ML19105B179

NRC-2019-000235 - Resp 1 - Final, Agency Records Subject to the Request Are Enclosed

ML19105B179
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Issue date:	04/10/2019
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U.S. Nuclear Regulatory Commission

• Real Property Efficiency Plan Federal Property Man.agement Reform Act of 2016 Implementation FY 2019 - FY 2023 September 2018

Ta_ble of Contents INTRODUCTION ... :........... :......................: ............................... :......................._............................... 1 ROLES

. AND RESPONSIBILITIES OF SENIOR OFFICIALS . ........................................................ 2 BUDGET ASSUMPTIONS AND IMPACT TO REDUCTION TARGETS .. :.................................... 3

• PORTFOLIO STATUS ......... :......................................*................. .- ..................................................... 4 Overall Agency Building Portfolio ................................................................................................. 4 Status Relative to the Reduce the Footprint Baseline Requirement.. .........*................................ 5 REDUCTION TARGETS ......... ,........ :........................... -............................................. :.................. :.. 6 Reduction-Targets for Office and Warehouse Space .........................................................; ........ 6 Perfor"mance Benchmarks ........................*................................................................................... 6 Disposal Targets*for Owned Buildings ........................ ,.................................................................. 7 Space Design Standard for Future Reductions .............................................................*............ 10 GSA CONSOLIDATION PROGRAM ............................................................................................ 11 COMPLIANCE INTERNAL CONTROLS ......................................................................:................ 11 Control of Acquisition of New Owned and Leased Ass~ts at the Agency Level ......... .'............. 11.

Tracking of Office and Warehouse Increases and Offsets ........................-................................ 12 Ensuring Timely Disposition of "Excess" and "Surplus" Properties ................ :** ........................ 12 Ensuring That Consolidation and Co-location Opportunities Are Identified and Prioritized ...... 12 Management of the Reduce the Footprint Policy Agencywide .................. ~ ................................ 12 FEDERAL REAL PROPERTY PROFILE (FRPP) DATA QUALITY IMPROVEMENT .................. 14 CHALLENGES AND I_MPROVEMENT OPPORTUNITIES ............................................... ." .......... 14

NRC Real Property Efficiency Plan, FY 201~FY 2023.

INTRODUCTION The U.S. Nuclear Regulatory Commission (NRC) is an independent agency created oy Congress. Its mission is to license and regulate the Nation's civilian use of radioactive .

materials to protect public health and safety, promote the common defense and security, and protect the environment. Specifically, the NRC regulates commercial nuclear power plants; research, test, and training reactors; nuclear fuel cycle facilities; and the use of radioactive materials in medical, academic, and industrial settings. The agency also regulates the.transport, storage, and disposal of radioactive materials and waste and licenses the export and import _of radioactive materials ..

Successfully_ accomplishing ttie NRC's mission requires substantial ongoing collaboration among NRG staff and across NRC offices. This collaboration among multiple technical experts and others is critical to resolving regulatory issues and fully addressing nuclear safety and security concerns. The NRC relies on staff collaboration for applying lessons learned from prior nuclear incidents, understanding the breadth and nuances of a technical

. issue,* and transferring technical knowledge to junior NRC staff on how to apply information

. appropriately and how to problem solve within the NRC's regulatory framework. Collaboration and unified problem solving enhances the quality of the NRC's response and organizational effectiveness. Co-location of NRC headquarters staff is vital for purposes of achieving .

operational efficiency, regulatory effectiveness, and incident response capability. Providing

. consolidated agency facilities is key to supporting tlie NRC mission.

• A summary of the agency's real property portfolio as of the end of fiscal year (FY) 2017 is shown below. The NRC does not directly lease or own any space; its entire 1,079,543 usable square feet (USF) office and industrial portfolio is provided by occupancy agreements (OAs) with the U.S. General Services Administration (GSA).

• FY 2017 Portfolio Summary per Federal Real Property Portfolio (FRPP).Submittal (All office and warehouse property, including the ~

Reduce the Footprint (RTF) baseline properties)

Direct Lease s *ace Owned S ace OAS ace USF None None 1,079,543 The NRC's portfolio remained unchanged from the agency's FY 2015 Reduce the Footprint

. (RTF) baseline of 1,079,543 USF. The agency is targeting a reduction of the portfolio to

. approximately 938,543 USF (87 percent of the FY 2015 RTF baseline) by the end of the FY 2019-FY 2023 planning period. The square footage of the planned reductions is slightly.*

above the targeted re.ductions reported in previous Real Property Efficiency Plans due to the availability of more accurate measurements and refined estimates. NRC plans to reach this target by renovating, reconfiguring, and releasing a total of approximately 141,000 USF of office space at its Rockville, MD, headquarters and four regional office locatio_ns.

