AN INDEPENDENT ASSESSMENT OF ENVIRONMENTAL
MONITORING AT AND AROUND THE ROCKY FLATS
ENVIRONMENTAL TECHNOLOGY SITE NEAR
DENVER, COLORADO
Ken Korkia
Board / Staff Coordinator
Rocky Flats Citizens Advisory Board
9035 Wadsworth Parkway Suite 2250
Westminster, CO 80021
V:(303)420-7855 F:(303)420-7579
e-mail: kkorkia@rfcab.org
ABSTRACT
In 1996, the Rocky Flats Citizens Advisory Board (RFCAB) participated in the development of a Community Needs Assessment (CNA) for Rocky Flats. One of the major themes expressed by the local citizens near Rocky Flats in the CNA was concern over health effects from potential exposure to contaminants from the site. Related to this health concern were questions about the effectiveness of the environmental monitoring systems in place at and around the Rocky Flats facility.
To address some of these concerns, RFCAB undertook an independent evaluation of the environmental monitoring systems. To do so, the members developed a Request for Proposals and selected a contractor to perform the evaluation. RFCAB asked the contractor to evaluate all monitoring systems for all media, including air, groundwater, surface water, soils, and ecology. The evaluation included both permanent and project specific monitoring systems. The scope of the investigation also included the several entities responsible for conducting environmental monitoring including the site, the state health department and the local communities.
The purpose of the evaluation was two-fold. First, the contractor was asked to prepare a summary of the monitoring systems. The resulting work product was a comprehensive description of all the monitoring systems written in easily understandable language with maps and other illustrations. For the first time, members of the local community had a one source description of the entire range of monitoring systems in place at and around Rocky Flats. The second major product from the contractor was a critical analysis of the monitoring systems. This analysis was accompanied by a set of recommended changes and improvements to the monitoring systems and data reporting mechanisms.
RFCAB used the contractor’s analysis and recommendations to develop its own set of recommendations to forward to the Department of Energy, the Colorado Department of Public Health and Environment, and the local communities. Contained within this recommendation were suggested ways of augmenting the existing monitoring systems. A significant recommendation was to improve reporting of environmental monitoring information and data to the public.
By conducting the evaluation, RFCAB was able to provide a credible resource to the local community to help alleviate concerns about the monitoring systems in place at and around the Rocky Flats facility. In addition, RFCAB was able to provide a set of technically based recommendations for improving the environmental monitoring systems.
INTRODUCTION
The mission statement of the Rocky Flats Citizens Advisory Board (RFCAB) states in part that it is "...dedicated to providing informed advice and recommendations to the agencies (Department of Energy, Colorado Department of Public Health and Environment and the Environmental Protection Agency), government entities and other interested parties on policy and technical issues and decisions related to cleanup, waste management and associated activities." In 1996, RFCAB participated in the conduct of a Community Needs Assessment for the communities surrounding Rocky Flats. Later in the Fall of 1996, while reviewing the results of the Community Needs Assessment, RFCAB determined that members of the community were most concerned about the possibility of contaminants leaving Rocky Flats and whether the environmental monitoring systems in place were adequate. Without having expertise in the area of environmental monitoring, RFCAB decided, in keeping with its mission statement to provide "informed advice and recommendations," to hire an independent contractor to review the monitoring systems. Using the analysis performed by the contractor, RFCAB developed a set of recommendations for improvements to the environmental monitoring program associated with Rocky Flats.
The purpose of this paper is to present a process perspective on how the Rocky Flats Citizens Advisory Board conceived, developed and conducted the project to independently assess the environmental monitoring systems at Rocky Flats. The paper will describe the process RFCAB used in developing a Request for Proposals, hiring a contractor, managing the project, reviewing draft and final reports, developing a set of recommendations for changes to the environmental monitoring systems, and hosting a dialogue with those responsible for conducting environmental monitoring at and around the Rocky Flats site. It is hoped that this paper will spark interest in those who might want to initiate a similar project at another DOE Weapons Complex Site or other contaminated area, and then serve as a template for how to conduct a similar analysis. Results from the assessment at Rocky Flats will be touched upon, but it is not the author’s intent to present a lengthy description of these results, nor focus on the technical process used by the contractor in conducting the assessment.
