a

GAO

United States Government Accountability Office

Report to Congressional Requesters

July 2006 NUCLEAR CLEANUP 

OF ROCKY FLATS

DOE Can Use Lessons 

Learned to Improve 

Oversight of Other 

Sites’ Cleanup 

Activities

GAO-06-352
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-06-352.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Gene Aloise at 

(202) 512-3841 or aloisee@gao.gov. 

Highlights of GAO-06-352, a report to 

congressional requesters 

July 2006

NUCLEAR CLEANUP OF ROCKY FLATS

DOE Can Use Lessons Learned to 

Improve Oversight of Other Sites’ 

Cleanup Activities 

Four factors contributed to the early completion of Rocky Flats’ cleanup: 

(1) DOE’s and the contractor’s ability to overcome numerous challenges, (2) 

the use of an accelerated cleanup process, (3) site-specific characteristics 

that limited the scope of the contamination, and (4) the contractor’s 

financial incentive to finish the work quickly and safely. 

Although the cleanup is complete, its sufficiency has not yet been 

ascertained; key steps remain before the planned Rocky Flats National 

Wildlife Refuge that will occupy the site can open to the public. For 

example, in about November 2006, the regulatory agencies—the 

Environmental Protection Agency (EPA) and the Colorado Department of 

Public Health and Environment—plan to issue their joint final decision on 

the sufficiency of the cleanup and any risk posed by residual contaminants. 

The total cost of the cleanup, since 1995, is about $10 billion in constant 2005 

dollars. This cost includes contract costs of about $7.7 billion (including 

contractor fees of about $630 million), long-term stewardship and pension 

liabilities estimated at about $1.3 billion, and other costs of nearly $1 billion. 

Although numerous measures in place to assess the cleanup appear 

adequate to judge the sufficiency of the cleanup, DOE did not effectively 

carry out some aspects of its oversight responsibilities. Among the 

assessment measures are completion of the regulatory process, activities 

undertaken to verify remedial actions, and reviews by independent and 

federal entities. The regulatory agencies have approved the cleanup of 360 

areas of known or suspected contamination at the site. Data supporting the 

cleanup of these areas form the basis of regulatory decisions regarding the 

cleanup’s sufficiency. Accordingly, we reviewed the contractor’s controls 

intended to ensure the quality of these data and found them to be robust. 

However, DOE lacked assurance that the controls were working as intended 

because it did not independently assess the quality of these key data. One 

official told us that DOE was involved daily in reviewing documents and 

discussed with the contractor any data quality issues that arose. 

 

DOE has identified and implemented at other sites some lessons from Rocky 

Flats, but DOE has not systematically tracked lessons learned at all of its 

cleanup sites, thus potentially losing the benefits of such lessons. 

Rocky Flats in 1995 Rocky Flats in 2005 

Source: DOE.

In 2001, when GAO reported on the 

cleanup of the Department of 

Energy’s (DOE) Rocky Flats site, a 

former nuclear weapons 

production facility, the cleanup 

was behind schedule and over cost. 

In October 2005, the contractor 

declared that it had completed the 

cleanup much earlier and at less 

cost than DOE and the contractor 

had anticipated 5 years earlier. 

GAO was asked to determine the 

(1) factors that contributed to the 

cleanup’s early completion, (2) 

remaining work and total costs, (3) 

measures to assess whether the 

cleanup achieved a level of 

protection of public health and 

environment consistent with the 

cleanup agreement, and (4) lessons 

the Rocky Flats cleanup may offer 

for other DOE cleanup projects. 

What GAO Recommends

GAO recommendations include 

that the Secretary of Energy ensure 

appropriate oversight of 

contractors’ controls over data 

quality and assess the costs and 

benefits of tracking lessons learned 

across the DOE complex. DOE, 

Interior, Colorado, and Kaiser-Hill 

provided written comments, and 

generally agreed with the contents 

of the report. EPA did not provide 

official written comments but did 

provide editorial and technical 

suggestions, as did the other 

agencies, that we incorporated, as 

appropriate. DOE concurred with 

our recommendation about 

tracking lessons learned but did 

not state whether it concurred with 

the other two. 
Page i GAO-06-352 Nuclear Cleanup of Rocky Flats

Contents

Letter 1

Results in Brief 4

Background 8

Four Key Factors Contributed to Early Cleanup 10

Cleanup of Rocky Flats Is Complete at a Cost of about $10 Billion, 

but Key Steps Remain Before the Planned Wildlife Refuge Will 

Open 26

Numerous Measures Were Taken to Assess the Cleanup’s 

Sufficiency, but DOE Could Improve Its Oversight of Data Quality 

and Clarify Its Verification Policy 39

DOE Implemented Some Lessons Learned at Rocky Flats but Has No 

Requirement to Ensure That Lessons Learned Are Implemented at 

Other Sites 56

Conclusions 62

Recommendations for Executive Action 63

Agency Comments and Our Evaluation 63

Appendixes

Appendix I: Objectives, Scope, and Methodology 67

Appendix II: GAO Survey Methodology, Response Rates, and Summary 

Responses 70

Survey Methodology 70

Survey Response Rates 70

Summary Responses 71

Appendix III: Additional Information on Decontamination and Demolition 

Activities at Rocky Flats 90

Appendix IV: Additional Information on the Quality of Remediation Data 

at Rocky Flats and on DOE’s Planned and Actual 

Verification 95

Information on Controls over Data Quality 95

Additional Information on DOE’s Planned and Actual Verification 

Activities 99

Appendix V: Comments from the Department of Energy 107

Appendix VI: Comments from the Department of the Interior 110

Appendix VII: Comments from the Colorado Department of Public Health 

and Environment 113

Appendix VIII: Comments from Kaiser-Hill Company L.L.C. 114
Contents

Page ii GAO-06-352 Nuclear Cleanup of Rocky Flats

Appendix IX: GAO Contact and Staff Acknowledgments 116

Table Table 1: Survey Response Rates, by Subgroup 71

Figures Figure 1: Workers in Protective Suits Cut Plutonium-Contaminated 

Equipment 10

Figure 2: Workers Use Cerium Nitrate to Decontaminate a 

Glovebox; Workers Load a Dismantled Glovebox into a 

Shipping Container 12

Figure 3: Use of Explosives in the Demolition of Rocky Flats’ 

Building 881 13

Figure 4: Transuranic Waste Packaged for Shipment to the Waste 

Isolation Pilot Plant 15

Figure 5: GAO Staff Being Briefed on the Prepackaging of Wet 

Combustibles, July 2002 and October 2000 18

Figure 6: Waste Removed and Contaminated Water Treated at 

Rocky Flats 29

Figure 7: Rocky Flats, before Cleanup, in 1995, and after Cleanup 

(in 2005) 30

Figure 8: Key Steps in Rocky Flats’ Transition to a Wildlife 

Refuge 31

Figure 9: The Lindsay Ranch 33

Figure 10: Plan for Public Access Trails and Facilities at the Rocky 

Flats National Wildlife Refuge 34

Figure 11: Four-Step Remediation Process for Individual Areas of 

Known or Suspected Contamination 43

Figure 12: Treatment of Contaminated Soils by Thermal Desorption; 

Installation of a Passive Treatment System at the Mound 

Storage Site, Rocky Flats 45

Figure 13: Terminal Pond in the B Series of Ponds 46

Figure 14: Super-Compacter without and with InstaCote 90

Figure 15: Hydrolase System at Work Removing Contaminated Paint 

and Underlying Surface Contamination 92

Figure 16: Workers Cut Contaminated Concrete from Building 771’s 

‘Infinity Room’ 93

Figure 17: A High-Purity Germanium Detector Can Detect Certain 

Radionuclides 100

Figure 18: Felled Electrical Poles Allow Lower Flight; Helicopter 

Scans Rocky Flats for Residual Plutonium in Surface 

Soil 102
Contents

Page iii GAO-06-352 Nuclear Cleanup of Rocky Flats

Figure 19: Confirmation and Independent Verification Samples 

Taken at the 903 Lip Area 105

Abbreviations

Advisory Board Rocky Flats Citizens Advisory Board

ATSDR Agency for Toxic Substances and Disease Registry

CERCLA Comprehensive Environmental Response, Compensation,

 and Liability Act

Coalition Rocky Flats Coalition of Local Governments

Colorado Colorado Department of Public Health and Environment

DOE Department of Energy

EPA Environmental Protection Agency

FWS Fish and Wildlife Service

HPGe high-purity germanium

MARSSIM Multi-Agency Radiation Survey and Site Investigation 

 Manual

ORISE Oak Ridge Institute for Science and Education

PARCC precision, accuracy, representativeness, completeness, 

 and comparability

pCi/g picocuries per gram

RCRA Resource Conservation and Recovery Act

Refuge Act Rocky Flats National Wildlife Refuge Act

RI/FS remedial investigation/feasibility study

TRC total recordable cases

VOC volatile organic compound

WIPP Waste Isolation Pilot Plant

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Page 1 GAO-06-352 Nuclear Cleanup of Rocky Flats

United States Government Accountability Office

Washington, D.C. 20548

A

July 10, 2006 Letr

The Honorable Jeff Sessions

Chairman

Subcommittee on Strategic Forces

Committee on Armed Services

United States Senate

The Honorable Wayne Allard

United States Senate

Once a bustling nuclear weapons production complex employing 

thousands of workers, the Department of Energy’s (DOE) Rocky Flats site, 

near Denver, Colorado, is being transformed into a wildlife refuge that will 

be managed by the Department of the Interior’s Fish and Wildlife Service 

(FWS). For about 40 years, the Rocky Flats plant produced plutonium 

triggers, or “pits,” for nuclear weapons. That activity resulted in 

radiological and chemical contamination of some of the site’s buildings, 

soil, and water. Cleanup of the site began in 1995 under a contract between 

DOE and Kaiser-Hill Company L.L.C.,1

 and included decontaminating and 

demolishing several plutonium-processing buildings, one of which had 

been labeled “the most dangerous building in America,” along with 

hundreds of other contaminated buildings and structures. The cleanup 

required the contractor to remove large volumes of nuclear material and 

radioactive debris, and investigate and remediate as necessary 

contamination at 360 individual hazardous substance sites that were 

identified through historical records and extensive sampling and analysis at 

the site in the early 1990s. In total, according to GAO’s calculations, the 

amount of cleanup waste that had to be removed from the site was 

equivalent to a 65-story building the length and width of a football field.

Cleanup of the site was conducted under the Rocky Flats Cleanup 

Agreement, the legally binding agreement that provided the framework for 

the cleanup effort. The cleanup agreement implements the provisions of 

the applicable statutes, including the Comprehensive Environmental 

Response, Compensation, and Liability Act of 1980, as amended

1

Kaiser-Hill Company L.L.C. is a joint venture between Kaiser Group Holdings Inc. and 

CH2M Hill.
Page 2 GAO-06-352 Nuclear Cleanup of Rocky Flats

(CERCLA);2 the Resource Conservation and Recovery Act of 1976, as 

amended (RCRA); and the Colorado Hazardous Waste Act. The cleanup 

agreement specified the roles of DOE and the two regulatory agencies for 

the site: the Environmental Protection Agency (EPA) and the Colorado 

Department of Public Health and Environment (Colorado). Pursuant to the 

cleanup agreement, EPA had lead regulatory authority over the cleanup of 

the site’s buffer zone, which includes about 5,900 acres of undeveloped 

land around the center of the site, while Colorado had lead regulatory 

authority over the cleanup of the core industrial area—which includes 

about 385 acres in the center of the site, where the plutonium-processing 

activities occurred.

When GAO reported on the cleanup effort in February 2001, the project 

was behind schedule and over cost.3

 However, in October 2005, the 

contractor declared that it had finished the physical cleanup of the site, as 

defined in the contract (e.g., demolishing buildings and shipping 

contaminated waste and soil off site), much earlier and at less cost than 

DOE and the contractor had anticipated 5 years earlier. Although the 

cleanup is complete, its sufficiency has not yet been ascertained. EPA’s and 

Colorado’s joint final decision on the sufficiency of the cleanup and the 

final remedy for the site is expected to be published around November 

2006.4

 With the exception of one pedestrian trail, most of the planned 

wildlife refuge will not open until at least 5 years after the refuge is 

established (depending on the availability of funding). 

In this context, we determined the (1) factors that contributed to the 

physical cleanup’s early completion; (2) work remaining to be done as well 

as total project costs, including long-term costs; (3) measures in place to 

assess whether the cleanup achieved a level of protection of public health 

and environment consistent with the Rocky Flats Cleanup Agreement; and 

2

Rocky Flats was added to CERCLA’s National Priorities List in October 1989. The National 

Priorities List is EPA’s list of national priorities among the known or threatened releases of 

hazardous substances, pollutants, or contaminants throughout the United States and its 

territories. As of April 2006, the final list comprised 1,244 sites, with another 59 sites 

proposed for listing. Another 309 sites that were formerly on the final list have been deleted.

3

GAO, Nuclear Cleanup: Progress Made at Rocky Flats, but Closure by 2006 Is Unlikely, 

and Costs May Increase, GAO-01-284 (Washington, D.C.: Feb. 28, 2001).

4

The final decision document will be a joint corrective action decision under RCRA and 

record of decision under CERCLA.
Page 3 GAO-06-352 Nuclear Cleanup of Rocky Flats

(4) lessons the Rocky Flats project may hold for other DOE cleanup 

projects.

In conducting our work, we visited the Rocky Flats site several times and 

reviewed documents and data prepared by DOE, EPA, Colorado, FWS, the 

contractor, and various scientific organizations. We reviewed and analyzed 

agency and contractor documents on decontamination and demolition 

accomplishments and techniques. We also analyzed documents related to 

the cost-plus-incentive-fee contract, including contract negotiation 

documents, the contract cost and fee structure, and contract modifications, 

although we did not evaluate the cost-effectiveness of the contract. We 

reviewed and analyzed cleanup verification strategies and results, and 

reviewed the content of scientific analyses, including a study of how 

actinides5

 migrate through soil and water and an assessment of the public 

health risk posed by contaminants remaining at the site, but did not 

evaluate the science underlying them. In addition, because decisions about 

the sufficiency of the cleanup have been and will be based on remediation 

data, we assessed the soundness of the agencies’ and contractor’s 

processes and procedures for ensuring the quality of these data. We also 

reviewed the results of audits of the key laboratories used by the 

contractor to analyze samples of radioactively contaminated soil.

