SEC

Ft EG& 'ýUNITED STATES

0 NUCLEAR REGULATORY COMMISSION

C'0 WASHINGTON, D.C. 20555-0001

June 8, 2015

RETARY COMMISSION VOTING RECORD

DECISION ITEM: SECY-15-0015

TITLE: PROJECT AIM 2020 REPORT AND RECOMMENDATIONS

The Commission acted on the subject paper as recorded in the Staff Requirements

Memorandum (SRM) of June 8, 2015.

This Record contains a summary of voting on this matter together with the individual vote

sheets, views and comments of the Commission.

Annette L. Vietti-Cook

Secretary of the Commission

Enclosures:

1. Voting Summary

2. Commissioner Vote Sheets

cc: Chairman Burns

Commissioner Svinicki

Commissioner Ostendorff

Commissioner Baran

OGC

EDO

PDR
VOTING SUMMARY - SECY-15-0015

RECORDED VOTES

CHRM. BURNS

COMR. SVINICKI

COMR. OSTENDORFF

COMR. BARAN

NOT

APRVD DISAPRVD ABSTAIN PARTICIP COMMENTS DATE

x x x

x x x

x x

x x x

3/18/15

4/7/15

2/20/15

3/20/15
TO:

FROM:

SUBJECT:

NOTATION VOTE

RESPONSE SHEET

Annette Vietti-Cook, Secretary

Chairman Burns

SECY-15-0015: PROJECT AIM 2020 REPORT AND

RECOMMENDATIONS

Approved X Dis

Not Participating _

COMMENTS: Below

1approved X Abstain

Attached X None

SIGNATURE

18 March 2015

DATE

Entered in STARS" Yes X No
Chairman Burns's Comments on

SECY-15-0015,"Project AIM 2020 Report and Recommendations"

I want to thank the staff, and in particular, the Project AIM Team and senior leadership for its

efforts to identify key strategies and recommendations to enhance the NRC's ability to plan and

execute its mission while adapting in a timely, proactive and effective manner to a dynamic

environment. The Project AIM 2020 report provides the Commission with a reasonable set of

recommendations to improve our operational effectiveness and simultaneously ensure that we

remain a strong, independent, stable and effective regulator.

The NRC is a high-performing organization and we should not lose sight of that important fact.

As I have stated in recent presentations to internal and external audiences, the NRC has an

excellent reputation and is a well-respected nuclear regulator. This is due in no small part to the

dedicated, talented and knowledgeable NRC staff and their unwavering commitment to the NRC

mission.

As with all high-performing organizations, the agency must be well positioned (i.e.,

organizational structure, programs, processes) to keep pace with its current regulatory

responsibilities while pro-actively assessing the potential for and impact of external

influences/challenges (e.g., declining interest in new reactor builds, reduced budgets) to its

regulatory approach. Equally important is the need to understand internal influences/challenges

(e.g., workload, critical skill needs, staffing levels).

The NRC has a long and successful record of continuous improvement and overall, I believe

that our performance budget and management framework ensures that the agency is largely

focused on the right activities in furtherance of our mission and achievement of our strategic

objectives. However, few can dispute the fact that the time has come for the agency to take

stock of itself, as pointed out in the Project AIM 2020 report. By undertaking some of the

Project AIM 2020 recommendations with strong leadership commitment and oversight, the

agency will be better positioned to respond to the challenges of 2020 and even beyond.

I offer several general observations that are relevant to all of the recommendations. Often an

organization undergoing change tries to address its organizational challenges by engaging in

additional analyses or by creating new processes or tools. However, the solution is many times

more straightfoward than that: strong, decisive leadership. If, for example, the agency needs to

improve the timeliness of licensing actions, it is leadership's responsibility to first ensure that

existing processes are being uniformly implemented and can be achieve the desired results

before reinventing entirely new processes. To this point, I strongly encourage the NRC's senior

leadership to consider its role in ensuring that Project AIM 2020 is successful before it looks to

develop new processes. Project AIM 2020 cannot be successful if, in 5 years from now, all the

NRC has to show for it is a collection of new studies, reports, and business process tools.

Although the entire leadership of the NRC must take responsibility for the success of this

project, a senior leader should be dedicated to oversee the implementation to ensure that

Project AIM 2020 is implemented in the most effective manner. I would note, that ensuring

more direct leadership attention for any future major change project was a recommendation

identified in the Transforming Assets into Business Solutions (TABS) lessons learned report

(SECY-1 5-0008, January 16, 2015). The Executive Director for Operations should designate

1
the responsible senior leader overseeing Project Aim within one month of the date of the SRM

for SECY-1 5-0015.

The following provides my vote on the individual recommendations for the Project AIM 2020

Report.

I. People

I-1) Ensure the NRC has the right number of people with the right skills at the right time.

a) Develop a strategic workforce plan that ensures the NRC is positioned to have

the right number of people with the right competencies at the right time.

I approve the development of a Strategic Workforce Plan (SWP) that maps the current

workforce to the projected future state of the agency workforce. The SWP should

include strategies for managing and minimizing staffing overages and skill gaps. This

should be a modest effort, unlike the elaborate SWP tool that was ultimately retired in

2009. We should understand and apply lessons learned from our experiences with the

previous SWP tool. Most notably, any SWP tool should set a standard approach that

can be easily deployed and managed by first-line supervisors and modified to meet the

changing needs of their organization. In addition, the tool should be sophisticated

enough (i.e., integration of input) so that it can be used as needed to assess

organizational health at the division, office and agency levels. Implementation of this

recommendation should begin approximately one month from the issuance of

Commission direction on SECY-1 5-0015, so that the agency is poised to hire, retrain

and reposition staff to meet today's work requirements, as well as the work projected

for FY 2016 and beyond.

1-2) Enhance employee agility by reducing the time required to shift employees or their

work assignments to meet the demands of a changing environment by the

following:

a) Based on agency priorities developed in I-l.a., develop a plan to identify mission

critical and/or safety-related positions considered most important for immediate

needs analysis (based on criteria such as highest percentage of workforce

characterized by the position or role, criticality of the job functions performed,

amount of training dollars targeted toward positions, maturity of the

qualification program, etc.).

b) Based on outcome of 1-2.a. determine timeline for developing competency

models for other agency occupations and functions.

I approve these steps, upon completion of I-la.

1-3) Increase organizational agility and efficiency through focus on "One NRC" and on

outcomes.

a) Develop or adopt an explicit NRC leadership model (or leadership philosophy)

that builds on the agency's existing culture (Principles of Good Regulation,

2
Organizational Values) and supports agility, to include empowering employees

by promoting personal responsibility and accountability along with creative

thinking, innovation, and informed risk-taking in all of our activities. Refine the

NRC Organizational Values to incorporate those values necessary to support

organizational agility or clarify that they are already included under the existing

values.