ADDRESSING CONCERNS ABOUT ENVIRONMENTAL MONITORING AT AND
AROUND ROCKY FLATS
In 1996, the University of Colorado Health Sciences Center School of Nursing and the Jefferson County Department of Health and Environment conducted a Community Needs Assessment involving residents in close proximity to the Rocky Flats Environmental Technology Site. The Rocky Flats Citizens Advisory Board (RFCAB) assisted in the development and conduct of this Needs Assessment. Funding for the assessment was provided by the Department of Energy.
The primary purpose for the assessment was to "provide direction to the United States Department of Energy (DOE) as they design and implement health studies and programs during the cleanup of the Rocky Flats Environmental Technology Site (RFETS)." The target community was identified as the population living or working within a five mile radius of the perimeter of Rocky Flats. The research methodology consisted of analysis of both primary and secondary data. Primary data was obtained through interviews and focus groups of community residents. Secondary data included demographic information, and birth and mortality statistics for the target community. Following the collection and analysis of data, a summary report was prepared.(1)
During its review of the Rocky Flats Community Needs Assessment Final Report, RFCAB noted with particular interest the universal concern with environmental monitoring. Most members of the public were not aware that a monitoring program for air and water was in place, and for those who did know, there was concern for the adequacy of the programs, particularly in an era of budget reductions.
To address these concerns, RFCAB determined to conduct a study of the environmental monitoring systems at and around Rocky Flats. Early on, RFCAB decided that the outcome of the study should serve two purposes. First, the study should produce a comprehensive description of all monitoring programs currently in place, and second, that it should allow for the development of a set of recommendations for improvements to the monitoring systems. RFCAB knew that several entities, including the site contractors, the Colorado Department of Public Health and Environment, and the local municipalities whose sources of drinking water are in close proximity to Rocky Flats all conducted environmental monitoring. Unfortunately, there was not a singular reference that members of the community could turn to who wished to learn about the monitoring systems. Those reports or monitoring program descriptions that existed were fragmented and not readily understandable by a non-technical reader. Therefore, RFCAB knew that a comprehensive report, written in readily understandable, non-technical language was necessary.
The second outcome of the study was more complicated. Without its own expertise in the technical aspects of environmental monitoring systems, RFCAB had no means to address concerns about the adequacy of the programs. To solve this problem, RFCAB decided it would hire an independent contractor to review and perform a critical analysis of the monitoring systems. The contractor would develop two work products: a comprehensive description of the monitoring systems written in readily understandable language, and a set of recommendations with justifications for changes to the monitoring systems. Using the work products from the contractor, RFCAB would in turn develop a set of recommendations to forward to the entities responsible for the monitoring systems. Most importantly, the contractor’s work would allow RFCAB to fulfill its stated mission of providing "informed advice and recommendations" that would be technically sound.
To manage the project, RFCAB assigned the Chair of its Health Committee, Beverly Lyne, and the Board / Staff Coordinator, Ken Korkia, as Co-Project Managers. Volunteers were solicited from the Board’s membership to serve as a project review team to develop a Request for Proposals, review the submitted proposals and select a contractor, and then oversee the work of the contractor. Following completion of the project, the review team would develop a set of recommendations that would be forwarded to the full Board for its approval. Once approved, the recommendations would be transmitted to the Department of Energy and other entities involved in environmental monitoring at Rocky Flats.
HIRING THE CONTRACTOR
Once it had determined to hire a contractor to perform the assessment, RFCAB first needed to determine how much money to allot for the analysis and to procure the money from the Department of Energy as part of its budget for 1997. In developing its budget for 1997, RFCAB decided that a reasonable request would be $35,000, which was approved by the Department of Energy. The question remained, however, would a contractor be willing to perform the analysis for this amount of money? RFCAB decided to develop a Request for Proposals with a fixed budget amount for $35,000, and see if contractors would respond with a suitable proposal.