For further review, we selected a nonprobability sample of four of Rocky 

Flats’ 360 cleanup areas (including areas referred to as individual 

hazardous substance sites, potential areas of concern, and under-building 

contamination sites), using criteria such as the location of the cleanup area 

and the severity of its contamination.6

 For these four individual cleanup 

areas—building 771, the 903 pad, the 903 lip area, and trench T-7—we 

assessed the closeout reports and the data supporting them to determine 

the extent to which the data collection and laboratory analyses adhered to 

data quality standards and procedures. For example, we reviewed records 

of laboratory analyses of contaminated soil samples from the areas, and 

documents showing the extent to which the projects adhered to stated data 

quality objectives. We did not evaluate the remedial data or laboratory 

analyses themselves. 

5

Actinides are a series of 15 radioactive chemical elements with atomic numbers 89 

(actinium) and greater.

6

Results from nonprobability samples cannot be used to make inferences about a 

population, because in a nonprobability sample some elements of the population being 

studied have no chance or an unknown chance of being selected as part of the sample.
Page 4 GAO-06-352 Nuclear Cleanup of Rocky Flats

Further, to obtain citizen and local government views about community 

input to the cleanup and the effect of various cleanup verification activities, 

we surveyed 58 current and past members of the two local community 

groups that served in an advisory capacity to DOE: the Rocky Flats 

Citizens Advisory Board and the Rocky Flats Coalition of Local 

Governments. We also attended monthly meetings of these two groups. We 

interviewed officials of DOE, EPA, Colorado, FWS, the contractor, and 

various scientific organizations. We conducted our work in accordance 

with generally accepted government auditing standards from March 2005 

through May 2006. In September 2005, we briefed you and your staff and 

reported on the preliminary results of our review.7

 Details on our 

objectives, scope, and methodology are in appendix I; summary survey 

results are in appendix II.

Results in Brief Officials of DOE, EPA, Colorado, and the contractor identified four key 

factors that contributed to Rocky Flats’ early cleanup:

• DOE and the contractor overcame significant challenges that we 

identified in our 2001 report, such as decontaminating and demolishing 

hundreds of structures and packaging and shipping vast quantities of 

radioactive and hazardous wastes. For example, innovative techniques, 

such as the use of cerium nitrate to decontaminate gloveboxes so they 

could be shipped whole rather than cut into pieces, enabled the 

contractor to proceed with cleanup much faster and at less expense 

than anticipated.

• An accelerated cleanup process allowed cleanup actions to proceed 

much more quickly and collaboratively than a traditional cleanup 

process would have allowed. As the cleanup progressed, DOE, the 

contractor, EPA, and Colorado staff often worked side by side in the 

field, participating in or observing soil removal actions and sampling 

procedures.

7

GAO, Nuclear Cleanup: Preliminary Results of the Review of the Department of Energy’s 

Rocky Flats Closure Project, GAO-05-1044R (Washington, D.C.: Sept. 22, 2005).
Page 5 GAO-06-352 Nuclear Cleanup of Rocky Flats

• Site-specific characteristics (e.g., climate, geography, the robust 

construction of the buildings, and the chemical nature of the key 

contaminants) physically limited the extent of the contamination. For 

example, the dry Colorado climate and the alluvial fan8

 on which the site 

is situated helped minimize erosion, thereby inhibiting off-site migration 

of contaminants. Also, the thick shale and claystone that underlie the 

site prevented contaminants from seeping into the deep drinking-water 

aquifer.

• The contractor had a large financial incentive, shared throughout the 

contractor workforce, to complete the work economically, quickly, and 

safely. The earlier the contractor finished its work, and the lower its cost 

in doing so, the more the contractor stood to earn—as much as $560 

million in incentive fees. This financial incentive drove site workers to 

seek creative cleanup solutions.

Although DOE’s contractor completed the physical cleanup of the site in 

October 2005, several additional actions need to be completed before the 

site can open to the public as a wildlife refuge. In July 2006, DOE expects to 

issue for public comment its proposed plan, which will include a summary 

of the three proposed future monitoring and remediation alternatives for 

the site and will identify the preferred alternative. After public comments 

on the proposed plan have been received and considered, EPA and 

Colorado will jointly determine whether any further cleanup is needed at 

the site or whether the cleanup actions already taken are sufficient to 

render the site safe for its intended purpose. A final decision by EPA and 

Colorado is expected in late 2006. If the joint decision is that no further 

action is required, and EPA certifies that the cleanup and closure of Rocky 

Flats is complete, DOE will transfer primary administrative jurisdiction 

over the majority of the site to the Department of the Interior for use as a 

wildlife refuge. If funds are available, FWS plans to open one pedestrian 

trail in the first year after the transfer and to open the remainder of the 

public trails and facilities between the fifth and 15th years following 

transfer. DOE expects to retain possession of the former industrial area, 

which will contain shallow groundwater treatment systems and monitoring 

wells, and will be responsible for the long-term stewardship of these 

systems. To protect these systems, DOE will restrict public access to this 

portion of the site. 

8

An alluvial fan is a fan-shaped wedge of sediment that typically accumulates in arid or 

semiarid climates on land where a stream emerges from a steep canyon onto a flat area.
Page 6 GAO-06-352 Nuclear Cleanup of Rocky Flats

The total cost of the cleanup since 1995 is about $10 billion.9 This cost 

includes DOE’s 1995 and 2000 contracts with Kaiser-Hill, which total nearly 

$8 billion; the cost of DOE’s Rocky Flats Field Office, which totals about 

$760 million; and the cost of other DOE sites’ support of the Rocky Flats 

project, which totals about $138 million; estimated future costs such as 

pension and benefits liabilities, estimated at approximately $1 billion over 

60 years; long-term stewardship of the site, projected to cost $303 million 

through 2080; and the potential acquisition of some private mineral rights 

at Rocky Flats, for which the Congress authorized $10 million in January 

2006.10

Numerous measures have been and are being taken to assess the cleanup. 

Although these measures appear adequate to judge the sufficiency of the 

cleanup, DOE did not effectively carry out some aspects of its oversight 

responsibilities. The three key cleanup assessment measures are (1) 

completion of the regulatory process—EPA’s and Colorado’s review and 

approval of the cleanup actions already taken and the results of other 

ongoing assessments under CERCLA and RCRA; (2) a DOE-initiated 

verification of the contractor’s cleanup actions; and (3) reviews conducted 

by other federal agencies and by consultants hired by local community 

groups:

• Completion of the CERCLA and RCRA process will culminate in EPA’s 

and Colorado’s final decision on the cleanup’s sufficiency and the 

selection of a final remedy. The contractor’s procedures to ensure the 

quality of the data supporting the accelerated cleanup actions appeared 

sound and comprehensive. However, DOE did not assess the 

contractor’s data quality assurance process, as required by the protocols 

agreed to with the regulatory agencies.11 A DOE official explained that 

DOE officials’ day-to-day review of data enabled them to detect data 

issues as they arose.

9

Unless otherwise noted, all costs cited in this report have been adjusted for inflation and 

are expressed in constant 2005 dollars.

10National Defense Authorization Act for Fiscal Year 2006, Pub. L. No. 109-163, § 3112, 119 

Stat. 3136, 3540 (2006).

11The review requirement was specified in the industrial area and buffer zone sampling and 

analysis plan, which contained the sampling, analysis, and documentation protocols agreed 

to between DOE and the regulatory agencies. 
Page 7 GAO-06-352 Nuclear Cleanup of Rocky Flats

• A DOE-initiated verification of the contractor’s cleanup was 

inconsistent with the verification plan. DOE did not complete an 

independent review of the accuracy of contractor-conducted scans for 

remaining radiological contamination. DOE officials said they had 

decided that these activities would not provide sufficient additional 

information to justify their completion, but had no documentation to 

support this decision. Further, existing DOE policy and guidance lack 

clarity about how they apply to the Rocky Flats cleanup and what the 

verification goals are.

• Federal agency reviews and community-driven independent reviews 

assessed aspects of the cleanup. For example, a CERCLA-required 

public health assessment concluded that no public health hazard exists 

for the communities surrounding Rocky Flats. 

Although DOE has identified and implemented at other cleanup sites some 

lessons learned at Rocky Flats, DOE does not require that lessons learned 

at one cleanup site be implemented at other sites, even though they may be 

applicable. In 2002, DOE identified a number of lessons from the Rocky 

Flats cleanup, including implementing a performance-based contracting 

strategy and encouraging the innovative application of technology. DOE 

then assessed the applicability of these lessons at some DOE sites and 

directed these sites to implement applicable lessons. Although DOE 

conducted follow-up reviews at the sites through 2005, these reviews were 

focused on other aspects of the cleanup program and did not assess 

whether the sites had implemented the lessons learned from Rocky Flats. 

During our review, we noted additional lessons that could also be useful for 

other DOE sites planning or undergoing cleanup, such as involving the 

future site manager in remedial decisions and taking a consultative 

approach with the regulatory agencies on cleanup decisions. However, 

DOE has no process for ensuring that all lessons are captured and 

implemented as appropriate at other DOE sites. As a result, DOE may be 

losing the chance to save both time and money in its planned or ongoing 

site cleanup efforts.

We are making a number of recommendations aimed at strengthening 

DOE’s oversight of data quality, its cleanup assessments, and its process for 

ensuring that lessons learned at cleanup sites are analyzed and 

implemented as appropriate at other DOE sites.

We provided a draft of this report to DOE, Interior, EPA, Colorado, and 

Kaiser-Hill for their review and comment. DOE, Interior, Colorado, and 
Page 8 GAO-06-352 Nuclear Cleanup of Rocky Flats

Kaiser-Hill provided written comments (see apps. V, VI, VII, and VIII, 

respectively), and generally agreed with the contents of the report. EPA did 

not provide official written comments but did provide editorial and 

technical suggestions, as did the other agencies, that we incorporated, as 

appropriate. DOE concurred with one of our recommendations but did not 

state whether it concurred with the other two. 

Background For nearly 40 years, the Rocky Flats plant, located about 16 miles 

northwest of downtown Denver, served as a nuclear weapons production 

facility. Afterward, the site bore the scars of that role: soil, groundwater, 

surface water, and many of the buildings at the site were contaminated 

with radioactive materials, such as plutonium and uranium; toxic metals, 

such as beryllium; and hazardous chemicals, such as cleaning solvents and 

degreasers. Accordingly, the site became one of DOE’s priorities for 

environmental cleanup. While most of the approximately 6,300 acres that 

make up the Rocky Flats site served through the years as an undeveloped 

buffer zone, about one-half of a square mile (385 acres) in the center of the 

site constituted the industrial area, where for decades, plutonium was 

shaped into plutonium triggers or “pits” for use in nuclear weapons. About 

one-fourth of the site’s more than 800 original structures (e.g., buildings 

and storage tanks) were radiologically or chemically contaminated—some 

severely so—by site operations over the years. 

The site was cleaned up under the terms of a contract between DOE and 

Kaiser-Hill. The first contract took effect July 1, 1995. In late 1999, DOE and 

Kaiser-Hill negotiated a new contract, which took effect on February 1, 

2000. The cleanup work was done predominantly by subcontractors, under 

the contractor’s management.
Page 9 GAO-06-352 Nuclear Cleanup of Rocky Flats

The 2000 contract specified both the contractor’s and DOE’s 

responsibilities. The contractor was responsible for processing, packaging, 

and shipping off site all of Rocky Flats’ nuclear materials and radioactive 

and hazardous wastes;12 cleaning up and demolishing more than 700 

structures that remained on site in February 2000; and cleaning up the site’s 

contaminated soil and groundwater. DOE was required to provide a variety 

of services and items to support the project. Essentially, the contract 

required DOE to arrange receiver sites for all the materials and wastes and 

obtain the necessary certifications for the containers in which the materials 

and wastes had to be packed and shipped. Many DOE sites played a 

significant role in Rocky Flats’ cleanup and closure, especially those sites 

that received materials or wastes from Rocky Flats, such as the Savannah 

River Site in South Carolina, the Waste Isolation Pilot Plant (WIPP) in New 

Mexico,13 the Nevada Test Site, and the Hanford Site in Washington.

Much of the cleanup work at Rocky Flats was labor intensive and tedious. 

Plutonium is dangerous to human health, even in minute quantities, 

especially if inhaled or ingested. Accordingly, workers handling plutoniumcontaminated materials and equipment had to wear cumbersome 

protective suits with enclosed respiratory systems, and sometimes had to 

wield heavy and ungainly tools. Also, the equipment being worked on had 

to be enclosed within plastic or glass to prevent airborne contaminants 

from reaching unprotected workers or surfaces. Figure 1 shows workers in 

protective clothing cutting contaminated materials to fit shipping 

containers.

12These wastes—items such as clothing, gloves, equipment, rags, paper, filters, and plastic—

included low-level radioactive waste, transuranic waste, and mixed waste. Low-level 

radioactive waste contains radioactive constituents measuring 100 or fewer nanocuries of 

transuranic isotopes (described below) per gram of waste (a nanocurie is 1 billionth of a 

curie; a curie is the amount of radioactivity in 1 gram of radium). Transuranic waste is 

radioactive waste contaminated with transuranic isotopes (i.e., isotopes of elements heavier 

than uranium, such as plutonium), with half-lives greater than 20 years, in concentrations 

above 100 nanocuries per gram of waste. Mixed waste is radioactive waste—either low level 

or transuranic—that also contains hazardous wastes such as toxic metals, cleaning solvents, 

degreasers, and paint thinners.

13WIPP is DOE’s deep geologic repository for transuranic and transuranic mixed wastes, 

located in an underground salt formation near Carlsbad, New Mexico.
Page 10 GAO-06-352 Nuclear Cleanup of Rocky Flats

Figure 1: Workers in Protective Suits Cut Plutonium-Contaminated Equipment

Four Key Factors 

Contributed to Early 

Cleanup

Four key factors contributed to the early completion of the physical 

cleanup of Rocky Flats: (1) DOE and the contractor overcame several 

major challenges identified in GAO’s 2001 report on the Rocky Flats 

cleanup, (2) DOE and the site’s regulatory agencies agreed to use an 

accelerated process to clean up the site, (3) a number of site-specific 

characteristics combined to limit the scope and complexity of the cleanup 

effort, and (4) DOE offered the contractor $560 million in total incentive 

fees to finish the cleanup ahead of schedule and under cost.

