Thomas P. Gallegos
Rocky Flats Citizens Advisory Board;
RFCAB Secretary and Co-Chair of the
Environmental/Waste Management Committee

A primary requirement of nuclear weapons complex cleanup is compliance with the public/stakeholder involvement aspect required under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). In order to achieve conformity with this public participation requirement at the Rocky Flats Environmental Technology Site, the Rocky Flats Citizens Advisory Board (RFCAB) was assembled.

The RFCAB formed five committees to address major issues surrounding the cleanup of the site. Those committees focused on several broad decision policies that were identified to underlie the majority of cleanup issues at the site. One of these committees, the Environmental/Waste Management Committee, was given the initial responsibility of developing a position paper on acceptable levels of cleanup for the Rocky Flats Environmental Technology Site. After initial research was performed, the project objective was changed to be more consistent with the RFCAB’s mission to provide public/stakeholder perspectives and informed recommendations. The modified project objective tasked the Environmental/Waste Management Committee to produce a set of guiding principles and reporting parameters/requirements.

This Environmental/Waste Management Committee project entailed the development of cleanup principles and reporting parameters/requirements, with specific tasks as follows:

1. to conceptually formulate, develop, and deliver a set of cleanup principles and reporting parameters/requirements presented in the form of a recommendation to the RFCAB;
2. to lead the RFCAB through the refinement of those drafted cleanup principles and reporting parameters/requirements to gain consensus on a final set to be submitted to the Department of Energy;
3. to construct a project workbook containing project process documentation and collected information, and;
4. to deliver a project report documenting the public involvement process utilized throughout this project.

This document is the fulfillment of the final task of the original cleanup principles and reporting parameters/requirements project. As the project report, this document presents the research and provides all the specific findings. From the findings, it is shown how the draft cleanup principles and reporting parameters/requirements were assembled. The pivotal decisions made during the RFCAB review sessions are presented, as well as, the change of the project name to the title, "Cleanup Principles and Critical Reporting Elements." Then, the process used to collect comments from the recommendation submitted to the Department of Energy is presented, and it is discussed how those comments will be utilized to improve the use and application of the "Cleanup Principles and Critical Reporting Elements." Most importantly, this report is a testament to the exhaustive work performed by volunteers with the common goal of making their community a better place to live, for themselves and future generations.

The RFCAB was assembled in November of 1993 as a representative group of stakeholders from the surrounding communities. The RFCAB was created specifically to provide recommendations and advice on the cleanup of the Rocky Flats Environmental Technology Site, to the Department of Energy (DOE), the Colorado Department of Public Health and Environment (CDPHE), and the Environmental Protection Agency (EPA). The true motivation behind the organization of the RFCAB was to fulfill a legal mandate for public/stakeholder involvement under CERCLA.

With public/stakeholder involvement required by law, DOE and the involved regulatory agencies have begun to devise avenues by which citizens advisory boards can be positively utilized in the cleanup of nuclear weapons complex facilities across the nation. To achieve this objective on a local scale, the RFCAB was assembled to allow the public to take on some responsibility for identifying the problems and solutions in the cleanup of the Rocky Flats Environmental Technology Site.

In an effort to better focus on the major issues involved in cleaning up Rocky Flats, the RFCAB organized five committees addressing specific areas of the decommissioning activities. These working committees are:

• Alternative Use Planning Committee - focuses on future use options for the Rocky Flats Environmental Technology Site.
• Community Outreach Committee - addresses public participation in Rocky Flats/RFCAB issues.
• Environmental/Waste Management (E/WM) Committee - addresses issues and makes recommendations on areas involving the environmental cleanup of contaminated areas at Rocky Flats, and also the treatment and storage of wastes.
• Plutonium and Special Nuclear Materials Committee - evaluates and makes recommendations concerning the treatment, storage, and ultimate disposition of plutonium and other radioactive materials at Rocky Flats.
• Site Wide Issues Committee - evaluates and makes recommendations on issues concerning waste and residue disposal policies, and Rocky Flats budget and regulatory/DOE agreements.

The committees initially addressed immediate site issues and projects; however, the RFCAB as a whole was striving toward identifying broad policy related decisions, and proceeded to designate specific topics to the appropriate committee. In turn, the RFCAB assigned the E/WM Committee with the responsibility to develop a position paper on acceptable levels of cleanup for the Rocky Flats Environmental Technology Site.

