MANAGING 

CRITICAL ISOTOPES

DOE’s Isotope 

Program Needs Better 

Planning for Setting 

Prices and Managing 

Production Risks

Report to Congressional Requesters

May 2012

GAO-12-591

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-591, a report to 

congressional requesters 

May 2012

MANAGING CRITICAL ISOTOPES 

DOE’s Isotope Program Needs Better Planning for

Setting Prices and Managing Production Risks

Why GAO Did This Study

DOE is the only domestic supplier for 

many of the over 300 different isotopes 

it sells that are critical to medical, 

commercial, research, and national 

security applications. Previous 

shortages of some isotopes, such as 

helium-3, an isotope used to detect 

radiation at seaports and border 

crossings, highlight the importance of 

managing supplies of and demand for 

critical isotopes. Prior reports by GAO 

and others highlighted risks and 

challenges faced by the Isotope 

Program, such as assessing demand 

for certain isotopes. GAO was asked to 

determine (1) which isotopes are 

produced, sold, or distributed either by 

the Isotope Program or NNSA and how 

the two agencies make isotopes 

available for commercial and research 

applications; (2) what steps the Isotope 

Program takes to provide isotopes for 

commercial and research applications; 

and (3) the extent to which DOE is 

assessing and mitigating risks facing 

the Isotope Program. GAO reviewed 

DOE and NNSA documents, visited 

Oak Ridge National Laboratory, and 

interviewed cognizant agency officials. 

What GAO Recommends

GAO recommends, among other 

actions, that DOE’s Isotope Program 

define what factors it considers when 

setting isotope prices, create clear 

objectives as a basis for risk 

assessment, and consolidate the lists 

of high-priority isotopes. DOE stated 

that it will address GAO’s 

recommendations through the Isotope 

Program’s current efforts to update its 

pricing policy and develop a strategic 

plan. 

What GAO Found

The Department of Energy’s (DOE) Isotope Development and Production for 

Research and Applications program (Isotope Program) provides over 300 

different isotopes for commercial and research applications. The Isotope 

Program is responsible for 243 stable isotopes that are no longer produced in the 

United States but are sold from the program’s existing inventory and for 55 

radioactive isotopes, called radioisotopes, that the program is able to produce at 

DOE facilities. An additional 10 isotopes sold by the Isotope Program are 

provided by the National Nuclear Security Administration (NNSA), a separate 

agency within DOE, as by-products of its nuclear weapons program. 

The Isotope Program may be forgoing revenue that could further its mission 

because of the manner in which it sets prices for commercial isotopes. The 

Isotope Program determines demand, coordinates production, and sets prices for 

commercial isotopes. To set prices for radioisotopes, the program considers the 

full cost of production, including direct costs (e.g., labor costs) and indirect costs 

(e.g., infrastructure costs). For research applications, isotope prices are set to 

recover direct costs to reduce prices and encourage research. For commercial 

applications, prices are set at full cost recovery—of both direct and indirect 

costs—or at an isotope’s market price when a market price higher than full cost 

recovery already exists. The program, however, has not fully assessed the 

pricing of most of these isotopes, as required by its 1990 pricing policy. This 

policy provides latitude for setting prices and states that prices should be 

assessed annually. Factors that may be considered when establishing prices 

include the value of an isotope to the customer, demand, and the number of 

suppliers. The program, however, has not assessed the value of isotopes to 

customers or defined what factors it will consider when it sets prices for 

commercial isotopes, including defining under what circumstances it will set 

prices at or above full cost recovery. As a result, the program does not know if its 

full-cost-recovery prices are set at appropriate levels so as not to distort the 

market, and it may be forgoing revenue that could further support its mission. 

The Isotope Program has begun taking some actions to identify and manage 

risks to achieving its mission of producing isotopes, but because it has not 

established clear, consistent program objectives, the program’s risk assessment 

efforts are not comprehensive. Actions the Isotope Program is taking include, 

among other things, identifying high-priority isotopes and using its revolving fund 

to mitigate risks from unforeseen events. For example, the Isotope Program has 

identified five lists of high-priority isotopes—those at risk of supply problems 

because they are already in short supply or are important to users. Isotope 

Program officials reported using these lists to set program priorities. The Isotope 

Program is taking these actions, however, without first establishing clear, 

consistent objectives. The federal standards for internal control state that a 

precondition to risk assessment is the establishment of clear objectives. Without 

clearly defined objectives, the program cannot be assured that it is assessing 

risks from all sources or that its efforts are focusing on the most significant risks 

to achieving its mission. Furthermore, without consolidating the multiple highpriority lists, Isotope Program managers may not be directing limited resources to 

the most important isotopes. 

View GAO-12-591. For more information, 

contact Gene Aloise at (202) 512-3841 or 

aloisee@gao.gov. 
Page i GAO-12-591 DOE’s Isotope Program

Letter 1 

Scope and Methodology 4

Background 5

DOE’s Isotope Program and NNSA Together Produce or Make 

Available over 300 Isotopes for Research and Commercial 

Applications 9

In Providing Commercial Isotopes, DOE’s Isotope Program May Be 

Forgoing Revenue That Could Further Support Its Mission 11

DOE’s Isotope Program Has Taken Some Actions to Identify and 

Manage Risks, but Its Efforts Are Not Comprehensive 17

Conclusions 23

Recommendations for Executive Action 24

Agency Comments and Our Evaluation 24

Appendix I Isotopes Available from DOE’s Isotope Program 27

Appendix II Comments from the Department of Energy 36

Appendix III GAO Contact and Staff Acknowledgments 39

Tables

Table 1: Revenues and Obligations of DOE’s Isotope Program, 

Fiscal Years 2009 through 2011 7

Table 2: The Eight Top-Selling Isotopes of DOE’s Isotope Program 

in Fiscal Year 2011 8

Table 3: Isotopes Available for Sale by DOE’s Isotope Program 9

Table 4: Stable Isotopes Sold by DOE’s Isotope Program with a 

Supply of Less Than 10 Years 10

Contents
Page ii GAO-12-591 DOE’s Isotope Program

Abbreviations

DOE Department of Energy

NNSA National Nuclear Security Administration

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Page 1 GAO-12-591 DOE’s Isotope Program

United States Government Accountability Office 

Washington, DC 20548

May 23, 2012

The Honorable Brad Miller

Ranking Member

Subcommittee on Energy and Environment

Committee on Science, Space, and Technology

House of Representatives

The Honorable Paul D. Tonko

Ranking Member

Subcommittee on Investigations and Oversight

Committee on Science, Space, and Technology

House of Representatives

The Department of Energy’s (DOE) Isotope Development and Production 

for Research and Applications program (Isotope Program) is the only 

domestic supplier for many of the more than 300 different isotopes that it 

sells, many of which are critical to medical, commercial, research, and 

national security applications.1 For example, the program produces and 

sells strontium-82, an isotope used to generate rubidium-82, which is 

used in the diagnosis of heart disease. Overall, approximately 20 million 

medical procedures are performed each year in the United States using 

isotopes. Other applications for isotopes include oil and gas exploration, 

physics research, and radiation detection monitors that screen cargo and 

vehicles at ports and border crossings. Additionally, a January 2012 

federal workshop on isotopes was held by the Isotope Program and the 

National Nuclear Security Administration (NNSA), a separately organized 

agency within DOE,2

 

1

Isotopes are varieties of a given chemical element with the same number of protons but 

different numbers of neutrons. For example, the helium-3 isotope has one less neutron 

than the helium-4 isotope, which is the helium isotope commonly used in party balloons. 

to discuss isotope supply and demand. At this 

workshop, more than 20 federal government entities, including the 

Department of Defense’s Defense Threat Reduction Agency, Department 

of Homeland Security’s Domestic Nuclear Detection Office, National 

Aeronautics and Space Administration, National Institutes of Health, and 

2

Congress created NNSA as a semiautonomous agency within DOE under Title 32 of the 

National Defense Authorization Act for Fiscal Year 2000 (Pub. L. No. 106-65, § 3211 

(1999)). NNSA is responsible for the management and security of the nation’s nuclear 

weapons, nonproliferation, and naval reactors programs. 

 
 

Page 2 GAO-12-591 DOE’s Isotope Program

Federal Bureau of Investigation identified more than 100 different 

isotopes that are key to achieving their missions, according to program 

officials. 