Source: DOE.
Page 11 GAO-06-352 Nuclear Cleanup of Rocky Flats

DOE and Contractor 

Overcame Previously 

Identified Cleanup 

Challenges 

The first key factor that contributed to the early completion of the physical 

cleanup of Rocky Flats was that DOE and the contractor resolved four of 

the five major challenges we identified in our 2001 report. These challenges 

included (1) completing the decontamination and demolition of the site’s 

structures; (2) overcoming limitations on the available number of 

transportation casks and on the loading capability for transuranic waste; 

(3) identifying the overall scope of the cleanup project—specifically, the 

extent of contamination, the eventual use of the site, and the level of 

cleanup that eventual use would require; (4) getting the automated 

plutonium-packaging system to reliably perform at the rate needed for 

timely completion; and (5) preventing safety problems, which can result in 

work shutdowns and delay cleanup work.

Completing Decontamination 

and Demolition of Structures

One major challenge DOE and the contractor overcame was completing the 

decontamination and demolition of hundreds of structures at the site. At 

the end of fiscal year 2000, the contractor had completed only about 10 

percent of the predemolition work, which included activities such as 

removing plutonium and other nuclear materials from furnaces, pipes, and 

other locations within buildings; draining and removing plutonium- or 

uranium-laden liquids or residues from process pipes and tanks; 

dismantling plutonium-processing furnaces; stripping out contaminated 

process pipelines; and cutting up and removing hundreds of contaminated 

gloveboxes.14 Further, at the time of our 2001 report, the contractor had 

demolished only 81 of the 802 structures that existed at the site when 

cleanup began. That accomplishment equated to about 10 percent of the 

total number of structures and only about 5 percent of the total square 

footage. Remaining to be demolished at the end of fiscal year 2000 were 721 

structures, encompassing about 3.4 million square feet. 

DOE and the contractor overcame challenges to decontamination and 

demolition primarily through innovation, as workers continuously sought 

innovative cleanup technologies that would accomplish tasks more safely, 

quickly, and cheaply. For example, the contractor found that it could 

chemically decontaminate large pieces of equipment, such as tanks and

14A glovebox is a closed glass, plastic, or metal chamber for handling hazardous or 

radioactive material. The operator handles the material through gloves sealed to the 

chamber’s wall. Gloveboxes range in size from a few square feet to thousands of square feet.
Page 12 GAO-06-352 Nuclear Cleanup of Rocky Flats

gloveboxes, by wiping their surfaces with a liquid cerium nitrate solution.15 

By doing so, the contractor could reduce the contamination enough that 

the contaminated object could be shipped as low-level radioactive waste 

rather than transuranic waste, which requires a more costly shipping and 

disposal process. The Rocky Flats buildings contained approximately 1,475 

gloveboxes, ranging from shoe box size to the size of an entire room. By 

reducing the level of contamination, the contractor could ship even large 

gloveboxes whole, rather than having to cut them into pieces small enough 

to fit into standard waste boxes used for shipping transuranic waste. Figure 

2 shows workers using cerium nitrate to decontaminate a glovebox and 

loading a dismantled, decontaminated glovebox into a container for 

shipping.

Figure 2: Workers Use Cerium Nitrate to Decontaminate a Glovebox; Workers Load a 

Dismantled Glovebox into a Shipping Container

15After being used to decontaminate tanks and gloveboxes, the cerium nitrate solution was 

processed and disposed of as low-level liquid waste. According to Kaiser-Hill, cerium nitrate 

was one of several decontamination solutions used at the site. 

Source: DOE.
Page 13 GAO-06-352 Nuclear Cleanup of Rocky Flats

The use of explosives in building demolition was another important timesaving demolition technique. Contractor officials said they had learned 

lessons from another DOE site at which DOE had doubted the demolitions 

experts and reduced the amount of explosives used, resulting in an 

explosion that failed to bring the structure down. At Rocky Flats, 

accordingly, the contractor and DOE brought in demolitions experts and, 

while closely reviewing the demolition plans and overseeing the work, let 

the experts’ opinions prevail. As a result, the use of explosives saved time 

and money for the contractor and DOE. For example, in bringing down 

building 881, one of the four original manufacturing facilities at Rocky 

Flats, a contractor official estimated that the use of explosives saved about 

4 months, and reduced risks to workers by removing hazards associated 

with heavy equipment and the falling debris that typically results from their 

use in lieu of explosives. After being completely decontaminated, building 

881 was wired with explosives and, as shown in figure 3, collapsed into its 

basement.

Figure 3: Use of Explosives in the Demolition of Rocky Flats’ Building 881

In addition to building 881, the contractor used explosives to bring down 

smaller facilities, such as the guard and water towers, and to separate the 

concrete from the rebar (the steel reinforcing bar) on the walls of building 

886.

Additional information on decontamination and demolition activities at 

Rocky Flats is contained in appendix III.

Source: DOE.
Page 14 GAO-06-352 Nuclear Cleanup of Rocky Flats

Overcoming Limitations on 

Shipping and Transportation 

Capabilities

A second challenge DOE and the contractor overcame was limitations on 

the available number of transportation casks and on the loading capability 

for transuranic waste. At the time of our 2001 report, the contractor’s 

ability to ship the total volume of waste off site to DOE’s WIPP facility by 

the target closure date was in doubt because of uncertainties about 

whether DOE could obtain and provide the number of transportation casks 

necessary to meet the contractor’s projected shipping schedule, especially 

for fiscal years 2002 and 2003, and because of uncertainties about whether 

the three loading facilities (two of which were still under construction at 

the time of our 2000 review) would be able to meet the shipping schedule 

for the site’s peak shipping years. That shipping schedule had been 

compressed by various events, including delays in the opening of WIPP.

DOE and the contractor overcame this challenge primarily through 

cooperation and perseverance. Whenever a DOE site could not use a 

shipping container as scheduled, WIPP would send the container to Rocky 

Flats instead. Also, DOE headquarters maintained a high priority on Rocky 

Flats throughout the cleanup and made sure that it received the 

government-furnished services and items it needed. Figure 4 shows special 

transportation casks used to transport transuranic waste.
Page 15 GAO-06-352 Nuclear Cleanup of Rocky Flats

Figure 4: Transuranic Waste Packaged for Shipment to the Waste Isolation Pilot 

Plant

Also, while buildings at Rocky Flats were being demolished, the contractor 

built the two additional loading facilities, as previously mentioned, to 

ensure that loading and shipping schedules could be supported. The new 

facilities resolved the challenge of inadequate loading capability and 

allowed the contractor to increase its transuranic waste-shipping capability 

to 15 shipments a week.

Identifying the Overall Scope of 

the Cleanup

A third major challenge DOE and the contractor overcame was identifying 

the overall scope of the cleanup—specifically, the extent of contamination, 

the eventual use of the site, and the level of cleanup that eventual use 

would require. At the time of our 2001 report, the postcleanup use of the 

site—and, therefore, the level of cleanup required—was uncertain. 

Moreover, the extent of soil contamination on the site and the depth and 

degree of contamination under many of the former production buildings 

was not fully understood, particularly in the former industrial area, because 

parts of the site had not been fully sampled. Finally, at the time of our 2001 

Source: DOE.
Page 16 GAO-06-352 Nuclear Cleanup of Rocky Flats

report, DOE, the regulatory agencies, and the community stakeholders had 

not yet reached agreement on an appropriate level of soil cleanup, although 

various studies were under way. These challenges were resolved through 

congressional intervention and community collaboration.

Congressional action ended the uncertainty about the end use of the site 

with passage of the Rocky Flats National Wildlife Refuge Act of 2001 

(Refuge Act).16 Knowing the site’s end use enabled DOE and the regulatory 

agencies to then make assumptions about site users and their risk of 

exposure to residual contamination. The risk posed to a person by 

exposure to a contaminant is measured by a combination of the 

contaminant’s toxicity, together with the frequency, pathway, and duration 

of exposure. Thus, a more stringent cleanup level is required for a site that 

will be used constantly, such as for residential purposes, than for a site that 

will be used sporadically, such as for recreational purposes. Once the 

Refuge Act was passed, DOE and the regulatory agencies assumed that the 

principal site users would be wildlife refuge workers, who would spend 

about 8 hours a day at the site (4 hours indoors and 4 hours outdoors), 250 

days a year, for 18.7 years; and refuge visitors, who would spend about 2.5 

hours a day at the site, 100 days a year, for 30 years (6 years as a child and 

24 years as an adult). Soil cleanup levels could then be set at a level that 

would protect both types of users. 

DOE collaborated with the community in determining the level of 

remediation the cleanup would achieve. Before passage of the Refuge Act, 

the Rocky Flats Cleanup Agreement had specified an interim soil cleanup 

level (action level) of 651 picocuries of plutonium per gram (pCi/g) of soil,17

meaning that a soil cleanup action18 would be triggered by a soil sample

16Pub. L. No. 107-107 §§ 3171-3182, 115 Stat. 1012, 1379-1388. Prior to enactment of the 

Refuge Act, DOE and the regulatory agencies proceeded under the assumption that the land 

would be used in the future for open space.

17A picocurie is a trillionth of a curie, which is the amount of radioactivity in a gram of 

radium. The higher the soil action level, the more plutonium can be left in the soil. A lower 

action level means that less plutonium can be left, so more soil must be removed. 

18Remediation of radioactively contaminated soil at Rocky Flats generally meant removal. In 

general, it is more cost effective to remove plutonium-contaminated soil than to treat and 

return it.
Page 17 GAO-06-352 Nuclear Cleanup of Rocky Flats

indicating the existence of plutonium in excess of 651 pCi/g.19 This action 

level was considered unacceptable by the two stakeholder community 

groups: the Rocky Flats Citizens Advisory Board and the Rocky Flats 

Coalition of Local Governments; these groups argued for a much more 

stringent action level. DOE funded a community-directed, independent 

scientific assessment of soil action levels. This independent assessment 

was overseen by a panel of community representatives. DOE also funded a 

workshop, organized by the Rocky Flats Citizens Advisory Board, featuring 

experts who provided presentations on radiological assessments, risk 

analyses, and various computer-modeling scenarios and assumptions. 

Working with local governments and members of the public, DOE and the 

regulatory agencies ultimately agreed on a soil action level of 50 picocuries 

of plutonium per gram (pCi/g) of surface soil (i.e., the top 3 feet of soil), 

meaning that a remedial action would be triggered by a soil sample 

indicating the existence of plutonium in excess of 50 pCi/g. A plutonium 

level of 50 pCi/g translates to a risk level of 1 in 500,000 (that is, this level of 

contamination could result in one more case of cancer than otherwise 

would have been expected in every 500,000 persons).20 DOE and the 

regulatory agencies decided that, with a surface soil action level of 50 

pCi/g, higher concentrations of plutonium in soil could remain at greater 

depth. Accordingly, DOE and the regulatory agencies agreed to set an 

action level of 3,000 pCi/g for depths of 3 to 6 feet below the surface, 

depending on the extent of the contamination. Once a remedial action was 

triggered, cleanup would continue until contamination greater than 1,000 

pCi/g had been removed. 

In addition to collaborating on decisions about soil cleanup levels, 

community groups provided comments and advice on many other aspects 

of the cleanup that influenced DOE’s decisions in some cases. Our survey 

of the Rocky Flats Citizens Advisory Board and the Rocky Flats Coalition 

of Local Governments found that 21 of the 25 respondents were very or 

somewhat satisfied with how DOE engaged the group in the cleanup 

process. Also, 19 of the 25 respondents said they were very or somewhat 

19According to Colorado officials, the action level (651 picocuries per gram) that was 

specified in the 1996 cleanup agreement was based on EPA’s draft proposed rule, which at 

the time was a dose-based, rather than the current risk-based, calculation.

20Initially, according to Colorado officials, cleanup action levels for all contaminants at the 

site, including uranium and americium, were set at a level equivalent to a risk level of 10-5 

(i.e., an excess cancer risk of 1 in 100,000). For plutonium, that level would be about 116 

pCi/g. However, through collaboration with the community stakeholders, a more stringent 

level was set for plutonium: 50 pCi/g. 
Page 18 GAO-06-352 Nuclear Cleanup of Rocky Flats

satisfied with how DOE used the group’s input. Nearly all (23 of 25) said 

they believed the groups’ input had a very or somewhat positive effect on 

the cleanup process.

Problems with Automated 

Plutonium-Packaging System

The unreliable functioning of the automated plutonium-packaging system 

is the only one of the five challenges we identified in 2001 that DOE and the 

contractor never fully resolved. It was only through persistence and “brute 

force” that the packaging was finally completed in July 2003, more than a 

year late and at least $50 million over budget. The system never worked 

reliably, and many of the processes that were designed to be automated 

had to be done manually. It required continuous maintenance and 

modification, and broke down as many as two or three times a day, 

requiring a “triage” repair team on call 24 hours a day. Nevertheless, 

according to DOE officials, the pursuit of any alternative to the system 

would probably have resulted in even greater cost and schedule delays. 

Figure 5 shows GAO officials and staff being briefed on the glovebox line 

behind the automated plutonium-packaging system; this glovebox line 

handled the prepackaging of wet combustibles.

Figure 5: GAO Staff Being Briefed on the Prepackaging of Wet Combustibles, July 

2002 and October 2000

Preventing Safety Problems The final challenge that DOE and the contractor overcame was safety 

problems, which can result in shutdowns and delay cleanup work. At the 

time of our 2001 report, DOE was concerned about the number and 

severity of safety violations that had occurred since the inception of the 

Source: DOE.
Page 19 GAO-06-352 Nuclear Cleanup of Rocky Flats

2000 contract. In response to those concerns, the contractor developed a 

comprehensive plan to improve its safety and compliance performance.

