Facility Relocation: NRC Based Its Decision to Move Its Technical
Training Center on Perceived Benefits-Not Costs (Letter Report,
10/19/2000, GAO/GAO-01-54).

The Nuclear Regulatory Commission (NRC) has decided to move its
technical training center from Chattanooga, Tennessee, to near its
headquarters in Rockville, Maryland. The facility relocation is meant to
improve the effectiveness and efficiency of the agency's operations. The
center provides diverse training curricula on such topics as nuclear
power plant technology augmented by training on simulators, risk
assessment, radiation protection, and regulatory skills. NRC used a
reasonable methodology to determine the costs of relocating its
facility. It considered costs related to staff salaries, travel costs
for center participants, and lease payments. However, NRC used several
assumptions that, if changed, would affect the move's cost. For example,
a change in the number of staff who would relocate would have an impact
on costs. NRC stated that the objective of the move was not to minimize
the cost of operating the center but rather to improve the effectiveness
and efficiency of the agency's operations. It believes that the move
would result in numerous benefits, including increased access to
training facilities by its headquarters staff and frequent use of
simulators in investigations. NRC has a number of issues that it must
resolve to ensure the long-term efficacy of its training program, such
as planning to replace training instructors who will be retiring in a
few years.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GAO-01-54
     TITLE:  Facility Relocation: NRC Based Its Decision to Move Its
	     Technical Training Center on Perceived Benefits-Not
	     Costs
      DATE:  10/19/2000
   SUBJECT:  Human resources training
	     Training utilization
	     Cost effectiveness analysis
	     Comparative analysis
	     Federal facility relocation
IDENTIFIER:  Rockville (MD)
	     Chattanooga (TN)

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GAO-01-54

Report to the Chairman, Committee on Governmental Affairs, U. S. Senate

October 2000 FACILITY RELOCATION

NRC Based Its Decision to Move Its Technical Training Center on Perceived
Benefits– Not Costs

GAO- 01- 54

Letter 3 Appendixes Appendix I: NRC's Views on the Potential Benefits of

Relocating the Technical Training Center 22 Appendix II: Comments From the
Nuclear Regulatory

Commission 27 Appendix III: Scope and Methodology 29

Tables Table 1: Relocation Plans of the Center's Staff 9 Table 2:
Headquarters' and Regional Offices' Attendance at

Technical Training Courses, Fiscal Years 1995- 99 12 Table 3: NRC's Reactor
Technology Instructors and the

Technologies for Which They Are Qualified 16 Table 4: Number of NRC Staff
Trained on Simulators, Fiscal

Years 1996- 99 17 Table 5: Center's Staff, NRC's Senior Managers, and NRC's

Commissioners Views on the Potential Benefits of Relocating the Center 22

Abbreviations

GAO General Accounting Office NRC Nuclear Regulatory Commission

Lett er

October 19, 2000 The Honorable Fred Thompson Chairman, Committee on

Governmental Affairs United States Senate

Dear Mr. Chairman: The Nuclear Regulatory Commission (NRC) issues licenses
to a wide array of private entities to ensure that they use radioactive
materials safely and in a manner that protects the public and the
environment, including 103 operating commercial nuclear power plants and 10
facilities that produce fuel for these plants. In addition, NRC or states
that have agreements with NRC (agreement states) regulate more than 20, 000
entities that use radioactive materials in medical, industrial, or academic
applications. To ensure that its staff and those from the agreement states
have the necessary expertise to carry out their responsibilities, NRC's
Office of Human Resources manages a wide range of training programs,
including those at the Technical Training Center (Center) in Chattanooga,
Tennessee. 1 The Center provides diverse training curricula on such topics
as nuclear power plant technology augmented by training on simulators, risk
assessment, radiation protection, and regulatory skills.

To improve the effectiveness and efficiency of the agency's operations, on
February 24, 2000, NRC decided to relocate the Center and its four
simulators from Chattanooga to a location near its headquarters in
Rockville, Maryland, after 5 years of debate. 2 NRC expected to maintain a
small staff in Chattanooga from fiscal year 2001 until April 2003 to provide
reactor technology training and expected to relocate the remaining Center
staff to headquarters by the end of fiscal year 2001. Because of your
concerns about the cost and programmatic implications of the proposed
relocation, you asked us to determine whether (1) NRC used a reasonable
methodology to estimate the costs to relocate the Center, (2) the expected

1 NRC requires the agreement states to ensure that their staff meet certain
training and experience requirements. To help ensure that agreement states'
personnel can obtain and maintain the required level of proficiency, NRC
annually offers a number of courses that directly relate to them.

2 A simulator is a model of a control room for different designs of
commercial nuclear power plants.

programmatic benefits of relocating the Center versus keeping it in
Chattanooga are reasonable and supported, and (3) other issues will affect
NRC's technical training program.

We used generally acceptable economic principles to evaluate NRC's cost
estimation methodology and the reasonableness of key economic assumptions
used in the estimate. Since the expected benefits cannot be easily
quantified, NRC could not develop a standard cost/ benefit analysis for
relocating the Center. In addition, neither the Office of Management and
Budget nor the General Services Administration requires agencies to prepare
a cost/ benefit analysis when relocating facilities.

Results in Brief NRC used a reasonable methodology to estimate the costs of
relocating the Center from Chattanooga to Rockville. For example, NRC
appropriately

considered such cost elements as the differences in travel costs of the
participants, salaries and benefits of the Center's staff, and lease
payments between the two locations. However, NRC incorporated a number of
assumptions in its estimate, including assumptions about the site that could
be used for a Rockville Center, the number of staff who would relocate, and
the timing of the move. Any change in these assumptions will affect the
estimated cost of the move.

NRC has said that moving the Center to Rockville will result in a number of
benefits for its technical training program and for improving the agency's
effectiveness and efficiency. Although NRC could realize some of the
benefits, it has no analysis supporting the extent that it could. For
example, one claimed benefit would be that an increasing number of
headquarters staff would participate in technical training. NRC may not
fully realize this benefit because less than 25 percent of its 2, 800 staff
are required to receive technical training. When NRC moved the Center to
Chattanooga in 1980, two of the expected benefits were that the remote
location would provide a more conducive training environment and that the
relatively low cost of living would facilitate the recruitment and retention
of qualified instructors. Although the Center's staff believe that
Chattanooga continues to provide these benefits, some NRC senior managers
view the remote location and the time required to travel there as
disincentives for headquarters staff to attend training.