Previous shortages of some isotopes, such as helium-3, highlight the 

importance of managing supplies of and demand for critical isotopes. For 

example, in May 2011 we reported on a shortage of helium-3—an isotope 

used in radiation detection monitors deployed at ports and border 

crossings to detect nuclear material and prevent terrorists from smuggling 

such material into the United States.3 DOE is the only domestic supplier 

of helium-3, producing about 8,000 liters per year. As demand for helium3 increased beginning in 2001, sales quickly outpaced production levels, 

resulting in a critical shortage in 2008. As a result, the federal government 

was forced to quickly begin developing alternatives to helium-3 in order to 

continue deploying radiation detection monitors.4

In fiscal year 2009, DOE transferred the Isotope Program from its Office 

of Nuclear Energy to its Office of Science and revised the program’s 

mission to three purposes: (1) produce or distribute isotopes in short 

supply, their associated by-products and surplus materials, and deliver 

isotope-related services; (2) maintain the infrastructure required to 

produce and supply isotopes and related services; and (3) investigate and 

develop new or improved isotope production and processing techniques 

that can make new isotopes available for research and other applications. 

To meet this three-pronged mission, the Isotope Program operates from 

an annual budget consisting of yearly appropriations5

 

3

GAO, Managing Critical Isotopes: Weaknesses in DOE’s Management of Helium-3 

Delayed the Federal Response to a Critical Supply Shortage, 

and revenues from 

isotope sales. In fiscal year 2011, appropriations totaled almost $20 

million, and revenues from sales of isotopes alone totaled almost $27 

million, according to data provided by agency officials.

GAO-11-472 (Washington, 

D.C.: May 12, 2011).

4

GAO, Neutron Detectors: Alternatives to Using Helium-3, GAO-11-753 (Washington, 

D.C.: Sept. 29, 2011).

5

In this report, we use the phrase “yearly appropriations” to refer to funding that is 

received by DOE through the annual appropriations process, but has no restrictions on the 

time by which it must be obligated.
 

Page 3 GAO-12-591 DOE’s Isotope Program

In addition to DOE’s Isotope Program, NNSA generates or provides some 

additional isotopes as by-products of the weapons program and research 

activities. Through its Office of Nuclear Materials Integration, NNSA 

makes these isotopes available to other federal entities, including DOE’s 

Isotope Program, which then coordinates their sale and distribution to 

researchers and commercial entities.

Since 2008, the Isotope Program has been addressing programmatic 

risks and challenges as identified by external stakeholders as part of a 

series of program reviews. The risks and challenges the reviews identified 

included concerns over supply limitations for some isotopes, the need for 

long-term infrastructure investments to maintain the capacity for isotope 

production, and difficulties with accurately forecasting isotope demand. 

Specifically, in August 2008, DOE organized a workshop bringing 

together a wide range of stakeholders to discuss the nation’s current and 

future isotope needs and to consider options for improving the availability 

of needed isotopes. This workshop identified 30 key isotopes that were in 

short supply at that time, including 12 whose supplies had been 

exhausted or were likely to run out within the following 3 years. Also in 

2008, DOE requested that the Nuclear Science Advisory Committee form 

an isotope subcommittee to advise the program on specific isotope risks.6

The subcommittee produced two reports in response: one identifying and 

setting priorities for compelling research opportunities using isotopes and 

another report presenting opportunities and priorities for ensuring a robust 

national isotope program. These reports highlighted short-term and longterm risks and challenges facing the Isotope Program, such as the 

program’s reliance on DOE laboratories to produce certain isotopes. 

Specifically, the report expressed concern that the Isotope Program relies 

on the linear particle accelerators7

 

6

The Nuclear Science Advisory Committee is an advisory committee that provides official 

advice to the Department of Energy and the National Science Foundation on basic nuclear 

science research. The lead responsibility for the direction of the advisory committee, 

selecting members, creating meeting agendas, and developing charges is shared by the 

two agencies. 

at Brookhaven National Laboratory 

and Los Alamos National Laboratory for isotope production, even though 

isotope production is not the primary mission of these laboratories.

7

A particle accelerator uses electromagnetic forces to accelerate charged particles, such 

as electrons or protons. The resulting beam of fast-moving particles may be used for a 

variety of applications, including the creation of different isotopes. 
 

Page 4 GAO-12-591 DOE’s Isotope Program

In light of the importance of the isotopes sold by the Isotope Program and 

the various challenges it faces, you asked us to review the program. 

Specifically, our objectives were to determine (1) which isotopes are 

produced, sold, or distributed either by the Isotope Program or NNSA and 

how the two entities make isotopes available for commercial and research 

applications; (2) what steps the Isotope Program takes to provide 

isotopes for commercial and research applications; and (3) the extent to 

which DOE is assessing and mitigating risks facing the Isotope Program.

To identify which isotopes are produced, sold, or distributed either by the 

Isotope Program or NNSA and how the two agencies make isotopes 

available for commercial and research applications, we reviewed the DOE 

Isotope Program’s information on available isotopes, isotope sales data, 

and information on NNSA’s isotopes. We also visited Oak Ridge National 

Laboratory in Tennessee, where the Isotope Program’s business office 

and the program’s inventory of stable isotopes are located, to view 

production facilities and interview officials about isotope production and 

sales. We interviewed officials at the national laboratories that produce 

isotopes for the Isotope Program: Brookhaven National Laboratory in 

New York, Idaho National Laboratory in Idaho, Los Alamos National 

Laboratory in New Mexico, Oak Ridge National Laboratory in Tennessee, 

and Pacific Northwest National Laboratory in Washington State. We also 

interviewed headquarters officials with the Isotope Program and NNSA 

about isotope production and how the two entities work together. To 

determine what steps the Isotope Program takes to provide isotopes for 

commercial and research applications, we reviewed the Isotope 

Program’s production schedules, pricing policy, and documents related to 

how the program gathers information on customers’ needs. We also 

interviewed representatives from commercial companies and researchers 

who purchase isotopes from the Isotope Program. We interviewed 

officials from the National Isotope Development Center; the Isotope 

Program; and Brookhaven, Los Alamos, and Oak Ridge National 

Laboratories because officials at these locations are involved in producing 

and selling isotopes to customers. To determine the extent to which DOE 

is assessing risks facing the Isotope Program, we reviewed reports from 

the Nuclear Science Advisory Committee’s isotope subcommittee and the 

report from the isotope workshop DOE held in 2008. We also reviewed 

the strategic plans, risk assessment plans, and related documents from 

Brookhaven, Los Alamos, and Oak Ridge National Laboratories because 

the Isotope Program is the steward of isotope production at these sites. 

We reviewed and compared lists of high-priority isotopes that were 

prepared by the Isotope Program, the Nuclear Science Advisory 

Scope and 

Methodology
 

Page 5 GAO-12-591 DOE’s Isotope Program

Committee’s isotope subcommittee, the National Institutes of Health, and 

stakeholders at the 2008 isotope workshop. We also interviewed officials 

from the Isotope Program and Brookhaven, Los Alamos, and Oak Ridge 

National Laboratories to learn about risk assessment planning at each 

site and for the Isotope Program. In addition, we compared actions the 

Isotope Program is taking to assess risks with federal standards for 

internal control.8

We conducted this performance audit from June 2011 to May 2012, in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Isotope production and distribution have been part of DOE’s mission 

since at least 1954, when the Atomic Energy Act of 1954 specified the 

role of the U.S. government in isotope distribution.9 DOE’s Isotope 

Program fills this role by providing isotopes to support the national and 

international need for a reliable supply for use in medicine, industry, and 

research. The Isotope Program provides both radioactive isotopes, called 

radioisotopes, and stable isotopes, which are not radioactive.10

DOE transferred the Isotope Program from the department’s Office of 

Nuclear Energy to its Office of Science in 2009, at which time DOE 

restructured the program. The program currently consists of four DOE 

In 

addition, the Isotope Program provides a range of isotope-related 

services to customers worldwide. For example, the program may lease 

some stable isotopes and also provides irradiation and isotopeprocessing services for research and commercial applications.

 

8

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(“Green Book”) (Washington, D.C.: November 1999).

9

Atomic Energy Act of 1954, Pub. L. No. 83-703, 68 Stat. 919.

10Radioisotopes are radioactive—that is, they are unstable forms of elements that decay 

or disintegrate, emitting radiation. Some radioisotopes are found naturally, and others can 

be produced in nuclear reactors or particle accelerators. Stable isotopes do not decay or 

emit radiation and are therefore not radioactive.

Background
 

Page 6 GAO-12-591 DOE’s Isotope Program

headquarters employees who oversee operations and set policy, plus the 

National Isotope Development Center, which is a virtual organization 

consisting of DOE contract employees located at Los Alamos National 

Laboratory and Oak Ridge National Laboratory. National Isotope 

Development Center employees carry out day-to-day operations of the 

Isotope Program, which include interacting with the isotope user 

community though a variety of outreach activities, monitoring short-term 

and long-term isotope demand, coordinating isotope production across 

DOE’s isotope production facilities, and distributing isotopes. The 

National Isotope Development Center includes DOE contract employees 

at the Isotope Business Office, located at Oak Ridge National Laboratory, 

who manage business operations involved in the production, sale, and 

distribution of isotopes. In addition, officials from the National Isotope 

Development Center and DOE headquarters coordinate with many 

federal programs, including the National Institutes of Health, to identify 

current and future isotope needs.