Although some safety incidents occurred after our 2001 report, the 

contractor’s overall safety performance improved. In two key measures of 

safety, for example, Rocky Flats’ performance was considerably better than 

the average performance in the construction industry. One of these 

measures is total recordable cases (TRC). Recordable cases, in general, are 

any that require “more than a Band-Aid,TM” according to a contractor safety 

official—for example, an injury that requires stitches, prescription 

medication, or 1 or more days away from work. At Rocky Flats, the 12-

month TRC rolling average at the end of 2004 was 0.9 per 100 full-time 

workers. This was a significant improvement over the 7.6 rate that existed 

at the site in July 1995, when Kaiser-Hill took over from the previous 

contractor. By comparison, the TRC average in the construction industry 

for calendar year 2004 was 6.4 per 100 full-time workers. The contractually 

established limit for TRCs at Rocky Flats was a 12-month rolling average of 

3.5 per 100 full-time workers. Using the other key measure of safety, lost 

workdays, Rocky Flats also performed well. At the end of 2004, the site’s 

12-month rolling average rate for lost workday cases was 0.2, much lower 

than the site’s July 1995 rate of 4.6 and well below the construction industry 

rate of 2.4 for calendar year 2004. The contractually established limit for 

lost workdays at Rocky Flats was a 12-month rolling average rate of 2.0.

The contractor’s safety director reported that these safety improvements 

were achieved through a combination of actions, including getting the 

Chief Executive Officer, Chief Operating Officer, and other top 

management officials involved; improving the work-planning process to 

incorporate job-hazards analyses; involving the workers early in safetyplanning and job-hazards analyses; holding first-line supervisors (i.e., 

foremen) responsible for informing workers of top management’s emphasis 

on safety; and improving the training provided to workers. The site 

developed a course, commonly known as Rocky Flats 101, that contained a 

hands-on, simulated work environment in which workers learned how to 

use ladders and various other tools in contaminated spaces. The course 

was very effective, according to the safety director.
Page 20 GAO-06-352 Nuclear Cleanup of Rocky Flats

Accelerated Cleanup 

Process Allowed Faster, 

More Collaborative Work

The second key factor that contributed to the early completion of the 

physical cleanup of Rocky Flats was the use of an accelerated cleanup 

process. The Rocky Flats cleanup began in the late 1980s and early 1990s 

with extensive characterization (sampling of soil, groundwater, surface 

water, and air). But after several years of characterization, public 

frustration was building at the lack of visible progress in cleaning up the 

contamination at the site. According to DOE officials, the extensive 

sampling that was done at the site in the late 1980s and early 1990s, 

together with historical documents about the use and disposal of materials 

and wastes, facilitated use of the accelerated process.21 Instead of 

proceeding under the full CERCLA/RCRA process, the Rocky Flats Cleanup 

Agreement authorized DOE to perform most of the cleanup through 

removal actions. In a 1996 report, we recommended that DOE make greater 

use of removal actions to increase the efficiency and cost-effectiveness of 

cleanups.22 Under the accelerated process, cleanup actions, including soil 

removal, occur early and throughout the process rather than at the end, 

with confirmation sampling at each cleanup area to ensure that the 

remediation was sufficient.23 DOE officials report that the accelerated 

process allowed more timely removal of contaminants from the site. 

The pace of work in reviewing and approving cleanup documents was 

“frantic,” according to Colorado officials. Colorado, DOE, and the 

contractor agreed on a “review template” of documents Colorado needed 

to see for each building and area; the template allowed Colorado officials 

to provide immediate review by working closely with the contractor. 

21The Rocky Flats cleanup implements both CERCLA and RCRA. Although the terminology 

used by each program differs, the CERCLA and RCRA processes are similar. The typical full 

remedial processes under CERCLA and RCRA include (1) determining the nature and extent 

of contamination; (2) assessing potential threats to human health and the environment; (3) 

establishing risk-based action levels; (4) identifying potential cleanup technologies and 

processes, and evaluating cleanup alternatives and corrective measures; (5) identifying the 

preferred remedy and obtaining public comment on it; (6) selecting and implementing the 

final remedy; and (7) monitoring and maintaining the remedy.

22GAO, Nuclear Waste: Greater Use of Removal Actions Could Cut Time and Cost for 

Cleanups, GAO/RCED-96-124 (Washington, D.C.: May 23, 1996). 

23The cleanup actions, called “accelerated actions,” were planned and executed to satisfy, 

among other things, the requirements of the Environmental Restoration Rocky Flats 

Cleanup Agreement Standard Operating Protocol for Routine Soil Remediation. Notification 

of the planned activities was approved by EPA or Colorado, depending on where the 

accelerated action was located. (EPA was the lead regulatory agency for the buffer zone; 

Colorado, for the industrial area.)
Page 21 GAO-06-352 Nuclear Cleanup of Rocky Flats

Although the cleanup agreement specified that Colorado had 14 days (30 

days in some cases) to review and provide comments on cleanup-related 

documents, use of the review template shortened the review time 

considerably. For example, the contractor would send draft documents to 

Colorado officials, who would provide comments directly to the 

contractor; the contractor then would respond by making corrections, 

providing additional data or documents, or doing more work if necessary. 

By working closely with the contractor along the way to resolve questions 

or concerns, Colorado was able to respond quickly—sometimes on the 

same day—to DOE’s faxed requests for official approval of cleanup-related 

documents. Colorado officials pointed out that had they not been willing to 

work in this way with the contractor, but had instead taken the 14 or 30 

days provided for review and approval under the cleanup agreement, the 

contractor would not have been able to complete the cleanup as early as it 

did. (DOE noted that Colorado’s work with the contractor was not done 

without DOE’s involvement; as mentioned throughout the report, the entire 

process was collaborative.)

DOE, EPA, and Colorado agreed that the accelerated process and the 

collaboration it fostered were essential to the cleanup’s early completion. 

According to EPA and Colorado officials, their agencies had staff on site 

“continuously,” working in the field with DOE and contractor staff to 

discuss and observe cleanup operations, and requiring “real time” changes 

as necessary. Throughout the process, the regulatory agencies were 

intimately involved in reviewing data and otherwise contributing to the 

development of studies, plans, and decision documents. As a result, the 

“back end” of the review process was very streamlined, according to 

contractor officials. 

While the accelerated cleanup actions were under way, and as data from 

the completed cleanup actions became available, DOE concurrently 

conducted the remedial investigation and feasibility study (RI/FS),24 which 

summarizes site conditions at closure and evaluates necessary long-term 

remedies, such as site monitoring. Based on all of the data collected at the 

site, including the results of the individual accelerated cleanup actions and 

24Throughout this report, our use of either a general descriptive term or a CERCLA term for 

a specific regulatory document is intended to include the RCRA equivalent as well. For 

example, if we refer to the final decision document, we mean both the CERCLA record of 

decision and the RCRA corrective action decision. Similarly, if we refer to the feasibility 

study (a CERCLA term), we mean that to include the corrective measures study (a RCRA 

term). 
Page 22 GAO-06-352 Nuclear Cleanup of Rocky Flats

the RI/FS, DOE will identify its preferred final remedy in the proposed plan, 

which will be released for formal public comment once the final RI/FS has 

been approved by EPA and Colorado. DOE shared the draft RI/FS with the 

public and obtained EPA’s and Colorado’s comments on it; these comments 

were considered during preparation of the final RI/FS. After considering 

comments received on the proposed plan during a 60-day public comment 

period, DOE will select and document its preferred remedy in the final 

decision document. Once EPA and Colorado approve the final decision 

document, it will serve as both the corrective action decision (under 

RCRA) and the record of decision (under CERCLA). 

Site-Specific Characteristics 

Aided Cleanup Effort

The third key factor that contributed to the early completion of the physical 

cleanup of Rocky Flats was a confluence of circumstances—climatic, 

geologic, chemical, structural and economic—that confined the scope and 

complexity of the cleanup effort. Climatically and geologically, the semiarid 

climate and the alluvial fan upon which the site is located contributed to 

slow erosion of soils over time, thus inhibiting the off-site migration of 

contaminants. The site also benefited from layers of shale and claystone—

hundreds of feet thick in places—that prevented contamination from 

seeping into the deep drinking-water aquifer that underlies part of the site.
Page 23 GAO-06-352 Nuclear Cleanup of Rocky Flats

Chemically, the cleanup was aided by the nature of the two key 

contaminants—plutonium and americium, which are essentially insoluble 

in water and, instead, tend to bind to soil and sediment particles, according 

to a study undertaken in the late 1990s.25 At Rocky Flats, there is little 

groundwater movement, and no groundwater was contaminated with 

plutonium and americium.26 Instead, soil was the predominant 

environmental medium requiring cleanup. Remediation of contaminated 

soil generally consists of digging it up and shipping it to a disposal site, a 

simpler task than remediating groundwater. The contaminants move 

around the site, and potentially off site, by surface-soil erosion, wind, or 

surface water. For example, westerly winds spread contaminated soil to 

off-site lands east of Rocky Flats. In a 1997 combined corrective action 

decision/record of decision about these lands,27 EPA and Colorado 

determined that the lands did not pose an unacceptable or significant risk 

to human health or the environment, notwithstanding the low levels of 

plutonium and americium that existed in the soil—in portions of the 

lands—from Rocky Flats activities.28

Structurally, the robust construction of the plutonium-processing buildings, 

with their thick concrete floors and walls, contained many leaks and spills 

of radioactive and hazardous materials, thereby limiting the extent and 

severity of contamination under the buildings. Building 371, for example, 

was a complex, extremely strong, and rigid structure that was built to 

withstand accidents such as earthquakes, tornadoes, winds, and fires. The 

building was a partially buried structure of reinforced concrete with an 

extensive foundation of concrete caissons up to 6 feet in diameter, drilled 

25Kaiser-Hill, Actinide Migration Evaluation Pathway Analysis Summary Report, ER-108 

(2002).

26Some contaminated groundwater seeps to the surface, particularly during periods of rain 

or snow, and then trickles into ditches and streams. The primary groundwater contaminants 

are volatile organic compounds (e.g., degreasers and solvents such as trichloroethene, 

carbon tetrachloride, and chloroform). These contaminants are largely controlled by the 

groundwater treatment systems on site, which were installed to protect surface water.

27EPA, Superfund Record of Decision: Rocky Flats Plant (USDOE), EPA ID: CO7890010526, 

OU 3, Golden, CO, EPA/ROD/R08-97/196, 1997 (Golden, Colo., June 3, 1997).

28In 1990 a class action suit was filed in federal court against two corporations that formerly 

operated the Rocky Flats Plant under contract to DOE. Among other things, the plaintiffs 

claimed that their land was damaged by the release of hazardous substances from Rocky 

Flats. In February 2006, a jury found for the plaintiffs and awarded compensatory and 

punitive damages. However, the court has not yet entered a judgment, and the litigation is 

ongoing. Cook v. Rockwell International, No. Civ.A. 90-CV-181-JLK (D. Colo.).
Page 24 GAO-06-352 Nuclear Cleanup of Rocky Flats

into bedrock, and concrete wall and slab thicknesses beyond typical 

industrial use and code requirements. Similarly, building 771 featured 

concrete thicknesses ranging from 6.5 inches to more than 2 feet. 

Finally, the local economy was a factor in the success of the cleanup, 

according to Colorado officials. The local economy was not heavily 

dependent on the cleanup project to provide jobs, so closing the site did 

not meet large-scale community opposition. 

DOE Provided the 

Contractor with a Financial 

Incentive to Finish Early 

and Under Cost

The fourth key factor that contributed to the early completion of the 

physical cleanup of Rocky Flats involved certain features of the cleanup 

contract, including a substantial financial incentive for the contractor to 

finish the cleanup work ahead of schedule and below budget. The contract 

provided for an incentive fee tied partly to schedule but predominantly to 

cost. The contractor would earn the target fee of $340 million if it 

completed its work between December 16, 2006, and March 31, 2007, at a 

cost between $4 billion and $4.2 billion.29 If the contractor completed the 

cleanup outside of these schedule and cost ranges, the fee would rise or fall 

accordingly—to as much as $460 million for less costly, earlier completion, 

or as little as $130 million for more costly, later completion. In 2003, when 

officials saw that the contractor was confident of earning the maximum fee 

and was no longer working aggressively to further shorten the completion 

timeline or reduce costs, DOE approved a $100 million increase in the 

maximum incentive fee. In the end, DOE awarded the contractor $49 

million of the additional available fee, based on a reduction in the total 

project cost of an additional $129 million.

29In this paragraph, the cost and fee amounts are those cited in the contract and have not 

been adjusted to constant 2005 dollars; the contract contains no provision for inflation.
Page 25 GAO-06-352 Nuclear Cleanup of Rocky Flats

DOE also encouraged the contractor to continue its practice of sharing 

incentive fees among its workforce by offering employees financial 

incentives to continue to work safely and generate ideas for ways to save 

costs and time. In its initial contract bid for the 1995 contract for the Rocky 

Flats cleanup, Kaiser-Hill committed to share 20 percent of its profits with 

employees. The contractor’s president explained that incentives were 

offered across the workforce, although the incentive type varied by work 

group. Salaried employees were individually evaluated based on their 

project and safety performance; the value of their incentive pay was based 

on the final total project cost. For hourly employees, incentive pay was 

determined though collective bargaining but was primarily based on 

schedule performance. Steelworkers received an annual incentive bonus, 

based on schedule performance; workers in the building trades received an 

annual hourly increase, also based on schedule performance. The 

contractor also had a safety incentive program that included spot cash 

awards. Over the life of the project, the contractor distributed 

approximately $100 million of company earnings (about 20 percent of its 

$510 million incentive fee) to its workers, and DOE contributed an 

additional $30 million that was used for incentive pay.30

According to the contractor, financial incentives for early or under-budget 

completion of a project are a powerful motivator; however, it is important 

to note that the financial incentive offered at Rocky Flats was only one of 

many factors contributing to the early completion of the cleanup. In GAO’s 

experience, such incentives are not always this successful. As we reported 

in December 2005, the Department of Defense has not fared well at using 

incentive-fee contracts to improve cost-control behavior or meet program 

goals.31 Specifically, about half of the 27 incentive-fee contracts included in 

GAO’s review failed or were projected to fail to meet a key measure of 

program success—completing the objective (i.e., delivering the product or 

service specified by the contract) at or below the target price. Research on 

incentive fees by GAO, Harvard University, and the RAND Corporation 

going back decades has concluded that incentive fees do not consistently 

motivate contractors to control cost.

30DOE’s contribution was specified in the contract, as 4 percent of salary cost.

