Accounting Office (GAO) within 60 days of publication, we hereby submit our responses to the recommendations made by the GA0 in their report entitled
" Implementing the Small Business Innovation Development Act --
The First 2 Years."
The Commission agrees with the three GA0 recommendations and shall initiate the action necessary to comply with those recommendations.
Specific comments on the GAO recommendations are presented in the enclosure.
Sinc rely,
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Thomas M. Roberts Acting Chairman
Enclosure:
Responses to GA0 Recommendations 1
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December 24, 1985
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20503
Dear Mr. Miller:
In accordance with the statutory obligation to respond to recommendations by the General Accounting Office (GAO) within 60 days of publication, we hereby submit our responses to the recommendations made by the GA0 in their report entitled
" Implementing the Small Business Innovation Development Act --
The First 2 Years."
The Commission agrees with the three GA0 recommendations and shall initiate the action necessary to comply with those recommendations.
Specific comments on the GA0 recommendations are presented'in the enclosure.
Sincerely, I
omas M. Roberts Acting Chairman
Enclosure:
Responses to GA0 Recommendations
w We Enclosure Response to Recomendations Chapter 2 The GA0 recommends that the annual report to SBA contain actual fiscal year extramural research and development obligations, not estimates.
NRC Response The reports to SBA for FY 1983 and FY 1984 rounded the extramural budget figure for those years to the nearest one thousand dollars giving the appearance that estimates were used. The FY 1985 report which is due to SBA by March 15, IS86, will be computed based upon total actual dollars.
Chapter 3 1.
The GA0 recommends (page 44) that the reports for FY 1983 and FY 1984
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be reassessed and revised as necessary, and ensure consistency in future reports.
NRC Response:
The NRC will use actual obligations in the FY 1985 report to SBA and shall ensure that subsequent reports are computed in the same manner.
The FY 1983 and FY 1984 reports will be revised and resubmitted to SBA along with the FY 1985 report.
2.
This recomendation (page 45) requires the non-SBIR goals to be established carly in the fiscal year and make such goals known to officials responsible for awarding external R&D funds.
NRC Response: On October 18, 1985, the NRC Office of Small and Disadvantaged Business Utilization and Civil Rights submitted the NRC-wide small business goals for FY 1986 to the SBA.
The goal is developed in conjunction with the NRC Division of Contracts which is responsible for awarding the external R&D funds.
Included within that agency-wide goal is the NRC non-SBIR goal.
Prior to submission of the next SBIR report to SBA, however, the NRC will identify that portion of the agency-wide small business goal which constitutes the non-SBIR goal.
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O COMPTROLLER GENERAL oF THE UNITED STATES WASHINGTON D.C.
20548 B-209790 October 25, 1985 Dr. Nunzio J. Pallidino Chairman, Nuclear Regulatory Commission
Dear Dr. Pallidino:
Public Law 97-219, the Small Business Innovation Development Act of 1982, requires GAO to report to the Congress on agencies' efforts to implement the act and on the nature of research conducted under the act.
The enclosed report, our first responding to the legislative mandate, assesses fundamental implementation efforts during the act's first 2 years.
The report contains recommendations to you on pages 30 and 44 As you know, 31 U.S.C. 720 requires the head of a federal agency to submit a written statement on actions taken on our recommendations to the Senate Committee on Governmental Affairs and the House Committee on Government Operations not later than 60 days after the date of the report and to the House and Senate Committees on Appropriations with the agency's first request for appropriations made more than 60 days after the date of the report.
Sincerely yours, Charles A. Bowsher Comptroller General of the United States Enclosure Revd M W amen.H. JN-E S -
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December P.7, 1985 OFFK:E OF THE CHAIRMAN The President The White House Washington, DC 20500
Dear Mr. President:
i An evaluation of the system of internal accounting and administrative control of the U. S. Nuclear Regulatory Commission in effect during the year ended 1
December 31, 1985 was performed in accordance with Guidelines for the Evaluation and Improvement of and Reporting on Internal Control Systems in the Federal Government, issued by the Director of the Office of Management and Budget, in consultation with the Comptreller General, as required by t!.e Federal Managers' Financial Integrity Act of 1982. The evaluation includeo an analysis of whether the system of internal accounting and administrative control of the Nuclear Regulatory Commission was in compliance with'the stan-dards prescribed by the Comptroller General. Attachment A provides additional information on how the evaluation process was conducted.
The objectives of the system of internal accounting and administrative control i
of the Nuclear Regulatory Conunission are to provide reasonable assurance that:
j Obligations and costs are in compliance with applicable law; j
Funds property, and other assets are safeguarded against waste, j
i loss, unauthorized use, or misappropriation; and
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Revenues and expenditures applicable to agency operations are properly recorded and accounted for to pennit the preparation of accounts and reliable financial and statistical reports and to I
maintain accountability over the assets.
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The concept of reasonable assurance recognizes that the cost of internal j
control should not exceed the benefits expected to be derived therefrom, and i
that the benefits consist of reductions in the risks of failing to. achieve the i
stated objectives. Estimates and judgments are required to assess the i
expected benefits and related costs of control procedures. Furthermore, t
errors or irregularities may occur and not be detected because of inherent limitations in any system of internal accounting and administrative control,
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including those limitations resulting from resource constraints, Congressional t
l restrictions, and other factors. Finally, projection of any evaluation of the i
system to future periods is subject to the risk that procedures may be inade-quate because of changes in conditions or that the degree of compliance with the procedures may deteriorate.
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The President The results of the evaluation described in the first paragraph, assurances given by appropriate Nuclear Regulatory Comission officials, plans for correcting weaknesses found, and other information provided indicate that the system of internal accounting and administrative control of the Nuclear Regulatory Comission in effect during the year ended December 31, 1985, complies with the requirement to provide reasonable assurance that the above-mentioned objectives were achieved within the limits described in the preceding paragraph.
Attachment B provides the statement regarding confomity of specific Nuclear Regulatory Comission accounting systems as required by Section 4 of the Act.
Respectfully,
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I Nunzio J. Palladino f Chairman Attachments:
As stated cc w/ attachments:
The Honorable James C. Miller, III Director, Office of Management and Budget I
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OF FICE OF THE CHAIRMAN The Honorable George H. W. Bush President of the Senate Washington, D. C. 20510
Dear Mr. President:
An evaluation of the system of internal accounting and administrative control of the U. S. Nuclear Regulatory Commission in effect during the year ended December 31, 1985 was performed in accordance with Guidelines for the Evaluation and Improvement of and Reporting on Internal Control Systems in the Federal Government, issued by the Director of the Office of Management and Budget, in consultation with the Comptroller General, as required by the Federal Managers' Financial Integrity Act of 1982. The evaluation included an analysis of whether the system of internal accounting and administrative control of the Nucles: Regulatory Commission was in compliance with the stan-dards prescribed by the Comptroller General. Attachment A provides additional information on how the evaluation process was conducted.
The objectives of the system of internal accounting and administrative control of the Nuclear Regulatory Commission are to provide reasonable assurance that:
Obligations and costs are in compliance with applicable law; Funds property, and other assets are safeguarded against waste, loss, unauthorized use, or misappropriation; and Revenues and expenditures applicable to agency operations are properly recorded and accounted for to permit the preparation of accounts and reliable financial and statistical reports and to maintain accountability over the assets.
The concept of reasonable assurance recognizes that the cost of internal control should not exceed the benefits expected to be derived therefrom, and that the benefits consist of reductions in the risks of failing to achieve the stated objectives. Estimates and judgments are required to assess the expected benefits and related costs of control procedures.. Furthermore, errors or irregularities may occur and not be detected because of inherent limitations in any, system of internal accounting and administrative control, including those limitations resulting from resource constraints, Congressional restrictions, and other factors.
Finally, projection of any evaluation of the system to future periods is subject to the risk that procedures may be inade-quate because of changes in conditions or that the degree of compliance with the procedures may deteriorate.
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The Honorable George H. W. Bush The results of the evaluation described in the first paragraph, assurances given by appropriate Nuclear Regulatory Commission officials, plans for correcting weaknesses found, and other information provided indicate that the system of internal accounting and administrative control of the Nuclear Regulatory Commission in effect during the year ended December 31, 1985, complies with the requirement to provide reasonabic assurance that the above-mentioned objectives were achieved within the limits described in the preceding paragraph.
Attachment B provides the statement regarding conformity of specific Nuclear Regulatory Commission accounting systems as required by Section 4 of the Act.
Respectfully, m
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.sc-Nunzio J. Palladino Chairman Attachments:
As stated cc w/ attachments:
The Honorable James C. Miller, III Director, Office of Management and Budget l
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UNITED STATES
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OFFEE OF THE December 27, 1985 CHAIRMAN The Honorable Thomas P. O'Neill, Jr.
Speaker of the United States House of Representatives Washington, D.C. 20515
Dear Mr. Speaker:
An evaluation of the system of internal accounting and administrative control of the U. S. Nuclear Regulatory Commission in effect during the year ended December 31, 1985 was performed in accordance with Guidelines for the Evaluation and Improvement of and Reporting on Internal Control Systems in the Federal Government, issued by the Director of the Office of Management and Budget, in consultation with the Comptroller General, as required by the Federal Managers' Financial Integrity Act of 1982. The evaluation included an analysis of whether the system of internal accounting and administrative control of the Nuclear Regulatory Commission was in compliance with the stan-dards prescribed by the Comptroller General. Attachment A provides additional information on how the evaluation process was conducted.
The objectives of the system of internal accounting and administrative control of the Nuclear Regulatory Commission are to provide reasonable assurance that:
- Obligations and costs are in compliance with applicable law; Funds property, and other assets are safeguarded against waste, j
loss, unauthorized use, or misappropriation; and
- Revenues and expenditures applicable to agency operations are properly recorded and accounted for to permit the preparation of accounts and reliable financial and statistical reports and to maintain accountability over the assets.
The concept of reasonable assurance recognizes that the cost of internal control should not exceed the benefits expected to be derived therefrom, and that the benefits consist of reductions in the risks of failing to achieve the stated objectives. Estimates and judgments are required to assess the i
expected benefits and related costs of control procedures. Furthermore, errors or irregularities may occur and not be detected because of inherent limitations in any system of internal accounting and administrative control, including those limitations resulting from resource constraints, Congressional restrictions, and other factors.
Finally, projection of any evaluation of the system to future periods is subject to the risk that procedures may be inade-quate because of changes in conditions or that the degree of compliance with j
the procedures may deteriorate.
The Honorable Thomas P. O'Neill, Jr. The results of the evaluation described in the first paragraph, assurances given by appropriate Nuclear Regulatory Commission officials, plans for correcting weaknesses found, and other information provided indicate that the system of internal accounting and administrative control of the Nuclear Regulatory Commission in effect during the year ended December 31, 1985, complies with the requirement to provide reasonable assurance that the above-mentioned objectives were achieved within the limits described in the preceding paragraph.
Attachment B provides the statement regarding conformity of specific Nuclear Regulatory Commission accounting systems as required by Section 4 of the Act.
Respectfully, w
Nunzio J. Palladino Chairman Attachments:
As stated cc w/ attachments:
The Honorable James C. Miller, III Director, Office of Management and Budget i
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ATTACHMENT A 1985 INTERNAL CONTROL REVIEW PROCESS I DESCRIPTION OF THE CONDUCT OF THE INTERNAL CONTROL EVALUATION f
In accordance with the Office of Management and Budget (OMB) Circular A-123,
" Internal Control Systems," the U.S. Nuclear Regulatory Commission (NRC) created an Internal Control Committee (ICC) in early 1982. The primary purpose of the ICC is to provide overall guidance and appraisal of NRC's evaluation process of internal controls.
During 1985, a number of significant actions were taken under the auspices of the ICC to strengthen NRC's overall internal control posture, as follows:
A.
NRC Manual Chapter 0801, " Internal Controls," was issued June 11, 1985 to formalize compliance with the Federal Managers' Financial Integrity Act of 1982. Manual Chapter 0801 sets forth the policies and activities to be followed by NRC in establishing, maintaining, improving as necessary, and reviewing internal controls for NRC's programs and activities. The membership of the ICC was modified to include senior NRC line managers.
B.
The ICC and all NRC offices reviewed and revised the inventory of assessable units, utilizing mission and function charts to capture all possible types of work done by NRC. The resulting assessable units are as follows:
Administrative Timekeeping Travel Personnel Payroll Procurement of Goods and Services for Administrative and Program Support Administrative Support Services Imprest Funds Resource and Management Analyses Management Directives General Ledger Reporting Employee Financial Disclosures Public Affairs Programmatic Reactor Operating License Revieu Regulation of Operating Reactors Operator Licensing TMI-2 Cleanup and Recovery l
Unresolved Safety and Generic Issues Regulatory Requiremercs l
Nuclear Safety Research l
Fuel Cycle and Materials Safeguards Waste Management 1
a Inspection Emergency Preparedness Quality Assurance Enforcement Agreement State Indemnification Import / Export Licensing International Information Exchange Analysis and Evaluation of Operational Information License Fee Management Investigation (External and Internal)
Audit Training Automated Data Processing Management C.
NRC internal control coordinators were given a full day of formal j
training by the U.S. Department of Agriculture Graduate School in the areas of vulnerability assessment techniques and internal control reviews (ICRs).
D.
After reviewing the effectiveness of the vulnerability assessment questionnaires utilized in prior years, a complete revision was made this year. This effort provided for a more comprehensive evaluation of NRC programs and functions.
It is intended that each year following the completion of 'he vulnerability assessment questionnaires, a review will occur as to the merit of selected questions, the clarity of instructions, etc., in order to improve the product in each succeeding review.
E.
In compliance vith the requirement to perform a complete review of all assessable unitz within a two-year cycle, NRC conducted vulnerability assessments on the entire inventory of assessable units. These vulnerability assessments were conducted by the responsible organizations (including all NRC offices). As a result of these assessments, line i
management recommended, as appropriate, actions to correct identified shortcomings or internal control reviews.
F.
1985 Internal Control Reviews Duplicate Payments. Pursuant to OMB Memorandum 85-7, dated November 7, 1984, the NRC conducted a limited internal control review of NRC's payment system. The review was performed by the NRC Office of InspectorandAuditor(OIA). The review indicated that the internal I
centrols established as a part of NRC's payment function are sufficient to detect and prevent duplicate payments, that invoices are being processed in accordance with OM8 Circular A-125, and that the number of payments requiring interest penalties is a small fraction of the total number of payments made. Consequently, further actions to strengthen the existing controls do not appear to be needed.
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In addition to the OMB mandated ICR noted above, 0IA conducted ICRs in the following areas:
Selected Aspects of NRC's Payroll Operations.
Survey of the Office of the General Counsel.
Review of NRC Regionalization.
Review of NRC's Allegations Management System.
Review of The Staff's Im)lementation of the Interim Procedures for 1
Managing Plant-Specific lackfitting of Power Reactors, i
The above ICRs identified some internal control shortfalls, but no material weaknesses.
Automated Data Processing (ADP). The ICR planned for ADP has been deferred due to (1) the implementation of recommendations resulting from a study performed by the ADP Steering Group; (2) an OIA review of limited aspects of ADP management, procedures and documentation; (3) an upcoming ICR dealing with acquisition,' use and accountability of personal computers; and (4) the development of ar-Automated Infonnation Services Strategic Plan, designed to integrate ar.d coordinate NRC activities related to information resources management.
i It appears that most, if not all, of the concerns in the ADP area may be addressed in the conduct of the above-mentioned studies or issuance of the plans. When the results of the previously mentioned work have been completed and reviewed, the ICC will evaluate the need for 4
conducting an ICR at that time.
II. DESCRIPTION OF THE CONDUCT OF THE ACCOUNTING SYSTEMS REVIEW PROCESS In accordance with the provisions of Section 4 of the Federal Managers' Financial Integrity Act of 1982, reviews of the accounting systems were conducted. The objective of these reviews was to determine whether these systems conform to the principles and standards. developed by the Comptroller General of the United States (CG) under Section 112 of the Accounting and Auditing Act of 1950 and implemented through OMB Circular A-127 " Financial Management Systems." NRC Bulletin 1103-19, " Financial Management System,"
prescribes the NRC policies and procedures for implementation of OMB Circular A-127. This Bulletin establishes an inventory of NRC accounting systems, identifies the system manager for each accounting system, and recuires the identified system manager to perform an annual evaluation of the system. The review process for each of the systems is described below.
I Payroll System The purpose of the payroll system is to collect, control, manage and maintain pay and leave data on NRC employees and consultants.
The system was approved by the CG on September 28, 1982.
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The Office of Inspector and Auditor performed an audit of NRC's payroll 4
operations in 1985. This audit included an evaluation of the payroll system's confomance with the principles and standards developed by the CG, as well as appropriate testing of the payroll system operations. Accordingly, the scope of the audit was sufficient to constitute a detailed evaluation, as defined in the Guidelines for Evaluating Financial Management / Accounting Systems i
(Guidelines) issued by OMB. OIA expressed concern that certain payroll procedures manuals were not current and that the control desk function needed to be strengthened.
NRC's Office of Resource Management (RM) has strengthened the control desk function, and has taken action to revise the manuals no later than the end of FY 1988.
During 1985, a limited review of the payroll system was performed in accordance with the OMB Guidelines. Further, all payroll.ADP work orders, either completed or outstanding at the end of 1985, were reviewed.. Proposed or completed corrective actions were reviewed to detemine the extent to which 4
they represent efforts to bring the payroll system into conformance with CG 4
requirements as implemented through OMB Circular A-127.
The reviews did not reveal any significant instances of nonconformance with the CG requirements.
The system manager for the payroll system has provided reasonable assurance that the payroll system is in general conformance with the OMB financial management and accounting objectives.
Administrative Accounting System The purpose of the administrative accounting system is to accumulate, maintain and report all accounting and budget execution information other than pay and leave data maintained in the payroll system.
Six component systems have been identified,as making up the administrative accounting system:
travel authorization and voucher system; travel advance system; plant and equipment subsidiary ledger system; funds control system; general ledger; and a system for preparation and issuance of bills.
This administrative accounting system has not been approved by the CG, as all of these component systems have been or will be merged by FY 1987 into a new system which is being reviewed by the i
CG.
)
During 1985, a limited review of the last component system was performed, as the OMB Guidelines do not require a review of component systems scheduled to be combined into other systems within the next two fiscal years. Various reports and procedures, including OIA audit reports, were reviewed. The system manager for this last component system has provided reasonable assurance that the system is in general conformance with the OMB financial management and accounting objectives.
System for Billing Licensees for Recoverable Costs The system for billing licensees for recoverable costs has as its purpose to recover fees for nuclear facilities and materials licenses and other regulatory services. Some component systems capture NRC manpower data while other component systems capture technical-assistance contractor costs. One manual system determines appropriate hourly billing rates, applies the billing 4
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rates to NRC manpower data, aggregates technical assistance contractor costs and NRC manpower costs, and generates information from which bills to licensees can be generated.
In 1985, the component systems were subject to vulnerability assessments performed in accordance with OMB Circular A-123. However, none of the component systems were subject to a detailed evaluation or a limited review, as defined in the OMB Guidelines. Considering the level of review performed in 1985, it is not possible to provide assurance that the system, or any of its components, generally conforms to the principles and standards developed by the CG and implemented through OMB Circular A-127. The necessary review will be accomplished in early 1986 as an element of an overall ICR (see Section III).
Property and Supply System The purpose of the property and supply system is to maintain records concerning property and supply transactions, warehouse inventory, stock reorder points, NRC item identification catalog, and abnomal maintenance incident rates.
During 1985, a limited review of the property and supply system was performed in accordance with the OMB Guidelines. The system was also subject to a vulnerability assessment in 1985 performed pursuant to OMB Circular A-123.
The system manager for this system has provided reasonable assurance that the system is in general confomance with the OMB financial management and accounting objectives.
III. PLANNED ACTIVITIES FOR 1986 During 1986, a number of activities are planned.
The inventory of assessable I
units for both programatic and administrative areas will again be reviewed to determine if any changes are warranted as a result of the 1985 process or by any organizational changes. The ICC will review any recommended or proposed corrective actions that were identified in the 1985 process, and will also review, as necessary, any ICRs performed. The ICC intends to provide training i
to offices and regions, as needed.
