SECRETARY 

DECISION ITEM: 

TITLE: 

UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

April 13, 2016 

COMMISSION VOTING RECORD 

SECY-16-0009 

RECOMMENDATIONS RESULTING FROM THE INTEGRATED 

PRIORITIZATION AND RE-BASELINING OF AGENCY 

ACTIVITIES 

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

Memorandum (SAM) of April 13, 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 

Secretary of the Commission 

~ 
VOTING SUMMARY - SECY-16-0009 

RECORDED VOTES 

NOT 

APPROVED DISAPPROVED ABSTAIN PARTICIPATING COMMENTS DATE 

Chrm. Burns x x 03/14/16 

Cmr. Svinicki x x 03/24/16 

Cmr. Ostendorff x x x 03/21 /16 

Cmr. Baran x x x 03/16/16 
TO: 

FROM: 

SUBJECT: 

NOTATION VOTE 

RESPONSE SHEET 

Annette Vietti-Cook, Secretary 

Chairman Burns 

SECY-16-0009: RECOMMENDATIONS RESULTING 

FROM THE INTEGRATED PRIORITIZATION AND REBASELINING OF AGENCY ACTIVITIES 

Approved X Disapproved Abstain Not Participating - - -- --

COMMENTS: Below 

Entered in STARS 

Yes X 

No 

Attached X None 

Date 
Chairman Burns's Comments on SECY-16-0009 

Recommendations Resulting from the Integrated Prioritization and Re-baselining of 

Agency Activities 

I want to thank the staff for the thorough and methodical approach, which resulted in 151 

individual activities that could be halted or performed with fewer resources. I commend the 

Executive Director for Operations (EDO) and the Chief Financial Officer for providing 

opportunities for all the staff to be engaged in the process. I believe the common prioritization 

and revised add/shed procedure was an important initial step in identifying areas to achieve 

savings. These procedures will also be valuable in the future in determining workload priorities 

and ensuring the budget remains appropriately sized in FY 2018 and beyond. 

I have carefully reviewed the staff's recommendations and agree that the proposed items can 

be shed, de-prioritized, or performed with fewer resources without impacting our ability to meet 

our mission. Accordingly, I approve implementing these workload changes as soon as 

practicable. Additionally, I approve delegation to the EDO the authority to issue Federal 

Register notices and other documentation to inform the public of the rulemaking activities the 

Commission approves for delay or termination. 

While the staff successfully completed this re-baselining effort and identified significant 

reductions for the FY 2017 budget, my expectation is that the subsequent papers scheduled to 

be submitted to the Commission will provide additional opportunities to achieve efficiencies in 

the long-term. I expect those proposals to include reviews of work processes, projections of the 

workload five years out and recommendations for appropriate resources and staffing that align 

with the projected workload. It is important that the completion of the re-baselining effort and 

the other Project AIM tasks must be viewed by the NRC staff and stakeholders as the beginning 

and not the end in our goal to be better positioned to respond to the challenges of 2020 and 

beyond. 

1j ~ March 2016 
TO: 

FROM: 

SUBJECT: 

NOTATION VOTE 

RESPONSE SHEET 

Annette Vietti-Cook, Secretary 

COMMISSIONER SVINICKI 

SECY-16-0009: RECOMMENDATIONS RESULTING 

FROM THE INTEGRATED PRIORITIZATION AND REBASELINING OF AGENCY ACTIVITIES 

Approved XX Disapproved Abstain Not Participating -- -- --

COMMENTS: Below Attached XX None 

j°ATE 

Entered on "STARS" Yes ~ No_ 
Commissioner Svinicki's Comments on SECY-16-0009 

Recommendations Resulting from the Integrated Prioritization 

and Re-baselining of Agency Activities 

Let me begin by commending the staff on the extensive work undertaken to produce this set of 

recommendations (Enclosure 1 ). I have carefully reviewed the staff's recommendations and 

have probed for further elaboration and explanation regarding a large number of the individual 

items. In all cases, I have found the staff's approach to these recommendations to be cautious, 

thorough, and appropriately conservative with respect to potential impacts to our vital safety and 

security missions. In light of this, I approve implementing these workload changes and approve 

delegating to the Executive Director for Operations the authority to issue any necessary Federal 

Register notices and other documentation to inform the public of the approved changes to 

rulemaking activities. It is my expectation that the staff will monitor the effect of these approved 

changes, commensurate with their significance, and report back to the Commission on future 

adjustments or course corrections that are needed, if any. 

