Department of Energy: Accelerated Closure of Rocky Flats: Status and
Obstacles (Chapter Report, 04/30/99, GAO/RCED-99-100).
Pursuant to a congressional request, GAO reviewed the Department of
Energy's (DOE) ability to close the Rocky Flats Environmental Technology
Site by the end of 2006, focusing on: (1) DOE's plans for accelerating
the site's closure and challenges that could impede closure; (2) the
condition of the site at closure and the activities that will remain
after closure; and (3) the costs of closing the site and the savings
expected from accelerating its closure.
GAO noted that: (1) while DOE and the Kaiser-Hill Company have had some
success in accelerating cleanup activities, it is questionable whether
they can meet DOE's target date of 2006 for cleaning up and closing
Rocky Flats at the costs and savings originally projected; (2) they face
numerous challenges, significant compression of scheduled activities,
and unresolved issues relating to the disposal of certain wastes and the
site's condition at closure; (3) Kaiser-Hill has encountered delays in
implementing its plan to close the site in 2010 and expects to have a
detailed plan and schedule for closing the site by the end of 2006 in
May 1999; (4) DOE and Kaiser-Hill believe that the contractor can take
advantage of learning curves and efficiencies gained through early
efforts to expedite cleanup and closure activities; (5) DOE and
Kaiser-Hill must overcome various challenges to accelerate key
activities to close the site by the end of 2006; (6) while plans for
closing the site depend on other organizations within and outside DOE to
take the site's materials and wastes for storage or disposal, several
types of materials and wastes have no sites available to take them; (7)
DOE and Kaiser-Hill officially maintain that the contractor can close
the site by the end of 2006; (8) DOE, the Environmental Protection
Agency (EPA), and Colorado have agreed on the condition of the site when
it is closed; (9) nevertheless, many specific decisions still must be
made; (10) if a more stringent cleanup level will be required than the
interim level agreed to by DOE, EPA, and Colorado, the site's closure
could be delayed; (11) developing plans and cost estimates for the site
after closure will be difficult until agreement has been reached on all
aspects of the site's closure and on future uses of the site; (12) the
costs of cleaning up and closing Rocky Flats could be higher than DOE's
official estimate; (13) although DOE has not validated the accuracy of
the estimate, DOE and contractor site managers maintain that the site
can be closed for $7.3 billion; (14) the contractor's 1998 detailed cost
estimate, based on the costs of specific projects needed to close the
site, totalled $8.4 billion; (15) these estimates do not include the
costs that will be incurred after the site is closed; (16) the savings
estimate for accelerating the site's closure from 2010 to 2006 was based
on avoiding the costs of operating and maintaining the site for 4 years;
and (17) if the cleanup and closure can be accelerated, health and
safety risks may be reduced and financial benefits may be achieved.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: RCED-99-100
TITLE: Department of Energy: Accelerated Closure of Rocky Flats:
Status and Obstacles
DATE: 04/30/99
SUBJECT: Nuclear waste management
Cost control
Nuclear waste disposal
GOCO
Nuclear facilities
Strategic planning
Cost analysis
Obsolete facilities
Cost overruns
IDENTIFIER: Colorado
New Mexico
DOE Long-Term Surveillance and Maintenance Program
DOE Rocky Flats Cleanup Agreement
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rc99100.book GAO United States General Accounting Office
Report to the Chairman, Committee on Armed Services, U. S. Senate
April 1999 DEPARTMENT OF ENERGY
Accelerated Closure of Rocky Flats: Status and Obstacles
GAO/RCED-99-100
GAO/RCED-99-100
GAO United States General Accounting Office
Washington, D. C. 20548 Lett er Resources, Community and Economic
Development Division
B-282092 Letter April 30, 1999 The Honorable John W. Warner
Chairman, Committee on Armed Services United States Senate
Dear Mr. Chairman: In response to your request, this report
reviews the Department of Energy's ability to close the Rocky
Flats Environmental Technology Site by the end of 2006.
Specifically, it examines (1) DOE's plans for accelerating the
site's closure and challenges that could impede closure; (2) the
condition of the site at closure and the activities that will
remain after closure; and (3) the costs of closing the site and
the savings expected from accelerating its closure.
As arranged with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 15 days after the date of this letter. At that time, we will
send copies of this report to the Honorable Bill Richardson,
Secretary of Energy; the Honorable Jacob Lew, Director, Office of
Management and Budget; and other interested parties. Copies will
also be made available to others upon request.
Please call me at (202) 512- 3841 if you or your staff have any
questions. Major contributors to this report are listed in
appendix II.
Sincerely yours, (Ms.) Gary L. Jones Associate Director, Energy,
Resources, and Science Issues
Page 2 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
Executive Summary Purpose In 1989, the Rocky Flats Environmental
Technology Site stopped making
plutonium components for nuclear weapons, leaving the Department
of Energy (DOE) with the challenge of managing and cleaning up
nearly 40 years' worth of contamination at the site. Compared with
the other sites in DOE's former nuclear weapons production
complex, Rocky Flats has some of the most dangerous and highest-
risk materials and facilities. Currently, DOE is spending
approximately two- thirds of the site's annual budget of nearly
$700 million to maintain the site in a relatively safe and secure
state, with the remaining one- third going to cleanup. Partly
because of these high maintenance costs, the Department developed
plans in fiscal year 1994 to clean up and close the site.
Subsequently, DOE advanced the site's goal for closure several
times, from the original date of 2070 to the current date of 2006.
Concerned about the Department's ability to meet its current goal
to close Rocky Flats by the end of 2006, the Chairman of the
Senate Committee on Armed Services asked GAO to review (1) DOE's
plans for accelerating the
site's closure and challenges that could impede closure; (2) the
condition of the site at closure and the activities that will
remain after closure; and (3) the costs of closing the site and
the savings expected from accelerating its closure.
Background The Rocky Flats site, located at the base of Colorado's
Rocky Mountains, lies about 16 miles northwest of Denver. More
than 2.5 million people live within a 50- mile radius of the site.
Of particular concern are the site's special nuclear materials--
such as plutonium and uranium-- and radioactive
wastes, which pose substantial risks to workers, the public, and
the environment. In 1995, after entering into a 5- year contract
with DOE to manage Rocky Flats, Kaiser- Hill Company, L. L. C.,
began to stabilize and consolidate these materials for safe
storage until they could be removed from the site. Kaiser- Hill
and DOE also began to arrange for other DOE and commercial
facilities to receive the various radioactive and hazardous
materials and wastes that had accumulated at the site or were by-
products of cleanup activities. Some wastes will be generated in
large quantities throughout the site's cleanup.
In 1996, DOE signed the Rocky Flats Cleanup Agreement with the U.
S. Environmental Protection Agency (EPA) and the state of
Colorado, the primary regulators of cleanup activities at Rocky
Flats. Under the cleanup agreement, special nuclear materials will
be removed by 2015; other
Executive Summary Page 3 GAO/RCED-99-100 Accelerated Closure of
Rocky Flats
radioactive and hazardous wastes will be removed; and all
buildings will be decontaminated, decommissioned, and demolished.
DOE plans to close the site when those tasks are complete. Also in
1996, DOE's Office of Environmental Management revamped its plans
for cleaning up the
Department's contaminated sites, attempting to accelerate the
closure of sites and coordinate cleanup activities across the DOE
complex. In response, in 1997, Kaiser- Hill proposed advancing
Rocky Flats' closure to 2010. 1 This plan remains in effect today,
even though DOE has since accelerated the target date for closing
the site to the end of 2006.
The cleanup and closure of Rocky Flats involves not only DOE and
the site's contractor and subcontractors but also regulatory and
oversight agencies and others with an interest in the site's
cleanup and closure. In addition to EPA and Colorado, the site's
regulatory and oversight bodies include the Department of the
Interior's Fish and Wildlife Service and the
Defense Nuclear Facilities Safety Board. Other interested parties-
- or stakeholders-- include local governments; citizen, community,
business, and environmental groups; and individuals.
Results in Brief While DOE and Kaiser- Hill have had some success
in accelerating cleanup activities, it is questionable whether
they can meet the Department's target
date of 2006 for cleaning up and closing Rocky Flats at the costs
and savings originally projected. They face numerous challenges,
significant compression of scheduled activities, and unresolved
issues relating to the
disposal of certain wastes and the site's condition at closure.
Kaiser- Hill has encountered delays in implementing its plan to
close the site in 2010 and expects to have a detailed plan and
schedule for closing the site by the end of 2006 in May 1999. DOE
and Kaiser- Hill believe that the
contractor can take advantage of learning curves and efficiencies
gained through early efforts to expedite cleanup and closure
activities. However, DOE and Kaiser- Hill must overcome various
challenges to accelerate key activities to close the site by the
end of 2006. For example, they have to compress the 2010 schedule,
which calls for decontaminating and decommissioning the majority
of the site's buildings from 2005 through 2007 and demolishing
over two- thirds of the buildings in 2006 or later. However, the
contractor has not determined how to compress these 1 The 2010
plan is based on closing the site by the end of fiscal year 2010.
Executive Summary Page 4 GAO/RCED-99-100 Accelerated Closure of
Rocky Flats
activities enough to close the site by the end of 2006, and some
site officials question both the feasibility of compressing the
schedule and the availability of resources, especially of
qualified workers. Furthermore, while the plans for closing the
site depend on other organizations within and outside the
Department to take the site's materials and wastes for
storage or disposal, several types of materials and wastes--
including some low- level radioactive waste and some uranium--
have no sites available to take them. Nevertheless, DOE and
Kaiser- Hill officially maintain that the contractor can close the
site by the end of 2006, primarily by taking advantage of lessons
learned and efficiencies gained through experience.
DOE, EPA, and Colorado have agreed, in general, on the condition
of the site when it is closed. Nevertheless, many specific
decisions still must be made. Issues remaining to be resolved
include how the site will be used in the future and what level of
cleanup will be required. If a more stringent cleanup level will
be required than the interim level agreed to by DOE, EPA, and
Colorado, the site's closure could be delayed. In addition, DOE is
just starting to consider issues that will be important after the
site is closed,
such as who will own, monitor, and maintain the site and what
barriers will be used to prevent exposure to residual
contamination. Developing plans and cost estimates for the site
after closure will be difficult until agreement has been reached
on all aspects of the site's closure and on future uses of the
site.