The purpose of this project is to incorporate public/stakeholder perspectives into a standard process for determining appropriate cleanup levels for individual areas at the Rocky Flats Environmental Technology Site. This standard process will take into account a variety of aspects including: land use; risk level; contamination level; the type of contamination and substance(s) involved; cleanup cost; public opinion on the cleanup; ecological impacts; the time required for cleanup; trade-off’s for action or in-action; existing conditions of the individual area; and the amount of waste generated.

The original objective of this project was to conduct an assessment of the "How Clean is Clean?" topic, and prepare a position paper answering the following questions: what are acceptable levels of cleanup; what part do land use decisions play; and what are the ethical considerations? After initial research was performed, in the form of stakeholder representative interviews, the objective of this project was modified.

The modified project objective was to produce a set of guiding principles and reporting parameters/requirements by which publicly acceptable cleanup can be achieved at the Rocky Flats Environmental Technology Site. Specifically, the committee was tasked to: 1) develop a set of principles to provide broad over-all guidance to the variety of cleanup activities that will occur at the Rocky Flats Environmental Technology Site; 2) develop a list of items that will function as reporting parameters/requirements to be used to convey the details of each cleanup project to the public/stakeholders; 3) perform basic research on background contamination levels, risk determination, risk assessment, risk management, and regulatory cleanup standards; 4) coordinate appropriate educational presentations for the committee and RFCAB; 5) develop a project workbook, and; 6) develop and deliver a final project report to the RFCAB.

In order to adequately address the issues involved in this broad topic, a variety of resources were identified by the E/WM Committee. These initial resources included: Future Site Use Working Group Report; Background Contamination Levels Information; Contaminant and Background Databases; How Clean is Clean National Project in Washington D.C., and; Regulatory Cleanup Standards. In addition to these resources, the E/WM Committee performed interviews with key DOE, CDPHE, EPA, Rocky Flats site contractor, academic, interest group, and stakeholder representatives to validate the initial project objective. The interviews solicited the opinions of the representatives on the initial project objective, and the overall interview process was intended to produce a refined project objective. To expedite the interview process, a standard project description and questionnaire document was developed. The final resource aspect that was identified by the committee, addresses raising the general awareness level of stakeholders with respect to risk topics. To accomplish this, the E/WM Committee identified three areas on which to receive educational presentations. The three areas were identified as toxicology/health physics, risk assessment (both human and ecological), and risk communication. The presentations were scheduled to take place at monthly RFCAB meetings, and were intended to coincide with the general project research being performed.

In conjunction with the project resources identified, the comprehensive project workplan for the E/WM Committee included the construction and maintenance of a project workbook to document the project and retain collected information. The primary component of the comprehensive project workplan was the development, drafting, and refinement of the cleanup principles and reporting parameters/requirements. As the final tasks, the "Cleanup Principles and Critical Reporting Elements" were delivered to the RFCAB for acceptance, and then forwarded on to DOE as a recommendation.

To accomplish the tasks identified in the comprehensive project workplan, several levels of management were utilized to focus on specific research areas. The various levels of management were necessary to compliment, promote involvement, and ingrain the public/stakeholder perspectives of RFCAB members, E/WM Committee members, and the general public. The levels of management participation were broken up into:

• E/WM Committee Point-of-Contact for a specific research area;
• E/WM Committee Point-of-Contact for an educational presentation;
• E/WM Committee member involved in development of the "Cleanup Principles and Critical Reporting Elements";
• E/WM Committee member involved in the review of research and written "Cleanup Principles and Critical Reporting Elements," and;
• RFCAB member involved in review and evaluation of written "Cleanup Principles and Critical Reporting Elements."

Throughout the course of this project, approximately forty people were involved. Those forty people included RFCAB members, E/WM Committee members (which is made up of RFCAB members and the general public), and RFCAB Staff.

In early June of 1995, the E/WM Committee first began defining what the project would entail. At that time, the project name was the "How Clean is Clean?" project. At the June 15th E/WM Committee meeting, a strawman outline and project flowchart were developed, and immediate research tasks were identified. The immediate research tasks included: identifying a list of resources on the "How Clean is Clean?" topic, and; identifying individuals and agencies to interview on the potential focus and breadth of the "How Clean is Clean?" project.

