ML24005A237

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FOIA-2024-000022 - Released Set
ML24005A237
Person / Time
Issue date: 12/11/2023
From:
NRC/OCIO
To:
References
FOIA-2024-000022
Download: ML24005A237 (22)


Text

From:

To:

Cc:

Subject:

Date:

Lawrence Crjscjone Mirela Gayr;las: Craig Erlanger Michael waters: Gwynne Eatmon: Kerby scales: ~

Jenna saucerman
Samuel Colvard: Ralph Costello; Dale Yeilding: Howard Crouch; Kathryn Brock; Richard Perkins: ~
Tanya Mensah DH 12.6, I.D.3 Attachments

Monday, October 23, 2023 8:02:27 PM imaaeoo1 ona HOO Office Consjderat;ons 2023-Oct-20.docx

Mirella, What is the guidance for SUNSI?

SUNSI still exists. CUI implementation has been postponed. Yet, it appears that the SUNSI management directive no longer exists, and the CUI management directive is active.

In reference to the attached document, Michael Walters states (in the email trail below):

Mark, handle, and communicate in accordance with SUNS! procedures at this time.

What does that mean? What are the "SUNSI procedures"?

That"s not a rhetorical question. What is the management directive-or other procedures-that are being referred to?

DH 12.6, NRC Controlled Unclassified Information (CUI) Program, item I.D.3 states:

No uncontrolled information may be labeled as CUI.

What does DH 12.6.I.D.3 mean to you? To me, it means that the attached document cannot be labeled-in toto-as CUI since the majority of the information in it is clearly not CUI (and, in my opinion, none of the information in it is CUI). If there is CUI in the attached document, then it needs the CUI banner applied and the CUI portions marked. We cannot claim the entire document is CUI since "No uncontrolled information may be labeled as CUI."

Of course, Michael Waters is not calling the attached document CUI. He is calling it SUNSI

-a term which I recognize still exists but for which I can no longer find any guidance.

When there was guidance, it was the originator (i.e., me) who decided if a document was SUNSI. My determination is that this document is not SUNSI.

The easiest route forward on this is for NRC management to point to us the sentences that you consider SUNSI and to discuss with us how to reword those sentences such that ever one is in agreement that the document contains no controlled information.

I appreciate your assistance in getting a timely resolution to this matter.

It is not a good look for an ostensibly "open & transparent" regulator to claim a blase document is controlled information yet not be able to point to the offending portions nor be readily able to suggest ways to reword those portions.

Thank you, Larry 573-230-3959 From: Lawrence Criscione Sent: Monday, October 23, 2023 7:08 PM To: Michael Waters <Michael.Waters@nrc.gov>; Gwynne Eatmon <Gwynne.Eatmon@nrc.gov>;

Kerby Scales <Kerby.Scales@nrc.gov>; Bill Gott <William.Got t@nrc.gov>; Jenna Saucerman

<Jenna.Saucerman@nrc.gov>

Cc: Samuel Colvard <Samuel.Colvard@nrc.gov>; Ralph Costello <Ralph.Costello@nrc.gov>; Dale Yeilding <Dale.Yeilding@nrc.gov>; Howard Crouch <Howard.Crouch@nrc.gov>; Kathryn Brock

<Kathryn.Brock@nrc.gov>; Richard Perkins <Richard.Perkins@ nrc.gov>; June Cai

<June.Cai@nrc.gov>

Subject:

RE: FOLLOW-UP - RE: HOO Office Considerations First point: This answer is completely unacceptable.

If you are going to burden us with making this SUNSI, hen you need to provide us the courtesy of PORTION MARKING it.

If you cannot portion mark it, then your review was wholly inadequate.

Think about what you are saying to us: "We can't point to the portions that are SRI but we are calling it SRI".

That is LAZINESS. And it is unacceptable.

Second point: NRC management needs to tweak our document, as slightly as possible, to make it non-SUNSI. It would be idiocy for us to keep this document SUNSI when our partnering/bargaining discussions about space design do not need to be SUNSI. However, I cannot do those tweaks since I have no idea how anything in the attached document-which I wrote on my personal computer and emailed via my hotmail account-can be viewed as SUNSI. If management is claiming parts of it are SUNSI, then management needs to tell us what minor adjustments can be made to remove the SUNSI determination.

Third point: I would like our next "Partnership" meeting to be a discussion of this document. In preparation for that discussion, I would like, at a minimum, for NRC management to inform the union which paragraphs contain SUNSI. The attached document has all the paragraphs numbered. Tell us the paragraph numbers that contain SUNSI and the ones that do not.

