The reality star's attorney Jay Surgent tells TMZ ... his client doesn't want to move prisons because he's afraid guards and officials within the new facility will retaliate against him for speaking out against living conditions in his current pad, FPC Pensacola.

Basically, Todd -- who's doing a 12-year bid for a slew of fraud charges -- thinks his well-documented criticism of FPCP will have other prison officials taking aim at him ... and he's keeping his head on a swivel.

Jay says TC's heard through the grapevine he could be on his way out after ripping on Pensacola for disgusting food, possible mold and bad plumbing ... among other issues.

It's all hypothetical currently -- Jay hasn't received formal notice of transfer or anything like that -- but says if Todd is booted out of Florida, he'll most likely stay in the federal system, not a state prison ... as his daughter, Savannah, said he might be.

Family is another reason Todd's lookin' to stay in Pensacola ... Savannah's consistently visiting him and her mom, Julie, who's locked up in Kentucky. Todd's worried they'll move him too far away, and it'll make it harder for Savannah to visit him.

Plus, Surgent says Chrisley's become a mentor to Pensacola's other inmates ... a good thing too since Surgent told us a few months ago Todd believes God sent him to prison to help other inmates.

For its part, a spokesperson for the Federal Bureau of Prisons said it doesn't comment on individual prison transfers, but explained it reassigns prisoners for a variety of reasons including medical needs and or security reasons.

The FBOP spokesperson adds the government agency's top priority is providing safe, secure and humane accommodations for prisoners. The org encourages incarcerated individuals to go through the proper channels when voicing their concerns.