It takes tremendous organizational objectivity to step back and analyze your own work, how you 

are approaching that work, and the contribution that work is making or is likely to make to the 

organization's overarching goals and objectives. I am proud of the NRC staff for exhibiting such 

objectivity, professionalism, and demanding standards of themselves and their organization. An 

endeavor like this re-baselining is even more challenging in a regulatory agency, where nearly 

every single element of work can be portrayed as forming an essential underpinning of public 

health and safety. But while our activities all generally have merit, that does not mean they are 

all effective or will return a health and safety benefit commensurate with the time we are 

spending on them. The tendency for me, as a reviewer of this work, is to pick apart the bases 

and question the impacts of individual recommendations. As a necessary part of my due 

diligence, I have done so and through this exercise, the staff has secured my confidence in the 

worth of their recommendations. Altering inspection protocols, durations, or frequencies does 

not mean we don't care about plant safety. Modifying the amount or type of fire research we 

conduct does not mean we abandon our care about fire safety. To suggest otherwise would 

mean that in our nearly $1 billion budget, nothing can be altered, nothing can be changed, 

everything is perfectly planned and executed, and not one penny is poorly allocated. We have 

not approached Project Aim in this fashion. 

The difficult part comes in identifying concrete next steps. Beyond this se,t of things most 

obvious to us, we must now figure out where to turn our attention. Two activities offer promise. 

The first is the Strategic Workforce Plan (SWP). The staff has admitted to experiencing a 

number of difficulties with developing a true picture of our skills mix and projected needs. In 

response, the staff developed the SWP Action Plan to make better progress in this regard. 

Candidly, I observe that the staff continues to struggle on this topic. The staff should develop a 

dashboard to track progress against the Action Plan and establish more concrete milestones for 

each element of the plan. The staff should update the Commission on strategic workforce 

restructuring every six months and in the first of these updates should propose a full time 

equivalent staffing target for the end of Project Aim in the year 2020, informed by the workforce 

planning. 

A needed complement to a renewed look at strategic workforce planning is improving the 

efficiency and effectiveness of how we do what we do. The staff's paper on Additional Rebaselining Products (SECY-16-0035) makes general reference to longer term Project Aim 

activities but lacks the specificity needed in some areas and lacks milestones for routine status 

reporting to the Commission. The identification and achievement of future efficiencies may 
have an over reliance on NRC's culture of continuous improvement, from which good things are 

presumed to flow. More practically, the staff should return to the Commission within 90 days 

with a set of specific business improvement areas or proposed "deep-dive" / "zero-based" 

reviews into agency functions or processes that do not appear to be performing efficiently and 

proposed timeframes within which these reviews will be conducted and recommendations 

developed. 

The greatest danger for multi-year improvement initiatives is that they will stall out as a result of 

organizational fatigue or skepticism. I share the Chairman's vision that Project Aim "must be 

viewed by the NRC staff and stakeholders as the beginning and not the end in our goal to be 

better positioned to respond to the challenges of 2020 and beyond." Much hard work has been 

completed but much lies before us. A refocusing of our efforts on higher fidelity strategic 

workforce planning and additional business process improvement reviews, with a focus on zerobased reviews in targeted areas, is essential to achieving this vision. 
TO: 

FROM: 

SUBJECT: 

NOTATION VOTE 

RESPONSE SHEET 

Annette Vietti-Cook, Secretary 

Commissioner Ostendorff 

SECY-16-0009: RECOMMENDATIONS RESULTING 

FROM THE INTEGRATED PRIORITIZATION AND REBASELINING OF AGENCY ACTIVITIES 

Approved X Disapproved X Abstain Not Participating 

COMMENTS: Below 

Entered in STARS 

Yes x --

No 

--

Attached X None 

Sig ~ 

Date 
Commissioner Ostendorff's Comments on SECY-16-0009, 

"Recommendations Resulting from the Integrated Prioritization and Re-Baselining of 

Agency Activities." 