From: M ichael Waters <M ichael Waters@ rc.fNY>

Sent: Monday, October 23, 2023 4:29 PM To: Gwynne Eatmon <Gwynne.Eatmon@nrc.gov>; Lawrence Criscione

<Lawrence Crjsciooe@nrc gov>; Kerby Scales <Kerby Scales@nrc gov>; Bill Gott

<William Gott@orc gov>

Cc: Samuel Colvard <SamueLColvard@nrc.gov>; Ralph Costello <Ralph.Costello@nrc.gov>; Dale Yeilding <Dale.Yeildiog@nrc.gov>; Howard Crouch <Howard.Crouch@nrc.gov>; Kathryn Brock

<Kathryn.Brock@nrc.gov>; Richard Perkins <Richard.Perkins@nrc.gov>; June Cai

<June.Cai@nrc.gov>

Subject:

FOLLOW-UP - RE: HOO Office Considerations Thanks Gwynne, Consistent with this determination, please treat the document as SUNSI-Mark, handle, and communicate in accordance with SUNSI procedures at this time. We need to provide a more in-depth review of all the elements in its entirety. The aircraft threat detail, in particular, should be treated as SRI. Other details in the document may fall into category as well.

To support this important discussion going forward, we will be working to determine specific portion markings for this document, to ensure proper control of any OUO-SRI related elements.

Thanks! Mike Michael D. Waters Deputy Director Division of Preparedness and Response Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission 301-415-4039 From: Gwynne Eatmon <Gwynne.Eatmon@nrc.gov>

Sent: Monday, October 23, 2023 3:56 PM To: Lawrence Criscione <Lawrence.Criscione@nrc.gov>; Kerby Scales <Kerby.Scales@nrc.gov>; Bill Gott <William.Gott@nrc gov>

Cc: Samuel Colvard <SamueLColvard@nrc gov>; Ralph Costello <Balph.Costello@nrc gov>; Dale Yeilding <Dale Yeilding@nrc gov>; Howard Crouch <Howard Crouch@ nrc gov>; Kathryn Brock

<Kathryn.Brock@nrc.gov>; Richard Perkins <Richard.Perkins@nrc.gov>; Michael Waters

<Michael Waters@nrc.gov>; June Cai <June.Cai@nrc.gov>

Subject:

RE: HOO Office Considerations Good Afternoon, Please know that this document has been evaluated to contain OUO SRI.

I have notified CSIRT.

Respectfully, Gwynne

From: Lawrence Criscione <Lawrence Criscione@nrc gov>

Sent: Monday, October 23, 2023 9:32 AM To: Gwynne Eatmon <Gwynne Eatmon@nrc gov>; Kerby Scales <Kerby Scales@nrc gov>; Bill Gott

<William Gott@nrc gov>

Cc: Samuel Colvard <Samuel Colvard@nrc gov>; Ralph Costello <Ralph Costello@nrc.gov>; Dale Yeilding <Dale Yeilding@nrc gov>; Howard Crouch <Howard Crouch@nrc gov>; Kathryn Brock

<Kathryn Brock@nrc gov>; Richard Perkins <Richard Perkios@nrc gov>

Subject:

RE: HOO Office Considerations I don*t think we need the SUNSI review to move forward.

HOWEVER, I don't want my document marked SUNSI merely as a "precaution". Once that stink gets attached to it, it's impossible to remove.

We'll treat the document as non-SUNSI, with no markings ap_Qlied to it, until formally told by

,a reviewer that it is SU NS I.

If it is later determined to be SUNSI, then whoever makes that decision can document a spill at that time (since the document originated outside the agency network and has left the network on at least one occasion).

From: Gwynne Eatmon <Gwynne Eatmon@nrc gov>

Sent: Monday, October 23, 2023 8:44 AM To: Kerby Scales <Kerby Scales@nrc.gov>; Lawrence Criscione <Lawrence.Crjsciooe@nrc.gov>; Bill Gott <William.Gott@nrc gov>

Cc: Samuel Colvard <SamueLColvard@nrc.gov>; Ralph Costello <Ralph.Costello@nrc.gov>; Dale Yeilding <Pale Yeilding@nrc gov>; Howard Crouch <Howard Crouch@nrc.gov>; Kathryn Brock

<Kathryn.Brock@nrc gov>

Subject:

RE: HOO Office Considerations Morning Larry, Do we have a response from the SUNSI review t hat you initiated on Friday?

I know we are all anxious to move this process forward.