31GAO, Defense Acquisitions: DOD Has Paid Billions in Award and Incentive Fees 

Regardless of Acquisition Outcomes, GAO-06-66 (Washington, D.C.: Dec. 19, 2005).
Page 26 GAO-06-352 Nuclear Cleanup of Rocky Flats

Additionally, according to the contractor, enhanced workforce transition 

benefits could be considered important to worker motivation and 

productivity. Enhanced benefits included pension and post-retirement 

medical benefits and outplacement services such as relocation and 

education benefits. 

Another unusual and critically important feature of the Rocky Flats 

contract was consistent funding. An underlying premise of the contractor’s 

ability to finish the job early and under budget was that a stable source of 

funding would be provided throughout the cleanup. As part of the contract 

negotiation process, DOE and the contractor assumed an annual funding 

level of $657 million per year. Both DOE headquarters and Congress helped 

each year to ensure that the site received a consistent funding level. The 

contract also stipulated the services and items that the government would 

provide, including making a number of shipping containers available and 

arranging treatment and disposal sites for radioactive waste at the site. If 

DOE did not meet its contractual obligation, it would be grounds for 

changing the contract. In that way, DOE bore the liability for any role it had 

in increasing contract costs.

Cleanup of Rocky Flats 

Is Complete at a Cost 

of about $10 Billion, 

but Key Steps Remain 

Before the Planned 

Wildlife Refuge Will 

Open 

 The physical cleanup at Rocky Flats is complete, at a total cost (including 

long-term costs) of about $10 billion;32 however, several regulatory steps 

remain before land can be transferred to the Department of the Interior for 

establishment of the wildlife refuge planned for the site. After DOE issues 

and considers public comments on its proposed plan, identifying its 

preferred alternative for the site’s future monitoring and remediation, EPA 

and Colorado will jointly determine whether any further cleanup is needed 

at the site or whether the cleanup actions already taken are sufficient to 

render the site safe for its intended purpose. A final decision by EPA and 

Colorado is expected in late 2006. If they decide that no further action is 

needed to remediate the site, EPA will delete portions of the site from the 

CERCLA National Priorities List33 and certify that the cleanup and closure 

of Rocky Flats has been completed; the Secretary of the Interior can then 

accept administrative jurisdiction of designated lands and establish the 

32Unless otherwise noted, all costs cited in this section have been adjusted for inflation and 

are expressed in constant 2005 dollars.

33Portions of the site being retained by DOE for long-term stewardship may not be removed 

from the list.
Page 27 GAO-06-352 Nuclear Cleanup of Rocky Flats

refuge, in accordance with the Rocky Flats National Wildlife Refuge Act of 

2001.

Regulatory Steps Remain 

Before the Site Can Open as 

a Wildlife Refuge

Although the contractor has finished the cleanup at Rocky Flats, DOE, 

EPA, and Colorado must complete the remaining steps of the regulatory 

process before Rocky Flats can be removed from the National Priorities 

List. On October 13, 2005, the contractor declared that it had successfully 

completed the Rocky Flats cleanup—more than 1 year before the target 

cleanup completion date cited in the contract and more than 3 years before 

the completion date the contractor thought likely in our 2001 report.34

In declaring the cleanup complete in October 2005, the contractor stated 

that it had met all of the cleanup requirements in the contract, which 

included: (1) demolishing all buildings; (2) investigating and remediating as 

necessary 360 individual cleanup areas; (3) removing wastes as specified in 

the cleanup agreement; (4) installing closure caps for two landfills; (5) 

covering appropriate areas such as building foundations, utilities, paved 

roads, and parking lots with a minimum of 3 feet of fill (e.g., Rocky Flats 

alluvium) after final grade; (6) ensuring that on-site surface water meets 

health-based standards for open-space use; and (7) ensuring that water 

leaving the site via two creeks will meet Colorado water quality standards. 

The contractor reported its major cleanup accomplishments in an October 

2005 report.35 Among these accomplishments were that the contractor

• deactivated, decontaminated, removed, and cut up 1,475 gloveboxes, 

and disposed of them off site; 

• cleaned up and removed more than 800 structures, including more than 

1 million square feet associated with five major plutonium facilities and 

two major uranium facilities;

• shipped to other DOE facilities 21 tons of special nuclear materials 

(plutonium and highly enriched uranium), including metals, oxides, and 

over 100 tons of plutonium residues;

34GAO-01-284.

35Kaiser-Hill Company L.L.C., Executive Summary, Draft RCRA Facility Investigation—

Remedial Investigation/Corrective Measures Study—Feasibility Study Report for the 

Rocky Flats Environmental Technology Site, prepared for the Department of Energy, 

October 2005.
Page 28 GAO-06-352 Nuclear Cleanup of Rocky Flats

Major cleanup accomplishments at 

Rocky Flats

● Shipped off site an amount of cleanup 

waste equivalent to a 65-story building the 

length and width of a football field, 

including more than 15,000 cubic meters

of transuranic and other radioactive waste, 

more than 500,000 cubic meters of 

low-level and other radioactive waste, 

more than 800,000 cubic meters of 

sanitary waste, and more than 4,300 cubic 

meters of hazardous waste (see fig. 6).

● Treated more than 11 million gallons of 

contaminated groundwater and 5 million 

gallons of contaminated seep 

water—enough to fill 24 Olympic-size 

swimming pools (see fig. 6).

• deactivated, decontaminated, removed, and cut up 690 tanks, and 

disposed of them off site;

• installed covers at two landfills;

• investigated and remediated, as necessary, 421 areas of known or 

suspected contamination, including 360 cleanup areas such as individual 

hazardous substance sites and contamination located under buildings; 

and

• installed three barriers and a seep collection system to treat 

contaminated groundwater plumes; installed passive treatment systems 

to protect surface water quality.
Page 29 GAO-06-352 Nuclear Cleanup of Rocky Flats

Figure 6 illustrates the equivalent amounts of waste removed and 

contaminated water treated at Rocky Flats during the cleanup.

Figure 6: Waste Removed and Contaminated Water Treated at Rocky Flats

Waste volume

65-story building (809 feet) the size of a football field (160 x 360 feet)

Ground and seep water volume

24 Olympic-size swimming pools (660,253 gallons each)

Sources: GAO.
Page 30 GAO-06-352 Nuclear Cleanup of Rocky Flats

Figure 7 shows the site as it was in 1995, when the contractor began its 

cleanup job, and on October 13, 2005, when the contractor declared its job 

done.

Figure 7: Rocky Flats, before Cleanup, in 1995 (left), and after Cleanup (in 2005)

The contract provided that when the contractor declared the cleanup 

finished, DOE would have 90 days to either accept the project as complete 

or provide the contractor with a list of items to address. In November 2005, 

DOE provided the contractor with the final list. In December 2005, after 

reviewing cleanup documentation, doing a final walk-through of the site, 

and ensuring that the contractor had completed the remaining items, DOE 

agreed that the contractor had fulfilled all of the cleanup actions specified 

in the contract and the cleanup was complete.

The next steps include the review, revision, and final approval of the 

remaining regulatory documents. Figure 8 shows the key steps in Rocky 

Flats’ transition from a cleanup site to a wildlife refuge.

Source: DOE.
Page 31 GAO-06-352 Nuclear Cleanup of Rocky Flats

Figure 8: Key Steps in Rocky Flats’ Transition to a Wildlife Refuge

Those steps are as follows:

• July 2006: DOE expects to issue its proposed plan, specifying its 

preference for future monitoring and remediation of the site from 

among the following alternatives outlined in an RI/FS: (1) no further 

action, with monitoring; (2) monitoring plus both institutional and 

physical controls; and (3) monitoring and both institutional and physical 

controls, plus additional targeted removal of plutonium-contaminated 

soil in an isolated area to reduce the excess cancer risk for wildlife 

refuge workers from 1 in 500,000 to 1 in 1,000,000. The proposed plan 

will also specify the area to be retained by DOE rather than transferred 

to FWS. As agreed between DOE and the regulatory agencies, the plan 

will be issued for a 60-day public comment period, which will include a 

public hearing.

2005 2006 

October 2005 

The contractor completed 

physical cleanup 

June 2006

DOE issues

proposed plan

November 2006

DOE, EPA, Colorado 

issue final decision 

document

December 2006

EPA certifies completion of cleanup 

and removes portions of the site 

from National Priorities List

2011 - 2016

FWS opens

public access

trails and 

facilities in 

wildlife refuge

December 2005

DOE agreed that 

the contractor had 

completed physical 

cleanup

Sources: GAO, based on information provided by DOE, EPA, and FWS.

Early 2007

DOE transfers portions

of the site to FWS

Actual 

dates

Estimated

dates
Page 32 GAO-06-352 Nuclear Cleanup of Rocky Flats

• November 2006: After considering public comments on the proposed 

plan, EPA and Colorado expect to finalize and issue the final joint 

decision document.36 The final decision document will specify what 

additional cleanup, if any, is necessary at the site and what monitoring 

and institutional and physical controls, if any, will be necessary. The 

document will also include a “responsiveness summary” that responds 

to questions from the public and other stakeholders on the proposed 

plan. 

• December 2006: EPA expects to certify that the cleanup is complete. It 

may then remove portions of the site from the National Priorities List.37 

• Early 2007: DOE expects to transfer jurisdiction of the majority of the 

site (approximately 5,400 acres) to FWS. The specific acreage to be 

transferred will be specified in the final decision document and will be 

contingent upon DOE’s purchasing privately owned “essential mineral 

rights” (i.e., the right to mine sand and gravel) affecting about 700 acres. 

Under the legislation authorizing DOE to purchase these essential 

mineral rights, the refuge will not include land that is subject to sand 

and gravel mining or is being actively mined by private parties.38

• 2012 through 2022: FWS expects to open public access trails and 

facilities in the wildlife refuge, as described in the agency’s Final 

Comprehensive Conservation Plan.39 FWS’s ability to implement its 

conservation plan is contingent on funding availability. In the first year 

following land transfer and refuge establishment, if funds are available, 

FWS will open one 1.75-mile pedestrian trail, which will follow the 

36This final decision document will be a joint CERCLA record of decision and RCRA 

corrective action decision. 

37In the future, some part of the DOE-retained lands may also be deleted from the National 

Priorities List. A site may be deleted from the list even though operation and maintenance of 

a remedy continue. Accordingly, at some point EPA may agree to delete the surface of the 

DOE-retained lands but not the subsurface or the groundwater. 

38Such lands are excluded from the refuge until the essential mineral rights are purchased or 

the surface land is mined and reclaimed by the mineral rights holder(s). National Defense 

Authorization Act for Fiscal Year 2006, Pub. L. No. 109-163, § 3112(b)(7)(B), 119 Stat. 3136, 

3542.

39U.S. Fish and Wildlife Service, Rocky Flats National Wildlife Refuge: FINAL 

Comprehensive Conservation Plan and Environmental Impact Statement (Denver, Colo., 

Sept. 16, 2004).
Page 33 GAO-06-352 Nuclear Cleanup of Rocky Flats

existing road to the Lindsay Ranch homestead site, which dates from the 

early 1940s (see fig. 9).

Figure 9: The Lindsay Ranch

Before opening other trails, FWS officials said they will concentrate on 

restoring wildlife and plant habitat, controlling noxious weeds, removing 

roads and culverts, and restoring the prairie grasslands. As funding 

permits, between 2012 and 2022, they plan to phase in the remaining 15 

miles of trail as well as other public-use facilities, such as parking lots, a 

visitors’ kiosk, wildlife-viewing blinds, and scenic overlooks. Figure 10 

depicts FWS’s plan for visitor use at the refuge, including about 16 miles of 

trails, parking, and developed overlooks.

Source: DOE.
Page 34 GAO-06-352 Nuclear Cleanup of Rocky Flats

Figure 10: Plan for Public Access Trails and Facilities at the Rocky Flats National Wildlife Refuge

Source: U.S. Fish and Wildlife Service.
Page 35 GAO-06-352 Nuclear Cleanup of Rocky Flats

Even after the wildlife refuge opens, some stewardship activities will likely 

continue at the site for an indeterminate time. For example, DOE will 

maintain groundwater monitoring wells and treatment facilities as long as 

necessary, subject to approval of the regulatory agencies. Additionally, as 

required by CERCLA,40 DOE will review the site at least every 5 years to 

determine whether remedies continue to be fully protective of human 

health and the environment. DOE, EPA, and Colorado reviewed parts of the 

site in 2002; the next review is scheduled for 2007. 

Further, DOE negotiated an environmental covenant with Colorado for one 

of the landfills at the site, called the Present Landfill. The purpose of this 

covenant is to ensure protection of human health and the environment by 

preventing intrusions into the landfill or damage to the various engineered 

structures on adjoining lands and preventing exposure to hazardous 

wastes. The covenant, which runs with the land in perpetuity, is binding on 

DOE and all other interested parties (including persons using the land), as 

well as their heirs and successors. Activities prohibited by the covenant 

include digging, drilling, tilling, grading, and excavating, as well as any 

activities that could damage or impair the proper functioning of the landfill 

cap and runoff controls, the passive seep intercept and treatment system, 

or the groundwater monitoring wells. According to a DOE official, DOE 

and the state anticipate that the covenant for the Present Landfill will be 

supplanted by a broader covenant for the DOE-retained lands; this broader 

covenant will become effective with execution of the final decision 

document (the combined corrective action decision/record of decision). 

The long-term care of the site is a subject of continuing debate and, for 

some, concern. The long-term condition and care of the site were the 

concerns most mentioned by community group survey respondents. Of the 

17 (of 25) survey respondents who said they had remaining concerns about 

the cleanup, 15 mentioned concerns about what would happen at the site in 

the future. 

Rocky Flats Cleanup Cost 

about $10 Billion, Including 

Long-Term Costs

The total cost of the cleanup—about $10 billion—comprises costs incurred 

from 1995 through 2005 and estimated long-term costs through about 2080. 

Costs incurred to date include the following: 

40CERCLA § 121(c); 42 U.S.C. § 9261(c). EPA and Colorado also have a significant role in the 

5-year review process.
Page 36 GAO-06-352 Nuclear Cleanup of Rocky Flats

• The 2000 closure contract cost DOE over $4.1 billion through October 

2005—nearly half the total cost of cleanup through closure. This cost 

includes the $510 million incentive fee that DOE paid the contractor.