I thank the Project AIM team and the offices for all the effort required to develop the integrated 

prioritization and re-baselining of agency activities. Overall, the staff identified a thoughtful set 

of proposed reductions and, with the exceptions discussed below, I approve the staff's proposal. 

In my vote on SECY-15-0015, "Project AIM 2020 Report and Recommendations," I stated, "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." To inform 

my decision on the present SECY paper, I analyzed the staff's recommendations using the 

description of re-baselining that the staff identified in SECY-15-0015 recommendation 11-2.a. 

Specifically, "the re-baselining review should 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)." I also considered SECY-15-0105, "Plan for Integrated 

Prioritization and Re-Baselining of Agency Activities," which indicated that "Staff will examine 

the bottom budget quartile to identify activities that can be shed or performed with fewer 

resources on a permanent basis [emphasis added], starting in FY 2016 or FY 2017." 

I am concerned that several of the proposed items do not seem to align with the re-baselining 

expectations, and I provide specific comments on those items below. 

• Item 6-delaying the Dodd-Frank Rulemaking: I agree with Commissioner Saran's vote 

to disapprove the staff delaying this work. 

• Item 39-eliminating funding for the Minority Serving Institutions Programs (MSIP): 

approve eliminating the funding for the MSIP. The staff should ensure that the IUP 

continues to support activities that were covered by the MSIP. 

• Items 51 , 52, and 59-decreasing funding for fire protection research: I approve the 

staff's proposal with the exception of those activities that relate to High-Energy Arc 

Faults testing. 

• Item 108 - Decrease resources for Rll Construction Inspection Program : It is not clear 

from this item that the staff's approach reached the underlying objective of Project AIM, 

specifically, to project future construction inspection requirements given the significant 

decrease in construction activity in the 2017 - 2020 period compared to projections from 

2006. I approve the proposed cut, but, in my view, there is an opportunity for future cuts. 

Page 1 of 1 
TO: 

FROM: 

SUBJECT: 

NOTATION VOTE 

RESPONSE SHEET 

Annette Vietti-Cook, Secretary 

Commissioner Baran 

SECY-16-0009: RECOMMENDATIONS RESULTING 

FROM THE INTEGRATED PRIORITIZATION AND REBASELINING OF AGENCY ACTIVITIES 

Approved X in part Disapproved X in part Abstain Not Participating 

COMMENTS: 

Entered in STARS 

Yes XX 

No 

Below 

-- --

Attached X 

re 3/Jt.p/}~ 

Date 

None 
Commissioner Saran's Comments on SECY-16-0009, "Recommendations Resulting from the 

Integrated Prioritization and Re-Baselining of Agency Activities" 

The NRC staff did a tremendous amount of work to generate 151 proposals to reduce agency 

expenditures. I appreciate the staff's systematic approach to prioritizing the work of the agency and am 

impressed with their willingness to scrutinize what work we do and how we do it. I took a hard look at 

the recommended measures to ensure that they would not compromise NRC's ability to carry out its 

safety mission. In my view, most of these items make a lot of sense. 

I approve the items proposed by the staff with the exception of those listed below. The 

disapproved items (or elements of items) represent $1,453,000 in contract dollars and 13.7 FTE. 

Therefore, I support over 92% of the total reductions proposed by the staff. 

#6, Delay of the Dodd-Frank Act of 2010 rulemaking: In my view, it is not appropriate to save funds 

by further postponing NRC compliance with a 6-year old statutory mandate. 

#35, Eliminating certain updates on the status of Japan lessons learned activities: I approve 

eliminating the six-month updates, but the staff should continue the monthly updates to the 

Commission. This approach will keep the Commission promptly informed of post-Fukushima 

developments while realizing most of the savings identified by the staff. 

#37, Proposed changes to materials licenses and related bankruptcy reviews: I approve the 

centralization of bankruptcy reviews at NRC headquarters but disapprove the remainder of this 

proposal. Changing the materials license terms from 10 years to 15 years is a significant policy 

change. The staff has not provided a basis to justify this change or conducted a thorough evaluation of 

the pros and cons of the proposal. 