Respectfully, Gwynne From: Kerby Scales <Kerby Scales@nrc gov>

Sent: Friday, October 20, 2023 10:40 AM To: Gwynne Eatmon <Gwynne.Eatmon@nrc gov>; Lawrence Criscione

<Lawrence.Criscione@nrc.gov>; Bill Gott <William.Gott@nrc.gov>

Cc: Samuel Colvard <SamueLColvard@nrc gov>; Ralph Costello <Ralph Costello@nrc gov>; Dale Yeilding <Dale,Yeilding@nrc gov>

Subject:

RE: HOO Office Considerations I agree. Let's what for the SUNS! review results.

From: Gwynne Eatmon <Gwynne.Eatmon@nrc.gov>

Sent: Friday, October 20, 2023 10:16 AM To: Lawrence Criscione <Lawrence.Criscione@nrc.gov>; Bill Gott <William.Gott@ nrc.gov>; Kerby Scales <Kerbv.Scales@nrc.gov>

Cc: Samuel Colvard <SamueLColvard@nrc.gov>; Ralph Costello <Ralph.Costello@nrc.gov>; Dale Yeilding <Dale Yeildiog@nrc.gov>

Subject:

RE: HOO Office Considerations Hello Larry, Great idea. I am more interested in getting to t he right answer. Lets see what the SUNSI review results are before engaging the HOO further.

Unless @Bill Gott has some spare t ime this weekend and volunteers. Otherwise, believe we w ill get what we need from the SUNS! review. Thoughts @Bill Gott @Kerby Scales? Am I/are we missing something?

Respectfully, Gwynne From: Lawrence Criscione <Lawrence Criscione@nrc.gov>

Sent: Friday, October 20, 2023 9:55 AM To: Gwynne Eatmon <Gwynne Eatmon@nrc gov>; Bill Gott <William Gott@nrc gov>

Cc: Kerby Scales <Kerby.Scales@nrc gov>; Samuel Colvard <Samuel Colvard@nrc gov>; Ralph Costello <Ralph.Costello@nrc.gov>; Dale Yeilding <Dale Yeildiog@nrc.gov>

Subject:

HOO Office Considerations

Gwynne, I think we are better off having SUNSI.Resource review the attached document than the HOOs.

But. if you are going to assign it to a HOO, then, based on Dan's comments in the email trail below, it should probably be Bill Gott.

Obviously, we can remove all reference to the DRSN "just to be safe". But as stuff starts getting removed, the document quickly falls apart.

One of the key obstacles in designing a desirable HOO space is removing the requirement for it to be in a vault. Maybe this can be done. Maybe it cannot. But the union wants the issue thoroughly vetted. We don't want the HOOs to work in a vault if they really don*t need to. And we don't want the issue cast aside from our initial document. We want to make

sure it is presented and discussed.

V/r, Larry 573-230-3959 From: Lawrence Criscione Sent: Friday, October 20, 2023 9:42 AM To: Gwynne Eatmon <Gwynne Eatmon@nrc gov>; Ralph Costello <Ralph Costello@nrc.gov>; Dale Yeilding <Dale Yeilding@nrc gov>; Kerby Scales <Kerby Scales@nrc.gov>; Mirela Gavrilas

<Mirela Gavrilas@nrc.gov>; Kathryn Brock <Kathryn Brock@nrc gov>; Bill Gott

<William Gott@nrc gov>

Cc: Dan Livermore <Dan,Livermore@nrc gov>; SUNSI Resource <SUNSl,Resource@nrc gov>; Richard Perkins <Richard Perkios@nrc.rNv>

Subject:

Need a SUNSI review I've copied SUNSI.Resource on this email at the advice of Dan.

SUNS I-in my experience-is a dumpster fire. Using the "mosaic" argument, everything can be termed SUNSI. Portion markings are not required for SUNSI, so if someone determines this to be OUO, then a banner will be slapped across the top and bottom of it, with no markings of the paragraphs, which will all of a sudden cause our entire discussion to be pointlessly controlled as OUO.

It would make life a lot easier if the attached document is determined not to be SUNS!. If there are legitimate reasons for making the changes Dan suggests below, then they must be made.

But I'm not going to play along with ridiculously claiming discussions of the HOO space redesign is OUO "just to be on the safe side". If we are going to make that claim-and burden all of us with what that entails-then there needs to be solid justification for those claims and not just "because it's the safest approach".

From: Dan Livermore <Dan,Livermore@nrc,gov>

Sent: Friday, October 20, 2023 9:29 AM To: Lawrence Criscione <Lawrence Crisciooe@nrc.gov>

Subject:

RE: OUO I would use this group to verify the document: SUNSLResource@nrc.goy What I see after a quick read.

Remove any reference to DRSN and aircraft threat procedures.