Implementing the reductions* at the regions will be challenging given the lengths and non-cancelable terms of the leases G~A has in place..

NRC Real Property Efficiency Plan, FY20~9-FY 2023 ROLES AND RESPONSiBILITIES OF SENIOR OFFICIALS The role of the Senior Real Property Officer (SRPO) for the agency has been delegated to the Director of the Office of Administration (ADM). As the SRPO, the Directbr of ADM

• serves as asset manager for the entire agency, with review and approval authority of all space disposal and acquisition projects. All requests for space are centrally reviewed at headquarters by the Senior Space Acquisition Manager (SSAM) in the Division of Facilities and Security (DFS) in ADM.

The Chief Financial Officer (CFO) is responsible for the NRC's planning and budgeting and performance management process and for all of the NRC's financial management activities.

The CFO provides an agency wide management control program to comply with the Federal Managers' Financial Integrity Act and is responsible for implementing the Chief Financial Officers Act. * *

• The Office of.the CFO (OCFO) leads the agency budget formulation process and provides oversight of the agency budget structure.

The Executive Director for Operations (EDO) determines the planning, workload, and resource requirements to be reflected in the budget. The Deputy Executive Director for Materials, Waste, Research, State, Tribal, Compliance, Administration, and Human .

Capital Programs and the Deputy Executive* Director for Reactor and Preparedness Programs provide offices with direction, as needed, including workload expectations, to

• ensure that the budget_ aligns with the Commission's direction.

ADM reviews the agency's real property portfolio, determines any new requirements for space modifications, acquisitions, and disposals, and, in coordination with OCFO, formulates the proposed agency budget for real property and its components (e.g., repair, maintenance, consolidation, disposal, new construction) for submission to OEDO. As part of the normal budget development process, the EDO and CFO meet to discuss the budget

• submission, which includes the annual real property budget. OCFO works witli ADM to adjust the budget request based on decisions made by the EDO and develops the budget proposal for submission to the Chairman. The Chairman then submits the budget proposal to the Commission. OCFO finalizes and submits the performance budget to the Office of Management and Budget (0MB) once approved by the Commission.

NRC Real Property Efficiency Plan, FY 2019-FY 2023 BUDGET ASSUMPTIONS AND IMPACT TO REDUCTION TARGETS The NRC formulates its annual budget 2 years in advance. The budget for the first fiscal year covered by this plan (FY 2019) will be informed by re-baselining, 2014 Project Aim recommendations, and the Agency Reform Plan, as described below.

lri June 2014, the EDO and CFO established the Project Aim team to develop a long-term workload forecast for the agency; along with the framework and recommendations to enhance the. NRC's ability to plan and execute its mission in a more effective, efficient, and agile manner. The team develqped a report and roadmap to improve the NRC's .;1gility, effectiveness, and efficiency, while also refining the basis for agency planning through 2020 .

and beyond.

• The Project Aim report includes a description* of what the NRC might look like in 2020 as the agency improves efficiency. This projection is based on understanding how the agency has grown and contracted throughout its history, adjusted to resolve national needs such as the response to the terrorist attacks in 2001, and the projected change within the nuclear industry.

The agency grew significantly following the terrorist attacks in 2001 to enhance security and incident response and to prepare for projected growth in the use. of nuclear energy (the nuclear renaissance) and developm(3nt of a high-level waste repository in the United States. However, the rorecasted growth for the industry reversed in response to changes in the energy sector, which has resulted in fewer requests for review and construction of new nuclear facilities, the early closure of a few operating plants, and reduced budgets. These adjustments, in turri; continue to prompt the NRC to adapt its structure, workforce, culture, and regulatory processes to achi~ve the agency's safety and security mission in an era of constrained resources. The NRC must reposition

• itself to function as an effective and efficient regulator in this new environment, while retaining .the capability to respond in an agile.manner to a range of possible futures.

The budget for the second and third fiscal year covered by this plan (FY 2020 and FY 2021) are informed by the Agency Reform Plan. As (firected by 0MB in memorandum, M-17-22, "Comprehensive Plan for Reforming the Federal Government and Reducing the Federal

• Civ.ilian Workfare~," the NRCs Agency Reform Plan identifies proposed areas for reform to improve agenqy efficiency, effectiveness, and accountability in four categories: eliminate activities, restructure and merge activities, improve organizational efficiency and effectiveness, and workforce management to improve performance, increase accountability, and reduce costs. The office and warehouse space reduction targets identified in this RTF plan are designed to be consistent with historic real property funding levels and the NRC FY 2020 proposed annual budget.