The Isotope Program produces most of its radioisotopes at three DOE 

production sites: the linear particle accelerators at Brookhaven National 

Laboratory in New York and Los Alamos National Laboratory in New 

Mexico, and the nuclear reactor at Oak Ridge National Laboratory in 

Tennessee. The program also produces a small number of radioisotopes 

at the Pacific Northwest National Laboratory in Washington State and at 

Idaho National Laboratory. The DOE facilities associated with the Isotope 

Program are recognized as uniquely capable of producing radioisotopes. 

Although the Isotope Program uses these DOE sites to produce 

radioisotopes, the program does not manage all the sites’ operations. 

Rather, the Isotope Program shares the use of these sites with other 

missions, which consist of a diverse combination of DOE activities related 

to nuclear science, materials research, or defense. The production sites 

are therefore not always available to the Isotope Program, and at times 

the program may not control the timing and duration of isotope 

production.

The Isotope Program relies on appropriations and revenues from isotope 

sales for funding its operations. Both yearly appropriations and sales 
 

Page 7 GAO-12-591 DOE’s Isotope Program

revenues are deposited into a revolving fund11

Table 1: Revenues and Obligations of DOE’s Isotope Program, Fiscal Years 2009 

through 2011

from which the program 

draws funds to operate its facilities, produce isotopes, pay employees’ 

salaries, and fund research, among other activities. Funds remain 

available to the program in the revolving fund, which allows the program 

to carry over balances from year to year, giving the program budgeting 

flexibility. Table 1 shows the Isotope Program’s revolving fund balances, 

annual appropriations, annual sales revenues, and obligations to operate 

the program for fiscal years 2009 through 2011. The Isotope Program’s 

annual spending on research and development is generally aimed at 

developing new or more efficient isotope production techniques.

Fiscal year 

2009

Fiscal year

2010

Fiscal year

2011

Revenues

Carryover from previous fiscal year $14,341,000 $24,235,000 $16,844,000

Sales revenues and other resourcesa $25,373,000 $18,620,000 $28,837,000

Appropriations $24,760,000 $19,116,000 $19,670,000

American Recovery and

Reinvestment Act fundsb $14,617,000 $0.00 $0.00

Total funding $79,092,000 $61,971,000 $65,351,000

Obligations

Research and development $5,424,000 $6,151,000 $1,644,000

Operations $49,433,000 $38,976,000 $45,696,000

Total obligations $54,857,000 $45,127,000 $47,360,000

Carryover to next fiscal year $24,235,000 $16,844,000 $17,991,000

Source: DOE.

Note: Numbers may not sum because of rounding. 

a

Sales revenues and other resources include revenues received for isotope sales and isotope-related 

services, as well as funds received from federal and other entities.

b

The Isotope Program received funds from the American Recovery and Reinvestment Act in fiscal 

year 2009.

 

11The Isotope Program’s revolving fund was first established under Public Law 101-101, 

Title III. Both yearly appropriations and revenues from the sales of isotopes are deposited 

into the revolving fund, which the program then draws from to fund its operations. Any 

funds remaining in the revolving fund at the end of a fiscal year are carried over to the 

next fiscal year.
 

Page 8 GAO-12-591 DOE’s Isotope Program

The Isotope Program sold isotopes or provided isotope-related services 

to more than 100 customers in fiscal year 2011, both in the United States 

and internationally, with 6 of those customers accounting for more than 

80 percent of all sales revenue in fiscal year 2011. More than 95 percent 

of the Isotope Program’s annual revenue came from the sale of eight 

different isotopes in fiscal year 2011; these eight isotopes generated 

almost $26 million in revenue (see table 2).

Table 2: The Eight Top-Selling Isotopes of DOE’s Isotope Program in Fiscal Year 

2011

Isotope 2011 revenue

Strontium-82 $11,560,000

Californium-252 $7,657,000a

Helium-3 $3,255,000

Germanium-68 $1,910,000

Nickel-63 $576,000

Strontium-90 $297,000

Actinium-225 $263,000

Lithium-6 $223,000

Total $25,741,000

Source: DOE.

a

This amount includes $2 million that was paid in fiscal year 2009 by customers as advance 

payments for future production costs. 
 

Page 9 GAO-12-591 DOE’s Isotope Program

DOE’s Isotope Program produces or makes available for sale and 

distribution over 300 different isotopes for research and commercial 

applications. NNSA generates or provides additional isotopes that are 

transferred to other federal agencies or sold by the Isotope Program (see 

app. I). The program may produce or make available to customers more 

than 300 different isotopes, but fewer than that number are sold in a given 

year. In fiscal year 2011, for example, the program sold less than 170 

distinct isotopes. The isotopes sold by the Isotope Program can be 

categorized as (1) radioisotopes currently produced by the Isotope 

Program at DOE production sites;12 (2) stable isotopes from the Isotope 

Program’s inventory, which are no longer produced in the United States; 

and (3) isotopes generated or provided by NNSA as by-products of its 

nuclear weapons program (see table 3).13

Table 3: Isotopes Available for Sale by DOE’s Isotope Program 

Category Number available

Radioisotopes produced by the Isotope Program 55

Stable isotopes in the Isotope Program’s inventory 243

Radioisotopes generated or provided by NNSA 10

Source: DOE.

The Isotope Program is responsible for the production and sale of 55 

radioisotopes produced at five DOE laboratories—Brookhaven, Los 

Alamos, Oak Ridge, Pacific Northwest, and Idaho National Laboratories. 

In any given year, the Isotope Program does not produce all 55 

radioisotopes; rather, it produces and sells those for which customer 

demand exists and is unmet by supply from commercial sources. At 

times, the Isotope Program may choose to begin or stop producing a 

given isotope depending on whether commercial entities are meeting 

demand, whether an isotope’s market price is so high that it inhibits 

research, or whether DOE has the facilities necessary to produce the 

isotope, among other considerations. For example, in 2009 the Isotope 

Program reestablished production of californium-252, which is used in a 

 

12Some isotopes that are produced by DOE’s Isotope Program are extracted from other 

materials held in inventory. For example, americium-241 is extracted from other materials.

13In addition to these categories, many radioisotopes that are not produced or sold by 

DOE’s Isotope Program are available from commercial entities, which produce and sell 

isotopes on the open market.

DOE’s Isotope 

Program and NNSA 

Together Produce or 

Make Available over 

300 Isotopes for 

Research and 

Commercial 

Applications
 

Page 10 GAO-12-591 DOE’s Isotope Program

variety of applications, including oil exploration and medical applications, 

because of customer demand. Californium-252 was previously produced 

by the Isotope Program in partnership with NNSA and sold through the 

Isotope Program. When NNSA no longer needed californium-252 for its 

mission, it stopped supporting its production in 2007, according to an 

Isotope Program official. The Isotope Program worked with a coalition of 

commercial customers to continue producing californium-252 to meet the 

needs of the coalition and researchers. Isotope Program officials 

indicated, however, that a change like this in the program’s production 

portfolio does not happen often.

In addition to the radioisotopes it produces, the Isotope Program also 

maintains an inventory of 243 stable isotopes that it sells to customers. 

These stable isotopes were produced by DOE until the late 1990s at DOE 

facilities that are no longer in use, and since these isotopes are stable, 

they can remain in storage almost indefinitely. Because stable isotopes 

are no longer produced, supplies of some of them have been exhausted, 

and supplies of others are dwindling. Specifically, according to current 

Isotope Program data, nine stable isotopes that were in the program’s 

inventory are no longer available, and six have less than 10 years’ supply 

at current rates of use (see table 4).

Table 4: Stable Isotopes Sold by DOE’s Isotope Program with a Supply of Less 

Than 10 Years

Isotope Supply (in years)

Gadolinium-157 0.5

Nickel-62 4.5

Neodymium-150 4.8

Gallium-69 5.9

Tungsten-183 7.6

Tungsten-182 9.9

Source: DOE.

According to program officials, the Isotope Program occasionally 

purchases quantities of some stable isotopes from foreign sources, such 

as Russia, in an effort to maintain the program’s supply. Isotope Program 

officials explained that the program buys stable isotopes from foreign 

sources and then resells them to domestic customers because the 

Isotope Program can take steps to ensure isotope quality and offer other 

services that foreign suppliers are unwilling to provide, such as leasing 

some stable isotopes for research or other applications. Given dwindling 
 

Page 11 GAO-12-591 DOE’s Isotope Program

supplies in DOE’s inventory and increasing reliance on foreign sources, 

whose supplies for some isotopes are also dwindling, the Nuclear 

Science Advisory Committee recommended in 2009 that the Isotope 

Program reestablish capability to produce stable isotopes in the United 

States. The Isotope Program is funding several projects in response to 

this recommendation, including the development of stable isotope 

production at Oak Ridge National Laboratory, in part, using funds it 

received in fiscal year 2009 from the American Recovery and 

Reinvestment Act. Isotope Program officials stated that the project is 

expected to be completed in 2014.

