ML20031E134

Requests That NRC Be Assigned Space Which Merit Sys Protection Board Will Vacate at 1717 H Street,Northwest Washington,Dc.Related Matl Encl

ML20031E134
Person / Time
Issue date:	05/11/1981
From:	Corley J NRC OFFICE OF ADMINISTRATION (ADM)
To:	Iselin R GENERAL SERVICES ADMINISTRATION
Shared Package
ML20031E094	List: ML20031E093 ML20031E095 ML20031E097 ML20031E100 ML20031E102 ML20031E114 ML20031E119 ML20031E122 ML20031E125 ML20031E127 ML20031E131 ML20031E132 ML20031E134
References
FOIA-81-316 NUDOCS 8110150131
Download: ML20031E134 (16)

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{{#Wiki_filter:~ r taAY 11 1981 p I;r. Richard Iselin, Chief DISTRIBUTlott: Assignment & Utilization Oranch, UPRU KITBili) ~ Subj. File, B0B Space Management Division, GSA Regional Public Buildings Service DJDonoghue, ADM 7th & D Streets, S.lf., Room 7031 PGNorry, ADM" Hashington, D. C. 20407 JHCorley, F0S - 1

Subject:

Additional Space - 1717 11 Street,f1.11., Washington, 0, C. This is to confirti recent discussions and to advise you that the flR want to be assigned the space which the l' erit System Protectio oes vacato at 1717 11 Street, H.U., Washington, D. C. Our preliminary assessment of the situation is that I:RC can reloca stantial portion of a major a sub-Safety and Safeguards (fii!SS) program office, the Office of U" clear Material. the Commission elements at il Street have been In addition and the spac,e assignment will provide minor relief there, as we on, The Office of t!uclear Regulatory Research.(RES), recently reor include the former Office of Standards Development o tions: partially relocated, we can then consolidate RES ('~'\\ viding them organizational integrity. ng, pro-The !!RC has been andergoing reorganizatio unctions in so many buildings. and with the planned assignment of approWith this assign Building of space,at East-Uest Toutrs (fornce LEAA space), ximately 40,000 sq return the building at 5650 Nicholson Lane to the GSA inventory.the r!R Timing will depend in large measure, on the speed with which GSA the necessary minimal alterations to the space at ll Street ccomplish preparing the space layout and alteration requestass early as we canHe w He appreciate your interest in and attention to our r. pace problems cooperate to expedite occupancy. and will please let us know. If additional information is requ, ired,

Oncefply, Origina1 Signed by:

John H. Corley John H. Corley, Director Division of Facilities and Operations Support Office of Administration 31 s10817 b PDR HEARNC'~316

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. *gd '. '* coreTnou.cn acucnAt. OF THE UtHTCD STATES %,g/ was m crou o.c. m. SEP 11 1930 B-200163 The Honorable Warren Magnuson Chairman, Committee on Appropriations United States Senate The Honorable Jamie'h itten Chairman, Committee on Appropriations 1, louse of Representativ'es

Subject:

Proposed Interim Consolidation of the Nuclear Regulatory Commission (EljD-80-ll8) This report responds to the July 2, 1980, supplemental appropriations conference report of the Senate and House Committees on Appropriations. the General Accounting Office to review the proposed NuclearThe Regulatory Commission (NRC) interim consolidation plan, to identify and evaluate other options which would enableand presently dispersed NRC activities to be consolidated at an early date in a cost-effective manner. An interim consolidation is planned pending completion of a permanent facility of suffi' ient size to house the entire NRC c headquarters. In this regard, both the Senate Committee on Works and Transportation recently authorized the Ge I vices Administration ing studies for a Fedcral building in Silver Spring,(GSA) to pr to house all of NRd.