A number of issues will have an impact on NRC's technical training program.
For example, NRC will face a significant challenge to replace the Center's
instructors. In 2003, 15 of the 18 instructors will be eligible to

retire; and in 2005, when the lease in Chattanooga expires, 17 of the
instructors will be eligible to retire. Our analysis of NRC's data shows
that the agency has potentially over 1,200 staff with the knowledge and
experience to replace the Center's staff. However, NRC has not developed a
plan to ensure that the agency has the appropriate number of instructors or
the skills and expertise needed for the staff who will eventually succeed
those at the Center. Timely succession planning will ensure the continued
quality of NRC's technical training program and can be carried out without
regard to relocating the Center. We are recommending that NRC identify the
skills required for staff who will replace its instructors and develop a
succession plan for replacing them.

We provided NRC a draft of this report for its review and comment. NRC
generally agreed with the report's conclusions and recommendations but
provided some additional information for our consideration. We incorporated
this information where appropriate.

Background Following the 1979 accident at the Three Mile Island nuclear
power plant in Pennsylvania, various investigative bodies recommended that
NRC

improve its technical training for its staff. Consequently, the Commission
approved the relocation of NRC's technical training to Chattanooga,
Tennessee, because that location was the only place in the United States
where NRC could train its staff on simulators for all of the nuclear power
plant designs. The Tennessee Valley Authority owned the simulators, and NRC
contracted with the Authority to use them. Subsequently, NRC purchased its
own simulators and no longer relies on the Authority for such training.
Therefore, the situation that was the primary cause of moving the Center to
Chattanooga has changed over the last 20 years.

Five Years of Debate and To respond to the National Performance Review's
recommendation that

Multiple Studies on NRC's federal agencies improve the effectiveness and
efficiency of their activities,

Technical Training Program in June 1995, NRC identified those functions that
could be done more

efficiently. One identified function was the training program. NRC's Office
of Administration initiated a study to determine the feasibility of
relocating the Center to enhance the agency's efficiency. The Office of
Administration found that (1) NRC could not install the simulators in its
headquarters buildings because the agency needed 40 feet between the
buildings' support columns, while the headquarters buildings had only a 20-
foot separation between support columns and (2) relocating the Center would
not be cost- effective when considering the one- time moving costs of about

$5 million and the annual $75,000 increase in operating costs. On the basis
of the increased operating costs, NRC's Office of Administration concluded
that relocating all or part of the Center to its headquarters buildings was
not feasible or cost- effective.

In April 1998, NRC's senior managers again tasked a group of staff to
identify ways to improve the effectiveness and efficiency of NRC's training
function. In its September 1998 report, the group made a number of
recommendations, including that NRC consolidate its training resources in
the Washington, D. C., area and that it reduce the number of simulators from
four to two. The group subsequently noted that NRC should evaluate a number
of programmatic, financial, infrastructure, staffing, and timing issues to
help the Commission make an informed decision related to the two
recommendations. In October 1999, the group provided the Commission with the
additional information. In the interim, an NRC contractor estimated the
costs of relocating the Center and its staff to Rockville, Maryland, and the
maintenance and operating costs for both the Chattanooga and Rockville
locations. The contractor developed four different estimates related to
moving one to four simulators and assumed that NRC would move the Center
over a 2- year period- fiscal years 2001 to 2003. The contractor also
compared the operation and maintenance costs for both Chattanooga and
Rockville over 10 years- fiscal years 2001 to 2010. The contractor estimated
that it would cost NRC over $4. 2 million (in 2000 dollars) to relocate the
Center. 3

NRC based its decision to relocate the Center on the expected programmatic
benefits identified by senior management rather than on cost. On February
24, 2000, NRC decided to

pursue, with the General Services Administration, a location near NRC's
headquarters for the Center; develop a comprehensive, integrated training
plan that identifies the

skills needed to implement NRC's mission and link the skills to the
technical training offered; take advantage of key program office staff to
enrich the training offered;

and 3 Because the Commission decided to move all four simulators, we limited
our examination to that segment of the cost analysis. For the purpose of
this report, we refer to the contractor's estimate as NRC's estimate.

maintain a small staff in Chattanooga from fiscal year 2001 until April 2003
to provide reactor technology training and relocate the Center's remaining
staff to headquarters by the end of fiscal year 2001. NRC did not specify
the number of staff who would remain in Chattanooga until April 2003.

Structure of NRC's NRC's Office of Human Resources manages the professional
development

Technical Training Program training (supervisory, management, and executive
development; sexual

harassment prevention; computer technology; and equal employment
opportunity) as well as the technical training offered by the Center.
Technical training has two components: reactor technology training and
specialized training and support. The 16 reactor technology training staff
include 12 instructors who primarily develop and conduct classroom and
simulator training, 3 engineers who maintain and update the simulator
software, and 1 supervisor. Of the additional nine staff in the specialized
training and support component, six develop and conduct training and manage
a wide range of contract courses, two provide administrative support for all
of the Center's technical training programs, and one supervises staff.
Specialized training includes courses related to maintenance, accident
investigation and root cause analysis, emergency diesel generators, and
motor- operated valves at nuclear power plants. This training also includes
nonreactor courses related to radiation protection, the industries that
produce fuel for nuclear power plants, and the transportation of nuclear
materials.

NRC Used a NRC used a reasonable methodology to estimate the costs of
relocating the

Reasonable Center from Chattanooga to Rockville. For example, NRC
appropriately

considered such cost elements as the differences in travel costs for
Methodology to

participants, salaries and benefits of the Center's staff, and lease
payments Estimate Relocation

at the two locations. However, NRC made a number of assumptions in its Costs
but Made Several

estimate, including assumptions about the site that could be used for the
Center, the staff to provide the training, and the timing of the move. Taken

Assumptions That together, these uncertainties suggest that without
identifying such factors

Could Affect the as an actual site in Rockville or the number of staff who
would relocate, the

final cost to relocate, operate, and maintain a Center in Rockville cannot
be Estimated Cost

precisely determined. Finally, recalculating the costs to improve the
precision of the estimate may be academic because NRC's objective was not to
minimize the cost of operating the Center but rather to improve the
effectiveness and efficiency of the agency's operations.

