ML20212F650
| ML20212F650 | |
| Person / Time | |
|---|---|
| Issue date: | 10/15/1986 |
| From: | Zech L NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20212F595 | List: |
| References | |
| PR-861015, NUDOCS 8701120095 | |
| Download: ML20212F650 (1) | |
Text
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NUCLEAR REGULATORY COMMISSION ANNOUNCEMENT NO.156 DATE: October 15, 1986 TO:
All NRC Employees
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SUBJECT:
NRC REORGANIZATION u
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The Chaiman and EDO will present a major reorganization proposal to the Comission in the next couple of days for its approval. The reorganization would:
Significantly streamline the management of HRC without any legislative changes and result in a more. efficient organization that could better fulfill its fundamental safety mission.
Simplify the NRC's management structure to be more closely aligned l
with the agency's changing role from being a licensing organization to one overseeing operational safety. The major changes would be as the inspection program responsibilities would be split
.follows:
between NRR and NHSS (the Office of Inspection and Enforcement would The enforcement functions previously iri the Office of beabolished).
Inspection and Enforcement would be transferred to a separate Office
' of Enforcement reportir.g to a Deputy EDO.. The Office of Research l
lwould have expanded rulemaking responsibilities; a new office would be created called the Office of Congressional, Intergovernmental, and This office would fulfill existing Congressional and i.Public Affairs.
Public Affairs office responsibilities and add the liaison roles fomerly the responsibility of State Programs and International Programs.
It would report to the Chaiman. The Office of Inter-fnational Programs would be abolished, its functions would be divided
- between NMSS and the Chaiman's office; the Office of State Programs g uld be abolished. its responsibilities woulo De divided between NM55 i
.and the Chairman's office._ A new Office of Administration and l
- Resource Management would be created which would consolidate three I
(existing staff offices,i he Division of Personnel would become a new T
office reporting to the EDO.
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8701120095 861224
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COMMS NRCC PDRCORRESPONDENCE PDR
!.ando W. Zec. Jr.
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..,'.,.3 wi$e.515&$th2;,..,. 5 ?U-:-;db-' ',- 'i'*i ?' l' eM n T19 October 22, 1986 f.N 9W f TdN e w a.m W. f.;tw:W+'q.f'.e . g.- r h;?, @ M.h Lando W. Zech, Jr., Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555 5,, ' ,.(. h..e.
Dear Chairman Zech:
.?Tk,y::5.Q h M,ON. W'I zation of the Nuclear Regulatory Commission, '4.M I have just recently learned of the proposed reorgani- ,Sp h[-b&pj to provide comment on that proposal. I .3 f'[:8.'y$.h[W The information I have on the proposal is of a general i i.e.fy).3% nature, and no specific details are identified. We WD,^bIf({$ recognize the need for the Commir.sion to re-evaluate its i $TJ organizational structure from time to time, and to realign '. c-l this structure as functions and responsibilities change. p' { ' $4j However, it's my understanding that the proposal would L. 9 include the abolishment of the Office of State Programs, Q -J dividing its responsibilities between NMSS and the I '"NN.,...1 Chairman's Office. It is the abolishment of this Office " ' which gives us concern. 2 N'. 4g;;;p The states now number twenty-eight (28) which have fey %pMjh signed an Agreement with the NRC, to regulate and control d,. Nh.t.4!certainradioactivematerialsundertheprovisionsofthe .~j Atomic Energy Act. These twenty-eight states regulate over T 60% of the total materials licenses. Three of the Agreement 3 (South Carolina, Washington, and Nevada) have the ' gjfp Stateslicensing and regulatory responsibility for the only L gqW operating commercial low-level radioactive disposal sites. P@! sj'q!Mh IY,T T
- ge Therefore, any action taken relative to the Office of
@ State Programs, which is presently the central focal point
- V"..M J h in the NRC for all Agreement States, will impact a majority ib..'.Yj6&Ohofstates.