Maryland,

. building several years ago.NRC and GSA began efforts to obtain such a The impetus for the proposed interim consolidation derives l from findings of investigations into the Three Mile Island nuclear i powerplant accident. These inve'stigations concluded that NRC's t regulatory effectivener.s is'significantly impaired because the agency is housed in eight buildings in four geographic locations in Washington, D.C. and Montgomery County, Maryland. concluded in our rec,ent assessment of NRC's overall performance j We also over its first 5 years that the agency's scattared physical G (301554) 8 9 + = + ~- M

B-200163 a locations adversely affect.its efficiency. Our assessmen,t was .~j largely based on 50 of our earlier reports covering a wide range of NRC programs and activities. The conference report. required us to report within 60 days. Consequently, we were limited in the amount of work we could do to independently verify the accuracy of the cost and other data' obtained during our review. tive judgments involved, Further, because of the many subjec-we were not able to arrive at any clear-cut viewpoint regarding NRC's position that its management would 4 i be most improved under its proposed interim consolidation plan j when compared to other alternatives. t 4 The NRC proposed interim consolidation entails relocating j about 1,200 employees,from Montgomery County to the Matomic building in Washington, D.C., i 1,400 NRC employees in four buildings in Bethesda.and consolidating the rema About 1,000 employees of 8 Federal agencies would be relocated to.the space vacated by NRC. GSA initially estimated that the proposed con-solidation would take 18 months at a minimum, cost of $3 million. l. According to NRC,'the proposed plan is an opportunity for ( NRC to achieve a substantial interim consolidation in two geo-j graphic locations. In so doing, the plan would put senior agency management and the major regulatory offices in the same building and put ' offices within about two city blocks of each other.the agency's resear i Another - advantage, according to NRC, it occupies from eight to five.is to reduce the number of buildings 1 i There are, however, some disadvantages. The cost of the proposed move could go as high as $5.7 million; staff of some organizational units would be split between the Matomic build-i ing and Bethesda; from the Matomic building will notapparently many Federal agencies being moved 3, " backfill" space vacated by NRC; and GSA's lease on the Matomic building has expired with no immediate prospects for renewal. A less costly interim alternative is to move the five Commissioners and their staff to Bethesda, { and to make room for them by relocating other NRC employees to the Matomic building. This alternative would cost on the order of $500,000. It would not permit a large consolidation under one poof, but it would keep organizational units intact and would not affect other 'l Federal agencies. This alternative would put the Commissioners ~ and about 1,800 of NRC's 2,700 headquarters employees in six buildings in Bethesda, any one of which is within 'a 15-minute walk of the others. '2 i

(. 1 .{ ~ B-200163

• t GSA also tried unsuccessfully to identify reasonable, options for permanently consolidating NRC in an existing federally owned or' leased building in the Washington, D C.,

j-metropolitan area. Our efforts to identify such an alterna- ,3 tive were also unsuccessful. In conclusion, we believe there are two pr.actical options i for consolidating NRC on,an interim basis. One is the pro - , )! posed plan. NRC's management believes it is the preferred option because it would consolidate senior management and .} key staff in the Matomic building and put the rest of NRC j in Bethesda, at the expense of breaking up some organizational units. The second alternative is to move the NRC Commission-1 ers and their staff to Bethesda, and to make room for them by j relocating other NRC employees to the Matomic building. This option is much less costly to implement, and we believe it 4 could accomplish the same basic objectives of the proposed" 1 plan. It would not reduce the number of NRC locations, nor l permit. a large consolidation in one' building. It would, how- .l ever, put about two-thirds of NRC's employees in buildings within a 15-minute' walk of each other. .r. 4 Thus, there is a clear-cut initial cost advantage to i moving the Commissioners'to Bethesda. Which interim consoli - dation would prove more effective from a management stand- .]. point involves many subjective judgments and cannot be clearly j evaluated. Further, the relative importance of the cost ad-vantage diminishes somewhat over time if budget const"aints or. other factors prevent the early completion of a permanent ., 'i facility for NRC and.the interim consolidation becomes more of 'i a permanent fix. .i Still other factors, in addition to initial costs and j potential management improvements, need to be considered in 1 choosing between the two basic interim options. Specifically: .i 'l --GSA and NRC need to resolve the matter of the Matomic ] building lease before the proposed plan is implemented. t } --The~ August 26, 1980, House Committee on Public Works j and Transportation resolution authorizing GSA to begin j work on a permanent. facility for NRC in Silver Spring i also directed GSA to consolidate NRC in suitable space in Bethesda on an interim basis. At the time we com-i pleted our review, GSA officials were as yet undecided j on how the resolution would affect NRC's proposed interim consolidation. 1 o 3 l n

