UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

SECRETARY February 22, 2016 

COMMISSION VOTING RECORD 

DECISION ITEM: SECY-15-0143 

TITLE: PROJECT AIM AND CENTERS OF EXPERTISE 

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

Memorandum (SRM) of February 22, 2016. 

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

sheets, views and comments 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-15-0143 

RECORDED VOTES 

APPROVED DISAPPROVED ABSTAINING N/P* COMMENTS DATE 

Chrm. Burns x x 12/4/15 

Comr. Svinicki x x x 2/5/16 

Comr. Ostendorff x x 1/816 

Comr. Baran x x 1/816 

*Not Participating 
TO: 

FROM: 

SUBJECT: 

NOTATION VOTE 

RESPONSE SHEET 

Annette Vietti-Cook, Secretary 

Chairman Burns 

SECY-15-0143: PROJECT AIM AND CENTERS OF 

EXPERTISE 

Approved X Disapproved Abstain Not Participating -- --

COMMENTS: Below Attached X None 

Entered in STARS 

Yes X ignature 

No 1 December 2015 

Date 
Chairman Burns Comments on SECY-15-0143, "Project AIM and Centers of Expertise" 

I commend the staff for its fulsome evaluation of existing Centers of Expertise (COEs) and 

consideration of 11 areas to determine whether expansion of this organizational model will lead 

to a more efficient use of agency resources. I approve the staff's recommendation to pursue 

COEs in the areas of rulemaking, allegations, external hazards evaluations, and technical 

specifications. My approval of these COEs is contingent upon completion of agency guidance 

on identifying, evaluating, and implementing COEs. 

Although the projected resource saving are small at the onset of implementing the COEs, I 

believe making these organizational changes will improve the agency's ability to respond to 

changing workloads and enhance agency wide standardization, which is the core goal of the 

Project AIM 2020 initiative. Further, the staff has taken a conservative approach by 

recommending limited scope COE's for allegations, external hazards and technical specification 

activities; thus, the resource savings are minimal. Accordingly, as part of the evaluation and 

implementation of COE's in these three areas, the staff should reevaluate whether full scope 

COE's can be accomplished in the near-term by establishing risk mitigation strategies. 
TO: 

FROM: 

SUBJECT: 

NOTATION VOTE 

RESPONSE SHEET 

Annette Vietti-Cook, Secretary 

COMMISSIONER SVINICKI 

SECY-15-0143: PROJECT AIM AND CENTERS OF 

EXPERTISE 

Approved XX In Part Disapproved XX In Part Abstain __ 

Not Participating __ 

COMMENTS: Below Attached XX None --

~ IGNT

~sew 

uRE ~-

Entered on "STARS" Yes _JNo _ 
Commissioner Svinicki's Comments on SECY-15-0143 

Project Aim and Centers of Expertise 

I approve the recommendation to pursue an expansion of the existing limited scope Center of 

Expertise (COE) for allegations housed within the Office of Enforcement (OE) to include the 

allegation coordination functions for headquarters. I disapprove the proposed recommendations 

for pursuing an agency wide COE for rulemaking and additional limited scope centers in the 

areas of external hazards evaluations and technical specifications. I join Chairman Burns and 

Commissioner Baran in conditioning my approval of the establishment of these or any other 

COEs (Recommendation 1) upon the completion of agency guidance on identifying, evaluating, 

and implementing COEs (Recommendation 2). Consistent with this, I approve the staff's 

Recommendation 2 and stipulate that it must be completed prior to the implementation of any or 

all parts of Recommendation 1. 

Although I am reluctant to belabor my skepticism of the benefits potentially accruing from the 

broad or pervasive adoption of "centers" here at the NRC, given the nature of our work and the 

way we conduct it, I was unexpectedly assisted during the Commission's public meeting on 

December 17, 2015, when, in response to my question regarding the establishment of a COE 

for rulemaking of "Why is it superior?", the answer given by the staff was ''I'm not saying it is 

superior. I'm saying it is - - it's a method you can do, right? This is a method we can use." 