The costs of cleaning up and closing Rocky Flats could be higher
than DOE's official estimate of $7. 3 billion 2 for fiscal year
1997 through fiscal year 2010. Although DOE has not validated the
accuracy of this estimate,
DOE and contractor site managers maintain that the site can be
closed for $7. 3 billion. However, the contractor's 1998 detailed
cost estimate, based on the costs of specific projects needed to
close the site, totaled $8.4 billion. Assumptions underlying both
estimates have changed or have the potential to change, generally
indicating higher costs. In addition, these estimates do not
include the costs that will be incurred after the site is closed,
which could range from hundreds of millions to billions of dollars
over a period of the first 30 to 40 years. Finally, the savings
estimate for accelerating the site's closure from 2010 to 2006 was
based on avoiding the costs of operating and maintaining the site
for 4 years. Therefore, if closure occurs after 2006, the savings
could be less than DOE's $1.3 billion
2 Unless otherwise noted, dollar values represent the sum of
annual expenditures and incorporate an annual 2.7- percent
increase for expected inflation.
Executive Summary Page 5 GAO/RCED-99-100 Accelerated Closure of
Rocky Flats
estimate. A preliminary estimate presented by the contractor in
February 1999 indicates that the savings from closing the site by
the end of 2006 could be lower.
DOE's decision to accelerate the closure of Rocky Flats to 2006 is
laudable. If the cleanup and closure can be accelerated, health
and safety risks may be reduced and financial benefits may be
achieved. With the May 1999 issuance of Kaiser- Hill's detailed
plan for closing the site by the end of 2006, the likelihood of
this effort's success and the accompanying potential benefits will
become clearer.
Principal Findings DOE Faces Many Challenges in Accelerating the
Site's Closure
Although Kaiser- Hill does not expect to have detailed plans for
closing the site by the end of 2006 until May 1999, both DOE and
the contractor believe that the accelerated closure date is
feasible. While developing detailed plans, the contractor is
attempting to advance scheduled activities, especially those
viewed as critical to closing the site by the end of 2006.
However, some of the work completed to date has fallen behind the
existing schedule for closing the site in 2010. For example, the
contractor
has encountered delays in preparing several types of nuclear
wastes for removal, as well as delays in shipping special nuclear
materials from the site-- both considered key to closing the site
in 2010.
The contractor has identified four key activities that must be
accelerated to close the site by the end of 2006. These include
(1) removing about 106 metric tons of plutonium- contaminated
residues left over from nuclear weapons production; (2) shipping
approximately 16. 5 metric tons of special nuclear materials off-
site; (3) decontaminating and decommissioning the
site's 691 buildings and facilities; and (4) constructing barriers
to prevent exposure to residual contamination. The contractor has
had some successes in accelerating some of these activities.
However, challenges in implementing each of these activities could
hinder acceleration. For example, the site has had difficulty
readying the residues and special nuclear materials for removal
from the site; decontamination and decommissioning are costing
more and taking longer than anticipated; and DOE and the
contractor have not reached agreement with the site's regulators
or stakeholders on the use of protective barriers over portions of
the industrial area.
Executive Summary Page 6 GAO/RCED-99-100 Accelerated Closure of
Rocky Flats
Other challenges within and outside the Department could also
hinder closure. For example, the operation of DOE's Waste
Isolation Pilot Plant in New Mexico was delayed because of
regulatory issues and litigation. 3 Consequently, Rocky Flats
could not dispose of radioactive waste there. In addition, several
types of orphan materials and wastes-- including some
low- level radioactive and hazardous wastes and some uranium
contaminated with plutonium or hazardous materials-- have no site
available to take them. To overcome these challenges, DOE is
working
with the site's regulators and stakeholders to coordinate Rocky
Flats' cleanup and closure activities with other organizations
within and outside the Department. However, DOE's progress in
accelerating the site's closure will depend, in part, on the
priority given to Rocky Flats' activities by other DOE sites and
organizations; the availability of transportation resources; and
litigation, which is largely outside DOE's control.
Status of the Site at Closure and Activities Required After
Closure Have Not Been Defined
Although there is general consensus that Rocky Flats should be
closed, DOE has not reached agreement with regulators or other
stakeholders on specifics of the condition of the site at closure
or on its future uses. According to DOE, it is moving forward on
decisions concerning the closure of the site and activities after
closure in accordance with the
regulatory requirements governing the site's cleanup. In the
meantime, DOE and the contractor are basing their closure plans
and estimates on broad goals and objectives addressed in the Rocky
Flats Cleanup Agreement. These include removing the site's special
nuclear materials, radioactive and hazardous wastes, and
buildings, as well as cleaning up the site's 6,000- acre buffer
zone for use as open space and its 385- acre former production
area for potential industrial use or for use as restricted open
space. Decisions or changes to assumptions about the status of
Rocky Flats at closure could affect current and future cleanup
requirements and, therefore, the feasibility of closing the site
by the end of 2006. For example, the specifics of the future uses
of the site are still undecided. Similarly, the interim soil
cleanup level agreed to by DOE and the regulators has been
questioned by local governments and by citizen and environmental
groups. A change to a more stringent cleanup level could
3 The Waste Isolation Pilot Plant is DOE's deep geologic
repository for transuranic and transuranic mixed waste, located in
an underground salt formation near Carlsbad, New Mexico. On Mar.
26, 1999, DOE made its first shipment to the facility from Los
Alamos. DOE anticipates beginning shipments from Rocky Flats over
the next several months.
Executive Summary Page 7 GAO/RCED-99-100 Accelerated Closure of
Rocky Flats
entail more cleanup work and could ultimately affect the site's
closure date.
DOE is just beginning to consider how Rocky Flats will be used
after it is closed. No decisions have been made about whether
additional cleanup or the removal of roads and other remaining
infrastructure will be required; who will own, monitor and
maintain the site; or what kinds of barriers (physical or legal)
will be used to prevent exposure to residual contamination at the
site. Although DOE is developing draft guidance for all of its
sites on activities and responsibilities after closure, this
guidance will take several years to develop. In any event, until
DOE and the
regulators have agreed on the condition of the site at closure and
its future uses, DOE may not be able to plan effectively for
activities after closure.
Costs of Closing Rocky Flats May Be Higher Than Estimated
DOE's official estimate of the costs to clean up and close Rocky
Flats is $7. 3 billion. This estimate is based on a 1997 proposal
by Kaiser- Hill to close the site in 2010. Both DOE and the
contractor maintain that the site can be closed in 2010 for $7.3
billion; however, several factors suggest that the costs could be
substantially higher. First, Kaiser- Hill's mid- level managers
responsible for specific projects necessary for closure recently
estimated that it would cost $8.4 billion to close the site. This
estimate was based on the same major assumptions and schedule that
Kaiser- Hill used
for the $7. 3 billion estimate. Finally, a number of assumptions
underlying the $7. 3 billion estimate have changed or have the
potential to change in ways that would generally increase costs.
For example, the contractor's assumptions about the costs of
decontaminating and decommissioning the site's facilities changed
with experience, causing the contractor to nearly triple the cost
estimate for these activities.
DOE's costs to manage Rocky Flats will not end when the site is
closed. Because DOE and the regulators have not yet defined DOE's
responsibilities after closure, DOE has not developed detailed
cost estimates. However, according to DOE site officials, DOE
could incur costs of as much as $100 million 4 for additional
cleanup; $20 million to $50
million per year for monitoring and maintenance, 5 and at least
$50 million 4 Unless otherwise noted, the cost estimates for
activities after closure are in fiscal year 1998 constant dollars
and are net of inflation.
5 Site officials estimate that the total cost of monitoring and
maintaining the site through 2040, including adjustments for
expected inflation, will be nearly $1.5 billion.
Executive Summary Page 8 GAO/RCED-99-100 Accelerated Closure of
Rocky Flats
per year for workers' pensions and benefits. In addition, DOE
could be exposed to litigation seeking compensation for damages
resulting from the effects of the site's activities on workers,
nearby residents, or natural resources.
DOE originally estimated that it would save $1.3 billion by
closing the site by the end of 2006 instead of in 2010. This
estimate represented the basic costs of operating and maintaining
the site for 4 years-- costs that DOE would avoid by closing the
site 4 years earlier. However, given the progress to date and the
challenges that remain, several site officials questioned the
feasibility of closing the site by the end of 2006. As long as the
site remains open, DOE will continue to incur operations and
maintenance costs, thereby reducing the savings. In addition, the
contractor's February 1999
preliminary cost estimate for closing the site by the end of 2006
indicated that the savings from closing the site 4 years earlier
may be only $700 million.
Recommendations This report makes no recommendations. Agency
Comments GAO provided a draft of this report to DOE for its review
and comment. The Department generally concurred with the facts of
the report, stating
that GAO had done a thorough job of documenting the complexity,
uncertainties, and challenges the Department is facing in
accelerating the closure of Rocky Flats. However, the Department
commented that while the report does note some of the site's
accomplishments, it does not adequately recognize the progress
already made or the obstacles already
overcome. GAO added material to the report to more thoroughly
discuss the actions that DOE has taken. In addition, the
Department raised a concern that the report identifies
uncertainties facing the site's closure that (1) are subject to
the regulations governing the cleanup, (2) are not at a point
where resolution is necessary, or (3) are not obstacles to closure
because the resolution of some uncertainties falls under the Rocky
Flats Cleanup Agreement. On the basis of DOE's comments, GAO added
information to the report, such as statements about the
Department's actions under the regulations governing the site's
cleanup, including the Comprehensive Environmental Response,
Compensation, and Liability Act. While DOE does not view the
issues discussed as obstacles to closure, GAO believes that the
issues could affect the site's closure because they are
Executive Summary Page 9 GAO/RCED-99-100 Accelerated Closure of
Rocky Flats
subject to a number of decisions and changes; as a result, GAO did
not revise this part of the report.