NRC Real Property Efficiency Plan, FY 2019-FY 2023 PORTFOLIO STATUS Overall Agency Building Portfolio The NRC does not directly lease or own any space; its entire portfolio is provided by OAs with GSA. Its building portfolio consists of a total of 1,033, 171 USF of office space, 46,372 USF of warehouse space, and 54,525 USF of other space at the technical training center.

FY 2017 Portfolio Summary per FRPP Submittal

{All prop_erty, including the RTF baseline properties)

Direct Lease Space Owned Space OA Space (USF)

Office None None 1,033,171 Warehouse None None 46,372 All Other None None 54,525 Total None None 1,134,068 The NRC's real property portfolio currently consists of space in nine buildings, located in six geographic areas around the country. The agency's FY 2012 Freeze the Footprint baseline total was 1,170,242 USF, with the release of space in the newly delivered 3WFN and interim locations, by July 2015 the portfolio was down to the FY 2015 RTF baseline of 1,079,543 USF and total GSA OA portfolio 1,134,068 USF. .

Accomplishment of the NRC's mission depends on collaboration among NRC technical experts and regulators and is critical to resolving regulatory issues and fully addressing nuclear safety and security concerns. The NRC staff relies on close collaboration for applying lessons learned from prior nuclear incidents, understanding the breadth and nuances of technical issues, and transferring technical knowledge within the NRC's regulatory framework to others. Collaboration and a multidisciplinary approach to problem

. solving enhance the quality of the NRC's organizational and operational effectiveness.

The agency has not confronted any major challenges in establishing the FY 2019-FY 2023 reduction targets however, it will confront several challenges in implementing the changes needed to achieve the FY 2019-FY 2023 reduction targets: 1) accurately forecasting housing requirements given uncertainty in the nuclear industry, 2)dependency on situations beyond the agency's control in terms of construction schedules and potential delays.

Status Relative to the Reduce the Footprint Baseline Requirement Throughout.FY 2017, NRC's total GSA OA portfolio of 1,134,068 USF, and FY 2015 RTF baseline of 1,079,543.USF remained unchangecl. In FY 2015, the agency relinquished over 155,000 USF of office and related space from two of its Rockville, Maryland locations as reported in the FY 2018 Real Property_Efficiency Plan. NRC plans to relinquish an approximately 141,000 USF of office space at its-Rockville, MD, headquarters and four regional office locations from FY 2019 through FY 2023.

NRC Real Property Efficiency Plan, FY 201~FY 2023 The agency expects to achieve further reductions of space by developing an effective program to release office .space and consolidating staff at headquarters. This effort requires

. extensive planning and coordination to minimize disruption, minimize the number of staff moves, and maintain mission effectiveness during consolidation. The agency will respond to challenges and opportunities presented with effective planning and project execution,

-widespread use of standardized workstation sizes.

_)

Maintenance of the Reduce the Footprint Baseline In accordance with the RTF guidance, the NRC identified excess office space within the portfol,io, and it "right-sized" the portfolio consistent with the number of onsite personnel to be housed. The NRC's revised Real Property Savings Plan called for consolidating operations at its headquarters at the White Flint Campus (WFC) in Rockville, MD. During FY. 2013 through FY 2015, the NRC reconfigured head.quarte~s space, and consolidated . operations to implement the plan. By the end of FY 2015, the NRC relinquished a net total of 364,997 USF, reducing its real property footprint to the current RTF baseline of 1,079,534 USF. The Long Term *Housing Strategy (LTHS) completed in FY 2015 and updated annually identified the opportunity to relinquish additional space.at the WFC. As a result, the agency is targeting a reduction of the office and warehouse portfolio to approximately 938,543 USF (87 percent of the FY 2015 RTF baseline) by the end of the FY 2019-FY 2023 planning period. The NRC plans to reach this target by renovating,* reconfiguring, and releasing approximately 141,000 USF of office space.at its 'Rockville, MD, headquarters and four regional office locations ..

The NRC will make corresponding space reductions, as *necessary, to address decreases in staffing. The agency plans to work with GSA to renovate, reconfigure, and release additional space for backfill by other Federal agencies at its headquarters and regional office locations.

Implementing these reductions regional locations may be challenging given the terms and lengths of the leases GSA has in place. *

. The NRC will continue to reduce the spac~ portfolio without reducing operational effectiveness and workforce productivity by focusing on more efficient workstations and support space configurations, collaborative work area adjacencies, and the enhancement of information technology applications if necessary to evaluate the feasibility and practical application of alternative solutions such as telework arid desk sharing.

