INVOLVING STAKEHOLDERS IN ROCKY FLATS
D&D POLICY DECISIONS
Jack Hoopes, APR, Alan Parker and John Corsi
Kaiser-Hill Co., L.L.C.
ABSTRACT
The Rocky Flats Closure Project involves deactivating and decommissioning (D&D) some 750 buildings and other structures ranging from highly contaminated former plutonium production facilities to uncontaminated office trailers and outbuildings. D&D program planning began in earnest in fiscal year 1997 with the formation of working groups to develop a Decommissioning Program Plan (DPP), Decommissioning Operations Plans (DOP), and D&D building radiation closure standards. Working groups comprise U.S. Department of Energy (DOE), U.S. Environmental Protection Agency (EPA), State of Colorado, and Kaiser-Hill representatives. D&D program decision-makers are engaging stakeholders concurrent with internal debate on critical policy issues, including: 1) building debris disposition options; 2) building cleanup standards; and 3) work controls to ensure the health and safety of workers, the public, and the environment. Stakeholder interactions are occurring on multiple levels, including: 1) direct participation by stakeholders in working group sessions; 2) stakeholder dialogue at a series of "D&D Pizza Meetings"; 3) "before" tours of buildings slated for D&D; 4) interactions with a Rocky Flats Citizens Advisory Board ad hoc D&D subcommittee; and 5) scoping sessions for receiving stakeholder comments on D&D program plans. D&D project managers are employing fundamental public participation strategy and tactics in managing communication among stakeholders in formulating D&D policy decisions. Key consensus points reached initially include a strong preference among stakeholders for off-site disposal of demolition debris and stringent work controls to prevent releases to the environment during D&D activities. These points have implications for D&D program scope and costs and for post-closure site land use and stewardship. Familiarity with Rocky Flats' experience will benefit other DOE sites seeking to manage stakeholder involvement programs intended to support D&D policy development.
INTRODUCTION
As the DOE Integrating Management Contractor for the Rocky Flats Environmental Technology Site, Kaiser-Hill Company, L.L.C., is responsible for the safe cleanup and closure of Rocky Flats, a former nuclear weapons production facility located 16 miles northwest of downtown Denver. Kaiser-Hill is now in the second year of a ten year project comprising three major elements: 1) removal of plutonium and special nuclear materials; 2) deactivation and decommissioning of all buildings and structures, and 3) environmental remediation to prescribed cleanup levels. These project elements are described among major objectives set forth in the Rocky Flats Cleanup Agreement (RFCA), a legally binding agreement signed by DOE, EPA, and the State of Colorado on July 19, 1996. An extensive stakeholder involvement effort accompanied RFCA negotiations.
The RFCA provides an overall framework for project D&D activities. The agreement stipulates that "all contaminated buildings will be decontaminated as required for future use or demolition; unneeded buildings will be demolished." It provides direction for the D&D sequence, disposition of building debris and consultation with stakeholders regarding potential future use of uncontaminated or decontaminated buildings. Though the RFCA provides this general framework for D&D, it offers few specifics on how the D&D program should be carried out.
INITIAL
EFFORTSD&D project managers understood that stakeholders had some level of awareness of the nature of the Rocky Flats D&D effort through their stakeholder dialogue concurrent with RFCA negotiations. In addition, stakeholders were provided the opportunity to comment on early D&D efforts through review of project-specific authorizing documents called Proposed Action Memoranda, or "PAMs". However, these early efforts only focused on a few uncontaminated buildings. Limited effort was devoted before fiscal year 1997 in providing stakeholders an opportunity to gain an understanding of the full scope of the D&D program and the approaches being contemplated by technical staff.
In November 1996, a D&D working group comprising DOE, EPA, State, and Kaiser-Hill technical staff was formed to draft a Decommissioning Program Plan (DPP). The DPP describes the overall D&D process at Rocky Flats. The working group recognized the need to engage Rocky Flats stakeholders in dialogue about building cleanup standards and other D&D planning assumptions. It was initially envisioned that the cleanup standards would guide the decontamination process and would have significant implications for important stakeholder issues like public health protection and building debris disposition.