The Isotope Program sells an additional 10 isotopes that are provided by 

NNSA. The program does not control the supply of these isotopes but 

coordinates with NNSA to sell and distribute them. Isotope Program 

officials coordinate with NNSA’s Office of Nuclear Materials Integration, 

which was created in 2008 to work across DOE to, among other things, 

make NNSA’s isotopes and other materials available to government 

entities. For example, NNSA has a stockpile of lithium-6, some of which it 

provides to the Isotope Program to sell; lithium-6 is used in research and 

security equipment to detect neutrons given off by other nuclear 

materials. The Isotope Program also coordinates with NNSA to produce 

isotopes that the Isotope Program does not have the capability to 

produce, such as americium-241, which is used in smoke detectors and 

medical diagnostic devices.

To provide isotopes for commercial and research applications, the 

Isotope Program takes steps to determine the demand for isotopes, 

coordinate production across production sites, and set prices for isotopes, 

but the program is not using thorough assessments to establish prices for 

commercial isotopes. The Isotope Program has flexibility to set prices at 

market levels for isotopes sold for commercial applications but instead, 

for most isotopes where the program is the only domestic supplier, sets 

prices at the level necessary to recover its cost to produce them. In 

setting prices for commercial isotopes, however, the Isotope Program is 

not assessing the value of the isotope to the customer or prices of 

alternatives, as permitted under its pricing policy. As a result, the Isotope 

Program may be forgoing revenue that could be used to further its 

mission and address unmet needs.

In Providing 

Commercial Isotopes, 

DOE’s Isotope 

Program May Be 

Forgoing Revenue 

That Could Further 

Support Its Mission
 

Page 12 GAO-12-591 DOE’s Isotope Program

To ensure the availability of isotopes for research and commercial 

applications, the Isotope Program annually determines demand, 

coordinates production across its production sites, and sets prices for 

selling isotopes. To determine annual demand, Isotope Program officials 

said they start with a general sense of demand based on historical sales 

data and frequent interaction with customers, through which they learn 

about changes in isotope needs. According to program officials, the Isotope 

Program asks customers to provide information on expected demand for 

the next year and as far as 5 years into the future, although some 

customers said such estimates are difficult to make. The Isotope Program 

also takes customers’ orders for isotopes throughout the year via e-mail, 

telephone, or the program’s website. These orders, for radioisotopes and 

stable isotopes, are received by the Isotope Program’s business office. To 

determine annual demand for strontium-82, for example, Isotope Program 

officials ask customers how much strontium-82 they need for the coming 

year, and each customer commits to a certain amount for that year. These 

customers then provide updates throughout the year to clarify actual 

strontium-82 quantities and delivery dates.

Orders for stable isotopes are received and processed throughout the 

year by the Isotope Program, but producing radioisotopes to meet 

demand requires considerable planning, according to program officials. 

When the Isotope Program receives an order for a stable isotope, such as 

calcium-48, it can be filled from the existing inventory of stable isotopes. 

In contrast, orders for radioisotopes are taken throughout the year and 

used to plan production during the Isotope Program’s annual production 

planning meeting. The outcome of the meeting is a production schedule 

for the production sites, which identifies radioisotopes needed for the 

coming year. The production schedule outlines the projected dates when 

each isotope will be produced and which site will produce it, but the exact 

schedule depends on a variety of factors. Specifically, because the 

Isotope Program generally does not control the operation of reactors or 

accelerators, it uses the facilities at the same time as other DOE 

programs, thus limiting the Isotope Program’s capability to produce 

isotopes, according to program officials. For instance, according to 

program officials, the accelerator at Los Alamos National Laboratory 

typically operates from July through December, and the accelerator at 

Brookhaven National Laboratory typically operates from January through 

June. In addition, because many radioisotopes decay rapidly after 

production, they need to be delivered in a timely manner, and officials 

To Ensure the Availability 

of Isotopes, DOE’s Isotope 

Program Determines 

Demand, Coordinates 

Production, and Sets 

Prices
 

Page 13 GAO-12-591 DOE’s Isotope Program

must consider customers’ desired delivery times when determining the 

production schedule. For instance, strontium-82 has a half-life14

To set prices for radioisotopes, program officials annually request detailed 

production cost data, including both direct and indirect costs, from the 

individual DOE and NNSA production sites that provided the isotope. 

According to program officials, direct costs include labor costs and costs 

for chemical processing, among others; indirect costs include facility 

maintenance costs and other infrastructure costs. These officials said that 

the Isotope Program uses cost data from the production sites to 

determine the sales price for each isotope and prices isotopes differently 

depending on whether the intended use is for research or commercial 

applications. For research applications, isotope prices are set to recover 

only direct costs. In addition, according to program officials, research 

isotopes are priced by unit, instead of batch, so researchers can buy 

small quantities of isotopes and not have to pay for production of an 

entire batch.

of about 

26 days and, according to one customer, must arrive predictably to be 

used for its intended purpose. Other isotopes have even shorter life 

spans and need to be delivered on a precise day before they decay too 

much to be useful. An Isotope Program official told us that that the 

production schedule is adjusted throughout the year as customers’ 

demands change, as new isotopes are ordered, as facilities experience 

unanticipated shutdowns, or for other reasons. During our discussions 

with several Isotope Program customers, we found that they were 

generally satisfied with the timeliness of isotope delivery.

15

 

14The half-life of a radioactive isotope is the time required for half the unstable atoms to 

disintegrate, or decay, and release their radiation. 

Thus, prices for research isotopes are subsidized by the 

Isotope Program, with indirect costs covered by the program’s yearly 

appropriation. Program officials told us that the intent of this subsidy is to 

promote independent research on uses of isotopes by making them more 

affordable to the research community. Overall, the result is that some 

research isotopes are priced significantly lower—from about 9 percent to 

75 percent less, in some cases—than the same isotope used for 

commercial applications.

15A batch of isotopes is the amount produced by an entire production cycle. Researchers 

may require a smaller quantity of an isotope than what is produced in a batch.
 

Page 14 GAO-12-591 DOE’s Isotope Program

For isotopes used in commercial applications, prices are generally set to 

recover, at a minimum, the full cost of isotope production, including both 

direct costs and indirect costs. For orders of large quantities of 

commercial isotopes, the per-unit cost of production is lower, so the 

Isotope Program can provide volume discounts. In addition, according to 

program officials, the Isotope Program adds a nominal fee to isotopes 

sold commercially, which amounts to approximately 10 percent in 

additional costs for commercial isotopes—6 percent for administrative 

costs to process orders for isotopes and 4 percent as a contingency 

charge to cover unanticipated events. A recent unanticipated event, for 

example, occurred in fiscal year 2011. According to a program official, 

orders for strontium-82, which had accounted for more than a third of the 

program’s sales revenue in 2010, decreased significantly and 

unexpectedly as the result of a recall of the cardiac imaging device that 

was the main application for strontium-82. According to program officials, 

the Isotope Program sales revenue declined by over $5 million from July 

2011 through January 2012 as a result, and program officials said they 

had to draw from the revolving fund to maintain operations.

For stable isotopes that are sold from its existing inventory, Isotope 

Program officials told us that prices are based on historical production 

costs adjusted annually for inflation, rather than on current replacement 

costs; the prices are the same regardless of whether they are used for 

research or commercial applications. Officials told us that they do not 

base the prices of stable isotopes on current replacement costs because 

DOE does not have the capability to produce these stable isotopes. 

Isotope Program officials told us that market studies were in the early 

stages of being carried out in preparation for reestablishing the capability 

to produce stable isotopes in 2014; these studies are intended to help the 

program determine which stable isotopes to produce and in what 

quantities.