REDUCTION TARGETS Reduction Targets for Office and Warehouse Space The NRC is headquartered in Rockville, MD, and has four regional offices and.a technical training center, which are located in King of Prussia, PA; Atlanta, GA; Lisle, IL; Arlington, TX; and Chattanooga, TN, respectively. The agency's entire space portfolio is provided through OAs with GSA, consisting of approximately 76 percent leased space and 24 percent*

federally owned space. The agency currently resides in nine buildings in six locations-three office buildings and a warehouse at headquarters, four regional office building locations, and a technical training center. The relatively small size of the agency's portfolio gives staff the ability to centralize the management of space facilitating the ability to identify opportunities to use the space more quickly and efficiently.

• NRC Real Property Efficiency Plan, FY 201~FY 2023 The NRC and the GSA developed a LTHS for the agency in FY 2015, in conjunction with the acquisition of a replacement lease for the Two White Flint North (TWFN) building that is part of the agency's Rockville, MD, headquarters campus. This effort provided the means and opportunity to evaluate existing NRC space in all three headquarters office buildings and create synergy in how space could be used effectively; how mobility, technology, and .

phased restacking and reconfiguration options could be implemented; and how the. NRC might better consolidate and co-locate organizations. Regional office space and technology requirements are included in the strategy and plan. The NRC will work with GSA to identify space disposal and backfill opportunities while addressing limitations of I.ease terms and cancelability.

• The NRC does *not own or directly lease office or warehouse space and, therefore, has no disposal projects. Given the relatively small size of the agency's office portfolio, consolidations will be limited to portions of the three buildings located at the WFC and'within individual assets in the regions by reconfiguring space and relinquishing portions of individual buildings. When evaluating opportunities to reduce space, the NRC's first priority and consideration is to assess and weigh the agency's continued ability to perform mission-essential functions, without interruption, within the space allotted. After as~urance that the agency will be able to continue .to perform its primary'mission, factors used to evaluate consolidation targets are the utilization ratio of office space to persofmel, lease expirations, lease rates, and ,the results of cost-benefit analyses.

• Proposed agency-Wide total space reduction targets are shown in the table below. The NRC only has on~ warehouse; it is not required to submit w~rehouse space reduction targets under the RTF policy. * *

• Domesf1c Off,cean dWare house s;c uare Foot Rd e uct,on Tar~ ets FY 2019-FY 2023 FY 2019

• FY 2020 FY 2021 FY2022 FY2023 Office Target* 54, 190** 60,810**

• 11,000** 15,000** 0 (Net SF Reduction)

Warehouse Targets N/A N/A N/A N/A N/A (Net SF Reduction)

• Reductions are reported as a positive value.

• • The NRG will require support from GSA to backfill space identified in the regional office locations as targets for future space reductions. Several of these locations curreriUy have non-cancelable OAs and lease agreements.

• NRC Real Property Efficiency Plan, FY 20~~FY 2023 Disposal Targets Owned Buildings The NRC has no disposal targets for owned buildings. The agency does not own any real property; its entire real property* portfolio is provided through OAs with GSA.

Disposal Targets for Owned Buildings FY 2019-FY 2023 FY 2019 FY2020 FY 2021 FY2022 FY2023 Disposal Target NIA N/A N/A N/A N/A (Net Square USF Reduction)

Disposal Target N/A N/A N/A N/A N/A (Number of buildings)

Performance Benchmarks Using the Federal Real Property Profile (FRPP) Real Property Management Tool (RPMT) the NRC uses real estate metrics such as portfolio size as*a percentage of the FY 2015 RTF baseline, proposed reductions for the RTF objectives, QA rent per square foot, and square feet per person to identify and prioritize consolidation projects.

The RPMT dashboards and spreadsheets provide the NRC the ability to view the portfolio data in the context of the RTF real property savings plan and overall space reduction strategy. Using the rent per square foot metric, the agency targeted the .

release of space in the highest cost-per-square-foot properties in the portfolio as .

identified by the RPMT. This led to the determination that approximately 94,000 USF

. (67 percent) of the NRC space in the highest rent-per-square-foot property in the portfolio (3WFN) could be released in the near future. Using the portfolio size as a percentage of the RTF baseline and the square-feet-per-person metrics, the agency identifiec::l reductions that will significantly reduce the portfolio-as a percentage of the RTF baseline.