Two ICRs are currently planned for 1986: Personal Computers and License Fee Management. An agencywide ICR for personal computers will begin in January 1986, with the fundamental objective to ensure that basic, comon sense internal controls exist and are being followed with regard to the acquisition, use and accountability of NRC personal computers and their related hardware
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and software. The purpose of the License Fee Management ICR, scheduled to -
begin in December 1985, is to systematically and comprehensively review the current system of internal controls established for the process to bill licensees for recoverable costs, to ensure their adequacy and to propose any improvements if necessary.
During 1986, it is expected that both OIA and the General Accounting Office (GAO) will conduct a number of audits and reviews of NRC programs and operations. The results of these audits will be reviewed for any internal control implications.
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IV. STATUS OF PRIOR YEARS' RECOMMENDATIONS NRC's 1983 and 1984 yearend reports listed non-material weaknesses and planned corrective actions. The following sections summarize those actions completed in 1985 and.those still outstanding.-
A.
Completed Corrective Actions Travel A small number of NRC employees had terminated employment still owing the NRC money for travel advances. Some funds have been recovered and the Office of Resource Management is continuing to pursue collection of such balances.
Procedures have been revised so that the payroll office needs positive confirmation that a terminating employee does not owe money before final salary and lump-sum annual leave payments are made.
Timekeeping Weaknesses were identified in large Time and Attendance (T&A) units; failure to compare overtime on payroll reports with overtime actually approved; and recording of "anticipited" overtime before it was actually worked. The controls for the identified weaknesses were corrected as a result of OIA recommendations and actions taken by RM.
In addition, T&A certifying officials were not provided with information to show what the payroll office had processed, in order to compare it to what the officials had certified. The payroll office now provides the T&A certifying officials with biweekly reports that allow for positive confirmation of time and attendance data.
The entire timekeeping process was reviewed in 1985, with no resulting impact of issues such as Compressed Work Schedule.
Personnel / Payroll Interface i
The lack of a comprehensive and timely comparison of data in the payroll and personnel systems to assure validation of the payroll system input t
from the personnel s NRC's Office of Administration (ADM)ystem was identified as a weakness.
and Office of Resource Management have worked l
together to implement revisions in procedures to ensure that manually produced or corrected personnel changes are correctly entered into the system, and that any identified programming changes needed have been made. A comparison of personnel and payroll data is now being performed on a biweekly basis.
Administrative Services (Document Management and Control)
The general area of document distribution proliferation within the NRC staff was addressed as a weakness. Two areas of concern-that had corrective actions taken were discontinuing distribution of documents to i
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4 Service Lists; and restricting office-level document reproductions.
These have been resolved by (1) cross-checking and reducing the duplicate distribution of documents and (2) issuance of instructions to all employees.
Analysis and Evaluation of Operational Data A revision to Manual Chapter 0515 (to clearly delineate the functional responsibilities of the Office for Analysis and Evaluation of Operational Data and the program offices so as to avoid unnecessary duplication of effort) had not yet been completed. The revised Manual Chapter was issued June 12, 1985.
Safeguards NRC's reactor safeguards program lacked a formal charter to define and document _the role of the Safety Interface Group and to provide guidance to the staff as to how safety / safeguards reviews were to be performed.
On February 5,1985, an agreement was signed by the office directors for NRC's Office of Nuclear Reactor Regulation and Office of Nuclear Material Safety and Safeguards on " Safeguards Interface and Division 4
Responsibilities."
Automated Data Processing In accordance with OMB Bulletin A-71, all NRC computer / application facilities will have completed vulnerability assessments and computer security reports. Any inadequacies in the physical protection areas will l
be addressed. The procedures for performance of the assessments are in place, and any new facilities coming on-line will be scheduled for assessments as resources permit.
Doerating License Review Process for Power Reactors A 1984 OIA report identified as a problem the responsibility for tracking, controlling and closing open issues in Safety Evaluation Reports. The staff continues to review its criteria to ensure that open safety issues and the number of allegations are consistently enumerated in a meaningful and standardized manner.
B.
Outstanding Corrective Actions To Be Taken Travel The large number of outstanding travel advance balances was identified as a weakness, with efforts to reduce such outstanding balances further exacerbated by the backlog of travel vouchers. The voucher backlog has been greatly reduced with the average processing time being cut in half.
With the reduced backlog in vouchers, greater attentien is being paid to reducing outstanding travel advance balances. Revisic s in administrative procedures to offset delinquent travel advance balances against current 7
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3 salary are being promulgated. The implementation of the travel module of a new automated accounting system for FY 1986 and future travel should n
provide a more effective tool for monitoring travel advance activity.
Property, Plant and Equipment 1
Concern was expres" sed over the proper identification of NRC purchased equipment in the' custody of Department of Energy. (DOE) laboratories.
Revisions are being made to Manual Chapter 1400 series to ensure that-information regarding NRC purchased property at DOE labs is reported for inccrporation into the Property and Supply System, as an informationi service.
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i Administrative Services (Document Management'and Control) t The general area of' document distribution proliferation within the NRC
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staff was addressed as a weakness. Two areas of concern were in limiting the distribution'of manual chapter: and rules and regulations, and in restricting internal cffice distribution and internal branch level 3
i circulation. These areas have been addressed in a management directive on document distribution, which is awaiting publication.
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j Debt Collection n
Deposits of civil penalty payments are delayed by having licensees send I
payments through NRC's Office of Inspection and Enforcement (IE),
Enforcement Staff rather than directly-to the Office of Resource f
Management. Di3cussions have been held with the Department of Treasury regarding the use of Treasury's Lockbox Network and steps have been taken
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by NRC to accelerate, deposits of receipts.
Implementation of the i
remaining recondendations with regard to det,t collection will be
-l completed in FY 1966.
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Resolution of Generic Safety Issues d
Weaknesses were identified in a 1964tGA0 report on NRC efforts to address l
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safety issues' common to nuclear power plants, specifically in the j
management of the resolution and implementation of identified'generie safety issues. The requirements definition phase for the denlopment of I
a Generic Issues Management System (GIMS) is' complete. System development is underway, wfth expected completion in 1986.
f V.PLANSANDSCHEDULESFORCORRECTING'NON-MATERIALWEAKNESSESIDENTIFIEDINI985 l
i No material weaknesses were identified in 1985. ifowever, the vulnerability I
assessment process, internal control reviews, 0IA audits and GAO audits l
recommended that a number of corrective actions be taken to strengthen overall internal controls. A majority of these. recommendations were, in fact, implemented during 1925.
The remainder are being tracked for scheduled implewentation.. The non-material weaknesses are divided into two categories:
l weaknesses (non-material) where corrective actions have been taken and t
weaknesses (non-material). requiring corrective actions.
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WEAKNESSES (NON-MATERIAL) IDENTIFIED IN 1985 WHERE CORRECTIVE ACTIONS HAVE BEEN TAKEN Weakness:
A number of responses in the Office of Inspection and Enforcement's vulnerability assessments indicated a need for improvement in written procedures in several administrative areas.
Corrective Action Taken:
IE has implemented a number of changes in the procedural aspects of selected administrative areas. A majority of the actions identified by IE have been taken, i.e., procedures issued August 9, 1985 for closing out DOE projects and accounting for equipment purchased; delineation of responsibilities associated with maintenance of DOE Project Files, issued July 17, 1985. Other actions currently planned will be implemented within the fiscal year.
Weakness:
In an April 24, 1985 GA0 report entitled "Better Inspection Management.
Would Improve Oversight of Operating Nuclear Plants," procedures in two areas were recommended to be improved. They-were:
1(1) to revise Manual Chapter 2515 to upgrade inspection policy for inspection planning based on SALP results, and (2) to incorporate into the IE Manual, policy on makeup and use of site specific inspection plans and direction for use of SALP results.
Corrective Action Taken:
(1) Manual Chapter 2515 was. revised November 5, 1985, and was transmitted from the Director, Division of Inspection Programs, IE to all Regional Administrators.
(2) The suggested changes were incorporated in the revised Manual Chapter 2515, issued November 5, 1985..
Weakness:
As a result of sacrificing appropriate internal controls for the sake of administrative convenience, a regional office was made vulnerable in the area of timekeeping.
Corrective Action Taken:
The Time and Attendance (T&A) clerk was relieved; additional T&A units were established to assure none exceeds 24 employees; T&A certifying i
officials now must sign facsimile reports, in addition to T&A cards; and i
new precedures have been implemented whereby management officials check hours paid against hours previously claimed and approved.
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Weakness:
In the area of Justification of Source Selection / Contract Monitoring within NRC's Office of Research (RES) NRC Form 367 was not being maintained, and the Official Project Files were not being maintained as required in NRC Bulletin 1401-3..
Corrective Action Taken:
A June 1985 memo was sent to RES Divisions alerting them of the responsibility of each project manager in maintaining an Official Project File in accordance with NRC Bulletin 1401-3.
4 Weakness:
An action plan needed to be developed in the area of Nuclear Safety.
Research/ International Information Exchange to correct deficiencies found in the safeguarding of proprietary documents.
Corrective Action Taken:
The affected RES Divisions have been advised of the minimum requirements for handling sensitive information. The Division of Security, ADM has conducted a. facilities inspection of the building. A request has been i
made to upgrade the physical storage capabilities of the building.
In 1
this regard, desk keys and file cabinet keys have been provided, with additional locks and cabinets to be delivered shortly.
i Weakness-An April 30, 1985 OIA review (" Review of NRC Regionalization")
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recommended the establishment of operator examiner training on a regular basis.
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Corrective Action Taken:
A six-course curriculum for NRC staff examiners and consultants is I
currently scheduled.- The first course was offered the first week of l
l December, with the remaining scheduled throughout the fiscal year.
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'eakness:
I Selected telecommunications activity was identified as a problem in that large numbers of employees have legitimate need for long distance lines i
and the quality and availability of FTS lines are extremely poor and 4
. inadequate. This results in the use of costly commercial lines.
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l Corrective Action Taken:
E Measures have been taken to ensure closer. control of telephone usage by I
revising telephone and tracking procedures and.by initiating the purchase of a devicesto track telephone calls to the extension from which they l
were made.
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Weakness:
Improved procedures and better management practices were needed to tighten controls dealing with property accounting in a selected region.
Corrective Action Taken:
An inventory of regional property was conducted in November 1985, with a favorable oral closeout report indicating that increased management controls and attention to property management activities were in evidence. There is also a project underway to implement an automated perpetual inventory system for the supply function.
B.
WEAKNESSES (NON-MATERIAL) IDENTIFIED IN 1985 REQUIRING CORRECTIVE ACTIONS Weakness:
A May 9, 1985 OIA report (" Review of NRC's Inventory Management")
recommended that the Director, Office of Resource Management periodically test the internal controls of the Property and Supply System (PASS) in conjunction with personnel from the Division of Security, ADN.
Status of Corrective Action:
The PASS Contingency Plan document is essentially complete. The Division of Security staff who work directly with PASS tested the system on November 21, 1985 and the results/ findings will be incorporated in the document. When this occurs, the final document will be forwarded to the Division of Security, ADM for final review and approval.
Weakness:
A July 5, 1985 OIA report (" Audit of Selected Aspects of NRC's Payroll Operations") indicated a need to strengthen written payroll procedures.
Status of Corrective Action:
The updating and revision of the Automated Payroll System Users Manual i
and the creation of a desk procedures manual will be undertaken in FY 1986 and should be completed within two years or less, depending on staff availability.
Weakness:
A May 31, 1985 OIA report (" Review of Allegations Management System")
i recommended incorporating appropriate guidance on the examination of licensee allegations management programs into inspection procedures.
Status of Corrective Action:
A Commission paper on formalizing NRC inspection of utility allegation programs is being reviewed, and the staff is awaiting Commission guidance prior to incorporation into inspection procedures.
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Weakness:
An April 24, 1985 GA0 report ("Better Inspection Management Would Improve Oversight of Operating Nuclear Plants") recommended (1) development of procedures on utility corrective action systems and (2) development of policy and procedures for using inspection data in planning and monitoring inspections.
Status of Corrective Action:
(1) Draft procedures are under management review.
(2) The first of r
periodic reports on inspection data was issued to Regional Administrators in late October.
Weakness:
l A June 21, 1985 OIA report (" Review of the Staff's Implementation of the i
Interim Procedures for Managing Plant-Specific Backfitting of Power Reactors") identified the need for revision of Manual Chapter 0514 regarding guidance of implementaticn of 10 CFR 50.109 of the Backfit Rule.
-1 Status of Corrective Action:
Manual Chapter 0514 has been revised, coordinated with headquarters and regional staff and has been forwarded for final approval and publication.
Weakness:
An April 26, 1985 OIA followup report (" Review of NRR's Use of Technical Assistance") recommended that a process be implemented to transfer I
completed project data to a historical file.
Status of Corrective Action:
An automated program (under development) will establish fiscal year specific files that will contain projects closed out in that year and the yearend status of all other projects.
It is planned that the historical files will be implemented by the end of February 1986.
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ATTACHMENT B 1
CONFORMITY OF NRC ACCOUNTING SYSTEMS TO THE PRINCIPLES AND STANDARDS.
PRESCRIBED BY THE COMPTROLLER GENERAL i
Pursuant to Section 4 of the Federal Managers' Financial Integrity Act of 1982, the accounting systems of the U.S. Nuclear Regulatory Commission (NRC),
in use during the fiscal year ending September 30, 1985, have been reviewed.
7 NRC accounting systems are identified in the financial systems inventory developed pursuant to OMB Circular A-127, " Financial Management Systems," and are grouped as follows: payroll system, administrative accounting system, i
system for billing licensees for recoverable costs, and property accounting l
system.
The results of the reviews described below, approvals already provided by the General Accounting Office for one of NRC's accounting systems, assurances' given by agency officials, and other information provided indicate that NRC's S
accounting systems, taken as a whole, generally conform to the principles and standards, develcped by the Comptroller General (CG) and implemented through OM8 Circular A-127, except as follows: -the level of review of the system for billing licensees for recoverable costs was not sufficient to provide reasonable assurance that it generally conforms to the CG principles and standards. A detailed evaluation in this area is scheduled to begin in l
December 1985.
Payroll System During the past year the payroll system was subject to an audit performed by the NRC Office of Inspector and Auditor, a vulnerability assessment performed i
pursuant to OMB Circular A-123, and a limited review made in accordance with the Guidelines for Evaluating Financial Management / Accounting Systems (Guidelines) issued by OMB.
The scope of the audit was sufficient to constitute a detailed evaluation, as the term is defined in the OMB 4
I Guidelines. The payroll system was approved by the Comptroller General on September 28, 1982.
Administrative Accounting System The administrative accounting system consisted of six component systems in FY 1985:
travel authorization and voucher system; travel ~ advance system; plant and ' equipment subsidiary ledger; funds control system; general ledger; and a system for preparation and issuance of bills.
l NRC has recognized that there are areas of nonconformance in the administrative accounting system, but none of these are material. NRC has recently initiated implementation of an integrated administrative accounting system to replace the first five components of the prior system. The prior j
system has been cumbersome and labor intensive. The Comptroller General has O
reviewed the documentation for the new system and has found no issues which would prevent approval.of the system.
For FY 1986 activity, the first three component systems have been discontinued entirely while the fourth and fifth component systems have been partially discontinued. The first five component systems'should be discontinued in their entirety within the next two fiscal years.
4 Pursuant to OMB Circular A-123, vulnerability assessments were performed during fiscal year 1985 for all component systems. Additionally, in accordance with the OMB Guidelines, a limited review of the last component system was performed, while reviews of the other component systems were not scheduled as they will be combined into other systems within the next two fiscal years.
System for Billing Licensees for Recoverable Costs During the past year, the component systems of the system for billing licenses for recoverable costs have been subject to vulnerability assessments performed in accordance with OMB Circular A-123.
An internal control review as prescribed by OMB Circular A-123 has been i
scheduled for the system in FY 1986.
The internal control review will encompass a detailed evaluation of the system as prescribed in the OM8 Guidelines.
Property and Supply System 1
The property and supply system was subject to a vulnerability assessment performed pursuant to 0MB Circular A-123 and a limited review made in accordance with the OM8 Guidelines.
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UNITED STATES i
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January 3,1986
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CHAIRMAN The Honorable Edward J. Markey, Chairman Subcomittee on Energy Conservation & Power Comittee on Energy and Comerce (Jnited States House of Representatives Washington, D.C.
20515
Dear Mr. Chainnan:
In your letter of January 2,1986, you state that you believe that the General Counsel's December 6, 1985, memorandum on the " Sunshine Act Rule" should be released to the public, and you ask us to advise you whether the Comission has any objection to its release.
As you know, the paper is scheduled for discussion in a public meeting on January 17, 1986. As a general matter, when a paper is discussed by the Comission in public session, copies of the document are provided for the public at that session. We intend to follow that course in this instance.
Thus the issue is not whether the document will be made public -- that is assured -- but whether it will be made public two weeks sooner than was planned.
The document in question is a predecisional advice memorandum from the General Counsel to the Comission.
It was provided to you at your request, for the furtherance of your oversight responsibilities, with the understanding that its confidentiality would be maintained. We see no reason to depart in this case from the general rule that the confidentiality of predecisional documents scheduled for public discussion should be maintained until the day of the public meeting.
Comissioner Asselstine would have no objection to release of SECY 85-67(A) at this time.
Sincerely sW l,
[h b Nunzio J. Pa ladino cc: Rep. Carlos Moorhead t
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January 3, 1986 CHAIMSAA00 The Honorable Edward J. Markey, Chairman Subcomittee on Energy Conservation & Power Comittee on Energy and Comerce United States House of Representatives Washington, D.C.
20515
Dear Mr. Chairman:
In your letter of January 2,1986, you state that you believe that the General Ccunsel's December 6, 1985, memorandum on the " Sunshine Act Rule" should be released to the public, and you ask us to advise you whether the Comission has any objection to its release.
As you know, the paper is scheduled for discussion in a public meeting on January 17, 1986. As a general matter, when a paper is discussed by the Commission in public session, copies of the document are provided for the public at that session. We intend to follow that course in this instance.
Thus the issue is not whether the document will be made public -- that is assured -- but whether it will be made public two weeks sooner than was planned.
The document in question is a predecisional advice memorandum from the General Counsel to the Comission.
It was provided to you at your request, for the furtherance of your oversight responsibilities, with the understanding that its confidentiality would be maintained. We see no reason to depart in this case from the general rule that the confidentiality of predecisional documents scheduled for public discussion should be maintained until the day of the public meeting.
Comissioner Asselstine would have no objection to release of SECY 85-67(A) at this time.
Sincerely l g6$hll
%W Nunzio J. Pa ladino cc: Rep. Carlos Moorhead i
i
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January 3, 1986 l
3 i
The Honorable Edward J. Markey, Chairman Subcommittee on Energy Conservation & Power Committee on Energy and Commerce United States House of Representatives Washington, D.C.
20515
Dear Mr. Chairman:
In your letter of January 2,1986, you state that you believe that the General Counsel's December 6, 1985, memorandum on the " Sunshine Act Rule" should be released to the public, and you ask us to advise you whether the Commission has any objection to its release.
As you know, the paper is scheduled for discussion in a public meeting on January 17, 1986. As a general matter, when a paper is discussed by the Commission in public session, copies of the document are provided for the public at that session. We intend to follow that course in this instance.
Thus the issue is not whether the document will be made public -- that is assured -- but whether it will be made public two weeks sooner than was planned.
The document in question is a predecisional advice memorandum from the General Counsel to the Commission.
It was provided to you at your request, for the furtherance of your oversight responsibilities, with the understanding that its confidentiality would be maintained. We see no reason to depart in this case from the general rule that the confidentiality of predecisional documents scheduled for public discussion should be maintained until the day of the public meeting.
Commissioner Assels' tine would have no objection to release of SECY 85-67(A) at this time.
Sincerely original signed by Nunzio J. Palladino Nunzio J. Palladino CLEARED BY ALL COMMISSION OFFICES BY OCA i 0FC :
NAME':
DATE :
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i Jo.m o omeau.a.ousen opygg COMMITTEE ON ENERGY AND COMMERCE WASHINGTON, DC 20515 January 2, 1986 1
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The Honorable Nunzio J. Palladino
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Chairman l
U.S. Nuclear Regulatory Commission j
1717 E Street, N.W.
washington, D.C.