NRC Used a Reasonable NRC's methodology is reasonable because the agency
incorporated the

Methodology appropriate cost elements in its comparison. For example, NRC
estimated

the one- time, nonrecurring costs of moving and establishing the Center in
Rockville and estimated that it would incur these costs in fiscal year 2000.
NRC also compared the estimated costs of maintaining and operating the
Center in Chattanooga and Rockville during fiscal years 2001 through 2010.
Specifically, NRC compared all cost elements for functions performed at or
related to the Center, including differences in the travel costs for
participants, salaries and fringe benefits of new and existing Center staff,
and lease payments and other operating and maintenance expenses at the two
locations. NRC discounted the 10- year operating and maintenance costs and
presented this value and the one- time moving and relocation costs in 2000
dollars. 4 In addition, to the extent possible, NRC used available sources
of information and made a number of reasonable assumptions in conducting the
cost estimate. We used generally acceptable economic principles to evaluate
NRC's cost estimation methodology and the reasonableness of key economic
assumptions used in the estimate. Since the expected benefits cannot be
easily quantified, NRC could not develop a standard cost/ benefit analysis
for relocating the Center. In addition, neither the Office of Management and
Budget nor the General Services Administration requires agencies to prepare
a cost/ benefit analysis when relocating facilities.

Several Uncertain Some of NRC's assumptions are uncertain and, if changed,
would affect the

Assumptions Could Affect estimated cost of relocating the Center to
Rockville. These assumptions

the Estimated Costs to include the site that could be used for the Center,
the staff who would

Relocate the Center provide the training, and the timing of the move.

NRC Does Not Have a Site for a NRC had not identified a site for the Center
when it prepared the cost

Rockville Center estimate. Rather, it used a site that was available at the
time. Since NRC

was not considering relocating the Center to that site, any cost comparison
between Chattanooga and Rockville is questionable. All of the estimated
costs could change once NRC selects the actual site for the Center. For
example, such estimated costs as the construction needed to meet NRC's
specifications, leasing cost per square foot, and shuttle service for

4 Per the Office of Management and Budget's guidelines, NRC used a nominal
rate of 10 percent to discount the total costs. In fiscal year 2000, the
Office recommended that agencies use a nominal rate of 6. 1 percent to
discount the nominal flow of funds.

transporting staff to and from NRC's headquarters could be different,
depending on the final location and conditions of the site selected.

Number of Staff Who Will Another key factor in the cost estimate relates to
the number of Center

Provide the Training Could Differ staff who would relocate or retire as well
as NRC's need to hire

Significantly replacement staff for those who retire or do not relocate. In
its cost

estimate, NRC assumed that 8 staff would retire in fiscal year 2001, 18
would relocate in that year, and 8 new staff would be hired by fiscal year
2000 to replace those who would retire. NRC's assumptions about relocations
differ significantly from what 25 Center staff told us. 5

First, as shown in table 1, 16 staff told us that they do not plan to
relocate, 4 told us that they plan to relocate, and 5 are undecided and
would relocate only if they cannot find other employment in Chattanooga.

Table 1: Relocation Plans of the Center's Staff Plan to relocate Category of
jobs No Yes Undecided Total

Instructors Reactor technology training 10 0 2 12 Specialized technical
training 3 2 1 6

Subtotal 13 2 3 18 Technical, Management, and Support

Simulator engineers 0 1 2 3 Managers 1 1 0 2 Support staff 2 0 0 2

Subtotal 3 2 2 7 Total 16 4 5 25

Source: GAO's analysis of information obtained at interviews with NRC
Center's staff during the week of May 1, 2000.

Second, NRC did not consider the natural attrition of instructors that would
occur over the 10 years included in the cost estimate. Third, NRC

5 Since NRC completed its cost estimate, one instructor has taken a job in
one of its regional offices. Therefore, the number of staff at the Center as
of September 24, 2000, was 25.

assumed that the federal grade level of staff hired to replace those who
would not relocate would be virtually the same (same grade but at the first
step). Fourth, NRC did not consider whether fewer than 18 instructors could
provide the training needed or whether some of the skills and experience
exist among the agency's headquarters and regional office staff. Ultimately,
changes in the assumptions about the number of staff who will relocate or
retire as well as the salary they would be paid would affect not only the
one- time relocation cost estimate but also the estimates of annual savings
in salaries and fringe benefits associated with filling the retiree slots
with less- senior staff.

A Different Relocation Date The estimated date to relocate the Center also
affects the final cost.

Would Yield a Different Delaying the relocation until the lease expires in
August 2005 could

Estimated Cost potentially reduce the total cost to the government. For
example, if NRC

moves the Center by April 2003 as the Commission directed, the General
Services Administration could, according to an NRC document, incur rent
expenses of up to $2 million if the Administration is unable to lease the
space between that date and August 2005. Moving the Center in 2005 could
eliminate this expense.

Expected Benefits of NRC has said that moving the Center to Rockville will
result in a number of

Relocating the Center benefits for its technical training program and for
improving the

effectiveness and efficiency of the agency. These perceived benefits include
to Rockville or Keeping

increased attendance at training courses by headquarters staff and the It in
Chattanooga Seem

increased use of simulators and instructors for the review and investigation
Reasonable, but NRC

of technical issues. Appendix I lists these and other expected benefits
outlined in NRC's decisionmaking documents for relocating the Center to

Has Not Analyzed the Rockville as well as the views of the Center's staff
and the current views of

Benefits NRC's Commissioners and senior managers. Although NRC could realize

some of the benefits, it has no analysis supporting the extent that it
could. NRC also has not analyzed the expected benefits of keeping the Center
in Chattanooga. When NRC located the Center in Chattanooga, two of the
expected benefits were that the remote location would provide a more
conducive training environment and that the relatively low cost of living in
Chattanooga would facilitate the recruitment and retention of qualified
instructors. Although the Center's staff believe that Chattanooga continues
to provide these benefits, some NRC senior managers view the remote location
and the time required to travel there as disincentives for headquarters
staff to attend training.