Remove any reference to reporting times. There were assaults/robberies at Beaver Valey when shift schedules were known.

Be as vague as possible while still communicating your concern (no need to mention the type of clearance).

I am not an expert on this stuff.

Dan From: Lawrence Criscione <Lawrence Criscione@nrc gov>

Sent: Friday, October 20, 2023 8:14 AM To: Dan Livermore <Dan Livermore@nrc gov>

Subject:

FW: OUO

Dan, If you believe anything in the attached is OUO, please let me know.
Thanks, Larry 573-230-3959 From: Lawrence Criscione Sent: Friday, October 20, 2023 7:59 AM To: Gwynne Eatmon <Gwynne Eatmon@nrc gov>; Kathryn Brock <Kathryn Brock@nrc gov>; Mirela Gavrilas <Mirela.Gavrilas@nrc gov>

Cc: Ralph Costello <Ralph Coste!lo@nrc gov>; Dale Yeilding <Dale Yeilding@nrc gov>; Sheryl Sanchez

<sheryl sanchez@nrc gov>; Kerby Scales <Kerby Scales@nrc gov>; 'lscriscione@gmail.com'

<lscriscione@gmail com>

Subject:

RE: OUO I can't imagine that the attached file-which originated on my personal computer and which I emailed to myself from my hotmail account-contains any OUO information, but please verify that it does not.

Thanks, Larry Lawrence S Criscione 573-230-3959 From: Ralph Costello <Ralph.Costello@nrc gov>

Sent: Friday, October 20, 2023 6:36 AM To: Lawrence Criscione <Lawrence Crjscjone@nrc gov>

Cc: Dale Yeilding <Dale Yeilding@nrc gov>; Sheryl Sanchez <sheryl sanchez@nrc gov>

Subject:

OUO Larry Check with your BC and make sure you don't have any OUO or higher in your considerations paper. Thanks

Ralph Costello Senior Cyber Security Specialist Cyber Security Branch Office of Nuclear Security and Incident Response Nuclear Regulatory Commission

'it: 301-287-3618 l

HOO space Design Considerations

§ 1. Considerations Regarding the work area for the Headquarters Operations Officers, consider some of the challenges faced by the HOOs as compared to the normal office staff:

C.1. The HOOs no longer have assigned cubicles, even though they typically only telework 10% of the time. They have no cubicles in which to store our personal items.

C.2. The HOOs work 12-hour shifts. Every shift, we either arrive to work just prior to midnight (AM shift), or we leave just past midnight (PM shift). We cannot commute via the metrn due to the metro operating times, HOOs need to drive into work.

C.3. Shift workers are noted to be at greater risk to many health conditions, mostly tied to poorer diets and exercise habits than normal office workers. Not being able to take care of one's health is a strong disincentive for many employees to remain in the position for a significant portion of their ca reer. 1 C.4. The HOOs cannot abandon their post at the end of the workday. They need to be relieved by the oncoming shift. If the oncoming shift cannot make it into work due to abnormally large amounts of snow-or other reasons-the HOO may need to indefinitely hold over. Similarly, the HOOs cannot abandon their post when an early dismissal is granted to office staff due to inclement weather or other reasons. So, even if their reliefs are able to make it into work, the HOOs might not be able to leave due to road conditions.

C.5. Licensees are sometimes required to make emergency notifications within tight time frames. Those notifications are made to the HOOs. If the HOO is not available-for example, in the bathroom-the licensee might miss their regulatory time requirement for making their notification.

C.6. One of the roles of the HOOs is to imolement thelCb)<7)(F)

I aircraft threat orocedures. This involves monitorinq thelCb)(7)(F)

(b)(7)(F)

!We've 1 https:/ /www. hea Ith. ha rva rd. ed u/blog/sh ift-work-ca n-harm-sleep-and-hea Ith-what-he I ps-202302282896

C.7. Although there are two watch officers, about 30% of the time the second watch officer is either not fully cleared (Q-clearance) or not fully qualified. When the second watch officer is either not fully qualified (HERO qualified but not HOO) or not fully cleared (L but not Q), the primary watch officer cannot leave the office for the entire 12-hour duration of their shift.

C.8. Although there are typically only two watch officers per shift, if a major event were to occur, the watch bill would likely be supplemented with a third and possibly fourth watch officer.

For example, during the 2003 northeast blackout (which resulted in 17 reactor trips) a third watch officer was brought in to augment the shift. Similarly for the North Anna earthquake in 2010.

C.9. The HOO space needs to not only be a functional workplace on a day-to-day basis handling the routine tasks of the HOO, but it also needs to be a functional workspace during any rare design basis event (e.g., a major reactor accident) when the work load is so great that there is little time to take care of the most basic human needs (e.g., bathroom breaks, access to water and/or food).