Disapprove. I do not support the development of a separate NRC leadership model or

modifying the NRC Organizational Values. I agree the agency needs to enhance its

ability to adjust to the changing environment by being more agile when it comes to

supporting higher-priority work that arises. I also agree with Commissioner Ostendorff

that effective decision-making can be achieved by focusing attention on the

characteristics of the Principles of Good Regulation and the Organizational Values.

I believe that NRC's leadership is fundamentally responsible for ensuring that these

existing principles, values and policies are communicated and embraced uniformly by

all offices across the agency. When there is an inconsistency between the

implementation of an agency practice between offices, this should not be viewed as a

failure of the practice; it should be viewed as a management challenge that should be

dealt with accordingly. The NRC does not need a rebranding effort or recasting of the

agency's Organizational Values to accomplish this.

In the brief time since my return to the NRC, I have observed in the Regions that

creative thinking, innovation, and informed risk-taking is promoted, and changes are

already being implemented without the need for Commission direction. For instance,

in a recent visit to Region II, I was briefed on the "Idea Greenhouse," initiative where

employees are given the means to raise new and innovative solutions to a wide range

of issues that can be simply implemented and which can result in substantial

improvement to processes and resource savings. I understand that other Regions

have similar processes that are being used and making a positive difference, and I'm

sure that there are offices within Headquarters also doing this. I commend the

Regions and those Headquarters offices for taking the initiative to maximize the talents

and expertise of their staff to be more effective and efficient in the conduct of their

work. Who better to identify opportunities to improve than the individuals performing

the actual work, each and every day.

A large part of this is going "back to basics," and in this context it is worth recalling our

statutory mandate under the Atomic Energy Act (AEA) of 1954, as amended. Under

the AEA's broad authority, the NRC imposes requirements and takes regulatory action

to ensure reasonable assurance of adequate protection of the public health and safety

and common defense and security. The NRC has continual emphasized over the

decades of its existence, its "adequate protection" authority does not require the

agency to seek to achieve zero risk in its regulatory activities. I have frequently heard

that one challenge the agency faces is a desire to always achieve the "gold standard"

which can result in expending more effort than required. The NRC should always seek

to achieve the highest standards of performance, but it must do so with a balanced

perspective of the significance of the activity in the overall context of our regulatory

responsibility and with the overarching objective to be focused on the right things.

3
The NRC should identify and consider additional opportunities to apply more broadly

risk insights to enhance our decision-making beyond traditional technical issues.

Decision-making that uses a graded approach should also be applied to determining

priorities and the level of resources dedicated to our corporate and infrastructure

programs.

Again, this approach does not require a fundamental change in the agency through a

new "One NRC" paradigm; it simply requires senior leadership to reinforce this concept

uniformly and consistently. It is also imperative that agency employees are thoroughly

engaged in this process. The employees of this agency have a significant depth of

experience and knowledge in this field. I am confident that when it comes to an

understanding of what the NRC does or does not need to be working on, no one is in a

better position than the NRC staff. It is also important for the staff to be engaged in

this effort because they must embrace and take ownership of the results of Project Aim

2020.

b) Explore greater reliance on centers of expertise to provide leadership, best

practices, research, and support in particular focus areas across the agency.

Currently, the NRC is utilizing centers of expertise across certain business lines

in areas such as vendor oversight, electrical engineering, allegations, force-onforce inspections, and fire protection licensing reviews. Based on the

evaluation, expand reliance by establishing additional centers of expertise.

I approve the evaluation of the effectiveness of existing NRC Centers of Expertise

(COE) to determine whether expansion of this organizational model will lead to greater

effectiveness and efficiency in accomplishing the agency's mission. Establishing or

using COEs in the science and engineering areas are similar to centralizing the

corporate functions recommended by the TABS Task Force Report in 2011, in that

they both are designed to consolidate common technical, programmatic and process

roles, responsibilities and functions that support the needs of multiple customers with

specific needs. Lessons learned from TABS implementation should also be

considered and factored into an evaluation of COE expansion. The staff should

provide the Commission with an evaluation and recommendation(s). The evaluation of

existing COEs is not dependent on other recommendations contained in Project AIM

2020 report, and should proceed on the timeline recommended by the staff.

c) Develop a transitional plan that describes the approach to conduct a merger of

NRO and NRR at the appropriate time, along with any associated organizational

changes in Region II. The plan will describe key criteria and factors that need to

be considered, interim actions that will be undertaken as key milestones are

achieved, and potential future events that could accelerate or decelerate the

timing of the merger.

I approve in part, and disapprove in part. It is premature to determine that a merger of

NRO and NRR is the appropriate solution to address the current and projected

declining workload in NRO. An organizational "transformation" plan may be more

appropriate than a "transitional" plan that considers the optimal organizational

construct for performing regulatory oversight of operating and new reactors. The

transformation plan should not be limited solely to an examination of NRR and NRO,

4
but what other organizational structures may be appropriate to be more efficient,

effective and agile. For example, the staff's evaluation of COE expansion highlighted

above, where the agency's science and engineering expertise is centralized and

provides technical support to the statutorily mandated offices (e.g., NRR, RES, and

NMSS) and Regions, should be integrated into any transformation plan. If the staff

supports the merger of NRO and NRR, the transformation plan should provide the

business case for the merger and indicate the optimal size of the organization and the

interim steps that are needed to achieve the appropriate size, including staff to

management ratios.

d) Evaluate further consolidation of the regional materials program to determine

whether further consolidation would be more efficient. The Materials Program

for Regions I and II was successfully consolidated into Region I in 2006.

Approve.

e) Evaluate the corporate support functions in the regions to ensure they are

appropriately resourced and identify if any savings can be reached through

standardization or centralization of specific functions. The evaluation should

reflect upon the lessons learned from the Transforming Assets into Business

Solutions initiative.

Approve.

II. Planning

I1-1) Improve the Planning and Budget Formulation Process

a) Benchmark with other agencies and seek external validation from a third party

to clearly define and justify overhead as well as identify the variable

components of Corporate Support.

Approve. This effort is currently underway to support the agency's effort to provide

greater transparency of the NRC Fee Rule.

b) Clarify agency priorities and use office and agency add/shed procedures to

ensure effective and efficient use of the staff's time and resources.

