Defense Nuclear Facilities Safety Board (DNFSB) 

Analysis of FY 2011 Service Contract Inventories 

Background: DNFSB is a small, independent agency (operating at 109 Full-time Equivalents 

(FTEs) in FY 2011) with responsibility for the oversight of the Department of Energy (DOE)’s 

defense nuclear facilities located throughout the United States. DNFSB’s mission as described 

by the Atomic Energy Act is to ensure that the public health and safety are adequately protected 

at the DOE defense nuclear facilities. Over 60% of DNFSB’s employees are engineers or 

scientists directly supporting its mission. DNFSB has a small administrative support staff 

responsible for the full range of administrative support functions, of whom approximately 1.5 

FTEs perform procurement (e.g., 1102) duties. DNFSB’s total obligations for supplies and 

services in FY 2011 were less than $4M. 

The analysis was performed by DNFSB’s senior Contracting Officer and has been concurred 

with by the Senior Procurement Executive and Chief Human Capital Officer. 

Special Interest Functions Studied: DNFSB had limited obligations in special interest 

functions, $130,000 under Engineering and Technical Services (R425), and $107,000 under 

Policy Review/Development Services (R406), each representing approximately 4% of 

obligations. Each special interest function was studied. 

Methodology Used to Support the Analysis: As the special interest function only consisted of 

two (2) contracts (one for each function), members of the acquisition workforce working on both 

contracts were interviewed. 

Agency Findings: 

1) DNFSB has no personal services contract obligations. 

2) A review of the special interest function contracts indicated none of the work performed 

under Engineering and Technical Services was closely associated with inherently 

governmental functions, and thus no special management attention was necessary for that 

contract. The work performed under Policy Review/Development Services was closely 

associated with inherently governmental functions, and special management attention 

was put in place. That attention included assignment of sufficient qualified Government 

employees for oversight and enhanced reporting requirements. In addition, it is clearly 

known within the agency that the applicable tasks were performed by a contractor. 

3) A review of the special interest function contracts indicated that DNFSB was not using 

contractor employees to perform inherently governmental functions. 

4) DNFSB has specific safeguards in place to ensure that the work being performed by 

contractors under this special interest function has not changed or expanded during 

performance to become an inherently governmental function (e.g., the Contracting 

Officer reviews all deliverables). 

5) A review of the special interest function contracts indicated that DNFSB is not using 

contractor employees to perform critical functions in such a way that could affect the 

ability of the agency to maintain control of its mission and operations. 

6) There are sufficient internal agency resources to manage and oversee contracts 

effectively. 

Explanation of Action Taken or Planned to Resolve Identified Weaknesses: NA, no 

weaknesses identified.