C.10. Staffing of the HOO ranks is a periodic problem that has engendered Inspector General interest in the past.2 Degrading our work environment will only exacerbate the staffing challenges.

C.11. The HOOs are essential employees. We needed to work on site throughout the pandemic. A University of Chicago study determined that 40% of all covid cases were asymptomatic and that those asymptomatic cases were responsible for half of all covid transmission. If an asymptomatic HOO were to transmit covid to his/her partner and tlheir reliefs, that could result in four HOOs out of the watch pool for at least 5 days (10 days if they have symptoms). That would be devastating to pandemic shift coverage. As a result, during the pandemic, the HOO and HERO stood watch in separate rooms.

2 OIG-18-A-16

§ 2. Past Practices The practices listed below are in effect regarding the HOOs. Changing these practices would be a change to work conditions, which would involve bargaining along with the bargaining of the operations center move for which pre-decisional involvement is beginning.

P.1. The HOOs have two large cots and associated bedding that can be used in the event that they cannot travel home (typically due to extreme snowfall but potentially other issues).

P.2. The HOOs have exercise equipment in an 18 X 20 foot storage room that is also the same place that the cots are kept. The equipment consists of two exercises bikes (different styles) and a treadmill. The room has a VOiP phone. The exercise room when the Ops Center was in TWFN (pre-2013) had an OCIMS (Ops Center Information Management System) phone.

P.3. The HOOs have a 20 X 20 foot shared space with two complete HOO workstations and two docking stations. The shared space contains twelve 16X20" wall mounted cabinets and fourteen five-drawer sets of drawers that are allotted to the watch officers in lieu of cubicle storage.

P.4. The HOO space contains three complete HOO workstations and one agency workstation.

There are twelve 16X20" wall mounted cabinets that are allotted to the watch officers to store the items they might wish to access while on watch (e.g., a sweater, food).

P.5. The HOO space contains a 10 X 7 1/2 foot bathroom that has a shower, toilet, urinal, wall mounted sink, 24X28X8" wall mounted cabinet and a OCIMS phone.

P.6. The HOO space contains a 7X12 foot kitchen that has a 10X2 foot counter and a 16"X24" counter. There is a large refrigerator/freezer, microwave, toaster oven, Keurig and ice machine which were all supplied by the agency. There is also an air fryer, electric skillet, toaster, waffle iron, burner plate, and coffee pot which were purchased by the HOOs.

§ 3. Requirements The requirements listed below are the items of interest to the union and staff concerning the quality of the HOO work environment. This list is not an inclusive list of all the items required to make the HOO space a robust work environment. There are other items which NSIR management needs to concern themselves with (e.g., redundant power supplies, redundant cabling). We expect Omar Khan and Howie Crouch to provide NSIR management with the requirements necessary to make the HOO space a robust command center (e.g., IT requirements, power requirements, COOP habitability requirements).

R.1. Desk space for six workstations: four HOO workstations and two agency workstations.

R.2. Four HOO workstations, each consisting of (1) a HOO networked computer with a dual monitor, keyboard and mouse, (2) an Avaya networked computer with a single monitor, key board, mouse and Plantronics box, (3) an OCIMS phone, (4) an unrecorded phone, (5) adequate desk space for note taking, and (6) a wall mounted cabinet for our procedures (one set of procedures for each workstation consisting of around ten 3-inch binders).

NOTE: Current practice is three such workstations. Two would be sufficient if there were 100% reliability, never any under instructions watches, and never any third/fourth watch officers brought in for extremely rare events (e.g., reactor accident, regional blackout). Given that (1) it is common to have one or more workstations unavailable, (2) having a third person standing an Under Instruction is common, (3) twice a day at shift turnovers there are four watch officers in the office and seating for only three, and (4) severe accidents would likely result in a third or fourth watch officer being brought in, it is prudent that the agency design the HOO space with four HOO workstations. See C.8.

R.3. Two agency workstations, each consisting of an agency networked computer with a dual monitor, keyboard, mouse and CAC reader.

NOTE: Current practice is one such workstations. Since there are two watch officers, there should be two workstations. The HOO workstations are segregated from much of the agency network. It is not possible to access NRC email accounts, TEAMS accounts, HCM Cloud, TMS, surveys, ETS2, one-drive, ADAMS and many other NRC functions necessary for the general administrative portion of one's job. Also, many of these functions are necessary to adequately participate in agency incident response and for completing general employee requirements (e.g., filling out time cards, taking required computer-based training).