The NRC's consolidation plans are known to. GSA, and the NRC has worked closely with GSA to find backfill opportunities for leases and OAs. The pursuit of backfill

• tenants resulted in FDA signing an occupancy agreement to backfill one additional floor in 3WFN in early FY 2019, and the National Institute of Health (NIH) signed an occupancy agreem~nt to backfill the remaining three floor~ as they become available in the FY 2019 through FY 2020 timeframe. Therefore, NRC anticipates rent

• savings to comme.nce in FY 2019 when FDA has agreed to backfill the 2nd floor of 3WFN, with similar savings to be realized in .mid FY 2019 and again by early FY

• 2020 as NIH begins to backfill the remaining three floors. To support this reduction, the NRC will need sufficient and appropriately configured space in the WFC to house the ~taff to be relocated from 3WFN. Efforts to renovate or reconfigure the space are currently underway. The remaining facilities in 3WFN would include the* NRC data center, conferen*ce center and NRC's Headquarters Operations Center, which serves as the focal point for the agency Primary Mission Essential Function of event

• response for incidents involving a commercial nuclear power plarit, research or test reactor, fuel cycle facility, or nuclear materials licensee.

NRC Real Property Efficiency Plan, FY 2019-FY 2023 As part of the LTHS and given the recent reductions in staff, the NRC is also exploring opportunities to accelerate the timing and amount pf space to be relinquished in its regional offices. These reductions can be achieved by re-stacking

. the existing space, thereby allowing for demisable blocks of space to be released.

Realizing cost savings by releasing the space will be a challenge due to the non-cancelable terms of the leases therefore the possibility exists that certain regions may not release space until termination rights become actionable. Lease expirations

• and. terms for the regional offices and square footage of the reductions are as follows:

Reported Occupancy Useable Fiscal Occupancy Reductions Per Agreement and Square Year of Agreement 2019 Real Lease Footage to the Space Cancelability

• Property Tetminatiori be Released Release Date Efficiency Plan Date Reoion Ill . 7,000 FY 2019 Cancelable Now June-23 Region II 15,688 FY 2020 November-22 November-24 Region IV 11,000 FY 2021 April-21 April-26 Reaion I 15,000 FY 2022 April-22 . April-27 The agency has recenjly made significant investments in tenant build-out costs for office space and an Incident Response Center in each regional office; therefore, releasing a portion of existing *space for backfill by another Federal agency as opposed to relocating to another location would be the most economical. strategy to .

reduce space. *

• NOTE: The NRC will require continued support from GSA to backfill space identified in the regional office locations as targets for future space reductions. Several of these location$ currently have non-cancelable OAs and lease agreements. It is the NRC's expectation that early involvement with GSA's leasing and disposal divisions will yield opportunities to.find suitable backfill or sublease tenants when needed. Well in advance of lease expirations, the agency will work with GSA to review and validate space requirements, identify opportunities for space reductions based on requirements

. and staffing changes, and work closely with GSA to ensure timely backfill of any released space. Given the agency's mission requirements, the NRC does not foresee any opportunities to redu.ce the number of locations in the near term: In support of NRC's mission, GSA has recently signed succeeding leases on NRC's behalf for TWFN (15 year lease commencing in December 2018 consisting of 295,734 USF) and NRC's Technical Training Center (20'year lease commencing in December 2016 consisting of 54,525 USF) and a renewed OA for OWFN (consisting of 275,369 USF) for 1O years commencing in March 2018. Therefore, the strategy to reduce space will

.consist of reduci11g the footprint in existing locations and buildings.

Benchmark Metric Summary for the Nuclear Regulatory Commission (includes Headquarters and Regions) using USF and Personnel Counts from September 30, 2017

• NRC Real Property Efficiency Plan, FY 201.9-FY 2023

• Rent and O&M Benchmark Metrics*

. Change (FY2017 Government-Agency Metric Units FY2013 FY2017 *less FY2013) wide Average NRC Rent per SF GSA OA Office $/SqFt $31.75 $27.17 -$4.59 $27.51 NRC Rent per SF GSA OA Warehom $/SqFt $16.03 $10.60 Personnel Benchmark Metrics Change (FY2017 Government-Agency Metric Units FY2015 FY2017 less FY2015) wide. Average NRC SF per person GSA OA Office Sq Ft/Person 249.56 293.33 43,78 272.3 In FY 2020 after the near term release of space in 3WFN and the regional locations NRC anticipates its "all-in" utilization rate for the WFC to be approximately 220 USF -and a total "

all-in" agency utilization rate of approximately 260 USF.

• Space Design Standard for Future Reductions In 2010, the NRG-developed and issued a policy that specifies the design standard for maximum usable square feet perworkstation (shown below) foruse in the design of owned and leas.ed domestic office space; including GSA-assigned space.* This standard was developed as part of the Program of Requirements for 3WFN. In 2016, during the design phase for the renovation of TWFN, the agency revised the standard by reducing the size of enclosed offices for office directors, division directors, deputy division directors and branch chiefs. The agency is working toward applying this standard to all future space renovations*

and new acquisitions for space in NRC regional offices while taking into account core mission performance, job functions performed in the space, and equipment necessary to perform the job. .