• The 1995 cleanup contract cost DOE nearly $3.6 billion through early 

2000, including a $120 million fee to the contractor.

• The cost of DOE’s Rocky Flats Field Office from fiscal year 1995 through 

October 2005 was nearly $760 million. This cost included staff salaries, 

site utilities, litigation support, regulatory oversight, and other 

expenses. 

• The cost incurred by other DOE sites in support of the Rocky Flats 

closure was approximately $138 million, for such activities as certifying 

shipping containers, providing transportation for nuclear materials and 

wastes, and receiving and storing Rocky Flats’ materials and wastes.

In addition, in January 2006, Congress authorized DOE to spend up to $10 

million on the purchase of designated “essential mineral rights” at the 

Rocky Flats site.41 The law provided that these mineral rights at the site can 

be purchased only from willing sellers and that the cost must not exceed 

fair market value. In January 2006, DOE shared the results of an appraisal 

of the mineral rights with the three ownership groups at Rocky Flats. DOE 

will meet with various natural resources trustees, including the 

Department of the Interior, to determine how to facilitate the sale of the 

designated essential mineral rights.

DOE anticipates that long-term costs will exceed $1.3 billion. The bulk of 

these costs will be the cost to DOE for pensions and postretirement 

benefits (primarily medical and life insurance coverage) for the 

contractor’s Rocky Flats employees. These costs will likely exceed $1 

billion, including about $822 million in medical benefits alone. DOE is liable 

for such costs under the provisions of not only the 2000 contract, but also 

previous site management contracts with Kaiser-Hill and its predecessors. 

Postretirement benefits and pensions are part of the total allowable 

compensation for DOE contractor employees, and DOE considers them to 

be necessary to attract the most qualified employees. DOE Order 350.1 

provides that when operations at a DOE facility are terminated and no 

41National Defense Authorization Act for Fiscal Year 2006, Pub. L. No. 109-163, § 3112, 119 

Stat. 3136, 3540 (2006).
Page 37 GAO-06-352 Nuclear Cleanup of Rocky Flats

other work is to occur under the contract (as in the case of Rocky Flats), 

pension and postretirement health benefit continuation will be provided by 

DOE for those contractor employees who earned retirement benefits in 

these plans. According to actuarial estimates prepared for DOE by a 

consultant, payments for contractor employees at Rocky Flats will 

continue until about 2064.

At Rocky Flats, 2,815 (43 percent) of 6,616 contractor employees were 

eligible for postretirement benefits.42 These employees worked for either 

the prime contractor (Kaiser-Hill) or one of its major subcontractors, and 

retired between January 1, 1995, and December 31, 2005. The estimated 

cost of over $1 billion does not include pensions and postretirement 

benefits for employees who would have become eligible if the site had 

closed on its original target closure date of December 31, 2006. When the 

site closed more than a year ahead of schedule, the early closure date 

preceded the eligibility date for full pensions and postretirement benefits of 

34 employees, according to a contractor official.

Costs for the long-term stewardship of the site are estimated at $303 

million. Long-term stewardship includes site surveillance and maintenance, 

as well as management of site records and information systems. For many 

decades to come, DOE will need to monitor environmental conditions at 

the site and maintain the systems and structures that remain there (e.g., 

groundwater treatment systems, ponds and surface water control features, 

and landfills). According to draft DOE guidance, surveillance and 

maintenance refers to “all activities necessary to ensure protection of 

human health and the environment following cleanup at a site, in 

perpetuity.” Thus, while long-term stewardship costs are estimated through 

about 2080, some costs will continue beyond that, depending on the extent 

of stewardship needed.

42Plan benefits were different for the eligible salaried employees (1,546 employees), hourly 

employees (1,187 employees), and security policy officers (82 employees). 
Page 38 GAO-06-352 Nuclear Cleanup of Rocky Flats

Our 2001 report noted that the total cost could rise if any claims for 

monetary damages were brought against DOE to compensate for injuries to 

natural resources. Under CERCLA, federal, state, and Indian tribal officials 

who have been designated as trustees can file claims for monetary damages 

for injuries to natural resources (including wildlife, fish, and lakes) 

resulting from releases of hazardous substances. Damages are usually for 

injuries that were not rectified by the cleanup and are to be used to restore, 

replace, or acquire equivalent resources. In a November 2005 report,43

DOE’s Inspector General said that DOE had not yet conducted the required 

Natural Resource Damage Assessment at Rocky Flats and that only the 

completion of that assessment would determine whether additional costs 

will be ultimately incurred. 

But speculation about the potential cost of natural resource damage claims 

at the site was laid to rest with passage of the 2006 National Defense 

Authorization Act. Under the act, a natural resource damage liability claim 

would be considered to be satisfied by the purchase of mineral rights for 

$10 million, as authorized by the act, or the payment of the authorized $10 

million to the natural resource trustees, or a combination of the two, for a 

total payment of $10 million.44 Although DOE had agreed with the Inspector 

General’s recommendation to immediately initiate the damage assessment, 

the subsequent provisions of the Defense Authorization Act rendered the 

damage assessment requirement moot. 

43DOE, Management Controls over Assessing Natural Resource Damage at Rocky Flats, 

OAS-M-06-02 (Washington, D.C., Nov. 25, 2005).

44Pub. L. No. 109-163, § 3112(b)(4), 119 Stat. 3136, 3540-41. For the Rocky Flats site, 

according to the cleanup agreement, the designated natural resource trustees are the 

Secretary of Energy, the Secretary of the Interior, the Executive Director of the Colorado 

Department of Public Health and Environment, the Colorado Attorney General, and the 

Deputy Director of the Colorado Department of Natural Resources.
Page 39 GAO-06-352 Nuclear Cleanup of Rocky Flats

Numerous Measures 

Were Taken to Assess 

the Cleanup’s 

Sufficiency, but DOE 

Could Improve Its 

Oversight of Data 

Quality and Clarify Its 

Verification Policy 

Numerous measures were and are being taken to assess the sufficiency of 

the cleanup; although these measures appear adequate, DOE did not carry 

out some aspects of its oversight responsibilities. Cleanup assessment 

measures include (1) the completion of the CERCLA and RCRA regulatory 

process, (2) DOE’s verification of the contractor’s remediation of 

radiologically contaminated soil, and (3) other reviews by federal agencies 

and independent consultants. The first assessment measure—completion 

of the CERCLA and RCRA regulatory review and approval process—relies 

on remediation data collected throughout the cleanup. Our review showed 

that the contractor appeared to have comprehensive quality controls for 

data. Nevertheless, DOE did not independently review the quality of these 

data. A DOE official said that, while he had no explanation for DOE’s not 

conducting the required reviews, DOE officials’ day-to-day review of data 

did enable them to detect data issues as they arose. The second assessment 

measure—DOE’s verification of the contractor’s actions to remediate 

radiologically contaminated surface soil—was not completed. DOE 

decided to eliminate parts of the planned independent review of the 

accuracy of contractor-conducted scans for remaining radiological 

contamination because DOE officials decided that the likely results would 

not justify the completion of an independent review. The third assessment 

measure—outside reviews—included a consultant review that convinced 

DOE to revise a key water management strategy at the site, and a federal 

review that found no public health hazard for the communities surrounding 

Rocky Flats. 

DOE Did Not Independently 

Review the Quality of 

Cleanup Data Crucial to the 

Regulatory Process

DOE did not independently review the quality of the data obtained 

throughout the cleanup—data crucial to the first assessment of the 

cleanup’s sufficiency, the CERCLA and RCRA process. As discussed earlier, 

the final steps of this regulatory process are still in progress,45 but much of 

the process is complete. Key data were obtained through a four-step 

process of remediating 360 individual areas at Rocky Flats, and EPA and 

Colorado documented their approval of these cleanups in closeout reports, 

giving DOE officials confidence that the site will meet the final cleanup 

requirements. The closeout reports also include data on residual 

contamination (i.e., the contamination that remains following completion 

of the cleanup action). The residual contamination data were analyzed in a 

45As discussed earlier, the regulatory agencies anticipate issuing the final decision document 

at the end of 2006. 
Page 40 GAO-06-352 Nuclear Cleanup of Rocky Flats

draft comprehensive risk assessment that was part of the remedial 

investigation/feasibility study, which determined that the site’s overall risk 

falls within EPA’s acceptable risk range. Because the data from the 

accelerated actions are crucial to the regulatory agencies’ final decision on 

the sufficiency of the cleanup, we reviewed the controls in place to ensure 

the quality of these data. We discussed these data quality policies and 

procedures with DOE, EPA, Colorado, and contractor and subcontractor 

officials and determined that, although the contractor’s data quality 

controls appeared robust and comprehensive, DOE could improve its 

oversight of them. Further, our review of several closeout documents 

revealed that the policies and procedures were generally followed.

Soil Cleanup Actions Followed a 

Four-Step Process

At Rocky Flats, accelerated soil cleanup actions were generally completed 

and approved through a four-step process.46 As of May 2006, EPA and 

Colorado officials said they had approved the closeout reports on all 360 

areas of known or suspected contamination at Rocky Flats and had 

concluded that no further accelerated cleanup actions were necessary for 

those areas.47 Closeout reports are the last step of a regulatory approach 

that documented the accelerated cleanup actions taken, quantified 

contaminants remaining after the cleanup actions were completed, and 

documented whether the project goals had been met. The remediation of 

each area of soil contamination at Rocky Flats followed a four-step 

process: characterization, contaminant remediation, confirmation 

sampling, and clean fill and project documentation. 

The first step—characterization—identified whether contamination had 

occurred. The contractor had to design a sampling and analysis approach 

for each specific cleanup area and receive DOE’s approval before 

submitting the approach to the regulatory agencies for their review and

46Much of the contamination at Rocky Flats was confined to the soil. Hazardous and 

radioactive waste was buried in trenches, and soil in areas where spills or leaks had 

occurred was contaminated with solvents and other hazardous chemicals. 

47Our references to closeout reports include data summary reports, which were prepared 

and approved in lieu of closeout reports if no cleanup was necessary at a cleanup area. 
Page 41 GAO-06-352 Nuclear Cleanup of Rocky Flats

approval.48 Once a potentially contaminated area was identified, the 

contractor would propose one of several approaches to collect the 

necessary samples. For example, the contractor might choose a standard 

statistical sampling approach, which entails designing a sample grid 

capable of identifying an elevated area of contamination with 90 percent 

confidence, then applying that grid to the actual cleanup area. Sample 

collection involved taking small scoops of dirt, which were analyzed in a 

laboratory for a variety of contaminants such as metals, volatile organic 

compounds, and radionuclides.

The second step—contaminant remediation—cleans up any contaminants 

that characterization found to exceed acceptable levels. Again, the 

contractor would prepare a remediation plan, based on a standardized 

approach for removing soil,49 in consultation with EPA, Colorado, and 

members of the public, for EPA and Colorado to approve. Once approval 

was granted, the contractor could proceed with the actual cleanup. 

Cleanup typically involved digging out the contaminated soil, packaging it, 

and shipping it to a licensed treatment or disposal facility. The depth to 

which soil was removed varied depending on the type and severity of 

contamination. In some areas, less than a foot of soil needed to be 

removed; in other areas, 20 feet of soil needed to be removed. The 

contractor took samples throughout the remediation to identify when the 

remediation goal had been met and could then move on to the third step. 

According to officials of both EPA and Colorado, they frequently directed 

their staff to observe the cleanup actions to ensure they were being 

implemented as agreed. Colorado officials said that, while the frequency 

and duration of their oversight varied by project, daily interaction and 

observation by Colorado staff was typical. 

The third step—confirmation sampling—required taking small scoops of 

dirt from areas where the contractor believed remediation was complete, 

and having them analyzed for the presence of previously identified 

contaminants. The samples could be analyzed at an on-site laboratory or 

48The characterization approach is documented in a Sampling and Analysis Plan Addendum. 

Occasionally, when schedule concerns existed and the planned work was routine in nature, 

DOE allowed the contractor to send draft documents to the regulatory agencies while DOE 

was reviewing them. 

49Depending on the complexity and the time required to complete the remediation, the 

remediation plan was set forth in an interim measure/interim remedial action, a proposed 

action memorandum, or a Rocky Flats Cleanup Agreement standard operating protocol.
Page 42 GAO-06-352 Nuclear Cleanup of Rocky Flats

sent off site, depending on the types of contaminants. If the laboratory 

confirmed that the contaminants had been removed to an acceptable level, 

the contractor could move on to the next step. If the laboratory results 

showed an unacceptable level of contaminants, then additional soil would 

be removed, followed by additional confirmation sampling. Additional soil 

removal and sampling rarely occurred, however, because field 

measurements and analyses were used to guide the remediation work 

before the final confirmation samples were taken. 

The fourth and final step—clean fill and project documentation—included 

filling the excavated area and preparing a closeout report that documented 

that the cleanup had met the stated goals and quantified any residual 

contamination. The contractor generally filled the excavated area with 

Rocky Flats alluvium, a mixture of sand, dirt, and gravel. Documentation of 

residual contamination was important to the regulatory process because 

these data were instrumental in completing the remedial investigation and 

feasibility study, including the comprehensive risk assessment.50 After 

DOE approved the closeout report, it was delivered to the regulatory 

agencies for final approval. The regulatory agencies’ approval meant that 

the cleanup was sufficient and that no further accelerated action was 

needed. This four-step remediation process is illustrated in figure 11. 

50The comprehensive risk assessment, prepared under CERCLA and included in the draft 

remedial investigation and feasibility study, is an evaluation of the potential adverse impacts 

to human health and the environment that may exist from contaminated environmental 

media associated with site-related activities. See 40 C.F.R. § 300.430(a)(2). 
Page 43 GAO-06-352 Nuclear Cleanup of Rocky Flats

Figure 11: Four-Step Remediation Process for Individual Areas of Known or Suspected Contamination

Source: GAO.