NRC Believes That More NRC contends that an increasing number of
headquarters staff would

Headquarters Staff May participate in technical training if the Center moves
to Rockville. However,

Take Training if the Center NRC may not fully realize this benefit because
less than 25 percent of its

Moves to Rockville 2,800 staff are required to receive technical training.

NRC's Commissioners and senior managers provided a number of reasons for
believing that the number of staff willing to attend technical training
would increase if the Center were in Rockville. The reasons included the
following: (1) Access to technical training would be easier, and some travel
would be eliminated because headquarters staff would not have to travel to
Chattanooga- a remote location; (2) management could more easily substitute
staff when cancellations occur; and (3) training could be offered to staff
who do not normally attend technical training. They said that headquarters
staff attend training at the Center now when they are required or have a
specific need to do so. But, with the recent downsizing, NRC staff are now
stretched thin to effectively carry out their responsibilities; therefore,
it is unlikely that staff would attend training that is not required. In
addition, since some of the required reactor technology curriculum includes
5 weeks of classroom training and 2 weeks of simulator training, senior
managers said that headquarters staff are reluctant to be away from their
job for that amount of time.

Although NRC could expect that more headquarters staff would participate in
technical training in Rockville, NRC has no analysis supporting the extent
to which this would occur. For example, NRC's senior managers told us that
slightly less than 25 percent of the agency's 2, 800 staff are required to
receive technical training. In addition, the Office of Nuclear Reactor
Regulation estimates that only about 40 staff, in addition to an average of
314 staff who annually take technical training, would attend training at a
Center located in Rockville. This would likely be a one- time occurrence
because the 40 staff primarily assist the regulatory staff and are not
responsible for reviewing and approving licensees' actions. In addition,
from fiscal year 1995 through fiscal year 1999, the overall attendance at
technical training courses declined for NRC's headquarters and regional
staff. Total attendance reached a high of over 2,400 participants in fiscal
year 1996 and declined to about 1,300 in fiscal year 1999- a 37- percent
decrease. 6 The largest decrease in attendance occurred in the specialized
technical training courses that do no involve the simulators. Table 2 shows

6 During the 5 years in which the overall attendance decreased, NRC reduced
its staff by about 10 percent.

the breakdown of attendance by NRC's headquarters and regional office staff.
7

Table 2: Headquarters' and Regional Offices' Attendance at Technical
Training Courses, Fiscal Years 1995- 99

Fiscal year Type of training received by headquarters and regional office
staff 1995 1996 1997 1998 1999

Headquarters

Reactor technology training 201 170 138 165 181 Specialized technical
training 934 1,077 811 943 598

Subtotal 1,135 1, 247 949 1, 108 779 Regional offices

Rector technology training 277 333 320 375 351 Specialized technical
training 695 852 423 466 189

Subtotal 972 1, 185 743 841 540 Total 2, 107 2,432 1,692 1, 949 1, 319

Source: GAO's analysis of NRC's data. According to NRC's Chairman and other
Commissioners, if the Center were in Rockville, the agency would likely
restructure its technical training courses to focus on the needs of
headquarters staff. This refocus, the Chairman notes, would encourage more
headquarters staff to participate in technical training. Another
Commissioner told us that he does not support the way in which NRC
“compresses” its reactor technology training. The Commissioner
noted that the utilities had used a similar approach to train their
employees but found it to be ineffective. Rather, the Commissioner supports
a more university- type approach for reactor technology training, whereby
NRC staff would be trained more frequently over a longer period

7 Other federal agencies, such as the Federal Emergency Management Agency,
the Department of Energy, the Department of Veteran Affairs, the Department
of State, the Navy, the Air Force, as well as agreement state personnel and
international officials, also participate in NRC- sponsored training. In
fiscal year 1999, 257 agreement state officials, 22 other federal agency
officials, and 20 international officials participated in training. In
fiscal year 1998, 334 agreement state officials, 23 other federal agency
officials, and 30 international officials participated in training.

of time. According to the Commissioner, a university- type approach would
allow the staff time to think about and better understand the training they
receive.

Using Simulators to Most of NRC's Commissioners and many senior managers
believe that if the

Investigate Technical Issues Center were in Rockville, the agency would use
the simulators more

Will Be Limited frequently to investigate technical issues related to
commercial nuclear

power plants. However, the Center's staff and one Commissioner told us that
using the simulators in this manner would be limited because their design
impedes these types of analyses.

In its decisionmaking documents, NRC said that if it relocated the Center to
Rockville, the agency's Office of Nuclear Reactor Regulation could use the
simulators to model events at nuclear power plants, such as the rupture of
the steam generator tube at the Indian Point 2 plant in New York, and to
assist in the staff's review of license amendment applications submitted by
utilities for NRC's approval. The document also noted that the Office of
Nuclear Regulatory Research could use the simulators for research on such
technical issues as digital instrumentation and control, accident scenarios,
and risk analysis. In another document, NRC's Office of Nuclear Material
Safety and Safeguards said that it would use the simulators to train those
staff who participate in emergency response activities.

NRC's use of the simulators for other regulatory activities has been
limited. For example, the Office of Nuclear Reactor Regulation asked the
Center to conduct accident scenario simulations and to evaluate the
effectiveness and acceptability of nuclear power plant operators' actions to
the changes in emergency procedures proposed by a utility group. In
addition, NRC's Office of Nuclear Regulatory Research has asked the Center
to evaluate control room staffing issues and to validate its human
performance model. Despite NRC's limited use in the past, NRC senior
managers believe that simulator usage would increase if the Center were in
Rockville. They believe that because the Center is geographically remote,
headquarters staff do not routinely consider involving the Center. If the
Center were in Rockville, they believe that headquarters staff would be more
willing to interact with- and be physically present during the analysis
conducted by- the Center's staff.

On the other hand, the Center's staff believe that headquarters staff could
increase their use of the simulators without relocating the Center to
Rockville. They said that their past actions demonstrate that they are

willing to use the simulators to conduct analyses for headquarters staff.
They also noted that using the simulators to analyze events and other issues
would be limited because a different type of simulator would be needed to
analyze real- time events. One NRC Commissioner with extensive background
and experience in the nuclear industry agrees with the Center's staff about
the limitations of the training simulators.

