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GAO-02-868R: 

United States General Accounting Office: 
Washington, DC 20548: 

June 26, 2002: 

The Honorable Sonny Callahan: 
Chairman: 
The Honorable Peter J. Visclosky: 
Ranking Minority Member: 
Subcommittee on Energy and Water Development: 
Committee on Appropriations: 
House of Representatives: 

Subject: 

Department of Energy: Observations on Using External Agencies to 
Regulate Nuclear and Worker Safety in DOE’s Science Laboratories: 

Unlike other government and private industrial facilities in the 
United States, virtually all of the Department of Energy's (DOE) vast 
complex of research and nuclear facilities is not inspected or 
licensed by an independent external regulator, such as the Nuclear 
Regulatory Commission (NRC), to help ensure safe operations. Instead, 
DOE and its predecessors[Footnote 1] have, since 1946, been granted 
legislative authority to self-regulate nuclear and worker safety in 
the department’s facilities. We have long criticized DOE for 
weaknesses in its self-regulation of the environment, safety, and 
health (ES&H) at its own facilities. 

DOE recognized the need for external safety regulation in 1993, when 
Secretary Hazel O'Leary announced that the department would seek 
external regulation for worker safety. In 1994, legislation was 
proposed and hearings held on externally regulating nuclear safety at 
DOE facilities. Although no legislation was enacted, DOE responded by 
creating advisory groups to help formulate its policies and implement 
plans to eliminate self-regulation of nuclear and worker safety in all 
of its facilities. To achieve this goal, in 1996 DOE endorsed 
recommendations to phase out its self-regulation practices over a 10-
year period. In late 1997, however, DOE took a more cautious approach 
when Secretary Federico Peña embarked on a 2-year pilot program to 
simulate regulation by the Nuclear Regulatory Commission and the 
Occupational Safety and Health Administration (OSHA) at selected 
facilities.[Footnote 2] The objectives of these simulations included 
testing regulatory approaches and determining the cost of moving to 
external regulation. Despite NRC and OSHA conclusions from these 
pilots that externally regulating DOE’s science laboratories is 
achievable, Secretary Bill Richardson decided not to pursue external 
regulation, citing cost and other regulatory uncertainties. In this 
context, we reported in 1998 (and again in congressional testimonies 
in 1999 and 2000) that DOE did not have a clear strategy on external 
regulation. In a subsequent overview report on DOE, we recommended 
that eliminating self-regulation would, among other necessary actions, 
help improve the accountability of the department.[Footnote 3] 

In its October 2001 report on energy and water development 
appropriations for fiscal year 2002, the conference committee directed 
DOE to prepare an implementation plan for transitioning to external 
regulation at the department’s 10 science laboratories. For the 
purpose of preparing this plan, the conference report stated that the 
department should assume that NRC would take over regulatory 
responsibilities for nuclear safety and OSHA would take over 
regulatory responsibilities for worker safety at these facilities. The 
plan was to address all details necessary to implement external 
regulation, including: 

* estimates of additional resources NRC and OSHA would need, 

* estimates of corresponding reductions in funding and staffing at the 
department, 

* specific facilities or classes of facilities for which external 
regulation cannot be implemented in a timely manner, 

* necessary changes to existing management and operating contracts, 
and, 

* changes in statutory language necessary to effect the transition to 
external regulation.[Footnote 4] 

The implementation plan was due to the House and Senate Appropriations 
Committees by May 31, 2002. DOE has, however, not completed its plan 
by the date of this report. 

As part of an ongoing monitoring effort, you asked us to (1) identify 
current stakeholder positions on external regulation of DOE’s science 
facilities, (2) summarize the costs and benefits of using external 
agencies to regulate DOE nuclear and worker safety, and (3) determine 
how comparable domestic and European science facilities are regulated 
for nuclear and worker safety. We briefed your offices on the results 
of our review on June 3, 2002, using the enclosed charts. This report 
summarizes the results of that briefing. 

To address these objectives, we asked DOE, NRC, OSHA, and the major 
science laboratory contractors for their current position on external 
regulation. We obtained cost and benefit information from these 
officials and visited major DOE science laboratories. We also obtained 
pertinent information on domestic facilities similar to DOE, but 
externally regulated, and comparable facilities in Belgium, the United 
Kingdom, France, and Switzerland. 