Approve. In my view, it is imperative that the agency enhance its ability to assess new

and emergent work by establishing an integrated prioritization scheme that eliminates

organizational and budgetary boundaries. Historically, the NRC has been effective at

identifying potential regulatory issues and prioritizing them. However, it has

sometimes struggled with balancing the resource needs of competing priorities and

shedding work. The staff should develop a common prioritization process with a

supporting add/shed procedure that integrates all work activities across the agency

and includes external mandates. I believe such a process and procedure will

ultimately enable the Commission, senior leadership, managers and staff to make

more informed and timely decisions. Efforts to improve the common prioritization

5
process should begin immediately to inform decisions in the FY 2017 budget

formulation process, to the maximum extent practical.

In my view, there is a close relationship between this effort and the rebaselining effort

in Recommendation 11-2) (a). It is difficult for me to understand how a rebaselining

effort could be effective if it does not also include an effort to clarify agency priorities

and undertake an add/shed process. Accordingly, the staff should integrate these

efforts.

c) Utilize foresight methods and stakeholder engagement to get a more informed

estimate of the future to ensure the agency is prepared.

Disapprove. The agency currently relies on input from licensees and the industry to

make projections on both a formal and informal basis to enhance resource decisions in

formulating its budget. Devoting resources to institutionalize a formal annual call for

workload projections and a detailed forecasting process is not likely to achieve the

intended results.

11-2) Re-Baseline the work of the Agency

a) Conduct a review of the work performed across the agency and confirm the

basis for the work (the requirement(s) that the work is intended to fulfill, whether

it is required by law (including judicial mandates and regulations), or

Commission direction). Work that is not required could be shed to help make

the agency more lean and reduce future budgets. With the growth that occurred

from FY 2005 through FY 2010, new activities may have been added to the

agency's workload and budget that are no longer required or to a lesser degree.

This activity would be performed by the staff, with assistance from an outside

entity.

I approve the concept of rebaselining the work of the agency, and integrating this effort

with the effort to clarify agency priorities and undertake an add/shed process as noted

above. Nonetheless, I have concerns about what the staff may be envisioning for the

scope and scale of this effort. I support a one-time assessment that results in the

Commission receiving a comprehensive list of activities that can either be shed or

performed with a less intense resource commitment. This assessment should be an

EDO-led and involve Office Directors, Division level managers and staff examining the

business lines activities, making decisions on what work is needed, and how much is

required to get back to basics (i.e., focused on what is required and our highest

priority). This effort should engage the entirety of the staff in developing

recommendations so that there is acceptance and ownership of the final result. Our

employees have a significant body of expertise and it would be a failure to not engage

that vast body of knowledge. In addition, the production of a major report that takes

several months to finalize is not necessary to achieve the intended objective of this

recommendation. I believe that the staff can accomplish this task by convening one or

a series of meetings to develop the recommendations, as I understand was done to

develop the FY 2013 Sequestration Implementation Plan.

6
3

Furthermore, this exercise should not resemble the rebaselining effort performed in the

mid 1990's that entailed a detailed examination of activities and binning them into one

of three categories (i.e., "mandated", "needs", and "should"). This effort could be

characterized ultimately as a largely theoretical exercise rather than a rebaselineing

that changed the scope of the agency's work. As I stated earlier, the NRC is a topperforming agency, we know what we should be doing for safety and security and what

mandated work is necessary. It is critical that this effort results in concrete, tangible

improvements and not just a collection of reports and analyses.

Ill. Process

I11-1) Improve the transparency and simplify how the NRC calculates and accounts for

fees, and improve the timeliness of when the NRC communicates fee changes.

When the NRC published the 2014 Fee Rule, many commenters raised

concerns regarding the lack of clarity in the work papers presented to justify fees.

Approve. This effort is currently underway.

111-2) Improve licensing by conducting a business process improvement review of the

operating reactor licensing process and make associated improvements to

enhance the predictability, timeliness, and efficiency of the reviews, while

ensuring and measuring the effectiveness and quality of the reviews.

Approve. The conduct a business process improvement (BPI) review of the operating

reactor licensing process should be done on a schedule that does not affect the staff's

ability to reduce the backlog of licensing actions. Consequently, I support the staff

recommended timeline for initiating the BPI review. Nonetheless, in formulating the FY

2017 budget, the staff should evaluate the existing performance metrics for licensing

actions and consider revising them to measure more accurately performance within

the staff's direct control. The staff should not be held to a timeliness standard that is

frequently impacted by a licensee's ability to provide complete and timely supporting

information to finish its review.

111-3) Improve processes by streamlining, standardizing, and clarifying roles and

responsibilities:

a) Evaluate and improve the acquisition process to clarify the roles and

responsibilities of the Contract Officer Representative (COR), standardize

processes, and improve quality and process time.

Approve.

b) Improve efficiency of processes by expanding the use of mobile information

technology solutions across the agency.

Approve. I strongly encourage the staff to push the envelope with respect to

enhancing the NRC's use of mobile technology, while carefully considering the

potential for cyber security issues. The staff should not be overly conservative when

assessing the use of new technology, but instead must appropriately balance any

7
concerns with anticipated benefits of using it. In my short time back at the NRC,

many times I have heard that restrictions on technology usage are hampering the

staff's ability to get work done. I am also aware that other Federal agencies with

sensitive security-related functions have found ways to use advanced technology and

still make sure that security concerns are addressed.

I believe modernizing the agency's thinking and approach toward advances in mobile

technology can enhance our effectiveness and efficiency, most notably save staff time

and effort. In addition, the increased use of laptops, tablets, and smart phones can

result in long-term reductions in other overhead costs, such as for paper and toner

cartridges.

c) Eliminate multiple request systems and paper forms by developing and

implementing a streamlined "One-Stop-Shop" solution for OIS and ADM

requests for services and support. This strategy would identify, evaluate, and

define the requirements for such a solution.

Approve.

d) Re-examine the processes and practices associated with the NRC's

assessment of the risks to its information systems in accordance with the

Federal Information Security Management Act (FISMA).

Approve.

8
NOTATION VOTE

RESPONSE SHEET

TO: Annette Vietti-Cook, Secretary

FROM: COMMISSIONER SVINICKI

SUBJECT: SECY-15-0015: PROJECT AIM 2020 REPORT AND

RECOMMENDATIONS

Approved XX In-part Disapproved XX In-part Abstain

Not Participating

COMMENTS: Below Attached XX None

04/%7 /15

DATE

Entered in STARS" Yes No
Commissioner Svinicki's Comments on SECY-15-0015

Project Aim 2020 Report and Recommendations

The NRC staff has provided the Commission with a quality deliverable and a rich set of

recommendations. They have done so within a concise period and while drawing upon a

diverse set of employee views and experiences. I thank them for their hard work. I have also

had the opportunity to review the feedback report provided by the study team of the National

Academy of Public Administration (NAPA) and appreciate the perspectives provided.