\\ B-2OOl63 ~ ~ --If GSA and NRC decide to consolidate NRC in Bethesda, the two agencies need to renew past efforts to r'elocate NRC's employees from Rockville and Silver Spring to

Bethesda, i

in addition to moving NRC's Commissioners and their staff from the Matomic building to Bethesda. 1 t Regardless of which option is pursued, it is important ,) that the Congress, the administration, and NRC not lose sight of the fact that neither option adequately fulfills the consoli- ~ i dation objectives. of the Three Mile Island investigation reports and our own recent report assessing NRC's regulatory effective-1 Thus, neither option is satisfactory as more than an in-ness. j terim step pending congressional approval, funding, and GSA con-struction of a facility large enough for the entire agency. I In commenting on this report, NRC said the proposed 5* interim consolidation is the only acceptable alternative identified to date'which would foster Commission interaction with its staff and the coordination of numerous staff offices ,{., with each other. NRC said our alternative option of moving .h the Commissioners to Bethesda is not acceptable because it would not cut down on the agency's dispersal problem. NRC's comments'did not address.the recent House Committee on Public Works and Transportation resolution directing GSA to locate 4' NRC in Bethesda on an interim basis. Furthermore, GSA t j officials c ould not tell us how the resolution would affect the proposed interim consolidation plan. l We agree that our alter ativ'e would not reduce the num-l ber of locations where NRC is presently housed. Unlike NRC's ' j proposal, however, our alternative would keep organizational j units intact and would permit the largest congregation of NRC q cmployees to be within walking distance of each other. En-closure II to this letter contains NRC's comments in thei~r- 'l entirety. Enclosure I discusses the results of our evaluation ~ . in more detail. 3 i ~ 4 G g .1-

.s 1 . E-200163 k'e are providing copies of this report and other inter'ested phrties, to the Chairman,

NRC, available to other.s on request.

and we will make copics i -DO./ 0 k A ' Comptroller General of the United States Enclosu'es - 2 r O o O se 9 9 9 4 t 9 e I 0 9 9 9 9 ~ e O e Alm I e 4 e O e 5 G S a ese e w* l-

., g' Lt4 CLOSURE I ..t ENCLOSURE I - l' ALTERNATIVES FOR AN INTERIM 1 CONSOLIDATION OF THE .n , NUCLEAR REGULATORY COMMISSION .i PERSPECTI'JE [. On January 19, 1975, the Atomic Energy Commission (AEC) f was abolished, the Nuclear Regulatory Commission (NRC) was created to regulate commercial nuclear activitier, 1' Energy Research and Development Administration 1/ was created and the to develop energy technologies. retained AEC's office building at Germantown,The new Energy ~ Administr Maryland, and the NRC staff remained in the Bethesda, Maryland, offices it occupied as AEC's regulatory arm. however, housed themselves in the Matomic building,The new NRC C j l

Street, N.W., Washington, D.C.

1717 H j " downtown" offices available to AEC's CommissionersThis of fice space The new NRC, however, was immediately faced with the need to acquire more office space because (1) certain AEC develop-i mental functions, such as reactor safety research, were trans-

j..

ferred to NRC, and.(2) as a new agency, NRC had'to develop its t own supporting infrastructure.- -Q additional of fi'ce space was leased in Bethesda,Over the next year, theref Silver Spring, and Rockville, Maryland. grown from about NRC's headquarters organization has employees at present.1,600 employees in January 1975, to about 2,700 NRC's Office of Administration, 3 at the direction of NRC's first Chairman, was also preparing to relocate the Commission-ers and their staff to Bethesda. Although renovation work was .i already in progress, that the selected space was too small.NRC officials said it then became appare Renovation work was' stopped and plans to relocate the Commissioners wera dropped, they said, building were unsu.ccessful.when efforts to acquire, additional space in th.e Also', NRC's first Chairman left the agency shortly thereafter and none of the subsequent NRC i Chairmen or Commissioners have attempted to relocate the Commissioners and their staff to Bethesda. 3 ~/On Oct. 1, 1977, the Energy Research and Development 1 Administration became a part.of the Department of Eaergy. s s .i {. I j 1 e

