DEFENSE NUCLEAR FACILITIES
SAFETY BOARD
Washington, DC 20004-2901

 

June 27, 2017

From: Daniel J. Santos, Board Member

To: Sean Sullivan, Acting Chairman
Bruce Hamilton, Acting Vice Chairman
Jessie Roberson, Board Member
Joyce Connery, Board Member
James Biggins, General Counsel

Subject: Memo from Acting Chairman Sullivan dated June 12, 2017 on draft Defense Nuclear
Facilities Safety Board reform plan

The subject memo asked for an informal review of a high level draft of a Defense
Nuclear Facilities Safety Board reform plan developed by and to be sent by the Acting
Chairman to the Of?ce of Management and Budget (OMB) in response to Executive Order
13781 of March 13, 2017 [Comprehensive Plan for Reorganizing the Executive Branch) and
OMB Memorandum of April 12, 2017 (Comprehensive Plan for Reforming the Federal
Government and Reducing the Federal Civilian Workforce}. This proposed reform plan was
developed without engaging the Board in a manner consistent with the Board?s enabling statute.
The justi?cation provided by the Acting Chairman was that Executive Order 13781 
agency heads to submit a plan. . and therefore, the Acting Chairman considers that the
Executive Order only solicits his personal opinion. Therefore, the draft reform plan does not
re?ect the collective opinion of the Board and does not re?ect my opinion or support. I lack
con?dence that the input I am providing will receive due consideration by the full Board (given
the lack of formality in this process] or by the Acting Chairman (given how previous input I have
provided in other matters was addressed].

I consider that the primary proposal in the draft plan is ?awed and that aspects of the
secondary proposal contradict the primary proposal and are inconsistent with the guidance
received from OMB as implementation over time could lead to greater inef?ciencies, duplication
of efforts, less accountability, and overall unnecessary agency growth. While there are some
aspects of the second proposal that are worth exploring and further discussing as a Board, I
strongly recommend to the Acting Chairman and the Board that given the small size, mission,
and structure of the that we seek a waiver to Executive Order 13781. This is not a new
practice given that the Acting Chairman has already solicited other waivers to Executive Order
13 777 of February 24, 2017 ?Enforcing the Regulatory Reform Agenda?, and to Presidential
Memorandum of January 23, 2017 ?Hiring Freeze.? It is my understanding that prior to sharing
the plan with the Board Members, the Acting Chairman had already informed OMB that the
will not be soliciting a waiver for Executive Order 13781. I strongly recommend that

we change this position.

Pagelofil

I do support internal reform and have formally communicated, following Board
processes, several actionable improvement initiatives to the Board in multiple occasions. While
the Board has acted on some, additional work remains. I look forward to continue working with
all my fellow Board Members in these endeavors.

 

 

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