More detailed discussions of the Department's comments are
included at the end of chapters 2 and 3. The full text of DOE's
comments is presented in appendix I. The Department separately
provided a number of technical comments, and GAO revised the
report, where appropriate, to reflect them.
Page 10 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
Contents Executive Summary 2 Chapter 1 Introduction
History of Rocky Flats 12 Magnitude of the Cleanup and Closure
Effort 13 Parties Involved in Rocky Flats' Cleanup and Closure 22
Objectives, Scope, and Methodology 25
Chapter 2 Challenges to Accelerating the Site's Closure
Detailed Plan Assumes That the Site Will Be Closed in 2010 28
Numerous Challenges Could Hinder Efforts to Accelerate Closure 30
Coordination of Closure Activities Could Affect Acceleration 37
Challenges Outside DOE's Control Could Affect Closure 44
Observations 45 Agency Comments and Our Evaluation 46
Chapter 3 Status of the Site at Closure and Activities After
Closure Have Not Been Defined
Full Agreement on the Status of the Site at Closure Has Not Been
Reached 47 Decisions on the Status of the Site at Closure May
Affect Accelerated Cleanup 48 DOE's Activities and
Responsibilities After Closure Have Not Been Defined 53
Observations 55 Agency Comments and Our Evaluation 56
Chapter 4 Costs of Closing Rocky Flats May Be Higher Than
Estimated
Closure Costs May Be Higher Than Estimated 57 Costs After Rocky
Flats Is Closed Could Be Substantial 61 Estimated Savings May Be
Reduced 64
Appendixes Appendix I: Comments From the Department of Energy 66
Appendix II: Major Contributors to This Report 70
Related GAO Products 72 Figures Figure 1.1: Rocky Flats
Environmental Technology Site 12
Figure 1.2: Cutaway View of Transuranic Waste Drums 17 Figure 1.3:
Sample Pipe and Go Container for Residues to Be
Disposed of at the Waste Isolation Pilot Plant 18
Page 11 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
Figure 1.4: Remediation Activities at One of Rocky Flats'
Contaminated Environmental Sites 21 Figure 2.1: A Rocky Flats
Worker Handling Plutonium Residues in a
Glovebox 31 Figure 2.2: Diagram of the Layers of a Closure Cap 36
Figure 2.3: Sites That Have Accepted and Expect to Receive Rocky
Flats' Nuclear Materials and Wastes 39
Abbreviations
DOE Department of Energy CERCLA Comprehensive Environmental
Response, Compensation, and
Liability Act EPA Environmental Protection Agency GAO General
Accounting Office PCB polychlorinated biphenyl RCRA Resource
Conservation and Recovery Act TRUPACT Transuranic Package
Transporter WIPP Waste Isolation Pilot Plant
Page 12 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
Chapter 1 Introduction Chapt er 1
History of Rocky Flats Rocky Flats Environmental Technology Site,
shown in figure 1.1, occupies about 6,300 acres at the base of the
foothills of the Rocky Mountains, about 16 miles northwest of
Denver, Colorado. The site began operations in 1952 and, at the
height of the Cold War, was 1 of 16 major U. S. defense nuclear
facilities. Rocky Flats received plutonium that was manufactured
elsewhere and produced plutonium triggers, or pits, for nuclear
weapons.
Most nuclear materials and other hazardous substances used in the
production of plutonium pits were employed in the site's
industrial area- about 385 acres in the center of the site, where
most of the 691 buildings and facilities were located. The
remaining nearly 6, 000 acres served as a buffer zone to help
ensure the security of the nuclear material and of the
site's operations, as well as the safety of nearby residents.
Figure 1. 1: Rocky Flats Environmental Technology Site
Source: Kaiser- Hill.
For years, the site's principal regulators-- the Environmental
Protection Agency (EPA) and the state of Colorado-- expressed
concerns about potential threats to the environment and human
health and safety at Rocky Flats. In 1986, the Department of
Energy (DOE) signed an agreement with
EPA and Colorado to ensure compliance with certain environmental
regulatory requirements and to establish milestones for major
cleanup operations. However, in 1989, Federal Bureau of
Investigation agents and
Chapter 1 Introduction
Page 13 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
EPA officials raided Rocky Flats, responding to alleged violations
of federal environmental laws and regulations. After the raid, DOE
stopped production at the site. Environmental studies revealed
that, over time, radioactive and hazardous substances had been
released into the environment, contaminating the groundwater,
soil, and surface water at the
site. In 1991, DOE signed a new agreement with EPA and Colorado to
ensure compliance with environmental laws and regulations and to
set milestones for certain cleanup activities. However, DOE fell
behind these milestones and, in 1994, agreed to regulatory
penalties and supplemental environmental projects costing an
additional $2. 8 million.
In fiscal year 1994, the Department developed plans to close Rocky
Flats. In 1996, DOE signed another agreement with EPA and
Colorado, called the Rocky Flats Cleanup Agreement, which allowed
DOE and the regulators to set priorities, make decisions on
cleanup and closure, and establish decision- making processes. Of
particular concern to the regulators were the weapons- grade
special nuclear materials (plutonium and enriched uranium) and
other radioactive and hazardous materials left at the site when
production ceased. These materials pose substantial threats to the
environment and could jeopardize human health and safety. An
estimated 2.5 million persons live within 50 miles of Rocky Flats,
and recent growth around the site, including residential and
industrial construction adjacent to the buffer zone, has raised
concerns for DOE and the regulators about possible future uses of
the site.
Magnitude of the Cleanup and Closure Effort
When Rocky Flats was shut down in 1989, DOE assumed that the site
would resume production and left much of its 16. 5 metric tons 1
of special nuclear materials in processing systems or short- term
storage. But the site did not resume operations, and the short-
term storage proved inadequate for the longer term, especially for
plutonium, plutonium- contaminated
residues, and plutonium- and uranium- bearing solutions. In 1994,
DOE's Plutonium Working Group identified numerous problems with
Rocky Flats' storage of plutonium and contaminated residues,
including containers that had ruptured because the materials were
improperly packaged and stored. 2 The group also reported that
many of the site's buildings and much of the
equipment, some dating back to the 1950s and 1960s, had
deteriorated with 1 A metric ton is equal to 1 million grams, or
1.1 tons. 2 Plutonium Working Group Report on Environmental,
Safety and Health Vulnerabilities Associated with the Department's
Plutonium Storage (DOE/ EH- 0415, Nov. 1994).
Chapter 1 Introduction
Page 14 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
age. Furthermore, some of the safety systems for these buildings
and equipment had become unreliable. Today, DOE and its
contractor, KaiserHill, face massive challenges in cleaning up the
results of nearly 40 years' worth of nuclear weapons production--
removing the site's materials and
waste, cleaning up and demolishing the site's structures, and
reducing the contamination at the site to agreed upon levels. The
Site's Nuclear Materials and Wastes
To close the site, Kaiser- Hill must prepare and ship huge
quantities of materials and wastes from the site, many of them
radioactive. These activities must be largely completed before the
contractor can remove the site's structures and perform further
cleanup activities. Each type of material and waste presents its
own challenges. The type of processing
and packaging required for each type of nuclear material and waste
varies in complexity. Descriptions of the primary types of nuclear
materials and wastes follow.
Chapter 1 Introduction
Page 15 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
Special nuclear materials. When the decision was made to close
Rocky Flats, there were approximately 16. 5 metric tons of special
nuclear materials on the site about 6. 7 metric tons of enriched
uranium and
about 9. 8 metric tons of plutonium metals and oxides and
plutonium pits-- to prepare and ship off- site. Uranium is a
naturally occurring radioactive element that can be enriched to
increase the percentage of a particular uranium isotope for use in
nuclear weapons or as reactor fuel. Some of the site's enriched
uranium must be processed to remove plutonium contamination before
it can be packaged and shipped to a site designated to receive the
material. The contractor recently started
shipping enriched uranium to DOE's Oak Ridge Reservation and
expects to complete its shipments of uranium to this facility by
September 1999. The contractor reports that as of January 1999, it
had shipped 40 percent of the enriched uranium off- site.
Plutonium, a man- made radioactive element produced by irradiating
uranium in nuclear reactors, is primarily in the form of metals,
oxides (fine powders), and pits. The
plutonium metals and oxides must be stabilized before they can be
shipped. Stabilization includes brushing the metals to remove
loose oxides and heating the oxides to a high temperature to
remove moisture and other impurities, and reduce the potential for
dispersal. Both the
metals and the oxides must then be packaged in long- term storage
containers, which are packed into containers certified by the
regulators as safe for transporting special nuclear materials. 3
The contractor has not yet started shipping plutonium metals and
oxides. A plutonium pit is the central core of a nuclear weapon,
which can be compressed with high explosives to create a nuclear
explosion. 4 To be shipped from
Rocky Flats, the plutonium pits must be packaged in certified
transportation containers. As of January 1999, the contractor had
shipped about 80 percent of the plutonium pits off- site. Both the
plutonium and the enriched uranium must be shipped in specially
designed trucks and trailers. Residues. Residues are plutonium-
contaminated materials left over from nuclear weapons production,
such as plutonium- contaminated
ash; combustibles (including paper, rags, cloth, and gloves that
can ignite easily); fluorides (compounds containing fluorine);
salts (chloride
3 For additional information on the Department's management of its
plutonium, see Department of Energy: Plutonium Needs, Costs, and
Management Programs (GAO/RCED-97-98, Apr. 17, 1997) and Department
of Energy: Problems and Progress in Managing Plutonium (GAO/RCED-
98-68, Apr. 17, 1998).
4 In a thermonuclear weapon, the pit is the primary device that is
imploded to cause a fission reaction to generate heat and energy
to create a fusion reaction in the secondary part of the weapon.