I consider the staff's paper, this Commission vote, and its resulting staff requirements

memorandum (SRM) to be the beginning steps in what will ultimately be a multi-year, multiprong, multi-phase effort. Consequently, I do not begin with an expectation that we must

identify all the elements from the start or that we must design and construct each measure with

particularity right now. I find myself in strong agreement with the sentiments of Chairman Burns,

as expressed in his vote, that in general we know now what we need to do, we have at our

command the necessary elements to do so, and that key among these elements is strong,

decisive leadership. This principle shapes my view on a number of the individual

recommendations. It is why assignment of each implementing action and accountability for its

successful achievement must reside with the line organizations, so that a unified chain of

command is maintained and so that the organizations responsible for the execution of the

NRC's missions can be measured against established metrics and can have "ownership" of the

agency processes/solutions they use to achieve that mission. As stated by Chairman Burns,

"Who better to identify opportunities to improve than the individuals performing the actual work,

each and every day?"

In a similar vein, I disapprove the NAPA suggestion that the NRC may be well-served by a Chief

Risk Officer. I do support a greater focus, however, on the use of Enterprise Risk Management

techniques. The staff should consider whether the successful management of enterprise risk

should be a factor/element in the annual performance evaluation of agency managers.

I disapprove the transfer of security oversight to NSIR from NRR with respect to research and

test reactors. Just this month, the Commission received the semi-annual status update on

research and test reactor license renewal reviews. Discouragingly, eight out of twelve of the

ongoing reviews now clock in at over a decade in duration. I offer no defense of these

timeframes. Based on my observation of the prolonged effort to address this backlog, and as

echoed in comments received from the National Organization of Test, Research, and Training

Reactors, I see no good purpose served in transferring any part of the RTR mission-related

activities between the two offices.

Separate and aside from the staff's Project Aim recommendations, and consistent with my

testimony before Congress, I formally propose that the Commission revoke the waivers

previously granted to the staff in 2006 [see SRM COMNJD-06-0004/COMEXM-06-0006, dated

May 31, 2006] related to initiation of agency rulemaking activities. Namely, I propose:

(1) That the Commission reinstate the requirement that the staff develop and submit to the

Commission rulemaking plans prior to embarking on a rulemaking activity;

(2) That the Commission reinstate the requirement for review by the Committee to Review

Generic Requirements (CRGR) at the proposed rule stage; and

(3) That the Commission reinstate the requirement for review by the Advisory Committee on

Reactor Safeguards (ACRS) at the proposed rule stage.

The waivers granted to the staff in 2006 eliminated several important checks and balances

occurring prior to the expenditure of significant agency resources on a potential rulemaking

effort. It is not clear that the circumstances that gave rise to these waivers are operative now

and it is not discernible to what extent the Commission absenting itself from the "up front"
2

decisions to embark upon these activities has contributed to the proliferation of individual

rulemakings. These waivers also eliminated an opportunity for these groups - the Commission,

the CRGR, and the ACRS - to form a holistic view, across rulemaking activities, of the agency's

concurrent efforts and their cumulative impact.

The following provides my vote on the individual recommendations for the Project Aim 2020

Report.

People Strategy

I-1) Ensure the NRC has the right number of people with the right skills at the right time.

a) Develop a strategic workforce plan that ensures the NRC is positioned to have the right

number of people with the right competencies at the right time.

I approve the development of a strategic workforce plan, but agree with my colleagues that this

should not be an overly elaborate undertaking. The development of this plan must be informed

by the rebaselining initiative but need not await the completion of the rebaselining. Rather, its

development should be initiated after the Commission has approved or concurred in the staff's

plan for the rebaselining. I further approve the establishment of an FTE ceiling of 3600 FTE

onboard strength by September 30, 2016, as a step towards achievement of the agency's

eventual rightsizing target for Fiscal Year 2020.

1-2) Enhance employee agility by reducing the time required to shift employees or their work

assignments to meet the demands of a changing environment by the following:

a) Based on agency priorities developed in I-1.a, develop a plan to identify mission critical

and/or safety related positions considered most important for immediate needs analysis.

b) Based on outcome of 1-2.a, determine timeline for developing competency models for

other agency occupations and functions.

I approve these activities, upon the completion of I-1.a.

1-3) Increase organizational agility and efficiency through focus on "One NRC" and on

outcomes.

a) Develop or adopt an explicit NRC leadership model (or leadership philosophy) that

builds on the agency's existing culture and supports agility, to include empowering

employees by promoting personal responsibility and accountability along with creative

thinking, innovation, and informed risk-taking in all of our activities.

I disapprove this activity at this time. Instead, the staff should return to this concept when the

Project Aim recommendations are more substantially underway, re-examine whether this

concept is a separate undertaking or is an organizational outgrowth of progress on the other

recommendations, and report to the Commission on whether this concept is, in the staff's view,

still needed and if so, what form it would take. I share the Chairman's observation that certain

cradles of innovation and empowerment already exist at NRC. The staff should encourage

greater sharing of best practices in this area. On the topic of informed risk taking, the staff

should use formal and informal mentoring to inculcate the understanding that zero risk is neither

the goal nor the metric for agency decision-making.

b) Explore greater reliance on centers of expertise to provide leadership, best practices,

research, and support in particular focus areas across the agency.
3

Expanded decentralization of lines of accountability for the fundamental work of this agency -

oversight and licensing - through greater reliance on centers of expertise is a step in the wrong

direction. In light of this, I disapprove this recommendation. Again, I second the view of

Chairman Burns that "strong, decisive leadership" within the unified chain of command in each

program office is vital. I will approve the analysis proposed by Chairman Burns in his vote,

however, consisting only of an evaluation of the effectiveness of existing NRC Centers of

Expertise. To the extent this model is organizationally effective in certain cases, however, the

staff should look instead to enhancing its existing Communities of Practice model, within the

NRC's Knowledge Management program.

c) Develop a transitional plan that describes the approach to conduct a merger of NRO and

NRR at the appropriate time, along with any associated organizational changes in

Region I1.

