ML19256A756

Comments on GSA Proposal to Relocate Region 5 Ofc from Walnut Creek,Ca to Downtown San Francisco.Identifies Detrimental Impact of Move.W/Encl Draft Forwarding Ltr to Congressman Miller

ML19256A756
Person / Time
Issue date:	11/29/1978
From:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Barton A GENERAL SERVICES ADMINISTRATION
Shared Package
ML19256A754	List: ML19256A753 ML19256A756 ML19256A757
References
NUDOCS 7901160085
Download: ML19256A756 (12)

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'"N UNITED STI.T F S

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.'5 NUCLEAR R EGui.ATOR Y COT ir.*;sSION T...i l.

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94596 HOV 2 9 1978

~ Arthur.0. Barton U

Regional Commissioner, Public Buildings Service ~

General Services Administration, Region 9 e

52514arket Street

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Dea'r Mr. Barton:

As reque~sted in your letter of October 20, 1978, enclosed are our corments concerning the GSA proposal to relocate the Region V office,

!;RC, to the central business district of. San Francisco.

The enclosed coments will assist GSA in its preparation of a comprehensive analysis of the impact of the proposed move, including the effect it would have on !!RC, the Region V office and its employees.

The NRC suppo:ts the goal of using Federal s' pace to strengthen cities; however, the meeting of Federal space needs must follo.e the process stated in Executive Order 12072.

The Executive Order, augmented by Office of Management and Budget Circulars A-95 and A-ii6, requires that serious consideration be given to'the inpact a pror:rai wilI hare on the--

social, economic, environmental and cultural conditions of urban ccm-muni ties. Therefore, before a decision is reached on the proposed relocation of the Region V office, we agree that the varicus impacts must be deliberated in an orderly, thoughtful manner.

The impact analyses cra., w a G es> thrcTiew applying-t:r both the~1criTrg and gairring cities.

After caref.ul review of the pertinent dccuments, and in consideration of significant progra=atic and organizational actions new underway by i;RC, we believe that 1981 is the earliest date by whicn a final decisica can be made in accordance with Executive Order 12072. Ine Chairman, !!RC, has made known these views to Mr. Solomon, Administrator, 3SA.

0ur coments point out many of the factors and f;RC studies which must be considered in the development oi an envn onmental impact analysis.

As noted in the enclosure, Items IV.l.c and Y.i. we are requesting a ecpy of the report of the results of any GSA consultations with governmental trd cor.1 unity groups conducted in performing this analysis.

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Tne i;P.C will cooperate fully with GSA aiming toward a decision in 1931. ~ '~.

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In the ceantice, we recuest that your office s;gedite the negotiation of

. 1 required additional space for prompt occupancy in 'r.'alnut Creek and extend the lease through 1981.

By separate correspondence, we have responded to Mr. Yiakis' request of :;ovefoer 6,1978 for details en.the.._...,

additional space needed -at our present. location..

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Enclosure:

As Stated cc w/ enclosures:

E. L. Kirby, P.egional Facilities Planner, GSA J. P. Yiakis, Director, Space Management Div., PES, GSA, P,egion 9 J. G. Davis, Acting Director, IE, HRC J. M. Hendrie, Chaircar NRC O

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' NUCLEAR REGULATO?.Y C0:*.:'.ISSIO:'

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,,_. [.HRC COMi~ENTS ON~THE.GSA~ PROPOSAL TO RELOCATE THE REGI0ft V 0FFICE FROM -....--

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-THE CITY OF MALNUT CP.EEK, CALIFORt!IA TO D0'.#1TO'.5 SAit FRA!iCISCO

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This statement has been prepared in response to the October '20, 1978 request from A. O. Barton, Regional Commissioner, Public Buildings Service, Region 9, GSA, in conformance with Section 1-202 of Executive Order 12972, August 16, 1978.

The information pro-vided in this statecon will assist GSA in its preparation of a comprehensive Environmental Impact Statement pertaining to the proposed relocation of !!RC Region V as part of GSA's program of relocating Federal agencies to the central business district of major cities.

II.

Backcround-Discussed herein are the numerous effects the propostJ relocation would have on the !!RC and the Region V office and its employees.