20555 i
Dear Mr. Chairman:
i I an disappointed by the General Counsel's December 6, 1985 i
" Sunshine Act Rule" memorandum and the Commission's response to
{
it.
I understand that three Commissioners have voted in favor and one Commissioner against the proposed final rule included in this i
memorandum.
You have reportedly stated that while you favor the i
proposal you would prefer to cast your vote at a Commisasion
)
meeting presently scheduled for January 17, 1985.
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The General Counsel's approach would maintain much of the i
fatally flawed proposal that the Commission first put forth on May i
21, 1985.
This rule, which was pushed through without prior i
public notice or comment, provided for secret " gatherings" of a
[
quorum of the Commission.
These non-Sunshine Act sessions would r
violate the spirit of the law which is that the public's business f
should be done in public.
This basic idea is as bad today as it was last Spring.
l Notwithstanding specific concerns expressed by the Subcommittee at its hearing last Spring, the proposed final rule i
fails to provide implementation procedures.
As the subcommittee warned, that deficiency makes the rule susceptible to i
unintentional misuse and intentional abuse.
Alternatives
+
l apparently rejected by the General Counsel and Commission include
[
having meetings only when all Commissioners are present; requiring l
i l
a representative of the General Counsel to be present to assure i
that the discussion stays within proper bounds; keeping a transcript; and deciding upon the topic for discussion in advance.
Instead the General Counsel recommended and the Commission has apparently agreed that procedures should be kept
"...to a minimum, t
1/3....To OCA to Prepare Response for Signature of Chairman and Cone Review..Date due: Jan 3....Cpys to: RF, Cmrs, EDO, SECY, OGC l
l 86-0010 l
- _ _ _. _ _ _j
l.
The Honorable Nunzio J. Palladino January 2, 1986 Page 2 1
in the interest of informality and collegiality" and that it would l
not be "...useful to adopt hard-and-fast rules for handling this problem."
The memorandum advised that no lawyer from Office of l
General Counsel need monitor the secret gatherings because:
"We i
do not believe that the Commissioners need chaperones."
Unfortunately, the Commission's handling of this matter and l
its overall expressed hostility to the Sunshine Act does not engender the public confidence necessary to have such an open ended rule; indeed, it has fostered an atmosphere of distrust.
i At botton, the final rule is unacceptable because there has yet to be any demonstration of valid need for it.
To be sure, j
despite the Commission's claim that doing business in public has resulted in a loss of collegiality, the Commission has been unable t
j to demonstrate that its old Sunshine Act regulations actually interfered with the NRC mandate of protecting public health and
{
safety.
While it is true that the agency has significant l
management problems, I find it hard to believe that secret meetings are really the answer to the agency's problems.
Part of doing the public's business is doing it in public.
The practices-of other Federal agencies, which the Commission cites as justification for its rule change, are not really. applicable since none of those other agencies have the same responsibiity of protecting public health and safety.
l Not surprisingly, the absense of a clearly defined need for j
the-rule change has led to a rule which is uncomfortably, and I
perhaps illegally, vague.
The Commission's inability to publicly i
describe exactly what " gatherings" it would hold under the new j
rule that it could not previously hold as either open or closed j
meetings under the old Sunshine Act regulations is the best evidence of this further problem.
j There is one change in the General Counsel's proposed final i
rule worth noting.
This version would no longer specifically i
l allow the Commission to hold " secret gatherings" on technical issues involving nuclear safety.
As you know, I was particularly critical of this provision in the initial rule at the Subcommittee's Nay 21, 1985 hearing.
While this change removes 1
one seriously objectionable part of the rule, the entire proposal remains seriously flawed because it will lead to exclusion of the j
public.
I wish to advise the Commission that if it proceeds to l
finalize this rule on January 17th, then I intend to take two actions.
First, I will continue to insist upon the reporting requirements established in the letter dated June 3, 1985 that was j
l l
l I
i l
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4 e
l Tha Honorcblo Nunzio J. Palladino January 2, 1986 1
Page 3 l
also signed by the Full Committee Chairman and the Ranking Minority Members of the Full Committee and this Subcommittee.
Second, I will seek to legislatively repeal the Commission's new rule through the passage of H.R. 2743.
Finally, I would like to advise you that I intend to publicly release the General Counsel's December 6, 1985 memorandum to the Commission (SECY-85-67A) because of the overriding public interest in learning in advance of the Commission's decision to further exclude the public from the regulatory process.
The public should i
be aware of the General Counsel's response to objections raised in the public comment process prior to any final Commission vote.
If you have a particularly compelling reason for why the public interest would be better served by maintaining the secrecy of this document, please personally contact me by 12:00 noon tomorrow, Friday, January 3, 1985.
There has been an outpouring of negative public response to the Commission's initial decision.
I urge you to reconsider your folly.
You have very little to gain and much to lose.
Sincerely, L
Edward J. Marke Chairman 1
1 I
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- ..*p January 6, 1986 CHAIRAAAN Mr. Charles H. Dean, Jr.
Chairman Tennessee Valley Authority 400 West Summit Hill Drive Knoxville, Tennessee 37902
Dear Mr. Chairman:
This letter is in response to your January 3,1986 request for a postponement of the u'pcoming Nuclear Regulatory Commission meeting now scheduled for January 9, 1986 with the TVA Board.
As I indicated to you by telephone on the afternoon of January 3, the meeting should go ahead as scheduled on January 9.
I also indicated that you should focus on: (1) a review of the history, from your vantage point, leading up to the current situation at TVA's nuclear facilities; and (2) an identification of the major issues, as you currently see them, in an effort to develop a common enderstanding by both of our agencies on what the problems are.
I suggested that you could add any status remarks as you see fit.
If another meeting between us is needed later in January or at some future time, we can arrange for it at a later date.
I l'ook forward to seeing you on January 9.
Sincerely,
')
il dd' <6,~r p.e.,.
i Nunzio J. Palladino
9
(
t TENNESSEE VALLEY Aumomry t
KNOXVILLE. TENNESSEE 379o2 i
400 West Sunuait Hill Drive i.
January 3, 1986 Thellonorable Nunzio J. Palladino Chatman U.S. Nuclear Regulatory Conunission Wash Lagton, D.C.
02555
Dear Mr. Chairman:
EVA Board of Directors announced today that effective January 13. 1986 The hen A. White, retired Admiral, will assume the post of Manager. Power and Step Engi neering (Nuclear), replacing H. G. Parris. Nr. White will be a contract employee to TVA from Stone and Webster for two years.
l Thorpfore, we are requesting postponement of the upcoming NRC Conseission We request this postponement for meeging now scheduled for January 9,1986.
at least 30 days beyond Mr. White's reporting date to TVA (January 13, 1986).
This time period will give Mr. White enough time to become. familiar with and be able to report on the TVA nuclear program.
Sincerely.
l C. H. Dean, Jr Chairman qubaceib aqd sworn go before paeP.tiss AA day of (
1986.
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7 2-The Honorable Nun'zio J. Palladino January 3,1986 ec:
Mr. James Taylor. Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 J
p.S. Nuclear Regulatory Commission
' Region II IAttention: Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 atlanta. Georgia 30323 g
lNr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 i
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WASHINGTON, 0.C. 20555 s.~. j OFFICE OF THE December 27, 1985 CHAIRMAN The Honorable George H. W. Bush President of the United States Senate Washington, DC 20510
Dear Mr. President:
In accordance with Title II of the Energy Reorganization Act of 1974, as amended, the Nuclear Regulatory Comission submits its quarterly report on full-time permanent employees hired and promoted for the FY-1985 quarter ending September 30, 1985. Also provided is a sumary of these activities for all of FY-1985, and a comparison with FY-1984.
A total of 250 employees were hired during FY-1985. Of that total, 20.4 percent were minorities and 47.2 percent women, which is an increase over FY-1984 (17.2 percent minorities and 36.4 percent women). At GG-11 and above there were 132 new hires, with minorities representing 10.6 percent and women 15.9 percent. This is an increase for women compared to FY-1984 (11.8 percent), and a slight decrease for minorities (11.4 percent in FY-1984)..
There were 554 promotions in FY-1985. Of that total, 15.3 percent were minorities and 56 percent women. This is an increase in promotions of women over FY-1984 (53.6 percent) and a slight decrease for minorities (15.9 percent in FY-1984). Of 301 promotions at GG-11 and above, minorities represented 9.6 percent (compared with 10.5 percent in FY-1984), and women 30.9 percent (compared with 28.5 percent in FY-1984).
In FY-1985, the Comission developed a Consolidated EE0 Program Plan to serve as the focal point for implementing and monitoring equal employment opportunity and affirmative action programs and activities agencywide. A similar plan was developed for FY-1986 (copy enclosed), which provides information on FY-1985 accomplishments and outlines initiatives to be undertaken during FY-1986 to improve the Agency EE0 Program.
Sincerely,
/g
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Nunzio J. Palladino Chairman
Enclosures:
1.
Quarterly Report 2.
Sumary/ Comparison Charts 3.
FY-1986 Consolidated EE0 Program Plan I
UNITED STATES yq NUCLEAR REGULATORY COMMISSION g
W ASHLNGTON, D.C. 20555
,., /
+...*
OFFICE OF THE December 27, 1985 CHAIRMAN The Honorable Thomas P. O'Neill, Jr.
Speaker of the United States House of Representatives Washington, DC 20515
Dear Mr. Speaker:
In accordance with Title II of the Energy Reorganization Act of 1974, as amended, the Nuclear Regulatory Comission submits its quarterly report on full-time permanent employees hired and promoted for the FY-1985 quarter ending September 30, 1985. Also provided is a summary of these activities for all of FY-1985, and a comparison with FY-1984.
A total of 250 employees were hired during FY-1985. Of that total, 20.4 percent were minorities and 47.2 percent women, which is an increase over FY-1984 (17.2 percent minorities and 36.4 percent women). At GG-11 and above there were 132 new hires, with minorities representing 10.6 percent and women 15.9 percent. This is an increase for women compared to FY-1984 (11.8 percent), and a slight decrease for minorities (11.4 percent in FY-1984)..
There were 554 promotions in FY-1985. Of that total, 15.3 percent were minorities and 56 percent women. This is an increase in promotions of womenoverFY-1984(53.6 percent) and a slight decrease for minorities (15.9 percent in FY-1984). Of 301 promotions at GG-11 and above, minorities represented 9.6 percent (compared with 10.5 percent in FY-1984), and women 30.9 percent (compared with 28.5 percent in FY-1984).
In FY-1985, the Comission developed a Consolidated EE0 Program Plan to serve as the focal point for implementing and monitoring equal employment opportunity and affirmative action programs and activities agencywide. A similar plan was developed for FY-1986 (copy enclosed), which provides information on FY-1985 accomplishments and outlines initiatives to be undertaken during FY-1986 to improve the Agency EE0 Program.
Sincerely, g
/
l
[.r 6 Nunzio J. Palladino Chairman
Enclosures:
1.
Quarterly Report 2.
Sumary/ Comparison Charts 3.
FY-1986 Consolidated EE0 Program Plan l
l l
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4 UNITED STATES i
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NUCLEAR REGULATORY COMMISSION "f
W ASHINGTON, D.C. 20555 s.... /
December 27, 1985 OFFICE OF THE CHAIRMAN The Honorable John Dingell, Chairman Subcomittee on Oversight and Investigations Comittee on Energy and Comerce United States House of Representatives Washington, DC 20515
Dear Mr. Chairman:
In accordance with Title II of the Energy Reorganization Act of 1974, as amended, the Nuclear Regulatory Comission submits its quarterly report on full-time pemanent employees hired and promoted for the FY-1985 quarter ending September 30, 1985. Also provided is a summary of these activities for all of FY-1985, and a comparison with FY-1984.
A total of 250 employees were hired during FY-1985. Of that total, 20.4 percent were minorities and 47.2 percent women, which is an increase over FY-1984 (17.2 percent minorities and 36.4 percent women). At GG-11 and above there were 132 new hires, with minorities representing 10.6 percent and women 15.9 percent. This is an increase for women compared to FY-1984 (11.8..
percent), and a slight decrease for minorities (11.4 percent in FY-1984).
There were 554 promotions in FY-1985. Of that total, 15.3 percent were minorities and 56 percent women. This i: an increase in promotions of women over FY-1984 (53.6 percent) and a slight decrease for minorities (15.9 percent in FY-1984). Of 301 promotions at GG-11 and above, minorities represented 9.6 percent (compared with 10.5 percent in FY-1984), and women 30.9 percent (compared with 28.5 percent in FY-1984).
In FY-1985, the Comission developed a Consolidated EE0 Program Plan to serve i
as the focal point for implementing and monitoring equal employment opportunity and affirmative action programs and activities agencywide. A similar plan was developed for FY-1986 (copy enclosed), which provides infomation on FY-1985 accomplishments and outlines initiatives to be undertaken during FY-1986 to improve the Agency EE0 Program.
Sincerely.j g
g Nunzio J. Palladino y
Chairman
Enclosures:
1.
Quarterly Report 2.
Sumary/ Comparison Charts 3.
FY-1986 Consolidated EE0 Program Plan cc: Rep. James T. Broyhill
i p1 Kttm g
UNITED STATES i;
NUCLEAR REGULATORY COMMISSION In
-f W ASHINGTON, D.C. 20555 l
%.x OFFICE OF THE December 27, 1985 CHAIRMAN The Honorable Alan Simpson, Chairman Subcomittee on Nuclear Regulation Comittee on Environment and Public Works United States Senate Washington, DC 20510
Dear Mr. Chairman:
In accordance with Title II of the Energy Reorganization Act of 1974, as amended, the Nuclear Regulatory Comission submits its quarterly report on 4
full-time permanent employees hired and promoted for the FY-1985 quarter ending September 30, 1985. Also provided is a sumary of these activities for all of i
FY-1985, and a comparison with FY-1984.
A total of 250 employees were hired during FY-1985. Of that total, 20.4 percent were minorities and 47.2 percent women, which is an increase over FY-1984 (17.2 percent minorities and 36.4 percent women). At GG-11 and above there were 132 new hires, with minorities representing 10.6 percent and women 15.9 percent. This is an increase for women compared to FY-1984 (11.8..
percent), and a slight decrease for minorities (11.4 percent in FY-1984).
There were 554 promotions in FY-1985. Of that total, 15.3 percent were minorities and 56 percent women. This is an increase in promotions of women over FY-1984 (53.6 percent) and a slight decrease for minorities (15.9 percent in FY-1984). Of 301 promotions at GG-11 and above, minorities represented 9.6 percent (compared with 10.5 percent in FY-1984), and women 30.9 percent (compared with 28.5 percent in FY-1984).
In FY-1985, tne Comission developed a Consolidated EE0 Program Plan to serve i
as the focal point for implementing and monitoring equal employment opportunity and affirmative action programs and activities agencywide. A similar plan was developed for FY-1986 (copy enclosed), which provides information on FY-1985 accomplishments and outlines initiatives to be undertaken during FY-1986 to improve the Agency EE0 Program.
Sincerely, f
/
i i
Nunzio J. Palladino Chairman
Enclosures:
1.
Quarterly Report 2.
Sumary/ Comparison Charts 3.
FY-1986 Consolidated EE0 Program Plan cc:
Sen. Gary Hart
f ne s
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UNITED STATES i
S NUCLEAR REGULATORY COMMISSION
%....}!
3' WASHINGTON, D.C. 20555
. December 27, 1985 o,,,c,o,rg,_
CHAIRMAN The Honorable Morris K. Udall, Chairman
-Subcommittee on Energy and the Environment Committee on Interior and Insular Affairs United States-House of. Representatives Washington, DC 20515
Dear Mr. Chairman:
In accordance with Title II of the Energy Reorganization Act of 1974, as amended, the Nuclear Regulatory Comission submits its quarterly report on full-time permanent employees hired and promoted for the FY-1985 quarter ending September 30, 1985. Also provided is a sumary of these activities for all of FY-1985, and a comparison with FY-1984.
A total of 250 employees were hired during FY-1985. Of that total, 20.4 percent were minorities and 47.2 percent women, which is an increase over FY-1984 (17.2 percent minorities and 36.4 percent women). At GG-11 and above there were 132 new hires, with minorities representing 10.6 percent and women 15.9 percent. This is an increase for women compared to FY-1984 (11.8;.
percent), and a slight decrease for minorities (11.4 percent in FY-1984)..
There were 554 promotions in FY-1985. Of that total,15.3 percent were minorities and 56 percent women. This is an increase in promotions of women over FY-1984'(53.6 percent) and a slight-decrease for. minorities (15.9 percent in FY-1984). Of 301 promotions at GG-11 and above, minorities represented 9.6 percent (compared with 10.5 percent in FY-1984), and women 30.9 percent (compared with 28.5 percent in FY-1984).
In FY_-1985, the Comission developed a Consolidated EE0 Program Plan to serve as the focal point for implementing and monitoring equal' employment opportunity and affirmative action programs and activities agencywide. A similar plan was developed for FY-1986 (copy enclosed), which provides information on FY-1985 accomplishments and outlines initiatives to be undertaken during FY-1986 to improve the Agency EE0 Program.
Sincerely, f!e m.-
% dws Nunzio J. Palladino Chairman
Enclosures:
1.
Quarterly Report 2.
Sumary/ Comparison Charts 3.
FY-1986 Consolidated EE0 Program Plan cc: Rep. Manuel lujpn
p rea s
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j NUCLEAR REGULATORY COMMISSION C
WASHIN GTON, D.C. 205$5
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December 27, 1985 OFFICEh0F THE CHAIRMAN The Honorable Edward J. Markey, Chairman Subcommittee on Energy Conservation and Power Comittee on Energy and Commerce United States House of Representatives Washington, DC 20515
Dear Mr. Chairman:
In accordance with Title II of the Energy Reorganization Act of 1974, as amended, the Nuclear Regulatory Connission submits its quarterly report on full-time permanent employees hired and promoted for the FY-1985 quarter ending l
September 30, 1985. Also provided is a summary of these activities for all of FY-1985, md a ccmparison with FY-1984.
A total of 250 employees were hired during FY-1985. Of that total, 20.4 percent were minorities and 47.2 percent women, which is an increase over FY-1984 (17.2 percent minorities and 36.4 percent women). At GG-11 and above there were 132 new hires, with minorities representing 10.6 percent and women 15.9 percent. This is an increase for women compared to FY-1984 (11.8..
percent), and a slight decrease for minorities (11.4 percent in FY-1984).
i There were 554 promotions in FY-1985. Of that total, 15.3 percent were minorities and 56 percent women.
This is an increase in promotions of women over FY-1984 (53.6 percent) and a slight decrease for minorities (15.9 percent in FY-1984). Of 301 promotions at GG-11 and above, minorities represented 9.6 percent (compared with 10.5 percent in FY-1984), and women i
30.9 percent (compared with 28.5 percent in FY-1984).
In FY-1985, the Commission developed a Consolidated EE0 Program Plan to serve as the focal point for inplementing and monitoring equal employment opportunity and affirmative action programs and activities agencywide. A similar plan was developed for FY-1986 (copy enclosed), which provides 4
information on FY-1985 accomplishments and outlines initiatives to be undertaken during FY-1986 to improve the Agency EE0 Program.
Sincerely, I
k?
,(
Nunzio J. Palladino
Enclosures:
1.
Quarterly Report 2.
Summary / Comparison Charts 3.
FY-1986 Consolidated EE0 Program Plan cc:
Rep. Carlos Moorhead
J 4*
j
[i, UNITED STATES 4 i I
NUCLEAR REGULATORY COMMISSION
\\ %@, }]lj W ASmNGTON, D.C. 20555
%yt OFFICE OF THE December 27, 1985 CHAIRMAN The Honorable Mike Synar, Chairman Subcomittee on Environment, Energy and Natural Resources Comittee on Government Operations United States House of Representatives Washington, DC 20515
Dear Mr. Chairman:
In accordance with Title II of the Energy Reorganization Act of 1974, as amended, the Nuclear Regulatory Comission submits its quarterly report on full-time permanent employees hired and promoted for the FY-1985 quarter ending September 30, 1985. Also provided is a sumary of these activities for all of FY-1985, and a comparison with FY-1984.