Maxin:ium Square Feet per V\forkstation Squ;Jre

• Enclosed Feet Office Director 240 Deputy Office Director 240 Associate Director 150 Division Director 150 Deputy Division Director 150 Deputy Associate Director 150 Branch Chief 120 Administrative Law Judge 120 SLS (interior) & Team Lead

• 100 Open Senior Staff (GG 15).

80 Professional Staff (GG 13 -* 15) 80 Professional Staff (GG 12 and below) 80

• Secretarial 80 Contractor 40 NRC Real Property Efficiency Plan, FY 2019-FY 2023 Per the RTF guidelines, and the agency LTHS, NRC incorporates a goal of a 200 USF per*

person "all-in" office utilization rate for tl'le NRC staff and contractors housed at the WFC calculated by dividing the total USF, without dispensation for special use space, by the number of office based personnel assigned to each location. The utilization rates for NRC's four regional locations is higher than that of the WFC due to the fact that the tenant build out in the regions incorporates a space plan design consisting primarily of enclosed offices. To mitigate this in the near term the agency intends to reduce space by consolidating in place in each region and will explore the feasibility and cost benefits analysis of changing to a

• more open space plan for its regional locations as the current leases expire in the FY 2023- FY 2027 timeframe. The NRC expects a decrease in personnel for the. FY 2018 Federal Real Property Council data reporting period which will have a corresponding effect on the agency's utilizatioQ rate until additional space is relinquished. The "all-in" utilization rates are monitored weekly and reported monthly in the agency's computer-based space planning and management system.

Another way to benchmark space utilization is a calculation referred to as the "administrative" ..

utilization rate, w.hich removes special use space from the equation. The administrative utilization rate is calculated by subtracting the amount of special use space (i.e. auditoriums, cafeterias, incident response centers, data centers) from the USF before dividing by the number of personnel. GSA has requested each agency to calculate and report on administrative utilization rates for headquarters and field .office locations.

The "administrative" utilization are illustrated in the chart below using the personnel counts as reported in the September 2017 Federal Real Property Profile (FRPP) data call.

• Nuclear Regulatory Commission Administrative Office Utilization Rates Administrative Headquarters/Regions Office UR Headquarters/WFC 199.6 USF NRC Regions (Combined) 375.7 USF NRC Total Portfolio (WFC and Regions Combined) 237 US.F After the relinquishment of space in 3WFN, the agency estimates the administrative utilization rate for the WFC to be approximately 175 USF.

GSA CONSOLIDATION PROGRAM NRC's largest planned space reduction is to release four additional floors in 3WFN (a total reduction of approximately 94;000 USF) in the FY 2019-FY 2020 timeframe by consolidating staff in the remainder of the WFC. The agency did not request GSA consolidation funds for this project. NRC and GSA aggressively pursued backfill tenants for the space resulting in FDA sigriing an OA to occupy one of the four floors and NIH signing an occupancy agreement for the _three remaining floors.

NRC Real Property Efficiency Plan, FY 2019-FY 2023 COLLOCATION OPPORTUNITIES Given NRC's mission requirements, the nature and length of the terms for each lease in the field office/regional locations, and the substantial recent investments the agency has made on space build out and their respective incident response centers, NRC does not have candidates for collocation opportunities in the foreseeable future, however the agency is in the early stages of evaluating whether or not the opportunity exists to share the data center in the 3WFN building.

To improve utilization rates, the agency is in the process of relinquishing space in the regional offices by consolidating in place and will evaluate collocation opportunities as the leases expire in the F.Y 2023 - FY2027 timeframe.

OPERATIONAL EFFICIENCIES Per the terms and funding available in the succeeding lease for TWFN, NRC is in the process of completing the renovation of space within the building. The renovations will have the effect of increasing the density on each floor as well as an increased potential to utilize mobile workspace concepts in the future. The TWFN renovations will enable the NRC to release approximately 94,000 USF in 3WFN as renovated space in TWFN becomes available to. relocate the current occupants on the effected floors in 3WFN. Per the current schedule, the project will be complete by FY 2020. Once complete, NRC estimates that the "administrative" utilization rate for the WFC will improve to 175 USF per occupant under the current rate of 199.6 USF per occupant.