The Isotope Program generally charges full cost recovery for commercial 

isotopes, but the program has not fully assessed the pricing of most of the 

commercial isotopes it sells, as required by its current policy, such as 

assessing the value of the isotopes to the customer or prices of similar 

isotopes. As a result, the program may be discouraging others from 

producing isotopes and, at the same time, forgoing sales revenue that 

could further support its mission to deliver needed isotopes, maintain 

isotope production infrastructure, and support research, in addition to 

addressing unmet needs. The Atomic Energy Act of 1954 states that the 

federal government should be reasonably compensated for isotopes it 

In Setting Prices for Most 

Commercial Isotopes, 

DOE’s Isotope Program 

May Be Forgoing Revenue 

That Could Further 

Support Its Mission
 

Page 15 GAO-12-591 DOE’s Isotope Program

sells and that isotope prices should not discourage commercial isotope 

producers from entering the market. Aside from these constraints, the 

Isotope Program has broad authority in setting isotope prices. To this 

end, the Isotope Program established a pricing policy in 1990 that 

provides latitude for establishing prices at full cost recovery or at market 

prices that are higher or lower than full cost recovery, but also states that 

when a market price already exists that is higher than full cost recovery, 

the market price should be used. The policy also states that prices should 

be assessed annually and that additional factors may be considered 

when establishing prices, including the number of suppliers, demand, 

competitors’ prices, and the value of the isotope to the customer. This 

policy appears to be consistent with guidance from the Office of 

Management and Budget on the sale of government goods and services, 

which suggests that sales should be self-sustaining and based on market 

prices.16

In practice, according to program officials, the Isotope Program generally 

sets the prices for commercial isotopes at full cost recovery—the lowest 

price possible for the program to recover its costs for providing an 

isotope. According to Isotope Program officials, prices for commercial 

isotopes are set above full cost recovery only when a higher price for the 

isotope already exists in the commercial market and pricing the isotope at 

full cost recovery would be low enough to distort the existing market.

In cases where no market currently exists, such as many of the 

commercial isotopes produced and sold by the Isotope Program, the 

Office of Management and Budget’s guidance states that prices can be 

set by taking into account the prevailing prices for goods that are the 

same as or substantially similar to those provided by the government and 

then adjusting the supply made available, prices of the goods, or both so 

that there will be neither a shortage nor a surplus.

17

 

16Office of Management and Budget, Circular A-25. 

If 

isotope prices are artificially low, the Isotope Program’s price may, in turn, 

discourage private entities from entering the isotope market, discourage 

commercial entities or researchers from exploring alternatives to using 

some isotopes, or encourage overconsumption. Isotope Program officials 

offered two reasons why the program charges no more than full cost 

17According to program officials, at present the Isotope Program has set the price above 

full cost recovery for helium-3 and two other isotopes. These three isotopes are priced 

above full cost recovery because, according to officials, market prices exist that are 

greater than the full cost of production, and setting the prices lower would distort their 

market prices.
 

Page 16 GAO-12-591 DOE’s Isotope Program

recovery for most of the commercial isotopes it sells. First, officials told us 

they believe many customers are sensitive to prices and already consider 

prices for isotopes to be too high. Isotope Program officials said that 

some potential customers are already unwilling or unable to pay current 

prices for many isotopes and that some existing customers have 

suggested that any price increases would make isotopes unaffordable 

and force them to seek other isotope sources. Second, Isotope Program 

officials stated that the program’s role is not to maximize revenue from 

isotope sales but to make isotopes widely available. Isotope Program 

officials told us that, consistent with the program’s mission and the Atomic 

Energy Act, the Isotope Program strives to supply isotopes at reasonable 

prices to encourage their use.

For most of the isotopes it produces and sells, however, program officials 

told us that in instances where the Isotope Program is the only domestic 

supplier, the program has not formally determined the value of isotopes to 

commercial customers or prices of alternatives. Program officials told us 

that they gain a sense of customers’ value for isotopes through various 

interactions with these customers, although they did not provide a formal 

analysis as described in the pricing policy. According to documents 

provided by the Isotope Program, the program has also collected limited 

market information for a small number of isotopes, but these studies are 

outdated or do not consider pricing. For example, a market study 

provided by the Isotope Program that was conducted in 2002 projects the 

future demand and potential revenues for 25 different radioisotopes used 

in medicine over the next 5 to 10 years, but that study is now outdated. 

Additionally, according to one program official, the market study to be 

conducted for the Isotope Program’s isotopes beginning in 2012 is to 

provide information on which isotopes are in greatest demand so officials 

will know which stable isotopes to produce, although the study will not 

address isotope prices.

Without formally assessing the value of isotopes to commercial 

customers or the prices of alternatives for isotopes where the Isotope 

Program is the only domestic supplier, the Isotope Program does not 

know if its full cost recovery prices for isotopes are in fact discouraging 

others from producing isotopes, discouraging commercial entities and 

researchers from developing alternatives, and/or encouraging 

overconsumption. If assessments of customers’ value for isotopes and 

the prices of potential alternatives show that prices can be increased 

above full cost recovery for some commercial isotopes, the additional 

revenue could be used to further the Isotope Program’s mission and 

address unmet needs. For example, revenues could be used to fund 
 

Page 17 GAO-12-591 DOE’s Isotope Program

research for the development of new or more efficient production 

capabilities for additional isotopes. Also, the Nuclear Science Advisory 

Committee recommended in its report on opportunities and priorities for 

ensuring a robust national isotope program that the Isotope Program 

invest in a facility dedicated to producing radioisotopes. Such a facility, 

according to the advisory committee, is the most cost-effective option to 

position the Isotope Program to ensure continuous access to many of the 

needed radioactive isotopes. Program officials told us they were 

developing a new pricing policy, but because the policy is in draft form 

and subject to change, we were unable to determine, among other things, 

whether the new policy would provide direction on how commercial 

isotope prices are to reflect the value of the isotope to the customer, the 

prices of alternatives, or both.

The Isotope Program has begun taking some actions to identify and 

mitigate risks to achieving its mission of producing isotopes, such as the 

risk of relying on sales of a small number of commercial isotopes for a 

large percentage of its revenues, but without first establishing clear, 

consistent program objectives, the program’s risk assessment efforts are 

not comprehensive.

The Isotope Program is taking some actions to assess risks to achieving 

its mission, including identifying high-priority isotopes and using its 

revolving fund to mitigate risks from unforeseen events. Risk assessment 

first involves, according to federal standards for internal control,18

 

18

identifying and analyzing risks associated with achieving a program’s 

objectives and then determining how to manage such risks. Our analysis 

shows that the Isotope Program currently assesses risks through several 

methods. First, Isotope Program officials, National Isotope Development 

Center staff, and production site managers identify risks to providing 

isotopes by monitoring long-term changes in demand within the isotope 

community that could affect isotope supply. Unlike determining demand 

GAO/AIMD-00-21.3.1. 

DOE’s Isotope 

Program Has Taken 

Some Actions to 

Identify and Manage 

Risks, but Its Efforts 

Are Not 

Comprehensive

DOE’s Isotope Program Is 

Taking Varied Actions to 

Identify and Mitigate 

Program Risks
 

Page 18 GAO-12-591 DOE’s Isotope Program

for annual production planning, these monitoring activities focus on 

changes that could influence isotope supply and demand in the longer 

term, such as new products that could eventually increase demand for a 

specific isotope, according to Isotope Program documents. According to 

program officials, long-term monitoring activities help them stay abreast of 

changes in the isotope community that may warrant adjustments to the 

program’s product portfolio. In addition, program officials told us that 

these activities play a role in long-range program planning, as well as 

informing decisions regarding research and development. Some 

monitoring activities are performed on a continuous basis, such as 

discussing new developments in isotope uses and production capacity 

with foreign isotope suppliers, while others occur once or a few times a 

year, such as attending industry conferences to collect information about 

new commercial products that use isotopes. To manage risks created by 

changes in demand, according to Isotope Program officials, the program 

gathers additional information on the issue and may convene workgroups 

that bring together isotope community stakeholders to discuss trends for 

one or several isotopes. For example, the program organized a working 

group in 2008 with representatives from the National Institutes of Health 

to explore supply and demand for medical research isotopes. It also 

convened a workshop of federal stakeholders in January 2012 to discuss 

isotope priorities, supply, and demand among federal entities.

The Isotope Program also assesses risks to the program by identifying 

high-priority isotopes—those at risk of supply problems, either because 

the isotopes are already in short supply or are important to users. Five 

lists of high-priority isotopes have been created by isotope stakeholders, 

and Isotope Program officials said that they use the lists to set program 

priorities. The following describes each of the lists and the entity that 

created them:

• The 2008 workshop of isotope community stakeholders created an 

unranked list of more than 47 isotopes considered to be in short 

supply or unavailable from DOE for research and applications.

• In 2009, the National Institutes of Health isotope working group 

developed a list of important medical research isotopes that are not 

commercially available; the list was updated and ranked in order of 

priority in January 2012.

• In 2009, the Nuclear Science Advisory Committee’s isotope 

subcommittee produced a list of isotopes important for medical and
 

Page 19 GAO-12-591 DOE’s Isotope Program

scientific research purposes and prioritized them according to the 

importance of the research opportunities.

• In 2011, the National Isotope Development Center listed stable 

isotopes in priority order according to the importance of the isotopes 

in research and commercial applications.

• In 2011, the National Isotope Development Center listed specific 

isotopes called nuclear materials and heavy elements and prioritized 

them on the basis of importance of the isotopes in research and 

commercial applications.