A total of 250 employees were hired during FY-1985. Of that total, 20.4 percent were minorities and 47.2 percent women, which is an increase over FY-1984 (17.2 percent minorities and 36.4 percent women). At GG-11 and above there were 132 new hires, with minorities representing 10.6 percent and. women 15.9 percent. This is an increase for women compared to FY-1984 (11.8 percent), and a slight decrease for minorities (11.4 percent in FY-1984).
There were 554 promotions in FY-1985. Of that total, 15.3 percent were minorities and 56 percent women. This is an increase in promotions of women over FY-1984 (53.6 percent) and a slight decrease for minorities (15.9 percent in FY-1984). Of 301 promotions at GG-11 and above, minorities represented 9.6 percent (compared with 10.5 percent in FY-1984), and women 30.9 percent (compared with 28.5 percent in FY-1984).
In FY-1985, the Commission developed a Consolidated EE0 Program Plan to serve as the focal point for inplementing and monitoring equal employment opportunity and affirmative action programs and activities agencywide. A similar plan was developed for FY-1986 (copy enclosed), which provides information on FY-1985 accomplishments and outlines initiatives to be undertaken during FY-1986 to improve the Agency EE0 Program.
Sincerely, r.
fA f!
f
~fv8
- f Nunzio J. Palladino Chairman
Enclosures:
1.
Quarterly Report 2.
Summary / Comparison Charts 3.
FY-1986 Consolidated EE0 Program Plan cc:
Rep. William F. Clinger, Jr.
4 e
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ENCLOSURE 2 SUPtMRY/ COMPARISON CHARTS FOR FY-1984/FY-1985 A
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St9 MARY OF FY-1984 REPORT ON HIRES TOTAL HIRES MALES HIRED FEMALES HIRED MINORITY NONMINORITY MINORITY NONMINORITY O
O O
O O
EX I EX II O
O O
O O
EX III 1
0 1
0 0
EX IV O
O O
O O
EX Y 0
0 0
0 0
ES 1 0
0 0
0 0
ES 2 1
1 0
0 0
ES 3 0
0 0
0 0
ES 4 2
0 2
0 0
ES 5 1
0 0
0 1
ES 6 0
0 0
0 0
UNGRADED (PROFESSIONALS) 2 0
1 0
1 GG-18 0
0 0
0 0
GG-17 0
0 0
0 0
GG-16 1
0 1
0 0
GG-15 7
1 6
0 0
GG-14 41 5
33 1
2 GG-13 115 7
99 1
8 GG-12 45 5
31 2
7 GG-11 30 5
19 0
6 SU8 TOTAL: GG-Il AND A80VE 246 24 193 4
25 GG-10 1
0 1
0 0
GG-09 22 1
11 1
9 GG-08 3
0 0
0 3
GG-07 25 2
12 1
10 GG-06 8
0 0
1 7
GG-05 57 3
7 19 28 GG-04 22 0
2 7
13 GG-03 14 2
1 3
8 GG-02 8
0'-
0 1
7 GG-01 1
0 0
1 0
UNGRADED (ADMIN / CLERICAL /W8) 0 0
0 0
0 SU8T0TAL: bMGRADEDTHRUGG-10 161 8
34 34 85 GRAND TOTAL 407 32 227 38 110
StMMARY OF MINORITIES AND WOMEN HIRED AND PROMOTED FY-1984 COMPARED TO FY-1985 FY-1984 FY-1985 Women Minorities Total Women Minorities Total EmployeesNSred:
1 Number Hired 148 70 407 118 51 250 Percent of Total 36.4%
17.2%
47.2%
20.4%
Hires at GG-11 and above 29 28 246 21 14 132 Percent of Total 11.8%
'11.4%
15.9%
10.6%
i Employees Promoted:
^
Number of Promotions 325 96 606 310 85 554 Percent of Total 53.6%
15.9%
56%
15.3%
Promotions at GG-11 and above 103 38 362 93 29 301 Percent of Total 28.5%
10.5%
30.9%
9.6%
s 8
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O SUPMARY OF FY-1984 REPORT ON PROMOTIONS TOTAL PROMOTIONS MALES PROMOTED FEMALES PROMOTED j
MINORITY NONNINORITY MINORITY N0fMINORITY
. EX I O
O O
O O
EX II O
O O
O O
EX III O
O O
O O
EX IV 0
0 0
0 0
EX V 0
0 0
0 0
ES 1 0
0 0
0 0
ES 2 0
0 0
0 0
ES 3 0
0 0
0 0
ES 4 0
0 0
0 0
ES 5 0
0 0
0 0
ES 6 0
0 0
0 0
UNGRADED (PROFESSIONALS)-
0 0
0 0
0 GG-18 0
0 0
0 0
GG-17 0
0 0
0 0
GG-16 6
0 6
0 0
GG-15 82 4
73 3
2 GG-14 99 8
75 3
13 GG-13 71 2
43 5
21 GG-12 55 3
28 5
19 G6-11 49 1
16 4
28 SUBTOTAL: GG-11 AND ABOVE 362 18 241 20 83 GG-10 7
0 1
0 6
GG-09 25 0
3 1
21 GG-08 28 0
3 2
23 GG-07 49 2
2 9
36 i
GG-06 68 1
2 18 47 GG-05 38 0
4 17 17 GG-04 16-0 1
5 10 j
GG-03 11 1
0 2
8 GG-02 0
0 0
0 0
i GG-01 0
0 0
0 0
j UNGRADED (ADMIN / CLERICAL /WB) 2 0
2 0
0 e
I SUBTOTAL: UNGRADED THRU GG-10 244 4
18 54 168 l
GRAk0 TOTAL 606 22 259 74 251
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SUPMARY OF FY-1985 REPORT ON HIRES TOTAL HIRES MALES HIRED FEMALES HIRED MINORITY NONMINORITY MINORITY NONMINORITY EX I O
O O
O O
EX II O
O O
O u
EX III 1
0 1
0 0
EX IV 0
0 0
0 0
EX Y 0
0 0
0 0
ES 1 0
0 0
0 0
ES 2 0
0 0
0 0
ES 3 1
0 1
0 0
ES 4 1
0 0
0 1
ES 5 0
0 0
0 0
ES 6 0
0 0
0 0
UNGRADED (PROFESSIONALS) 0 0
0 0
0 GG-18 0
0 0
0 0
GG-17 0
0 0
0 0
GG-16 0
0 0
0 0
GG-15 6
0 6
0 0
GG-14 15 0
12 0
3 GG-13 69 9
53 1
6 GG-12 29 2
21 0
6 GG-Il 10 2
4 0
4 SUBTOTAL: GG-ll AND AB0VE 132 13 98 1
20 GG-10 0
0 0
0 0
GG-09 14 2
8 1
3 GG-08 0
0 0
0 0
GG-07 13 1
6 0
6 GG-06 15 0
1 2
12 GG-05 38 0
1 18 19 GG-04 24 0
1 6
17 GG-03 9
1.
0 5
3 GG-02 5
0 *.
0 1
4 1
GG-01 0
0 0
0 0
UKGRADED (ACMIN/ CLERICAL /WB) 0 0
0 0
0-SUBTOTAL: UNGRADED THRU GG-10 118 4
17 33 64 GRAND TOTAL 250 17 115 34 84
SUMARY OF FY-1985 REPORT ON PROMOTIONS TOTAL PROMOTIONS MALES PROMOTED FEMALES PROMOTED MINORITY NONMINORITY MINORITY NONMINORITY h 0 0
0 0
0 EX I EX II O
O O
O O
EX III O
O O
O O
EX IV 0
0 0
0 0
EX V 0
0 0
0 0
ES 1 0
0 0
0 0
ES 2 0
0 0
0 0
ES 3 0
0 0
0 0
ES 4 0
0 0
0 0
ES 5 0
0 0
0 0
ES 6 0
0 0.
0 0
UNGRADED (PROFESSIONALS) 0 0
0 0
0 GG-18 0
0 0
0 0
GG-17 2
0 2
0 0
GG-16 2
0 2
0 0
GG-15 58 4
48 0
6 GG-14 58 3
45 0
10 GG-13 83 5
50 4
24 GG-12 65 5
31 3
26 GG-11 33 3
10 2
18 SUBTOTAL:
GG-11 AND ABOVE 301 20 188 9
84 GG-10 8
0 0
0 8
GG-09 49 1
16 4
28 GG-08 25 1
1 3
20 GG-07 60 4
6 11 39 GG-06 46 2
1 9
34 GG-05 29 0
1 6
22 GG-04 23 3
0 6
14 GG-03 12 0
0 5
7 GG-02 1
0 0
1 0
GG-01 0
0 0
0 0
UNGRADED (ADMIN / CLERICAL /WB) 0
-0 0
0 0
i SUBTOTAL: UNGRADED THROUGH GG-10 253 11 25 45 172 GRAND TOTAL 554 31 213 54 256
October 1, 1985 CONSOLIDATED EQUAL EMPLOYMENT OPPORTUNITY PROGRAM PLAN FY 1986 e
e e
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF SMALL AND DISADVANTAGED BUSINESS UTILIZATION AND CIVIL RIGHTS
CONTENTS Page i
LIST OF TABLES..............................................
vii ix PREFACE.....................................................
t 1.
EXECUTIVE
SUMMARY
I 1
i 1.1 Pu rp o s e............................................
1 1.2 Background.........................................
I 1.3 An alysis of Current EE0 P rograms...................
2.
INTRODUCTION............................................
3 2.1 Statutory and Regulatory Basis for NRC EE0 Programs 3
2.2 EE0 Responsibilities and Authorities m..............
4 2.3-EE0 Constituent Group Committees...................
4 2.4 Overview of the NRC Workforce......................
5 2.5 P rogres s Du ring FY-1985............................
5 2.5.1 Increase in Women Employees.................
10 2.5.2 Increase in Minority Employees..............
10 i
2.5.3 Increase at GG-13/15........................
10 2.5.4 Representation at SES Levels................
10 3.
CURRENT NRC EE0 PR0 GRAMS................................
11
-~
3.1 Affi rmati ve Empl oyment Programs....................
11 3.1.1 Federal Women's Program.....................
11 3.1.2 Federal Equal Opportunity Recruitment Program.....................................
12 3.1.3 Programs for Veterans.......................
13 3.1.3.1 Disabled Veteran Program............
13 3.1.3.2 Vietnam Era Veterans................
13 3.1.4 Handicapped Program.........................
13 3.1.5 Hispanic Employment Program.................
14 3.1.6 Part-time Employment Program................
14 3.2 Affirmative Action Recruitment Hiring, and Placement..........................................
15 3.2.1 Encouragement of Entry-Level Hiring.........
15
'l 3.2.2 Entry Level Recrui tment.....................
15 3.2.3 Hiring Experienced Staff....................
16 3.2.4 Cooperative Education Program...............
16 I
3.2.5 Review of NRC Employment Practices..........
16
~
3.2.6 Qualifications Review and Analysis..........
17 iii
.P.ag!!
i 3.3 Development and Utilization of NRC Staff...........
17 17 3.3.1 Tra i ni n g P ro grams...........................
18 3.4 Compl aint Recei pt and P rocessing...................
i 3.4.1 The Complaint Process.......................
18 3.4.2 Analysis of Complaints......................
19 i
i 3.5 EE0 Training for NRC Staff.........................
19
?
3.5.1 Executive Training..........................
19 l
3.5.2 Employee Orientation and Awareness..........
21 3.6 EE0 Planning, Implementation,, and Review...........
2}
3.6.1 Review of Program Planning..................
21 i
3.6.2 Program Implementation......................
21 3.6.3 Reporti ng Responsi bili ti es..................
21
[
3.6.4 Reports to NRC Management...................
21
)
3.6.5 Reports to Other Agenci es...................
22 3.6.6 Status of Reporting Systems.................
22 j
3.6.6.1 Automated Personnel Sys tem..........
22 i
3.6.6.2 Manual Reporting Systems............
22 i
i 3.7 Management Accountability for EE0 Accomplishmerts..
22 i
3.7.1 Authori ty and Accountabil i ty................
22 l
3.7.2 EE0 and the Performance Appraisal Process...
23 i
3.7.3 EE0 as a Factor in Recognition and Awards...
23
+
l 4.
ASSESSING THE FY-1985 NRC EE0 PLAN......................
24
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t i
4.1 Division of Organization and Personnel.............
24 l
l l
4.2 Office of Small and Disadvantaged Business Utilization / Civil Rights...........................
25 4.2.1 Civil Rights Program........................
25 i
4.2.2 ' Federal Women's Program.....................
25
-l 4.3 Upward Mobility....................................
26 4.4 Goals 0btained.....................................
27 5.
FY-1986 NRC EE0 PROGRAM PLAN............................
28 l
5.1 0verview............................................
28 1
l iv i
9 Page 5.2 Federal Women's Program.............................
30 5.3 Federal Equal Opportunity Recruitment Program.......
30 5.3.1 Underrepresentation Determinations...........
30 5.3.2 Vacancy Forecasts for NRC's Most Populous Occupations.................................
31 5.3.3 Hiring Goals for Minorities and Women........
31 5.3.4 Progras.s for Veterans........................
31 1
5.3.5 Handicapped Program..........................
31 5.3.6 Hispanic Employment Program..................
31 5.3.7 Part-Time Employment Program.................
32 5.3.7.1 Identification of Part-Time Career Posi ti on s for FY-1.986...........,....
32 5.4 Affirmative Action Recruitment, Hiring and Placement 32 5.4.1 Cooperative Education Program................
32 5.4.1.2 Campus Recruitment..................
32 1
5.4.1.3 Job Fairs...........................
33 5.4.2 Advertisement................................
33 5.4.2.1 Attendance at Technical Society Meetings............................
33 5.4.3 Job Analysis and Restructuring...............
33 5.4.3.1 Long-Range Cyclic Review............
34 5.5 Development and Utilization of NRC Staff............
34 5.5.1 Revitalizing Upwa rd Mobili ty.................
34 5.5.2 Increasing the Use of Individual Development P1ans........................................
35 5.5.3 Supervisory & Management Development for NRC Employees....................................
36 5.5.3.1 Pre-supervisory Orientation Program.............................
36 5.5.3.2 Supervisory _ Development.............
36 5.5.3.2.1 Supervising Human Resources Course.........
36 5.5.3.2.2 NRC Management Workshop..
37
~
5.5.3.2.3 Continuing Supervisory Education................-
37 Y
t i
Page l
1 5.5.3.3 Executive Leadership Program..........
37 f
5.5.3.4 SES Candidate Development Program.....
37 i
5.5.4 Administrative / Clerical / Assistant Job Development....................................
38 j
5.5.5 Secretarial and Clerical Development Program...
38 l
1 5.6 Complaint Receipt and Processing......................
39 5.6.1 Enhancing the Utilization of EEO Officers and
{
Counselors.....................................
39 5.6.2 Enhancing the Internal Ccmplaint Management 5
System.........................................
39 5.6.3 Improving Liaison with EE0C....................
40 l
i 5.7 EE0 Training and Awareness Programs...................
40 i
1 5.7.1 EE0 Training for Supervisors and Managers......
40 5.7.2 Increasing Employee Awareness and Participation i n EE0 Activ i ti e s..............................
40 5.7.3 Assessing EE0 Performance Problems.............
40 5.8 Improving Program Coordination........................
40
'~
l 5.8.1 Monitoring Implementation......................
41 I
5.9 Management Accountabil i ty..............................
41 l
".9.1 Fixing Accountability for EE0 Accceplishments...
41 5
j 5.9.2 NRC EE0 Award...................................
41 l
5.9.3 Summary of Resource Requi rements................
42 GLOSSARY.......................................................
43
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B
LIST OF TABLES P_ age a
Table 2.1 NRC Workforce Profile by Organization as of March 31, 1985.....................................
6 2.2 NRC Workforce Profile by Grade Level as of March 31, 1985.....................................
7 2.3 NRC Workforce Profile by Occupation Group as of March 31, 1985.....................................
8 2.4 NRC Workforce Profile by Age and Occupation Group as of March 31, 1985.....................................
9 3.1 Formal EE0 Complaints Filed at NRC through June 30, 1985...
20 b
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vii r
PREFACE This document outlines the consolidated agency-wide Equal Employment Opportunity (EEO) Program Plan for FY 1986.
EE0 is a fundamental policy of the Federal government, and the NRC is comitted to providing a personnel management system free from discrimination for all employees and applicants for employment.
Moreover, the NRC recognizes its obligation to implement programs that will eradicate underrepresentation or barriers to equal opportunity wherever these may exist. Thus, the Commission and senior NRC management are comitted, as a matter of policy, to the establishment and pursuit.cf vigorous and effective Equal Employment Opportunity and Affirmative Action programs.
e i
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9
J 1.
EXECUTIVE
SUMMARY
1.1 Purpose This is the second Consolidated EE0 Program Plan prep red by the staff of the Office of Small and Disadvantaged Businm Utilization /
Civil Rights (OSDBU/CR),
The Plan structures the strategy for implementing and monitoring EE0 and affirmative action programs and activities agency-wide in FY 1986.
1.2 Background
NRC staff and managers have prepared a number of EE0 related plans and other initiatives since the agency was established in 1975. Review of these multiple plans and program reports showed the need to prepare a single, consolidated EE0 Program Plan setting both overall directions and specific but achievable objectives.
This plan permits flexible implementation by individual executives and managers, and makes executives and managers responsible and accountable for achieving the program's objectives.
1.3 Analysis of Current EE0 Programs j
NRC has conducted EE0 and affirmative action programs since its establishment.
A' number of programs have been implemented to respond to government-wide affirmative employment objectives.
A wide range of both formal and infonnal career development opportunities have been provided to all employees. Appropriate efforts have been made to increase the representation of minorities and women in the workforce.
Programs have been directed at disabled veterans and the handicapped.
The numbers of minorities and wcmen in technical and scientific occupations are small in the civilian labor force. This has had an unfavorable impact on the NRC's ability to increase the representation of these groups in the Agency's workforce. Additionally, public health and safety concerns have sometimes restricted NRC managers from hiring other than fully trained, experienced staff, which further limits opportunities for either entry-level hiring or large scale development of NRC staff.
l NRC has the appropriate organization structure in place to l
achieve EE0 hiring goals. The activities themselves need to be results oriented and systematically monitored against specific program objectives. Greater emphasis will be placed on coordinating e
9 l
1 1
1 i
the various affirmative employment programs while retaining their individual identity.
Recruitin' and placement strategies should g
continue to be examined critically to maximize the potential for reachinC minorities, women and other protected groups, as appropriate, and then encouraging them '. accept NRC employment. More emphasis needs to be placed on developing and utilizing current NRC employees. Most important, managers and supervisors need to know their EE0 responsibilities, plan realistic accomplishments, and be held accountable. for proper implementation of the program. The Comission and NRC senior management are committed to achieving demonstrable progress in each of~ these areas.
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.2.
INTRODUCTION
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2.1 Statutory and Repulatory Basis for NRC EE0 Programs Equal Employment Opportunity (EEO) is a system of employment practices under which individuals are not excluded from participation, advancement, or benefits because of their race.
color, religion, sex, national criain, age, handicap, or other factor which cannot lawfully be the basis for employment actions.
EE0 provides an employment system in which neither intentional nor unintentional discrimination operates.
Title VII of the Civil Rights Act of 1964 is the primary foundation for all EE0 programs in the Federal government.
Several Executive Orders and Public Laws further emphasize government policy to provide equal opportunity in Federal employment.
Executive Order 11478 of August 8,1969 states, in part, that "it is the policy of the Government of the United States to provide cqual opportunity in Federal employment for all persons, to prohibit discrimination in employment because of race, color, i
religion, sex or national origin, and to promote the full realization of equal employment opportunity through a continuinp affimative program in each executive department and agency."
This executive order further states that "the head of each executive department and agency shall establish and maintain an affirmative program of equal employment opportunities for all civilian employees and applicants for employment within.the agency's jurisdication."
i The Equal Employment Opportunity Act of 1972 (P.L.92-261) gave the Civil Service Comission authority to enforce antidiscrimination provisions within the Federal government. The Federal Rehabilitation Act of 1973 extended protection against discrimination to employees and applicants for employment on the basis of mental or physical handicap..The Fair Labor Standards Amendments of 1974 (P.L.93-259) established provisions in Federal government employment for nondiscrimination due to age; these were further expanded by the Ape Discrimination in Employment Act of 1978 (P.L.90-202).