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(l. ENCLOSURE I \\^ j ENCLOSURE-I e t (. e Soon after it was created, NRC, working with the General Services Administration house the entire headquarters organization in one building.( In May 1977 GSA submitted a prospectus on such a building ~~ iJ to the Congress. Recently, the Senate Committee on Environ-ment and Public Works and the House Committee on Public Works 4 ~ and Transportation authorized GSA to proceed with design and engineering on a Federal building to house NRC in Silver Spring. GSA officials told us this congressional action would ) ',} depending on future congressional appropriations. enable them _The Three Mile Island accident 1 in March 1979 renewed the impetusThe accident at,the Three Mile Isla j for consolidating NRC's headquarters organization. For example, the President's J Commission on the Accident at Three Mile Island found that the geographic spread of NRC inhibited the easy exchange of i, ideas. The President's Commission' recommended locating top g m.anagement and major staf.f components in the same building or group of buildings. On December 7, 1979, the President ..i, agreed and directed that GSA plah to consolidat'e the NRC .i Commissioners with NRC's major staff components in the same 'q' building or a group of buildings close to each other. l The NRC Commissioners' own Special Inquiry Group investi-j gating the Three Mile Island nuclear powerplant accident also I concluded that NRC should be consolidated. I The Group pointed ~ i out that physical separation of organizational components wastes time on travel and fosters poor working relationships, i The group recommended.

• 1

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• that high priority be given to locating the entire agency in a single location.

i The fact that the location may not be in downtown Washington, should not slow down the agency's unification. D.C, i In the interim, we believe the offices of the Commis-sioners and their personal staff should be promptly i relocated in Bethesda, Maryland, adjacent to most NRC staff offices." 1 Fin ~ ally, in our r'ecent assessment of NRC's overall perfor- ,i mance over its first 5 years, we also concluded that its scat-tered physical locations adversely affected its efficiency. 1/ 1/"The Nuclear Regulatory Commission: More Aggressive Leadership Needed," EMD-80-17, Jan. 15, 1980. l 2 3 -.i - -

.4 ENCLOSURE I 3 J. ENCLOSURE I e 4 i Our asse'ssment was covering a wide range of NRC programs,and activities.largely bas On the stren'gth of the three major reports discussed above, the NRC Commissioners and the Office of Management and Budget (OMB) decided that some interim consolidation step was essential pending completion of a facility large enough to house the entire agency. f existing facility in the Washington,According to GSA,,there was no ~ D.C., metropolitan area large enough for an interlm consolidation of all of NRC. I NRC decided, with OMB concurrence,

Thus, i

would be to colocate senior management and the Offices ofthat the best Nuclear Reactor R'egulation, Nuclear Material Safety and Safe- [ guards, and Inspection and Enforcement in the Matom c building. Leasing new office space for the Commissioners in Bethesda was rejected because this would not consolidate these key personnel in one facility, and because contacts with agencies such as the Department of Energy and the Environmental Protection Agency are in Washington, D.C. Another objective is to move ] the research and s,tandards development offices from their pres-ent Silver Spring and Rockville locations to buildings in i Bethesda within two city blocks of each other. . p. -( We have evaluated the proposed consolidation plan and ] foand it t. be much more costly than moving the Commissioners and their staff to Bethesda as NRC's first Chairman had planned. ' 4, There are strong and weak points about both options, j, but on balance, we believe both represent an improvement over how the agency is presently located. We alco tried to identify options for an early permanent consolidation of NRC. Our work confirmed earlier GSA conclusions that there are no realistic options for I an early permanent consolidation. l The following sections discuss the results of our work in more detail. ADVANTAGES AND DISADVANTAGES OF h 'a THE PROPOSED INTERIM CONSOLIDATION i 1 The proposed interim consolidation plan c'ntails (1) relo-j cating about 1,200 selected NRC employees from buildings at three locations in Montgomery County, Maryland, to the Matomic building; (2) relocating about 1,000 employees of eight Federal i agencies now in the Matomic building to the space vacated by { NRC; and, (3) consolidating the remaining approximately 1,400 .*. l NRC employees into four buildings in Bethesda which are within two city blocks of each other. GSA initially estimated that >. ] the interim. consolidation would cost about $3 million and take 18 months. a I O 't' 3 i l L