We found that the simulators seem to be underutilized, as shown in the
following example. The 12 reactor technology instructors spent an average of
14 weeks in fiscal year 1999 providing classroom and simulator training.
According to the instructors, they also plan and develop courses, which
includes using the simulators for an average of 9 weeks. Although NRC
periodically updates the software used in the simulators, the equipment is
idle a good portion of the year.

Expected Benefits of When NRC moved the Center from Bethesda, Maryland, to
Chattanooga in

Keeping the Center in 1980, two of the expected benefits were that the
remote location would

Chattanooga provide a more conducive training environment and that the
relatively low

cost of living would facilitate the recruitment and retention of qualified
instructors. According to NRC's decisionmaking documents, senior managers,
and the Center's staff, the most obvious benefit for the Center to remain in
Chattanooga is the reduction of distractions to students from normal office
duties and home responsibilities. The remote location allows full
concentration on the training curriculum and study outside of class, which
is essential for the intensive reactor technology courses.

NRC's Commissioners and senior managers have stated that appropriate steps
can be taken to help avoid staff disruptions, maintain the effectiveness of
technical training, and preserve the quality of the learning environment if
the Center were in Rockville. In voting on the proposal to relocate the
Center, two of the five Commissioners discussed the managerial challenges
associated with having the Center in Rockville. These challenges included
the need to minimize class interruptions as well as competing work and
family interests. Both Commissioners agreed that management oversight is
required to minimize distractions and that NRC will need to implement strong
administrative and managerial controls to help minimize the organizational
situations that could interfere with staff's participation in training. As
discussed in the next section, NRC has not assessed the potential to recruit
staff for a Center located in Rockville.

NRC Needs to Resolve Regardless of where the Center is located, NRC needs to
resolve other

Other Issues to Ensure issues that affect the long- term efficacy of its
technical training program.

For example, NRC did not consider whether the agency needs 18 technical the
Long- Term Efficacy

training instructors and did not consider where it would recruit staff with
of Its Technical

the skills needed to replace the instructors who would not relocate.
Training Program

However, NRC has not developed a plan to ensure that the agency has the
appropriate number of instructors or the skills and expertise needed for the
staff who will eventually succeed those at the Center. While a serious
shortfall of instructors could become more acute if NRC relocates the Center
before 2005, the agency is not planning now to meet its future staffing
needs. Timely succession planning will ensure the continued quality of NRC's
technical training program and can be carried out without regard to
relocating the Center.

NRC's Need for 18 Technical Over the last several years, NRC has offered the
intensive 7- week reactor

Training Instructors Is technology training course only once a year. In the
past, NRC offered the

Questionable course much more frequently to help reduce the backlog caused
by

inspectors who had not received such training. NRC has since eliminated the
backlog, and the maturity of the industry and reductions in the number of
NRC staff have lessened the demand for the 7- week course. Instead, NRC has
focused on the annual refresher training that inspectors are required to
take. Although the demand for the intensive reactor technology training
course has declined, NRC has not determined whether it has the appropriate
number of instructors and whether the skill mix is appropriate to meet the
agency's needs. For example, NRC has qualified all 12 reactor technology
instructors in at least two different nuclear power plant technologies.
Table 3 shows the technologies for which the 12 instructors are qualified.

Table 3: NRC's Reactor Technology Instructors and the Technologies for Which
They Are Qualified

Type of Technology Combustion

Babcock and Instructor Westinghouse General Electric a Engineering Wilcox

A X B X X C X X X D X X E X F X X G X X H X I X J X X K X L X X

Total 7 5 4 4

a General Electric has several versions of the boiling water reactor design.
The instructors qualified to teach this technology are qualified in more
than one of the designs. Source: GAO's analysis of NRC's data.

As can be seen in table 3, 7 of the 12 reactor technology instructors have
been qualified to teach the Westinghouse design, and 4 instructors have been
qualified in the Combustion Engineering and the Babcock and Wilcox designs.
In addition, two specialized training instructors are qualified reactor
technology instructors: one in the General Electric designs and one in the
Westinghouse design. In essence, NRC has 14 staff qualified to teach the
reactor technology courses. Of the 103 commercial nuclear power plants that
operate in the United States, 48 use the Westinghouse design, 34 use the
General Electric design, 14 use the Combustion Engineering design, and 7 use
the Babcock and Wilcox design.

In addition, the demand for training on the various simulators varies. Table
4 shows the number of NRC staff who were trained on each of the four
simulators from fiscal year 1996 through fiscal year 1999. As shown in table
4, the highest demand is for training on the Westinghouse and General
Electric simulators; the least demand is for the Babcock and Wilcox and

Combustion Engineering simulators because fewer operating plants use these
two designs.

Table 4: Number of NRC Staff Trained on Simulators, Fiscal Years 1996- 99
Number of NRC staff Fiscal year

Fiscal year Fiscal year

Fiscal year Type of simulator 1996 1997 1998 1999

Westinghouse 101 123 118 129 General Electric 74 61 82 101 Combustion
Engineering 30 25 31 22 Babcock and Wilcox 16 11 10 21

Total 221 220 241 273

Source: GAO's analysis of NRC's data.

Like reactor technology instructors, the specialized technical training
instructors spend only a limited amount of time in the classroom. In fiscal
year 1999, for example, these instructors spent an average of 3 weeks
teaching and most of the remaining time overseeing the contractors that
provide training for NRC. From fiscal year 1995 through fiscal year 1999,
NRC reduced the number of specialized training courses offered from 49 to 36
but offered some courses more than once a year. In addition, in fiscal years
1998 and 1999, only about 12 percent of the specialized technical training
courses were held at the Center. The remaining courses were held either in
headquarters, regional offices, or locations that have specific equipment
and facilities, such as hospitals, which are integral for courses in the
nuclear materials area or are convenient for agreement state officials.

Taken together, the amount of time spent in the classroom, the decreasing
number of courses offered, and the number of instructors qualified to teach
both the reactor and specialized training courses would suggest that NRC
reassess its need for 18 technical training instructors. According to senior
managers, NRC recognizes the need to continually assess the number of
instructors that it needs. However, they could not provide any documentation
showing the assessments conducted.