Reorganization Plan No.1 of 1978 and Executive Order 12067 gave the Ecual Employment 2
Opportunity Comission lead coordinating responsibility for all Federal equal employment opportunity programs and activities.
Further regulations are codified under 29 CFR 1613.
l i
l 3
i j
2.2 EE0 Responsibilities and Authorities j
Federal regulations provide that each agency head is required to f
exercise personal leadership in establishing, maintaining, and j
carrying out a continuing affirmative program designed to promote
}
equal opportunity in every aspect of agency personnel policy and practice in the employment, development, advancement, and treatment of t
employees. The EDO is the senior NRC staff official responsible for operating i
and monitoring the overall EE0 program. The Director OSDBU/CR, is the i
principal staff manager responsible for assisting the EDO in managing NRC, EE0 i
programs, and for advising the Commission on EE0 matters.
l 2.3 EE0 Constituent Group Comittees j
NRC has four recognized employee committees which advise the EDO and other
[
agency officials on EE0 matters.
Comittees meet regularly to discuss EE0 l
matters of interest to NRC staff and periodically relate issues and concerns f
to management.
The EE0 Advisory Comittees are providing a valuable service to the Agency, f
and they are to be encouraged in their work by assistance from OSDBU/CR and t
the staff management. This assistance will include ornviding the EE0 Advisory Comittees with full and timely access to infomation, consultation on the
[
develepcent of subsequent EE0 plans and policies, and cooperation in providing time for members to attend meetings of the cemittees.
The Affimative Action Advisory Comittee (AAAC) advises EDO and the Director, OSDBU/CR, on affirmative action matters. The AAAC also reviews EE0 plans as f
formulated and implemented by the Civil Rights Program Manager (CRPM) in OSDBU/CR, the Federal Women's Program Manager (FWPM), the Division of l
Organization and Personnel (0&P1,ADM, and other NRC offices.
l The Federal Wccen's Program Advisory Committee (FWPAC) advises the FWPM, the j
Director, OSDBU/CR and the EDO regarding women's issues and concerns.
The FWPAC also reviews EE0 plans formulated and implemented by OSDBU/CR and ADM as they relate to NRC wcmen emoloyees and applicants for employment.
i The Committee on Age Discrimination advises the Director, OSDBU/CR, and the EDO, in carrying out both the spirit and the intent of the Age Discrimination in Employment Act of 1978, as amended. The Committee does not beceme involved in individual cases, but NRC employees are urged to bring to the attention of i
the Committee any generic matters associated with age discrimination.
~
The Joint Labor-Managerent Equal Employment Opportunity Comittee was i
'nstablished on April 19, 1982, by the NRC and the National Treasury Employees Union (NTEU) to advise manacement on matters concerninp EEO.
Half the members are appointed by NRC managemant and half by the NTEU.
4 l
l
The NRC has also authcrized the establishment and operation of an NRC Chapter of Blacks in Government (BIG). This organization l
advises the Director, OSDBU/CR, and the EDO on matters pertaining l
to the recruitment and advancement of Black employees.
2.4 Overview of the NRC Workforce j
As of May 31, 1985, the total NRC workforce of 3367 permanent full-time employees was 68.1 percent male and 31.9 percent female. Members of the four designated minority groups j
constituted 15.9 percent of the workforce:
10.7 percent were i
l Black,1.1 percent Hispanic, 3.8 percent Asian-American or l
Pacific Islander, and 0.? percent Native American or Alaskan Native. Table 2.1 shows the mir;ority group representation by sex for groups of headquarters offices and each region.
j
~
l As of May 31, 1985, women constituted 85.8 percent of the i
i workforce at grades GG-1 to GG-8; 61.2 percent of the GG-9 to f
GG-12 workforce; 9.8 percent of the GG-13 to GG-15 workforce; 6.5 percent of the GG-16 to GG-18 workforce, and 2.9 percent of
~
~the SES workforce. Minority group members constituted 29.6 per-t cent of the GG-1 to GG-8 workforce 20.7 percent of the GG-9 to GG-12 workforce; 11.4 percent of the GG-13 to GG-15 workforce; j
2.2 percent of the GG-16 to GG-18 workforce, and 4.4 percent of i
the SES workforce. Table 2.2 shows the distribution of specific i
minority group members by sex in these grade groups.
l Most minorities and wcmen are clustered in the clerical.and administrative fields. With respect to the three most populous j
professional occupation groups, as of May 31, 1985, women i
constituted 3.6 percent of those in the engineering occupations, l
I 13.4 percent of the scientific occupations, and 70.8 percent of the attorney group.
In the same fields, 12 percent of engineers were minorities, 7.4 percent of scientists, and 7.5 1
percent of attorneys. Table 2.3 shows the distribution of specific minority grcups by sex within NRC occupational groups.
The majority of the NRC workforce is over age 40.
As of May 31, 1985, 56.9 percent of employees were 40 years of age or older. Table ?.4 shows the distribution of employees by age within NRC occupational groups.
l 2.5 Progress During FY-1985 A comparison of this year's figures with those provided for FY-1984 shows gains in several important areas. These figures reveal that NRC continues to experience positive results from its Affirmative Action efforts.
i I
5 1
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Table 2.1 feet Workforce Profile by Or9anisatten as.f II.rch 31.1985 (Permanent ruli.ifese Employees) i l
Totai lihite Bisck Ittspanic Asfan-Amer.
Betty. Amer.
i Pec. Island Aiaska Nativ.
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- i. mi.
r ie m i.
r ie mi.
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l Cem.issten 186 116 168 85 9. 29 1
0 7
2 1
0 Offices (61.6) (38.4) (55.6) (20.0)
(3.0).(9.6)
(0.3) (00)
(2.3)
(0.7)
(0.3)
(to) 1 E00 Staff 366 330 290 239 67 91 4
I 3
4 2
3 Offices (52.0) (48.0) (41.2) (34.0)
(9.5)(12.9)
(0.6) (0.1) (0.4) (0.6)
(0.3)
(0.4) l leiss Is5 300 17 73 4
23 1
2 7
3 0
3 j
(64.9) (35.1) (60.0) (25.6)
(2.1) (0.1)
(0.35)
(0.7) (2.5)(0.35)
(00) (0.35)
NRR 400 144 400 112 7
24 5
2 59 4
1 0
(76.9) (23.1) (65.4) (30.0)
(1.1)(4.2)
(0.8) (0.3)
(9.5) (0.6)
(0.2)
(80) i a
I ars 15s 5a 139 47 3
le 2
0 le 1
0 0
j (73.1) (26.9) (64.4) (21.8)
(1.4) (4.6)
(0.9) (00)
(6.5) (0.5)
(00)
(60)
It 179 54 164 51 6
7 1
0 0
0 0
0
,3.4)
(60)
(00)
(00)
(
i (75.5) (24.5) (69.2) (21.5)
(2.5) (3.0)
(0.4)
(90) 1 Regten I 199 60 185 49 3
9 3
I O
1 0
0 i
(76.8) (23.2) (71.4) (10.9)
(1.2) (3.5)
(1.2) (0.4)
(3.1) (I.2).
(00)
(60) segten it 192 63 179 to 11 35 0
1 2
1 0
0-j (75.3) (24.7) (70.7) (10.2)
(4.3)(13.7)
(00)
(0.4) (0.8) (0.4)
(00)
(00) 1 l
Regfee !!!
174 72 164 66 5
4 3
0 2
2 1
0
)
(70.7) (29.3) (66.7) (26.9)
(2.0) (1.5)
(1.2)
(00)
(0.8) (0.8)
(0.4)
(00) l Retten ly se de 91 37 4
2 3
1 0
0 0
0 a
(71.0) (29.0) (66.0) (27.9)
(2.9) (1.4)
(2.2) (0.7)~ (00)
(00)
(00)
(00) j l
l nesten v 76 25 6s 20 2
2 4
2 2
1 0
0 (75.2) (24.8) (67.3) (20.0)
(2.0) (2.0)
(4.0) (2.0)
(2.0) (1.0)
(es)
(00) 1 4
i Totais 2293 1974 2027 005 123 238
'27 le lit 17 4
4 J
(68.1) (31.9) (60.2) (24.0) (3.7) (7.1)
(S.8) (0.3)
(3.3) (0.5)
(0.12)
(0.12)
{
l Source: AInt. OEP i
l l'
h i
Table 2.2 NRC Workforce Proffle by Grade Level as of March 31,1985-Total White Black Hispanic Asian-Amer.
Native Amer.
Pac. Island Alaska Native Grades
le Male Female Male Female Male Female Male Female Male Female Male Fema GG-1 to GG-8 **
102 615 65 440 30 160 4
5 2
8 1
2 i
(14.2)
(85.8)
(9.1)
(61.4)
(4.2)(22.3)
(0.56)
(0.7)
(0.3)
(1.1)
(0.14)
(0.28)
GG-9 to GG-12 163
. 257 133 200 24
~53 2
3 4
1 0
0 (38.8)
(61.2)
(31.7)
(47.7)
(5.7)(12.6)
(0.48)
(0.7)
(0.9)
(0.23)
(00)
(00)
GG-13 to GG-15 1786 193 1597 156 65 25 21 2
101 8
2 2
(90.2)
(9.8)
(80.7)
(7.9)
(3.3)(1.26)
(1.1)
(0.1)
(5.1)
(0.4)
(0.1)
(0.1)
GG-16 to GG-18 43 3
42 3
0 0
0 0
1 0
0 0
(93.5)
(6.5)
(91.3)
(6.5)
(00)
(00)
(00)
(00)
(2.2)
(00)
(00)
(00)
SES 199 6
190 6
4 0
0 0
4 0
1 0
(97.1)
(2.9)
(92.7)
(2.9)
(2.0) '(00)
(00)
(00)
(2.0)
(00)
(0.5)
(00)
Tctals 2293 1074 2027 805 123 238 27 10 112 17 4
4 (68.1)
(31.9)
(60.2)
(24.0)
(3.7)
(7.1)
(0.8)
(0.3)
(3.3)
(0.5)
(0.12)
(0.12)
- PermanentFull-timeEmplo[ees Includes Wage Grade Employees Source: ADN OSP i
i 1
i i
l Table 2.3-NRC Workforce Profile by Occupation Group as of March 31, 1985 j
i-f Total White Black Hispanic Asian-Amer.
Native Amer.
Pac. Island Alaska Native Occupation Male Female Male Female Male Female Male Female Male Female Male Female i
i Engineers 1268 47 1118 39 30 0
16 1
103 6
1 1
l (96.4)
(3.6)
(85.0)
(3.0)
(2.3)
(00)
(1.2)
(0.08)
(7.8)(0.46)
(0.08)
(0.08) i Scientists 446 69 418 59 18 8
4 2
6 0
0 0
1 (86.6)
(13.4)
(81.2)
(11.5)
(3.5)
(1.6)
(0.8)
(0.4)
(1.2)
(00)
(00)
(00)
L l
Attorneys 95 25 89 22 4
3 0
0 2
0 0
0
)
(79.2)
(20.8)
(74.2)
(18.3)
(3.3)
(2.5)
(00)
(00)
(1.7)
(00)
(00)
(00)
Administrators ** 398 247 350 192 42 49 3
2 1
3 2
1 (61.7)
(38.3)
(54.3)
(30.0)
(6.5)
(7.6)
(0.5)
(0.3)
(0.16)(0.47)
(0.3)
(0.16)
Clerical 86 686 52 493 29 178 4
5 0
8 1
2 j'
(11.1)
(88.9)
(6.8)
(63.9)
(3.8)(23.1)
(0.5)
(0.65)
(00)
(1.0)
(0.13)
(0.26) i Totals 2293 1074 2027 805 123 238 27 10 112 17 4
4 i
(68.1)
(31.9)
(60.2)
(24.0)
(3.7)
(7.1)
(0.8)
(0.3)
(3.3)
(0.5)
(0.12)
(0.12) i
!~
- Permanent Fu11-time Emp1oyees L
- Includes Employees in Professional Non-technical Occupations such as Management' Analyst, Program Analyst,
}-
Personnel Specialist, Contracts Specialist Computer Programmer, and Librarian.
Source: ADN, D&P i
j.
):
4
\\-
Table 2.4 NRC Workforce Profile by Age and Occupation Group as of March 31, 1985 e
Occupation Total Under 30 30-39 40-49 50-59 60 and Over j
Engineers 1315 87 383 405 332 108 (39.1)
(6.6)
(29.1)
(30.8)
(25.2)
(8.2)
Scientists 515 38 151 151 141 34 (15.3)
(7.4)
(29.3)
(29.3)
(27.4)
(6.6)
Attorneys 120 4
47 35 25 9
(3.6)
,(3.3)
(39.2)
(29.2)
(20.8)
(7.5)
I.
Administrators 645 32 224 225 130 34 (19.2)
(5.0)
(34.7)
(34.9)
(20.2)
(5.3)
=
Clerical 772 241 243.
152 105 30 (22.9)
(31.2)
(31.5)
(19.7)
(13.7)
(3.9) i Totals 3367 402 1048 968 734~
215 (100)
(11.9)
(31.1)
(28.7)
(21.6)
(6.4)
[
- Permanent Full-time Employees i
Source: ADM OSP i
l a
r
9 7.5.1 increase in Women Employees Between March 1r84 and March 1985, NRC grew by a total of 68 permanent full-time (PFT) employees, 3299 to 3367, a 2.1 percent increase.
During the same time, the number of PFT women employees rose 60 persons,1014 to 1074, a 5.9 percent increase. Thus, in net, women's percentage of the Acency increase was 88.2 percent or 60 of 68 persons. Women's representation in the Agency PFT population rose from 30.7 percent to 31.9 percent, a 1.2 percent increase.
2.5.2 Increase in Minority Employees Similarly, during the same time, against the 2.1 percent Agency growth, minority group PFT employees increased their number by 52, a 10.8 percent growth. Minority group employees' percentage of the net Agency increase was J
77 percent or 52 of 68 persons, and minority group employees' representation in the population grew from 14.6 percent to 15.9 percent, a 1.3 percent increase.
2.5.3 Increases at GG-13/15 In grades 13-15, while the Agency increased 33 PFT employees, a 1.7 percent Women constituted
.. growth, women increased 72 persons, a 12.9 percent growth.
66.7 percent of the Agency net growth in this range, and their representation in this pcpulation rose from 8.8 percent tn a 9.8 percent.
In grades 13-15, against the 1.7 percent Agency growth, minority group PFT employees increased by 13 employees, a 6.1 percent rise.
The minority group increase represented 39.4 percent of the Agency net increase in this range, and their representation in this population rose from 10.9 percent to 11.4 percent.
2.5.4 Representation at SES Levels In the SES, during the year March.1984 to March 1985, women ex;trienced a growth of 2 persons, increasinp their SES representation from 1.9 percent to 2.9 percent.
Similarly, minority group employees increased by
- employee, while their representation in the population rose from 3.9 peretnt to 4.4 I
l percent.
0 0
.o l
10 1
~
)
3.
CURRENT NRC EE0 PROGRAMS 3.1 Affirmative Employment Programs Affirmative Employment Programs are personnel management programs which are implemented for the purpose of furthering EE0 goals and objectives. The Office of Personnel Management (OPM) has established several specific affirmative action programs for use government-wide to focus personnel staffino and management attention on EE0 related problems.
Under provisions of the Civil Service Reform Act (CSRA) of 1978, the regulatory responsibility for the development of policies for affirmative employment programs was delecated to OPM and the enforcement aspect was delecated to the Equal Employment Opportunity Commission (EEOC). Unless an exception has been granted, all covered Federal agencies and organizations must develop programs and pqlicies consistent with those established by OPM.
3.1.1 Federal Women's Program.
s The Federal Women's Program (FWP) is an affirmative employment program which
. places special emphasis on the employment concerns of women. The program was
. established by the Civil Service Commission in 1967 to address the under-
. representation and underutilizatior. of women in the Federal government and was made an integral part of the Federal EE0 program in 1969 for program emphasis and visibility. The FWP is the broadest in program responsibility of
~~
all the affirmative employment programs because it focuses, in particular, j
on employment matters as they affect women, the largest single constituent i
group. Provisions of all the other affirmative employment programs also apply to women. The FWP is managed by a designated Federal Women's Program 7
Manager (FWPM) who reports to the Director, OSDBU/CR, and is the principal advisor to NRC managers on employment concerns of women.
A Federal Women's Program Advisory Committee (FWPAC) has been established to advise and assist the FWPM, in addressing specific concerns of NRC women.
In addition, there is an appointed collateral duty Federal Women's Program Coordinator (FWPC) in each region.
l The FWPM participates in formal recruitment activities with the Division of O&P and in informal recruitment efforts of the various minority and women oroanizations; counsels managers /supervisnrs concerning strategies aimed at improving employment opportunities for women; counsels woman regarding performance, training, and other career enhancing efforts; develops and implements plans and procrams for women emplovaes; and in con.iunction with the i
Management Development and Training Staff (MDTS) and the Federal Women's Program Advisory Committee (FWPAC), conducts trainino and awareness programs
' opened to all NRC employees. To ensure that there is an Agency-wide, uniform l
FWP effort, the FWPM assists the Reoional Administrators in implementing a viable FWP by assisting the Regional FWP Coordinators to develop and achieve their goals and objectives.
11
.. - _ _ _, _ _ ~. _,, _ -., _.., _ _,,,. _.,,..,, _ ~. - _ _. _.
3.1.2 Federal Equal Opportunity Recruitment Program The CSRA created the Federal Equal Opportunity Recruitment Program (FEORP) l r; quiring Federal agencies to develop a recruitment plan to eliminate under-representation of minorities and women in certain covered positions. Although i
NRC positions are not among the covered positiens, in 1981 the Agency l
voluntarily established a program which parallels FEORP and which is designed l
to eliminate underrepresentation in targeted categories of employment in NRC.
j NF.C makes yearly determinations of underrepresentation in accordance with EEOC j
criteria in the most populous professional occupations in NRC: General l
Engineering, GG-801; Nuclear Engineering, GG-840; Health Physics, GG-1306; Attorney, GG-905; and Security Administratinn, GG-080. Annual goals have been l
f established since 1982 for each of the major offices planning to employ a significant number of staff in these occupations, and an annual assessment of progress towards meeting the goals is made in-November of each year.
In 1982, the NRC advised the Equal Employment Opportunity Comission (EEOC) that the percentage of women and minnrity representation ia the total l
professional civilian labor force could not be uniformly applied to engineering l
and scientific occupations.
In 1984, in order to obtain more accurate data, NRC contracted with the U.S. Department of Energy and Oak Ridge l
i Associated Universities to develop specific information pertaining to the
~
representation of Engineers and Scientists in the workforce. This information was used to set goals in the engineering and scientific occupations for-.the FY-1985 Affirmative Action Plan, which were as follcws:
Occucation Office FY-1985 Goal l
Nuclear Engineer, GG-840 NRR 2 Asian Males i
IE 2 Asian Males i
General Engineer, GG-801 NRR 1 Hispanic Male i
IE 1 Black Male Security Administrator, GG-080 ADM 1 White Female j
NMSS 1 White Female Attorney, GG-905 OGC 1 White Female ELD 2 White Females j
External strategies have emphasized broadening and increasing the applicant
[
pool from which selections into target positions are made.
NRC has an l
aggressive recruitment advertising policy, and special emphasis has been given to advertising in publications and at professional meetings which are tarpeted l
towards minority and women's groups.
In addition, the staff annually recruits i
,at colleges and universities and participates in en11ege job fairs; l
I
[
12
(
I i
i
here again emphasis is placed on those with a high quality engineering curriculum and a good representation of minority and women students.
Finally, since its inception NRC has had an active Cooperative Education (Co-op) Program to increase the availability pool for engineering, scientific, and legal positions.
3.1.3 Programs for Veturans Various statutes and Federal regulations recognize the particular employment problems many veterans face. NRC affirmative action programs directed toward veterans include focusing on the special needs of disabled veterans.
3.1.3.1 Disabled Veteran Program OPM requires all agencies to develop and have.in place a current Disabled Veterans Affirmative Action Plan (DVAAP). The NRC DVAAP, was approved by the Office of Personnel Management (OPM) on January 11, 1985.