The E/WM Committee wanted to perform interviews with key DOE, CDPHE, EPA, Rocky Flats site contractor, academic, interest group, and stakeholder representatives to validate the initial project objective. These individuals or groups were labeled as having a "key interest" in the project’s end product. The interviews would solicit the opinions of the representatives on the initial project objective, and contribute to producing a refined project objective. To expedite the interview process, a standard project description and questionnaire document was developed, and the committee quickly identified individuals to be interviewed. Primarily, the committee would interview individuals in EPA, CDPHE, Kaiser-Hill, and DOE. The committee also identified a professor at the University of Denver, a local city representative, and a local business manager to be interviewed.

The committee decided that the interviews with DOE, Kaiser-Hill, EPA, and CDPHE would be in a roundtable format that would make up the majority of the next committee meeting on July 20, 1995. The committee felt that the roundtable format would be most productive and beneficial for these four "key interest" groups, since they often question the intent and focus of each other. By having them all in the same place, answering the same questions, a common understanding and discussion could take place.

As for the last three interviews, Mike Freeman and Tom Gallegos would perform these and provide the results back to the E/WM Committee by October 19, 1995. Mike Freeman would interview a professor at the University of Denver, and Tom Gallegos would interview a manager with U S WEST and a local city representative. The focus of these interviews was to obtain comments and opinions from members of the public with knowledge of the issues at Rocky Flats.

After the roundtable discussion was held with DOE, Kaiser-Hill, EPA, and CDPHE at the July 20, 1995 E/WM Committee meeting, the committee found itself reevaluating the initial project objective. The roundtable discussion yielded some very valuable insights from these four "key interests," the most important of which focused on the project’s final product or deliverables. DOE, Kaiser-Hill, and the two agencies concurred that setting quantitative cleanup levels was well beyond what the E/WM Committee should be trying to produce. They also uniformly agreed that a set of "guiding principles" would be the most valuable with regard to what we were trying to accomplish. In particular, those "guiding principles" should entail a list of "core values" that are important in making cleanup decisions.

The E/WM Committee held a work session on July 25, 1995 to digest all the information that surfaced during the roundtable discussion. Most importantly, the meeting was necessary to have a dialog regarding changing the project objective, and planning next steps for the project. Tom Gallegos recommended at this meeting that the initial project objective be modified to focus on producing a set of guiding principles and reporting parameters/requirements. The E/WM Committee members attending this work session agreed, and Tom committed to further define that modified project objective.

At the next E/WM Committee meeting held on August 17, 1995 the committee began with a review of the last monthly meeting, specifically the roundtable discussion. The dialog that took place at the work session was also discussed, along with the necessity to change the initial project objective. Tom Gallegos made a recommendation to modify the initial project objective to focus on producing a set of guiding principles and reporting parameters/requirements. The committee members agreed, and a discussion on developing a more qualitative project approach, and concentrating less on quantitative cleanup levels, proceeded.

In particular, the committee discussed the value of focusing on qualitative guidance and not trying to interpret numeric cleanup levels. After all, the Committee members were not experts in evaluating the variety of cleanup levels that exist, and any numeric recommendation we might make could be easily disregarded. In addition to the Committee’s rather uneducated standing, the point was raised that numeric cleanup levels are dynamic and unfixed in nature. Existing numeric cleanup levels are based on current scientific knowledge and can be influenced by the current political climate. So, why would the Committee want to make a recommendation that might change or not be applicable in some situations?

Based on these arguments, the committee decided that the new project objective should be to develop a "philosophy" that can guide DOE and the regulatory agencies in performing the cleanup activities. This philosophy should be flexible enough to allow for a variety of cleanup alternatives and future land uses, and, most importantly, incorporate our public/stakeholder perspectives into a standard process for determining appropriate cleanup levels for individual areas. Our public/stakeholder perspectives being the most valuable and important part of the product, since DOE and the regulatory agencies had never really factored these into the decision making process before. Once this conclusion was reached, the Committee began discussing the particular components that would make up these guiding principles or "philosophy."