Program officials told us they use the high-priority lists to establish 

program priorities, such as determining what research and development 

initiatives to undertake. For example, according to program officials, for 

some of the listed isotopes, the program has reached out to universities 

to research new production methods. In addition, the Nuclear Science 

Advisory Committee’s isotope subcommittee’s list serves as a criterion for 

awarding research and development grants; research projects for 

isotopes on the list receive higher priority for funding than projects for 

isotopes not on this list. Four of the lists rank the isotopes in order of 

priority, and one does not; the prioritized lists rank isotopes according to 

different criteria. For example, the National Institutes of Health prioritized 

isotopes on the basis of their importance to medical research, while the 

National Isotope Development Center prioritized isotopes on the basis of 

their importance to research and commercial applications. In total, 104 

different isotopes appear on the five lists—about 18 percent of the total 

number of isotopes currently available from the program. Although a few 

isotopes are found on more than one list, most isotopes are found on only 

a single list.

The Isotope Program mitigates risks by using the flexibility of its revolving 

fund to help manage unexpected events, such as losses in revenues. The 

Isotope Program is authorized to carry over revenues and yearly 

appropriations in its revolving fund from fiscal year to fiscal year. The law 

authorizing the revolving fund provides the program broad discretion for 

managing the fund, stating that appropriations and revenues deposited 

into the fund are to be used for “activities related to the production, 
 

Page 20 GAO-12-591 DOE’s Isotope Program

distribution, and sale of isotopes and related services.”19

The Isotope Program also assesses risks at its three primary isotope 

production facilities by identifying and managing risks to the production 

sites. The isotope production facilities at Oak Ridge and Los Alamos 

National Laboratories in 2011 developed plans that describe processes 

for identifying and managing risks at the sites that could be detrimental to 

isotope production.

The program 

uses its flexibility in managing the revolving fund to prepare for and 

mitigate unexpected events. To this end, of the 10 percent fee the 

program adds to the price of isotopes sold to commercial customers, it 

deposits 4 percent into the revolving fund to cover unanticipated events. 

For example, the program drew on the fund to maintain operations in 

2011 and 2012 in the face of a significant, unexpected decline in revenue 

from the sale of strontium-82.

20

 

19Energy and Water Development Appropriations Act, 1990 (Pub. L. No. 101-101, 103 

Stat. 641).

The plans lay out which production site elements—

such as infrastructure, chemical processing, and shipping processes—

should be assessed for risks and describe how site officials are to 

determine the likelihood and consequence of any identified risks. In 

conjunction with the plans, Oak Ridge and Los Alamos National 

Laboratories created spreadsheets for tracking risks—called risk 

registers—that list each identified risk, its likelihood, consequence, and 

mitigation strategy, among other things. Many of the identified risks focus 

on equipment failure or malfunction, such as risks that components of a 

processing facility shut down unexpectedly. Other risks are related to 

management and regulatory issues. Brookhaven National Laboratory has 

developed a similar risk-tracking spreadsheet that focuses exclusively on 

risks to production equipment. According to one program official, the risk 

management plans and spreadsheets help the program set priorities for 

investments that will help manage risks. For example, on the basis of Los 

Alamos National Laboratory’s risk register, the program decided to modify 

its facilities to reduce radiation risks. These risk management plans and 

risk registers are specific to the three production sites and do not identify 

risks to the entire Isotope Program.

20The plans also describe a similar process for identifying and managing opportunities. 

The third production site at Brookhaven National Laboratory has not developed a similar 

risk and opportunity assessment and management plan.
 

Page 21 GAO-12-591 DOE’s Isotope Program

The Isotope Program is taking risk assessment actions without first 

establishing clear, consistent objectives; that is, it does not identify and 

mitigate risks to achieving program objectives in a comprehensive way. 

One of the federal standards for internal control—risk assessment—

states that a precondition to risk assessment is the establishment of clear, 

consistent objectives. Long-term goals and objectives describe how the 

program will implement its mission, when actions will be taken, and what 

resources are needed to reach these goals. Once objectives have been 

set, the program then identifies risks that could keep it from efficiently and 

effectively achieving those objectives at all levels. After risks have been 

identified, they are to be analyzed for their possible effect and decisions 

made on how to manage the identified risks.21

DOE’s Isotope Program has not established clear, consistent objectives 

to serve as a basis for risk assessment. Isotope Program officials told us 

the program is relying on two reports from the Nuclear Science Advisory 

Committee’s isotope subcommittee to guide its decisions and that these 

two reports provide adequate guidance. Together, these reports 

recommend 15 different long-term actions for the program but do not 

provide clear objectives for the program or a description of how those 

objectives are to be achieved. For example, one report recommends that 

the program construct and operate an electromagnetic isotope separator 

facility for stable and long-lived radioisotopes but does not describe how 

this recommendation is to be achieved. The report also does not provide 

criteria for measuring progress toward meeting this or other 

recommendations. Isotope Program officials told us, however, that the 

program is undertaking a new strategic planning process in 2012 to 

develop a 5-year strategic plan.

Without clearly defined objectives that lay out what the program is to 

accomplish, the Isotope Program cannot be assured that its current risk 

assessment and mitigation efforts focus on the most significant issues 

that could impede achievement of its mission. For example, the program 

does not have objectives that could provide direction about which of the 

five high-priority isotope lists warrants the most attention. Instead, 

program officials reported that they take all the lists into account when 

making production and research decisions. They could not tell us if one 

list of isotopes is a higher priority than the others. Furthermore, without 

 

21GAO/AIMD-00-21.3.1. 

DOE’s Isotope Program 

Does Not Have Clear 

Objectives That Enable It 

to Comprehensively 

Assess Program Risks
 

Page 22 GAO-12-591 DOE’s Isotope Program

clear objectives, program officials cannot determine how important one 

isotope on a list is relative to isotopes on the other lists because they are 

prioritized using different criteria, or they are not prioritized. For example, 

• thallium-203 is ranked as the most important isotope on the National 

Isotope Development Center’s list of stable isotopes; 

• actinium-225, astatine-211, and lead-212 are identified as the most 

important isotopes in medicine, pharmaceuticals, and biology in the 

report of the Nuclear Science Advisory Committee’s isotope 

subcommittee; and

• californium-252 and radium-225 are identified as the most important 

isotopes for physical science and engineering in this same report.

Without consolidating the multiple lists of high-priority isotopes, however, 

it is unclear which isotopes have greater priority than others. Thus, 

program managers may not be focusing limited resources on the most 

important isotopes. 

Furthermore, because the program does not have clear objectives, it 

cannot be assured that it is assessing and mitigating risks from all 

relevant external and internal sources. In particular, the program has not 

assessed risks associated with relying on a small handful of isotopes for a 

large percentage of annual revenue. This issue is important in the context 

of the unexpected decline in strontium-82 orders that occurred in 2011, 

which resulted in a large reduction in expected revenue. The program 

likely could not have anticipated this loss, but comprehensive risk 

assessment efforts might have identified the risk of relying on strontium82 and a few other isotopes for a large amount of revenue. Without 

identifying all relevant risks, the program also cannot determine how to 

manage such risks. When the strontium-82 orders declined, the program 

was able to rely on its revolving fund to make up for unexpected revenue 

loss, but it may not always be able to do so. Isotope Program officials told 

us there is no guiding document for how the revolving fund should be 

spent or managed. Without guidance on how to manage the revolving 

fund in a way that helps mitigate risk, the program cannot be assured that 

it will be able to continue using the fund to both advance program 

missions and mitigate risks. For example, if the program unexpectedly 

loses revenue for several years in a row, the revolving fund may not 

provide sufficient reserves to maintain program operations.
 

Page 23 GAO-12-591 DOE’s Isotope Program

Managing the production and sale of over 300 different isotopes for 

various research, commercial, industrial, and medical applications is a 

daunting task. With a wide variety of customers, whose needs may 

change over time, it is difficult for the Isotope Program to determine 

demand, plan production, and project revenue streams to avoid shortages 

of important isotopes or interruptions in the revenues that help to sustain 

the program. The Isotope Program is taking several actions to assess 

demand and plan production. In addition, the Isotope Program has clearly 

defined under what circumstances it will charge reduced prices for 

research isotopes. The program has not, however, defined what factors it 

will consider when it sets prices for isotopes sold commercially, including 

defining under what circumstances it will set prices for such isotopes at or 

above full cost recovery. Without transparency in decisions on pricing, it is 

unclear if Isotope Program officials are setting prices consistently. 

Moreover, in the absence of established market prices and without 

current information on the value customers place on isotopes and prices 

of similar products, the Isotope Program cannot ensure that the prices it 

sets are appropriate and thus may be forgoing revenues that could be 

used to further its mission and ensure the program’s long-term viability.