Although the staff went on to elaborate conceptual benefits of centralization, they concluded 

with this: "But I think, Commissioner Svinicki, in answer to your question, it remains to be seen 

if it's superior from the current. I'm not sure we can say that right now." 

The staff was directed to examine the lessons learned from the agency's TABS initiative in 

constructing these COE proposals for the Commission's consideration. One of those lessons 

was "build a clear case for change." Have we done that here? 

I approve the COE for allegations on the basis that it is a clearly distinguishable case from the 

staff's other proposals. First, the process is fundamentally amenable to centralization. Second, 

it is an expansion of a currently well-functioning process. Third, the staff has estimated 

quantifiable savings to be achieved and assesses that this proposal "improves organizational 

agility and consistency across the agency with low risk of negative side effects." 

I am far from convinced that the same is true of the staff's other proposals for centers. Without 

much effort at all on my part to build a case against the idea, I readily note the following . The 

centralization of rulemaking has been tried at the NRC, was rejected as a failure, and was 

eventually corrected into the de-centralization we have today. The same correction is likely to 

be made within the next decade, but unfortunately only after we have played out the old adage 

of "The lesson had been learned but we had to keep relearning it until each of us individually 

experienced the joy of learning it." With respect to centralizing technical expertise, I am 

attaching a colorful NRC memorandum from 1979 describing how well that particular effort 

seems to have worked here. 

In light of these concerns and the ugly agency experiences of the past, final agency guidance 

on implementing COEs should include the following elements, which are essential to the 

effective functioning of this structure. 

• No COE shall have ultimate or final decision making authority for individual licensing 

actions or the resolution or determination of regulatory outcomes. Centers provide 

1 
technical input and safety analysis. Decision making authority resides with the program 

office line management consistent with existing delegations. 

• Centers shall function as an agency "in-sourcing" of centralized expertise akin to an inhouse consultancy or contractor. Therefore, centers shall not be in the concurrence 

chain for regulatory products for which they provide input. 

• Program offices shall continue to identify individual Project Managers (PMs) for licensing 

actions/facilities within the line management chain. These PMs shall continue to 

respond to and communicate with licensees directly. 

• Agency timeliness metrics associated with the review of licensing actions shall continue 

to be monitored and tracked by the program offices and program office performance 

shall continue to be assessed against these metrics. 

• The performance of the COEs shall be evaluated by the program offices against metrics 

established by the program offices at the initiation of each task. 

Consistent with existing Commission direction, the staff continues to evaluate and plan for the 

eventual merger of the Office of New Reactors (NRO) into the Office of Nuclear Reactor 

Regulation (NRR), whence it came. The Commission's direction in this regard has its roots in 

the changed circumstance of declining work associated with new reactors. In light of this 

ramping down, the staff should not artificially inflate the work load of NRO to stave off this 

inevitable reunification by establishing a COE for external hazards in NRO. If establishment of 

the COE for external hazards is approved by the Commission, it should be established within 

NRR and the appropriate staff from NRO should be transferred to NRR, coincident with the 

COE's establishment. Instead of potentially staving off the reunification, establishing the center 

in NRR would improve the efficiency of the eventual merger by housing the expertise where it 

will eventually reside for the long term. 

In a parallel vein, rulemaking must be informed by NRC's technical subject matter experts but it 

is simply impossible to transfer every needed type of expertise into the new COE for 

rulemaking, should it be approved by the Commission. (This is fundamentally why rulemaking 

is decentralized now, and should stay so, but I have apparently failed to persuade on this point.) 

Consequently, the rulemaking COE should not reside in a program office but rather in ADM. 

The staff's dismissal of this idea and selection of the Office of Nuclear Materials, Safety, and 

Safeguards (NMSS) to house their new COE strikes me as an arbitrary sidestepping of the 

problem, which does not and cannot solve the fundamental technical coordination issue, and 

likely another attempt at "normalizing" workload between the offices. (As an aside, we 

normalize through FTE allocations to each office. Unless we are levelizing for purposes of 

organizational ego, we've already got this one taken care of.) As the staffs working group 

acknowledged, "a rulemaking COE in ADM would benefit from the existing experience that ADM 

has in working across business lines to prioritize and coordinate rulemaking activities, as well as 

ADM's established relationships with external stakeholders involved in the rulemaking process." 