Lab analysis

Lab analysis

1 Characterization

2 Remediation and in-process sampling

4 Clean fill and documentation 

3 Confirmation sampling

Closeout

Report and

Documentation

Samples in jars

Samples in jars
Page 44 GAO-06-352 Nuclear Cleanup of Rocky Flats

Although soil remediation was the primary cleanup focus at Rocky Flats, 

some groundwater required remediation for elevated levels of uranium, 

nitrates, and volatile organic compounds. Three passive systems were 

installed to treat the contaminants in the groundwater. At one former 

waste-drum storage area, for example, remediation of a carbon 

tetrachloride plume, along with other volatile organic compounds, involved 

excavating about 700 cubic yards of contaminated soils, treating them 

through thermal desorption,51 and then constructing a passive treatment 

system that uses iron filings to cleanse contaminants from the 

groundwater. Figure 12 shows the cleanup of a plume of carbon 

tetrachloride and other volatile organic compounds (VOC) that originated 

from a waste-drum storage area at Rocky Flats.

51Thermal desorption is a remedial technology that uses heat to physically separate (desorb) 

volatile organic compounds (VOC) from excavated soils. As the soils are subjected to high 

heat (e.g., 900 degrees Fahrenheit), the VOCs change into gas (vapors) and evaporate out of 

the soil. Essentially, the process involves collecting the vapors and further heating them (to 

as much as 1,800 degrees), which causes oxygen to react with the hydrogen and carbon in 

the VOC vapors, forming water and carbon dioxide. Hydrochloric acid is also formed from 

the chlorine in the VOCs. The carbon dioxide, water, and hydrochloric acid are then 

neutralized, forming water and salt. The treated soils are tested to ensure that they meet 

cleanup objectives; the soils can then be returned to the excavation area. 
Page 45 GAO-06-352 Nuclear Cleanup of Rocky Flats

Figure 12: Treatment of Contaminated Soils by Thermal Desorption; Installation of a Passive Treatment System at the Mound 

Storage Site, Rocky Flats

Because of the tendency of plutonium and americium particles to cling to 

soil, a primary concern among stakeholders was the potential off-site 

transport of soil contaminated with plutonium and americium via surface 

water. Contaminated soil washes into ditches and streams when it rains or 

snows. Accordingly, cleanup efforts have focused on the surface soils to 

reduce the source of radionuclides that could be susceptible to erosion and 

eventual transport off site via Walnut and Woman Creeks. Also, surface 

water is managed and monitored both on site—through a series of holding 

ponds—and at the points where it leaves the site. The ponds, which DOE 

constructed decades ago to retain any major release during operations, are 

used to ensure that water leaving the site meets all applicable water quality 

standards.52 DOE operates the final pond in each series as a “batch and 

release” system; that is, releases from those ponds occur only after water 

sampling has confirmed that the water meets water quality standards. The 

Source: DOE.

52The ponds were not constructed as a remedial action; rather, they are historical features of 

the site that were left in place and serve as insurance that contaminated surface water does 

not leave the site. Further, they serve as excellent flood control mechanisms. One of the 

objectives of the cleanup is for all surface water on site to meet Colorado water quality 

standards. Rocky Flats currently has a waiver—for nitrate, nitrite, and organic 

parameters—in one stream segment; that waiver will expire in 2009. 
Page 46 GAO-06-352 Nuclear Cleanup of Rocky Flats

efficacy of the accelerated cleanup actions taken to protect water quality 

will be evaluated in the remedial investigation/feasibility study. Figure 13 

shows the terminal pond in one series.

Figure 13: Terminal Pond in the B Series of Ponds

Draft Comprehensive Risk 

Assessment Concluded That 

Residual Risk Is Acceptable

The draft sitewide comprehensive risk assessment, one of several 

documents that will contribute to the final regulatory decision on the 

sufficiency of the Rocky Flats cleanup, concluded that the cumulative 

remaining risk to human health and the environment at Rocky Flats is 

acceptable. The draft comprehensive risk assessment—part of the larger 

remedial investigation and feasibility study—concluded that the 

cumulative risk to human health, after completion of the accelerated 

cleanup actions, falls at the more protective end of EPA’s “excess cancer

Source: GAO.
Page 47 GAO-06-352 Nuclear Cleanup of Rocky Flats

rate” risk range of between 1 in 10,000 and 1 in 1,000,000.53 This is the range 

that EPA considers to be adequately protective of human health.

As discussed previously, the Rocky Flats cleanup was designed so that any 

residual contamination after completion of the accelerated cleanup actions 

would be documented in closeout reports and subsequently analyzed in 

accordance with the exposure assumptions in the sitewide comprehensive 

risk assessment. The comprehensive risk assessment incorporated 

approximately 2 million data records and examined both human and 

ecological risk. Specific tasks included 

• identifying remaining contamination at Rocky Flats and determining 

whether it can adversely affect humans, animals, or plants;

• determining whether pathways exist whereby human or ecological 

receptors may come into contact with these contaminants, for example, 

through inhalation or ingestion of surface water;

• assessing the contaminants’ potential effects, including cancer, on the 

human and ecological receptors, where complete pathways exist; and

• calculating the potential risk to the human and ecological receptors, 

based on the pathways and the levels and toxicity of the contaminants.

The human health risk assessment calculated the risk that residual 

contaminants posed to wildlife refuge workers and visitors. The 

assessment identified five residual contaminants at the site that could 

affect human health, including plutonium located adjacent to the most 

contaminated precleanup areas of the site. The risk model assumed that 

the primary pathways for plutonium were either through inhalation or 

through skin contact. Based on assumptions about how frequently a 

wildlife refuge worker would be exposed to residual plutonium at the site, 

the model calculated an EPA acceptable risk of 1 in 500,000 excess cancers, 

and an even lesser risk for a refuge visitor. 

The ecological risk assessment estimated the risk that exposure to any 

residual contaminants would pose to species of concern, including the 

53For example, an excess cancer rate of 1 in 1,000,000 means that, given exposure to the 

residual contamination at Rocky Flats at the end of the cleanup, one would expect only one 

additional (excess) cancer than would normally be expected in a million people.
Page 48 GAO-06-352 Nuclear Cleanup of Rocky Flats

Preble’s Meadow jumping mouse, a protected species. After modeling risks 

to selected terrestrial and aquatic species, the risk assessment concluded 

that the residual contaminants at Rocky Flats do not represent a significant 

risk of adverse ecological effects to these species.

Nearly all respondents to our community group survey expressed 

confidence in the cleanup’s outcome. Specifically, 11 of 25 respondents said 

they were very or extremely confident that the cleanup will be protective of 

public health and the environment, and another 12 said they were 

somewhat confident.

Rocky Flats Cleanup Data 

Quality Procedures 

Comprehensive, but DOE’s 

Oversight Was Lacking

One of the most important aspects of the cleanup process was ensuring the 

validity of the data used to determine whether the site had been remediated 

to the agreed-upon levels. However, DOE did not complete the independent 

and management assessments required by the cleanup agreement to ensure 

that these data quality controls were working as intended. We identified 

four key data quality controls: establishing data quality objectives, using 

data quality parameters, verifying and validating data, and auditing 

laboratories that analyzed samples for Rocky Flats. Our review showed 

that the contractor generally followed these data quality controls and 

documented its compliance with them. Appendix IV contains additional 

information on the four data quality controls and our review of the 

contractor’s compliance with them.

Although the data quality controls the contractor had in place appeared to 

be robust and comprehensive, DOE did not conduct independent 

assessments to ensure that this was the case. Specifically, DOE did not 

conduct the management and independent assessments called for by the 

quality assurance project plan.54 A quality assurance project plan describes 

the planning, implementation, and assessment procedures for a particular 

project, as well as any specific quality assurance and quality control 

activities.55 These independent assessments, according to DOE’s 

Management Assessment and Independent Assessment Guide, are 

intended to measure the adequacy of work performance, among other 

things. Among the essential areas that should be assessed, according to the 

54The Rocky Flats Quality Assurance Project Plan is included in the Industrial Area and 

Buffer Zone Sampling and Analysis Plan.

55The required assessments are based on DOE Order 414.1A on Quality Assurance, which 

directs field managers to perform independent assessments of their contractors to evaluate 

the adequacy and implementation of their quality assurance plans.
Page 49 GAO-06-352 Nuclear Cleanup of Rocky Flats

guide, are data quality controls such as calibration controls, computer 

software controls, and environmental management systems.

DOE’s failure to conduct independent assessments is particularly troubling 

because of the importance of the cleanup and residual contamination data. 

These data were not only the basis for EPA’s and Colorado’s approvals of 

the accelerated cleanup actions, but also the foundation for EPA’s and 

Colorado’s pending decisions about the overall sufficiency of the site’s 

cleanup. Without independent assessments of the contractor’s data quality 

control measures, DOE had no assurance that the controls were working as 

intended. Also troubling was that EPA and Colorado—the regulatory 

agencies that jointly approved the site’s quality assurance project plan and 

are responsible for ensuring its implementation—were unfamiliar with 

these assessment requirements. When we discussed with EPA officials 

DOE’s failure to conduct independent or management assessments, they 

acknowledged that their confidence in the data quality would have been 

increased had DOE completed these assessments. A DOE official said he 

had no explanation for DOE’s not conducting the required assessments, 

other than that DOE officials had reviewed sampling and analysis plans, 

remediation plans, and closeout reports, and discussed with the contractor 

any data quality issues that arose.

Colorado officials said they reviewed the data and the controls provided by 

the contractor, which is the state’s standard procedure for determining the 

usability of data provided it, and that DOE’s failure to conduct assessments 

of the data does not affect the decisions made by the state. Colorado noted 

that it did not have significant issues with the data provided, and that any 

data issues were resolved using the consultative process, including 

bringing in experts to discuss and resolve specific issues. In addition, 

Colorado said, it performed routine independent sampling and analysis of 

water samples, as well as occasional building samples, which confirmed 

the data results provided to the state. Accordingly, although DOE 

assessments might have provided another check on data quality and 

adequacy, the lack of these assessments had little adverse effect on the 

quality or usability of the data and does not cloud the results or 

appropriateness of the site’s cleanup.

DOE’s Planned Cleanup 

Verification Not Completed

The second assessment of the cleanup’s sufficiency—DOE’s planned 

verification of the contractor’s remediation of radiologically contaminated 

soil—was inconsistent and not completed as planned. DOE policy 

currently requires radiological cleanup to be verified, but the policy is 
Page 50 GAO-06-352 Nuclear Cleanup of Rocky Flats

unclear about how and why verification should be done. DOE’s planned 

verification for the cleanup at Rocky Flats was twofold: First, DOE asked 

the contractor to develop a final scanning and sampling plan, and second, 

DOE asked its Oak Ridge Institute for Science and Education (ORISE) to 

develop a separate verification plan that included a review of contractorconducted scans for remaining radiological contamination.56 However, 

DOE chose not to complete several of the plan’s objectives, including part 

of ORISE’s review. A DOE official said they had decided that these 

activities would not provide sufficient additional information to justify 

their completion, but he had no documentation to support this decision. As 

a result, DOE lost the opportunity to independently verify the sufficiency of 

several aspects of the cleanup.

The respondents to our community group survey had mixed views on the 

degree to which the verification activities—in the aggregate—affected their 

confidence in the site’s cleanup. Of the 21 (of 25) who provided responses, 

13 said that the verification activities greatly or somewhat increased their 

confidence in the site’s cleanup. Another 8 said the verification activities 

had no effect or a negative effect on their confidence. The remaining four 

said they either did not know or had no basis to judge. 

DOE Policy Unclear on 

Application and Purpose of 

Verification

Although DOE has a general policy on radiological cleanup verification, its 

guidance is unclear on how the policy applies and what the verification 

goals are. In January 2001, the Secretary of Energy issued a memorandum 

that contained guidance on the release of radiological property and 

directed DOE field offices to “establish independent verification programs” 

that “should be commensurate with the potential for contamination, as well 

as the complexity and hazard.”57 Additional DOE guidance on verification is 

found in other documents, including draft guidance called “Control and 

Release of Property with Residual Radioactive Material;” this document 

implements guidance for DOE Order 5400.5, which includes requirements

56ORISE is a DOE facility operated by Oak Ridge Associated Universities, a multiuniversity, 

nonprofit consortium established in 1946. Over the past 2 decades, ORISE has performed 

radiological surveys and environmental assessments at sites contaminated with hazardous 

or radioactive materials. ORISE staff include health physicists, environmental specialists, 

radiochemists, and analytical chemists. 

57Memorandum 2001-001288, January 19, 2001, Managing the Release of Surplus and Scrap 

Materials.
Page 51 GAO-06-352 Nuclear Cleanup of Rocky Flats

for the release of radiologically contaminated property.58 The draft 

guidance, which was approved for interim use, includes a section on 

verification that states that “the DOE organization responsible for the 

release of property should verify or provide for independent verification of 

the radiological condition of the property before release.” However, the 

draft neither contains specific guidance about verification techniques nor 

specifies the goals of verification. Accordingly, it was little help to Rocky 

Flats officials and may have contributed to the inconsistent 

implementation of the verification plan. 

Lacking clear guidance, DOE’s project manager at Rocky Flats said he took 

a common sense approach that, in his view, fulfills the intent of DOE’s 

policy by cleaning the site up through the CERCLA and RCRA process. 

That is, he believes that the regulatory agencies’ approvals of the 

radiological cleanup actions at the site constitute independent verification. 

However, the official acknowledged that there is room for interpretation 

and disagreement on this issue. Another area of confusion was what the 

goals of the independent verification should be. At Rocky Flats, DOE 

officials commissioned a cleanup verification plan that used a different 

methodology than the one used to implement the cleanup. The result was 

that while the cleanup verification confirmed that an area had met the 

standards of the cleanup agreement, it also identified “hot spots” that 

caused alarm among the public at the end of the 10-year cleanup. The 

Rocky Flats manager stated that clear guidance on independent 

verification would have been helpful, especially as to how it related to 

CERCLA cleanups. 

DOE Did Not Fully Implement Its 

Planned Verification or Explain 

Its Reasons for Not Doing So 

Although DOE agreed to ORISE’s final verification plan, DOE did not fully 

implement it and did not offer a public explanation for its decision. 