Analyses of the costs and benefits of prograr_?.atic, personna.1 and environmentaT impacts are ircT::ded.

III. Iccact on the Acency 1.

Convenience and Cost of Location (a) Accessibility to Office There might be a slight improvement in accessibility to the office by certain licensees and some members of the public. A location in San Francisco would be closer to the San Francisco airport and to major hotels.

However, any improvement in accessibility would 'oe offset by increased operating costs incurred by visitors, the IRC and licensee organizations.

The cost of icdging and meals is significantly higher in San francisco than in the Walnut Creek area.

The ISO Federai per diec rates fcr San Francisc: are o.er C:'

higher than allor:a'.e ratis for usinut creek.

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the cost of trant:crte ' " f?ca the St.n -ran:isc: ai r;.:. t

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-to Walnut Creek is greatar than that to ccwnte.:n San Francisc$,

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for stays longer than :we ccys, i:ainu-Creek has the compatitive edce.

Tharefore the cost of supporting official business trips cc an ::RC cffice in San Francisco versus the office in ',alnut Creek will in many instances be greater for both private companies and federal agencies.'

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. ;..-The frequency of' visitors and local caetings has been,

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-increasing and will continue to do so in the future..

m-Changes.in operational-techniques and practices has

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resulted in greater i.nvolvement of Region V employees in '

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ilRC:HQs projects.

1'. ore NRC emp.loye'es are traveling to Region V with greater frequency for meetings, planning sessions and the conduct of' joint i:RC-licensee seminars.

Often meetings and seminars are arranged on relatively

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short notice and require the leasing of conference rooms at motels.

Our experience in arranging for lodging and meting roces is that space frequently is not availabh in San Francisco.

On the other hand, motels in the ulnut Creek-Concord area have been able to provide such accommodations and at

. a cost substantially less than prevailing rates in San Francisco.

If we had been located in San Francisco, travel would have been required outside the city to hold meetings and seminars, resulting in lost time and in-convenience to attendees.

Retention of the office in Walmtr Cree'c of fersmorm beneihits.for-a'cco: oda.tions.. than_. -

a city such as San Francisco.

(c)

Communications With Other Federal Agencies Essentiany-an oil our infrequent.cif.icial centacts and dealings with other feceral agencies is by telephone or mail.

This holds true for those agencies located in San Francisco.

Also, it is i;=aterial where our office is physically loca ed since the method of contact would remain the same.

A San Francisco location would offer no

. improvement in.commun'ications with other federal agencies.

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'(d). Summary - Convenience and Cost of Location No benefits will accrue to the NRC, the public, !!RC -

licensees or other federci agencies by tne F.egion V office being relocated to San Francisco.

On the contrary, probie:s would be crea ed and Edditi:nal cos.s wcJ d '.e e

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incurred by all parties.

Sections 1-10 Q ) and 1-1C5 cf Executive Order 12072 ha.te been considered and determir.ed to have no. applicability to Ine. neec for relocation.

The convenience of the public served, as mer.tiened in Section 1-203(a), may be adversely affected by a. move to San Francisco.

2.

Mission performance

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" (a) New Programs.Q.;-}

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Major modifications to ARC progra.s are currently under consideration or in progress.

They are scheduled for

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completion or for final decision in 1980-. A relocation -

. of the Region V office from Walnut -Creek prior to com-pleting the evaluation of these" programs would have a disruptive effect on. schedules and plans and might well be inconsistent with the final decisions that result from the studies.

Among the new programs are decentralization of HQs functions involving nuclear reactor licensing, liaison with State agencies and byproduct material licensing which would require moving HQs personnel to the regions; a three-phased major r.cdification of inspecti n prcgrams conducted by regional inspectors which would revise inspection procedures and methods and possibly cove more inspectors to reactor sites; and, a restructuring of regional boundaries and offices which would consider consolidation of some offices and establishment of new offices to meet shifting work load patterns.

The dis-traction of a major relocation would impede implementation and possibly severely impact the ex:ected beneficial.

results of= these programs.

(b)

Employee Morale The majority of the Region V employees live within a short commuting distance of the h'ainut C~ reek office.

Most of the employees purpcsely selected residences with the objective of minimizing ccmmuting time and costs, conserving energy, and at the same time achieving desired community living.