If the proposed reorganization would place this . b ~ M @ central focal point in the Chairman's Office, the action hl, : would be considered a positive impact. However, if the focal point would be transferred as a sub-unit of the Office w , i.. of Nuclear Material Safety and Safeguards, then the action gM i p would be considered a negative impact upon the states and their regulatory relationship with NRC. ' k?f""1 Over the years, the Agreement States have consistently i ,..; urged the NRC to keep their central focal point as close to p #,,3 ( the Chairman's Office as possible. The needs and interest 'e.k :g. i44.wiW j e- @y.%M'8S.ih!.! C " " 'V LN._w > oe G %'WE,$1.yy p:n ~ : pp n I
s i of the Agreement States should be at.an organizational level in the NRC, comparable to other major programs. This position is con- 'sistent with the recommendations of the NRC to Agreement States; that their regulatory programs should be at an organizational' level, comparable with other state programs with similar responsi-bilities. Some specific concerns, should the focal. point for Agreement States be at a lower level of the organization than presently exists,'are listed below: (1) The potential for the loss or dilution of vital infor-mation from Agreement States to the Chairman's Office. (2) The potential loss or dilution of a strong training program for Agreement State personnel. The NRC provides an excellent training program, and this program should not be weakened. (3) The potential loss or dilution of a strong commitment of support to Agreement States and to the Conference of C Radiation Control Program Directors, as is presently provided by NRC. (4) The potential loss of a. fair hearing when Agreement States views differ from the views of the NRC staff. An example is the recent revisions to 10 CFR 35, where Agreement States took a different view than some NRC staff. The existing independent Office of State Programs has helped assure that state views receive attention at the appropriate organizational levels. ~ It is my understanding that the primary function of NMSS is related to NRC licensees. The relationship between NRC and the Agreement States is not a licensor / licensee relationship. It is true they both perform similar licensing functions, but the relationship between the regulatory agencies is one of federal / t state cooperation in reaching the mutual goal of' protecting the public health and safety. The Agreement States, and the Conference strongly urge that the focal point for Agreement States at the Headquarters level have high visibility. This is especially important as a result of the Low-Level Radioactive Waste Policy Act, which gives states the responsibility for the management of low-level radioactive waste. As the states are " gearing up" to take this responsibility, they must have access to the NRC, at both a policy level and at an operational level. It is preferable that this accessibility, to both policy and operational' matters, be within one location and not fragmented. 1 The organizational history of NRC has shown that identifying i the focal point for Agreement States at a high level of the organization, has substantially improved communication of the states with NRC. i t ~~-
.t In summary, the Agreement States Program has been a model for both the states and the-Commission. This excellent relationship between the states and NRC does not exist in any other federal agency. It is an exceptional program, and should not be weakened. In the 1983 report of the National Governors' Association, "The Agreement State Program: A State Perspective," the following is stated: "The Agreement State Program is one of the most successful state / federal partnerships yet established in terms of 1) the flexibility provided states in assuming regulatory responsibility,
- 2) successful state performance of regulatory duties and 3) consultation with states in the preparation of new regulations."
The Agreement States play a very important role in the protection of public from radiation exposure, and this role will increase as more states become Agreement States, and as more states assume their responsibility for the management of low-level radioac.tive waste. The training and guidance provided by NRC to the states has been invaluable in their efforts to protect the public health, and we strongly urge that any reorganization not result in the dilution of this important service, but to the contrary, that any reorganization enhance the relationship of the NRC with the states. We believe the public health and safety has received the benefit of the very effective NRC/ Agreement States Program. Any change that would place this Program at a lower level within the organization may be perceived by state policy makers as a down-grading of the Agreement States Program, and a lowering of interest by NRC in such Program. Because of our concern for the impact of the proposed reorgan-ization, I would like to request that a. selected group of state radiation control representatives be given an opportunity to meet with the full Commission at the earliest possible time to discuss this matter. l l Very truly yours, W AM.-C - John A. Eure, Chairman Conference of Radiation Control Program Directors, Inc. CMH/es cc: Commissioner Thomas M. Roberts Commissioner James K. Asselstine Commissioner Frederick M. Bernthal l Commissioner Kenneth M. Carr Victor Sello, Jr. Wayne Kerr ._}}