We did not verify the costs and benefits reported by these sources, 
but we did review the reasonableness of their claims. We conducted our 
review from November 2001 through May 2002 in accordance with 
generally accepted government auditing standards. 

In summary: 

The positions of DOE and its potential regulators—NRC and OSHA—are 
essentially unchanged since the 1999 congressional hearing held on the 
results of simulated inspections at several DOE facilities.[Footnote 
5] DOE officials told us that (1) the department’s current position on 
external regulation is “neutral” because the Secretary has 
insufficient information on which to make a decision, (2) another 
study is needed to develop data on the costs and benefits of making 
the transition to and operating under external regulation, and (3) a 
realistic implementation plan cannot be developed until the study is 
completed, which DOE estimates will take 6 to 9 months. On the other 
hand, NRC and OSHA report that they are currently prepared to begin 
regulating the department’s 10 science laboratories, given adequate 
resources to do so. The two safety regulators are familiar with most 
of the facilities they would regulate and are already regulating parts 
of DOE where the Congress has given them specific authority. The 
laboratory contractors that we spoke with—representing most of DOE’s 
science work—were unanimous in their support for external regulation 
under certain conditions, primarily that DOE will reduce its current 
level of nuclear and worker safety oversight once NRC and OSHA assume 
these responsibilities. 

Data from past regulatory simulations, and ongoing work by DOE, NRC 
and OSHA, show that shifting to external regulation of science 
laboratories would not be prohibitively expensive. For example, NRC’s 
and OSHA’s estimates to regulate the 10 science laboratories are 
potentially less than DOE expenditures to regulate itself in terms of 
personnel costs. The cost of upgrading DOE facilities to regulator 
standards is less certain, but may not be significant for a variety of 
reasons: (1) NRC concluded from its simulations that few, if any, 
changes to DOE facilities are needed to meet NRC’s licensing 
requirements; (2) NRC stated that it would be flexible in applying its 
standards to DOE’s unique facilities without compromising safety; and 
(3) OSHA concluded from its simulations that DOE deficiencies are 
similar to levels found in the private-sector (DOE has adopted OSHA-
like standards). DOE needs to make several decisions that will affect 
costs, the most important of which is determining what the role of its 
field staff will be under external regulation. These and other 
decisions form the assumptions upon which an implementation plan must 
be based, but have not been made. 

The potential benefits of external regulation have been widely 
reported. A 1996 DOE task force concluded that externally regulating 
DOE facilities would improve safety, eliminate the inherent conflict 
of interest from self-regulation, achieve consistency with current 
domestic and international safety management practices, and gain 
credibility and public trust.[Footnote 6] Potential cost-saving 
benefits were also noted. For example, the task found that seven large 
contractors regulated by NRC and OSHA employed substantially fewer 
dedicated ES&H staffs than were found at DOE facilities. More 
recently, DOE's major science laboratory contractors told us that they 
could reduce their ES&H staff by up to 30 percent if DOE relinquished 
its oversight to external regulators. DOE’s largest science 
contractor, Battelle Memorial Institute,[Footnote 7] reported that it 
spends one-half to one-third less (as a percent of total costs) on 
ES&H in its externally regulated private sector laboratories.[Footnote 
8] DOE found similar results in a recent study comparing the 
management of its Lawrence Berkeley National Laboratory with two other 
federal agencies that use externally regulated contractors to manage 
their laboratories—the National Atmospheric and Space Administration’s 
(NASA) Jet Propulsion Laboratory and the National Science Foundation’s 
(NSF) National Center for Atmospheric Research.[Footnote 9] 
Contractors operating these laboratories had a smaller ratio of ES&H 
staff to total workers than exists in DOE’s Berkeley lab contractor. 
In addition, NASA and NSF were able to rely on far fewer staff to 
oversee ES&H responsibilities at their laboratories. For example, 
while there was only 1 ES&H person out of 23 NASA site office 
personnel at its Jet Propulsion Laboratory, there were 5 dedicated 
ES&H personnel out of 15 at DOE’s Berkeley site office.[Footnote 10] 
On average, we found that DOE dedicated about 30 percent of its site 
office staffs to ES&H oversight, not including technical staffs at the 
operations offices and several offices at headquarters. 