The preposed relocation to San Francisco is completely contrary to their expectations for.a con-tinued suitable work environment.

Employees will suffer significant hardships in terms of a real dollar loss in take-home pay due to increased commute costs.

The in-creased cost is inflationary in that no benefit resul a from the additional expense.

Also, the employees and their families will. suffer the loss cf time at come due to irrcreased cecmuting time.

The resultir.; negative o

impact on employees will have an advarse effect on mcrale wi-h possible negative effects on high standarcs of pErf ormar.ce.

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Recruiting We cannot stress enough the influence a good le ation, b

such as.that offered by the Cit, cf..sint. Creek, has en our ability to recruit and retain experien:ed profes-pr=

sionals in the fields of nuclear engineering, radiation protect. ion and nuclear material safeguarcs.

This is a

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. major issue.??The l'RC has'. faced this problem before and -.

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has been forced to relocati regional offices in order to

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attract and reta'.n 'the high cali~cer professionals we

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require in our inspection programs. The relocation away

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from an attractivi work and nearby residential environment G-to the central business district of a high-cost city with

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its attendant lack of parking, inadequate transportation

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system and time c'onsuming commutes will adversely affect our recruiting program.

The relocation might well impair HRC's ability to retain the present regional office 1

staff.

Our ability to maintain high performance standards might well be adversely affected.

The recruiting issue must' consider possible added costs to the agency and the taxpayer.

Each of our new in.

spectors undergoes two years of intensive training before being qualified to conduct inspections.

Both on-the-job and formal classroom training is provided at a cost of about $100,000 per-employee.

Each loss of an experienced e

inspecton. because_ot-a rele:stien will require an outlay of 5100,000 to train a replacement.

This type of outiay benefits no one. There is a high probability of losing c Teasr three empToyees ictediately. upcn relocation to San Francisco.

The HRC recruiting experience over the years ';as shown p

that the staff is not' recruited from large city popu-latiens The-ind:stries free which m:st cf our employeas -

come are not suited to urban locations.

We do not draw employees from one lccale, consequently our regional office would have little impact on ic:al employment.

In fact, location of our office in San Francisco could displace an empicyer.who might utilize the indigenous populatio.n.

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(d')' Emergency Response A relocation of the Region V office to San Francis:c would disrupt the a:ility cf the GRC to carry out emer-gency response resper.sibilities.

As a rescit of public and congressicnai : r.:crn, the ::RC h s biccme increi-ic;1y sensitiV2 *O the ma!:tr cf respOns& tc C;iefsenCf sitoitiCnS S

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involving radiation in:idents, nu$ lear power plar.:

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accidents, and threats to ?.e securi:y of r.uclear caterials or facilities usir.; s;;.T. ::erials.

Pecapt dis;.atch cf properly equipped ar.d fully inf:r: ed investi5ative23 5 is a necessity.

The response process requires quick access to the regional effice to establish and ran a response center, provide staff members with the necessary material, and to make trani arrangements.

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senior' professional -and adcif nistrative staff is currently - ";'

n located within 30 ninutes of the Walnut Creek office, wa -

can be ready'to cope with emergencies in a short time.

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On the other hand, a cove to San Francisco would un-questionably delay the. process and depending on the time i

of day, could add several hours to tur response time.-

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There.artr-/mrna'tives to consider in responding to emergencies.

Increased response time,.however, would not be considered an acceptable option. We could maintain duplicate equipment and files at employee residences, or even provide around-the-clock coverage in the regional office.

These alternatives would be costly and not totally effective.

Additional files and equipment would have to be set up and additional staff might be required.

These actions would be contrary to Presidential and agency efforts to reduce federal spending and federal empioyment.

(e) Overtime Activities A-reaccatiotr to Sart Francisco will increase' ceployee- -~

working days by two to three hours. 'The increase will result from added to-.uting time.

T.% iengthened v;orking day will reduce voluntary overtice work and adversely impact paid overtime.

The timely completion of priority ass.igomants.cculd. b.a affected. by the_ i. ors of ave.rtica.

options.

Alternative considerations such as required overtime will not _* - -. sie to staff member.