Discussions at the June 28, 1995, E/WM Committee work session were primarily focused on assembling the interview format and schedule but, we also began talking about constructing a decision matrix. Tom Gallegos presented the idea of constructing a decision matrix to correlate numeric cleanup levels with specific areas of our public/stakeholder concerns. The idea was to provide DOE, Kaiser-Hill, and the regulatory agencies with this matrix that they would refer to when making the cleanup decisions. The overall format of the decision matrix was to be, "if this is the situation, then this is the action that you take, or cleanup level that must be met."

In the brief time left in the two hour work session, we quickly constructed a list of specific areas in the decision matrix. The specific areas that were initially identified for the decision matrix included: land use; risk level; contamination level; type of contamination; cost of the cleanup activity; public/stakeholder perspective on the cleanup; ecological impacts; project duration and immediacy; trade-offs for action or in-action; existing conditions of the area to be cleaned up, and; waste generation.

In following E/WM Committee meetings and work sessions, we continued to entertain the idea of the decision matrix, and added a couple more items to the list of specific areas. However, with the subsequent change in the project objective, the Committee’s attention was turned to developing guiding principles or "core values." At the October 10, 1995, E/WM Committee work session, the idea of developing the decision matrix finally met an end, and that basic list was rolled into creating "core values."

At the October 10, 1995, E/WM Committee work session, all the participating members agreed that one of the tasks that the entire Committee should undertake was to develop a list of "core values" associated with acceptable cleanup standards for Rocky Flats Environmental Technology Site. All the Committee members were asked to construct their own list of values and beliefs that they felt were important to address in the cleanup of the site, and present them at the next committee meeting.

The next Committee meeting was held on October 19, 1995, and several members presented ideas that they had constructed on "core values." A discussion was held, and many of the ideas were consolidated since they followed similar themes. The initial list of "core values and beliefs" as constructed that night included: 1) Future use should be compatible with risk; 2) Risk management in lieu of risk elimination; 3) There should be no further degradation of the environment; 4) Budgetary considerations should be a part of decision-making; 5) Selected areas may never be cleaned to unrestricted use; 6) Institutional controls should be developed to ensure proper management of contaminated parcels, and; 7) Cleanup should minimize waste generation. In assembling this list of "core values and beliefs," the Committee decided that we would continue to add items as they came up. Therefore, this list of "core values and beliefs" was regarded as a living document, to be added to and modified as the project proceeded.

At the same October 19th committee meeting, the Committee had a lengthy discussion over identifying the boundaries or types of cleanup projects to which our project would apply. We felt there was a clear need to pin point the types of cleanup activities that the "core values and beliefs" would be used for, so they could not be taken out of context. After all, there were a wide variety of cleanup activities that would be taking place at the site, and many are quite different in nature.

After discussion, the Committee drafted the following "boundary" language to identify the types of cleanup activities that our "core values and beliefs" would address:

The Committee did conclude that guiding principles associated with building decontamination and demolition (D&D) would be a separate effort or project to be undertaken in the future. Building D&D is very specialized, and through the course of actual D&D work, would eventually progress to be governed by our guiding principles covering external cleanup activities.

On September 21, 1995, the monthly E/WM Committee meeting was held, and the Committee was transitioning from creating the new project objective, to developing "core values." At this meeting, which occurred between those two activities, the Committee members concentrated on developing project tasks, establishing research assignments, and establishing deadlines for completion of research. To achieve this, the Committee first assembled a list of general categories of research activities, then focused on specific tasks within those categories. Next, committee members volunteered for specific research tasks, and finally deadlines were assigned to those individual research tasks. Those research tasks and deadlines were as follows:

• Toxicology/Health Physics (October 5, 1995)
  By: Susan Griffin, EPA Toxicologist
  Title: Contaminants at Rocky Flats
• Risk Assessment (November 2, 1995)*
  By: Bonnie LaVelle, EPA CERCLA project manager
  Title: Fundamentals of Risk Assessment
• Panel on Risk Assessment and Risk Management (December 7, 1995)*
  Panelists: Jim LaVelle, Camp, Dresser, and McKee; Frazier Lockhart, DOE/Rocky Flats; Diane Niedzwieki, CDPHE; and Niels Schonbeck, Metropolitan State College
• Risk Communication (February 1, 1996)*
  By: Sonya Pennock, EPA, and Laura Belsten, University of Denver
  Title: Conceptualizing and Communicating Risk

With these research tasks assigned and the schedule set, the Committee embarked on establishing the foundation of this project.