R.4. Two dry erase boards and 4 bulletin boards. White boards need to be located where they can be easily reached. Some human factoring should go into where to place the bulletin boards versus white boards.

R.5. At least 17 16X48" wall mounted cabinets inside the primary HOO space for storing personal items.

NOTE: Often (about 30% of the time) one of the watch officers is confined to the office for the entire 12-hour duration of their shift (see C.7). During an emergency, it is likely that both watch officers will be too busy to leave their posts, even if they are self-relieving (i.e., both are fully cleared and fully qualified). The watch officers need a place to store drinks, food, sweaters, eye drops, toothpaste, etc. Current practice is there are twelve cabinets ( see P.4 ). The requirement for 17 comes from: 14 FTE for watch officers, 2 rotations, 1 for the Regional Response Officer (ROOs) to share. The ROOs individually come up several times a year and should have a place to store their stuff (they should be able to leave things like coffee, saline, or toothpaste, in a personal locker for the next time they visit).

R.6. Two high speed laser printer/scanner/fax machine/combo units:

R.6.A. one connected to the HOO network R.6.B. one connected to the normal NRC network.

NOTE: Current practice is we only have one such unit and it is connected to the HOO network. This is vital to do our job. We would like a second one connected to the NRC LAN so that we can print/scan/fax documents that are work related but do not pertain to our job as watch officers and thus are only accessible from the NRC LAN and not the HOO network.

R. 7. Seventeen pairs of hooks to hang jackets and sweaters.

NOTE: Currently there are six pairs of hooks. We should have seventeen (14 HOOs in the branch, two rotations, and a visiting ROO). Each watch officer should have a hook on which to hang a sweater/light jacket that they keep at work for when the office is cold and a second hook to hang their winter coat.

R.8. 1OX15 foot kitchen within the watch officer's envelope that contains the following:

R.8.A. 30" standard glass top range oven R.8.B. 32" wide Refrigerator with freezer R.8.C. 32" wide Freezer R.8.D. 24" wide dishwasher R.8.E. Double basin sink with garbage disposal R.8.F. Ice machine R.8.G. Eleven linear feet of 24" deep counter space R.8.H. Range hood microwave oven R.8.1. Standard cabinetry above and below counterspace

NOTE: Food preparation and storage is essential for numerous reasons: (1) the HOOs work long days at off-hours which minimizes their ability to shop daily and eat healthy (see C.2 and C.3), (2) often one of the HOOs cannot leave the office for an entire 12-hour shift and thus cannot leave the office to get food, (3) the office needs to support emergency conditions (e.g., deep snow) that might require watch officers to stay on the premises for several days.

NOTE A: There is currently not a range oven in the HOO envelope, but past practice is that the agency provided a toaster oven and the HOOs have been allowed to cook on the countertop using a privately purchased electric skillet and a hot plate. A glass top range oven is requested to facilitate ease of cleaning.

NOTE B & C: Currently there is a 32" wide combination freezer/refrigerator. Due to the nature of the HOO's shift schedule (long days and off-hours that leave little time for daily shopping trips), there is more demand for freezer space than refrigerator space. A separate full size 32" wide freezer is needed.

NOTED: There is currently no dishwasher, but dishwashers are standard for 24-hour response centers.

NOTE G: There is approximately eleven linear feet of counterspace in the curlfent kitchen. This is woefully inadequate for supporting all the appliances. However, it should be adequate if a range oven, a wall-mounted range-hood microwave oven, and a dishwasher are provided since the biggest uses of counter space are the microwave, the toaster oven, and the drying rack. However, more than 11 linear feet of counterspace would allow for a less cramped and more hygienic food preparation environment, and would also allow for more cabinet space.

NOTE H: There is currently an agency provided countertop microwave oven. A range hood microwave oven would preserve counterspace.

NOTE I: The current amount of cabinetry is inadequate. See Note G.

R.9. Seventy-five square foot bathroom within the watch officer's envelope that contains the following:

R.9.A. Shower R.9.B. Toilet with manual flush valve R.9.C. Urinal with manual flush valve R.9.D. Sink with counter space R.9.E. Wall cabinet R.9.F. Vent fan R.9.G. OCIMS phone with push-to-talk handset R.9.H. Wall hooks for towels and toiletries (currently there are 8)

NOTE: All of the above are currently in the bathroom design except for the manual flush valve and the counterspace for the sink. A bathroom within the watch officer's envelop is essential (see C.4, C.5, C.7 & C.9).