As of May 31, 1985, the Agency employed 66 disabled veterans entitled to ecmpensation for disability or who had been released frem active duty because of disabilities.
- 3.1.3.2 Vietnam Era Veterans Although the competitive civil service has established several
~
special hirin~g authorities to facilitate the entry of Viettim era veterans into Federal service, NRC hires these veterans under its own excepted merit system. Approximately 292 staff members are Vietnam era veterans; these veterans account for about 8.7 percent of the total NRC staff.
i 3.1.4 Handicapped Program The NRC Affirmative Action Plan for Handicapped was updated and femally approved by the EDO on November 23, 1984.
During FY-1984 two new employees with targeted disabilities were hired.
During FY-1985 (as of July 15,1985), one new employee with such a disability had been hired. The number of NRC employees with targeted disabilities remained at 19 as of July 15, 1985.
During October and November of 1984, the NRC made serious efforts to upgrade and update the data base on handicapped employees.
The Agency canvassed the total NRC work force twice within two months, encouraging all employees to complete and return Standard Fom No. 256, "Self-Identification of Reportable
- Handicap." Approximately one-third of our employees responded, giving the j
Agency a more reliable data base on which to gauge future progress.
Recruitment efforts during FY-1985 included attending the Job Fair sponsored
.~
by the President's Comission for the Handicapped in May 1985.- We have also i
commenced discussions with the State of Maryland's Vocational Rehabilitation Center with the objective of participating in their student volunteer service program.
13 l
i j'
3.1.5 Hispanic Employment Program The Hispanic Employment Program (HEP) is an affimative employment program which places.special emphasis on the hiring, promotion, and retention of Hispanics.
l The program was established in 1970 as the Sixteen Point Program for Spanish Speaking Americans by Executive Order and was incorporated into the Federal Personnel System through FPM Letter 713-18 of January 23, 1973.
In 1978, I
1 the program name was changed to the Hispanic Employment Program.
l 4
HEP focuses on the underrepresentation of Hispanic Americans in the Federal employment sector comensurate with their availability in the i
civilian labor force.
Hispanic representation in the NRC workforce is about i
I percent.
l l
HEP is guided and directed by OPM.
Like other affimative employment programs, its accomplishments are evaluated by the EEOC.
In NRC, HEP is a collateral duty managed program; a. Hispanic member of the OSD80/CR staff is the HEP Manager (HEPM) for NRC; the HEPM attends meetings at OPM and conferences throughout l
the country where Hispanic issues and concerns are addressed.
In addition, the HEPM participates in recruitment activities directed tcward Hispanics and coordinates programs to increase awareness of Hispanic issues. Concerns for l
the representation and utilization of Hispanics are addressed in the " Report of Accomplishments" for Minorities and Women submitted annually to the EEOC.
~~
3.1.6 Part-time Employment Program
]
The Federal Employees Part-time Career Employment Act of 1978 (P.L.95-437) required Federal agencies to develop a program to provide part-time career employment opportunities to the maximum extent feasible.
In 1979, NRC published i
proposed management directives for its program for coment, and the directives 5
were published in final fom in 1982 as part of NRC Manual Appendix 4108, j
1 Annex 2.
As of May 11, 1985, a total of 152 permanent part-time staff
)
members were employed by NRC.
{
I i
Office Directors and Regional Administrators have established annual goals for part-time career employment in the Office / Region Staffing Plan prepared annually.
Additionally, selecting officials are required to review each position under their l
supervision as it beccmes vacant to determine the feasibility of filling it on
(
a part-time career basis; and NRC regulations provide information concerning part-time employment for employees interested in changing from full-time to i
part-time status.
)
I NRC has historically encouraged the use of part-time professional employees.
,j In addition, the program has been of particular value in the regions, where f
- part-time clericals are employed at many of the reactor sites to support Resident Inspectors.
In most cases, these positions provide employment to v
persons, primarily wcmen, who would otherwise be unable to enter the labor
{
market.
l l
l i
\\
14 l
I l
[
f 3.2 Affirmative Action Recruitment, Hiring, and Placement l
i NRC is constantly working to increase the representation of minorities, l
women, and the handicapped in positions where underrepresentation of these groups may exist.
l 3.2.1 Encouragement of Entry-Level Hiring Both the affinnative action benefits and other advantages of entry-level hiring l
are recognized within the NRC. The importance of entry-level hiring was given j
strong emphasis by the EDO when on March 11, 1985, he directed that during the remainder of FY-1985 and for FY-1986, 25 percent of all NRC outside hires
{
would be employed at the entry levels. This program is being carefully monitored by the Division of O&P; Regional Personnel Officers, and OSDBU/CR.
l As of July 3,1985, a total of 10 entry-level professional staff members had l
been hired during FY-1985. These included 5 white females and 2 male minority
}
group members.
i 3.2.2 Entry-level Recruitment Among the several protected groups, the availability of minorities and women l
~ ~1n most professional occupations appears to be measurably greater among those l
"at the beginning of their careers than among experienced applicants.
For this i
reason, more highly qualified women and minorities have expressed interest in j
joining NRC at the entry level. -To attract highly qualified women and cinority applicants, the NRC is attempting to fill as many positions as 1
possible at the entry level.
l t
Since its inception, NRC has conducted an active college recruitment program.
Emphasis is placed on colleges with a high quality engineering program and a good minority and female representation.
The FY-1985 College Recruitment Program included 32 visits to college campuses. Ten of these visits were to predominately minority schools. These visits included participation in 18 t
l minority or women campus job fairs.
j The " Student Inventory" of applicants for the Agency's entry-level engineering i
and scientific positions has shown the positive results of our recruitment.
I Of the 409 entry-level applicants who have been entered into the Student Inventory between October 1, 1984 and July 12, 1985, approximately 34 percent l
(141 applicants) have been either women or members of minority groups.
l t
j These applicants included:
95 women (including 7 Asian, 11 Black, and 3 Hispanic wcmen) l 1 American Indian male l
28 Asian males i
15 Black males i
2 Hispanic males ITT Total 15 j
i i
__ = -,- - - -,- -,, - - _ 2
{
J 3.2.3 Siring Eyperienced Staff Recruitment programs ave been increasingly successful in soliciting applications from experienced engineers and scientists who are women and/or members of minority groups.
Cf the 258 experienced applicants who have been entered into the Headq' carters Applicant Review System between October 1,1984 and July 12, 1985, approximately 28 percent (73 applicants) have been either women or members of minority groups. Thesa applicants included 12 women (including 3 Asian women) i 1 American 1ndian male.
a 52 Asian males
.i' 5 Hispanic males 3 Black males 7.T Total
! r ;.
In attempting to reach experienced workers,Wr. regularly advertises in national technical magazines and journals and in predominantly minority and women's magazines with technical readership such as U.S. Black Engineer, Society of Women Engineers, and Hispanic Engineer.
In addition to 1
attending meetings of; organizations such as the American Nuclear Society (ANS), NRC is either represented at or participates in technical society meetings conducted by minority and women's organi::ations.
i 3.2.4 Cocperativa Education Program
~
_,C j
l The NRC Co-op Program is aimed primarily at individuals pursuing degrees in engineering and scientific disciplines of interest to NRC.
There is an l
occasional requirement for Co-ops in non-technical disciplines.
FTE for this program is centrally funded and managed by OI.P.
I The Co-op Program can provide NRC with mincrities and women who can later j
become applicants for entry-level professional positions.
In FY-1985 a total i
ef 32 Co-ops were on NRC rolls.
These included 15 women (including 3 minority women) and 3 minority men; thus, 18 (or 59 percent) of the Acency's Co-op employees were protected group members.
Six of the NRC Co-op eeployees graduated in FY-1985. Two accepted offers with the Agency, one declined, one went to military service and two pursued further goals in higher education.
3.2.5 Review ef NRC Employment Practices
- The majority of NRC employment practices which impact affirmative action recruitment or advancement are covered by NRCM A108, " Employment," and NRCM 4130, " Position Evaluation and Pay Administration." Both these issuances have j
been revised within the past 3 years, and particular attention was paid during.
the revision process to ensure that none of the policies and practices created artificial barriers to the employment or advancement of minorities and women in NRC.
{
16 l
4 In addition, review of employment practices is an ongoing process.
Input and feedback from EE0 constituent groups, EE0 Specialists, and employees have been helpful in this process.
For example, the Labor-Management EE0 Committee has continued to stress the advantages of entry-level recruitment over recruitment of experienced personnel in furthering affimative action goals; the Committee has been an important influence in promoting these advantages among selecting officials and in locating minority candidates.
3.2.6 Qualifications Review and Analysis During FY-1985, the Division of O&P has conducted a special review of the The qualifications required in vacancy announcements for selected vacancies.
i purpose of the review is to assure that qualifications are not unduly restrictive and are related to the duties of the vacant position.
As of May 31, 1985, a total of 78 vacancy announcetgents had been reviewed. Thus far, ats a result of these reviews, four vacancy announcements have been reposted to more correctly state qualifications requirements and in the interest of assuring that requirements are not too narrowly drawn.
l 3.3 Development and Utilization of NRC Staff NRC training and development goals have been established to provide the maximum l
i
. feasible amount of both technical and scientific and non-technical train ng to the broadest spectrum of NRC employees.
NRC provides training to new employees cntering on duty, current professional employees so that they can stay abreast of technoingical developments, all employees to maintain and improve their l
l present jcb skills and knowledge, present and prospective supervisory, I
management, and executive personnel, and employees who need to be retrained as j
a result of reassignment.
t 3.3.1 Training Programs
(
l The Government Employees Training Act (P.L.85-507) authorizes agencies to i
train employees to enable them to better perfom their duties. The Management Cevelopment ar.d Training Staff (MDTS), ADM, is responsible for administering the i
Government Employees Training Act at NRC.
Consistent with definite needs which l
arise or are anticipated, employees are provided the opportunity to develop their knowledge, skills, and abilities to enhance their job performance and
}
prepare themselves for future duties.
Additionally, NRC provides opportunities f
)
for employees to acquire or update knowledge or skills necessary to maintain j
and improve NRC operations and to acquire kncwledge or skills necessary to perform newly assigned responsibilities or responsibilities which will be l
l assigned in the imediate future such as the next step on the career ladder of
(
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the employee's position.
1 f
Since 1977, NRC has conducted a femal Career Counseling Program which is new i
open to all employees.
Participation is voluntary, and the objectives of the l
counseling are to provide:
an increased awareness of skills, interests and aptitude; clarification of values and priorities; development of goal setting i
j abilities; understanding of obstacles to career planning; and understanding I
the process of career decisionrraking.
Over 1,000 NRC employees nationwide l
17 i
increased awareness of skills, interests and aptitude; 4
clarification of values and priorities; development of goal setting abilitie.s; understanding of obstacles to career planning; and understanding the process of career decision making. Over 1,000 NRC employees nation-wide have attended this program.
Since 1979, NRC has sponsored training under the Certified Professional Secretary Program.
Specifically targeted at Secretaries, the program requirements pennitted an expansion of the definition of " job relevancy." Courses in fields such as accounting, para-legal training, and economics, which are normally unavailable, are available in a modified program administered in association with the National Association of Secretaries.
In order to ensure that 'ali employees are awlire of the training opportunities available to them. ADM issues a Guide to Training Opportunities (NUREG/BR-0017) to all employees. In addition.
Training Announcements are distributed to all employees when new in-house training is made available.
NRC managers are given detailed course descriptions and schedules in order to ensure wide dissemination of training infomation.
3.4 Complaint Receipt and Processing There are well established, femal procedures for filing, receiving, and adjudicating complaints of discriminarfon.
Throughout the process, discussion and infomal problem resolution, where possible, are encouraged.
i 3.4.1 The Complaint Process NRC has 26 EE0 Counselors who are appointed by the Director, i
OSDBU/CR.
Sixteen are located in headqutrters and two in each l
regional office. The counselor is the first stop for an employee or applicant for employment who believes he/she has been discriminated against in some' aspect of his/her employment.
The counselor has 21 calendar days to attempt to reach an infomal resolution.
If the final counseling, interview is not ccmpleted in 21 days, the counselor must give written notice of the right to file a discrimination complaint any time up to 15 calendar days after the final interview.
If infomal resolution fails, the employee or appifcant may file a formal complaint with designated members of the OSDSU/CR staff.
In addition,
- bargaining unit employees may file a grievance under the negotiated grievance procedure.
NRC has developed an effective discrimination complaint investigation system based on a' system of contractor based investigations and reports. This approach permits a; full, independent review and T
18-1
investigation of complaints by trained investigators, not regular employees of the agency. After completing the investigation, the investigator presents the Director, OSDBU/CR, with a fully documented report. The Director, OSDBU/CR, forwards one copy of the investigation report to the complainant and one copy to a designated EE0 Officer for review, (nalysis, and an attempt at reaching an informal resolution.
If an informal resolution is agreed upon, the terms of the agreement are reduced to writing, and the matter is closed.
If informal resolution fails, the EE0 Officer issues a proposed disposition of the complaint based on the recommendation of the EE0 Officer and the Ofrector, OSDBU/CR.
If the complainant rejects the proposed disposition, he or she is informed of his or her rights under the law, including the right to a hearing before an EEOC examiner, the right to appeal any agency decision made in connection with the complaint to the EEOC Office of Review and Appeals, and the right to file a civil action in a U.S. District Court after 180 calendar days from the date the initial complaint was filed.
3.4.2 Analysis of Complaints NRC policy is to maintain a positive environment for the EE0 complaint process and to ensure that complainants and witnesses are free from reprisal er harassment.
Since its inception in 1975, the NRC has had a total of 50 formal EE0 complaints filed and accepted for processing under the regulations. Table 3.1 summarizes these complaints by the basis for each.
Overall, complaints based on race factors lead the list,, closely followed by those based on age.
Only 1.9 complaints remained open as of May 31, 1985.
Of the 31 complaints closed,19 were withdrawn after resolution satisfactory to the employee in 13 cases, 7 were cancelled by NRC after a finding of no discrimination, 4 were re,iected by the NRC, and I was cancelled by NRC for failure to prosecute.
In addition, data on informal complaints and contacts with EE0 Counselors is systematically collected and analyzed to spot potential problem areas and trends.
3.5 EE0 Training for NRC Staff Employees, supervisors, and managers need to be aware af the impacts of past discrimination on members of protected groups and be sensitive to potential discriminatory actions. More important, supervisors and managers need to knnw how to integrate the principles of affirmative action into their personnel decisions.
Accordingly, EE0 and affirmative action training has been and will continue to be provided for NRC staff at all levels.
3.5.1 Executive Training i
- Senior-level managers had not received formal EE0 training as a group since 1976, although EE0 topics had been included in many general management courses. This situatinn was addressed by means of two 1-day EE0 trainirg
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seminars conducted in May 1985.
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_ _ _ _, ~ _ _. _
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Table 3.1 Femal EE0 Complaints Filed at NRC 1975 through June 30, 1985 Basis Individual Class Total Age 11 1
12 Sex 8
2 10 Race 16 2
18 Race & Sex 2
2 4
Age & Sex 2
0 2
Race, Color &
1 0
1 National Origin Harassment 3
0 3
Totals 43 7
50 Source: OSDSU/CR l
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3.5.2 Employee Orientation and Awareness Semiannually, MDTS conducts orientation training for all new employees. Representatives from selected NRC offices, including OSDBU/CR, describe their primary functions, and in the case of OSDBU/CR, their EE0 program responsibility. The OSDBU/C4 supports various functions of special emphasis groups anc' comittees, such as the Asian / Pacific American Heritage kek; Black History Month; and the Hispanic Heritage Week.
Each year OSDBU/CR makes funds available to each special emphasis group for use on special activities-as needed.
3.6 EE0 Planning Implementation, and Review NRC has a centralized tystem for EE0 planning.
However, program implementation is carried out by several EDO staff offices working with individual headquarters offices and regions.
3.6.1 Review of Program Planning Within NRC, OSDBU/CR has the principal responsibility for EE0 program planning.
The objective of the EE0 planning process is to provide NRC with a systematic approach for establishing affimative action plans and goals.
In turn, these plans are designed to be integrated into the ongoing management and personnel process.
3.6.2 Program Implementation Once EE0 plans and affimative action goals are established and approved by the Comission and the EDO, staff offices such as OSDBU/CR and ADM are responsible for-developing specific programs and activities for achieving the goals and then.
monitoring achievement of those goals.
Ultimately, individual managers and i
supervisors are the focus for the implementation of NRC EE0 and affimative action programs through their day-to-day personnel decisions.
3.6.3 Reporting Responsibilities O&P provides the basic perscnnel data needed by OSDBU/CR, ADM, the EDO, and the Comission to prepare, operate, monitor and evaluate EE0 programs.
In turn, j
OSDBU/CR has the principal responsibility for analyzing data and submitting reports.
3.6.4 Reports to NRC Management Based on data from O&P, OSDBU/CR prepares information to provide NRC management with an assessment of the effectiveness of EE0 and affirmative action i
initiatives and to show long-tem changes in EE0 conditions.
Reports to NRC management are usually made in conjunction with the ~ preparation of formal
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l reports to the EE0C and other agencies rather than on a recurring internal cycle.
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i 3.6.5 Reports to Other Agencies All Federal agencies are required to prepare and submit to the EECC a yearly l
Affimative Action Plan containing goals and accomplishments.
In addition to this report, NRC also prepares and submits program-specific reports on the various affimative employment l
Affirmative Action Plan (DVAAP) programs such as the Disabled Veterans for disabled veterans.
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3.6.6 Status of Reporting Systems t
NRC analysts and managers use a combination of automated and manual systems to l'
record EE0 related data.
3.6.6.1 Automated Personnel System The Automated Personnel System (APS) maintained by the Division of Organization and Personnel (0&P) is the principal source of EE0 data for the NRC.
Identification of minority group membership and handicapped status is based on i
t amployee self-identificatinn. Data on sex and age is based on OSP review of i
official employment records. The system builds a transaction history file which l
provides the data from which analysis of employment trends can be undertaken.
In addition, the system produces a number of pre-formatted reports analyzinp the j
corpnsition of the NRC workforce, j
The current APS is en excellent system for capturing and storing data reouired i
for EE0 analyses; during the period October 1,1984 thrcugh July 31, 1985, the Division of O&P produced 62 EEO-related reports. The availability of micro-computers new makes it possible to transfer, manipulate, and format this data.
3.6.6.2 Manual Reporting Systems Labor-intensive manual systems are now used to collect selected data on i
applicants for NRC employment and to track them through the employment process.
A significant percentage of training and development data is maintained manually.
1 3.7 Management Accountability for EE0 Accomplishments r
Individual supervisnrs and manapers have the ultimate respnnsibility for the success or failure of achieving EE0 program objectives, and will be held accountable for performance in meeting the Agency's EE0 policies and ob.iectives.
l 3.7.1 Authority and Accountability
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- The head of each agency, or his desionee, has the responsibility for l
establishinp, maintaining, and carrying out a continuino affimative i
action propram.
After tne proposed hirino goals and other
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'y
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affirmative actions are approved by the Chairman, #tay are formally transmitted to Office Directors and Regional Administrators by.he EDO. OSDBU/CR then provides the EDO and the Chairman with assessments of management EE0 activity based on reports submitted by individua~1 offices and review of data submitted by 0&P.
3.7.2 EE0 and the Performance Appraisal Process The EE0 accomplisnment report submitted annually by Office Directors and i
Regional Administrators to OSDBU/CR is analyzed in order to provide the EDO and the Chairman information regarding the performance of managers and supervisors in achieving their assigned goals, in addition, the Director, OSDBU/CR has been appointed as a non-voting, ex officio, long-term member of the SES Performance Review Board.
Under = current NRC performance appraisal systems, both SES and non-SES managers and supervisors must be rated on their EE0 performance as a part of their overall management effectiveness.
Rating officials evaluate EE0 performace as part of the aporaisal process. While both OSDBU/CR and ADM now provide input to the parformance rating process for Office Directors and Regional Administrators, the EE0 effectiveness of lower-level managers and supervisors is generally not assessed as systematically.
3.7.3 EE0 as a Factor in Reccgnition and Awards The NRC Equal Employment Opportunity' Award is presented to employees for outstanding achievements or contributions in furtherance of the NRC EE0 Program. The award is approved by the EDO and presented during the Annual Incentive Awards Program.