Before developing the Request for Proposals, RFCAB advertised in the Commerce Business Daily and local and regional newspapers stating that it was seeking expressions of interest and statements of qualifications from contractors who wished to bid on a proposal to conduct the analysis. Press releases announcing the project were also sent to trade papers and environmental newsletters. With these announcements, RFCAB received over 100 expressions of interest.
To develop the actual Request for Proposals, RFCAB divided the project into three discrete tasks, with specific deliverables for each. The first task was an investigation of the current monitoring program associated with Rocky Flats. This investigation would include all entities conducting monitoring such as the site contractors, the Colorado Department of Public Health and Environment, and the local municipalities. All environmental media would be included, specifically air, surface water, groundwater, soils and sediments. The contractor would be asked not only to look at the permanent monitoring systems, but those which were temporary or project-specific in nature as well. The deliverable for this task would be a written report describing all the monitoring systems in place, with a goal that it be concise and readily understandable, complete with appropriate maps and graphics.
The second task would be for the contractor to perform a critical analysis of the current environmental monitoring program, again for all media, and for both permanent and project-specific programs. In addition to their professional judgment, the contractor would be asked to review the Community Needs Assessment to ascertain the desires and concerns of the community to serve as a standard by which to evaluate the monitoring systems. The task deliverable would be a written report, again meeting the goal of presenting the information in simple, readily understandable language.
The final task would be to develop recommendations for changes to the current environmental monitoring program. This task would use the information developed in the previous two and serve as a tool to seek changes or enhancements to the monitoring systems to better match the current or projected future mission of the Rocky Flats site, and also to meet the expressed needs and desires of the community. As with the previous two tasks, the deliverable would be a written report. Additional overall deliverables for the entire project would be two oral presentations to RFCAB, one mid-way through the project following the completion of the first two tasks, and one at the conclusion of the project. RFCAB also stipulated that intermediate oral or written progress reports could be requested at its discretion.
RFCAB developed a proposed timeline for the project as part of the Request for Proposals. It estimated that the project would take three months from the time the contractor was selected to the time the final oral presentation would be given. Commencement of the project was to start in the Spring of 1997 in hopes that favorable weather would allow for field observations of the monitoring stations and equipment.
Other inclusions in the Requests for Proposals were required procurement language necessary because RFCAB would be using federal grant money to pay for the project, a list of evaluation criteria by which RFCAB would judge the proposals, as well as specific instructions on proposal format and transmittal. As stated earlier, RFCAB capped the price bid at $35,000.
Once the text of the Requests for Proposals was completed by the project review team, it was forwarded to RFCAB for its approval and then sent out to those who had responded with expressions of interest. Potential bidders were given six weeks to develop and submit proposals. From the over 100 requests sent out, 22 bidders responded with proposals. It was the responsibility of the review team to read the proposals and select four finalists for interviews. A scoring sheet was developed to assist in the proposal evaluation. Review criteria included the adequacy of the methodology proposed to accomplish each task, the bidder’s experience and qualifications, the completeness of the proposal, and the price bid. Most bidders quoted prices within the $30 - 35,000 range. RFCAB did hear from several contractors who elected not to submit proposals because of their concerns that the project could not be accomplished with such a small budget.
Of the four finalists selected for interviews, two were local Denver area companies, and two were from out-of-state. The review team decided to conduct all four interviews by phone. A list of specific questions for each bidder, as well as a set of common questions were developed in advance to allow for a smooth thirty minute interview. Following the interviews, a check of references and a review of writing samples, the review team selected a team headed by Parker-Hall, Inc. (PHI) from Boise, Idaho. The strength of the Parker-Hall team’s proposal was a combination of experience in both technical and citizen oriented projects, expertise with environmental monitoring systems, background with radiological materials, and the ability to produce documents that would be both technically sound and user friendly for the average citizen. Besides the environmental media mentioned in the Request for Proposals, PHI added an analysis of ecological systems as part of its proposal, an addition RFCAB agreed was important. There was some apprehension in selecting an out-of-state contractor, but the review team felt that the benefit of bringing "fresh eyes" to the project outweighed the logistical difficulties created by distance from the site. Having selected the contractor, the review team began negotiations to develop a contract. Once finalized, the selection of the contractor and the contract were submitted to and approved by the full Board.
