GAO

United States General Accounting Office

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

Page 1 GAO-01-54 Technical Training Center

Contents

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
Page 2 GAO-01-54 Technical Training Center
Page 3 GAO-01-54 Technical Training Center

United States General Accounting Office

Washington, D.C. 20548 Letr

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.
Page 4 GAO-01-54 Technical Training Center

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
Page 5 GAO-01-54 Technical Training Center

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

Multiple Studies on NRC’s

Technical Training Program

To respond to the National Performance Review’s recommendation that

federal agencies improve the effectiveness and efficiency of their activities,

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
Page 6 GAO-01-54 Technical Training Center

$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.
Page 7 GAO-01-54 Technical Training Center

• 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

Technical Training Program

NRC’s Office of Human Resources manages the professional development

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

Reasonable

Methodology to

Estimate Relocation

Costs but Made Several

Assumptions That

Could Affect the

Estimated Cost

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 for

participants, salaries and benefits of the Center’s staff, and lease payments

at the two locations. However, NRC made a number of assumptions in its

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

together, these uncertainties suggest that without identifying such factors

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

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.
Page 8 GAO-01-54 Technical Training Center

NRC Used a Reasonable

Methodology

NRC’s methodology is reasonable because the agency incorporated the

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

Assumptions Could Affect

the Estimated Costs to

Relocate the Center

Some of NRC’s assumptions are uncertain and, if changed, would affect the

estimated cost of relocating the Center to Rockville. These assumptions

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

provide the training, and the timing of the move.

NRC Does Not Have a Site for a

Rockville Center

NRC had not identified a site for the Center when it prepared the cost

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.
Page 9 GAO-01-54 Technical Training Center

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

Provide the Training Could Differ

Significantly

Another key factor in the cost estimate relates to the number of Center

staff who would relocate or retire as well as NRC’s need to hire

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

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.

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
Page 10 GAO-01-54 Technical Training Center

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

Would Yield a Different

Estimated Cost

The estimated date to relocate the Center also affects the final cost.

Delaying the relocation until the lease expires in August 2005 could

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

Relocating the Center

to Rockville or Keeping

It in Chattanooga Seem

Reasonable, but NRC

Has Not Analyzed the

Benefits

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

effectiveness and efficiency of the agency. These perceived benefits include

increased attendance at training courses by headquarters staff and the

increased use of simulators and instructors for the review and investigation

of technical issues. Appendix I lists these and other expected benefits

outlined in NRC’s decisionmaking documents for relocating the Center to

Rockville as well as the views of the Center’s staff and the current views of

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.
Page 11 GAO-01-54 Technical Training Center

NRC Believes That More

Headquarters Staff May

Take Training if the Center

Moves to Rockville

NRC contends that an increasing number of headquarters staff would

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

NRC may not fully realize this benefit because less than 25 percent of its

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.
Page 12 GAO-01-54 Technical Training Center

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

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.

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
Page 13 GAO-01-54 Technical Training Center

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

Investigate Technical Issues

Will Be Limited

Most of NRC’s Commissioners and many senior managers believe that if the

Center were in Rockville, the agency would use the simulators more

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
Page 14 GAO-01-54 Technical Training Center

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

Keeping the Center in

Chattanooga

When NRC moved the Center from Bethesda, Maryland, 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. 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.
Page 15 GAO-01-54 Technical Training Center

NRC Needs to Resolve

Other Issues to Ensure

the Long-Term Efficacy

of Its Technical

Training Program

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

issues that affect the long-term efficacy of its technical training program.

For example, NRC did not consider whether the agency needs 18 technical

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

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

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

Training Instructors Is

Questionable

Over the last several years, NRC has offered the intensive 7-week reactor

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

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.
Page 16 GAO-01-54 Technical Training Center

Table 3: NRC’s Reactor Technology Instructors and the Technologies for Which They

Are Qualified

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

Type of Technology

Instructor Westinghouse General Electrica

Combustion

Engineering

Babcock and

Wilcox

A X

BX X

C X XX

DX X

E X

FX X

GX X

H X

I X

JX X

K X

LX X

Total 7 5 4 4
Page 17 GAO-01-54 Technical Training Center

Combustion Engineering simulators because fewer operating plants use

these two designs.