Since 1977, nine, or 45 percent, of these awards
.have been to supervisors and managers in recognition of their EE0 accomplishments.
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4.
ASSESSING THE FY-1985 NRC EE0 PLAN The Office of Small and Disadvantaged Business Utilization / Civil Rights has the lead for monitoring the implementation and assessing and reporting the
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accomplishments under NRC's FY-1985 Consolidated EE0 Program Plan. The following sections review the actions taken by the organizations having responsibility for the implementation of actions under the FY-1985 Consolidated EE0 Program Plan.
4.1 Division of Organization and Personnel The Federal Equal Opportunity Recruitment Plan (FEORP) and an Affimative Action Plan for the Handicapped were completed by O&P and approved by the EDO on October 23, 1984.
A Disabled Veterans Affimative Action Plan was prepared by O&P and approved by the Office of Personnel Management (OPM) on October 23, 1984.
Thirty-two colleges and thirteen job fairs or conferences had been visited by March 4,1985, including six events sponsored by minority or women's organizations.
FY-1985 vacancy forecast for professional occupations with 100 or more employees were made and enlarged to include three additional professional occupations with 50 or mere employees.
Disabled veteran employees were identified.
i An announcement concerning the benefits of part-time employment was published by s
the Director Division of Organization & Personnel.
A poll pertaining to entry-level hires in FY-1985 was taken.
i A system for following up on students contacted by NRC was devised and a i
transmittal was published providing guidelines for recruiters.
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05P has aimed to review 5 percent of all NRC positions during FY-1985.
By f
the third quarter of FY-1985, 346 positions were reviewed.
j l
O&P is currently conducting an impact analysis of qualification requirements by having an O&P Review Board analyze vacancy anncuncements.
l l
Individual memos were sent to employees, inviting educational updates in order to conduct a review of the APS data base regarding education. Approximately
'3000 responses were received and the data base has been updated.
l In order to update the' handicap data, announcements were sent to all employees invitint updates. Approximately 1200 responses were received and data input has been completed.
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^l EE0 related matters were included in the Sumer and Fall issues of " News, Reviews & Coments."
4.2 0FFICE OF SMALL AND DISADVANTAGED BUSINESS UTILIZATION / CIVIL RIGHTS 4.2.1 Civil Rights Program Quarterly meetings with Headquarters EE0 Counselors were started successfully.
EE0 Counselors provided quarterly statistical reports.
EEOC official made presentation to EE0 Counselors on " Handicap Discrimination."
i Several one-day EE0 seminars for Office Directors and Regional Administrators were conducted at NRC by USDA Graduate School instructors.
Meeting with EEOC personnel was held for discussing methods to improve the discrimination complaint process and to obtain updated infomation on EE0 counseling and discrimination complaints.
All complainants with active discrimination complaints were contacted in order to discuss the status of their cases.
In order to obtain accura'.e inf'omation on the availability of women and i
minorities in the engineering and scientific Civilian Labor Force, a contract was awarded to the U.S. Department of Energy and Oak Ridge Associated Universities who developed the data.
Underrepresentation deteminations were prepared for pr'ofessional occupations with 50 or more incumbents.
l Hiring goals for minorities and women were established and transmitted to Office Directors and Pegional Administrators.
An Hispanic Employment Program Manager and Black Affairs Coordinator were appointed on a collateral basis.
Th( FY-1985 Affirmative Action Plan was prepared and submitted to the EEOC.
4.2.2 Federal Wcmen's Program In con.iunction with MDTS and the Regional FWP Coordinators, the FWP conducted Individual Development Plan (IDP) seminars in the Washington Headquarters and three Regional Offices.
The FWP Manager met with the Regional Administrators and Office Directors and their staff members, providing guidance and assistance aimed at improving emplo.yment opportunities for.NRC women.
In conjunction with the FWPAC, the FWP sponsored awareness programs and conducted Lunch and Learn programs for all employees addressing such issues as SF-171 Preparation, Networking, Mentoring, Why Should I Hire You, interviewing Technioues, A Man's View of the Women's Program, Time and Stress Management, and more.
25 i
l.
i The FWP developed, published, and provided FWP brochures to O&P for use in the orientation packet. These brochures were distributed to all regions and are i
given to all new women employees.
The FWPM prepared seven articles pertaining to women in the NRC News, Reviews, and Comments Newsletter.
l The Agency hired two women for SES positions and several others for supervisory and managerial jobs.
j t
Regional FWPCs were made members of the EE0 Advisory Comittee in their regions and provided input to their regions operating plan.
[
t Career counseling for women was made a focus by the Regional FWPC of those receing this assistance, the majority were women.
In Region II this program was reactivated and it was extended in Region V.
The FWP conducted exit interviews with cooperating wemen leaving NRC.
I 4
The FWP assisted O&P in recruitment activities by personally participating in job fairs, recomending participation and suggesting recruiting areas that
(
could produca more minorities and women.
The FWP provided individual counseling to women concerning child care, career planning, performance, and cther issues affecting their employment.
t The FWP was also instrumental in informal resolution of EE0 complaints.
l f
4.3 Upward Mobility 3
NRC has established a revised Upward Mobility Program (UMP) to provide f
developmental opportunities to lower-level employees. This program was i
published on November 9, 1984, as Part VI of NRC Appendix 4150 Employee Development and Training.
The program focuses on selection of those employees who show potential to function effectively in professional or paraprofessicnal positions with greater growth potential.
l Thus far during FY-1985 six upward mobiilty positions have been announced i
throughout the Agency.
These are:
I I,
i Contracts Management Trainee, GG-5/7 (ADM) l Personnel Management Specialist GG-5/7 (RII) l InspectionAssistant,GG-6/7(RII)
Administrative Aide, GG-7 (NRR)
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i Emergency Preparedness Specialist, GG-7 (RIII) l Records Holding Specialist GG-5/7 (ACM) j 1
Additional upward mobility vacancies are anticipated as FY-1986 office and
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regional staffing plans are developed, approved, and implemented.
f I
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4.4 Goals Obtained As of July 31, 1985, our success in meeting FY-1985 goals was as shown below:
Total Actual Hires Other Hires In Occupation Office FY-85 Goals Meeting Goals Targeted Series Nuclear Engineer, NRR 2 Asian Males 2 Asian Males 1
GG-840 IE 2 Asian Males 1 Asian Male 3
General Engineer, NRR 1 Hispanic Male None 6
GG-801 IE 1 Black Male None 8
Security Administrator ADM 1 White Female 1 White Female None GG-080 NMSS 1 White Female 1: White / Hispanic Female 3 Attorney, GG-905 OGC 1 White Female None 2
ELD 2 White Females None 1
D I
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5.
FY-1986 NRC EE0 PROGRAM PLAN 5.1 Overview t
NRC has a wide range of EE0 and affirmative action programs. These programs are augmented by individual offices and managers providing opportunities for staff development. Continued evaluation of these activities is one aspect of l
the FY-1986 Plan. The FY-1986 Plan also includes program elements that are l
. intended to assure greater accountability by NRC managers for EE0 performance.
i' NRC has the necessary basic structure in place to achieve EE0 program goals.
The activities themselves are result-oriented and systematically monitored against specific ambitious, yet achievable, objectives. Managers and l
I supervisors will continue to be made aware of their EE0 responsibilities, Plan accomplishments, and to be held accountable for proper implementation of their EE0 responsibilities.
1 i
In FY-1986, NRC staff will continue to develop and implement the full range of affirmative employment programs now in place.
Ccliege recruiting will l
continue at a high level and will be focused on colleges and universities which are productive of entry-level protected group applicants. Job related training offering potential for personal and professional development will i
continue to be offered and approved as funds permit.
i During FY-1986, NRC will continue to place more attention on developing.and j
utilizing the skills of its present staff as a proven means of achie'ing EE0 v
i and affirmative action goals;
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.i i
Operation of an Upward Mobility Program will be an important part of the FY-1986 EE0 Program Plan. The upward mobility procram for FY-1986 will be j
i increased from 6 to a goal of 15 participants, as long as this can be i
accomplished within budget constraints.
NRC will continue to design programs to increase opportunities for staff
[
development consistent with long-term NRC mission objectives and i
funding availability; Qualifications analysis will continue to'be examined to ensure that only job related requirements are used in merit selections. The Division of O&P will continue to conduct a review of each vacancy before an announcement is issued I
to ensure that the qualifications requirements fit what is needed to do the job and are stated in a way that enhances opportunities to recruit from available pools of special emphasis candidates.
O&P will report to the Ccmmission on whethe'r their reviews disclose a pattern of unduly restrictive
- qualifications requirements in the Agency as a whole or in individual prngram offices; l
I Regional EE0 Coordinators advise Recional Administrators on EE0 and affirmative action matters; l
28 i
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_ ___ _ ___. ___ ~ _
EE0 program evaluation and reporting will be enhanced in.
1986; individual projects and activities will be tracked throughout the year, and accomplishments i
r will be judged against planned outcomes in quarterly (management reviewsEDO) and sem conducted for the Executive Director for Operations briefings to the Comission; Emphasis will be placed on comunicating EE0 and affirmative action goals to i
top agency managers and working with these managers to formulate realistic EE0 goals for each headquarters office and region; EE0 effectiveness will be a more visible factor in assessing the overall '
t management performance of top NRC managers; j
NRC staff will continue to develop and implement the affirmative employment j
programs now in place; College recruiting will continue to emphasize those colleges and universities i
with significant minority and women student populations; j
Training offering potential for personal and professional development will i
continue to be offered with new emphasis on developmental opportunities;-
l i
EE0 training for new supervisors and managers will be continued in FY 1986; Employee awareness programs such as Black History Month, Hispanic Heritage Week, I
l and Women's Equality Day will be supported; t
The Comission will hold semiannual meetings on the EE0. program.
The l
Comission will hear from the OSDBU/CR, the EDO, and EE0 Advisory Comittees i
at these meetings. The EE0 Advisory Comittees will have the responsibility i.o report periodically to the EDO on EE0 policies, programs and progress and j
during the semiannual briefings to the Comission directly.
l In order to present a professional analysis regarding Agency EE0 policies and procedures, the briefing should focus on presentations by the Directors of
)
05DBU/CR and ADM who are tasked with relevant aspects of. the EE0 program.
l l
These Office Directors will reflect input from all committees in formulating l
l the content of the briefing.
l l
Although fonnal complaint processing is not a major factor in the NRC EE0 i
program, EE0 Counselors will continue to be used to identify potential l
prnblems to NRC management before employees seek counseling. Accordingly, in FY-1986 activities are planned to make use of the insights of EE0 Counselors l
while enhancing their status.
Individual pro,iects and activities will be tracked throughout the year, and i
accumplishments will be judged against planned outcomes in quarterly l
management reviews conducted for the Executive Director for Operations and l
biannual reports to the Commissior.
i l
29 i
l.
i i
The FY-1986 Consolidated EE0 Program Plan will place emphasis on communicating EE0 and affimative action goals to top Agency managers, working with these managers to fornulate realistic EE0 programs for their offices, and then judging results using performance appraisal mechanisms.
5.2 Federal Woman's Program The Federal Wocan's Program (FWP) in FY-1986 will continue to provide a system of comunicaticn between the Regions and Headquarters, and to provide timely feedback to managers and supervisors on the FWP.
IncoordinationwiththeManagementDevelopmentandTrainingStaff(MDTS).
ADM, the FWPM will continue to encourage NRC women to prepare Individual Development Plans (IDP). The FWP will continue to assist MDTS in implementing and evaluating the Upward Mobility Program.
The FWPM will be available to counsel women employees in the program and will assess its overall impact on wcmen throughout FY-1986.
The FWP and the FWPAC will continue to sponsor awareness programs for all employees and provide assistance and advise to management on all matters concerning employment of women in NRC. A continuous assessment of the way NRC does business (both in-house) and its impact on EE0 for women will be the primary focus of the FWP for FY-1986.
5.3 Federal Equal Opportunity Recruitment Program The NRC Federal Equal Opportunity Recruitment Program (FEORP) program provides a framework for detemining those occupations in NRC which have underrepresentation of minorities and women when compared to the same occupations in the civilian labor force; and for setting goals to overcome underrepresentation.
5.3.1 Underrepresentation Determinations Equal Employment Opportunity Comission (EEOC) guidelines currently require using Civilian Labor Force (CLF) data supplied by OPM for underrepresontation determinations.
CLF data may be misleading with reference to NRC mainstream engineering and scientific positions for the following reasons:
the data reports minority and women representation in all professional occupations combined, which is widely at variance with their representation in NRC mainstream occupations; the data includes non-citizens, who can only be hired by NRC under very unusual circumstances; the' data includes all persons age 16 or older while persons under age 22 are rarely qualified for NRC mainstream occupations.
In FY 1985, NRC contracted with the U.S. Department of Energy
- and Oak Ridge Associated Universities to develop specific information pertaining to the representation of Engineers and Scientists in the workforce.
This information was used to make the underrepresentation deteminations for FY-1985 and will be used in subsequent 'deteminations.
This project was managed by the Office of Small and Disadvantaged Business Utilization / Civil Rights (OSDBU/CR) with coordination and support from O&P.
30
Following completion of the CLF analysis, NRC will continue to make revised I
determinations of underrepresentation for all professional occupations in NRC with more than 50 employees for which hiring is anticipated in FY-1986.
Because these occupations represent the most populous occupations in NRC, and because they also provide generally goed opportunities for advancement and for movement into supervisory and management positions, it is important that i
underrepresentation in these occupations be the focus for future affirmative action programs.
5.3.2 Vacancy Forecasts for NRC's Most Populous Occupations O&P,' Regional Personnel Officers, and line managers will forecast FY-1986 1
vacancies to be filled in those professional occupational groups with more than 50 NRC employees.
The vacancy forecasts will allow realistic affirmative action hiring and internal placement goals to be set.
The forecasts will be completed i
by October 31, 1985 by O&P in coordination with all headquarters offices and l
the Regional Offices.
5.3.3 Hiring Goals for Minorities and Women l
)
i Based on vacancy forecasts, and anticipated recruitment activity OSDBU/CR l'
staff will set goals for the hiring and placement of minorities and women in target occupations.
Goals will be set not later than one month after.2 the NRC-based underrepresentation determinations have been made end priorities assigned, or not later then November 30, 1985.
OSDBU/CR, with assistance from O&P, will take the lead in assisting individual offices and regions in accomplishing their FY 1986 hir,ing and placement goals.
i 5.3.4 Programs for Veterans During FY-1gS6 NRC will continue affirmative action efforts aimed at hiring i
veterans.
Preference for veterans will be enforced and recruitment liaison with j
veterans' groups will be maintained.
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i 5.3.5 Handicapped Program l
l The O&P staff and Regional Personnel Officers will maintain and refine
(
contacts with local and state vocational rehabilitation sources.
l The Employment Programs Section. O&P, in reviewing proposed personnel policies l
and procedures, will ensure that they do not create barriers for handicapped j
i individuals or discourage the handicapped from applying for employment.
This l
will be an ongoing activity throughout the fiscal year as new policies and i
procedures are proposed.
Potential problems and barriers will be discussed with i
- the Policy and Program Development Branch O&P.
i 5.3.6 Hispanic Employment Program As in prior years, an all-employee bulletin describing Hispanic Heritage Week l
will be prepared and distributed.
In addition. Headquarters employees will be encouraged by the HEPM to join in the observance of Hispanic Heritage Week.
l 31 j
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During FY 1986 the Hispanic Employment Program Manager (HEPM) will accompany OSP staff on recruiting trips to colleges and universities with clusters of Hispanic students. The objective is to solicit applications for employment from Hispanics in order to increase the representation of Hispanic professionals in the applicant pool.
1 5.3.7 Part-time Employment Program Part-time career employment is often particularly attractive to women, older, or handicapped individuals, students, and parents with family responsibilities.
5.3.7.1 Identification of Part-time Career Positions for FY-1986 Through their staffing p'lans,-Office Directors and Regional Administrators identify positions to be utilized during the fiscal year for part-time career employment. Part-time positions are identified both at the time of original submission of the staffing plan and during the year as plans are modified.
Position descriptions for part-time jobs are furnished at the time when 1
I recruitment is started.
Again in FY-1986, O&P will publish an NRC anouncement for all employees explaining the benefits of part-time employment and encouraging both employees and supervisors to consider this alternative.
0&P will include the number of i
l part-time positions in quarterly EE0 program reviews for the EDO.
5.4 Affirmative Action Recruitment Hiring, and Placement Affirmative action is an integral part of personnel management and cannot be l
separated from day-to-day recruitment efforts.
In FY-1986, special emphasis l
wil be placed cn entry-level hiring.
5.4.1 Cooperative Education Program
{
The Cocperative Education Program will be continued curing R-IT:~ w!'.h a t,W of 6 FTE staff years devoted to Co-ops. The Agency anticipates that 12-14 students will be employed under this program during the fiscal year.
5.4.1.2 Campus Recruit =ent Effective, aggressive recruitment on college campuses is a critical l
prerequisite to entry-level hiring of minorities and women.
This will include initial pre-visit contacts with college placement offices to provide them with f
l information about NRC and Federal employment and follow-up centacts after
/
tecruitment visits. NRC staff members who graduated from schools to be visited will be used as resource personnel for both pre-visit and follow-up contacts.
During FY-1986, the NRC on-campus team will include a Personnel Specialist and one or two technical staff members; when feasible, OSDBU/CR staff will join the team.
0&P will use a tracking system to ensure follow-up through the schools
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to students contacted during the visits.
32 l
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NRC will visit approximately 28 to 32 colleges and universities during the 1985-l 1986 school year. The ob.iective is to increase the number of minorities and women interviewed. The Staffing and Position Evaluation Branch, 0&P, will be j
responsible for managing this activity with support from individual headquarters i
l offices and regions.
5.4.1.3 Job Fairs Participation in minority and women job fairs broadens the applicant pool and 4
l specifically increases the number of minority and women applicants for NRC positions. The NRC team at job fairs will consist of a Personnel Specialist l
and one or two technical staff. NRC will participate in approximately 10-15 cinority and women job fairs throughout FY-1986 to solicit completed l
applications. The Staffing and Position Evaluation Branch, OSP, will manage i
this program with the assistance of staff from individual headquarters offices l
and regions.
l 5.4.2 Advertisement l
NRC will continue to advertise in national technical magazines and journals such l
as Nuclear News and Power and in predominantly minority and women's magazines with a technical readership base such as Society of Women Engineers, Hispanic Engineer, and U.S. Plack Engineer. Minority newspapers having sufficient circulation to attract qualified applicants will also be used as advertising sources.
NRC will also continue to advertise in meeting and conference programs published by minority and women's engineering and technical I
organizations.
j It is difficult to capture data on how many applicants s"ubmit resumes to NRC as a direct result of such advertising; however, experience shows that an overall increase is apparent when such advertising is regularly used.
5.4.2.1 Attendance at Technical Society Meetings s
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A: 9 ;nv4m yurs. NRC staff will attend meetings of groups such as the American Nuclear Society (ANS) and the riealch Physics Seelety.
In :dditi:n, j
NRC will be represented, and participate as appropriate, at four technical society meetings conducted by minority and women's organizations in FY-1986.
i l
The recruiting team at all meetings will include a technical staff member and will make initial contact and conduct interviews. The objective will be to receive more applications from attendees who are members of protected groups.
l l
TheStaffingandPositionEvaluationBranch,0&P,willmanagethisactivitywith j
,oa ticipation from technical offices and regions.
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5.4.3 Job Analysis and Restructuring i
Job analysis and restructuring will be used to broaden occupational designat' ions j
and qualification requirements.
Such changes broaden the' applicant pool and allow for a greater number of candidates to be considered for positions.
NRC has expanded occupational series coverage in the past, most notably for Project Manager positions in NRR and NMSS and Inspector positions in the regions by l
using mnre general occupational series.
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l 5.4.3.1-Long-Range Cyclic Review i
The Staffing and Position Evaluation Branch, OSP, will continue its review j
of 5 percent of all NRC positions during FY-1986.
Special emphasis will be placed on identifying opportunities for job restructuring which would enlarge the available talent pool to include more minorities and women.
Throughout FY-1986, the Staffing and Position Evaluation Branch 0&P, and
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Regional Personnel Officers will review each recruitment request for potential' job changes in order to expand series coverage.