NRC's Chairman told us that keeping the same number of instructors at a
Center in Rockville assumes that the technical training would be the same as
that offered in Chattanooga. The Chairman noted that NRC anticipates that it
would integrate technical training more into the agency and change,

refocus, and revitalize the curriculum to make it more attractive to
headquarters staff if the Center were in Rockville. In addition, one
Commissioner told us that with the change to digital instrumentation, the
possibility exists for NRC to develop desktop computer exercises that, over
time, would eliminate the need for the simulators.

NRC Has Not Developed a Regardless of where it locates its technical
training facility, NRC will face a

Succession Plan for Its significant challenge to replace its 18 instructors.
In 2003, 15 of the 18

Instructors instructors will be eligible to retire; and in 2005, 17 will be
eligible to retire.

However, NRC has not developed a plan to ensure that the agency has the
appropriate number of instructors or the skills and expertise needed for the
staff that will eventually succeed those at the Center.

Of its approximately 2, 800 staff, at least 1, 200 potentially have the
knowledge and experience to replace the Center's staff. For example, reactor
analysts, various types of engineers, and resident inspectors would have the
background and experience in the reactor technology area and for specialized
training related to emergency diesel generators, motor- operated valves, and
the fundamentals of regulation. Health specialists would have the background
and experience to perform the functions of the three specialized technical
training instructors who manage, oversee, and provide health physics
training, primarily for agreement state officials. In addition, the Office
of Nuclear Regulatory Research has staff experienced in developing and
analyzing risk assessments.

Both the headquarters staff and the Center's staff agree that background and
experience alone do not make an instructor effective. NRC would have to
ensure that the staff selected have the necessary “people”
skills to ensure that the training provided is effective. In addition, since
the specialized training staff serve as project managers who oversee
contractor- provided training and ensure that the training meets NRC's
requirements, the six Center staff who perform these functions generally
believe that the replacement staff must have this expertise also.

To determine the type of technical training needed and the appropriate
number of instructors, NRC needs to identify the skills required to
implement its mission and to ensure that its technical training program is
linked to the skills identified. NRC does not have this information and has
not linked the skills required to the technical training offered. In 1997
and 1998, the Office of Nuclear Reactor Regulation reviewed the knowledge,
skills, and abilities that headquarters and regional office staff needed to

effectively perform their jobs and the training needed for them to do so.
Although this review identified a need for additional training in regulatory
processes, procedures, and skills, NRC did not conduct a similar review for
its other major program offices.

In its performance plan for fiscal year 2000, NRC identified the need to
maintain core competencies (knowledge, skills, and abilities) and staff as a
factor that could affect the achievement of its performance goals. NRC noted
that maintaining the correct balance of knowledge, skills, and abilities is
critical to accomplishing its mission and is affected by various factors.
These factors include the labor market for experienced professionals, the
workload as projected by the nuclear industry, and the declining university
enrollment in nuclear engineering studies and other fields related to
nuclear safety. In February 2000, the Commission directed the staff to
develop a comprehensive plan that links the abilities needed to carry out
NRC's mission with the training offered and have the plan available for its
review in September 2000. According to NRC's senior managers, the lack of a
computer system that is tied to NRC's personnel system has hampered the
staff's efforts to conduct the skills assessment. NRC wants to collect the
data for all of its staff and have a mechanism to automatically update the
data as warranted. The senior managers noted that without a link to NRC's
personnel system, the usefulness of the skills assessment data will be
limited. They estimated that NRC could initiate the skills assessment
sometime in fiscal year 2001.

Conclusions Until it has a firm location for a Rockville Center and can
better identify the number of staff who would relocate, NRC cannot precisely
estimate the

cost of relocating the Center. However, recalculating the costs to improve
the precision of the estimate may be academic because NRC's objective was
not to minimize the cost of operating the Center but rather to improve the
effectiveness and efficiency of the agency's operations.

NRC has not addressed a number of issues that will affect its technical
training program over the next several years. Given the number of staff who
told us that they would not relocate and given the number of instructors who
are eligible to retire over the next 3 to 5 years, NRC will face major
challenges in providing effective technical training for its staff,
regardless of where it locates the Center. However, NRC has not identified
the skills required for the staff who will replace the instructors and has
not developed a succession plan to identify, hire, and train replacement
staff.

Recommendations To ensure that NRC continues to provide effective technical
training, we recommend that the Commissioners direct NRC staff to

identify the skills required for the staff who will replace its technical
training instructors and develop a succession plan to ensure that qualified
staff are available and

trained to minimize the disruption of the technical training provided.
Agency Comments We provided NRC a draft of this report for its review and
comment. NRC

generally agreed with the report's conclusions and recommendations but
provided additional information for our consideration. We incorporated this
information where appropriate. NRC's comments are in appendix II.

We conducted our work from April through September 2000 in accordance with
generally accepted government auditing standards. Appendix III provides
details on our scope and methodology.

Unless you publicly announce its contents earlier, we plan no further
distribution of this report until 30 days after the date of this letter. At
that time, we will send copies to the Honorable Richard A. Meserve,
Chairman, Nuclear Regulatory Commission; the Honorable Nils J. Diaz, the
Honorable Greta Joy Dicus, the Honorable Edward McGaffigan, Jr., and the
Honorable Jeffrey S. Merrifield, Commissioners, Nuclear Regulatory
Commission; and the Honorable Jacob J. Lew, Director, Office of Management
and Budget. We will make copies available to others on request.

If you or your staff have any questions about this report, please call me on
(202) 512- 8021. Other key contributors to this report are Mary Ann
Kruslicky, Mehrzad Nadji, Philip Olson, Carrie Stevens, and Derek Stewart.

Sincerely yours, Jim Wells Director, Natural Resources

and Environment

Appendi xes NRC's Views on the Potential Benefits of

Appendi xI

Relocating the Technical Training Center Table 5 reflects the information
that we obtained through meetings with all 26 of the Technical Training
Center's staff as well as the views of senior managers in the Nuclear
Regulatory Commission's (NRC) Offices of Nuclear Reactor Regulation, Nuclear
Material Safety and Safeguards, Nuclear Regulatory Research, and Human
Resources on the expected benefits from relocating the Center outlined by
NRC in its decisionmaking documents. Where applicable, table 5 also includes
the views expressed by NRC's five Commissioners.

