AUDIT

REPORT

DECONTAMINATION AND

DECOMMISSIONING AT THE

EAST TENNESSEE TECHNOLOGY

PARK

U.S. DEPARTMENT OF ENERGY

OFFICE OF INSPECTOR GENERAL

OFFICE OF AUDIT SERVICES

DECEMBER 1998

ER-B-99-01
DEPARTMENT OF ENERGY

Washington, DC 20585

December 21, 1998

MEMORANDUM FOR THE MANAGER, OAK RIDGE OPERATIONS OFFICE

FROM: Terry L. Brendlinger, Manager

Eastern Regional Audit Office

Office of Inspector General

SUBJECT: INFORMATION: Audit Report on “Decontamination and Decommissioning at the East

Tennessee Technology Park”

BACKGROUND 

The East Tennessee Technology Park (ETTP) contains about 400 buildings with approximately

14.4 million square feet of space. Almost 90 percent of the space is comprised of buildings that are

currently undergoing or are planned for decontamination and decommissioning (D&D). Departmental

policy requires that D&D projects be prioritized based on employee and public health and safety,

protection of the environment, compliance with environmental laws and regulations, cost-effectiveness,

and future site plans. The objective of this audit was to determine whether the Oak Ridge Operations

Office (Operations Office) reduced health, safety, and environmental risks through D&D projects at the

ETTP.

RESULTS OF AUDIT 

The Operations Office reduced health, safety, and environmental risks through D&D projects at the

ETTP. However, the major ongoing D&D project at the ETTP did not involve the facility which posed

the greatest risks from exposure to radioactive waste, hazardous or toxic materials, and structural

collapse. This condition occurred because the Operations Office did not fully emphasize reductions of

health, safety and environmental risks when it selected and performed D&D projects at the ETTP. As a

result, a high-risk facility continues to deteriorate, and hazards to workers and the environment are

increased. Also, the Department could incur $34.5 million in unnecessary surveillance and maintenance

costs between FYs 1998 and 2002 for a building which poses significant risks to workers and the

environment. We recommended that the Operations Office require that D&D projects be selected and

performed with greater emphasis on reducing health, safety, and environmental risks for workers and the

public.

MANAGEMENT REACTION 

Management did not concur with the finding, recommendation, or estimated monetary impact in the

report. Management stated that the decision to decontaminate and decommission Buildings K-29, K-31,

and K-33 before Building K-25 was an appropriate approach to risk reduction due to the complexity and

hazardous nature of process equipment dismantlement and the associated risks posed to demolition

workers.
-2-

We determined that the overall health and safety risks to ETTP workers would be reduced if

Building K-25 was decontaminated and decommissioned before Buildings K-29, K-31, and K-33.

Management’s response centers on the possible risk to demolition workers; however, it does not

give adequate consideration to the daily health and safety risks experienced by workers who enter

the K-25 vaults to perform surveillance and maintenance activities.
Overview 

Introduction and Objective .........................................................1

Conclusions and Observations..................................................2

Decontamination and Decommissioning 

Details of Finding ......................................................................3

Recommendation and Comments .............................................5

Appendix 

Scope and Methodology ............................................................8

Decontamination and Decommissioning at the East

Tennessee Technology Park

TABLE OF

CONTENTS
Page 1

INTRODUCTION AND

OBJECTIVE

The ETTP, formerly known as the K-25 Site, occupies about

4,700 acres, or 14 percent of the Oak Ridge Reservation. ETTP was

established in 1942 to produce enriched uranium. Since the production

mission ended in 1987, ETTP has focused on environmental

management activities. These activities include maintaining facilities

pending decisions about their disposition, characterizing and managing

hazardous materials and conditions, and preparing for and performing

D&D. The ETTP contains about 400 buildings totaling approximately

14.4 million square feet of space. Almost 90 percent (12.5 million

square feet) consists of buildings that are currently undergoing or are

planned for D&D.

The Operations Office is responsible for identifying contaminated

facilities at the ETTP, documenting the potential for reuse and recovery

of materials and equipment, and developing schedules for

decommissioning facilities. Departmental policy requires that D&D

projects be prioritized based on worker and public health and safety,

protection of the environment, compliance with environmental laws and

regulations, cost-effectiveness, and future site plans.