As the Isotope Program moves forward with its process to establish a 5-

year strategic plan, creating clear goals and objectives is the first step in 

being able to identify and manage risks to achieving the program’s 

mission. Identifying high-priority isotopes that may need additional 

oversight is a good step toward managing risks, but without consolidating 

those lists and prioritizing them, program managers may not direct limited 

resources toward the most important isotopes.

Finally, when the Isotope Program’s revenues from strontium-82 

unexpectedly stopped, program officials were fortunate to have the 

revolving fund to mitigate the unexpected loss in revenue and maintain 

operations without disrupting supplies of other isotopes. Without clear 

guidance on when and how to use the revolving fund to mitigate future 

unexpected losses in revenue, the program cannot ensure that it will have 

sufficient funds to maintain operations, or for other activities, such as 

funding research and other projects that help the Isotope Program 

achieve its mission.

Conclusions
 

Page 24 GAO-12-591 DOE’s Isotope Program

We are making four recommendations to the Secretary of Energy 

designed to improve the Isotope Program’s transparency in setting prices 

and efficiency in managing isotopes. Specifically, we recommend that the 

Secretary of Energy direct the Isotope Program to take the following four 

actions:

• Clearly define the factors to be considered when the program sets 

prices for isotopes sold commercially, including defining under what 

circumstances it will set prices at or above full cost recovery. This 

should include assessing, when appropriate, current information on 

the value of isotopes to customers and the prices of similar products.

• In conjunction with strategic planning efforts already under way, 

create clear goals and objectives to serve as a basis for risk 

assessment, identify risks to achieving its goals and objectives, and 

determine what actions to take to manage the risks.

• Consolidate the lists of high-priority isotopes so the program can 

ensure that its resources are focused on the most important isotopes. 

• Establish clear guidance for managing the revolving fund to ensure 

that the fund is sufficient to use as a contingency for unexpected 

losses in revenue.

We provided a draft of this report to DOE for review and comment. In its 

written response, reproduced in appendix II, DOE explained that our 

recommendations will generally be addressed through the Isotope 

Program’s current efforts to update its pricing policy and develop a 

strategic plan. DOE took exception, however, to our characterization of 

how the Isotope Program sets prices for commercial isotopes. 

Specifically, according to DOE’s letter, the Isotope Program does 

consider “value of isotopes to customers” when setting prices for 

commercial isotopes. Nevertheless, none of the documents provided by 

the Isotope Program during our review show that the program conducted 

a current, formal analysis of what customers are willing to pay for 

commercial isotopes. Our report points out that program officials gain a 

sense of the value customers place on commercial isotopes through 

informal interactions with the customers themselves. Such interactions, in 

our view, do not provide a rigorous approach to determining a customer’s 

value for commercial isotopes as customers generally strive to obtain 

needed materials, including isotopes, at the lowest possible cost. We are 

encouraged to see that, according to DOE’s comments, the Isotope 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 25 GAO-12-591 DOE’s Isotope Program

Program’s updated pricing policy is to identify which factors are to be 

considered in setting prices, including formal analysis of the value of 

commercial isotopes to customers.

In its comments, DOE expressed concern that our report suggests 

maximizing revenue and pricing commercial isotopes to increase 

revenue. DOE explained that the Isotope Program generally sets prices to 

fulfill the mandate established by the Atomic Energy Act of 1954 to 

provide isotopes at prices that do not discourage their use. Our report 

does not emphasize maximizing revenue or setting prices solely to 

increase revenue. It does point out that the Isotope Program has not 

performed the formal market analyses required by its own pricing policy. 

DOE further stated that the Isotope Program considers several factors 

when determining prices for commercial isotopes, including a “bottom-up 

activity-based costing for isotope production,” and it has initiated two 

market studies that will provide input into the assessment of market 

prices. Comprehensive market studies would determine the prices 

customers are willing to pay for isotopes and prices of alternatives, 

among other factors, and would thus determine if the Isotope Program’s 

prices for commercial isotopes are set at the appropriate level. Such 

analyses would also show whether the full-cost-recovery price, which is 

used for all but three of the commercially sold isotopes, is resulting in 

unintended, but avoidable, consequences. General economic 

considerations suggest that setting prices of isotopes at artificially low 

levels could have unintended consequences such as discouraging other 

entities from producing isotopes, discouraging commercial entities and 

researchers from developing alternatives, and encouraging 

overconsumption. Furthermore, our report points out that the Atomic 

Energy Act of 1954 states that isotope prices should not discourage 

commercial isotope producers from entering the market.

With regard to our recommendations, DOE’s letter indicates that three of 

our four recommendations are being addressed through the Isotope 

Program’s present efforts to update its pricing policy and develop a 

comprehensive strategic plan and risk assessment. With regard to our 

fourth recommendation—to consolidate and prioritize isotopes from the 

lists of high-priority isotopes—DOE stated that it “will need to assess the 

value added of doing an overall prioritization.” DOE further states that 

even though an isotope may be a high priority for the isotope community, 

there is no guarantee that an entity is capable of producing it. In our view, 

this situation highlights the need for our recommendation. The Isotope 

Program has done outreach with the isotope community to identify the 

most important isotopes and has created a peer-review process that 
 

Page 26 GAO-12-591 DOE’s Isotope Program

considers isotopes on the various high-priority lists as one of its factors in 

selecting projects for funding. This process alone, however, cannot 

ensure that the program’s resources are accurately focused on the mostneeded isotopes. Therefore, we believe it is up to the Isotope Program to 

consolidate the lists of high-priority isotopes and develop criteria to 

determine on which isotopes resources are to be focused.

Finally, DOE’s letter stated that we mischaracterized NNSA’s mission, 

which does not include providing isotopes to stakeholders. We clarified 

this statement and have made changes throughout the report as needed. 

DOE also provided technical comments that we incorporated in the report 

as appropriate. 

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the appropriate 

congressional committees, Secretary of Energy, and other interested 

parties. In addition, the report will be available at no charge on the GAO 

website at http://www.gao.gov. 

If you or your staff members have any questions about this report, please 

contact me at (202) 512-3841 or aloisee@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix III.

Gene Aloise

Director

Natural Resources and Environment
Appendix I: Isotopes Available from DOE’s 

Isotope Program

Page 27 GAO-12-591 DOE’s Isotope Program

This table identifies the isotopes provided at the time of this report for sale 

by the Department of Energy’s (DOE) Isotope Development and 

Production for Research and Applications program (Isotope Program). 

According to Isotope Program officials, the availability of these isotopes 

may change and some isotopes may be provided in different chemical 

forms. For example, bromine-79 is available as sodium bromide but also 

as potassium bromide, silver bromide, and ammonium bromide. The table 

also shows how the Isotope Program classifies each isotope—as a 

radioisotope or stable isotope—and if an isotope is provided by the 

National Nuclear Security Administration (NNSA) and sold by the Isotope 

Program. 