F. iring additional staff to compensate for los overtime is costly and counter to efforts to reduce federal spending.

Con-tractir' v;ork is not presently allowad.

(f)' Oper ing Costs Op:.2ti..: ws:s in Sar Francisco will be higher than P.at ex,narien:ed in Walnut Creek.

.The adced costs will not beratit either the :: ~ cr the v_xpays.

As one exa-- -ic of higher operating c:'.ti, the c.n.nly sg ire f o::t rev.:.i costs in Wir.ut Creek rar.,'e fre-30 cen s to 51.15.

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higher to pramium spa:c. ~- First class office s; ace in San Francisec rents fcr 71.~~

g 21.E5 per s::are ic00.

Additionally, from a business-:::: unity stand point, the City of Walnu Creek w:_^.: bansfit c:re frc: the preser. e of this agency than w;uld San Francisco.

There is space available in Walnut Creek a: the lower figure, wherea the availability of first class space in San Francisco appears to be essentially unavailable until mid-1930.

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0ther economic impacts such as Lthe cost of housing government vehicles and the cost of utilities cust be

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(g)

Summary 5 Mission Performance

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The proposed relocation of the Region V office, NRC, to San Francisco will adversely affect the ability of the agency to efficiently and effectively perform its functions and will have a detricental impact on operating programs.

There are no identifiable benefits accruing to the Government, the NRC, cr the public from the proposed move.

Section 1-104(c) has been considered and determined to have only a negative impact.

The GSA proposed relocation will ~ conflict with the policies of the Executive Order specifically resulting in actions centrary to the intent of Sectinns 1-201(a),1-201(d),1-203(a), and 1-203(d).

IV~.

Imacercrr the-Ecclcyeer 1.

Commuting (a)

Increased Costs About 905 of the Regica V employees working in Wale.ut Creek spend less than 60 minu. es per day ccmmut:ng bet.vetn their residences and -he office.

(Over 50$ Of the staff lives within ten miles of the office.

Inn minimum daily commuting time is less than 10 minutes.) These employees live in the Malnut Creek-Concord area or along direct commuting corridors to Malnut Creek.

Weekly cc muting costs amount to less than 53.50 per e pioyee.

Relocating the office :: San Francisco would increase each individuai's ccr..:ing tice by a minitu.m cf tuc hours per day.

There.;ould be.a minima of a threefold increase in daily ce tir; ti::a.

The avert;e ir.:rei:.e in cct:Ute time w0uld 15 six tines and the ar.it;m 15 times cur" n: :c: :ti : - i t..

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4 transportation, individuci ::.mutir.g costs would increase in am:unts rangir.g frcr 511.50 t: 522.C3.cer week - up te a six fold it.:rease ir. ccmr.u-in: ccsts.

The cos of automobile insurance would incr' esse significantly for those employees using private sahicles for commuting.

In these days of diminishing pure..asing power of the dollar and when federal pay raises lag behind the rate of

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inflation, it.is difficult to justify why federal empicyees

.1 should part with hard-earned dollurs to pay for commuting

.. wl.onger distances.-It is equally difficul_t to justify uhy

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employees should sacrifice, as a minimum, an additivnal two' hours per day - ten hours per week - 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per month - of their leisure time ' time now spent at home with their families, for the purpose of commuting to a city 20 or 25 miles from their present location.

Other than remaining in the Walnut Creek area, there are.

nc meaningful alternatives to consider regarding additional commuting time and costs.

(b)

Commuting Options The manner and ease by which Region V employees could get back and forth to San Francisco during peak commuting hours is an issue which must be addressed.

There is no alternative to consider except not to cccmute.

Since most of our employees will be taking the Conecrd '.'ainut Creek partr-ta-Sarr Francisco, there are only. tv c cp-icas available -

by automobile along Route 2? or by BART.

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The BART commute hour capacity is inadecuate to handle the present volume.

Plans to alleviate the situation wi n not suffice: Foretor more riders c:r to BAR7-wWr-exacerbate the commuting situation.

The Route 24, I-580, Bay,2 ridge corridor is satureted with vehiciar ccmmuting.

Driving is hazardous, ner e racking and time consuming; vehicle pollution is a cajor problem and one that the A:sociation of Bay Area. Governments is diligently trying to overcome.

