Rocky Flats Closure Legacy

Thank you for taking the time to read some or all of this Rocky Flats Closure Legacy report. The Rocky Flats Closure Project spanned over a decade and was unique in many ways. Recognizing that uniqueness this report takes a unique approach to sharing the lessons learned from the project, by considering not only the technical and scientific lessons, but also the policy and programmatic issues. Communicating “lessons learned” and reaching the target audience has always been difficult. This report was developed recognizing the challenge of communicating lessons learned as discussed in DOE-STD-7501-99, The DOE Corporate Lessons Learned Program. The overall Legacy Project seeks to address that challenge in several ways:

• First, the Rocky Flats Closure Legacy report is introduced by the “Rocky Flats – A Proud Legacy, A New Beginning” brochure, an 18-page, full color summary of the project history. This summary of the Rocky Flats Closure Legacy introduces themes that are explained in more detail by this report, and the visually engaging format is intended to increase interest toward pursuing the more detailed lessons learned. (See /lm/rocky-flats-site-colorado for info.)
• Second, this report does not try to represent all viewpoints, or consensus positions reinforcing current DOE policy. Rather it tries to fairly and accurately represent the conditions and influences that existed during the 10-year span of the project from the viewpoint of the DOE/Rocky Flats Managers and staff, and how the DOE and others reacted to them at the time.
• Third, it is brutally frank. The Rocky Flats Closure Project ended well, ahead of schedule, under budget, and with no major injuries to workers. However, hundreds of events occurred along the way, some we learned from at the time and others only became clear in hindsight. It is only through a frank and open look at the project history and lessons, both good and bad, that we can hope to learn and improve for the future.

As the responsible DOE- Rocky Flats Manager at final site closure, I have assembled this report from over three years of diverse excerpts on lessons of various types. However, the report has been prepared to chronicle the full history of the project, and as such capture events and lessons involving previous Rocky Flats Managers and the myriad of other participants. Many people know some of the history and lessons at Rocky Flats. From this comprehensive report both DOE employees and non-DOE may learn from the complete story. I believe there are lessons for us all in the story of the Rocky Flats Closure.

   Frazer R. Lockhart
   Manager, Department of Energy
   Rocky Flats Project Office

The purpose of this Rocky Flats Closure Legacy report is to capture the successes and failures of the Rocky Flats closure experience. The Legacy report fulfills the guidance for capturing lessons learned found in the following DOE documents:

• DOE Order 413.3
• DOE M 231.1A -Chg1
• Office of Legacy Management Terms and Conditions for Transition
• DOE-STD-7501-99
• EM Quality Assurance Plan

Although a substantial amount of information is provided, this document is not a template for success, since there is not a single recipe for this. There is no formula that can be applied to every site, since each site is different geographically, in terms of cleanup scope and future mission, and with different cultural and political issues. However, this document presents the experience at Rocky Flats to provoke thought about the vision, mission, project progress, and cooperation of the parties at other Environmental Management sites. And before the Rocky Flats experience is dismissed as an anomaly, it is hoped that some of the lessons from Rocky Flats will be carried forward and adapted to the closure experience at other sites.

Conversations between people that have contributed to the Rocky Flats Closure Project invariably lead to speculation as to why the project was successful. What is said and heard will depend upon the role played by the individuals...the regulators were cooperative...the contractor was incentivized and motivated...the DOE delivered most of its government furnished services and equipment on time...the budget appropriations were consistent and reliable at $650 million per year...closure was managed as a finite project and using project management principles...stakeholders were involved in project planning...workers were involved in work planning. While each person brings a unique perspective, most will agree that no single factor was responsible for achieving accelerated closure, but that in some measure all of these factors and more were necessary for success. Some observers have stated that Rocky Flats was lucky. While there was certainly a measure of good fortune, Rocky Flats was poised and willing to take advantage of it whenever it did materialize.

Beyond any specific innovation, it was through unparalleled cooperation among the interested parties that a conservative and compliant cleanup and closure of Rocky Flats was enabled; ahead of schedule, under cost, and without a fatality or serious injury. For  some individuals, engagement in the process of closing and transitioning Rocky Flats was derived from a dedication to the vision and mission. For others it was a more calculated commitment to what was achievable. But regardless of motivation, and with the exception of a few citizen activist groups, each party recognized that it was at the confluence of interests, rather than the satisfaction of any one particular interest, that the vision of accelerated closure would be realized. 