In April 1997, DOE-Rocky Flats Communication staff responded to a working group request to initiate stakeholder dialogue on the D&D building cleanup standards. A public meeting was scheduled, stakeholder notifications were made, and the meeting was held on April 22, 1997. Stakeholder feedback on this initial meeting was decidedly negative. Post-meeting analysis revealed several weaknesses, including:
Shortly after the initial public meeting, DOE and Kaiser-Hill communication staff held a conference call with interested stakeholders to seek input on how to restart the dialogue and how they would like to be included in D&D decision-making.
D&D STAKEHOLDER INVOLVEMENT PROGRAM STRUCTURE
Based on stakeholder input and analysis of D&D project needs, a three-tiered stakeholder involvement program was developed. Major program elements were as follows:
The D&D Scoping Session was conducted as part of a series of public meetings held routinely to update stakeholders on Rocky Flats activities. The session was designed for stakeholders who desired an overview of the D&D program and an opportunity to provide input into general policy decisions. The session was advertised through major areas newspapers, direct mail, and community newsletters.
For those stakeholders desiring a greater level of understanding and involvement, a series of "D&D Pizza Meetings" was held. These meetings were convened once every two weeks from May 21, 1997, through mid-September, 1997. Regular participants included representatives from local cities, activist groups, the local Steelworkers union, the Rocky Flats Community Reuse Organization, and the Rocky Flats Citizens Advisory Board (RFCAB). Kaiser-Hill Communication staff facilitated the meetings, which were structured to maximize interaction and dialogue among stakeholders and D&D project management and technical staff. The agenda for each session was developed in consultation with stakeholders. Conference calls among D&D staff and stakeholders were held between sessions early in the series to gain stakeholder feedback on the sessions and develop agenda topics for future meetings. The Kaiser-Hill Vice President for Closure Projects led technical briefings throughout the series. A record of each meeting was provided to attendees in a follow-up mailing.
In addition, D&D project management extended an open invitation for stakeholders to participate in the internal D&D working group sessions. The invitation targeted stakeholders desiring the greatest level of understanding and involvement in D&D issues. Few stakeholders responded, primarily due to the time commitment and high level of detail involved. None-the-less, opening these sessions to the public served to increase trust between stakeholders and decision-makers.
The D&D stakeholder involvement program included several other measures. Very early drafts of the DPP and Building 779 Decommissioning Operations Plan (DOP) were provided to interested stakeholders. A DOP is a RFCA decision document that provides a detailed project description for each significantly contaminated building; it is envisioned that approximately 15 DOPs will be created at Rocky Flats. This was the first time that major Rocky Flats decision documents had been released at such an early stage of development. Release of these documents not only helped build stakeholder understanding and stimulate dialogue, but also symbolized D&D project managers' interest in collaboration with stakeholders and served as a significant trust-builder.
The RFCAB was contacted regarding their interest in becoming involved in D&D dialogue. Briefings on D&D project planning and status were offered to RFCAB. The RFCAB elected to establish a D&D ad hoc committee. The committee co-chairs determined that the most effective way to gain information and engage in dialogue about the D&D program was to participate in the D&D Pizza Meeting series. Committee chairs provided periodic reports to the full RFCAB at their monthly work sessions.
D&D project managers offered stakeholders a tour of Building 779, the first major plutonium building scheduled for D&D. Stakeholders expressed interest in the tour, which was conducted on October 20, 1997. This timing was planned as a benchmark visit to allow stakeholders to track Building 779 D&D progress. Follow up tours are planned once every three to four months throughout the Building 779 D&D project to allow stakeholders to track progress.
Progress in the D&D stakeholder dialogue was covered in Crossroads, the Rocky Flats Site newspaper, and Closure, the Rocky Flats Site community newsletter.
STAKEHOLDER ISSUES
The greatest amount of stakeholder input was learned through dialogue at the D&D Pizza Meeting series. Primarily through this dialogue, stakeholders expressed concern about the following issues:
Worker Health and Safety -- Stakeholders are interested in gaining confidence that D&D work controls would be protective of worker health and safety. Many saw these controls as the principal means of ensuring not only protection of workers but also prevention of potential off-site releases of contamination.
Disposition of Building Debris -- Stakeholders acknowledged the need to balance the costs of off-site disposal vs. the building cleanup standard level. However, the majority of stakeholders made it clear that D&D building debris should not be disposed at Rocky Flats.