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

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,

Number of NRC staff

Type of simulator

Fiscal year

1996

Fiscal year

1997

Fiscal year

1998

Fiscal year

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
Page 18 GAO-01-54 Technical Training Center

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

Succession Plan for Its

Instructors

Regardless of where it locates its technical training facility, NRC will face a

significant challenge to replace its 18 instructors. In 2003, 15 of the 18

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
Page 19 GAO-01-54 Technical Training Center

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.
Page 20 GAO-01-54 Technical Training Center

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.
Page 21 GAO-01-54 Technical Training Center

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
Page 22 GAO-01-54 Technical Training Center

Appendix I

NRC’s Views on the Potential Benefits of Apendxies

Relocating the Technical Training Center ApendxiI

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

Potential benefits identified in

decisionmaking documents The Center’s views on the potential benefits

Views of NRC’s Commissioners and

senior managers on the potential

benefits

Use the simulators for review and

investigation of such technical issues

as event analysis and licensing action

reviews

NRC could do this now, and the program offices

could receive the results via E-mail or fax. NRC

does not need to have the simulators in Rockville.

However, NRC rarely uses the simulators for event

analysis or to assist with licensing action reviews.

Moreover, because the simulators relate to a

specific plant design, it is difficult to model events

at other plants. In addition, if NRC needs

simulators to review and investigate technical

issues, why did it recently decommission rather

than move two simulators to Rockville?

All five of NRC’s Commissioners discussed

this potential benefit. One noted that it was

secondary to NRC’s improving its

effectiveness and efficiency, and one noted

that the use of the simulators for technical

issue reviews would be limited.

At least once or twice a year, NRC’s

headquarters has asked the Center to use

the simulators to analyze events. If a

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.
Appendix I

NRC’s Views on the Potential Benefits of

Relocating the Technical Training Center

Page 23 GAO-01-54 Technical Training Center

Would allow program offices to be

involved in course development

NRC could do this now. The Center does not need

to be in Rockville for management, possibly in

conjunction with a visit to Region II in Atlanta,

Georgia, to spend time at the Center working on

the content of courses. However, program offices

have not interacted with the Center on needed

long-term revisions to the nuclear power plant

inspector courses to reflect the new oversight

process. In addition, NRC program offices have

provided relatively few suggestions on the content

of courses—reactor technology training has

generally been the same for the past 20 years.

NRC acknowledged that the former Training

Advisory Group could have been more

successful. However, having the Center in

Rockville would minimize the “out-of-sight,

out-of-mind attitude.” With the number of

changes occurring within NRC, it is not

realistic to telephone or conduct a

videoconference to discuss policy issues.

Program office staff have participated in

course development. However, with the

Center located in Rockville, the involvement

would increase.

Would allow for rotation of staff

between program offices and the

Center

NRC can do this now. With sufficient notice, the

Center’s staff could plan their time to allow for a 3-

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

participated on the various task forces in

preparation for the pilot project for the new

oversight process. One staff spent 6 months

working at the Office of Incident Response

Operations.

If NRC rotated the Center’s staff to program

offices, who would conduct the training in the

interim? Would that staff need to meet the

instructor qualification requirements?

The Center’s staff can rotate through

program offices and make valuable

contributions when they have been involved

on task forces and other agency activities. If

the Center were in Rockville, NRC could

better utilize the experience and expertise of

the Center’s staff.

Staff would not be rotated in and out of

training positions in a way that would create

instability in the training program. NRC

needs to invest in the future by getting other

staff qualified as instructors.

Contracting process may be more

efficient by having the Center’s project

managers in close proximity to

headquarters’ contract staff

NRC staff need to have both the knowledge about

and the practical experience related to the courses

to effectively oversee the contractor to ensure that

the quality of training meets NRC’s requirements.

Headquarters’ technical staff could perform

the functions performed by the Center’s

staff. If the Center were in Rockville, NRC

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

or changing agency priorities and the

current and future direction of the

agency

NRC can do this now. Both headquarters and the

Center have videoconferencing, and

arrangements can be made for senior

management to address all classes. However, the

program offices have not until recently elected to

do so. The Center would need to be flexible if

senior managers had to reschedule the time for

the presentations. In June 2000, the Center invited

the Office of Nuclear Material Safety and

Safeguards to address a training class. The Office

did so and expects to do so again in September

2000.