Surely the staff does not intend to house technical staff with every possibly relevant subject 

matter expertise in this new rulemaking COE. Technical staff should not be transferred to 

populate this new rulemaking COE. In any event, Mr. Martin's memorandum makes clear the 

many pitfalls of such a thing and I need not say more. 

In closing, I repeat the admonishment of Mr. Martin from the attached memorandum: "We 

should not fragment this work in a fashion which is inherently unmanageable." In light of the 

Commission's likely approval of the creation of these COEs and, I fear, the proliferation of more 

of them, the staff should establish safeguards on the process in order to ensure greater 

transparency for those with pending matters before the agency, continued line management 

2 
accountability for meeting agency performance metrics, and the minimization of NRC employee 

frustration in carrying out our important day-to-day work. 

3 
Attachment to Commissioner Svinicki 's 

Comments on SECY-15-0143 

.. 

M:MOP.At:DUM FOR: . 

FROM: 

SUBJECT: 

UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASH INC TON, O. C. 20HS 

,. :'· 

AUG 8 · 1979 . 

Robert S. Brown, Jr ., Ass istant Di rector · Chi ef, Program Support Branc.h , NHSS 

John B. Ma rt in 11 Oi ret tor 

Division of Waste Management 

CEN TRALJ Z£0 VERSUS DECEIHRALIZED CONCEPT FOR SITE 

TECHNOLOGY (NMSS -79-1153) 

. . ~ . 

The "center of excellence" concept has proven to be unworkable. Despite 

a 11 the promises and written memos of uriders tanding between Oen ton and 

Cliff Smith, the he 1 p has never bee n there \<!hen we -needed it. They 

constantly have found other reactor matters more pressing. . . Jn addition, we have. no management control over their people. This leads 

to endless proble:ns on issues l-thich usually require management judgments 

to resolve. The NRR people having no responsibility for the licensing · issues at hand tend to be prirna donnas and are very hard for us to get 

answers from or to direct their approach. · . . 

Another fact of 1 ife is .~hat their own "'ir.anagement cannot control them either. 

This leads to cQntinual Mexican standoffs. W~ would not have these problems 

with our own people who have.- .a direct sense of responsibility for the work 

and hav~ to live with the results. In addition. we can manage their efforts 

so we get what we want when we want it. 

Another fact of life is that the NRR mode of operation makes ft very difficu1 t 

to deal with problems that ar e non·routine~ Their whole area is so fegfrnented 

and 1 itigative of nature that they have a hard time dealing with our types 

of problems. We are able to train our own people to deal with t~ese nonroutine problems effectively. · · 

·. 

Jn surmiary, I consider depending on NRR to be unsound based on past experience. The help is never there when needed. l·lhen we do get it. it's often more 

trouble than help. In WM. we have very different, non-routine prob1e-ns 

completely outside the experience base of NRR. We should not fragment 

this work in a fashion which is inherentl unmanageable. , 

.... B. Hilrtin 11 Direct or 

Division of Waste Management 
TO: 

FROM: 

SUBJECT: 

NOTATION VOTE 

RESPONSE SHEET 

Annette Vietti-Cook, Secretary 

Commissioner Ostendorff 

SECY-15-0143: PROJECT AIM AND CENTERS OF 

EXPERTISE 

Approved X Disapproved Abstain Not Participating 

COMMENTS: Below 

Entered in STARS 

Yes 

No 

--

Attached X None 

Sign ~ I Date 

I ! fl/, 
Commissioner Ostendorff's Comments on SECY-15-0143: 

Project AIM and Centers of Expertise 

I thank the staff for its efforts to evaluate Centers of Expertise (COEs) in response to the Staff 

Requirements Memorandum for SECY-15-0015, "Project AIM 2020 Report and Recommendations." 