Chapter 1 Introduction
Page 16 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
salts); sand, slag, and crucibles (from plutonium metal
production); and scrub alloy (a plutonium and aluminum alloy from
plutonium recovery operations). The plutonium content of these
residues ranges from onetenth of a percent to 80 percent. During
production, Rocky Flats retained its residues to recycle the
plutonium from them. When the site was shut down, it was left with
about 106 metric tons of residues, contaminated with about 3.1
metric tons of plutonium. Each type of residue may require a
different method of preparation for shipment;
some residues must be stabilized, while others can be processed
and packaged in their current form. The variety of residues, and
the mixture of other materials with them, makes their management
difficult. 5 The contractor is making progress in processing and
repackaging residues
and recently shipped a small quantity of more highly contaminated
and higher- risk residues to DOE's Savannah River site for
processing. Transuranic and transuranic mixed waste. Transuranic
waste is radioactive waste contaminated with elements heavier than
uranium,
such as plutonium, in concentrations above 100 nanocuries per gram
of waste. 6 This waste includes materials ranging from clothing
and gloves to pieces of equipment or other materials that are
contaminated with radioactivity. Figure 1.2 shows examples of
typical transuranic waste drums.
5 For additional information on Rocky Flats' residues, see Nuclear
Materials: Removing Plutonium Residues From Rocky Flats Will Be
Difficult and Costly (GAO/RCED-92-219, Sept. 4, 1992), Nuclear
Materials: Plutonium Storage at DOE's Rocky Flats Plant (GAO/RCED-
95-49, Dec. 29, 1994), and
Department of Energy: Problems and Progress in Managing Plutonium
(GAO/RCED-98-68, Apr. 17, 1998). 6 A nanocurie is one- billionth
of a curie, which is the amount of radioactivity in 1 gram of
radium.
Chapter 1 Introduction
Page 17 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
Figure 1. 2: Cutaway View of Transuranic Waste Drums
Source: Kaiser- Hill.
Transuranic mixed waste contains hazardous as well as radioactive
materials. The contractor at Rocky Flats plans to dispose of
approximately 14, 500 cubic meters of transuranic and transuranic
mixed waste generated
through former production activities or anticipated from the
decontamination, decommissioning, and demolition of the site's
buildings. In addition, the site plans to dispose of most of its
residues as transuranic waste after they are processed and
packaged in robust storage containers, called "pipe and go"
containers, that are then packed into 55- gallon drums (see fig.
1.3). In total, site officials expect the site could generate up
to 80, 000 drums of transuranic and transuranic mixed waste, which
must be
shipped in specially designed transportation casks. The contractor
has not
Chapter 1 Introduction
Page 18 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
started shipping its transuranic wastes because the facility
designated to receive these wastes, the Waste Isolation Pilot
Plant (WIPP) in New Mexico, has not been available to receive
these wastes. 7 The contractor is in the process of implementing
additional storage for the site's transuranic wastes to allow
processing and packaging and cleanup activities to continue while
the site awaits the ability of WIPP to take Rocky Flats'
transuranic wastes.
Figure 1. 3: Sample Pipe and Go Container for Residues to Be
Disposed of at the Waste Isolation Pilot Plant
Source: Kaiser- Hill.
Low- level and low- level mixed waste. Low- level waste has less
radioactive content than transuranic waste-- 100 or fewer
nanocuries per gram of waste. Low- level mixed waste is low- level
waste that contains hazardous materials. At Rocky Flats, these two
types of waste consist 7 WIPP is DOE's deep geologic repository
for transuranic and transuranic mixed waste, located in an
underground salt formation near Carlsbad, New Mexico. On Mar. 26,
1999, DOE made its first shipment to the facility from Los Alamos.
DOE anticipates beginning shipments from Rocky Flats over the next
several months.
Chapter 1 Introduction
Page 19 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
mainly of rags, paper, plastic, glassware, filters, soil, and
building rubble with low levels of contamination. Through cleanup
and closure, the site expects to ship over 180, 000 cubic meters
of low- level and low- level
mixed waste. Because this waste is less radioactive than
transuranic waste, it does not require the same degree of special
handling. After being packaged, it can be shipped by standard
semitrailer trucks and trailers. Site officials reported that, in
fiscal year 1998, the contractor shipped about 2,600 cubic meters
of the site's projected 143,000 cubic meters of low- level waste
to a disposal facility on DOE's Nevada Test
Site and about 6, 500 cubic meters of the site's projected 60, 000
cubic meters of low- level mixed waste to a commercial disposal
facility in Utah. According to DOE, the site has met its 1999
targets for shipments of low- level and low- level mixed waste.
Cleanup and Closure of the Site
In addition to preparing and shipping the site's nuclear materials
and waste, DOE and the contractor are cleaning up and demolishing
the site's structures and cleaning up the site for closure.
Decontamination and decommissioning of the site's 691 buildings
and facilities. This work involves removing or reducing
radioactive and/ or hazardous contamination to stabilize the
environment and to prepare the buildings and facilities for
demolition. Decontamination and
decommissioning may include dismantling equipment or scrubbing
down portions of buildings. One hundred thirty- one of the site's
691 buildings and facilities have some radiological contamination,
and 6 have significant radiological contamination. Others may be
contaminated with hazardous materials. As of March 1999,
decontamination and decommissioning had been completed for 48
buildings, 3 of which had some radiological contamination. In
addition, the contractor reported that as of March 1999, 7
additional buildings were being decontaminated and decommissioned-
- 3 with some
radiological contamination and 4 with significant radiological
contamination. Buildings and facilities on the site range from
small tanks to massive processing buildings, including tents,
trailers, towers, slabs, pads, stacks, and pipelines. Demolition
of nearly 3.5 million square feet of buildings and facilities.
After being decontaminated and decommissioned, the site's 691
buildings and facilities will be demolished. As of January 1999,
the contractor had demolished 48 buildings and facilities
comprising 109,266 square feet, or about 3 percent of the total
square footage. According to contractor officials, this is
consistent with the site's
Chapter 1 Introduction
Page 20 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
decontamination and decommissioning strategy, in which the
majority of facilities are demolished later in the closure
project. Remediation of 116 designated contaminated environmental
sites.
According to DOE, 116 of an estimated 367 environmental sites are
expected to require soil remediation. The 367 environmental sites
are locations on Rocky Flats where DOE and the regulators believed
there could be radioactive or hazardous contamination. A DOE
official reported that of 367 sites identified, 25 have been
remediated, 116 may still require remediation, and the remainder
may require no further
action, because further examination revealed or may reveal that
contamination levels are less than expected or nonexistent. The
116 environmental sites that may still require remediation include
areas where radioactive or hazardous materials were buried or
leaked. Remediation could include removing contaminated soil or
water or employing other treatment options. In addition, surface
water leaving the site must be safe for all uses, including
drinking. Some of these contaminated sites are beneath existing
structures, and their cleanup
will not begin until after the structures have been demolished.
Some environmental sites may be very complex and expensive to
clean up, while others may be less so. Other contaminated
environmental sites may be identified in the future, especially
because the amount and level of contamination in the industrial
area-- especially under the buildings- has
not yet been determined. Contractor officials expect that many of
the remaining environmental sites may not require further cleanup.
Figure 1.4 shows workers in protective clothing conducting
remediation activities at one of Rocky Flats' contaminated
environmental sites.
Chapter 1 Introduction
Page 21 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
Figure 1. 4: Remediation Activities at One of Rocky Flats'
Contaminated Environmental Sites
Source: Kaiser- Hill.
Disposal of up to 1 million items of personal property. Estimates
of the site's personal property (including computers, chairs, and
desks) vary- from approximately 600,000 to 1 million items--
because a complete inventory has not been done. 8 DOE officials
said that much of the
personal property is old and may be more of a liability than an
asset. Therefore, in May 1998, the site was authorized to use
expedited disposal methods, which allow the site to bypass certain
federal disposal requirements, including those for screenings to
determine whether other federal agencies can use the property
before disposing of it. However, before releasing property to the
public, the contractor must follow specific procedures to ensure
that items are not contaminated
with radiological or hazardous substances. According to the
contractor, from fiscal year 1996-- when the site started
disposing of its personal 8 For more information on Rocky Flats'
property management, see Department of Energy: The Property
Management System at the Rocky Flats Plant Is Inadequate
(GAO/RCED-94-77, Mar. 1, 1994), Department of Energy: Property
Management Has Improved at DOE's Rocky Flats Site (GAO/RCED-96-39,
Dec. 28, 1995), and Department of Energy: Management of Excess
Property (GAO/RCED-99-3, Nov. 4, 1998).
Chapter 1 Introduction
Page 22 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
property in preparation for closure-- through mid- February 1999,
Rocky Flats disposed of almost 100,000 items of personal property.
About onefourth of these items were disposed of using the
expedited procedures, which were implemented near the end of
fiscal year 1998.
Parties Involved in Rocky Flats' Cleanup and Closure
The cleanup and closure of Rocky Flats is a complex undertaking,
involving not only DOE; the site's primary contractor, Kaiser-
Hill; and subcontractors but also regulatory and oversight
agencies and others with an interest in the site's cleanup and
closure. The regulatory and oversight
bodies include the EPA, the state of Colorado, the Department of
the Interior's Fish and Wildlife Service, and the Defense Nuclear
Facilities Safety Board. Other stakeholders include local
governments; citizen,
community, business, and environmental groups; and individuals.
DOE DOE's Office of Environmental Management, a headquarters
organization,
is responsible for cleaning up the Department's nuclear weapons
complex and closing down facilities, including Rocky Flats, that
are no longer needed for producing nuclear weapons. In June 1998,
Environmental Management released Accelerating Cleanup: Paths to
Closure, 9 which
projects the technical scope, cost, and schedule required to clean
up and/ or close these facilities. At the Rocky Flats Field
Office, approximately 230 DOE employees manage and oversee the
site's cleanup. Other DOE headquarters organizations also play a
role in the site's cleanup and closure, including the Office of
Defense Programs, the Office of Fissile Materials Disposition, and
the Office of Worker and Community Transition. In addition, other
DOE sites play a significant role in Rocky Flats' cleanup and
closure, especially those that are scheduled to receive materials
or wastes from Rocky Flats.
Contractor and Subcontractors
In 1995, through a competitive procurement process, Kaiser- Hill
Company, L. L. C. (Kaiser- Hill), 10 was awarded the contract to
manage Rocky Flats through June 2000. Kaiser- Hill proposed
managing the site's work through four principal subcontractors,
which now include Rocky Mountain Remediation Services, L. L. C.;
Safe Sites of Colorado, L. L. C.; Rocky Flats
9 Accelerating Cleanup: Paths to Closure (DOE/ EM- 0362, June
1998). 10 A company formed through a joint venture by IFC Kaiser
International, Inc. and CH 2 M Hill.