It was also realized that while the plant was undergoing risk reduction, the participants in the cleanup would need to take some political and programmatic risks if this project was to be successful. When Congress committed to the closure fund and to a 2006 closure for Rocky Flats they did not have available to them a final integrated project baseline. When the Kaiser-Hill  Company L.L.C. (K-H) signed the cleanup contract, Site characterization was not complete and DOE had not lined up the necessary assistance from Carlsbad, Savannah River, Oak Ridge, Richland, LANL, LLNL, and others important to the success of Rocky Flats materials disposition. The regulators had not yet agreed to align project milestones with the lifecycle baseline. The community had not yet agreed to cleanup levels. Long standing issues of distrust needed to be overcome, yet, each of these organizations understood the opportunity to remove the risk from metropolitan Denver, to turn a liability into an asset and to focus  on a common vision, even when disagreeing on some of the details. And so, while debates about issues such as cleanup levels, dirty demolition, landfill capping, and 903 Pad remediation were acrimonious at times, they did not cause the cleanup mission to unravel. And when external barriers to closure were encountered, these same groups were largely united in their efforts to remove the barriers.

There are many lessons-learned from the Rocky Flats Closure Project included in this report. Although it is recognized that these lessons are not always directly applicable to every DOE clean-up effort, it is hoped that in some way they can be beneficial to every DOE site, and in fact, any controversial cleanup effort. We consider the following lessons, summarized here and addressed in more detail later in the report, as universally applicable:

• SAFETY IS JOB 1: This lesson was reinforced throughout the closure project. If work cannot be safely performed, then the project grinds to ahalt. Early on in the project it was recognized that a significant investment in hazard identification, safety planning, and safety implementation during the actual work (i.e., the DOE’s Integrated Safety Management System) ensured that work was performed safely without unacceptable risks or unnecessary delays to correct safety deficiencies. Later in the project we came to understand that safety focus did not merely enable work, but facilitated efficiency and acceleration by building trust and engaging the workforce.
• CONTRACT REFORM WORKS: The Rocky Flats "experiment" proved that the DOE’s contract reforms worked. The first K-H "Integrating Management" contract demonstrated that incentivizing clearly defined performance measures vastly improved actual results. In fact, the performance measures sometimes worked too well, incentivizing results at odds with the ultimate goals of the contract. The Closure Contract took the concept to the next level, providing large incentives to the company and the workers to safely and compliantly complete the clean-up and closure scope within a target scope and cost. Additional incentives for schedule and cost savings resulted in closure more than one year ahead of schedule and $530 million under the contract budget.
• WHAT, NOT HOW: The DOE must manage to a contract, not manage the work for the contractor. The contractor must learn to respond to contractual direction and not DOE informal requests. This was a difficult transition at Rocky Flats due to years of conditioning from the "Management & Operations" contract approach typical at large DOE sites. Ultimately, the DOE Rocky Flats learned (although not perfectly) to define the work scope and standards that must be met and observe, evaluate, and report to the manager and contracting officer regarding the contractor's performance on the terms of the contract. This did not undermine, but enhanced DOE’s safety and compliance oversight because the contract clearly required the contractor to work safely and compliantly in accordance with clearly defined requirements in the contract. Ultimately DOE's safety and compliance oversight became more objective and technical issues became less subjective as the DOE was forced to clearly cite a contractual non-compliance that required correction per the contract.
• COLLABORATIVE WORKING RELATIONSHIPS: As described in detail throughout this report, the Rocky Flats Closure was successful because the stakeholders (in the broadest sense of the word) were engaged in the process and supportive of the ultimate goal. The interests of numerous key figures, including Members of Congress, senior DOE management, state and local elected officials, and state and federal regulators, were actively solicited and ultimately met – the regulatory cleanup agreement, closure contract, desired end state and project parameters were brought to convergence. We communicated openly and often to seek the best solutions, and came to value the input from formerly dogmatic opponents. Although there were differences in the details, the entire Rocky Flats community shared a common goal: Make It Safe - Clean It Up - Close It Down.
• DON’T WAIT FOR ALL GREEN LIGHTS, BE READY: As the analogy states, "If we waited for every light to be green we would never get anywhere."  The Site moved steadily, ploddingly, painfully, but inexorably toward one goal: 2006 Closure. Early in the project this goal seemed unachievable, in 2003 we started to believe we could beat 2006, and by 2004 the momentum was established to finish in 2005. Nonetheless, if we had focused on what we couldn’t do in 1995, when K-H took over the Site, or 1999, when the DOE was trying to open WIPP, or 2002, when we were fighting in court to ship plutonium to SRS, or throughout the project as we debated "how clean is clean enough?" then we would still be sitting here talking about when will Rocky Flats be done. The fact is, we’re done! We didn’t have all the answers at the beginning but we made course corrections along the way. Good fortune favors those ready to take advantage of the opportunity and momentum builds with progress. Define your goal and get moving!