As part of this project, the Committee identified several educational presentations for the RFCAB. These presentations were intended to provided RFCAB members, E/WM Committee members, and the public with basic information on the relevant topics of this project. The presentations were scheduled to take place at monthly RFCAB meetings, and were intended to coincide with the general project research being performed. Three topics were identified to include toxicology/health physics, risk assessment (both human and ecological), and risk communication. These presentations were scheduled in successive months, beginning in October, and the E/WM Committee utilized "neutral" parties to give them. The Committee also resolved to have follow-up presentations, as needed, at monthly committee meetings.

Mike Freeman’s research task was to review and evaluate the Rocky Flats Future Site Use Working Group (FSUWG) Report, and provide a summary to the E/WM Committee by the October committee meeting. At the E/WM Committee meeting on October 19, 1995, Mike gave a verbal report of his review and evaluation of the document. Mike reported that the FSUWG Report’s consensus recommendations were well-founded, and that they did support the purpose and objective of this project. Mike advocated that some of the FSUWG consensus recommendations be utilized in this project, especially to form specific "core values and beliefs" statements.

Ken Korkia’s research task was to review the report published by the National Environmental Policy Institute (NEPI) on its "How Clean is Clean?" project, and provide a summary report to the E/WM Committee by the November 16, 1995, committee meeting. The focus and purpose of Ken’s research was to review the NEPI report to see if any of its findings/recommendations would be useful for this project. In his report, Ken recommended that the E/WM Committee continue to track this NEPI project, and obtain the phase two report when it comes out. Ken did not see a need to incorporate the NEPI recommendations into this project, since the project’s "core values and beliefs" were already addressing those aspects.

The focus and purpose of this research task for Tom Gallegos was to develop a comprehensive project workplan for the project to guide the development, drafting, and refinement of the cleanup principles and reporting parameters/requirements. When this project first began, aspects of the workplan came from a preliminary project flowchart that was developed by Tom DuPont, the other E/WM Committee Co-Chair. With the preliminary project flowchart as a starting point, Tom Gallegos began developing a comprehensive list of project tasks for a project task schedule. At the November 16, 1995, E/WM Committee meeting, Tom presented the comprehensive project workplan, and asked for comments from all the Committee members. While the Committee reviewed and commented on this first draft, which took until February 1, 1996, Tom proceeded to make modifications to formalize the document as the comprehensive project workplan. When the comments were received back from the Committee, the document was modified appropriately and finalized in late February of 1996.

As Tom Gallegos’ second project task, he worked with Ken Korkia to design and construct the project workbook. The focus and purpose of this task was to assemble a book that would contain all the project process documentation, and information created or collected throughout the project. The project workbook would serve as the retaining vault of everything that was done on this project, from the beginning to its successful completion.

Sasa Jovic’s research task was to review the contaminant and background databases currently maintained by Rocky Mountain Remediation Services (RMRS) and R.M. Stoller and Associates, and provide a summary report to the E/WM Committee. The focus and purpose of Sasa’s research was to review the two databases to provide the E/WM Committee with baseline information on the extent and types of contamination at Rocky Flats. At the E/WM Committee meeting on February 15, 1996, Sasa gave a final report presentation of his review of the databases and the contaminant information they contain. In his report, Sasa stated that really no temporal or spatial site-wide contamination summary was available. Therefore, it would not be possible for this project to identify priorities with regard to contamination at Rocky Flats, in any of the specific media (i.e., soils, surface water, and ground water). For these reasons, Sasa recommended that this project must remain in the qualitative domain, without identifying specific contaminants, their phase, and their temporal or spatial distribution.

Gary Thompson and Kelly Coleman’s research task was to investigate existing cleanup standards, and provide a summary report to the E/WM Committee. The focus and purpose of Gary and Kelly’s research was to examine existing regulatory cleanup standards, and evaluate how they could be utilized in this project. In their report, Kelly presented the CDPHE ground water and surface water standards, and explained that they were the regulatory cleanup levels that were applicable to Rocky Flats. Kelly went on to remark that, although these standards were valuable, they were not really applicable to this project. Since the project’s objective had changed from a quantitative to a qualitative focus, numeric cleanup levels were not necessary. Kelly closed by stating that this research task had been very valuable, both for himself, and the E/WM Committee. The value was that it had made the committee members aware of the CDPHE radionuclide standards, and we could now apply that knowledge to future projects.