D&D Technologies -- Some stakeholders expressed interest in seeing an ongoing effort to identify D&D technologies used elsewhere that could be applied to improve the effectiveness and efficiency of the Rocky Flats D&D project. Project managers responded by providing extensive briefings on D&D experience at other DOE sites, including Hanford and Weldon Spring, as well as at the Fort St. Vrain civilian nuclear reactor decommissioning project in Colorado.
Impacts to Groundwater -- Some stakeholders gained awareness that dismantlement of major plutonium buildings could impact groundwater flows, potentially introducing contamination into the groundwater. These stakeholders sought assurances that groundwater impacts would be adequately mitigated to prevent off-site releases.
Impacts to Air Quality -- Some stakeholders expressed concern that work controls be put in place to prevent the possibility of airborne releases of fugitive dust caused by D&D activities. These stakeholders indicated a further desire to see "real-time" monitoring of any fugitive dust emissions.
Building 779 as a D&D Pilot -- Stakeholders recognized that D&D project managers and workers will gain significant experience as the overall D&D project proceeds. They expressed interest in applying lessons learned during Building 779 D&D to improve future performance and considering the DPP as a dynamic document that could be revised to reflect new, improved ways of performing D&D work.
MANAGEMENT RESPONSE
A key factor contributing to the success of the Rocky Flats D&D program has been the sustained, active involvement of senior level Kaiser-Hill decision makers. In some organizations, management interaction with stakeholders is delegated to middle managers and/or communication staff. In these cases, stakeholders can quickly become skeptical of whether their input will have meaning. Senior-level Kaiser-Hill decision makers have been actively involved in all aspects of the Rocky Flats D&D public involvement program. Their leadership during Pizza Meeting dialogue has been particularly effective. "Real-time" commitments are being made. The relationships forged through these interactions have led to increased trust among stakeholders that their input not only has meaning, but is actually affecting project decisions and direction. Management has made a commitment to continue to dialogue on unresolved issues, including building standards and future disposal options.
The Building 779 DOP is now being finalized. This document will codify key decisions on how the D&D project will be executed in Building 779. Because dialogue with stakeholders occurred well before the draft was complete, the content reflects stakeholder values and interests. For example, stakeholder interest in preventing the possibility of airborne releases is reflected in the extent of air monitoring and dust suppression and other air emissions controls called for in the document. Also, the 779 DOP addresses stakeholder concern about on-site disposal of D&D building debris by indicating that all Building 779 demolition rubble will be disposed off-site. Finally, D&D project managers have responded affirmatively to stakeholder interest in considering Building 779 D&D as a pilot project and applying lessons learned in future D&D activities. Other formal D&D decision documents, such as DOPs for Buildings 771 and 886, are in the early draft stage and also being written to reflect stakeholder values.
RETURN ON INVESTMENT
A basic tenet of public participation is that stakeholders should be involved early in the decision-making process, before decisions are made. The Rocky Flats D&D stakeholder involvement program is a successful case-study-in-the-making demonstrating the value of this approach. Two outcomes derived by this approach should motivate D&D project managers at other DOE sites to use it: 1) the Rocky Flats D&D planning effort is benefiting from information about stakeholder expectations, and 2) confidence is high that stakeholder interests have been identified and addressed before they emerge through other channels as reasons for delaying or complicating project plans and schedules once on-the-ground D&D work is under way. The fundamental approach of identifying stakeholders and inviting dialogue during early D&D program planning is directly transferable to other DOE sites.
Dialogue between D&D project managers and Rocky Flats stakeholders continues today. Several steps have yet to be taken to derive fully the benefit of this dialogue. First, formal documents codifying policy decisions reflecting stakeholder values need to be finalized. Second, efforts should be intensified to publicize continuing opportunities for stakeholder involvement in the D&D program. Only in this way can new participants be attracted to the dialogue and can the D&D stakeholder involvement program be legitimately considered an open process. Finally, the effect of stakeholder input on D&D program policy decisions needs to be broadcast widely. By doing so, DOE managers can reinforce growing perceptions that they are administering the Rocky Flats Closure Project with the publics' best interests in mind.