l' 4 ENCLOSURE I 'j ENCLOSURE'I -l According to NRC' a substantial interim consolidation in two geographic loca-th tions which has these principal advantages:

3. i.

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--It wou.ld put the Commissioners, the Executive Dir*ector for Operations, .5 same building. and the major program offices in the t --It would permit NRC to put its standards and research. 3 1 offices, which require close coordination,

• i within two I

blocks of each other in Bethesda. --It would reduce the. number of buildings NRC occupies from eigh't to five. .t l The cost of implementing the proposed plan, however, 1 much higher than the cost of moving the NRC Commissioners to is .i

Bethesda, i

as discussed below.and there are a number of disadvantages to the plan, GSA's initia1 $3 million cost estimate for the proposed interim consolidation was based on a minimal amount of of space renovation; emergency-related incident response center in Bethesda to sj.- either the Matomic building o,r other space in Bethesda; and did not include the cost of relocating any other special equip ment belonging to NRC or the other affected agencies. l estimate also assumes that the agencies vacating the Matomic The j building will " backfill" office space in Silver Spring, ville, and Bethesda to be vacated by NRC. Rock- - i Thus, any more than minimal essential renovation requirements will increase the j cost of the consolidation. Furthermore, apparently few of the .j what is now NRC office space in Montgomery County ^ - J i

however, GSA plans, blocks of this space.now call for requiring other agencies to use major j

GSA has yet to identify space for some of the eight Federal agencies affected by the proposed consolidation ',1 , GSA now estimates-that the cost of the proposed plan could in-crease from $3 million to agencies acquire new space $5.7 million, depending on how many rather than backfill the vacated NRC j space.

Finally, some agencies are resisting the move from the 3

Matomic building, and as a result, schedule has already slipped, the projected consolidation GSA's ability to locate new space for these agenciesand may slip more NRC's detailed plan for implementing the interim consolida tion also shows that the pr'posal~would break up some organiza o .ional components now physically intact. i For example: s 4 l

t ENCLOSURE I ENCLOSURE I 4 'i --The Office of Nuclear Reactor Regulation would be

split, ing, and 415 employees remaining in Bethesda.with 3 it recognized that Although might necessitate this split,some higher NRC management objectives the management of this Office considers keeping the Office staff physically intact tive Office operations.to be the most important criterion for effec-

] --The Directors of the Offices of Standards Development and Nuclear Regulatory Research would move to the Matomic building, but"their staffs would be in j Bethesda.. '1 --The NRC incident response center would be relocated j within Bethesda, j even though key incident response personnel would be located in the Matomic building. i NRC also plans to move about 100 employees to the Matomic building who do not have any direct role in nuclear regulation. the Commissioners'These~ units include equal employment opportunity, office of. Inspector and Audit,or, and por-tions of the Executive Director's Management and Program Analysis Office. 1 Other factors also detract from the proposal.

First, Assistant Secretary for Nuclear Energy, NRC's contacts s

j i the Department's nuclear technology organization are located l at Germantown, Maryland, rather than Washington, D.C. a i

second, in the Matomic building,there would be no room for further expansion i

'have to occur in Bethesda or a second Washingtonso any future staff ex i location. D.C., J .i Finally, and of importance to the proposed interim consolidation, GSAs lease on the Matomic building expired on August 1, 1980. GSA has been inf mally negotiating with the building owner for about 1 year, pending congressional au- .i thorization.to negotiate a lease extension, but the owner ~ has been unwilling to renew the lease on the terms offered by GSA. Until the lease is renewed, GSA is in what it terms a building without a lease." holdover status" in which the tenants contin GSA officials could not estimate when they might finally be able to.obtain a new lease, but -j also said they foresee no difficulty in eventually obtaining one. they 1 5 e I.

d. '.