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Page 23 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
Closure Site Services, L. L. C.; 11 and Wackenhut Services, L. L.
C. The first two companies perform most cleanup activities, the
third handles support services, and the last provides security.
Kaiser- Hill and the four principal subcontractors enter into
contracts with other subcontractors to perform various site
operations and cleanup activities.
Regulatory and Oversight Agencies
EPA and the Colorado Department of Public Health and Environment
are the primary regulators for Rocky Flats. EPA derives its
regulatory authority primarily from the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980,
as amended (CERCLA) 12 and the Resource Conservation and Recovery
Act of 1976, as amended (RCRA). 13 Colorado exercises regulatory
authority over hazardous wastes under RCRA and the Colorado
Hazardous Waste Act 14 and other legislative and
regulatory requirements. Both regulatory agencies have field staff
at Rocky Flats to oversee cleanup and closure activities. These
federal and state laws cover hazardous wastes, but not special
nuclear materials. 15
Under the Rocky Flats Cleanup Agreement, DOE, EPA, and Colorado
annually establish or update regulatory milestones for the site
for the next 2 fiscal years. If these milestones are not met, the
regulators can fine DOE according to a penalty schedule included
in the agreement. 16 In general, EPA has primary authority over
the site's buffer zone, while Colorado has primary authority over
the site's industrial area.
The Department of the Interior's Fish and Wildlife Service has had
a regulatory presence at Rocky Flats for many years. The Fish and
Wildlife Service derives its regulatory authority from the
Endangered Species Act. 17 11 Rocky Flats Closure Site Services,
L. L. C., replaced DynCorp of Colorado as a top- level
subcontractor in 1998. DynCorp continues to provide some services
at Rocky Flats as a lower- tier subcontractor. 12 42 U. S. C.
section 9601 et seq. 13 42 U. S. C. section 6901 et seq. 14
Colorado Revised Statutes 25- 15- 301 et seq. 15 These federal and
state laws do not cover special nuclear materials or source or by-
product materials as defined in the Atomic Energy Act of 1954, 42
U. S. C. 2014. However, the Rocky Flats Cleanup
Agreement defines plutonium as a hazardous material under CERCLA.
16 According to DOE, to date, the site has not missed a regulatory
milestone without an excusable delay (such as delays in WIPP's
opening). 17 16 U. S. C. section 1531 et seq.
Chapter 1 Introduction
Page 24 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
The Endangered Species Act prohibits DOE from taking any actions
that would jeopardize the existence of species listed as
threatened or endangered. The Fish and Wildlife Service, through a
consultative process, may require mitigation efforts to ensure the
protection and recovery of listed species.
The Congress created the Defense Nuclear Facilities Safety Board
in 1988 to oversee DOE's defense nuclear facilities and to ensure
the protection of public health and safety. The Board is charged
with identifying safety problems at DOE's nuclear facilities and
recommending corrective actions
to the Secretary of Energy. If the Secretary accepts a
recommendation, DOE develops an implementation plan. The Board has
issued several recommendations pertaining to Rocky Flats,
including recommendations
about the safety of the site's plutonium and residues, and the
site is implementing corrective actions to address these
recommendations. Although the Board does not have regulatory
authority over DOE, a memorandum of understanding attached to the
Rocky Flats Cleanup Agreement recognizes the Board as the primary
oversight entity for Rocky Flats' special nuclear materials and
activities relating to them.
Other Stakeholders The site's other stakeholders include local
governments; community, business, and citizen groups; and
individuals. The Rocky Flats Cleanup Agreement requires that these
stakeholders be consulted during the development of cleanup plans.
The stakeholders may also provide input to and exert influence on
the regulatory and oversight agencies, as well as their local,
state, and federal elected representatives. The stakeholders'
level of involvement varies. Some of the stakeholders and their
roles are
listed below. Rocky Flats Citizens Advisory Board. The Citizens
Advisory Board was
formed in 1993 to provide informed, community- based
recommendations to EPA, the state, and DOE on the cleanup of Rocky
Flats. The board consists of up to 30 volunteers, including local
citizens; businesspersons; Rocky Flats employees; and
representatives of local governments, academia, and public
interest and environmental organizations.
Local communities. Because they are located near Rocky Flats and
could be affected by its cleanup and closure activities, cities
such as Arvada, Broomfield, and Westminster provide input to DOE
and the
contractor on cleanup and closure issues. Partly because the
communities surrounding Rocky Flats do not depend for their
economic
Chapter 1 Introduction
Page 25 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
vitality on jobs related directly or indirectly to the site, the
cities generally agree on the need to close it. However, they do
not agree on how the site should be used in the future. For
example, Arvada wants to see part of the site used as an
industrial area, while Broomfield and Westminster would like to
have all of it converted to open space, with little or no
development.
County governments. Rocky Flats is located almost entirely within
Jefferson County, along the foothills of the Rocky Mountains.
Although the county government has only recently become involved
in the site's cleanup and closure, DOE officials expect it to
become a major
stakeholder as the cleanup progresses and the site nears closure.
About 35 acres of the site lie within Boulder County, which also
borders the site on the north. Boulder County has also begun to
take an interest in the site's cleanup and closure. Rocky Flats
Local Impacts Initiative. Formed in 1991 and funded by DOE, this
organization represents and serves as a focal point for the views
and concerns of about 60 organizations, including businesses and
environmental, academic, and citizen groups. It also advises DOE
on the impact of workforce restructuring on local communities and
manages several DOE- funded programs to help mitigate the impact
of downsizing on these communities. Outside this organization,
according to site officials, business groups such as the Denver
and Northwest Metro Chambers of Commerce, the Colorado Forum, and
various other groups also provide input to the site on issues
concerning the cleanup and closure of Rocky Flats. The Rocky Flats
Local Impacts Initiative
will be disbanded in early 1999, and in April 1999, a new
organization, the Rocky Flats Coalition of Local Governments, will
begin operations. The coalition's mission will be to "provide an
effective mechanism for local governments in the vicinity of Rocky
Flats and their citizens to work together on issues of mutual
concern relating to the safe, prompt and effective cleanup and
closure of Rocky Flats, its future use and long
term protection. . . ." Environmental/ activist groups. These
types of groups have been
involved in issues at Rocky Flats for many years. The groups'
activities have ranged from conducting antinuclear protests during
the site's production years to taking stands on current cleanup
and closure issues. Objectives, Scope, and Methodology
Concerned about the Department's ability to meet its current goal
to close Rocky Flats by the end of 2006, the Chairman of the
Senate Committee on Armed Services asked us to review (1) DOE's
plans for accelerating the site's closure and challenges that
could impede closure; (2) the condition of
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Page 26 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
the site at closure and the activities that will remain after
closure; and (3) the costs of closing the site and the savings
expected from accelerating its closure.
We performed our work at DOE headquarters in Washington, D. C.;
DOE's Inspector General Denver Audit Group in Golden, Colorado;
and the Rocky Flats Field Office, located on the Rocky Flats site,
near Golden, Colorado.
We also performed work at the primary contractor's and some of the
subcontractors' locations on the site. We contacted other DOE
sites and headquarters organizations whose activities either
affect or are affected by Rocky Flats' closure. In addition, we
performed work at EPA's Region VIII in Denver, Colorado, and at
two Colorado offices the Office of Policy and
Initiatives, within the Office of the Governor, and the Department
of Public Health and Environment, both in Denver. We also obtained
information from stakeholders in communities surrounding the site.
To examine DOE's plans for accelerating the site's closure and
challenges that could impede closure, we reviewed many complexwide
and sitespecific planning documents, including Accelerating
Cleanup: Path to Closure: Rocky Flats Environmental Technology
Site and Closure 2006- Rocky Flats Closure Project: Management
Plan, both dated June 1998, as well as plans and schedules from
the Rocky Flats Field Office and KaiserHill. We also obtained and
analyzed other documents. In addition, we interviewed DOE
officials from the Office of Environmental Management, the Rocky
Flats Field Office, and other DOE sites with activities related to
Rocky Flats' closure. We also interviewed representatives of
Kaiser- Hill and some of its subcontractors, as well as officials
from EPA, Colorado's
Office of the Governor and the Department of Public Health and
Environment, and the Defense Nuclear Facilities Safety Board's
Rocky Flats office. We obtained documents from and interviewed
representatives of numerous stakeholder groups, including the
Rocky Flats Citizens
Advisory Board; the Rocky Flats Local Impacts Initiative; the
Rocky Mountain Peace and Justice Center; and local city
governments, including those of Broomfield and Westminster,
Colorado.
To determine the condition of the site at closure and the
activities that will remain after closure, we obtained and
analyzed the Rocky Flats Cleanup Agreement and interviewed
officials from the three organizations that developed it: DOE
(headquarters and Rocky Flats Field Office), EPA, and Colorado
(the Office of the Governor and the Department of Public Health
and Environment). In addition, we obtained and analyzed documents
and interviewed officials from DOE's Office of Inspector General,
Kaiser- Hill,
Chapter 1 Introduction
Page 27 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
some of the subcontractors, and the Defense Nuclear Facilities
Safety Board. We also toured various facilities and cleanup
projects at the site. Finally, we obtained documents and
interviewed representatives from several local stakeholder groups,
including the Rocky Flats Citizens Advisory Board, the Rocky Flats
Local Impacts Initiative, the Rocky Mountain Peace and Justice
Center, and local city governments.
To determine the costs of closing the site and the savings
expected from accelerating closure, we obtained and analyzed
documents and interviewed officials from DOE's Office of
Environmental Management and Rocky Flats Field Office and from
Kaiser- Hill. Specifically, we reviewed cost and savings estimates
in closure planning documents, including Closure 2006-- Rocky
Flats Closure Project: Management Plan; cost estimates prepared by
Kaiser- Hill and the Rocky Flats Field Office,
including project baseline descriptions and project baseline
summaries; and other reports by DOE and the contractor on the
site's cost and savings estimates. We also interviewed regulatory
officials and representatives of local stakeholder groups to
obtain their views on the Department's cost and savings estimates
for Rocky Flats. We provided DOE with a copy of a draft of this
report for its review and comment. DOE's comments are discussed
and evaluated at the ends of chapters 2 and 3. The full text of
DOE's comments appears in appendix I. We conducted our review from
May 1998 through March 1999 in
accordance with generally accepted government auditing standards.