Tom DuPont’s research task was to investigate the background levels of radionuclides that exist in the Denver Metro area, and provide a summary report to the E/WM Committee. The focus and purpose of Tom’s research was to examine the background levels of radionuclides that exist in the Denver Metro area, assuming that Rocky Flats never existed, and to provide the E/WM Committee with baseline information on the extent of Plutonium contamination in soils along the Front Range of Colorado. At the E/WM Committee meeting on February 15, 1996, Tom gave a final report presentation of his investigation into the background levels of radionuclides in Denver, and Plutonium contamination in soils. In his presentation, Tom went on to make several recommendations on how his research findings would be applied to this project. First, Tom recommended that a range of values be used for background radionuclide levels, rather than a single number. Next, Tom recommended that those background radionuclide values be utilized as benchmarks or references, rather than a goal or target. Finally, Tom recommended that the E/WM Committee define a method or guideline for utilizing those background radionuclide values in the cleanup process.

As can be seen from the previous section on research and development, that a great many aspects contributed to the finalized Clean Principles and Critical Reporting Elements, and served to established the project’s foundation. However, the process of creating and refining the final product by applying the research, was perhaps the most valuable part of the overall project. In this section, that process of creation and refinement of the final product, will be presented.

The start of the creation process occurred after a discussion at the February 15, 1996, E/WM Committee meeting. The discussion centered on the list of "core values and beliefs," and regarded developing an explanatory paragraph for each item. The intention of providing explanations to the "core values and beliefs" was to define their meaning from the E/WM Committee’s standpoint, and to help the RFCAB understand what they were about. Well, that discussion prompted Sasa Jovic to write, over the next several days, a two page paper with brief explanations for six of the "core values and beliefs." Sasa’s paper created explanations for health and safety during cleanup, minimization of waste generation, no further degradation of the environment, background levels, technology utilization, and risk management vs. risk elimination. What Sasa had produced in his paper, provided a great start for writing the explanations, and the E/WM Committee decided to have a special work session to focus on them.

In addition to this activity on the "core values and beliefs" explanations, the E/WM Committee began assembling a list of "critical elements of the process" from the old decisions matrix items. These "critical elements" were intended to be the standard aspects addressed in each cleanup project at Rocky Flats, and would accompany the "core values and beliefs" in the RFCAB’s recommendation to DOE.

In the meantime before the work session, Tom Gallegos and Tom DuPont reviewed Sasa Jovic’s paper, and began modifying and adding to the explanations. At the work session on February 27, 1996, the E/WM Committee members proceeded to review, discuss, and modify the explanations. The work session provided a great deal more focus on what we were trying to accomplish with the explanations, and we also added several "core values and beliefs" to the list. The "core values and beliefs" that were added to the list included: applicable cleanup regulations can be tailored to Rocky Flats; future use should be compatible with risk; areas not clean to the level of unrestricted use; institutional controls; and budgetary considerations as part of the decision making process.

Over the next two months, Tom DuPont, Sasa Jovic, and Tom Gallegos worked diligently on the "core values and beliefs" explanations to produce a first draft on April 8, 1996. The only departure from work on the explanations, was when the E/WM Committee formally changed the project’s title to the "Cleanup Principles and Standards Project." Along with this, the Committee began referring to the "core values and beliefs" explanations as the "cleanup principles," and the "critical elements" as the "operating requirements/parameters for cleanup."

This first draft of the cleanup principles document contained all six of the explanations that Sasa Jovic had written, with some changes. Tom Gallegos and Tom DuPont had also added six new cleanup principles, and the list of operating requirements/parameters for cleanup. The cleanup principles that Tom DuPont wrote, included budgetary considerations, tailoring of cleanup standards, and institutional controls. Tom DuPont also re-wrote, and took ownership of, two of Sasa’s original explanations for, background levels and risk management/elimination. The cleanup principles that Tom Gallegos wrote included risk levels/land use, phases of action, and optimization of these principles. Tom Gallegos also re-wrote and took ownership of Sasa’s original explanation for technology utilization. In addition to the cleanup principles Tom Gallegos developed for this first draft, he expanded each item in the list of the operating requirements/parameters for cleanup, and wrote the purpose and scope from the comprehensive project workplan that he had recently completed. With regard to the operating requirements/parameters for cleanup, it was decided to renamed them to something less vague. So, the "operating requirements/parameters for cleanup" were renamed the "Critical Reporting Elements."