NOTE B & C: The current toilet and urinal have automatic flush valves. This is unsatisfactory in that they prevent the watch officer from using the speaker phone when an emergent call comes in while they are in the bathroom (you don't want a toillet inadvertently flushing when you are talking to a licensee). The toilet and urinal should have manual flush valves. And the handset on the phone (item R.9.G) needs to remain push-to-talk for the same reason.

NOTE D: There is currently a wall mounted sink. We would like one that has some counterspace to it.

R.10. 18X20 foot Exercise Area/Room that is inside the watch officer's envelop and contains the following:

R.10.A. Tread mill R.10.B. Wall-mounted Pull-up bar R.10.C. Recumbent exercise bike R.1 0.D. Traditional exercise bike R.1 0.E. weight bench and dumbbells R.1 0.F. floor space to do calisthenics R.10.G. OCIMS phone NOTE: All items are currently available except the pull-up bar and the OCIMS phone.

The current room is 18X20 but is about half storage. The current room is outsiide the watch officer's envelop but needs to be inside (see C.7). Workout equipment is necessary to the watch officer's health due to the difficulty their schedule presents in establishing a fitness routine (see C.2 & C.3).

NOTE F: The open floor space can double as the emergency sleeping quarters (see R.11 ).

NOTE G: The current set up contains a VOiP phone but an OCIMS phone is required.

The current set up was ad-hoc and the agency did not wish to spend the expense of running an OCIMS line.

R.11. A sleeping space large enough for two cots and associated bedding, within the watch officer's envelop.

NOTE: Since this space is only used on an emergency basis, it can be (as it currently is) the exercise room. Ideally the space would be within the watch officer's envelop in

the event that one or both relieving watch officers are unable to arrive for their shifts and the watch officers must stand a shift that extends beyond 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Under no circumstances would a watch officer need to sleep during the first 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of their shift.

But, in emergency situations where the watch officers are not relieved, the expected practice would be that they would be allowed to take turns sleeping. Thus, ideally the sleep area would be in the watch officer's envelope so that the second watch officer is readily available were an event to occur that demanded the attention of two people. See C.4.

R.12. An auxiliary 20X20 work area that contains the following requirements and is as close to the primary HOO space as feasible (ideally within or just off the HOO envelope yet having a different ventilation than the primary HOO space):

R.12.A. Desk space for six workstations: two HOO workstations and four agency workstations. (see B & C)

R.12.B. Two HOO workstations, each consisting of (1) a HOO networked computer with a dual monitor, keyboard and mouse, (2) an Avaya networked computer with a single monitor, key board, mouse and Plantronics box, (3) an OCIMS phone, (4) an unrecorded phone, (5) adequate desk space for note taking, and (6) a wall mounted cabinet for our procedures (one set of procedures for each workstation consisting of around ten 3-inch binders).

R.12.C. Four non-HOO workstations for qualifying HOOs and HOOs on office days, each consisting of an agency networked docking station with a dual monitor, keyboard, mouse and CAC reader.

R.12.D. Bulletin boards and white boards.

R.12.E. At least 17 16X48" wall mounted cabinets for storing personal items R.12. F. Fourteen 5-drawer cabinets of drawers.

R.12.G. Printer connected to the HOO network R.12.H. Printer connected to the agency LAN R.12.1. The auxiliary space is as close to the primary HOO space as feasible yet must be isolated enough to be considered a separate space in terms of covid masking requirements. That is, if a mask mandate is in effect, the primary and auxiliary spaces must be structured such that masks need not be worn if the only two people working in the spaces is the HOO in the primary office with the HERO in the auxiliary office.

R.12.J. The auxiliary space is outside of the HOO security envelop and has a security rating such that phones and laptops are allowed in the space.

NOTE: The HOO used to each be assigned a cubicle. The HOOs are not subject to hoteling since they work the overwhelming majority of their time in the office. The total number of workstations combined under R.1 and R.1 2 is twelve, which is two less than the anticipated FTE for the HOO group. That is, if we were given four HOO workstations in the HOO space, two agency workstations in the HOO space, two HOO workstations in the auxiliary office and four agency docking stations in the auxiliary office, we would still have less than one workstation for every HOO FTE.

NOTE A & C: We currently have four workstations in the auxiliary office: two HOO stations and two agency docking stations. An additional two agency docking stations are needed so our new hires have a place to work (they currently need to find an open space in the emergency response area which is unsatisfactory during drills and meetings in that space).

NOTE E: We currently have twelve and need 17. Seventeen is based on 14 FTE, 2 rotations, and a shared locker for the ROOs.

NOTE H: Sometimes HOOs must print documents not accessible on the HOO network yet accessible on the agency LAN.

NOTE I: The auxiliary office should be right off the primary office, but since a major requirement of this space is that it be a separate space per pandemic requirements, that takes precedence on determining proximity.