Page 28 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
Chapter 2 Challenges to Accelerating the Site's Closure Chapt er 2
DOE and the primary contractor, Kaiser- Hill, are attempting to
accelerate the closure of Rocky Flats to meet the Department's new
target date of 2006. The contractor has not yet developed a
detailed plan and schedule for closure by the end of that year and
has encountered some delays in implementing the earlier plan for
closing the site in 2010. 1 The contractor is developing a plan
for closing the site by the end of 2006 and believes that it can
take advantage of learning curves and efficiencies gained through
early efforts to expedite required cleanup and closure activities.
However, although DOE and the contractor have made progress in
some areas, they face challenges that could hinder efforts to
accelerate the site's closure. In addition, extensive requirements
for coordinating the work at Rocky Flats
with work at other DOE sites and challenges outside of DOE's
control could further hinder efforts to close Rocky Flats by the
end of 2006. Detailed Plan Assumes That the Site Will Be Closed in
2010
In fiscal year 1994, when the Department developed plans to close
Rocky Flats, DOE estimated that the site could be closed as late
as 2070. In 1995, DOE selected Kaiser- Hill to manage and operate
Rocky Flats. At that time, Kaiser- Hill proposed closing the site
in 2015. Then, in 1996, DOE's Office of
Environmental Management announced efforts to accelerate the
cleanup of contaminated sites throughout DOE's nuclear complex. In
1997, Kaiser- Hill proposed closing the site in 2010 and developed
a detailed plan and schedule to support its proposal. This plan
remains in effect today, even though DOE has advanced the date for
closure to the end of 2006. To meet the 2006 target, the
contractor must complete the tasks set forth in the 2010
plan in about 30 percent less time. Kaiser- Hill has started
developing a detailed plan to close the site by the end of 2006.
According to contractor officials, this plan will be submitted to
DOE by the end of May 1999. In the
meantime, both contractor and DOE officials are attempting to get
ahead of the 2010 plan by accelerating activities they view as
critical to closing the site by the end of 2006.
While making progress in some areas, the contractor has incurred
delays in some activities considered important to closing the
site. These delays could affect the schedule for accomplishing
other cleanup activities. For example, the contractor fell behind
the 2010 schedule in preparing three
types of plutonium- contaminated residues for removal from the
site, as well as in shipping plutonium pits to DOE's Pantex Plant,
the site designated to receive and store most of DOE's nuclear
weapons 1 The 2010 plan is based on closing the site by the end of
fiscal year 2010.
Chapter 2 Challenges to Accelerating the Site's Closure
Page 29 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
components. Such delays can have a cumulative impact because many
of the site's cleanup and closure activities must be completed in
sequence. For example, delays in removing residues and special
nuclear materials from the buildings where they are now stored can
delay efforts to decontaminate, decommission, and demolish these
buildings.
Site officials maintain that the contractor can make up for the
delays experienced thus far and accelerate activities to close the
site by the end of 2006. According to many site officials, the
contractor is climbing a learning curve in many of the activities,
and once it has gained experience, it will be able to accelerate
activities and achieve efficiencies. However, the officials have
not yet clearly indicated how learning curves and efficiencies
will accelerate later activities in time to meet the 2006 target.
Furthermore,
subsequent cleanup tasks may present different problems. Despite
DOE's and Kaiser- Hill's position that they can close the site by
the end of 2006, several DOE and contractor personnel told us that
although they think some acceleration of the 2010 plan is
possible, they are not sure that closure by the end of 2006 is
feasible. Some of these personnel believe that a date between 2006
and 2010 may be more realistic, while others characterize even the
2010 date as ambitious. Many of the site's regulators and
stakeholders said they support efforts to accelerate Rocky Flats'
closure but are more concerned that it be done right than that it
be done by
the end of 2006. The contractor's recent risk analysis of the 2010
closure plan identified uncertainties and technical problems that
the contractor must overcome to close the site. The uncertainties
and problems include
such key areas as preparing the site's nuclear materials and
wastes for shipment, establishing sites to take Rocky Flats'
materials, and decontaminating and decommissioning the site's
buildings and facilities. The risk analysis determined that unless
the contractor resolves these existing uncertainties and technical
problems, it has a 1- percent chance of closing the site by the
end of fiscal year 2010. 2 Kaiser- Hill management stated that
this risk analysis is a tool to identify and focus management's
attention and planning efforts on cost and schedule uncertainties
and problems that could affect the site's closure. Whether and
when these uncertainties and technical problems are resolved will
also affect the prospects for closing the site by the end of 2006.
Both DOE and Kaiser- Hill 2 According to Kaiser- Hill, a schedule
risk analysis process was initiated in 1998 to periodically
identify and prioritize uncertainties that must be overcome to
close the site by 2006. An initial analysis identified
uncertainties associated with several technically complicated
activities scheduled to occur in the later stages of closure;
consequently, a 1- percent chance of overall success resulted.
Chapter 2 Challenges to Accelerating the Site's Closure
Page 30 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
officials emphasized that the site has been able to resolve or
overcome uncertainties and problems in the past.
Numerous Challenges Could Hinder Efforts to Accelerate Closure
DOE and the contractor have identified four primary activities
that will need to be accelerated in order to close the site by the
end of 2006: (1) processing and removing plutonium- contaminated
residues; (2) shipping special nuclear materials off- site; (3)
decontaminating and decommissioning buildings; and (4)
constructing closure caps-- man- made protective barriers between
contamination that remains on the site and the public or the
environment. According to DOE and contractor officials, the
contractor may be able to accelerate the removal of special
nuclear materials and residues by 2 years, allowing for closure in
2008, largely by
identifying and implementing more expeditious ways of processing
and shipping the residues and special nuclear materials. However,
the officials are less confident that they can gain 2 more years
by compressing the schedule for decontaminating and
decommissioning buildings and
constructing closure caps. These activities are scheduled for
later years and largely require the completion of other activities
first. We found challenges in each of the four areas that could
hinder efforts to close the site by the end of 2006.
Challenges in the Residues Program
Recently, as well as historically, Rocky Flats has faced problems
and delays in managing its plutonium- contaminated residues.
According to DOE officials, to close the site by the end of 2006,
the contractor needs, by 2003, to treat, package, and ship
approximately 106 metric tons of residues to sites designated to
receive them. However, DOE, the Defense Nuclear
Facilities Safety Board, and we have reported that Rocky Flats has
had problems managing its residues in the past. 3 To accelerate
the removal of residues from the site, Rocky Flats is no longer
planning to extract the
plutonium from them. The site is now planning to send most of the
residues that are high in plutonium content or categorized as high
risk to DOE's Savannah River Site in South Carolina for
processing. It is also planning to prepare the bulk of the
residues-- sometimes by blending them with less contaminated or
clean material to lower the percentage of 3 See Plutonium Working
Group Report on Environmental, Safety and Health Vulnerabilities
Associated
with the Department's Plutonium Storage (DOE/ EH- 0415, Nov.
1994), Recommendation 94- 1, Improved Schedule for Remediation in
the Defense Nuclear Facilities Complex, Defense Nuclear Facilities
Safety Board (59 FR 28848, May 1994), and Department of Energy:
Problems and Progress in Managing Plutonium (GAO/RCED-98-68, Apr.
17, 1998).
Chapter 2 Challenges to Accelerating the Site's Closure
Page 31 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
plutonium and sometimes by just repackaging the materials-- for
disposal as transuranic wastes at the Waste Isolation Pilot Plant
(WIPP) in New Mexico. A DOE official estimates that this change
will shave at least 1 year from the residues program and save at
least $50 million. Figure 2.1 shows a Rocky Flats worker handling
plutonium residues in a glovebox. 4
Figure 2. 1: A Rocky Flats Worker Handling Plutonium Residues in a
Glovebox
Source: Kaiser- Hill.
However, even under this revised approach to managing the site's
residues, the contractor has recently experienced additional
delays in processing and repackaging some of the site's residues.
According to a DOE official overseeing the processing,
repackaging, and removal of residues, some repackaging efforts
have fallen behind schedule and some processes have been
temporarily shut down. According to Kaiser- Hill officials, they
are
4 A glovebox is a sealed glass, metal, or plastic chamber designed
to protect a worker handling radioactive or hazardous materials
from exposure to contamination. The worker, who remains outside
the box, uses gloves attached to the wall of the chamber to handle
the contaminated materials.
Chapter 2 Challenges to Accelerating the Site's Closure
Page 32 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
adding funding and other resources primarily additional workers
and equipment to make up for these problems, catch up to the 2010
schedule, and accelerate future processing and repackaging
efforts. According to contractor officials, despite some of the
earlier delays, progress is being
made in processing and repackaging residues. 5 The contractor told
us that it has already made up for some of the delays and is
working to overcome the others. According to DOE, as of April
1999, the site had caught up to the 2010 processing schedules for
four of the five major residue types. In addition to the
contractor's efforts, DOE redirected an additional $2 million to
$3 million in fiscal year 1999 funding to residue repackaging
activities, according to site officials. The recent delays have
nevertheless prompted regulatory and DOE officials to question
whether the contractor will meet its fiscal year 1999 and 2000
goals for processing and repackaging the site's residues.