COMPLIANCE INTERNAL CONTROLS Control of Acquisition of New Owned and Leased Assets at the Agency Level The role of the SRPO for the agency has been delegated to the Director of ADM. All requests for space are centrally reviewed at headquarters by the SSAM in ADM/DFS. The SRPO reviews and approves all acquisitions and disposals of office and warehouse space.

The SSAM maintains a detailed inventory of space in a summary that is updated monthly and covers all NRC real property occupancies. The space summary displays square footage assignments, rent and related costs, locations, lease start and end dates, and notations on increases and decreases by building.

Under NRC MD 13.2, "Facility Management," approved September 25, 2012, the ADM Director is the designated representative for the authorities delegated from GSA to the NRC and other activities relate_d to facilities management, including the approval of assignment of all space for headquarters, the regional offices, and the technical training center (TTC) in Chattanooga, TN. The SRPO also establishes office space standards that are used to determine space allocation for headquarters, regional offices, TTC, and contractors.

Documentation of real property occupancies are contained in OAs with GSA.

All requests involving new leases, dispositions, acquisitions, expansions, or other changes in the agency's office and warehouse space portfolio are reviewed initially by the SSAM to ensure compliance with RTF principles and guidance before recommending approval or disapproval to the SRPO. These reviews are reinforced by the NRC's reliance on GSA-issued NRC OAs, the NRC's monthly review of GSA rent bills, and SSAM review of the NRC's weekly updates of office space occupancy rates.

NRC Real Property Efficiency Plan, FY 2019-FY 2023 Tracking of Office and Warehouse Increases and Offsets Tracking of .increases and offsets is accomplished by the SSAM through documented changes in OAs approved by the SRPO, cross-checked against monthly GSA rent bills, and agency space planning and management system reports that are updated weekly.

Ensuring Timely Disposition of "Excess" and "Surplus" Properties The SSAM reviews the status of all real property issues on a periodic basis and projects including any proposed acquisitions or dispositions of excess or surplus properties. These

• periodic reviews, supported by data from the agency space pfanning and management

. system, ensure continuous monitoring of space utilization and early identification of issues affecting the timely disposition of "excess" and "surplus" space. The NRC continues to work with its GSA regional contacts and the National Capital Region lease contracting officer and

. team to identify its space disposal and backfill opportunities. The agenqy will ensure these interactions continue with GSA to coordinate all space/disposa!/backfill activities.

Ensuring That Consolidation and Collocation Opportunities Are Identified and Prioritized The NRC's real property portfolio is tracked through a space summary maintained by the SSAM. The SSAM maintains a spreadsheet with descriptions of policies, strategies, and priorities; planned consolidations; co-locations; disposals; and new construction projects and leases. Consolidation and collocation opportunities are identified internally and by external authorities (e.g., GSA) and reported in periodic meetings with the SRPO ..

GSA and the NRC are currently reviewing opportunities for co-location in. the regional office locations. In addition, the NRC and GSA also are reviewing opportunities for increasing efficient space use such as telework and desk sharing in the agency's LTHS.

Management of the Reduce the Footprint Policy Agencywide All requests for space acquisitions an<:! dispositions for the agency are channeled through the SSAM who reviews and consults with the SRPO to determine the merit of each request and ensure that each request meets agency and Government-wide policies, guidance, and mandates. The SRPO reviews and approves all space acquisitions to ensure compliance with the RTF policy and guidance.

The NRC's LTHS provides a blueprint for the agency's real property needs, including regional space, by identifying efficiencies to achieve the optimal use of the agency's real property portfolio. The study addresses such items ~s space utilization, workstation standards, workstation configurations, adjacencies, alternative workspace solutions such as telework and desk sharing, the standardization of furniture, the enhanced use of technology, and additional energy saving technologies.

• NRC Real Property Efficiency Plan, FY 201!rFY 2023 The development of the strategy and plan is well underway, it provides a strategy and plan*to

• target a 200 USF per person "all-in" utilization rate for the NRG staff and contractors housed at the WFC, supports the acquisition of the TWFN replacement lease renovations, implements Government-wide space standards, (such as Freeze/Reduce the Footprint),

• refurbishes and renovates headquarters workspace, provides equitable workspace for staff across the WFC, and allows a review of regional office space for the future.

The NRG will use the recommendations and findings of the housing study to guide and manage the implementation of the RTF and FRPMA policy. * * '

FEDERAL REAL PRO~ERTY PROFILE (FRPP) DATA QUALITY IMPROVEMENT The NRG will *use the FRPP's RPMT and established data validation tools to fully implement GSA's FRPP data validation and verification guidance regarding the identification and

• reconciliation of data anomalies in the agency's annual FRPP data submission for the FY 2018 reporting cycle. Data anomalies will be reconciled using the NRC's data verification procedures to check accuracy and reliability of data before reporting the FY 2018 FRPP data. The NRC's space portfolio is relatively small compared to other executive agencies in terms of number of assets and total square footage. The NRC's real property.portfolio currently consists of space in nine buildings, located in six geographic areas around the country, allowing intimateJamiliarity with the data in a user-friendly asset management system, which corresponds to a high level of confidence in the data's accuracy and reliability.