Concurrent with negotiation of the contract, RFCAB sent letters to the various entities involved in environmental monitoring programs associated with Rocky Flats asking for their cooperation during the study. RFCAB received a response from each assuring support for the project.
WORK BEGINS
Work on the project began immediately following approval of the contract. Parker-Hall (PHI) traveled to Denver to meet with the RFCAB review team and present a work plan. Following this meeting, PHI began its field investigations and interviews with individuals responsible for the monitoring programs. The team members also visited the local reading rooms, gathering needed written information. Kaiser-Hill, the Integrating Management Contractor for Rocky Flats, arranged a kick-off meeting with the principals involved in monitoring. Kaiser-Hill also provided a draft copy of a document entitled, the Integrated Monitoring Plan (IMP), which proved a valuable resource for the PHI team. In total, PHI spent two weeks in the local area gathering information during their initial visit.
Upon returning home, PHI began its analysis and started preparing the written reports. To track progress on the project, the RFCAB Project Managers conducted weekly phone calls with the PHI staff. RFCAB scheduled an oral presentation by PHI six weeks into the project, focusing on descriptive information about the monitoring systems. PHI also presented their initial analyses and solicited feedback from RFCAB and other members of the public who attended the presentation. While in Denver, PHI conducted additional interviews and gathered more information.
In order to make certain that the written reports would contain information that was factually correct, RFCAB and PHI decided to make draft reports available to representatives from the site, the Colorado Department of Public Health and Environment, and the local municipalities. The comments from representatives of these organizations, as well as the RFCAB review team were incorporated into the draft reports.
PHI encountered several difficulties which led to an extension of the project timeline. The first of these was transmittal of information from the site. For the most part, this problem was attributable to PHI’s having to conduct their follow-up investigations from far away. Vacations of key individuals, numerous rounds of "phone tag" and other problems combined to cause serious project delays. Another difficulty was the inability of the site to produce up-to-date maps showing current monitoring locations. It was RFCAB’s intent that the site would provide quality maps that would go into the reports. After several weeks of frustrating communication, or lack thereof, an agreement was reached that the site would produce base maps which would be sent to PHI for further refinement. The one problem which caused the most serious delay was the release of a revised draft of the Integrated Monitoring Plan by Kaiser-Hill. At no point during the previous months of the project was PHI made aware that a revised draft was imminent. When PHI reviewed the revised draft, the team members discovered that changes had been made to the monitoring programs, the impact of which would mean that the PHI report was out-of-date only two weeks before it was to be presented to RFCAB. In consultation with the contractor, RFCAB granted an extension for PHI to incorporate changes to its draft reports.
Once the changes were incorporated, PHI transmitted a final review draft of the reports for RFCAB members to study before the final oral presentation. PHI gave the oral presentation of its findings to RFCAB on October 9, 1997, seven months after work began, four months later than the original proposed RFCAB schedule. The focus for this presentation was PHI’s critical analysis of the monitoring systems and the team’s recommendations for improvements.
Following the presentation, PHI solicited final feedback from RFCAB members on the draft report. Using the feedback, they prepared a final document summarizing their analyses and recommendations.
RESULTS OF THE STUDY
Although the intent of this paper is to describe the process RFCAB used in developing and conducting the independent assessment of the monitoring systems at Rocky Flats, some readers might be curious to learn about the results of the study. The following paragraphs will briefly summarize PHI’s analysis of and recommendations for improvements to the environmental monitoring systems.
In its final oral presentation to RFCAB, PHI reported that the monitoring program met regulatory requirements, but did not go much beyond what is required. They saw a need for better integration of the various programs, and also stated that there needed to be major improvement in the presentation of monitoring results to the community.