Experiences from foreign governments and their laboratories provide 
additional evidence that external regulation is feasible and 
beneficial. The United Kingdom, France, Switzerland, and Belgium all 
have science facilities operated by contractors on behalf of 
sponsoring government agencies. These governments have long traditions 
of using external regulators; essentially none of them self-regulate 
nuclear and worker safety. All told us that external regulation is 
valuable and necessary to ensure safety and public credibility. Two 
countries, the United Kingdom and France, also use external regulators 
to oversee parts of their nuclear defense research and development 
establishment. The United Kingdom, after transferring its two nuclear 
defense research facilities to private sector contractors, shifted 
much of the oversight of the facilities to external safety regulators 
within a 2-year period. United Kingdom officials told us that the 
shift to external regulation not only increased safety and improved 
public credibility but also provided greater freedom to voice worker 
safety concerns. 

Overall, growing evidence suggests that external regulators can 
potentially oversee DOE science laboratories more effectively and at 
less cost than DOE’s internal staff.We believe that their greater 
independence, coupled with use of national nuclear and worker 
standards and enforcement powers, will also make them more effective 
regulators. Ultimately, shifting to external regulation should allow 
DOE and its contractors to potentially re-direct ES&H resources to 
other mission priorities. We also believe that DOE has had ample time 
to develop an implementation plan to externally regulate its 10 
science laboratories. 

We met with DOE officials and provided them with a draft of our 
briefing charts for comment. The department offered several clarifying 
changes, which we have incorporated as appropriate. DOE officials told 
us that the Secretary needs more cost and other information before 
making a decision on external regulation and completing an 
implementation plan. 

As agreed with your offices, we will make copies of this report 
available to others upon request. This letter will also be available 
at no charge on GAO’s Web site at [hyperlink, http://www.gao.gov]. 

If you have any questions or need additional information, please 
contact me at (202)512-3464 or Gary Boss, Assistant Director, at (202) 
512-6964. Major contributors to this letter include Charles Egan, 
Thomas Laetz, and Michael Sagalow. 

Signed by: 

(Ms.) Gary Jones: 
Director, Natural Resources and Environment: 

Enclosure: 

[End of section] 

Enclosure: 

Briefing Presented on June 3, 2002: 

Observations on Using External Agencies to Regulate Nuclear and Worker 
Safety in DOE’s Science Laboratories: 

Prepared for the Subcommittee on Energy and Water Development, House 
Committee on Appropriations: 

June 3, 2002: 

GAO’s Objectives: 

* Identify current stakeholder positions on external regulation of 
DOE’s science facilities. 

* Summarize the costs and benefits of using external agencies to 
regulate DOE nuclear and worker safety. 

* Determine how comparable domestic and European science facilities 
are regulated for nuclear and worker safety. 

Scope and Methodology: 

For our review, we: 

* interviewed DOE, NRC and OSHA officials and examined past studies; 

* visited major DOE science laboratories (Lawrence Berkeley, Stanford, 
Argonne, and Oak Ridge); 

* obtained information on other domestic facilities; and; 

* visited comparable facilities in Belgium, the United Kingdom, France 
and Switzerland, and interviewed government agencies, contractors, and 
regulators. 

We did not verify the costs and benefits reported by federal agencies, 
contractors, or foreign officials we interviewed, but we did review 
the reasonableness of their claims. 

Background: 

DOE is the only federal agency whose facilities are essentially exempt 
from regulation by NRC for nuclear safety and OSHA for worker 
protection. 

History of DOE External Regulation Activities: 

1989: 
Significant workplace safety and health problems found in its 
facilities (Tiger Team reviews). 

1992: 
OSHA and DOE formalize relationship for technical assistance and 
consultation. 

1993: 
Energy Secretary announces intention to end DOE self-regulation of 
worker safety and health. 

1994: 
Legislation proposed requiring NRC licensing of all new DOE nuclear 
facilities. 

1995: 
DOE blue ribbon panel recommends, “essentially all aspects of safety 
at DOE nuclear facilities should be externally regulated.” 

1996: 
DOE sets a 10-year timetable for ending self regulation. 

1996: 
OSHA conducts simulated inspections at DOE’s Argonne Lab. 

1997: 
NRC and OSHA to conduct simulated inspections at several DOE 
facilities. 