With this first draft of the "Cleanup Principles and Standards" written, the E/WM Committee finalized the document with minor modifications at its April 22, 1996, meeting. Tom Gallegos was scheduled to present this first draft before the RFCAB at its May 2, 1996, meeting but, due to more immediate issues facing the RFCAB, the presentation was postponed. The Committee, however, did not waste this opportunity, and we invited

RFCAB members to provide comments on the "Cleanup Principles and Standards" anyway. So, at the May E/WM Committee meeting, we received and discussed comments from several RFCAB members. The comments included rewording the "no further degradation", "technology utilization", and "background levels" cleanup principles, and adding some language to clarify "near-term" actions. The E/WM Committee took those comments provided on May 16, 1996, and made the appropriate changes and additions that had been suggested.

Tom Gallegos was scheduled to present the second draft of the "Cleanup Principles and Standards" at the June RFCAB meeting. The approach was to discuss each principle individually, and to identify substantive issues. At the meeting, RFCAB members spent some time reviewing the draft "Cleanup Principles and Standards," and recommended several changes to the text. However, the discussion was not completed. Since there was no specific deadline for completing this project, the RFCAB tabled further review of the draft until its next meeting. The areas that the RFCAB commented on, and revised, included "technology utilization" and "background levels." The RFCAB also changed the title of the document to "Cleanup Principles and Critical Reporting Elements," to be consistent with the name of the critical reporting elements section. With the RFCAB comments, and revised language, that were generated from this meeting, the E/WM Committee reviewed the modifications, and made several small edits to produce draft three.

Tom Gallegos presented draft three of the "Cleanup Principles and Critical Reporting Elements" at the July 11, 1996, RFCAB meeting. In a continuation from the previous month’s progress, RFCAB members worked through several more sections of "Cleanup Principles and Critical Reporting Elements." Again, several comments were made, and some modifications resulted. Most importantly though, many of the sections were approved with final language, including "technology utilization." The "background levels" section remained unapproved, with final language to be provided at the August RFCAB meeting. As was the routine, the E/WM Committee reviewed the modifications, and made several small edits to produce draft four.

Tom Gallegos presented draft four of the "Cleanup Principles and Critical Reporting Elements" at the August 1, 1996, RFCAB meeting. The RFCAB members continued their work through the unapproved sections, and made minor modifications. Review of all the "Cleanup Principles and Critical Reporting Elements" were completed but, a couple issues arose that needed the E/WM Committee’s clarification. First, the "background levels" language needed to be approved by Jack Kraushaar, a RFCAB member who was not in attendance at this meeting. Second, the question was raised as to whether language should be included under the "health and safety during cleanup" section, regarding retention of experienced workers? Again, per the routine, the E/WM Committee reviewed the modifications, and made several small edits to produce draft five. After a lengthy discussion, the Committee also decided not to include the retention of experienced workers language, for the "health and safety during cleanup" section.

Tom Gallegos presented draft five of the "Cleanup Principles and Critical Reporting Elements" at the September 5, 1996, RFCAB meeting. The RFCAB members had three outstanding points to resolve including: adding a new sentence for the "scope of applicability section; language on the retention of experienced workers; and final wording for the "background levels" section. In addressing these points, the RFCAB decided to add the proposed sentence to the "scope of applicability" section, with a minor modification. Then, the RFCAB decided to modify the "health and safety during cleanup" section, to include language on retaining the trained work force. Last, Jack Kraushaar reviewed the "background levels" language, and made a slight modification. No more additions or modifications were made to the document, and the RFCAB approved the "Cleanup Principles and Critical Reporting Elements" as modified.