ENCLOSURE I ENCLOSURE I 1 [ Furthermore, GSA currently prohibits alterations in amounts over $50,000 for a. building in " holdover" Incledad in the proposed consolidation plan, however, are status. which GSA estimates will cost about $1.5 million." min.' l-these alterations cannot be made until GSA obtains a new l Therefore, 't or changes its current policy on renovating space in a " holdover" status. I ~ ADVANTAGES AND DISADVANTAGES OF ') 1 MOVING THE COMMISSIONERS TO ECTHESDA 3 .l-than the proposed interim consolidation plan.We identified a i This alterna-tive would involve relocating the 5 Commissioners and their j staff--up to about 150 employeen--to Bethesda. for them, To make room other NRC employees could be relocated to the Matomic building. For example, Panel and Atomic Safety and Licensing Appeal Board PanelNRC -i j 50 employees in all, about These panels operate independently and,could be moved to the Matomic j j therefore, to be close to the Commissioners or the NRC staff. have no need native This alter- .}, (1) would cost on the order of $500,000;'(2) accomplished relatively quickly; (3) would involve up to about could be '( 450 NRC employees rather than 1,200 NRC employees and about' 1,000 employees of eight other Federal agencies; and (4) would noe re' quire NRC to acquire additional space, except for temporary i space to facilitate movement of personnel and space alterations. The cost of acquiring a small amount of temporary space is not known at this time. t This alternative would not permit NRC to consolidate 1 almost half its organization "nder one roof, nor would it reduce the total number of NRC locas j ons and buildings. It would, how-i the Commissioners,ever, permit organizational units to remain intact and wou j the Executive Director for Operations, the Office of Nuclear Reactor Regulation within two blocks of and ,i cach other. The O~ffice of Inspection and Enforcement and the NRC incident response center would also be in Bethesda at about a 15-minute walk from these other units. Without further reshufflin,g, the Offices of Nuclear Material Safety and Safe-j guards and Nuclear Regulatory Research would remain 5 miles from Bethesda in Silver Spring 'and the Office of Standards Development would remain 5 miles away from Bethesda in Rockvi&1e I Additional reshuffling of NRC organizational units could further cubance the relative physical proximity of units ' directly involved in the day-to-day regulation of nuclear power. I e L e 1 I

1 ENCLOSURE I ENCLOSURE I The extent of any such further reshuffling would, of course, increase the cost of this alternative option accordingly. EARLY PERMh. I' CONSOLIDATION a* DOES NOT APPEAR

• FEASIBLE

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• j We also attempted to identify reasonable options for permanently consolidating NRC in a federhlly owned or leased building complex sooner than the 5 to 10 years currently required to construct a new Federal building.

According to GSA officials, they also tried to identify any available options, but were unable to do so. Our discussions with area realtors, developgrs, and county government officials confirmed that there is no realistically available option for permanently f consolidating NRC in an existing federally owned or leased i building in the Washington, D.C., metropolitan area. CONCLUSIONS I, We believe there are two practical options'for consoli-dating NRC on an interim basi.s. One is the proposed plan. NRC's management believes it is the preferred option because it would consolidate senior management and key staff in the Matomic building and put the rest of NRC in Bethesda, -{ at the expense of breaking up some organizational units. The second alternative is to move the NRC Commissioners and their staff . to Bethesda, and to make rcom for them by relocating other NRC employees to the Matomic building. This option is much less costly to implement, and we believe it could accomplish the same basic objectives of the proposed plan. It would n'ot reduce the number of NRC locations, nor permit a large consoli-dation in one building. It would, however, put about two-thirds , 'j' of NRC's employees in buildings within a 15-minute walk of each other. 5 ]