1998: 
Appropriations conference report directs DOE to build new nondefense 
nuclear facilities (2000 and beyond) to NRC standards. 

1999: 
Energy Secretary decides to continue self-regulation, citing cost and 
regulatory uncertainties. 

2001: 
GAO recommends DOE end self-regulation to improve its accountability 

The 2001 Appropriations Conference Report directed DOE to prepare a 
plan to implement external regulation that: 

* includes only its 10 science laboratories (see appendix)-defense 
facilities are excluded, 

* addresses all details necessary to implement external regulation, 

* estimates additional resources NRC and OSHA need and corresponding 
reductions in DOE staff, and, 

* identifies contractual and legislative changes needed to effect the 
transition to external regulation. 

Plan was due May 31, 2002. 

Stakeholder Positions: 

DOE officials told us that their current position on external 
regulation is “neutral” because the Secretary has insufficient 
information with which to make a decision on external regulation; a 6 
to 9 month study is planned to develop the cost and other information 
he needs. 

DOE’s potential regulators--OSHA and NRC--support new 
responsibilities, assuming resources are available and new authority 
is granted. 

Contractor directors representing 6 of DOE’s 10 science laboratories 
(and nearly 90 percent of DOE’s 10-lab budget) told us they support 
external regulation if they hold the license and DOE substantially 
reduces its safety oversight(other directors were not contacted). 

NRC and OSHA interact with DOE in several areas specifically 
authorized by the Congress, thus giving DOE valuable experience 
operating under external regulators. 

NRC: 

* is participating in over 20 DOE sites and activities in which it 
licenses, certifies or consults. For example, NRC regulates the: 

- high-level waste repository (Yucca Mountain), 

- gaseous diffusion plants, 

- uranium mill tailings sites, 

- Independent Fuel Storage Facility at Fort St. Vrain, and, 

- West Valley Demonstration Project. 

* participated in DOE studies of external regulation at several 
laboratories. 

OSHA: 

* regulates non-Atomic Energy Act sites (e.g., power administrations, 
technology office, and petroleum reserves), 

* regulates the gaseous diffusion plants leased by DOE to a private 
sector company, and, 

* participated in early DOE studies of external regulation and was 
part of the late 1980s DOE inspection teams (Tiger Teams). NRC and 
OSHA, however, have no regulatory presence at the 10 science 
laboratories. 

Cost Issues: 

External regulatory costs cannot be reasonably ascertained until DOE 
benchmarks its facilities against regulatory standards, decides on 
license holder, and defines its roles and responsibilities. 

* Costs are dependent on the regulatory flexibility applied by NRC to 
DOE’s unique facilities. For example, NRC: 
- gives exemptions and waivers, as its did when it waived its seismic 
requirements at a DOE-licensed facility in Idaho, saving $7 million; 

- reports it will waive it decommissioning and decontamination (D&D) 
requirements for DOE facilities; 

- says that applying regulatory flexibility would not compromise 
safety. 

* NRC simulated inspections found few facility changes needed to meet 
its standards. 

OSHA simulated inspections identified a level of deficiencies only 
slightly above national averages. 

OSHA noted that the cost of correcting “legacy” hazards (i.e., 
facilities that were built to older standards) is substantial, and 
needs to be addressed independent of external regulation decisions. 

Continued substantial DOE oversight under external regulation would 
result in costly dual regulation. 

NRC estimates to regulate DOE’s 10 science laboratories: 

* Transition Period: 

- FY 2003: 42.1 FTEs, $6.8 million total costs; 

- FY 2004: 41.0 FTEs, $6.4 million total costs. 

* Steady State or Annual: 22.1 FTEs, $4.5 million total costs. 

* Six Labs: Ames, Berkeley, Fermi, Thomas Jefferson, Princeton Plasma 
and Stanford require only one license for each site: 

- Transition per year: 0.2 FTEs per site & $30 thousand travel; 

- Steady state per year: 0.2 FTEs per site & $20 thousand travel. 

* Oak Ridge (most complex): Requires three separate licenses: 

- Transition per year: 15 FTEs, $0.7 million in FY 2003 & $0.5 million 
in FY 2004); 

- Steady state per year: 5 FTEs annually, $0.1 million including a 
resident inspector. 