Some specific recommendations included the need to expand the list of contaminants that the site tests for in its analyses and to increase the sampling frequency, particularly in the ground and surface water programs. Parker-Hall noted several locations where new groundwater and surface water monitoring stations should be installed. A critical recommendation was the need to speed up the time it takes to get monitoring results back from the laboratory. PHI stated that this need was particularly acute for the surface water program, where it could take from four to six weeks to receive analytical results.
For the ecological program, Parker-Hall recommended additional sampling of vegetation and lower forms of animals, both terrestrial and aquatic, to determine concentrations of contamination in the organisms and evaluate the potential for contaminant bioaccumulation. They also recommended that the data collection area be expanded, especially in relatively undisturbed and uncontaminated areas north and west of the main industrial areas of the site in order to establish a baseline for comparison with more contaminated areas.
PHI was surprised to learn that no routine soil and sediment sampling programs existed at Rocky Flats and as such, recommended that programs be implemented. They stated that this recommendation was significant in order to track the potential movement of contaminants from the soil into the surface water systems, which could allow contamination to travel beyond the site’s boundaries.
Generally, Parker-Hall had few specific recommendations for changes or improvements to the air monitoring programs, with the exception of the need to explore means of better communicating information to the public. They were highly supportive of the Community Radiation Monitoring Program (COMRAD). COMRAD is a community based air monitoring program managed by area high school science teachers. Six COMRAD stations are set up within the local community. These stations record meteorological conditions and also have detectors for plutonium and gamma radiation. PHI suggested installation of some additional equipment at the COMRAD stations which would provide more information on the length or duration of exposure should there ever be a major release from the site.
DEVELOPMENT OF RFCAB RECOMMENDATIONS
To develop a set of recommendations based on its review of the PHI report, RFCAB noted that the comments and recommendations fell into three categories. First, there were editorial and content comments specific to the site’s Integrated Monitoring Plan. These were collected and transmitted to the Department of Energy for its consideration in the next iteration of the plan.
The second category consisted of specific recommendations for changes to the monitoring systems. RFCAB felt is was important to gain the site’s perspectives on the PHI recommendations before developing its own set of recommendations that would be formally transmitted to DOE. A series of meetings were set up in which representatives from the site, the regulators, and the local communities offered their perspectives on the PHI recommendations. In addition, these entities provided written comments to RFCAB. RFCAB used this information in developing a set of "official" recommendations it forwarded to DOE. Using this dialogue process allowed RFCAB and the site to come to a better understanding of the most critical areas for improvements to the monitoring systems.
The third category of PHI comments and recommendations pointed to deficiencies related to how environmental monitoring data and information is presented to the community. RFCAB decided to recommend that DOE, its contractors and the other entities responsible for environmental monitoring enter into a collaborative process to discuss and develop better means for communicating monitoring information. While not complete at the time of this writing, RFCAB hopes to develop more pictorial means to present monitoring data, with easier to read narrative, so that community members can better understand and appreciate the environmental monitoring systems in place at Rocky Flats.
OUTCOMES AND LESSONS LEARNED
Overall, the members of RFCAB were pleased with the outcomes of the project. The first outcome was the production of a comprehensive guide to the environmental monitoring systems entitled, A Citizens Guide to the Environmental Monitoring Program at Rocky Flats. This guide was widely distributed to members of the community, placed in local libraries, made available on the Internet, and given to local area science teachers. Because this Guide was produced by citizens and not those who are responsible for the monitoring systems, the long term hope is that is will serve as a credible reference to those in the community concerned about the environment and the health and safety of themselves and their families.
The second outcome was a set of recommendations for improvements to the monitoring systems. In developing the assessment, RFCAB was aware of the community’s concerns about the quality and effectiveness of the monitoring systems. Without internal expertise, RFCAB was not able to credibly evaluate the systems, separating perception from fact. The use of an independent contractor who understood the community members’ concern and evaluated the systems in light of these concerns allowed RFCAB to develop technically sound recommendations.
The assessment of the environmental monitoring systems at Rocky Flats was the first major contract research project undertaken by the Rocky Flats Citizens Advisory Board. As such, each step in the process, from the development of the Request for Proposals, the selection and oversight of the contractor, and the use of independently derived analyses to prepare recommendations were new experiences for the Board. In review of the overall project there were several important lessons learned.