Table 5: Center's Staff, NRC's Senior Managers, and NRC's Commissioners
views on the Potential Benefits of Relocating the Center

Views of NRC's Commissioners and Potential benefits identified in

senior managers on the potential decisionmaking documents The Center's views
on the potential benefits

benefits

Use the simulators for review and NRC could do this now, and the program
offices

All five of NRC's Commissioners discussed investigation of such technical
issues

could receive the results via E- mail or fax. NRC this potential benefit.
One noted that it was

as event analysis and licensing action does not need to have the simulators
in Rockville.

secondary to NRC's improving its reviews

However, NRC rarely uses the simulators for event effectiveness and
efficiency, and one noted

analysis or to assist with licensing action reviews. that the use of the
simulators for technical

Moreover, because the simulators relate to a issue reviews would be limited.

specific plant design, it is difficult to model events at other plants. In
addition, if NRC needs

At least once or twice a year, NRC's simulators to review and investigate
technical

headquarters has asked the Center to use issues, why did it recently
decommission rather

the simulators to analyze events. If a than move two simulators to
Rockville?

simulator has good fidelity, it can be useful in determining how long an
event will last and how many staff it will take to handle the situation.

Although NRC could use the Center in Chattanooga for such analysis, it would
be more effective to have headquarters staff directly participate in the
analyses conducted. For such participation to occur, the Center would have
to be located in Rockville.

(Continued From Previous Page)

Views of NRC's Commissioners and Potential benefits identified in

senior managers on the potential decisionmaking documents The Center's views
on the potential benefits

benefits

Would allow program offices to be NRC could do this now. The Center does not
need

NRC acknowledged that the former Training involved in course development to
be in Rockville for management, possibly in

Advisory Group could have been more conjunction with a visit to Region II in
Atlanta,

successful. However, having the Center in Georgia, to spend time at the
Center working on

Rockville would minimize the “out- of- sight, the content of courses.
However, program offices

out- of- mind attitude.” With the number of have not interacted with
the Center on needed

changes occurring within NRC, it is not long- term revisions to the nuclear
power plant

realistic to telephone or conduct a inspector courses to reflect the new
oversight

videoconference to discuss policy issues. process. In addition, NRC program
offices have provided relatively few suggestions on the content

Program office staff have participated in of courses- reactor technology
training has

course development. However, with the generally been the same for the past
20 years.

Center located in Rockville, the involvement would increase.

Would allow for rotation of staff NRC can do this now. With sufficient
notice, the

The Center's staff can rotate through between program offices and the

Center's staff could plan their time to allow for a 3- program offices and
make valuable

Center to 6- month rotation. Some of the Center's staff

contributions when they have been involved participated on the various task
forces in

on task forces and other agency activities. If preparation for the pilot
project for the new

the Center were in Rockville, NRC could oversight process. One staff spent 6
months

better utilize the experience and expertise of working at the Office of
Incident Response

the Center's staff. Operations.

Staff would not be rotated in and out of If NRC rotated the Center's staff
to program

training positions in a way that would create offices, who would conduct the
training in the

instability in the training program. NRC interim? Would that staff need to
meet the

needs to invest in the future by getting other instructor qualification
requirements?

staff qualified as instructors. Contracting process may be more

NRC staff need to have both the knowledge about Headquarters' technical
staff could perform

efficient by having the Center's project and the practical experience
related to the courses

the functions performed by the Center's managers in close proximity to

to effectively oversee the contractor to ensure that staff. If the Center
were in Rockville, NRC

headquarters' contract staff the quality of training meets NRC's
requirements.

would probably need fewer specialized technical training instructors, and
the remaining staff could possibly manage and oversee a larger number of
contractors.

Enhance NRC's ability to address new NRC can do this now. Both headquarters
and the

Two of NRC's Commissioners noted that or changing agency priorities and the

Center have videoconferencing, and having the Center in Rockville would not

current and future direction of the arrangements can be made for senior

only provide senior managers an agency

management to address all classes. However, the opportunity to address new
or changing

program offices have not until recently elected to agency priorities but
also to conduct

do so. The Center would need to be flexible if portions of the training
curriculum.

senior managers had to reschedule the time for the presentations. In June
2000, the Center invited

NRC's senior managers acknowledged that the Office of Nuclear Material
Safety and

they could better utilize videoconferencing to Safeguards to address a
training class. The Office

discuss new or changing agency priorities. did so and expects to do so again
in September

However, videoconferencing does not 2000.

provide the students with the same experience as that provided in a face-
to- face discussion.

(Continued From Previous Page)

Views of NRC's Commissioners and Potential benefits identified in

senior managers on the potential decisionmaking documents The Center's views
on the potential benefits

benefits

Increase opportunities for regional A large percentage of technical training
is

One of NRC's Commissioners strongly office staff to network with

provided at contractor sites or at NRC's regional believes that regional
office staff would

headquarters staff offices. If it is important for regional staff to

benefit greatly from networking with their network, NRC could require that
they spend a few

headquarters counterparts. days or a week each year working and interacting
with headquarters staff.

Some regional office staff have never been to headquarters. Therefore,
having the Center in Rockville would provide more opportunities for regional
office staff to interact with the headquarters staff with whom they work.

(Continued From Previous Page)

Views of NRC's Commissioners and Potential benefits identified in

senior managers on the potential decisionmaking documents The Center's views
on the potential benefits

benefits

Increase the number of headquarters NRC has no requirement that all of its
professional

All five NRC Commissioners believe that staff who would receive technical

staff acquire some minimum level of training each training of headquarters
staff will increase

training year. However, NRC has specified training for

because the agency expects to restructure nuclear plant, fuel cycle, and
materials inspectors.

the technical training program with courses If NRC does not require staff to
take training, they

that would be more focused on will not do so. On the other hand, if NRC does
not

headquarters staff, thereby encouraging require training, managers would be
reluctant to

them to participate in training. One approve staff to take technical
training.