Isotope Radioisotope Stable isotope Provided by NNSA

Actinium-225 X 

Americium-243 X X 

Antimony-121 X 

Antimony-123 X 

Argon-36 X 

Argon-40 X 

Arsenic-72 X 

Arsenic-73 X 

Barium-130 X 

Barium-132 X 

Barium-134 X 

Barium-135 X 

Barium-136 X 

Barium-137 X 

Barium-138 X 

Berkelium-249 X 

Beryllium-7 X 

Bismuth-207 X 

Bromine-79 X 

Bromine-81 X 

Cadmium-106 X 

Cadmium-108 X 

Cadmium-109 X 

Cadmium-110 X 

Cadmium-111 X 

Cadmium-112 X 

Appendix I: Isotopes Available from DOE’s 

Isotope Program
Appendix I: Isotopes Available from DOE’s 

Isotope Program 

Page 28 GAO-12-591 DOE’s Isotope Program

Isotope Radioisotope Stable isotope Provided by NNSA

Cadmium-113 X 

Cadmium-114 X 

Cadmium-116 X 

Calcium-40 X 

Calcium-42 X 

Calcium-43 X 

Calcium-44 X 

Calcium-46 X 

Calcium-48 X 

Californium-249 X 

Californium-252 X 

Carbon-12 X 

Cerium-136 X 

Cerium-138 X 

Cerium-140 X 

Cerium-142 X 

Chlorine-35 X 

Chlorine-37 X 

Chromium-50 X 

Chromium-52 X 

Chromium-53 X 

Chromium-54 X 

Cobalt-60 X 

Copper-63 X 

Copper-65 X 

Copper-67 X 

Curium-244 X X 

Curium-248 X X 

Dysprosium-156 X 

Dysprosium-158 X 

Dysprosium-160 X 

Dysprosium-161 X 

Dysprosium-162 X 

Dysprosium-163 X 

Dysprosium-164 X 

Dysprosium-166 X 

Erbium-162 X 
Appendix I: Isotopes Available from DOE’s 

Isotope Program

Page 29 GAO-12-591 DOE’s Isotope Program

Isotope Radioisotope Stable isotope Provided by NNSA

Erbium-164 X 

Erbium-166 X 

Erbium-167 X 

Erbium-168 X 

Erbium-170 X 

Europium-151 X 

Europium-153 X 

Gadolinium-148 X 

Gadolinium-152 X 

Gadolinium-154 X 

Gadolinium-155 X 

Gadolinium-156 X 

Gadolinium-157 X 

Gadolinium-158 X 

Gadolinium-160 X 

Gallium-69 X 

Gallium-71 X 

Germanium-68 X 

Germanium-70 X 

Germanium-72 X 

Germanium-73 X 

Germanium-74 X 

Germanium-76 X 

Gold-199 X 

Hafnium-174 X 

Hafnium-176 X 

Hafnium-177 X 

Hafnium-178 X 

Hafnium-179 X 

Hafnium-180 X 

Helium-3 X X 

Holmium-166 X 

Indium-113 X 

Indium-115 X 

Iridium-191 X 

Iridium-192 X 

Iridium-193 X 
Appendix I: Isotopes Available from DOE’s 

Isotope Program

Page 30 GAO-12-591 DOE’s Isotope Program

Isotope Radioisotope Stable isotope Provided by NNSA

Iron-52 X 

Iron-54 X 

Iron-55 X 

Iron-56 X 

Iron-57 X 

Iron-58 X 

Krypton-78 X 

Krypton-80 X 

Krypton-82 X 

Krypton-84 X 

Krypton-86 X 

Lanthanum-138 X 

Lanthanum-139 X 

Lead-204 X 

Lead-206 X 

Lead-207 X 

Lead-208 X 

Lithium-6 X X 

Lithium-7 X X 

Lutetium-175 X 

Lutetium-176 X 

Lutetium-177 X 

Magnesium-24 X 

Magnesium-25 X 

Magnesium-26 X 

Magnesium-28 X 

Mercury-196 X 

Mercury-198 X 

Mercury-199 X 

Mercury-200 X 

Mercury-201 X 

Mercury-202 X 

Mercury-204 X 

Molybdenum-92 X 

Molybdenum-94 X 

Molybdenum-95 X 

Molybdenum-96 X 
Appendix I: Isotopes Available from DOE’s 

Isotope Program

Page 31 GAO-12-591 DOE’s Isotope Program

Isotope Radioisotope Stable isotope Provided by NNSA

Molybdenum-97 X 

Molybdenum-98 X 

Molybdenum-100 X 

Neodymium-142 X 

Neodymium-143 X 

Neodymium-144 X 

Neodymium-145 X 

Neodymium-146 X 

Neodymium-148 X 

Neodymium-150 X 

Neon-22 X 

Nickel-58 X 

Nickel-60 X 

Nickel-61 X 

Nickel-62 X 

Nickel-63 X 

Nickel-64 X 

Nitrogen-15 X 

Osmium-184 X 

Osmium-186 X 

Osmium-187 X 

Osmium-188 X 

Osmium-189 X 

Osmium-190 X 

Osmium-192 X 

Oxygen-16 X 

Palladium-102 X 

Palladium-104 X 

Palladium-105 X 

Palladium-106 X 

Palladium-108 X 

Palladium-110 X 

Platinum-190 X 

Platinum-192 X 

Platinum-194 X 

Platinum-195 X 

Platinum-196 X 
Appendix I: Isotopes Available from DOE’s 

Isotope Program

Page 32 GAO-12-591 DOE’s Isotope Program

Isotope Radioisotope Stable isotope Provided by NNSA

Platinum-198 X 

Plutonium-238 X X 

Plutonium-239 X 

Plutonium-240 X 

Plutonium-241 X 

Plutonium-242 X X 

Polonium-209 X 

Potassium-39 X 

Potassium-40 X 

Potassium-41 X 

Radium-223 X 

Radium-225 X 

Rhenium-185 X 

Rhenium-186 X 

Rhenium-187 X 

Rubidium-83 X 

Rubidium-85 X 

Rubidium-87 X 

Ruthenium-96 X 

Ruthenium-97 X 

Ruthenium-98 X 

Ruthenium-99 X 

Ruthenium-100 X 

Ruthenium-101 X 

Ruthenium-102 X 

Ruthenium-104 X 

Samarium-144 X 

Samarium-147 X 

Samarium-148 X 

Samarium-149 X 

Samarium-150 X 

Samarium-152 X 

Samarium-153 X 

Samarium-154 X 

Selenium-72 X 

Selenium-74 X 

Selenium-75 X 
Appendix I: Isotopes Available from DOE’s 

Isotope Program

Page 33 GAO-12-591 DOE’s Isotope Program

Isotope Radioisotope Stable isotope Provided by NNSA

Selenium-76 X 

Selenium-77 X 

Selenium-78 X 

Selenium-80 X 

Selenium-82 X 

Silicon-28 X 

Silicon-29 X 

Silicon-30 X 

Silicon-32 X 

Silver-107 X 

Silver-109 X 

Sodium-22 X 

Strontium-82 X 

Strontium-84 X 

Strontium-85 X 

Strontium-86 X 

Strontium-87 X 

Strontium-88 X 

Strontium-90 X 

Sulfur-32 X 

Sulfur-33 X 

Sulfur-34 X 

Sulfur-36 X 

Tantalum-180 X 

Tantalum-181 X 

Technetium-95 X 

Technetium-96 X 

Technetium-99 X 

Tellurium-120 X 

Tellurium-122 X 

Tellurium-123 X 

Tellurium-123a X 

Tellurium-124 X 

Tellurium-125 X 

Tellurium-126 X 

Tellurium-128 X 

Tellurium-130 X 
Appendix I: Isotopes Available from DOE’s 

Isotope Program 

Page 34 GAO-12-591 DOE’s Isotope Program 

Isotope Radioisotope Stable isotope Provided by NNSA 

Thallium-203 X 

Thallium-205 X 

Thorium-227 X 

Thorium-228 X 

Tin-112 X 

Tin-114 X 

Tin-115 X 

Tin-116 X 

Tin-117 X 

Tin-117a X 

Tin-118 X 

Tin-119 X 

Tin-120 X 

Tin-122 X 

Tin-124 X 

Titanium-44 X 

Titanium-46 X 

Titanium-47 X 

Titanium-48 X 

Titanium-49 X 

Titanium-50 X 

Tungsten-180 X 

Tungsten-182 X 

Tungsten-183 X 

Tungsten-184 X 

Tungsten-186 X 

Tungsten-188 X 

Uranium-234 X 

Uranium-235 X X 

Uranium-238 X X 

Vanadium-48 X 

Vanadium-49 X 

Vanadium-50 X 

Xenon-124 X 

Xenon-126 X 

Xenon-127 X 

Xenon-129 X 
Appendix I: Isotopes Available from DOE’s 

Isotope Program

Page 35 GAO-12-591 DOE’s Isotope Program

Isotope Radioisotope Stable isotope Provided by NNSA

Xenon-131 X 

Xenon-134 X 

Xenon-136 X 

Ytterbium-168 X 

Ytterbium-170 X 

Ytterbium-171 X 

Ytterbium-172 X 

Ytterbium-173 X 

Ytterbium-174 X 

Ytterbium-176 X 

Yttrium-88 X 

Zinc-64 X 

Zinc-65 X 

Zinc-66 X 

Zinc-67 X 

Zinc-68 X 

Zinc-70 X 

Zirconium-88 X 

Zirconium-90 X 

Zirconium-91 X 

Zirconium-92 X 

Zirconium-94 X 

Zirconium-96 X 

Source: DOE.

a

Tellurium-123 and tin-117 each has two forms offered by the Isotope Program, one that is stable and 

a second that emits radiation when it decays to the stable state. 
Appendix II: Comments from the Department 

of Energy

Page 36 GAO-12-591 DOE’s Isotope Program

Appendix II: Comments from the Department 

of Energy
Appendix II: Comments from the Department 

of Energy

Page 37 GAO-12-591 DOE’s Isotope Program
Appendix II: Comments from the Department 

of Energy

Page 38 GAO-12-591 DOE’s Isotope Program
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 39 GAO-12-591 DOE’s Isotope Program

Gene Aloise, (202) 512-3841 or aloisee@gao.gov

In addition to the individual named above, Ned H. Woodward, Assistant 

Director; Wyatt R. Hundrup; Katherine Killebrew; and Michael Krafve 

made key contributions to this report. Eric Bachhuber, Ellen W. Chu, R. 

Scott Fletcher, Cindy Gilbert, Jonathan Kucskar, Mehrzad Nadji, and 

Timothy M. Persons also made important contributions.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(361311)
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