* Incremental cost to include accelerators: 7.3 FTEs in FY 2003 ($1.4 
million), 5.8 FTEs in FY 2004 ($1.0 million), and 1.5 FTEs steady 
state ($0.3 million). 

Key assumptions for NRC estimates: 

* All DOE facilities would be licensed in 2 years (ORNL a possible 
exception). 

* Management and operating contractor is the licensee. 

* NRC D&D requirements would be suspended. 

* Estimates are based on experience in similar facilities, and pilot 
results. 

* DOE facilities are generally in safe condition. 

OSHA estimates to regulate DOE’s 10 science laboratories (provided to 
DOE): 

* Transition costs: $445,000 to create a special office to inspect DOE 
sites. 

* Annual costs: $2.13 million and 19 FTEs. 

* Other costs: $6.35 million to develop revised standards for ionizing 
radiation, spread over 5 years. 

Key assumptions: 
 
* Estimates are based, in part, on its OSHA simulated inspection of 
Argonne in 1997. 

* OSHA would inspect DOE science laboratories in the same way it 
inspects any other facility. 

Benefits: 

DOE’s 1996 Working Group on External Regulation, which included DOE 
and other federal executives, said external regulation would: 
 
* improve safety, 

* eliminate the inherent conflict of interest from self-regulation, 

* become more consistent with current domestic and international 
safety management practices, and, 

* gain credibility and public trust. 

Stronger NRC and OSHA enforcement powers should lead to improved 
safety culture (1999 hearings): 

* NRC: “external oversight…provides an increased assurance of safety 
in the long run.” 

* OSHA: “it appears that there is room for improvement in safety and 
health at DOE sites.” 

Other Potential Savings Could Offset Some Costs: 

* Reduction/redirection of DOE staff. 

- DOE’s 2002 Best Practices study found that NASA and NSF required 
fewer resources than DOE to oversee their contractor-operated 
facilities. 

- About 30 percent of staff at the 4 major site offices we visited are 
dedicated to ES&H oversight (excluding significant staff in operations 
and headquarter offices). 

* Reduction/redirection of contractor staff. 

- Lab directors representing DOE’s five multi-program science labs 
told us they could reduce or redirect their ES&H staff by up to 30 
percent under external regulators (assuming DOE reduced its oversight). 

- Battelle, manager of 3 of these science labs, told us that it spends 
one half to one third less (as a percent of total costs) on ES&H at 
its externally regulated private-sector labs. 

- DOE’s 1996 report found that 7 large companies used from 47 to 92 
percent fewer ES&H staff per 1000 employees than DOE. 

Figure: Comparison of ES&H Staff across Three Government Laboratories: 

[Refer to PDF for image: vertical bar graph] 

FTEs per 1,000 employees: 

Berkeley Lab (DOE): 10.71; 
Jet Propulsion Lab (NASA): 7.69; 
National Center for Atmospheric Research (NSF): 2.13. 

Source: DOE Best Practices Pilot Study (February, 2002). 

[End of figure] 

Figure: Comparison of ES&H Staff Across DOE & Seven Private Sector 
Companies: 

[Refer to PDF for image: vertical bar graph] 

FTEs per 1,000 employees: 

DOE: 22; 
Monsanto: 11; 
Dow Chemical: 10; 
Mobil: 9; 
Dupont: 8; 
J&J: 5; 
FP&L: 2; 
CH2MHILL: 2. 

Source: DOE Working Group on External Regulation (December, 1996). 

[End of figure] 
Benefits 
Page 15 GAO–02-868R External Regulation of DOE 

Contractors told us they can be more efficient: 

[Refer to PDF for image: vertical bar graph] 

* external regulators are more consistent and predictable than DOE, 
making planning easier and improving efficiency; 

* reducing ES&H staff time could redirect scientists to mission work; 
and; 

* working to NRC and OSHA standards allows consistency with other 
research facilities, making DOE labs more competitive and user 
friendly. 

Other Experiences: 

Belgium, the United Kingdom, France, and Switzerland value the 
benefits of external regulation: 

* All research facilities have been licensed and inspected by 
independent regulators for some time--most are variations of 
government-owned and contractor-operated sites. 

* Public concerns for nuclear safety and radiation exposure have been 
forces behind recent legislative changes to establish even more layers 
of independence. 