The Department's Office of Environment, Safety and Health performed

an oversight review of the safety management of disposition efforts at

the ETTP and issued a report in September 1997 entitled Special

Review: Safety Management Evaluation of Facility Disposition

Programs at the East Tennessee Technology Park. The review team

concluded that the Operations Office had made limited progress in

decommissioning contaminated buildings scheduled for demolition. One

of the contaminated buildings was the subject of the Operations Office's

For-Cause Review of Worker Respiratory Illnesses Associated with

Working in the K-25 Vaults at the East Tennessee Technology Park,

issued in June 1998. The review concluded that mold, fungi, and

bacteria growing in the vaults resulted in some workers' respiratory

illnesses.

In October 1997, the Office of Inspector General reported adverse

conditions in the D&D program at the Department's Savannah River

Site. Report ER-B-98-01, Audit of the Deactivation, Decontamination,

and Disposal of Surplus Facilities at the Savannah River Site,

concluded that Westinghouse Savannah River Company did not

completely deactivate or decontaminate any of the 162 facilities

identified as surplus in FY 1996.

Overview

Decontamination and Decommissioning

at the East Tennessee Technology Park
Page 2

The objective of this audit was to determine whether the Operations

Office reduced health, safety, and environmental risks through D&D

projects at the ETTP.

The Operations Office reduced health, safety, and environmental risks

through D&D projects at the ETTP. However, the major ongoing D&D

project at the ETTP did not involve the facility which posed the greatest

risks from exposure to radioactive waste, hazardous or toxic materials,

and structural collapse. This condition occurred because the Operations

Office did not fully emphasize reductions of health, safety, and

environmental risks when it selected and performed D&D projects at the

ETTP. As a result, a high-risk facility continues to deteriorate, and

hazards to workers and the environment are increased. Also, the

Department could incur $34.5 million in unnecessary surveillance and

maintenance costs between FYs 1998 and 2002 for a building which

poses significant risks to workers and the environment.

The audit identified issues that management should consider when

preparing its yearend assurance memorandum on internal controls.

 /S/

 Office of Inspector General

Decontamination and Decommissioning

at the East Tennessee Technology Park

CONCLUSIONS AND

OBSERVATIONS
Page 3

The major ongoing D&D project at the ETTP did not involve the facility

which posed the greatest risks from exposure to radioactive waste,

hazardous or toxic materials, and structural collapse. The Operations

Office awarded a $238 million contract for the D&D of three enriched

uranium process buildings (K-29, K-31, and K-33) in August 1997.

However, the health, safety, and environmental risks associated with

Buildings K-29, K-31, and K-33 were not as significant as the risks

associated with Building K-25.

Building K-25 is the oldest process building and has been shutdown

23 years longer than the other process buildings. The roof of Building

K-25 has leaked, and the water has accumulated on the operating floor,

causing floor panels to collapse. Additionally, water has leaked into

vaults used to store packaged Resource Conservation and Recovery Act

waste, low-level waste, and waste awaiting disposal in the Toxic

Substances Control Act incinerator. ETTP personnel were required to

enter the vaults on a daily basis to perform surveillance and maintenance

activities. As of August 1998, the roof leaks were not repaired and the

wastes were not removed from the building. According to a for-cause

review performed by the Operations Office, the accumulation of

moisture and the lack of ventilation were ideal conditions for the growth

of mold, fungi, and bacteria. Further, a series of employee concerns and

issues related to working in or near the vaults were raised as far back as

1992.

Departmental Order 5820.2A establishes policies and guidelines for the

management, decontamination, and decommissioning of radioactively

contaminated facilities under Departmental ownership or control. The

order requires that Departmental organizations manage radioactively

contaminated facilities in a safe, cost-effective manner to assure that the

release of, and exposure to, radioactivity and other hazardous materials

comply with Federal and state standards. Program offices are required

to identify contaminated facilities under their jurisdiction, document the

potential for reuse and recovery of materials and equipment, and

develop schedules for decommissioning the facilities. Departmental

policy requires that D&D projects be prioritized based on worker and

public health and safety, protection of the environment, compliance with

environmental laws and regulations, cost-effectiveness, and future site

plans.