The use of a contractor not from the immediate area, and who did not have previous experience at Rocky Flats, presented both benefits and difficulties. The benefit of having a contractor who had not worked previously for the contractors at Rocky Flats allowed for greater public acceptance of the results. PHI brought fresh eyes to the analysis and was not encumbered by previous biases. Several difficulties arose while trying to conduct an analysis from a distance. Although PHI spent close to two weeks in their initial visit to the area, it was often times difficult for them to receive information or contact specific individuals once they returned to Boise. Communication between RFCAB and PHI was facilitated by weekly phone calls between the project managers for each organization. These phone calls provided a forum to measure progress of the project as well as a means to discuss and resolve problems.
The relationship between PHI and representatives from the site needed to be carefully monitored. There was obvious apprehension from site contractor representatives as the project began. Rocky Flats has been the center of much scrutiny over the years, with outside reviewers arriving quite regularly to look at one program or another. The fact that PHI was sent by citizens often critical of the work being done at the site contributed to the apprehension. RFCAB project managers several times had to step in to broker the exchange of information between the site and PHI. Fortunately by the end of the project, the site representatives and those from the Colorado Department of Public Health and Environment and the local municipalities especially, proved quite helpful to this project. Providing the site representatives access to the draft reports and allowing them to make comments and suggestions early in the assessment was a positive step in encouraging their support. Once they read the draft reports and realized that indeed the contractor was credible and "not out to get them," the flow of information greatly improved.
A significant problem which impacted the timeliness in completing the project was that the environmental monitoring program was in flux during the time the assessment was being conducted. Deciding when to end the assessment and produce the final reports was a challenge. When PHI learned that the draft of the site’s Integrated Monitoring Plan had been modified, they realized that changes would need to be made in the reports they would provide to RFCAB, so that the reports would contain the most up-to-date information. Unfortunately, the site did not communicate these changes to the monitoring program as they were providing comments to PHI on review drafts for the project. Establishing clearer lines of communications and asking specific questions about the dynamic nature of the monitoring programs would be valuable for anyone seeking to complete such a project at another site.
Contract and fiscal management for a project of this size was a new experience for RFCAB. To help in preparing a contract between the Board and PHI, RFCAB asked for assistance from other non-profit organizations who had used outside contractors. These organizations provided examples of contracts which RFCAB used in developing the contract for PHI. Fortunately, RFCAB had an attorney serving as a member of the Board who was helpful in providing final language. RFCAB and PHI agreed to an installment approach to fiscal management. RFCAB reserved final payment until all project activities were finished, a valuable incentive for making sure that the final work products were complete and acceptable.
CONCLUSIONS
The Rocky Flats Citizens Advisory Board undertook the independent review of the environmental monitoring systems at Rocky Flats to address concerns raised by the community about the protectiveness and adequacy of these systems. Although these systems cannot prevent the accidental release of contaminants from the site, they do serve as vigilant sentinels providing some assurance that releases will not go unnoticed.
At Rocky Flats, the Department of Energy has made significant progress in changing the culture of secrecy and suspicion by the public. Still, remnants of this legacy linger. By contracting with an independent firm to conduct the analysis of environmental monitoring at the site, RFCAB was able to provide a credible resource to the community regarding questions related to the adequacy of the environmental monitoring systems. With better understanding of the areas in which the contractor felt the systems were adequate, RFCAB was able to focus its recommendations on those areas where improvements could be made. Equipped with the technical expertise of its own contractor, RFCAB stood on an equal footing for the discussions related to improvements in the monitoring systems. In the process, DOE and its contractors, the regulatory agencies, RFCAB and the public learned a valuable lesson in communication.
Hopefully, this dialogue will only be the beginning for similar discussions on other matters of importance to DOE and the community as progress is made in the cleanup and closure of the Rocky Flats site. Mistrust, suspicion and secrecy are the legacies of the weapons production era. In the future as historians look back at the cleanup era, hopefully the legacies they report will be trust, understanding and open communication.
REFERENCES