I approve this recommendation and applaud the staff in NRO and NRR for modeling strong,

decisive leadership in putting this recommendation forward. The Commission should join them,

by approving it. I know some of my Commission colleagues were unconvinced on this

recommendation. As someone who has been observing and taking part in the NRC's activities

in response to the planned "nuclear renaissance" for a number of years (but not, certainly, as

long as the NRC staff), I respect the staff's (perhaps reluctant) admission that now is the time to

begin planning for the alignment of these two offices to reflect external reality. Large

organizations do not wait to begin planning for the future of offices until their activities have

wound down. To do so would be a singular disservice to the employees of NRO whose skills

are now and will continue to be vital to the agency's success, and who moreover deserve,

based on their commitment and contributions, to be provided with a vision of how and where

their skills will be housed organizationally going forward. The staff should provide a transition

plan within six months of the issuance of the SRM for this paper, which will accomplish the

transition within a time certain. The leadership of both organizations has already been

contemplating this merger, so it is time to eliminate staff uncertainty and give our employees

greater clarity about their own futures.

d) Evaluate further consolidation of the regional materials program to determine whether

further consolidation would be more efficient.

I do not have sufficient information to know whether further consolidation is a good idea but I

approve further evaluation of the idea.

e) Evaluate the corporate support functions in the regions to ensure they are appropriately

resourced and identify if any savings can be reached through standardization or

centralization of specific functions.

I approve further evaluation of this area but it is essential, as noted in the recommendation, that

the evaluation reflect upon the lessons learned from the Transforming Assets into Business

Solutions initiative, which did not proceed smoothly in many aspects and therefore provides

important organizational lessons for any similar undertakings (such as this one) in the future.

Planning Strategy

I1-1) Improve the Planning and Budget Formulation Process

a) Benchmark with other agencies and seek external validation from a third party to clearly

define and justify overhead as well as identify the variable components of Corporate

Support.
4

This effort is ongoing and I approve its continuance.

b) Clarify agency priorities and use office and agency add/shed procedures to ensure

effective and efficient use of the staff's time and resources.

Under law, agency priorities are established through the Commission's deliberation and vote on

the Chairman's budget proposal and subsequent enactment of agency appropriations by the

Congress. Any priority setting or add/shed process must not violate these principles. The

Commission is the first level of determining priorities or clarifying them. I agreed with (then)

Commissioner Jaczko when he once remarked, in a Commission meeting, to the effect that the

Commission voted on a budget and argued about individual elements at the $500,000 level (or

lower) and then it seemed that the agency staff went off and executed whatever budget it

wanted within Congressional reprogramming limits. Consequently, I do not hold up the NRC's

budget formulation process as a model of perfection but I acknowledge that many of its quirks

arise from our governing structure - that of a Commission and not a unitary executive. The staff

must hold this aspect of our operations harmless in any proposed changes.

c) Utilize foresight methods and stakeholder engagement to get a more informed estimate

of the future to ensure the agency is prepared.

In light of the adequacy of the existing process (i.e., letters of intent and other licensee

forecasting), and in acknowledgement of Commissioner Baran's observation (with which I

agree) that predictions will always be wrong to some degree, I disapprove initiating any effort on

this recommendation at the present time.

11-2) Re-baseline the Work of the Agency

a) Conduct a review of the work performed across the agency and confirm the basis for the

work.

I approve this recommendation but believe there is great peril in creating too elaborate of a

process. I share Chairman Burns' cautions about the tendency of large organizations to spin

such efforts into something of an all-consuming, resource intensive scope and scale.

Consequently, the staff should submit its plan for conducting the re-baseling to the Commission.

This should take the form of an information paper. If the staff has understood the Commission's

expectations for the rebaseling, the staff will have kept us informed. If the plan contained in the

information paper is not in alignment with the Commission's expectations, a member of the

Commission can convert it into a voting matter. Either way, time and effort will not be

squandered on something which fails to align with expectations.

Process Strategy

Il1-1) Improve the transparency and simplify how the NRC calculates and accounts for fees, and

improve the timeliness of when the NRC communicates fee changes.

This effort is already underway. I commend the Chief Financial Officer and the staff of her office

for these efforts and approve their continuation.

111-2) Improve licensing by conducting a business process improvement review of the operating

reactor licensing process and make associated improvements to enhance the predictability,

timeliness, and efficiency of the reviews, while ensuring and measuring the effectiveness and

quality of the reviews.
5

I approve this activity in the abstract but would delegate decision-making about this activity - its

timing, its scope, and the application of its results to the Director of NRR. For Project Aim (the

recommendations before us now and all their progeny over the coming years) to be

implemented successfully and incorporated in a cycle of continuous organizational learning and

process improvement, agency organizations at every level will need to have ownership of the

improvement activities within their span of control. The successes in innovation and

improvement in the regions, remarked upon by Chairman Burns in his vote and observed by

many of us, have their roots in employee engagement and empowerment. This

recommendation should be approved but its design and execution should be delegated to the

Director of NRR in its entirety.

111-3 a. - d.) Improve processes by streamlining, standardizing, and clarifying roles and

responsibilities.

Although generally described in ways that sound meritorious, I agree with Commissioner Baran

that these recommendations lack sufficient detail to be approved or disapproved. Consistent

with my view that employee engagement and empowerment is key to the achievement of our

Project Aim objectives, the staff should develop and implement process improvements that are

within the staff's authority, as appropriate. If something is crosscutting or has a pervasive

agency-wide impact, the staff should seek the Commission's review and approval in those

cases. In all cases, the staff should keep the Commission informed of planned improvements,

of successes, and of challenges encountered along the way.

Again, I thank all of the staff who contributed to this impressive set of recommendations. I do

not support instruction to the EDO to assign a senior leader to own this process because, as I

said at the Regulatory Information Conference, I think this process should and does belong to

every single NRC employee. You will create the NRC you want to be working at in the year

2020 and you will work with and be supported by your management at every level in

establishing the metrics to get there, while holding each other accountable along the way. The

EDO should develop and submit, however, a high level plan for initiating all of the activities

approved in the Commission's SRM, including how they will be sequenced and assigned.

•ristine L. Svinicki 04/Er /15
TO:

FROM:

SUBJECT:

NOTATION VOTE

RESPONSE SHEET

Annette Vietti-Cook, Secretary

COMMISSIONER OSTENDORFF

SECY-15-0015: PROJECT AIM 2020 REPORT AND

RECOMMENDATIONS

Approved X Di

Not Participating

COMMENTS: Below

5approved Abstain

Attached X None

atý SIGNATURe

?,/;0// ýDATE

Entered in STARS" Yes X No
Commissioner Ostendorff's Comments on,

"Project AIM 2020 Report and Recommendations"

I want to thank the Project AIM team and NRC staff for thoroughly assessing future states and

identifying recommendations to move the agency forward constructively. The Project AIM

Team's work, in collaboration with the Guiding Coalition, has presented the Commission a

thoughtful product to structure decisions associated with the NRC's future organization, size,

work practices, and human capital strategy.