We hope you can use this report and its lessons as a springboard for action at your respective sites. It is the sincere hope of everyone involved with the Rocky Flats Closure Project that the legacy of Rocky Flats will not be "Look what we did here" but rather, "Look what started here."

The Rocky Flats Closure Legacy report is organized into the following topical areas. The first five sections focus on the strategic issues necessary to establish and sustain the closure project:

• 1 - Accelerated Closure Concept
• 2 - Congressional Support
• 3 - Regulatory Framework  
• 4 - Contract Approach  
• 5 - Projectization  

The remaining ten sections focus on issues associated with implementation of the project:

• 6 - Safety Integration  
• 7 - Special Nuclear Material Removal  
• 8 - Decommissioning  
• 9 - Waste Disposition  
• 10 - Environmental Restoration  
• 11 - Security Reconfiguration  
• 12 - Technology Deployment  
• 13 - Future Land Use, End State, and Stewardship  
• 14 - Federal Workforce  
• 15 - Stakeholder Involvement 

The sections are designed to be independent, but also mutually reinforcing. Each section may be read as a stand-alone report, and enough background is provided to give the context and relevance of the section's topic area within the overall Rocky Flats Closure Project. In contrast, a user that reads the entire report from cover to cover will see certain themes and fundamental aspects of the project repeated, being reinforced and interwoven through multiple sections. The intent of this design was to make the lessons readily accessible to readers with a wide variety of backgrounds and interests. The effect can be compared to viewing the same events through different colored lenses, such that the focus of each section is highlighted against the backdrop of the total project. The most fundamental themes and lessons, present to some degree in almost every section, are reflected in the Executive Summary as the "bottom line".

The section format is designed to facilitate both general scanning for topics of interest and detailed discussion of the section topic. Margin quotes are provided to focus attention on key elements of the discussion. A "case study" format, with underlined titles at the beginning of a topic covered in the next few paragraphs also facilitates identification of topics of interest. The "Introduction" subsection is followed by a "Discussion" subsection that contains the details of the project approach and is sometimes further subdivided. The section concludes with a "Key Success Factors" subsection that summarize what Rocky Flats learned in the topic area. Citations are provided both by section and summarized in Appendix 1.

Strategic Planning

• 1 - Accelerated Closure Concept (1-1 — 1-18)  
• 2 - Congressional and Executive Administrative Support (2-1 — 2-18)  
• 3 - Regulatory Framework (3-1 — 3-29)  
• 4 - Contract Approach (4-1 — 4-16)  
• 5 - Projectization (5-1 — 5-23)

Project Implementation

• Safety Integration (6-1 — 6-24)  
• Special Nuclear Material Removal (7-1 — 7-15)  
• Decommissioning (8-1 — 8-25)  
• Waste Disposition (9-1 — 9-15)  
• Environmental Restoration (10-1 — 10-22)  
• Security Reconfiguration (11-1 — 11-18)  
• Technology Deployment (12-1 — 12-36)  
• Future Land Use, End State, and Stewardship (13-1 — 13-16)  
• Federal Workforce (14-1 — 14-14)  
• Stakeholder Involvement (15-1 — 15-19)  

Table Of Figures

• Figure 1-1, Rocky Flats Environmental Technology Site 1995 versus 2005 (Page 1-1)  
• Figure 1-2, Map of proposed boundaries for the DOE Retained lands and the future Rocky Flats Wildlife Refuge lands (Page 1-2)  
• Figure 1-3, RFETS Location Map; major facilities within the former industrial area (DOE Retained Lands) (Page 1-3)  
• Figure 1-4, RFETS Timeline of Major Events (Page 1-3)  
• Figure 1-5, Key Leaders Impacting the Rocky Flats Site Closure (Page 1-5)  
• Figure 1-6, Accelerated Closure Evolution (Page 1-14)  
• Figure 2-2, Key Leaders Impacting the Rocky Flats Site Closure (Page 2-5)  
• Figure 9-1, Location of Principal Rocky Flats Waste Disposition Sites (Page 9-2)  
• Figure 9-2, Transuranic Waste Shipments (Page 9-5)  
• Figure 14-1, Rocky Flats Federal Staffing Levels (Page 14-2)