In my vote on SECY-15-0015, I approved moving forward with establishing additional COEs but 

believed that work should be deferred until the rebaselining work was completed and approved by 

the Commission. That vote was cast with the expectation of a more robust assessment of, and 

recommendation for, potential COEs built on the rebaselining efforts. The staff's recommendations 

in SECY-15-0143 are more modest than I envisioned . That said, I am supportive of moving forward 

with establishing COEs. COEs will be an important tool for the agency to address the changing 

external environment as they, can enhance coordination and mutual support among offices, 

increase the ability of the organization to adapt to surges in work, improve efficiency, enhance 

cross-office standardization, and expand employee knowledge and experience. 

Consistent with the Chairman's vote, I approve the staff's Recommendation 1 to pursue COEs for 

Rulemaking, Allegations, External Hazards Evaluation, and Technical Specifications. Regarding 

the COE for Rulemaking, I believe such a move is appropriate at this time of constrained resources 

and the associated need for increased agility. I see several benefits to this change. First, a 

Rulemaking COE will allow better normalization of workload, easier shifting of resources to 

accommodate changing priorities, and better cross training for project management staff as 

rulemakings, by their very nature, have cyclical resource needs. Second, while rulemaking 

processes and procedures are similar across the agency, a Rulemaking COE would ensure that 

these processes and procedures are implemented in a more consistent manner. Lastly, as the 

number of rulemakings decrease, housing resources centrally would allow for easier rightsizing 

while ensuring that rulemaking activities continue on the appropriate schedule. The staff has 

committed to re-engage the Commission if issues arise during the implementation of COEs, which 

is appropriate. 

I also approve the staff's Recommendation 2 to fully develop and complete agency guidance on 

identifying, evaluating, and implementing future COEs. In its assessment, the staff identified several 

potentially advantageous COEs but did not recommend their creation at this time due to potential 

disruption of ongoing agency mission-critical work. I respect these concerns and note the need for 

future evaluation to determine whether these or other COEs should be created at some appropriate 

future time. To ensure that the agency maximizes the benefits of COEs, the staff should assess the 

impacts of the new COEs and continue consideration of additional COEs as appropriate. In 

implementing Recommendation 2, consistent with prior Commission direction, the staff should 

continue to refine how it ensures that "stove-piping" is mitigated and organizational complexity and 

confusion is minimized. Additionally, the staff should: 1) assess successes and lessons learned 

from implementation of the COEs proposed in Recommendation 1 and issue associated agencywide communications within one year of their implementation; and 2) as resources become 

available, reassess the viability of those COEs that the staff identified could be appropriate, but for 

the impact on current agency work. 
TO: 

FROM: 

SUBJECT: 

NOTATION VOTE 

RESPONSE SHEET 

Annette Vietti-Cook, Secretary 

Commissioner Baran 

SECY-15-0143: PROJECT AIM AND CENTERS OF 

EXPERTISE 

Approved X Disapproved Abstain Not Participating 

COMMENTS: Below Attached X None 

Entered in STARS 

Yes XX 

No 

Date 
Commissioner Saran's Comments on SECY-15-0143, 

"Project Aim and Centers of Expertise" 

In this paper, the staff recommends pursuing three limited scope Centers of Expertise 

(COEs) for allegations, external hazard evaluations, and technical specifications, as well as an 

agencywide rulemaking COE. I would like to thank the staff for several thoughtful and frank 

discussions that assisted me during my consideration of the paper. I approve the staff's 

proposal, contingent upon completion of agency guidance for identifying, evaluating , and 

implementing COEs. 

While the initial resource savings of this Project Aim initiative are modest, the staff has 

made a strong case that the COEs will boost NRC's agility by improving its ability to shift 

resources and work assignments to meet future workload. The CO Es also are expected to 

enhance consistency and knowledge management. 

Effective implementation will be the key to realizing additional efficiencies and capacities 

over the long term. This is particularly true for the rulemaking COE to be located in the Office of 

Nuclear Materials Safety and Safeguards. As the staff acknowledges, establishing clear lines of 

responsibility, accountability, and communication will be critical to the success of this COE.