Any serious look at assessing these organizational/staffing issues requires a reference

baseline from which to begin the dialog. In the case of Project AIM, I see re-baselining

(identified in recommendation 11-2.a) as the starting point for many of the other

recommendations. While I appreciate staff identifying a target FTE and budget number for

2020, I see the outcome of the re-baselining effort and other consolidation efforts providing the

foundational basis for any realistic target for 2020. Hence, I neither approve nor disapprove

the 3400 FTE number contained in the report. Rather, I think the agency needs an interim FTE

planning number with final staffing decisions to await the re-baselining efforts and other

ancillary initiatives in Project AIM. Consistent with my vote on the NRC Fiscal Year 2016

budget, the staff should plan for an FTE ceiling of 3600 by the end of Fiscal Year 2016 so that

the agency can begin the transition to the eventual target for 2020.

I note that in the coming months, the staff is expecting to receive a review of recommendations

on the "Achieving Exemplary Nuclear Regulation in the 2 1st Century," by the National Academy

of Public Administration. Should this report provide additional insights that should inform

Commission action, I reserve the option of providing additional direction on Project AIM.

As an aside, I also note that moving forward, the Project AIM effort is a journey, and there will

be future engagement with the Commission.

My votes on individual recommendations from the Project AIM report are provided below.

I. People

I-l.a. Develop a strategic workforce plan that ensures the NRC is positioned to have the right

number of people with the right competencies at the right time.

While I approve this step, staff should defer commencing work on this recommendation

until 11-2. a (re-baselining) is completed and approved by the Commission.

Furthermore, staff should include in its plan the additional need to have staff in the right

place, for example filling resident inspector and regional SES positions.

1-2.a. Based on agency priorities developed in I-1.a., develop a plan to identify mission critical

and/or safety-related positions considered most important for immediate needs analysis.

While I approve this step, staff should defer commencing work on this recommendation

until 11-2. a (re-baselining) is completed and approved by the Commission.

1-2.b. Based on outcome of I-2.a., determine timeline for developing competency models for

other agency occupations and functions.
While / approve this step, staff should defer commencing work on this recommendation

until 11-2. a (re-baselining) is completed and approved by the Commission.

I-3.a. Develop or adopt an explicit NRC leadership model (or leadership philosophy) that builds

on the agency's existing culture and supports agility, to include empowering employees by

promoting personal responsibility and accountability along with creative thinking, innovation,

and informed risk-taking in all of our activities.

I do not support the development of a separate NRC leadership model. This step is not

needed and would likely confuse the staff. Rather, the staff should emphasize the

existing Principles of Good Regulation, Organizational Values, and behavior matters

campaign to support effective and efficient decision-making. As we move the agency

forward, the staff should focus attention on those characteristics of the Principles of

Good Regulation and Organizational Values that support empowerment and feeling a

sense of personal responsibility and accountability through creative thinking,

innovation, and informed risk-taking in all of our activities.

I-3.b. Explore greater reliance on centers of expertise to provide leadership, best practices,

research, and support in particular focus areas across the agency. Based on the evaluation,

expand reliance by establishing additional centers of expertise.

While I approve this step, staff should defer commencing work on this recommendation

until 11-2. a (re-baselining) is completed and approved by the Commission. The staff

should provide the Commission with its recommendation for which centers of expertise

should be initiated; the recommended host organization (i.e., program office, regional

office, RES, NSIR); the recommended geographic location; the appropriate balance

between staff, contractors, and Department of Energy laboratories as well as other

outside laboratory or academic institutions and what efficiencies should be expected

from the establishment of these centers of expertise. The staff should use lessons

learned from TABS including NTEU observations, the NMSS/FSME merger, and

existing centers of expertise in its evaluation. Given the significant human capital

expertise in the Office of Research, the Office of Research needs to be listed as a lead

office for this initiative under the Resources breakout for recommendation 1-3. b

I-3.c. Develop a transitional plan that describes the approach to conduct a merger of NRO and

NRR at the appropriate time, along with any associated organizational changes in Region I1.

Approved. The staff should use lessons learned from TABS including NTEU

observations, the NMSS/FSME merger, and the OIS reorganization. Examples of focus

areas to address before any consolidation is initiated are transparency in reassignment

decision-making and adequately resourcing, planning, and managing the change.

Additionally, staff should not limit its consolidation efforts to those areas identified in I3.c, d, and e, but should look at the agency broadly as an outcome of the re-baselining

to ensure that the right work is being done in the most efficient and effective manner.

I-3.d. Evaluate further consolidation of the regional materials program to determine whether

further consolidation would be more efficient. The Materials Program for Regions I and II was

successfully consolidated into Region I in 2006.

Approved.
I-3.e. Evaluate the corporate support functions in the regions to ensure they are appropriately

resourced and identify if any savings can be reached through standardization or centralization

of specific functions. The evaluation should reflect upon the lessons learned from the

Transforming Assets into Business Solutions initiative.

Approved.

I1. Planning Strategy

I1-l.a. Benchmark with other agencies and seek external validation from a third party to clearly

define and justify overhead as well as identify the variable components of Corporate Support.

I acknowledge that efforts had already begun in this area prior to it being considered as

a Project AIM 2020 recommendation and approve these efforts continuing.

11-l.b. Clarify agency priorities and use office and agency add/shed procedures to ensure

effective and efficient use of the staff's time and resources.

I approve addressing the agency priorities and use of the office and agency add/shed

procedures. The Secretary to the Commission should provide the Commission a onetime listing of outstanding Commission directed actions. This list should include staff

recommendations as to which selected actions should be terminated. The Commission

will review the actions to reassess whether each action is still required. Separately, the

staff should provide annual rulemaking plans for Commission review and approval.

These rulemaking plans should include, where appropriate, staff recommendations for

suspending or terminating rulemaking due to changed or changing circumstances.

1-1l.c. Utilize foresight methods and stakeholder engagement to get a more informed estimate

of the future to ensure the agency is prepared.

I disapprove development of a separate annual report with scenarios and extensive

stakeholder outreach. I approve application of lessons learned from the development of

the Project AIM 2020 report regarding assessment of the external environment into the

current strategic planning and budget processes.

11-2.a. Conduct a review of the work performed across the agency and confirm the basis for

the work (the requirement(s) that the work is intended to fulfill, whether it is required by law

(including judicial mandates and regulations), or Commission direction). This activity would be

performed by the staff, with assistance from an outside entity.