Commissioner told us that program and project managers as well as other
staff in The Center provides some training in

the Office of Nuclear Reactor Regulation headquarters. NRC could increase
the number of

and the regional offices that regulate courses held at headquarters.

commercial nuclear power plants should be provided with simulator training
to have a If it is important for headquarters staff to receive

certain amount of knowledge and technical training, why would NRC wait until
the

understanding about the scope of activities Center is in Rockville to
provide the needed

on the reactor operator console and the training?

culpabilities of the plants. Such knowledge and understanding, the
Commissioner noted, would allow NRC staff to better determine the impact of
a regulation or license amendment, thereby enhancing NRC's effectiveness and
efficiency. Some staff are reluctant to travel to Chattanooga to attend
training. However, NRC will continue to send to training those staff who are
required by NRC's policies or whose job performance, in management's
opinion, could be improved through such training.

In February 2000, the Commission directed the staff to develop a
comprehensive training plan that links the abilities needed to carry out
NRC's mission with the training offered. NRC staff had expected to provide
the Commissioners with the plan by the end of September 2000. Although NRC
has task groups assessing whether a need exists to revise the agency's
technical training requirements, it stopped conducting a number of other
activities, such as the development of the comprehensive training plan, when
it learned that we had been asked to assess the Commission's decision to
relocate the Center.

(Continued From Previous Page)

Views of NRC's Commissioners and Potential benefits identified in

senior managers on the potential decisionmaking documents The Center's views
on the potential benefits

benefits

Reduce travel time and costs for Travel costs would increase for regional
office,

Although travel costs would be higher for headquarters staff agreement
states, and others if NRC relocates the

Region II (Atlanta, Ga.) staff who can now Center to Rockville.

drive to training, it would be lower for Region I (King of Prussia, Pa.)
staff. Overall, travel costs may increase if the Center moves to Rockville,
but access to three airports would make it more convenient for staff to get
to and return from training.

Facilitate the last- minute substitution Many headquarters staff cancel
their planned

NRC's headquarters does not track this of students training. Although the
Center did not have reliable

information. information on the extent to which headquarters and regional
office staff cancel and/ or substitute students for scheduled training, the
data available showed that the Office of Nuclear Reactor Regulation and
Region III (Lisle, Ill.) had the highest number of cancellations for
training in fiscal year 1999. The Office of Nuclear Materials Safety and
Safeguards and Region II (Atlanta, Ga.) had the second highest number of
cancellations.

Would facilitate NRC's using the NRC can do this now. A number of examples
exist

NRC's senior managers acknowledge that knowledge and expertise of the

where the Center's staff participated in various the agency can do this now
and has used

Center's instructors initiatives, such as developing the new training

the Center's staff expertise in the past. In course for the pilot project
for the new oversight

addition, headquarters staff can also contact process and its implementation
industrywide.

the Center's staff by telephone to share knowledge and expertise. However,
these interactions would be more beneficial if conducted on a face- to- face
basis with the Center in Rockville. In addition, if the Center were in
Rockville, the instructors would be more knowledgeable about policy issues
and be able to include such issues in their curriculum on a real- time
basis.

Comments From the Nuclear Regulatory

Appendi xII Commission

Appendi xI II

Scope and Methodology To assess whether NRC used a reasonable approach to
estimate the costs to relocate and operate the Center, we reviewed cost
analyses prepared by an independent consultant in July and September 1999
under contract to NRC. We used generally acceptable economic principles to
evaluate NRC's cost estimation methodology and the reasonableness of key
economic assumptions used in the estimate. We also reviewed various Office
of Management and Budget guidelines related to the preparation of cost
analyses for or by federal agencies. We reviewed the assumptions for
estimating the cost elements and discussed them with managers and staff in
NRC's Offices of Administration, the Chief Financial Officer, and Human
Resources. In addition, we met with all 26 of the Center's staff to
determine whether the assumptions used in the cost analyses regarding those
staff who would relocate accurately reflected their plans to do so. However,
we did not verify such information as the costs incurred by NRC staff to
travel and participate in training, the salaries and benefits of existing
staff or staff who would be hired to replace them, lease payments for the
two locations, or the costs to move the simulators.

To assess whether NRC's expected benefits to relocate the Center are
reasonable and supported and to determine the benefits of keeping the Center
in Chattanooga, we reviewed NRC's decisionmaking documents, analyses that
supported these documents, and memorandums provided by the Executive
Director for Operations to identify the expected benefits and the rationale
and support for them. We met with all 26 of the Center's staff to obtain
their views on the expected benefits. We also met with senior managers in
the Offices of Nuclear Reactor Regulation, Nuclear Material Safety and
Safeguards, Nuclear Regulatory Research, and Human Resources to obtain their
views on the expected benefits and the analyses conducted to support them.
We also met with the five NRC Commissioners to obtain their perceptions on
various relocation issues as well as the benefits expected from relocating
the Center. We obtained the views of the Nuclear Energy Institute and the
Vice President for Economic Development and the Existing Industry
Coordinator for the Chattanooga Chamber of Commerce on NRC's decision to
relocation the Center. In addition, we analyzed various data obtained from
NRC's Office of Human Resources and the Center's staff to assess the
reasonableness of expected benefits.

To provide information on other issues that could affect NRC's technical
training program, we reviewed NRC's decisionmaking documents, material
presented by the Center's staff to the Commission during a November 1999
meeting, and inspection manual chapters to determine the training required

for NRC's staff. We obtained and analyzed such data as the relocation plans,
workload, and retirement eligibility of the Center's staff. We also obtained
information showing the technical positions of all NRC staff to determine
those who could potentially replace the Center's staff who would not
relocate to Rockville. Finally, we analyzed the attendance of headquarters
and regional office staff at technical training courses during fiscal years
1995- 99; the percentage of technical training courses offered at the
Center, headquarters, regional offices, and other locations during fiscal
years 1998- 99; the technologies in which NRC's reactor technology
instructors are qualified to teach; and the number of NRC staff trained on
simulators during fiscal years 1996- 99.

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Appendix I

Appendix I NRC's Views on the Potential Benefits of Relocating the Technical
Training Center

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Appendix I NRC's Views on the Potential Benefits of Relocating the Technical
Training Center

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Appendix I NRC's Views on the Potential Benefits of Relocating the Technical
Training Center

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Appendix I NRC's Views on the Potential Benefits of Relocating the Technical
Training Center

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Appendix II

Appendix II Comments From the Nuclear Regulatory Commission

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Appendix III

Appendix III Scope and Methodology

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