Details of Finding

The Operations Office Is

Required to Manage

Contaminated Facilities in

a Safe and Cost-Effective

Manner

DECONTAMINATION AND DECOMMISSIONING

Decontamination and

Decommissioning Had

Not Begun for Building

K-25
Page 4

The Policy on Decommissioning of Department of Energy Facilities

Under the Comprehensive Environmental Response, Compensation,

and Liability Act (CERCLA) issued May 1995, establishes the

approach agreed upon by the Department and the Environmental

Protection Agency for the conduct of decommissioning projects

consistent with CERCLA requirements. The policy’s objective is to

reduce risk without unnecessary delay and is based on the goal of

earlier guidance “to develop decisions that appropriately address the

reduction of risk to human health and the environment as

expeditiously as the law allows.” 1

The Operations Office did not fully emphasize reductions of health,

safety, and environmental risks when it selected and performed D&D

projects at the ETTP. Despite Building K-25’s deteriorating

condition, it was not scheduled to begin D&D until FY 2003. The

Operations Office stated that it started the D&D of Buildings K-29,

K-31, and K-33 because it received a proposal to complete the

buildings for $550 million less than previously estimated.

Management stated that since other factors, such as long-term

surveillance and maintenance cost, risk to workers and the

environment, and the critical path for ETTP closure, were relatively

equal between the two projects, it decided to undertake Buildings

K-29, K-31, and K-33 first to take advantage of the large cost

savings.

We determined that the large cost savings cited by the Operations

Office was primarily related to the contracting method used rather

than the specific project selected. In December 1995, the

management and operating contractor (M&O) at the ETTP estimated

it would cost $817 million to decontaminate Buildings K-29, K-31,

and K-33 using M&O labor and overhead. Then, in November 1996,

the Operations Office solicited proposals for the decontamination of

the buildings from contractors other than the M&O. The Operations

Office received proposals and awarded a contract in August 1997 for

a fixed price of $238 million. The price was substantially less than

previously proposed by the M&O because (1) the Operations Office

awarded a fixed-price contract to a private contractor using

______________________________

1 Guidance on Accelerating CERCLA Environmental Restoration at Federal

Facilities, established by the Environmental Protection Agency, Department of

Energy, and Department of Defense; August 22, 1994.

Details of Finding

Operations Office Did Not

Fully Emphasize Health and

Safety Risk Reduction
Page 5

competitive procedures rather than negotiating a cost-reimbursable task

order with the M&O; (2) the Department agreed to transfer ownership

of the decontaminated metals removed from the buildings to the new

contractor rather than require the M&O to dispose of the metals after

they were decontaminated; and (3) the contractor's overhead and fees

were lower than those proposed by the M&O. If the same contracting

method was used to decontaminate Building K-25, we estimate that a

similar cost savings could be realized.

In addition to the health and safety risks, the Department could incur

$34.5 million in unnecessary surveillance and maintenance costs for

Building K-25 before it is demolished in FY 2003. As a result of its size

and rapidly deteriorating condition, Building K-25 accounted for more

than one-third of the surveillance and maintenance costs incurred at the

ETTP in FY 1997. It will cost the Department about $51.3 million to

maintain Building K-25 in its current condition until it can be demolished

in FY 2003. However, it would have cost the Department only

$16.8 million to maintain Buildings K-29, K-31, and K-33 in their

current condition until FY 2003. Therefore, the Department could avoid

$34.5 million in surveillance and maintenance costs by demolishing

Buildings K-25 before decontaminating and decommissioning Buildings

K-29, K-31, and K-33.

We recommend that the Manager, Oak Ridge Operations Office require

that D&D projects be selected and performed with greater emphasis on

reducing health, safety, and environmental risks for workers and the

public.

Management did not concur with the finding, recommendation, or

estimated monetary impact. Management stated that the decision to

decontaminate and decommission Buildings K-29, K-31, and K-33

before Building K-25 was an appropriate approach to risk reduction due

to the complexity and hazardous nature of process equipment

dismantlement and the associated risks posed to demolition workers.

Management stated that Buildings K-29, K-31, and K-33 were

configured in such a way that supports dismantlement. Problems

associated with uranium deposits are more easily handled considering

both the low assay of the deposits and the maintenance support

infrastructure designed into these buildings. Management stated that the

conditions are considerably different in Building K-25, which was

configured with multiple confined spaces that present a considerable

Recommendation and Comments

Unnecessary Costs Are

Incurred for Surveillance

and Maintenance

RECOMMENDATION

MANAGEMENT REACTION
Page 6

hazard to dismantlement workers. Also, management stated that

Building K-25 contains multiple bulky deposits of uranium in assays

over 20 percent.