Thus, the Commissioners to Bethesda.there is a clear-cut" initial cost advantage to mov Which interim consolidation 3

would prove more effective from a management standpoint involves many subjective judgments and cannot be clearly evaluated. . Further, the relative importance of the cost advantage dimin~ i ishes.somewhat over time if budget constraints or other factors j thE early completion of a permanent prevent facility for NRC and the interim consolidation becomes. more of a permanent fix. Still other factors, in addition to initial costs and 'j potential mantgement improvements,,need to be considered in j choosing between the two basic interim options. Specifically: 'l i 9 I 7 3 a-

.o 't ,i ENCLOSURE I ENCLOSURE I. a --GSA and NRC nee to resolve the matter of the Matomic building lease before the proposed plan is, implemented. t.

3. '

--The August 26, 1980, House Committee on Public Works and Transportation resolution authorizing GSA to begin work on a permanent facility for NRC in Silver '.- - 4 Spring also directed GSA to consolidate NRC in suit- .j able space in Bethecda on an interim basis. i time we completed our review, GSA officials were as At the j yet undecided on how the resolution would affect i NRC's proposed interim consolidation. --If GSA and'NRC decide to consolidate NRC in Bethesda, the two agencies need to renew past efforts to relo-cate NRC's employeec from Rockville and Silver C;,.ing to Bethesda, in addition to moving NRC's Commissioners and their staff from the Matomic building to Bethesda. Regardless of which option is pursued, it is important that the Congress,- the administration, and NRC not lose sight of the fact that neither option adequately fulfills the con-solidation objectives of the'Three Mile Island investigation .i ' reports and our own recent report assessing NRC's regulatory .I-effectiveness..Thus, i than an interim step pending congressional approvalneither opt and GSA construction of a facility large enough for the entire

funding, i

agency. f. NRC COMMENTS AND OUR EVALUATION 9 NRC maintained that the proposed interim consolidation- .i plan is the only identified option which can signific lj and coordination among numerous staff offices. j advantage, NRC said, The basic . ]. of distinct agency locations to two.is that the plan would reduce the number On the other hand, NRC

said, moving the Commissioners to Bethesda is unacceptable because it does nothing to solve the present dispersal problem l

HRC's comments did not address the recent House Committe locate NRC~in Bethesda on an interim basis.Public Works '{ I GSA officials could not tell us how tha resolution wouldFurthermore, I affect the proposed interim consolidation plan. .i the number of dispersed NRC locati~ons,If the objective of an we agree that the proposed interim consolidation is superior to our alternative 8 l m mw+m a-mes ..s

ENCLOSURE I ENCLOSURE I U. :- option.. The basic objective, however, prove interaction among all NRC organizational components sois that the agency, in its entirety, While the alternative we offered would not reduce the numberf of disperse,d NRC locations, it would, as discussed in our

report, within walking distance of each other.put the largest number of NRC l

not disperse organizational units, Furthermore, it-would Office of Nuclear Reactor Regulation,such as splitting up the i in the process of con- 'j solidating the agency. In the final analysis, the issue boils down to whether or not it is better, J tiveness viewpoint, from a management effec-to have the Commissioners and about two-thirds of the { or within walking di' stance of each other. ncy i. I NRC also said the $500,000 I Commissioners i to Bethesda is low, cost estimate for moving the i account for special Commission needs,because (1) it does not such as hearing rooms and security arrangements; and (2) NRC would save about $1 ' two locations.million a year in administrative costs by consolidating in q We disagree.t' hat our $500,000 a and their staff to newly leased space in Bethesda low.. s simultaneously moving NRC employees from Bethesda to the i about $200,000..Matomic building as proposed in our alternative option) i savings by consolidating in two locations.We recognize that N These could, how-agencies to be moved from the Matomic building.be o

over,

.l has not Because GSA l however,yet decided where some of these agencies will be housed, istrative cost impact would be on the Federal budgetwe we j.j -OBJECTIVES, SCOPE, AND METHODOLOGY \\ j Our objective was to determine if there are cost-effective j ~ alternatives Because the Appropriations Committees *to the proposed interim conso 1 j quired us to report within.60 days, conference report re-in conducting our review was limited tothe methodology we followed --interviewing officials of the Office of Management and l Budget, GSA, NRC, Montgomery County, other 3 cal govern-ment officials, and area real estate developers; ~ 4 .9 e e