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5.5 Development and Utilization of NRC Staff 2
l Employee development has a critical role in aiding NRC to attract, develop, and retain capable employees.
NRC recognizes the key role that training and development plays in its EE0 and affimative action effort. Training and i
development programs and activities will be emphasized again in FY-1986 to i
achieve EE0 and affirmative action goals.
The Comission intends to take the broadest pemissible interpretation of the Comission's authority to provide additional training to qualify employees for i
advancement into other career paths within the Agency.
Further, in providing training, the training office will apply the broadest interpretation of the Comission's authority to provide additional training to cJalify employees for advancement into other career paths within the Agency.
j 5.5.1 Upward Mobility NRC has established a revised Upward Mobility Program (UMP) to provide develop-l mental ooportunities to lower-level employees which will eventually qualify participants for administrative or technical positions within the Agency.
A j
l goal of 15 upward mom iity positions are anticipated during FY-1986 depending l
on budget contrainti.
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The Upward Mobility Program envisions progression through paraprofessional i
towards a professional towards a professional career; however, each upward l
mobility position can provide assistance in making only a limited number nf i
steps on that career path.
Each upward mobility position is established with i
a target grade to which the employee selected can advance after training and l
on-the-job experience. Licensing Assistant positions, for example, do not j
offer career potential beyond the GG-11 level, slobs that are paraprofessional i
in nature generally can not offer a direct bridge to professional engineerinc or scientific positions with the rigorous academic qualifications, because the credential recuirement for these professional positions can not be
- overridden.
It is up to the individual to provide him/herself with the recessary credentials via continuing education or training to move into these kinds of professional slots.
The Upward Mobility Program is intended to offer assistance in this process but it is not* intended to supplant required credentials.
The managers of the Upward Mobility Program will work with the Training i
Prnerams to define the potential of each upward mobility position for career l
advancement.
The limits of each upward mobility program career ladder will 1
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be delineated. The possibility of forward linkages with relevant higher level career ladder will be detailed. The credentials required for progressing l
beyond the current ladder limit in related fields will also be identified.
The Training Office will provide as much training and counseling assistance as possible to upward mobility program participants to enable each to realize i
his/her upward mobility program and career goals.
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The ED0 will review what grade caps exist for the 15 Upward Mobility positions to make sure that they meet the overall upward mobility objectives. A significant number of the Upwardly Mobile positions should be in disciplines which, with NRC-sponsored training, can lead up career ladders to genuinely professinnal positions.
A revised NRCM 4150 Part VI, Upward Mobility Program, has been approved and j
publicized to all NRC employees.
)
5.5.2 '
Increasing the Use of Individual Development Plans l
An Individual Development Plan (IDP) is an individually tailored plan 1
established between a supervisor and an employee outlining the employee's i
short-term and long-range career objectives and the means, such as formal training, on-the-job training (0JT), or developmental assignments, for achieving t
'these objectives within certain time frames. The purpose of an IDP is to I
increase the current proficiency, development, and progression of the employee through a systematic training plan. An IDP provides the best means of planning
.i a developmental program which both satisfies Agency needs and concentrates on an individual's total developmental requirements. The IDP documents the reasons for engaging in developmental activities; indicates what developmental i
)
objectives are to be achieved; lists specific activities which are to occur; and outlines the time frame for implementing the plan.
l NRC is encouraging every employee to develop both short-term and long-range development goals and to pursue self-development activities.
Emphasis has been added by the EDO in his Annual Program Guidance. However, the fact that training and development activities are identified on an IDP cannot be seen as j
either formal NP.C approval or authorization to undertake them.
I Implementation of the plan must be in accordance with the provisions established in Manual Chapter 4150 "Emplovee Develcoment and Training.-
Simply including a developmental activity on an IDP does not validate the legality and authority for the activity; it must still pass the tests imposed by law and regulations.
Preparation of IDP's is (ncouraged, but optional; except they are required for j
employees in femal training and 4tvelopment programs such as UMP or the NRC i
l Intern Program. MDTS has developed and published an employee guide for individual development planning which was issued to t.11 employees; it also j
included specific infomation on designing developmental assignments.
IDP's are i
most effective when developed in discussion between supervisor and employee, and
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their contents are related to improved performance.
The counseling and performance appraisal can be conducted at the same time. When remindino headquarters offices and regions of the timetable for submitting appraisals, i
0&P will note the desirability of concurrently preparing IDP's.
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5.5.3 Supervisory and Management Development for NRC Employees NRC has extensive supervisory and management development programs and activities i
for its current staff members. Supervisory development training has been made mandatory for all new supervisors and soon to be supervisors. The programs utilize a systematic approach to developing non-supervisory and supervisory i
personnel and are based upon current and long-term human resource needs of the Agency. Through these programs NRC managers and supervisors receive training in personnel management and development responsibilities, including their EE0 and affirmative action responsibilities. They also provide the pathway for upward movement through the organizational structure.
i 5.5.3.1 Pre-supervisory Orientation Program I
Most minority and women employees are not supervisors or managers. Many of these employees, as well as other non-supervisory NRC staff, have expressed a desire to pursue career goals leading to a supervisory position.
In recognition of the need for orienting NRC employees about supervisory career opportunities, i
a " Pre-Supervisory Orientation Program" (P-SOP) was developed in FY-1983. The j
objectives of the program are to provide career guidance and orientation toward an understanding of the supervisory role within NRC.
The P-SOP is open to all non-supervisory employees by their self-initiation and consists of two parts:
Part I is a self-study correspondence course designed to provide an appreciation of the supervisory role; and Part II is a group orientation for j
those completing Part I and designed to clarify individual career goals.~
The P-SOP had 365 participants in FY-1983.
In the FY-1984 program there were j
225 participants.
During FY-1985, 225 individuals were enrolled. MOTS j
announced the P-SOP in June 1985. One hundred and fifty-one employees applied and were enrolled in the third session.
i 5.5.3.2 Supervisory Development First-level and second-level supervisors are an integral part of the NRC management team.
Emphasis on the training of supervisors is important since j
they are the ones who implement policies at the working level and have the most innediate contact with the employees who produce the organization's output.
I 5.5.3.2.1 Supervising Human Resources Course The Supervising Human Resources Course (SHR) is the core course for first-level j
and second-level supervisors.
The content of this five-day program includes j
such aspects of supervision as role definition, planning, leadership style t
identification, motivation techniques, consnunications and interpersonal j
' relations techniques. This course was initiated in FY 1983.
The SHR course util be offered several times in FY-1986 as part of the mandatory Supervisory i
l Development Program.
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36
o In soliciting nominations, MDTS will ensure that supervisors in protected groups are made aware of the availability of this course thrcugh the issuance of an "All Employees" announcement in conjunction with the schedule of in-house courses.
1 5.5.3.2.2 NRC Management Workshop i
j The Management Workshop has been redesigned as a follow-up activity to the SHR course. The Workshop enables managers to evaluate 'nd analyze their current a
managerial effectiveness and practices.
It is suggested participants complete i
the Workshop six to twelve months after the SHR course. The Management Workshop will again be offered twice in FY-1986.
In soliciting nominations, MDTS will ensure that supervisors in protected groups are made aware of the availability of this course through promulgation of an "All Employees" announcement issued concurrently with the in-house course schedule.
4 5.5.3.2.3 Continuing Supervisory Education I
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Supervisors have a responsibility to continue their development and performance improvement through training courses as well as on-the-job experiences.
Continuing aducation courses may include those provided by OPM at the Executive r
Seminar Centers and other selected government and non-government training and j
development, experiences.
l NRC will offer specific continuing educational development programs at the OPM i
Exacutive Seminar Centers and at othcr institutions in FY-1986.
Approximately
]
40 spaces are planned at OPM Executive Seminar Centers.
Complete schedule and space allocation listing will be published by OPM in August 1985, at which time i
MDTS will advise agency nominees of their acceptance into the program.
Prior to l
developing the final list of those who will attend in FY-1986, MDTS will review the total list of nominees to ensure appropriate representation of protected groups.
}
5.5.3.3 Executive Leadership Program 1
i This 1984-85 program was established by the Office of Personnel Management j
(OPM) for women employees GG-9 through GG-12 to create a source of capable and trained wcmen to enter supervisory and management positions.
NRC has monitored the program throughout its first year and has found it feasibile and desirable to conduct a similar, limited, in-house NRC program in FY-1986.
The scope of the in-house program will be expanded to include both men and women employees, GG-9 through GG-13, to enable more employees to apply.
5.5.3.4 SES Candidate Development Program The purpose of this program is to develop executive competencies in Agency
[
employees with high potential to become managers in order to create a pool of
(
employees who are SES-certified and available to fill newly created or vacated l
i SES positions.
A number of women and minorities have been selected to 37 i
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participate in the program as a precursor to entering the SES. Based upon a forecast of SES vacancies and the number of employees in the SES pool, the Agency solicits application for the SES Candidate Development Program from employees in grades GG-14 and GG-15.
Employees nominate themselves and participants are selected by a panel appointed by the Chair, Executive Resources Board. The program is part-time, participants remain in their current jobs, and complete an approved IDP over a 2-year perind. The Program content and procedures are directed by OPM rules and regulations.
NRC has correnced a third SES Candidate Development Program during CY 1985-87; and 15 employees were selected.
5.5.4 Administrative / Clerical / Assistant Job Development Federal statute's and regulations permit the head of an agency full latitude to provide programs directed at improving individual performance for mission accomplishment, at improving organizational effectiveness, and at complying with statutes and Executive Orders.
In administering the NRC training and development program, EF0 responsibilities suggest the need to establish a broad development program targeted generally at the lower-grade levels in the administrative, clerical, and " assistant" job series, where the career ladder progression is more limited in comcarison to employees in technical job series. By instituting such a progrant, the agency should be able to broaden the spectrum of available training vis-a-vis the strict job relevancy restrictions.
An Administrative / Clerical / Assistant Development Program was developed in FY-1985 by MDTS. The program includes three separate components:
continuation of the Certified Professional Secretary Program; a Computer Science Development Program; and an Administrative Skills Enhancement Program.
Application for entry into any one of these programs is open to all NRC employees who meet established written elioibility criteria.
Career Counseling will continue to provide for career orientation development and a new in-house "NRC and Its Environmant" course, in the development stage will provide for NRC orientation.
MDTS submitted to E00 in May 1985, a fully developed concept of the three I
proqrams under this heading.
MDTS intends to implement the programs in FY-1986.
5.5.5 Secretarial and Clerical Development Program Secretarial and clerical employees are generally subject to heavy l
workload pressures that normally lead to restrictions on time available to obtain training or advance their career prospects.
MDTS has created a more structured, cohesive, and beneficial program of development of important skills for secretarial and clerical empicyees.
This program makes available the necessary information on training 38 l
opportunities and, wherein required, the actual training to all secretarial and clerical employees.
It parallels the Secretarial / Clerical / Assistant Development Program and may ultimately be incorporated into the broader program.
The responses to the Development and Training Needs Survey for NRC secretarial and clerical staff which was distributed in May 1984 were analyzed by the USDA, Graduate School and a development program was outlined. Many of the needs are to be satisfied from off-the-shelf courses.
Seven courses were designed and implemented to meet specific individual needs and others will continue to be developed as needs change.
5.6 Complaint Receipt and Processing Since 1975, 50 formal EE0 complaints have been filed at NRC. While this relatively small number of complaints has permitted the staff to ensure strict compliance with EEOC and NRC deadlines and regulations, a broad perspective on complaints will continue in FY-1986. More effective networking of EE0 officials has permitted management to gain a better understanding of the underlying causes of complaints and spot significant trends before the femal complaint stage.
5.6.1 Enhancing the Utilization of EE0 Officers and Counselors l
Because EE0 Counselors can be effective in preventing the development of formal complaints by recognizing problems and concerns OSDBU/CR will hold quarterly meetings with all headquarters EE0 counselors and an annual meeting with both headquarters and regional EE0 Counselors.
In addition to quarterly meetings, OSDBU/CR will continue to collect counseling statistics from EE0 counselors on
'j a quarterly basis.
In turn, OSDBU/CR will assemble and analyze the data before feeding it back to EE0 Counselors and NRC management.
The data will include the number and nature of ccmplaints originatin in each organizational unit; the number and nature of EE0 contacts with emp oyees assigned to each unit; and the i
total time spent counseling employees and applicants on EE0 related matters.
Sumary data will be presented to the EDO in quarterly EE0 program reviews.
EE0 Officers are involved in the formal stages of EE0 complaints.
Since there have been relatively few formal complaints at NRC, EE0 Officers did not have the opportunity to see Agency trends in EE0 or share perception: with others in the EE0 program. Accordingly, in FY-1985 OSDBU/CR EE0 officers participated in the plenary meeting of EE0 Counselors.
This will increase dialog between EE0 i
Counselors and Officers and enhance understanding of overall EE0 probicms at NRC.
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5.6.2 Enhancing the Internal Complaint Management System The current complaint management system is effective and efficient in meeting all statutory and regulatory requirements in a timely manner. However, complainants continue to experience lengthy delays when formal EEOC hearings are held.
Consequently, OSDBU/CR has established and maintains quarterly contact with all employees and applicants who have a complaint in process. Although 39
Although these contacts do not shorten the process, they identify factors which could lengthen the process and allow OSDBU/CR staff to intervene.
5.6.3 Improving Liaison with EEOC The most significant part of formal EE0 cnmplaint processing is in the hands of the EEOC.
In the past, the lengthly EEOC hearing process has been a source of frustration to NRC employees with formal EE0 complaints in adjudication.
During FY-1986, OSDBU/CR staff will maintain contact with their EEOC counterparts to improve the dialog between the agencies.
5.7 EE0 Training and Awareness Programs Since its establishment, NRC has conducted programs to increase staff awareness and sensitivity to EE0 related matters.
These programs will be continued and expand,ed in FY-1986.
i 5.7.1 EE0 Training for Supervisors and Managers EE0 training for managers and supervisors at the branch chief level and belcw was develcped by OSDBU/CR and NDTS in FY 1984.
This course will be continued in FY-1986 for all newly appointed supervisors and managers, as appropriate.
5.7.2 Increasing Employee Awareness and Participation in EE0 Activities As in previous years 0508U/CR will prepare and disseminate information to all NRC employees informing them of the various EE0 activities and soliciting their participation.
Special solicitations will be sent to recognized soecial interest groups to encourage them to develop some activity to be presented during their commemorating week or month.
5.7.3 Assessing EE0 Performance Problems The Office of Small and Disadvantaged Business Utilization / Civil Piphts and the FWP Manager, in consultation with the EE0 Advisory Comittees, will conduct a survey of all minorities and women who leave the Agency to determine whether EE0 program performance contributed to their decision to leave the Agency and if so, what can be done to correct the problem.
The results of these surveys are to be factored into subsequent EE0 Program Plan updates and be used by the Director, OSDBU/CR in his evaluations of the EE0 perfomance of staff managers.
To minimize the resources required, the Comission recommends a writter form
- to be administered to all employees during the existing procedures.
5.8 Improving Program Coordination In order to improve coordination during the implementation of the FY-1986 EE0 Program Plan, regular comunication will b* continued between OSOPU/CR and ADM, the principal supporting office.
The Director, OSOBU/CR, and the Directnr, ACM, will meet periodically to informally review the implementation of the EE0 Program Plan and resolve operational problems.
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The EDO will establish an Ad Hoc Comittee by October 1985 to review the efforts of various constituency comittees in order to enhance their overall effectiveness and coordination.
The Comittee will provide recomendations to the EDO by December 1985.
5.8.1 Monitoring Implementation Each individual project and activity identified in this EE0 Program Plan will be tracked by OSDBU/CR.
Significant deviations from planned accomplishments in any activity will be discussed with the responsible offices in order to maintain momentum.
The Civil Rights Program Manager (CRPM) and the Federal Women's Program Manager (FWPM) will hold quarterly meetings with the EE0 constituent group comittees and other interested groups such as BIG to review the progress of the EE0 Program Plan. Significant issues and problems will be brought to the attention of the'Oirector, OSDBU/CR, and the EDO.
During FY-1986, the Director, OSDBU/CR, will brief the E00 and senior managers at a regularly scheduled NRC Management Meeting.
An annual report will be submitted to the Comission. The various EE0 constituent groups will be invited to take an active part in preparing these briefings.
5.9 Management Accountability Panagement accountability is the key factor in a successful EE0 and affirmative action program.
Because of the central role Office Directors and Regional Administrators play in personnel management decisions an,d organizational planning, the FY-1986 EE0 Consolidated Program Plan continues to fix special management accountability at this level.
S.9.1 Fixing Accountability for EE0 Accomplishments Office Directors and Regional Administrators work with the EDO to prepare their individual SES perfomance plans for the 1985-86 cycle.
As part of this process, each Office Director and Regional Administrator will include specific EE0 and affimative action initiatives. The Director, OSDBU/CR, will also suggest a possible range of activities.
For example, an office with a small number of minority technical staff may make a comitment for someone frcm its staff to participate in recruitment trips to selected colleges and univarsities.
Similarly, a Regional Administrator might plan to speak to a number of minority and women's organizations to make their memoership better aware of NRC programs and employment opportunities.
Activities and planneo accomplishments will be reviewed in January 1986 and updated as necessary; for example, hiring goals
' for each office cannot be set until OSDBU/CR completes its analysis of possible underrepresentatinn.
All initiatives and activities will be developed to address achievement of the objectives in the FY-1986 EE0 Program Plan.
S.9.2 NRC EE0 Award The WC Ecual Employment Opportunity Award will continue to be used to recognize the efforts of individual managers in the pursuit of EE0 and affirmative actinn.
41
l 5.9.3 Sunnary of Resource Requirements To implement the FY-1986 EE0 Program Plan, NRC staff plans to use about 8.0 direct FTE staff years: 3.0 FTE in OSDBU/CR, 3.0 in O&P, 1.0 in MDTS, and about 1.0 from drawing on program office and regional staff for recruiting and related activities; $190,000 in program support funds for training related activities, EE0 complaint investigations, and recruiting; and $15,000 for travel.
Sufficient resources are available in the FY-1986 budget estimates to implement the Plan although some resource reprogramming may be necessary.
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a GLOSSARY Affimative Action:
In employment law, specific employment-related actions which are designed to encourage protected groups to apply for positions and to remove any improper, artificial barriers to subsequent advancement.
Bridge Position: A position specifically designed, within the Upward Mobility Program, in which an employee will train while making a transition frem a position in one occupational series to a position in another with greater promotional potential.
Career Ladder: The entry and developmental grade levels leading to the full perfonnance level of a given position.
EE0 Counselor: An NRC employee appointed and formally trained to assist employees and applicants with complaints of discrimination and to seek an infonnal resolution of the complaint.
EE0 Officer: A senior NRC employee or manager appointed and femally trained to analyze and reach a conclusion on discrimination complaints.
The EE0 Officer reviews investigative reports and prepares a proposed disposition letter for the EDO.
Handicapped Persons: A person who has a physical impalment which (1) substantially limits one or more of such person's major life activities.
(2) has a record of such an impaiment, or (3) is regarded as having such an impaiment.
In this Plan handicapped persons means qualified handicapped persens, i.e., a person who, with or without reasonable accomodation, is qualified for and can perfom the essential functions of a particular position.
Job Fair: A 1 to 3-day meeting of prospective emploiets and employers arranged by a professional recruiting fim; companies and agencias rent space from the recruitmer.t fim; applicants do not pay a fee.
Job Related Training:
Training or education programs whose primary objective is to provice knowledge, skills, or abilities which can be utilized by employees in perfoming their current duties or those that they can be reasonably expected to do in the future.
Protected Group:
Classes of persons afforded statutor non-discrimination on the basis of their race, color, y and regulatory rights to national origin, religion, sex, age, or handicap.
Target Position: A position, within the Upward Mobility Program, which an employee will ultimately occupy after successfully completing the program and meeting all other requirements.
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y Underrepresentation: As defined by the Equal Brplopent Opportunity Comission (EEOC), the situation when the absolute percentage of members of a protected group is lower than their availability in the civilian labor force.
Upward Mobility: A systematic management effort that focuses personnel policy and practice on the development and implementation of specific career opportunities for employees at GG-9 or below who are in positions or occupational series which do not enable them to realize their full potential, p
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