Management stated that there is no release of radioactive

contamination or hazardous or toxic materials, and there is no threat

of external structural collapse in Building K-25. It is management’s

opinion that Building K-25 can be maintained to contain the

contamination and is safe for limited use by personnel with

administrative controls, engineered constraints, and personnel

protective equipment until major funding is available to begin

dismantlement.

Management concluded that the decision to proceed with the D&D of

Buildings K-29, K-31, and K-33 provides a proving ground for these

efforts while maintaining worker safety. The knowledge obtained

from that effort will be transferred to support safe dismantlement of

Building K-25.

Finally, management disagreed with the estimated cost savings of

$34.5 million. Management stated that the D&D of Buildings K-29,

K-31, and K-33 before Buildings K-25 and K-27 will result in a cost

savings of up to $147 million. Management stated that the

surveillance and maintenance costs for Buildings K-25 and K-27 are

high and will continue to increase; however, the costs to maintain

Buildings K-29, K-31, and K-33 would also increase if D&D were

deferred. For example, Building K-33 would need a new roof.

Further, the delay in decommissioning Buildings K-29, K-31, and K33 might cause the buildings to be torn down rather than reused,

resulting in a substantial cost increase over the current project for

reuse.

We disagree with management’s statement that the decision to

decontaminate Buildings K-29, K-31, and K-33 before Building K-25

was an appropriate approach to risk reduction. Management’s

conclusion centers on the possible risk to demolition workers.

However, it does not give adequate consideration to the daily health

and safety risks experienced by ETTP workers who are required to

enter the K-25 vaults to perform surveillance and maintenance

activities.

Recommendation and Comments

AUDITORS COMMENTS
Page 7

Management’s estimate of cost savings was not supported. In its

calculation of the $147 million cost savings, management included

$33 million for surveillance and maintenance costs for a 7 to 10 year

period, $30 million for a new roof and other major repairs for Building

K-33, and $84 million for the demolition of the buildings. However,

this calculation is flawed for three reasons. First, the cost of

surveillance and maintenance is much greater for Building K-25 than

for Buildings K-29, K-31, and K-33. Management stated that, for a

7 to 10 year period, surveillance and maintenance costs for the three

buildings would be about $33 million. By comparison, the

surveillance and maintenance costs for Building K-25 would be

$101.6 million for a 10 year period. Second, we question

management’s assertion that Building K-33 needs $30 million in repairs

since the contractor performing D&D activities on K-33 has not

been asked to perform repair work. Finally, we disagree with

management’s methodology whereby both the cost of repairs and the

cost of demolition are used as a basis for determining cost savings.

Management estimated that the cost to repair Building K-33 was

$30 million. Management also estimated the cost of demolishing the

buildings at $84 million. We do not believe management would spend

$30 million repairing a building it planned to demolish in the near

future.

Recommendation and Comments
Page 8

Appendix

The audit was performed from August 4, 1997, to June 12, 1998, at the

Operations Office and the ETTP. The scope of the audit included 123

facilities in the D&D program at the ETTP. FY 1997 surveillance and

maintenance costs for the D&D program at the ETTP were about

$22 million. The Operations Office developed an integrated

prioritization process which included D&D, waste management, and

remedial action projects. As of February 1998, there were 260 projects

ranked in the prioritization.

To accomplish the audit objective we:

• Reviewed Federal and Departmental regulations for the

D&D process;

• Analyzed the costs and risks associated with D&D projects

at the ETTP;

• Reviewed estimated repair and annual surveillance and

maintenance costs for the five uranium process buildings at

the ETTP;

• Evaluated the effectiveness of the Operations Office’s

prioritization system; and

• Held discussions with Departmental and contractor personnel

regarding D&D activities.

The audit was performed in accordance with generally accepted

Government auditing standards for performance audits and included

tests of internal controls and compliance with laws and regulations to the

extent necessary to satisfy the audit objective. Accordingly , we

assessed significant internal controls related to the D&D of facilities at

the ETTP. Because our review was limited, it would not necessarily

have disclosed all internal control deficiencies that may have existed at

the time of our audit. We did not conduct a reliability assessment of

computer-processed data because only a very limited amount of

computer-processed data was used during this audit.

We held an exit conference with the Assistant Manager for

Environmental Restoration on December 9, 1998.

SCOPE

METHODOLOGY

Scope and Methodology
IG Report No. ER-B-99-01 

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