Parking in San Francisco is at a. premium - both availability of space and cost -

and will worsen because of a new policy in San Francisco of intentionally nat providing parkir.g fer ter.an r cf r.s :

office buildings.

(The policy is to disccurage the use of private autoccbiles in the city. )

The policy of GSA :c er.: cura;e r:r c rt; ting te San : in:i:::

is contrary to c derci, 5 a:e. an-L ca: G: verr.e cc:7 c s a

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Summary - Impact On E.npiNyres - C:rm;;ir.g Not a single factor can be identified which would benefit the Government, the NRC, the public or NRC ecoloyees if the Region V office were required to relocate in San Francisco.

On the contrary, the proposed relocation would have

-c significantly adverse impacts on the personal lives and

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financial status'of the -NRC employees and their ihmilies.

On a collective' basis, the relocation would result in an

<--immediate : Toss ofzat least.530,000 annually to the employees.

More realistically, the annual-loss probably would be

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close to 550,000. Additionally; a ' minimum of 25000 hours would be added.to the annual work effor with no apparant benefit to anycne.

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The proposal by GSA to relocate the Region V NRC office is contrary to the requirements of Section 1-104(a),1-104(b) and 1-203(a) of the Executive Orders.

The proposal is not consistent with the criterion established in Section1-104(e).

The Executive Order requires that GSA consult with and coordinate proposals with other governmental bodies and community groups.

Sections 1-201 (d),1-203(b),1-203(c),

1-203(d) and 1-204 are applicable to this ma:ter.

The Region V office, NRC requests copies of any GSA reports and analyses that resulted from these consultations.

2.

Health,and Welfare (a)_ Increased Use of Lehve Because of the necessi y fcr maintaining health care facilities near one's residence, relocation of the Region V office to San Francisco will result in an increased use of sick and, annual leave.

Many dentists and physicicns do not have weekend hours.

Therefore, for personal 2nd family health care situations, employees will be required to use more leave to attend to health matters.

The increased use of leave will deprive employees of the use of annual leave for vacation or recreational uses.

Furthermore the increased use of sick leave adverseiy impacts the employee's ' option of accumulating sich leave for eventual ir.clesier in -he tcm;;tati:n of re-iremin-annui ties.

Tne poter.:ial financial icss could be su:-

stantial.

The e is r.: way :c ccm;ensa e fer this i: 5.

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(b)

Less cf Perscnal Time Increased cc :uting time o San Francisco will ceprive the staff of time pres ~ently available for family purposes and community ar.J cul.tural activities.

The addet ioss of personal time will have a detrimental effect en the general welfare of the regional inspection staff.

The inspectors now spend a minimum of one-third cf their weekdays away frca hera.

Frequently travel er inspectica effort. occurs on weakends.

The loss of personal time due

=" to' increased commuting will have an adverse effect on

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employee morale and will lead to intangible losses in employee productivity.

Both the employee and the agency-will suffer as a result of required additional commuting time.

(c)

Increased Risk of Bodily Harm Employees will be subjected to increased risk of bodily harm as a direct consecuence of increased travel on over-crowded highways to San Francisco during peak traffic times.

The chance of being involved in an accident will increase for those driving en Route 24 and I-580.

(d) Nousing The availability of adequate low and moderate housing for-federal employees and facilies is lacking in San Francisco.

This wouM severely-harpe: the abiM y of !3C explcyc-es-to find suitable housing at an affordable cost.

One viable alternative Ic the high ccst of San Francisco, which is available to both present and future employees, is to consider housing along the Route 24-680 corridnrs.

For.nex ecployae.s this.maans c = uting._

Many of the professional employees are in their early or mid-career period.

They are still raising families and are engaged in ccccunity, social and religious activities resulting in a preference for suburban living. These employees fe'ei that ney should not be required t.o sacrifice the advantages of surburan living and suffer the adverse effects on the quality of their lives that.

would result frca relocating to an urban environment.

(e)

Summary - Health ~and ilelfare of Employees The prcposed reicci-icn tc Sar Francis-uill ha'ee a serious detrimentti cffece er the 1;vec of the '72 eeployees_ and fr-ilict.