To verify and validate the reliability, accuracy, and completeness of space portfolio data, the SSAM and space management team cross-references data sets such as the annual FRPP data, the NRC's automated space planning and management system data, and individual OAs issued by GSA. Periodic reviews* and exception processing will be conducted by the SSAM and support contractors while updating utilization metrics and reviewing and a

approving the rent bili on monthly basis. Underlying anomalies will be identified quickly and addressed. In addition, the SSAM and the space management team will coordinate semi-annually and as needed throughout the year with the following:

• The Office of Chief Human Capital Officer and the Office of Chief Information Officer staff to review employee data and reconcile discrepancies between on-board, vacant,'

and aut~orized positions, active network accounts, arid weekly staffing count and workstation occupancy data; and, *

• The Acquisition Management Division to review onsite contractor staffing data' and reconcile discrepancies between authorized positions, active network accounts, and weekly staffing count and workstation occupancy data.

CHALLENGES AND IMPROVEMENT OPPORTUNITIES The implementation of the NRC's LTHS and corresponding space reductions will present a series of challenges to the agency, both tangible and intangible. When evaluating opportunities to reduce space, the first priority and consideration is to assess and weigh the NRC's continued ability to perform mission-essential functions, without interruption, within the space allotted.

• Each space reduction project will require an initial investment to reconfigure and furnish space before any consolidation or disposal. NRG must complete a cost-benefit analysis to NRC Real Property Efficiency Plan, FY 2019-FY 2023 determine the financial feasibility of each project before its initiation. Each analysis' will weigh the initial investment against the projected timing and amount of savings to determine if the project is beneficial to the agency. Other factors to be taken into consideration are the lease.

terms and severability of individual leases and OAs. If the amount of time required to realize a cost savings is longer than the remaining term on the location's lease, the project may not be feasible.

The majority of the NRC's OAs are "hon-cancelable," meaning the agency will still be responsible for the lease costs of any space relinquished until such time as the lease expires or GSA is able to find a bac_kfill tenant. The marketability and demand for space at each location must be taken into consideration when estimating the cost savings. The demand

• for space in each of the NRC's locations will be a determining factor in GSA's ability to backfill relinquished space in sufficient time to realize cost savings relative to each lease's expiration. In the regional'office locations, given the anticipated continuing need at each location, the availability and projected costs of alternate space versus the reconfiguration of existing space will need to be analyzed, as individual leases expire.

Another consideration in the regions is the agency's continuity of operations plans (COOP) and relocation sites, The NRC's space -reduction plans rieed to consider the agency's requirement for a sufficient presence in the regions to accommodate a COOP scenario.

Another challenge is the use and cost of technology and the changing work environment.

One of the drivers for a smaller space footprint is the anticipation that the NRC's work -*

environment will evolve as technology evolves, allowing for a more mobile workforce. The agency will need to budget for and fund the new technoiogy necessary to support these new work modes. To be successful, the agency.must also create acceptance of this evolution, which will depend heavily upon a successful change management initiative. Finally, a successful space plan will depend upon the agency's ability to accurately forecast the future workload and staffing requirements given the uncertainty regarding the current state of the nuclear industry.

• The primary program improvement opportunities are related to the agency's commitment to improve the_utilization rates for both the headquarters and regional office locations by

• releasing additional USF by consolidating in place.

Respectfully submitted, 9/21/2018

.X Mary C. Muessle Mary C. Muessle, Director Office of Administration Signed by: Mary C. Muessle

_r Standard GSA-Provided Spreadsheet - NRC Office and Warehouse *

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Standard GSA-Provided Spreadsheet- NRC 3 Projects Relinquish 1 floor of 3WFN with NRG Headquarters Reconfiguration of corresponding staff consolidation into consolidation Existing Space other WFG buildings Rockville, MD 10/01/2017 09/30/2018 22,561 Relinquish 1 floor of 3WFN with NRG Headquarters Reconfiguration of corresponding staff consolidation into consolidation Existing Space other WFG buildings Rockville, MD 10/01/2018 09/30/2019 22,561 Reconfiguration of Existing Space Relinquish NRG 3WFN cafeteria space Rockville, MD 10/01/2016 03/31/2019 3,000