R.13. Separate ventilation feeds for the primary HOO space and the auxiliary office:

R.13.A. Ventilation supplies should be HEPA filtered R.13.B. Ventilation supplies should have ultraviolet purifiers R.13.C. Ventilation returns should meet whatever requirements are necessary to ensure that the primary and auxiliary spaces are considered separate spaces from a covid mask mandate standpoint NOTE: See C.11 regarding the importance of ventilation isolation.

R.14. The HOOs are able to control the thermostat of the primary and auxiliary spaces R.15. High volume, secret level shredder (i.e., a larger shredder than the one we have-one that is emptied less often).

R.16. Ringdown phone to HQ security (CAS)

§ 4. Security Envelope Issue Currently the entire HOO space is a security container. It doesn't need to be that way. It's that way because it was easier for the security folks to put overly restrictive measures in place that they were sure would meet the requirements instead of determining what the minimum requirements are and designing to those. If the HOO space were not a security container, it would greatly reduce the complexity of the floor design and ease the burden of being a HOO.

S.1. An agency expert on security container requirements needs to be involved in this partnership endeavor from the earliest stages. This expert should determine what the minimum requirements are for the space so we can design the space to those requirements and provide citations that justify.

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S.7. The HOO space was not a security container when it was in TWFN.

S.8. If the entire HOO space were not a security container, then it would have the following advantages:

S.8.A. The HOO space could have multiple entrances, and axes would not be needed to chop out an emergency egress.

S.8.B. The kitchen in the HOO envelope could have a separate access to the broader Emergency Response spaces and could be larger and utilized by all of DPR. Access to the HOO space from the kitchen could be via a card reader.

S.8.C. The exercise room in the HOO envelope could have a separate access to the broader floor and could be larger and utilized by all of OWFN. Access to the HOO space from the exercise room would be via a card reader.

S.8.0. The restrictions on recording devices in the HOO space would be lifted.

S.8.0.1. The HOOs would be allowed to participate on TEAMS calls with cameras.

S.8.0.2. Agency laptops would be allowed in the HOO space.

S.8.0.3. Cell phones would be allowed in the HOO space.

S.9. If Facility Security chooses to support us as a customer, we can write our security plans in a manner that adequately protects classified information yet still allows flexibility for the employees working in the primary HOO space.

§ 5. Adobe Licensin~ Issue The Adobe licensing issues have nothing to do with the move, but they have been brought forth by the HOOs providing comments. This issue should be address as swiftly as possible.

Just like all NRC users-such as MXG5 and KMB3-NRC user HOO1 is allowed to use Adobe on only two machines concurrently. But NRC user HOO1 is different than other users in that it is an ID that at least 13 different people routine use on five different workstations.

The HOOs routinely are locked out of Adobe because they have exceeded the number of machines that they can use it on (two). When this happen, we can't open/read the Adobe document that we are trying to access. This occurs at very inopportune times (like while on the phone with licensees and trying to open the Adobe document they just emailed us).

When this happens, the HOOs need to open the password locker and log into Adobe. As part of the login process, they need to choose one of their two current sessions to close-which blocks the use of Adobe on the workstation they choose, thus blocking out the next HOO that uses that workstation.

We have been told to, as a workaround, log in with our personal ID. This is not an adequate work around, since we are only allowed to use two separate sessions under our personal log-in, yet we work on five separate machines (six if you count our agency laptop).

Whether we use HOO1 or our personal ID, we are consistently locked out of Adobe at inopportune times.

The HOOs cannot understand why the agency will not address this. Why can't the license used by HOO1 not take into account that it needs to be used on five machines and not two.

A simple fix is to just set up four more user accounts (e.g., HOO2, HOO3, HOO4, HOO5) so that there is now one account for each of the five HOO workstations.

§ 6. Parkin~

The HOOs cannot commute via public transportation (see C.2). Currently, everyone drives.

We need two parking spots reserved for the HOOs. Two for the HOO/HERO combination

.arriving at noon during normal business hours when the parking lot might be full.

That is, the agency needs to set aside reserved parking spots for the HOO/HERO combination coming in every day at noon since the two arriving at midnight would have plenty of spaces available.

The HOO/HERO combination coming in at midnight just needs access to the parking garage.

However, part of being a HOO should entail access to the parking garage.

Access to the parking garage is currently a non-issue. But it is likely that, at some point, occupancy in the White Flint North campus is going to return to levels such that there is not enough parking for everyone working in the building. We need to set aside parking now, for the HOOs, to establish our right to parking when occupancy conditions might change.