In addition, the site has had problems obtaining the
certification, or approval, it will need from DOE's Carlsbad Area
Office to ship its processed and packaged residues to WIPP for
disposal. In August and September 1998, auditors from the Carlsbad
Area Office found adverse conditions, such as inadequate record-
keeping and verification procedures, that required correction
before the residues could be certified for eventual disposal at
WIPP. A DOE site official told us that the audit results indicated
a serious cultural problem-- a failure by subcontractor engineers
and managers to understand DOE's requirements and make a
commitment to meeting them. The residues will not require further
processing, and after the site takes the required corrective
actions, the auditors will return to
certify the residues. Their return visit was scheduled for March
1999. According to Kaiser- Hill officials, the contractor has
completed correcting the findings from the 1998 audit. An audit of
the site's transuranic waste characterization and certification
processes in March 1999 resulted in no
major audit issues. Challenges to Accelerating the Shipment of
Special Nuclear Materials Off- Site
Rocky Flats has shipped about 80 percent of its plutonium pits
off- site, and the remainder are expected to be shipped to the
Pantex Plant near
5 In Mar. 1999, Kaiser- Hill officials said that the contractor is
approaching the production rates needed to finish reprocessing all
of the residues by fiscal year 2002, a date the officials view as
critical to closing the site by 2006.
Chapter 2 Challenges to Accelerating the Site's Closure
Page 33 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
Amarillo, Texas, or to the national laboratories by September
1999. 6 However, most of the site's plutonium metals and oxides
must still be stabilized, packaged in long- term storage
containers, 7 and then shipped to DOE's Savannah River Site for
storage until they can be processed for ultimate disposal at DOE's
high- level waste repository. The Savannah River
Site is modifying an existing structure to accommodate the
accelerated shipment of Rocky Flats' plutonium metals and oxides.
The site is now planning to accelerate the stabilization,
packaging, and shipment of its plutonium metals and oxides by 2
years. The 2010 closure schedule called for this plutonium to be
stabilized, packaged, and shipped
to Savannah River by the end of fiscal year 2004. The site now
expects to complete these tasks by May 30, 2002. However, as we
reported in April 1998, the site has encountered problems--
including difficulties in procuring an automated plutonium
stabilization and packaging system-- that have delayed its
progress and increased its costs. 8 Recently, because of
reliability and technical difficulties, the site decided to use
manually operated furnaces to stabilize the plutonium oxides
instead of the stabilization portion of the automated system. Site
officials estimate that these furnaces should be ready to
stabilize the plutonium oxides in April 2000. The packaging
portion of the automated system, turned over-- a year
late-- to the contractor in September 1998, must be operational by
December 1999 to meet the accelerated shipping schedule. However,
as of February 1999, the complex automated plutonium packaging
system was still in a warehouse in a community near the site. The
automated packaging system proved very sensitive and performed
below expectations during off- site testing and required
unanticipated modifications. The contractor must still move the
system to the site, install it in a building within the site's
protected area, test it, and bring it up to operational
capability-- tasks that may require months' worth of adjustments
to the equipment, given its complexity and sensitivity. While the
contractor has developed and is implementing a schedule to install
the equipment to enable the stabilization and accelerated shipment
of the plutonium metals 6 DOE anticipates that the pits that can
be shipped to the Pantex Plant will be shipped by the end of May
1999. 7 Some plutonium metals are classified because of their
shape or constituents and will require additional processing at
another site to make them unclassified before they can be stored.
These metals will be
shipped to the site designated to receive them, where they will be
processed and then packaged into long- term storage containers.
8 Department of Energy: Problems and Progress in Managing
Plutonium (GAO/RCED-98-68, Apr. 17, 1998).
Chapter 2 Challenges to Accelerating the Site's Closure
Page 34 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
and oxides, some site officials note the challenges ahead and
question the contractor's ability to meet the required time
frames. Challenges in Decontaminating and Decommissioning
Buildings
Of the 691 buildings or facilities at Rocky Flats, as of March
1999, 48 had been decontaminated, decommissioned, and demolished.
Three of these buildings had some radiological contamination. In
addition, the contractor
reported that as of March 1999, seven additional buildings were
being decontaminated and decommissioned-- three with some
radiological contamination and four with significant radiological
contamination.
According to the 2010 closure plan, the majority of the remaining
buildings, including some of the most difficult radiologically
contaminated buildings, are now scheduled for decontamination and
decommissioning from 2005 through 2007, and over two- thirds of
the demolition is scheduled from 2006 through 2009. Contractor
officials have not yet determined how the schedule for
decontamination, decommissioning, and demolition can be compressed
enough to close the site by the end of 2006. The contractor is
developing a detailed decontamination and decommissioning schedule
as
part of its detailed plan for closing the site by the end of 2006.
According to the contractor, its senior management recognizes that
the site faces a daunting task in achieving the accelerated
decontamination and
decommissioning of the site's nuclear facilities; nevertheless,
the managers remain convinced that the earlier closure can be
accomplished. However, some DOE and contractor officials have
questioned both the feasibility of completing the work under the
compressed schedule and the availability of
resources-- especially of qualified workers-- to carry out the
work on time. The contractor has successfully conducted some of
the more complex early decontamination and decommissioning work
nearly on schedule, but at double the anticipated cost. In
decontaminating and decommissioning
two of the first major buildings at the site a health science
building and a plutonium processing building-- the contractor
found that the work on these radiologically contaminated buildings
took longer and cost more than
planned. The tasks proved to be more complex and generated more
waste than expected, and unanticipated radiological or hazardous
contamination was found. The contractor offset delays of several
months through the use of overtime work and the application of
lessons learned, especially in reducing the time for packaging
waste materials. As a result, the contractor finished
decontaminating and decommissioning one building
only about a month behind schedule and expects to do the same for
the second building. However, overcoming these problems and delays
had a significant cost. The contractor more than doubled the cost
estimate for
Chapter 2 Challenges to Accelerating the Site's Closure
Page 35 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
decontaminating and decommissioning the plutonium processing
building, from $21. 1 million in November 1997 to $55.4 million in
October 1998. 9
Contractor officials said they expect to learn from their early
efforts and develop efficiencies that will enable them to make up
for lost time, reduce costs, and accelerate the decontamination
and decommissioning of the remaining buildings. For example,
according to Kaiser- Hill officials, the subcontractor was able to
remove gloveboxes five times faster from the
plutonium processing building by applying lessons learned-- using
better tools and learning to cut the gloveboxes to better fit into
the disposal containers-- and by funding overtime work. According
to contractor officials, as of March 1999, over 120 gloveboxes had
been removed from this building. However, earlier efforts may not
always be applicable because each building-- especially each
radiologically contaminated building-- may present unique
problems. Because different types of activities took place in the
buildings where nuclear weapons were produced, the buildings
contain widely different levels and types of contamination,
requiring different cleanup activities.
Adding to the challenges involved in decontaminating,
decommissioning, and demolishing the site's buildings and
facilities, the contractor increased its estimates of the wastes
expected from these efforts. These wastes will ultimately have to
be packaged and removed from the site. Primarily on
the basis of its experience with decontaminating and
decommissioning the first major buildings and some subsequent
changes in approach, in July 1998, the contractor increased its
estimates of transuranic waste from
about 9, 500 cubic meters to over 14,500 cubic meters and of low-
level waste from about 66, 000 cubic meters to nearly 143, 000
cubic meters. It also decreased its estimate of low- level mixed
waste by over 20,000 cubic
meters. Contractor officials stated that they believe they will be
able to ship these wastes off- site at the rate they are generated
by decontamination, decommissioning, and demolition activities.
Contractor and DOE officials told us that decontamination and
decommissioning activities tend to be labor intensive, especially
for former nuclear weapons production buildings in the site's
protected area. 10 9 These cost estimates are for decontaminating,
decommissioning, and demolishing the building cluster, which
consists of the primary plutonium processing building and its
support buildings and facilities.
10 The protected area is a safeguarded zone within the site's
industrial area where activities that involve special nuclear
materials are conducted. Access requires special authorization,
and a protective force of guards and physical barriers provide
security for the nuclear materials.
Chapter 2 Challenges to Accelerating the Site's Closure
Page 36 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
Workers, who require special training and security clearances,
must go through time- consuming procedures to dress in required
protective gear and enter contaminated buildings. Site officials
said they plan to create
special decontamination and decommissioning teams to work
simultaneously on different radioactively contaminated buildings.
They noted that using teams should create efficiencies, allowing
them to compress the schedule for decontamination and
decommissioning. According to contractor officials, the majority
of the site's buildings are not contaminated and their
decontamination and decommissioning will not require special
training, security clearances, or protective equipment.
Challenges With the Use of Closure Caps
The contractor is planning to use closure caps to isolate residual
contaminants in four areas, but the site's regulators have agreed
to the use of these caps for only two of the areas. Closure caps
are man- made barriers designed to isolate contaminants from the
surrounding environment or the public. Descending layers are made
of increasingly finer materials to restrict the infiltration of
water to contamination below
(see fig. 2.2).
Figure 2. 2: Diagram of the Layers of a Closure Cap
Source: GAO's presentation of data provided by Kaiser- Hill and
DOE. 24
12 24
Top Soil and Vegetation Gravelly Sand - Coarser Material
Sandy Gravel - Finer Material Membrane- Man- Made Material
Clay Layer Gravel or Rock - Structural Backfill
Chapter 2 Challenges to Accelerating the Site's Closure
Page 37 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
As allowed under the Rocky Flats Cleanup Agreement, the contractor
plans to construct closure caps over the site's landfills and
solar evaporation ponds 11 (about 33 acres of caps). However, the
contractor also plans to construct closure caps over two portions
of the industrial area (an additional 31 acres) after the
contaminated buildings have been demolished. DOE and the
contractor are just starting to discuss the use of these
additional caps with the regulators and stakeholders, and no
agreements have been reached. Contractor officials told us they
need a
final decision on the use of closure caps for the two portions of
the industrial area by 2004 if they are to finish constructing the
caps by the end of 2006. If the contractor is not allowed to use
caps in these areas, site officials said, the costs of closure
could be higher and the site's closure could be delayed.
Many of the site's stakeholders oppose the use of additional
closure caps because they are concerned that the caps will not
provide an adequate barrier for the industrial area for as long as
necessary. Given current technology, they expect the caps to fail
long before the radiological contamination ceases to pose a threat
to human health and the
environment-- many thousands of years in the future. A DOE
official said that closure caps have failed in the past, primarily
because the construction was not adequate for the conditions or
the caps were not properly maintained.