With the completion of the RFCAB approval process on September 5, 1996, the finalized "Cleanup Principles and Critical Reporting Elements" document could be delivered to DOE as a recommendation. A short cover letter was drafted by the RFCAB Chair, Tom Marshall, and the "Cleanup Principles and Critical Reporting Elements" document was attached. During the course of drafting the recommendation cover letter, the RFCAB Executive Committee decided that the recommendation would go to EPA and CDPHE as well. Their decision was based on the fact that DOE, EPA, and CDPHE are jointly involved in planning and administering all the cleanup activities at Rocky Flats through the Rocky Flats Cleanup Agreement (RFCA). By sending the "Cleanup Principles and Critical Reporting Elements" to EPA and CDPHE, the RFCAB will have covered all the bases. So, on September 9, 1996, the "Cleanup Principles and Critical Reporting Elements" recommendation was sent to Jessie Roberson the DOE manager over Rocky Flats, Jack McGraw the EPA Deputy Regional Administrator, and Tom Looby the CDPHE director over the Office of Environment.

With the delivery of the "Cleanup Principles and Critical Reporting Elements" recommendation, the E/WM Committee discussed what the next steps were to be, since the final product had been delivered. In the past, the RFCAB had always delivered its recommendations to DOE, and waited for a response on how it would be utilized. The E/WM Committee felt that there was a fundamental flaw in this approach, since nothing was ever done to get feedback to improve and refine the product. So, the Committee decided that the "Cleanup Principles and Critical Reporting Elements" recommendation would be a perfect situation to try a new approach for making the RFCAB’s products more useable.

Tom Gallegos proposed to the E/WM Committee that we "close the loop" on the "Cleanup Principles and Critical Reporting Elements" by obtaining direct feedback from DOE, Kaiser-Hill, EPA, and CDPHE. Specifically, we would use a feedback process to include: soliciting comments from DOE, Kaiser-Hill, EPA, and CDPHE; discussing their issues and comments; incorporating appropriate items and aspects; and delivering the improved "Cleanup Principles and Critical Reporting Elements" as a living document. All the Committee members thought this was a great approach, and necessary in our plight to form a partnership in cleaning up Rocky Flats. Tom Gallegos took on this task to obtain feedback on the "Cleanup Principles and Critical Reporting Elements" recommendation.

The purpose of this task for Tom Gallegos was to obtain formal and informal feedback from DOE, Kaiser-Hill, and the agencies on how the E/WM Committee could make the "Cleanup Principles and Critical Reporting Elements" a better tool, and how we could encourage their use. To achieved this, Tom Gallegos identified key contacts at each of the concerned parties, beyond the three people that received the formal recommendation. Tom was looking for people that were familiar with this project, and could give specific informal comments. Tom focused on obtaining informal comments because the RFCAB expected to receive formal responses, from an agency standpoint, from the three people that initially received the recommendation. Tom was able to identify the following people for the informal feedback: Jeremy Karpatkin for DOE; Rick Roberts for Kaiser-Hill; Tim Rehder for EPA; and Steve Tarlton for CDPHE. After receiving the informal comments from these individuals, all the research and development tasks for this "Cleanup Principles and Critical Reporting Elements" project would be completed. On January 27, 1997, the last set of informal comments was received, and the construction of this project report was initiated.

The one year and seven months that it took to complete this project pales in comparison to the broad objective that was identified, and the type of sophisticated and multifaceted issues it contained. This report, as it was identified in the first pages, documents the public involvement process utilized throughout this project. Most importantly, it shows how public/stakeholder ideas and concerns were taken, discussed, and then developed into a set of principles to be used in cleaning up Rocky Flats. This "Cleanup Principles and Critical Reporting Elements" project accomplished what no other DOE citizens advisory board had ever done, and that achievement can be viewed as a milestone for the type of issues that can now be addressed by the public. The high quality and comprehensive nature of the "Cleanup Principles and Critical Reporting Elements" is due to the thoughtfulness and dedication of all the volunteers that contributed their time to this project. The finest hour for all the people that were involved in this project came on July 3, 1997, when the "Cleanup Principles and Critical Reporting Elements" were first applied to a cleanup project at Rocky Flats. On that day, the RFCAB voted unanimously to include and use the "Cleanup Principles and Critical Reporting Elements" as part of an E/WM Committee recommendation on the T1 Trench Proposed Action Memorandum.

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