#46, Eliminating the informal staff review of individual reactor operator applicants' appeals: 

This proposal risks compromising the fairness of NRC's existing process, does not account for ongoing 

efforts to enhance the process, and could increase the number of formal adjudications, which likely 

would erase any savings generated by this proposal. 

#51, 52, and #59, Fire research: I approve the staff proposal, except as it relates to the High Energy 

Arc Faults and Human Reliability Analysis research. This work should continue because it has the 

potential to identify elements of NRC's regulatory requirements that may be insufficiently conservative. 

#62, Eliminating research related to environmental transport of radiological releases from 

severe accidents to aquatic systems: As the experience at Fukushima Daiichi demonstrates, 

managing large quantities of radioactive water can be a significant challenge following severe 

accidents. We should continue work in this area. 

#63, Reduce the rate of updating SPAR models: I do not support efforts to move away from the use 

of SPAR models, which allow the NRC staff to conduct independent analyses related to inspection 

findings, enforcement discretion, incident investigations, generic issues, and license amendment 

requests. Slowing updates to SPAR models would directly impact the effectiveness of these important 

tools. 

#82, Reducing Technical Library subscriptions and librarian services: I approve this proposal with 

the exception of the cancellation of the E&E suite of subscriptions. That subscription, which represents 

just 3% of the identified potential savings, should be restored. 
#83, Reduce staff support for FOIA/Privacy Act activities: As the staff acknowledges, reduced 

resources in this area may delay FOIA responses and impede the agency's ability to comply with FOIA 

timeliness requirements. 

#88, Eliminate contractor support for public meetings and workshops on Emergency 

Preparedness activities: Given the high level of interest in the decommissioning rulemaking, public 

meetings and workshops on the emergency preparedness elements of this rulemaking are valuable. 

#94, Changes to the 2.206 process: In my view, any major changes to the 2.206 process should be 

considered as part of a transparent, broader review of the process rather than in isolation. 

#95, Eliminating licensing commitment audits, specific reviews, and revising public meeting 

guidance: As the staff acknowledges, some elements of these reductions are inconsistent with the 

SONGS lessons learned report and the Davis-Besse lessons learned report. 

#101, Efficiencies in the enforcement process: I approve this proposal with two exceptions. I do not 

support reducing the Office of Enforcement's (OE) support for the 2.206 petition process or eliminating 

its reviews of FOIA responses related to discrimination cases. As I discussed above, substantial 

changes to the 2.206 process should be considered in the context of a broader examination of the 

process. With respect to the FOIA reviews, the staff admits that eliminating OE's review of FOIA 

responses for discrimination cases may result in the identity of more allegers and witnesses being 

inappropriately released to the general public. That would be an unacceptable result. 

#110, Revising IMC 2800 for inspections of materials licensees: I do not support reductions in 

baseline inspections as part of the Project Aim effort. This item involves significant changes to baseline 

inspections, including reducing the frequency and number of inspections for some licensees. 

#111, Efficiencies to be gained by risk-informing the inspection hours allocated to 

decommissioning reactors: This item also would reduce inspection hours and potentially the time 

available to inspectors to follow up on their observations. 

#118, Revise the guidance for the Fuel Cycle Inspection Program to result in fewer reactive 

inspections: These projected savings appear to be contingent upon changes in licensee behavior 

rather than upon NRC practice. Moreover, the stated purpose of this measure is to reduce the number 

of inspections initiated in response to potentially safety-significant events at fuel cycle facilities. I do not 

support reducing safety inspections to achieve agency cost savings. 

#126, Reduce sampling size for operating reactor baseline inspection procedures: According to 

the staff, this item involves both reduced inspection hours (reduced sampling) and fewer plants being 

inspected because of decommissioning (reduction in the number of reactors). However, my 

understanding is that the savings associated with a reduction in the number of reactors are negligible in 

FY17 and FY18. Nevertheless, I approve the "fact of life" change to account for fewer plants but 

disapprove reducing baseline inspection hours.