Coordination of Closure Activities Could Affect Acceleration
Closing Rocky Flats depends on coordinating activities across the
DOE complex, as well as outside the complex. Virtually everything
at the site must go somewhere else for storage or disposal. 12
Currently, DOE does not have sites to receive all of the materials
and wastes that must be removed from Rocky Flats. Furthermore,
other DOE facilities will need sites to receive their materials
and wastes, and Rocky Flats will be competing with these other
facilities for storage and processing services, as well as for
vehicles and containers to transport materials and wastes. The
Department has made some efforts to coordinate activities across
the DOE complex to support Rocky Flats' accelerated closure,
including 11 According to documentation from the site, these ponds
were used to store and evaporate radiological
and hazardous wastes. 12 Exceptions include some uncontaminated or
slightly contaminated materials that may be disposed of on- site.
Chapter 2 Challenges to Accelerating the Site's Closure
Page 38 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
establishing a headquarters office, a senior management team, and
a management plan.
Rocky Flats Does Not Have Facilities to Take Some of Its Materials
and Wastes
Rocky Flats has shipped some of its nuclear materials and wastes
to other DOE sites and commercial facilities. It has also
designated other sites to receive additional types of materials,
but these sites have not yet been able to receive the materials
from Rocky Flats. However, no sites are available to take several
orphan materials and wastes, including some low- level mixed
wastes and uranium contaminated with plutonium or hazardous
materials. No sites are available to take these materials because
existing facilities are not licensed to accept them. Rocky Flats
has already shipped plutonium pits to the Pantex Plant near
Amarillo, Texas; low- level waste to a disposal site on the Nevada
Test Site; and enriched uranium to the Oak Ridge Reservation in
Tennessee. In addition, some materials have been sent to
commercial facilities. For example, some low- level mixed waste
has gone to the Envirocare disposal facility in Utah, and some
sanitary waste (nonradioactive and
nonhazardous waste) has gone to a landfill near Erie, Colorado.
Other types of materials and wastes have been designated to go to
other DOE sites. As noted, the Savannah River Site in South
Carolina is designated to receive the site's plutonium metals and
oxides, and the WIPP
facility near Carlsbad, New Mexico, is designated to receive
transuranic and transuranic mixed waste. (Fig. 2.3 shows the
location of the sites that have accepted or expect to receive
Rocky Flats' nuclear materials and wastes.)
Chapter 2 Challenges to Accelerating the Site's Closure
Page 39 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
Figure 2.3: Sites That Have Accepted and Expect to Receive Rocky
Flats' Nuclear Materials and Wastes
Key: Solid lines indicate that shipments have occurred; broken
lines indicate that no such shipments have taken place.
Note: The map shows the sites that are receiving or are designated
to receive the majority of these types of materials. Small amounts
of the materials may be sent to other sites.
Source: GAO's presentation of data provided by DOE.
Envirocare
Low- Level Waste/ Some Low- Level Mixed Waste Disposal
Oak Ridge Reservation
Highly Enriched Uranium Storage
Savannah River Site
Residue Processing and Plutonium Storage
Pantex Plant
Plutonium Pit Storage
Waste Isolation Pilot Plant
Transuranic/ Transuranic Mixed Waste Disposal
Nevada Test Site
Low- Level Waste Disposal
Rocky Flats Enviornmental Technology Site
Current receiver sites Future receiver sites
Plutonium Metals
and Oxides Some
Residues
Chapter 2 Challenges to Accelerating the Site's Closure
Page 40 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
Rocky Flats currently has nowhere to send low- level mixed waste
with higher plutonium contamination (10 to 100 nanocuries per gram
of material). Rocky Flats expects to generate about 10,000 cubic
meters of this kind of waste, but no commercial or DOE facility
has the RCRA permits required to accept it. 13
According to site officials, the most promising option for
disposing of the site's orphan low- level mixed waste is to enter
into a contract with a waste management company that is interested
in operating a low- level mixed waste disposal facility in eastern
Colorado. The company is currently operating a hazardous waste
disposal facility at this location but does not have the authority
to accept low- level mixed waste. However, according to DOE
officials, the Department is required under a DOE order to use DOE
facilities for radioactive waste disposal and can use commercial
facilities only on an exception basis. 14 DOE recently analyzed
this waste disposal policy to determine if it needed to be
changed. DOE headquarters put the proposal for the Colorado waste
disposal facility on hold during this study.
On March 11, 1999, the Department announced that the policy
analysis had concluded that DOE should continue its preference for
using DOE disposal facilities for DOE wastes and should use
commercial facilities under an
exemption process when disposal at DOE facilities is not
practical. DOE has delegated the exemption authority to the
managers of its field offices- in consultation with its Office of
Environment, Safety and Health-- to facilitate the process when
the use of commercial facilities is necessary and in DOE's best
interest.
According to site officials, if the Colorado disposal facility is
not established, Rocky Flats may have to store its orphan low-
level mixed waste on- site, greatly diminishing the likelihood of
closing the site by the end of 2006. Alternatively, site officials
say, the site could send this orphan waste to existing disposal
facilities at another DOE site (if the site could obtain a state
permit to dispose of hazardous waste) or to a commercial facility
(if the facility could obtain a license to dispose of low- level
radioactive waste). However, according to the site officials,
these alternatives appear unlikely.
13 Low- level mixed waste includes hazardous wastes and therefore
is subject to regulation under RCRA. Authorized state hazardous
waste programs issue permits for hazardous waste treatment,
storage, and disposal within their borders.
14 Department of Energy Order on Radioactive Waste Management (DOE
5820.2A, Sept. 26, 1988).
Chapter 2 Challenges to Accelerating the Site's Closure
Page 41 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
Rocky Flats also needs a site to receive about one- fourth of its
enriched uranium that is contaminated with plutonium. The site is
sending most of its enriched uranium to the Oak Ridge Reservation.
However, Oak Ridge is unable to take uranium that is contaminated
with plutonium, and Rocky Flats cannot remove enough of the
plutonium contamination to send all of its uranium to Oak Ridge.
Rocky Flats may be able to send this plutoniumcontaminated
uranium to Savannah River, which can process the material.
However, DOE is evaluating other technical options and is
attempting to determine where existing environmental impact
statements allow for the disposition of the remaining uranium. 15
Still another orphan material at the site is depleted uranium
contaminated with polychlorinated biphenyls (PCB), a toxic
substance. 16 A few drums of this material were unearthed during a
recent environmental cleanup
project at the site. The one DOE facility that can process
depleted uranium with PCBs is the Oak Ridge Reservation. However,
Tennessee is not allowing the site to accept this waste. DOE is
currently exploring potential commercial disposal options for this
material. Other Coordination Issues Could Affect the Site's
Closure
To close by the end of 2006, Rocky Flats will need adequate
numbers of specialized transportation vehicles to ship large
amounts of special nuclear materials and nuclear wastes in the
near future. However, contractor officials regard the coordination
of shipping schedules as a "key challenge," given projected
generation rates, volumes, and storage capacity. For example,
plutonium and enriched uranium must be shipped in specially
equipped trucks and trailers called Safe Secure Transports,
managed by
DOE's Albuquerque Operations Office. Some Rocky Flats officials
have questioned whether enough of these transports will be
available when the site needs them, especially when shipping
schedules change and other sites are competing for their use. The
site's transuranic wastes must be shipped
in another type of truck and trailer with specialized
transportation casks called Transuranic Package Transporters
(TRUPACT), managed by DOE's Carlsbad Area Office, where WIPP is
located. DOE has only 15 TRUPACTs
available, and, according to site officials, Rocky Flats will need
two to three 15 Environmental impact statements are prepared to
accompany major federal actions under the National Environmental
Policy Act, 42 U. S. C. 4321 et seq. 16 Depleted uranium is
natural uranium that has had most of its fissionable isotope,
uranium 235, stripped out for use in weapons or nuclear fuel
production. PCBs are regulated by EPA under the Toxic Substances
Control Act, 15 U. S. C. 2601 et seq.
Chapter 2 Challenges to Accelerating the Site's Closure
Page 42 GAO/RCED-99-100 Accelerated Closure of Rocky Flats
times that number to meet its schedule for shipping transuranic
wastes, at the same time that other DOE sites will also need to
ship transuranic waste to WIPP. For example, under a court-
approved consent order, the Idaho National Engineering and
Environmental Laboratory must begin shipping transuranic waste
off- site by April 30, 1999, ship 3,100 cubic meters of this waste
off- site by December 30, 2002, and remove all transuranic waste
from
the site by 2018. As these dates approach, the laboratory's needs
will grow more critical and could take priority over Rocky Flats'.
The priority given to Rocky Flats for limited transportation and
other resources will have an important impact on DOE's ability to
close the site by the end of 2006. However, the Carlsbad Area
Office has assured Rocky Flats that sufficient
numbers of TRUPACTs will be available to support the shipping
schedule for the site's accelerated closure. The question of how
much priority will be given to Rocky Flats' needs is not limited
to transportation resources. Rocky Flats is located
organizationally under the Office of Environmental Management and
often depends on receiving cooperation, priority for its needs,
and budgetary support from other DOE organizations to move forward
with activities
required to close the site. In some instances, other DOE
organizations have not given priority to such activities. For
example, Rocky Flats depends on the Pantex Plant, which is managed
by DOE's Office of Defense Programs, to receive and store the
majority of its plutonium pits. In fiscal year 1998, Defense
Programs' funding for the Pantex Plant to receive Rocky Flats'
plutonium pits was not sufficient, and this, in part, caused some
shipments
to be delayed. This issue was resolved in June 1998 when Defense
Programs and Environmental Management agreed that Defense Programs
would provide the resources needed to support the transportation,
receipt, and storage of the pits at the Pantex Plant.
DOE Has Taken Steps to Promote Coordination DOE has made efforts
to coordinate activities across the Department to
support Rocky Flats' accelerated closure. These efforts include
establishing a headquarters office, a senior management team, and
a management plan.
Under the Office of Environmental Management, the Rocky Flats
Program Office at headquarters works to coordinate Rocky Flats'
closure activities, primarily by working with the program people
within various DOE organizations and sites. According to DOE
officials, the staff in the Rocky Flats Program Office have worked
to establish sites to receive Rocky Flats' materials and wastes,
resolve issues raised under the National
*** End of document. ***