1:h.ile the ateerse effec c c c,e

welfare of Region V employees has no direct impa:: cn other covernr. ental ag5cci:s cr remiers cf the public, reduced e.gic.se mora'e c:al: cd.e: 31y affect tr.e quality of the services rendered by these employees.

Consideration of the. criteria set forth in Secticn 1-

.104(c),1-104(d) and 1-203(a) in evaluating the impact o'

-_ __the proposed' relocation clearly establishes a severely 7

adverse affect on the I!RC employees.

Ncthing can be

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identified that in any way offsets this adverse impact.

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General Imoact _ y;

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1.

Urban and Cor.:nunity

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The relocation of Federal agencies to the central business districts of selected cities as proposed by the General Services Administration includes a responsibility for GSA to prepare a comprehensive analysis of the cost, benefits and the impact en cities and cow. unities as a consequence of that proposal.

OMB Circular A-116, August 16, 1978, requires that GSA develop such analyses and that potentially adverse impacts be identified during the decision making process.

The impacts to be analyzed include those identified in Executive Order 12072 (Sections 1-104(c),1-104(d) and 1-203(a)).

Additionally, Executive Order 12072 identifies other requirements and criteric to be con-sidered by GSA.

Examples are Sections 1-101,1-102,1-104(a),

1-104(b),.1-10?(e),1-201(a),1-203(b),1-203(c) and 1-203(d).

OMB Circular A-95 (Revised - January 2,1975) require, the submittal. of certain reports to St?.te and Local Governments and to Federal agencies.

The information developed fer these

. reports as well as the impact analyses developed pursuant to OMB Circuhr A-116-and-Exec::tive Order 12072 will have a direct bearing on the propcsed relccaticn cf the NRC F.egica Y office.

Therefore, we requ6s that copies of these reports and analyses be provided to MC.

In addition to other issues, we believe the GSA analyses should address the following:

the overall impact or locating Federai agencies in the CBD of San Franc ~isco, especially in light of the demand for space by priva e enterprises, the inadequacy cf public transportation, and the lack of parkir.g the-optimum mix cf,. 0li: and c iva e c; ic. en:

i CCD of San Franciscc

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t the impact on cities anf cc.r.;..i-ies 1 air.g Federai agen:ies under the GSA ;r:?:.s31 til::E:ior. ;.rc;r 3:

the criteria used in deter.7inir.; - it tr.e CBD of Sin Francisco is in fact in need of revivifica-ion and in need of additional Federal facilities to en::cra;e deeelopment and redevelopment; and the impact s atement addressing

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these matters...

-c the criteria used in apparently detsrmir.ing that the City of Walnut Creek 'does not need revivification and the

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presence of Federal facilities to encourage development

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and redevelopment.

Regarding these issues, it is obvious that the loss of the HRC office to the City of Walnut Creek would be measurable, whereas the gain to San Francisco is theoretical at best.

The real socio-economic benefits derived by the City of Walnut Creek from the presence of the I;RC office far outweigh the theoretical benefits that would result to the City of San Francisco if it were to be located there.

The costs to the I;RC, the public and the NRC employees, or, the other hand, are substantial and considerably outweigh any benefits to be derived from such a relocation.

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Dear Congressman Miller:

Thank you for your letter of October 6, 1978, which discussed pertinent matters concerning the proposed reio. cation of tlie

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C - ERC Region V office from Walnut Creek, California to downtown

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f. ~fSan Francisco.

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i" We have just responded to a letter of October 4, 1978, from

'Mr.

Jay W.

Solomon, GSA, concerning this matter.

Our reply expresses the NRC position which is generally consistent with

.yours.

A copy of our letter to Mr. Solomon is attached.

Although we support the goal of Executive Order 12072 of s

using Federal spacd in urban areas to strengthen the cities, we believe that consideration of the impact of the mission

.of the Region V of fice involved in the proposed relocation, as required by E.O.

1207?., necessarily results in'the position which we take.

.Your continuing interest in this matter is much appreciated.

We will keep you informed on this matter.

Sincerely, Joseph M.

Hendrie

Enclosure:

Cy ltr to J. Solomon cc:

Mr.

J.

Solomon

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