Two of NRC’s Commissioners noted that

having the Center in Rockville would not

only provide senior managers an

opportunity to address new or changing

agency priorities but also to conduct

portions of the training curriculum.

NRC’s senior managers acknowledged that

they could better utilize videoconferencing to

discuss new or changing agency priorities.

However, videoconferencing does not

provide the students with the same

experience as that provided in a face-to-face

discussion.

(Continued From Previous Page)

Potential benefits identified in

decisionmaking documents The Center’s views on the potential benefits

Views of NRC’s Commissioners and

senior managers on the potential

benefits
Appendix I

NRC’s Views on the Potential Benefits of

Relocating the Technical Training Center

Page 24 GAO-01-54 Technical Training Center

Increase opportunities for regional

office staff to network with

headquarters staff

A large percentage of technical training is

provided at contractor sites or at NRC’s regional

offices. If it is important for regional staff to

network, NRC could require that they spend a few

days or a week each year working and interacting

with headquarters staff.

One of NRC’s Commissioners strongly

believes that regional office staff would

benefit greatly from networking with their

headquarters counterparts.

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)

Potential benefits identified in

decisionmaking documents The Center’s views on the potential benefits

Views of NRC’s Commissioners and

senior managers on the potential

benefits
Appendix I

NRC’s Views on the Potential Benefits of

Relocating the Technical Training Center

Page 25 GAO-01-54 Technical Training Center

Increase the number of headquarters

staff who would receive technical

training

NRC has no requirement that all of its professional

staff acquire some minimum level of training each

year. However, NRC has specified training for

nuclear plant, fuel cycle, and materials inspectors.

If NRC does not require staff to take training, they

will not do so. On the other hand, if NRC does not

require training, managers would be reluctant to

approve staff to take technical training.

The Center provides some training in

headquarters. NRC could increase the number of

courses held at headquarters.

If it is important for headquarters staff to receive

technical training, why would NRC wait until the

Center is in Rockville to provide the needed

training?

All five NRC Commissioners believe that

training of headquarters staff will increase

because the agency expects to restructure

the technical training program with courses

that would be more focused on

headquarters staff, thereby encouraging

them to participate in training. One

Commissioner told us that program and

project managers as well as other staff in

the Office of Nuclear Reactor Regulation

and the regional offices that regulate

commercial nuclear power plants should be

provided with simulator training to have a

certain amount of knowledge and

understanding about the scope of activities

on the reactor operator console and the

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)

Potential benefits identified in

decisionmaking documents The Center’s views on the potential benefits

Views of NRC’s Commissioners and

senior managers on the potential

benefits
Appendix I

NRC’s Views on the Potential Benefits of

Relocating the Technical Training Center

Page 26 GAO-01-54 Technical Training Center

Reduce travel time and costs for

headquarters staff

Travel costs would increase for regional office,

agreement states, and others if NRC relocates the

Center to Rockville.

Although travel costs would be higher for

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

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

of students

Many headquarters staff cancel their planned

training. Although the Center did not have reliable

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.

NRC’s headquarters does not track this

information.

Would facilitate NRC’s using the

knowledge and expertise of the

Center’s instructors

NRC can do this now. A number of examples exist

where the Center’s staff participated in various

initiatives, such as developing the new training

course for the pilot project for the new oversight

process and its implementation industrywide.

NRC’s senior managers acknowledge that

the agency can do this now and has used

the Center’s staff expertise in the past. In

addition, headquarters staff can also contact

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.

(Continued From Previous Page)

Potential benefits identified in

decisionmaking documents The Center’s views on the potential benefits

Views of NRC’s Commissioners and

senior managers on the potential

benefits
Page 27 GAO-01-54 Technical Training Center

Appendix II

Comments From the Nuclear Regulatory

Commission ApendxiI
Appendix II

Comments From the Nuclear Regulatory

Commission

Page 28 GAO-01-54 Technical Training Center
Page 29 GAO-01-54 Technical Training Center

Appendix III

Scope and Methodology ApendxiI

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
Appendix III

Scope and Methodology

Page 30 GAO-01-54 Technical Training Center

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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