Foreign government funding agencies and laboratory contractors cite 
several benefits of external regulation: 

* Increasing safety; 

* Improving credibility with the public; 

* Leveraging funds for infrastructure improvements; 

* Fostering more efficient organizations. 

The United Kingdom and France use external regulators to oversee 
safety in many defense facilities. 
 
* The United Kingdom has an independent external regulator for defense 
R&D facilities shared with the civilian side, but uses an internal 
regulator for warheads and naval nuclear propulsion. 

- These facilities made the transition from internal to external 
regulation in just 2 years. 

- Only minor facility upgrades were needed. 

* France has an independent external regulator for defense R&D 
facilities, parallel to the civilian side, but shares a common 
technical advisory agency. 

Observations: 

* External regulation would help improve public confidence and 
credibility in DOE, enhance the safety culture in its facilities, and 
provide DOE and its contractors with an opportunity to redirect their 
resources to important mission work. 

* Growing evidence shows that external agencies could potentially 
regulate DOE more effectively and at less cost than DOE’s internal 
staff. 

* Experiences from research facilities in comparable domestic and 
European laboratories provide additional evidence that external 
regulation is feasible and has many benefits. 

* DOE has had ample time to develop an implementation plan to 
externally regulate its10 science labs. NRC and OSHA, as DOE potential 
external regulators, have provided DOE with the cost and 
implementation data necessary for developing a plan. 

Appendix: DOE’s 10 Science Labs: 

Multi-program: 

1. Argonne National Laboratory-East, Argonne, IL (University of 
Chicago). 

2. Brookhaven National Laboratory, Upton, NY (Brookhaven Science 
Associates). 

3. Lawrence Berkeley National Laboratory, Berkeley, CA (University of 
California). 

4. Oak Ridge National Laboratory, Oak Ridge, TN (UT-Battelle, LLC). 

5. Pacific Northwest National Laboratory, Richland, WA (Battelle 
Memorial Institute). 

Single-purpose: 

1. Ames Laboratory, Ames, IA (Iowa State University). 

2. Fermi National Accelerator Laboratory, Batavia, IL (University 
Research Association). 

3. Princeton Plasma Physics Laboratory, Princeton, NJ (Princeton 
University). 

4. Stanford Linear Accelerator Center, Menlo Park, CA (Stanford 
University). 

5. Thomas Jefferson National Accelerator Facility, Newport News, VA 
(Southeastern Universities Research Association). 

[End of section] 

Footnotes: 

1. DOE’s predecessor agencies are the Atomic Energy Commission and 
Energy Research and Development Administration. 

2. These facilities include all or part of the Lawrence Berkeley 
National Laboratory in California, the Oak Ridge National Laboratory 
in Tennessee, and the Savannah River Site in South Carolina. OSHA 
participated in the California and Tennessee sites and had previously 
conducted a pilot program at DOE's Argonne National Laboratory in 
Illinois. 

3. U.S. General Accounting Office, Department of Energy: Fundamental 
Reassessment Needed to Address Major Mission, Structure, and 
Accountability Problems, [hyperlink, 
http://www.gao.gov/products/GAO-02-51], (Washington D.C. Dec. 21 2001). 

4. H.R. Rep. No. 107-258, Oct. 30, 2001, at 109-110. 

5. External Regulation of DOE Facilities: Pilot Project Results, 
Hearing before the Subcommittee on Energy and Environment of the 
Committee on Science, House of Representatives, Serial No. 106-29, 
July 22, 1999. 

6. Report of Department of Energy Working Group on External 
Regulation, DOE/US-0001, December 1996, p.1-1. 

7. Battelle Memorial Institute is DOE’s management and operating 
contractor for the Pacific Northwest National Laboratory, and manages 
Brookhaven National Laboratory (in partnership with the State 
University of New York at Stonybrook), and for the Oak Ridge National 
Laboratory (in partnership with the University of Tennessee). 

8. Battelle has also concluded that the aggregate hazards associated 
with the R&D activities at these institutions cannot account for these 
cost differences. 

9. DOE Best Practices Pilot Study, Berkeley Lab, LBNL/PUB-865, 
February 2002. 

10. We were not able to disaggregate department staff overseeing 
environmental issues from those involved in safety and health. 

[End of correspondence]