~ ENCLOSURE I ENCLOSURE I --reviewing corresjondence and other documentation pro-vided by the above officials related to the proposed interim consolidation and alternatives to it; and' --developing"rotential alternative options for consoli-dating NRC, interim consolidation, comparing these options with the proposed 8 and eliminating all but one alternative as impractical compared to the proposed plan. We were limited in the amount of work we could do to indepen-j dently verify the accuracy of. data obtained, such as GSA and NRC estimates of the costs of various consolidation options i or to develop our' own cost estimates of alternatives not con- ,j sidered by those agencies. us that their cost estimates of the proposed interim consolida-Fu { tion are subject to significant changes as work proceeds 1 Furthermore, because of the many subjective judgments ? involved, we were not able to evaluate how effectively NRC i dation plan or alternatives to it.could improve its management unde i

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'J 1 I f. l i ,s 1 i f '1 i e l' l i j ~ 10 j

6 ENCLOSURE II ENCLOSURE II ' 5 .j s, 1 un:TED STATES

i i*'8 E

NUCLEAR REGULATORY COMMISSION A ~ - y m. f September 3,1980 W AS HINGT O N. D.C. 20555 f I OFFICE OF THE CHAlnMAN Mr. J. Dexter Peach Director, Energy and Jiinerals Division. U.3. General Accounting Office j Washington, O.C. 20548

Dear fir. Peach:

Ve have reviewed the draft r.0 report, " Proposed Interim Consolidation of the !!RC," and agree with the ~ lusion that IRC's scattered physical locations seriously affect 12C ope

as.

We cor.tinue to maintain, however, that the OMB proposed interim consolidation plan, which would relocate half the agency in the Matomic Building and half it) Bethesda, is the only acceptable short- ' tem solution identified to date. This, plan would significantly reduce two existing problems of Cor.ission interaction with its staff and the coordination .~,. of numerous staff offices with each other. The proposed alternative plan e suggested by GAO, however, would only carginally address the first of these problems. l'oreover, by raerely reshuf fling the agency within the currently dispersed configuration, the 3A0 plan would leave the I2C scattered in five dif ferent locations. In contrast, the OMB plan providas for substantial consolidation in two locations. Since the GA0 alternative would not in. prove t our dispersal problem, we feel strongly that the agency should'aot go forward with this alternative. i With regard to the difference in costs of the alternatives, it is important to note two points. First, the $500,000 estimate for the GAO alternative is low since it does not take account of the extensive alterations which would be required to meet the Comission's special needs, such as p"blic hearing roons and security. arrangements. Second, we estimate that under the OMB proposal the agency would save one million dollars a year in administrative costs by consoli-dating in two locations. Thus, over a five-year ^ period, which is the shortest. possible time before a permanent building could be ready, the savings would be enough to offset the initial. cost difference. These savings would not be. realized under the GAO prop; sal. In sumary, the Comission is concerned that the GAO report could create the , false impression that either of the proposed alternatives is acceptable. To the contrary, the GAO alternative does nothing to solve the current state of dispersal and as such is unacceptable. We have to emphcsize that it is we who are given the responsibility of managing this agency to Assure safe nuclear We have pointed out for years the need to deal with the chaotic housing power. .i pattern of the ap,ency. It was only after the accident at Three Mile Island i _ p /DD$$0V 1.1 s e 9

6f7' T ,J. Dexter Peach -. 2 September 3, 1980 that we received general recognition of the need to assist us with our problem. If we lose this opportunity that is presented to us in the fonn of the OP.B proposal, it will be. extremely unfortunate, not only for us in our abilities to manage and control this acency, but more significantly for the adverse impact of this loss on our ability to assure safe nuclear power. Sinc

ely, D

? / 4 IJ hn F. Ahearne l Chairman 3 -

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