I strongly approve re-baselining the work of the agency and, as stated at the beginning

of my vote, believe it is the starting point for many of the other recommendations.

In support of this recommendation, I believe it helpful to provide some historical

context. The last re-baselining effort occurred in the 1990's. After the attacks of 9/11,

the agency significantly increased staffing in the area of security. While appropriate at

the time, now is an opportunity to take a fresh look at the work/staffing of NSIR. I will

note that while NRO (which experienced a rapid expansion in workforce following the

2005 Energy Policy Act), NMSS/FSME, and OIS have all undergone significant

organizational staffing changes, the agency has not taken a recent look at NSIR's work.
Additionally, for almost the past four years, the agency has been addressing regulatory

enhancements post-Fukushima. That work will draw to a close in the near future.

Again, the timing is right for a re-baselining effort.

While it may go without saying, this re-baselining should also ensure that we perform

those work activities necessary to fulfill our regulatory mission. The Executive Director

for Operations (EDO) should actively oversee the re-baselining and provide clear

guidance to ensure a consistent and effective review using top-down high-level

principles. The EDO's guidance shall be submitted to the Commission for review and

approval prior to being implemented. The re-baselining effort should furthermore

provide clearjustification for any work to be continued. As I indicated in my vote on

recommendation Il-l.b., I believe the Commission needs to also assess the work it has

directed the staff to do to determine if it continues to provide appropriate value

compared to the resources expended. The results of the re-baselining should be

provided to the Commission for approval.

III. Process

I11-1. Improve the transparency and simplify how the NRC calculates and accounts for fees,

and improve the timeliness of when the NRC communicates fee changes. Also, assess

alternative methods of allocating fees.

I acknowledge that efforts had already begun in this area prior to it being considered as

a Project AIM 2020 recommendation and approve these efforts continuing.

111-2. Improve licensing by conducting a business process improvement review of the operating

reactor licensing process and make associated.

I approve conducting the business process review. I do not approve deferring the

activity until the completion of existing initiatives and backlog reduction, as a broader

review of the process may negate the need to perform planned changes and could

improve our ability to reduce the backlog. Implementation of this recommendation

should be accelerated to begin in FY16 by reprogramming resources as necessary. If

this effort prevents staff from making progress on reducing the backlog, the staff should

inform the Commission.

111-3.a-d. Improve processes by streamlining, standardizing, and clarifying roles and

responsibilities.

I do not object to implementing these recommendations as long as it does not impact

implementation of the recommendations I have explicitly approved. The staff should

develop clear success criteria for these recommendations so that involved stakeholders

can effectively support implementation and the agency can adequately measure

whether the recommendation achieved its desired outcome.

Again, I want to thank the staff for their professionalism in developing and providing this

product.
TO:

FROM:

SUBJECT:

NOTATION VOTE

RESPONSE SHEET

Annette Vietti-Cook, Secretary

Commissioner Baran

SECY-15-0015: PROJECT AIM 2020 REPORT AND

RECOMMENDATIONS

Approved X Disapproved • Abstain

Not Participating _

COMMENTS: Below Attached ')( None

ATURE

DATE

Entered in "STARS" Yes X No
Commissioner Baran's Comments on SECY-15-0015

Project AIM 2020 Report and Recommendations

I want to express my appreciation to the Project AIM team, the Guiding Coalition, and

every staff member who participated in any of the outreach efforts related to Project AIM 2020

for their hard work and contributions to this report. I also want to thank the National Treasury

Employees Union for their insights on the report and willingness to remain engaged on these

issues going forward.

The completion of the Project AIM 2020 Report is an important first step in the ongoing

process of preparing NRC for the future. Now is the right time for the Commission to take a

close look at the agency as a whole and the ways we can improve our performance while

preserving the many positive aspects of the agency. With that goal in mind, I support a number

of the principles and recommendations presented in the Project AIM Report, including better

matching the agency's resources to its expected workload, increasing agility and efficiency,

strengthening talent management, and sharpening our focus on the overall NRC mission. My

thoughts on the individual Project AIM recommendations are described below.

I. People

Recommendation I-1 (a): Develop a strategic workforce plan that ensures the NRC is positioned

to have the right number of people with the right competencies at the right time.

I approve this recommendation. In my view, the development of a strategic workforce

plan should begin immediately, in parallel with the implementation of other recommendations.

The strategic workforce plan should not be overly burdensome and will necessarily be dynamic,

requiring updates as related items, such as the re-baselining, are completed. However, the staff

can begin assessing the agency's current workforce competencies and identifying any current

or anticipated gaps now. Hiring managers should also work with OCHCO to thoughtfully assess

whether to fill vacancies as they are created by attrition. I agree with Commissioner Ostendorff

that it is appropriate to establish, for planning purposes, an interim FTE ceiling of 3,600 for the

end of Fiscal Year 2016.

Recommendation 1-2: Enhance employee agility by reducing the time required to shift

employees or their work assignments to meet the demands of a changing environment...

I approve this recommendation, which should be implemented upon completion of

recommendation 1-1(a). The recent experience of shifting employees from NRO to NRR should

provide lessons learned that could inform this activity.

Recommendation 1-3(a): Develop or adopt an explicit NRC leadership model (or leadership

philosophy) that builds on the agency's existing culture (Principles of Good Regulation,

Organizational Values) and supports agility, to include empowering employees by promoting

personal responsibility and accountability along with creative thinking, innovation, and informed

risk-taking in all of our activities. Refine the Organizational Values to incorporate those values

necessary to support organizational agility or clarify that they are already included under the

existing values.

I disapprove proceeding with the broad scope of this recommendation at this time.

However, I agree with the Project AIM team that it is important for the agency's leaders at all

levels to focus on agency priorities instead of office-wide or other more narrow priorities. To
assist in this effort, I approve proceeding with Recommendation (a)(viii) to incorporate

candidates' modeling of these leadership attributes into selection decisions for positional

leaders.

Recommendation (a)(ix), which is to assess the NRC's organizational structure to

determine whether staff-to-supervisor ratios can be increased and whether layers of the

hierarchy can be eliminated, is a valuable activity but does not appear to fit naturally within this

recommendation. My understanding is that this ratio has been an agency-wide focus for some

time. The staff should continue to analyze the staff-to-management ratios and whether levels of

management can be decreased when implementing each approved recommendation that

contemplates the overall structure of a program or organization, including the development of a

strategic workforce plan.

After the agency completes implementation of the approved recommendations from the

Project AIM Report, the staff should notify the Commission if it continues to think that the

remaining portions of this recommendation are necessary or would be beneficial.

Recommendation 1-3(b): Explore greater reliance on centers of expertise to provide leadership,

best practices, research, and support in particular focus areas across the agency.

I approve the staff presenting the Commission with a plan and recommendations related

to establishing additional centers of expertise. The plan should evaluate the effectiveness of

existing NRC centers of expertise and provide more details regarding what additional specific

centers of expertise the staff recommends and what office would house each center. The plan

also should address (1) how these centers can avoid the "stove-piping" that the report identifies

as a concern with the existing office structure and (2) how the agency can avoid organizational

complexity and confusion with the creation of additional centers of expertise. I agree with

Commissioner Ostendorff that the Office of Research should be added as a lead office for this

effort.

Recommendation 1-3(c): Develop a transition plan that describes the approach to conduct a

merger of NRO and NRR at the appropriate time...

I disapprove this recommendation at this time. Before the staff conducts an in-depth

examination of how to merge these offices, there should first be an assessment of the pros and

cons of this potential merger and a recommendation to the Commission regarding whether an

NRR-NRO merger is beneficial for the agency. In the absence of this threshold decision about

whether to merge the two offices, I believe it would be premature to expend resources

examining how to execute such a merger.

The staff should provide the Commission with a SECY paper assessing the pros and

cons of merging NRR and NRO and providing recommendations to the Commission on whether

and when to proceed with a merger. In determining whether to merge the two offices, the staff

should consider the lessons learned from the NMSS-FSME merger and the process used to

make the determination to merge NMSS and FSME. The staff also should consider how an

NRR-NRO merger would relate to the formation of any additional centers of expertise.
Recommendation 1-3(d): Evaluate further consolidation of the regional materials program to

determine whether further consolidation would be more efficient.

I approve this recommendation to perform an evaluation of the best way to structure the

regional materials program. The staff should submit to the Commission a SECY paper with a

specific consolidation plan prior to implementation.

Recommendation 1-3(e): Evaluate the corporate support function in the regions to ensure they

are appropriately resourced and identify if any savings can be reached through standardization

or centralization of specific functions. The evaluation should reflect upon the lessons learned

from the Transforming Assets into Business Solutions Initiative.

I approve this recommendation, particularly with regard to taking a close look at whether

"standardization" or "centralization" makes sense for corporate support functions in the regions.

As stated in the recommendation, this activity should incorporate the lessons-learned from the

Turning Assets into Business Solutions (TABS) initiative, including the comments of the National

Treasury Employees Union on that initiative. Additionally, this effort should be coordinated with

implementation of any other corporate support efforts recommended by the Project AIM team

and approved by the Commission.

II. Planning

Recommendation I1-1 (a): Benchmark with other agencies and seek external validation from a

third party to clearly define and justify overhead as well as identify the variable components of

Corporate Support.

I approve this recommendation. Carrying out this activity should involve both properly

defining "corporate support" and actually reducing the amount of agency overhead, however the

term is ultimately defined.

Recommendation 11-1 (b): Clarify agency priorities and use office and agency add/shed

procedures to ensure effective and efficient use of the staff's time and resources.

I approve this recommendation. I agree with Chairman Burns that the staff should

develop a common prioritization process with a supporting add/shed procedure that integrates

all work activities across the agency and includes external mandates.

Recommendation 11-1 (c): Utilize foresight methods and stakeholder engagement to get a more

informed estimate of the future to ensure the agency is prepared.

I encourage the staff to continue engaging stakeholders about expected future workload.

However, I do not believe it is necessary to develop a separate report on this topic. Ultimately,

the agency should focus its efforts on improving its agility rather than on trying to develop ever

more precise predictions of future workload. Predictions of this kind will inevitably be imprecise

so it is important for the agency to be prepared to respond to unanticipated changes in

workload. Therefore, I disapprove this recommendation.
Recommendation 11-2(a): Re-Baseline the work of the agency.

I approve this recommendation. In my view, this effort should begin as soon as

practical. However, I do not believe that re-baselining needs to be completed before other

approved recommendations are implemented.

I agree with Chairman Burns that it is important to have a common understanding of the

scope and scale of this effort. It should be a one-time assessment that results in the

Commission receiving a comprehensive list of activities that can be shed, de-prioritized, or

performed with a reduced resource commitment. However, for the effort to be valuable, the

inquiry should not narrowly focus on whether there is a specific statutory requirement or

Commission direction to perform a given task. The process should also consider what work is

most critical to the safety and security mission of the agency and how the relevant NRC staff

subject matter experts would prioritize their work. If, through this process, the staff finds that the

agency expends resources on tasks that may no longer be necessary but which the staff was

previously directed to perform, the staff should propose changes for Commission consideration

along with a discussion of why the task was originally required and why it is no longer needed.

The staff should be authorized to seek assistance from an outside entity in performing this rebaselining activity, if it determines that such assistance is necessary.

III. Processes

Recommendation Il1-1: Improve the transparency and simplify how the NRC calculates and

accounts for fees, and improve the timeliness of when the NRC communicates fee changes.

I note that this activity is already ongoing and approve continuing efforts to make the fee

rule clearer to licensees, other stakeholders, and the public.

Recommendation 111-2: Improve licensing by conducting a business process improvement

review of the operating reactor licensing process and make associated improvements to

enhance the predictability, timeliness, and efficiency of the reviews, while ensuring and

measuring the effectiveness and quality of the reviews.

I approve this recommendation. As noted in the estimated start time for this

recommendation, implementation of this recommendation should not begin until after the staff

works through the current backlog of licensing actions. However, any lessons learned about

how this backlog originated and how it was resolved should be incorporated into the review.

Recommendation 111-3: Improve processes by streamlining, standardizing, and clarifying roles

and responsibilities.

I defer making a decision on the specific actions proposed in this recommendation. The

staff should provide the Commission with greater detail on these proposed process

improvements in a SECY paper if, during the course of implementing other approved actions, it

determines that the proposed process improvements would be beneficial.

Conclusion

Given the breadth and volume of the recommendations proposed in this report,

sequencing and synchronizing implementation will be critical. OEDO should submit an overall

implementation plan to the Commission for the approved recommendations. This plan should
focus on implementation timeframes and metrics and ensure that it is feasible for the lead

office(s) to execute each approved recommendation within the established schedule. With

OCHCO tasked as the lead office for several of the proposed actions, it should be fully engaged

in the development of this plan.

I agree with Chairman Burns that a senior leader should be dedicated to overseeing the

implementation of approved recommendations. The Executive Director for Operations should

designate the responsible senior leader within one month of the date of the SRM for SECY-1 5-

0015.