Specifically, ORISE never completed two of its objectives—an assessment 

of the aerial and ground-based scanning and an assessment of the 

contractor’s investigations of the results of the aerial and targeted groundbased scans. According to a DOE official, DOE decided in mid-September 

2005 that it needed to re-evaluate the need for ORISE’s work. DOE decided 

that because the contractor’s aerial survey had failed to find any anomalies, 

ORISE’s remaining work was unnecessary. DOE remained unsure about the 

final outcome of the ground-based scanning but still decided not to ask 

ORISE to complete the remaining objectives. A DOE official explained that 

58Draft DOE G 441.1-XX, Control and Release of Property with Residual Radioactive 

Material, for use with DOE 5400.5, Radiation Protection of the Public and the Environment.
Page 52 GAO-06-352 Nuclear Cleanup of Rocky Flats

completing the work was not warranted, given the results of the aerial and 

ground-based scanning. According to an ORISE official, DOE’s Rocky Flats 

Project Office notified ORISE on November 11, 2005, that it would not be 

asked to complete the remaining objectives. Additional information on 

DOE’s independent verification is contained in appendix IV.

Independent Consultants 

and Other Federal Agencies 

Conducted Additional 

Cleanup Reviews, and Some 

Influenced DOE’s Final 

Cleanup Strategy

Reviews conducted by independent consultants and other federal agencies 

commented on cleanup actions, and some reviews influenced the final 

cleanup strategy, thereby providing additional assurance to DOE and the 

regulatory agencies that their remedial decisions were correct. 

Independent consultants, hired by local stakeholder organizations, 

commented on several cleanup remedies, including surface and 

groundwater cleanup actions and landfill remediation. Some of these 

influenced the final cleanup; for example, a study on surface water 

management called for a specific pond discharge strategy, with which DOE 

concurred. On the other hand, DOE did not incorporate all comments and 

suggestions made by independent contractors, such as recommendations 

on how to close a landfill. Other federal agencies, including the Agency for 

Toxic Substances and Disease Registry and FWS, also conducted studies, 

one of which concluded that no health hazard existed for surrounding 

communities. Another study is still under way.

Several Recommendations from 

Independent Consultants Were 

Incorporated into Site Remedies, 

but Disagreements and Concerns 

Remain

Independent consultants, hired by local communities or through the Rocky 

Flats Coalition of Local Governments, conducted technical reviews of 

cleanup actions and provided recommendations, some of which DOE 

incorporated into its cleanup plan. The Rocky Flats Coalition of Local 

Governments sponsored these independent reviews to assure the local 

governments and the public that the cleanup would meet the regulatory 

guidelines. Overall, members of the Coalition initiated four technical 

reviews, which examined groundwater, surface water and pond 

management, and landfill remediation. The Coalition hired a consultant to 

comment on DOE’s independent verification process.

One instance in which DOE incorporated a recommendation from a 

consultant involved surface water management. During Rocky Flats’ 

operational days, a series of ponds was constructed as part of a surface 

water management system to ensure that no contaminated surface water
Page 53 GAO-06-352 Nuclear Cleanup of Rocky Flats

left the site.59 As a safeguard to ensure that all water leaving the site meets 

the state’s water quality standards, the water is tested prior to its release. 

An independent consultant’s study raised the concern that DOE was 

allowing one of the terminal ponds to fill to a high level, thereby 

diminishing its ability to store large quantities of water should a heavy 

rainfall occur. Such an event could result in water being released without 

being tested. The independent review recommended that DOE maintain the 

pond at a lower capacity as a precautionary strategy, and DOE concurred. 

Another example was DOE’s concurrence with the Coalition consultant’s 

recommendation that ORISE include in its verification plan a 100 percent 

scan of certain areas to detect any residual contamination that might 

exceed established cleanup levels. 

However, several of the independent consultants’ reviews identified points 

of contention with DOE’s ultimate cleanup approach. One area of 

contention involved the landfill that had been used at Rocky Flats in the 

1950s and 1960s. DOE’s characterization of the landfill suggested that 

uranium and volatile organic compounds were present.60 DOE and the 

regulatory agencies subsequently agreed to implement an accelerated 

cleanup action that included buttressing the landfill to prevent the waste 

from slumping into Woman Creek; regrading parts of the landfill, which is 

located on a hillside, to prevent erosion; placing 2 feet of soil atop the 

surface to isolate the contaminants; installing storm water management 

berms to divert surface flows to perimeter channels; and seeding the entire 

cover, buttress, and channels with native grass species. An independent 

review disagreed with several aspects of this accelerated action, including 

that it did not include a biointrusion layer; these layers inhibit the ability of 

burrowing animals like mice and prairie dogs to bring contaminants up to 

the surface, where people at the site might be exposed to them. DOE and 

Colorado felt that a biointrusion layer was unnecessary because the 

accelerated cleanup action met the legal requirements for landfill closure, 

and the observed environmental conditions indicated that the landfill 

posed only a minimal risk. EPA added that the issue of biointrusion was 

examined during the remedy’s design, with the conclusion that the steep 

slope (18 percent), combined with the native grass cover, would not be 

attractive habitat for burrowing animals. In the end, a biointrusion layer 

was not included in the landfill cover. Monitoring of Woman Creek and 

59These ponds were not constructed as part of the CERCLA remedy.

60According to the contractor, four uranium hot spots were removed in July 2004.
Page 54 GAO-06-352 Nuclear Cleanup of Rocky Flats

wells will continue at locations both upgradient and downgradient of the 

landfill to ensure that no contaminants are escaping from the landfill.

Other Federal Reviews 

Concluded Minimal Risk or Are 

Still Under Way

The Agency for Toxic Substances and Disease Registry (ATSDR), part of 

the Department of Health and Human Services, conducted a public health 

assessment that concluded that Rocky Flats poses no health hazard.61 

Specifically, ATSDR concluded that the Rocky Flats data present a 

consistent picture that local residents’ current and future exposures to 

contaminants from Rocky Flats are below levels associated with adverse 

health effects. ATSDR officials conducted their own data reliability tests on 

the site’s data and concluded that the data were adequate to make public 

health decisions. The officials then assessed the contaminant pathways at 

Rocky Flats, including soil, air, and surface water and groundwater and 

concluded that environmental contamination at Rocky Flats posed no 

apparent public health hazard to surrounding communities. (However, 

ATSDR did not evaluate the health implications for people within the 

boundaries of Rocky Flats.) ATSDR offered several recommendations on 

how to ensure that the site’s contamination will not pose a future risk to 

residents of surrounding communities, including continued monitoring of 

surface water along the eastern boundary of the site and groundwater 

wells. DOE is not required to officially respond to the ATSDR 

recommendations, but reported that the recommendations had already 

been included, or were under discussion with the regulatory agencies for 

inclusion, in the postclosure monitoring and maintenance plans.

Additionally, as discussed previously, the 5-year reviews required by 

CERCLA will continue to compile information about whether remedies at 

the site continue to fully protect human health and the environment. The 

first 5-year review, completed in 2002,62 included areas of the site for which 

final decision documents (i.e., corrective action decisions/records of 

decision) had been completed, as well as areas where accelerated cleanup 

actions had been completed as of September 30, 2001. At that time, final 

61ATSDR was established by CERCLA in 1980—CERCLA § 104(i); 42 U.S.C. § 9604—and, 

since 1986, has been required to conduct public health assessments of sites on CERCLA’s 

National Priorities List— CERCLA § 104(i)(6); 42 U.S.C. § 9604(i)(6). In conducting a public 

health assessment, ATSDR officials review environmental data and assess pathways, or how 

individuals might come into contact with the contaminants, and whether such contact 

would result in any health effects.

62Department of Energy, Rocky Flats Field Office, First Five-Year Review Report for Rocky 

Flats Environmental Technology Site, Golden, Colorado (Golden, Colo., July 2002).
Page 55 GAO-06-352 Nuclear Cleanup of Rocky Flats

decision documents had been completed for two areas (the 881 hillside and 

the off-site areas), and accelerated cleanup actions had been completed at 

several areas. Among the completed accelerated actions were the removal 

and, as necessary, treatment of contaminated debris and soil at several 

trenches; the installation of three groundwater treatment systems; the 

removal of contaminated sludge from solar evaporation ponds; and 

emptying and treating the contents of six underground storage tanks. The 

review concluded that the remedies for these two areas were protective 

and that the accelerated actions had addressed immediate hazards and 

were generally functioning as intended. The review of the off-site areas, 

though not required under EPA guidance,63 was nonetheless conducted 

because of the substantial public interest in those areas. The off-site areas 

did not have a defined boundary, but rather referred to off-site 

contamination emanating from Rocky Flats in general, including surface 

contamination of lands to the east of the site, along with the Great Western 

Reservoir, Standley Lake, and Mower Reservoir. The review concluded that 

all calculated excess cancer risks in the entire unit were well within or 

below EPA’s acceptable risk range of 1 in 10,000 to 1 in 1,000,000. 

Also, FWS sampled areas at Rocky Flats that are likely to become part of 

the future wildlife refuge. Prior to any transfer of land management 

authority to FWS, FWS typically surveys the property to identify any 

potential hazardous substances that pose a threat to fish and wildlife. In 

May 2006, consistent with its survey plan, FWS took 45 soil samples 

(including four duplicate samples), mostly along proposed trails as 

indicated in the Comprehensive Conservation Plan for the refuge. The 

samples will be examined for a range of potential contaminants, including 

metals, radionuclides, organics, and polychlorinated biphenyls, commonly 

referred to as PCBs. FWS took an additional 12 vegetation samples 

(including one duplicate sample), principally to ensure that any future 

prescribed burns will be safe. An FWS official said that the results of the 

laboratory analyses of the samples are due in early July, at an estimated 

cost of $70,000. If the results identify contaminants that concern them, 

FWS officials will notify DOE, EPA, and Colorado; the agencies will then 

determine what steps would need to be taken. 

63EPA’s 2001 Comprehensive Five-Year Review Guidance requires 5-year reviews of remedial 

actions resulting in any hazardous substances, pollutants, or contaminants remaining above 

levels that allow for unlimited use and unrestricted exposure. The contaminants remaining 

in the off-site areas were at low enough levels to allow unlimited use and unrestricted 

exposure.
Page 56 GAO-06-352 Nuclear Cleanup of Rocky Flats

DOE Implemented 

Some Lessons Learned 

at Rocky Flats but Has 

No Requirement to 

Ensure That Lessons 

Learned Are 

Implemented at Other 

Sites

Although DOE has identified and implemented at other cleanup sites some 

lessons learned at Rocky Flats, DOE does not require applicable lessons 

learned at one cleanup site to be implemented at others. The Rocky Flats 

project offers many lessons about innovative techniques, risk- and costsharing contract provisions, accelerated cleanup processes, involvement of 

community groups, oversight of contractor controls over data quality, and 

cleanup verification processes. However, DOE has not developed a system 

to ensure that all lessons are captured and implemented as appropriate at 

other DOE sites. As a result, DOE may be missing valuable time- and costsaving opportunities at other sites that are planning or undergoing cleanup. 

DOE Identified Lessons 

from Rocky Flats and 

Assessed Their Applicability 

to Other Sites

DOE has gathered and disseminated to some other DOE sites numerous 

lessons learned at Rocky Flats. These lessons included the following: 

• Clearly define government oversight of the contractor, and limit the 

number of DOE personnel providing direction.

• Conduct external reviews of the project baselines to build credibility 

and provide objective recommendations for project improvement.

• Use employee incentives to reward high-performing individuals. 

• Use a flexible project management approach that allows the contractor 

to complete the project in the safest and most cost-effective manner. 

• Establish a clear “end state” vision and risk-based cleanup defined in 

conjunction with specific future land/site use. 

• Develop and use an integrated project baseline schedule and budget.

• Use government-furnished services and items to integrate and manage 

the delivery of items not within the contractor’s control. 

• Implement new technology that significantly accelerates the schedule 

and reduces total costs, such as techniques for reducing the number of 

radioactive waste shipments off site for disposal. 

In October 2002, DOE authorized a corporate review team to determine the 

effectiveness of DOE cleanup efforts. In 2003, the team reviewed work 
Page 57 GAO-06-352 Nuclear Cleanup of Rocky Flats

activities, management processes, and contract administration practices at 

selected sites, and used a checklist of more than 50 lessons learned at 

Rocky Flats to assess their applicability and potential benefits to each site. 

The review team issued nine reports with findings and recommendations. 

With the exception of one report, which was part of the preliminary review 

effort, each report also included the team’s determination of whether the 

lessons on the checklist applied to the sites, and the progress the sites had 

made toward implementing applicable lessons learned.

DOE Lacks a System for 

Ensuring Continued 

Collection and 

Implementation of Lessons 

Learned at Its Cleanup Sites

During 2004 and 2005, DOE’s Office of Performance Assessment conducted 

follow-up reviews of many of the sites the corporate review team had 

reviewed earlier. These follow-up reviews, however, did not assess whether 

the sites had implemented the lessons learned from Rocky Flats. According 

to the DOE official responsible for tracking the status of these reviews, 

DOE does not require sites to implement applicable lessons from Rocky 

Flats (or from other cleanup sites). Instead, he said, each site is responsible 

for tracking its implementation of these lessons. Although he said he 

believes the sites are taking steps to implement those lessons and are 

continuing to improve their systems for managing cleanup, he had no 

documentation to support his conclusions. 

DOE’s Office of Performance Assessment reviewed lessons learned at 

Rocky Flats in the March 2004 and June 2005 Rocky Flats baseline 

performance review reports. In the 2004 report, DOE noted that valuable 

information and processes from Rocky Flats should be available to other 

sites that are beginning the cleanup process. The report noted that DOE’s 

Rocky Flats office had begun a program to archive project cost information 

that could be used to prepare cost estimates for future contracts at other 

sites, and recommended that the office develop a database that identifies 

the number of personnel and time durations required to perform specific 

cleanup tasks. According to the Rocky Flats DOE manager, the costarchiving program continued to provide periodic information updates, and 

provided the final download of project data to DOE’s Office of Engineering 

and Construction Management in December 2005. The 2005 Rocky Flats 

baseline performance review report included 30 additional lessons learned 

at Rocky Flats. Among these were improved contract language that 

established a close working relationship between DOE and the contractor, 

made measurement of progress easier, and reduced the need for contract 

changes; improved safety processes at the site; consolidated procurement 

functions; and streamlined methods for handling and shipping radioactive 

waste and disposing of excess property. One of the lessons identified in the 
Page 58 GAO-06-352 Nuclear Cleanup of Rocky Flats

2005 report actually resulted from a request from another cleanup site. A 

DOE official in the Office of Performance Assessment told us that officials 

at DOE’s Office of Environmental Management visited Rocky Flats in 2005 

to document lessons learned from the demolition of a plutoniumprocessing building. They visited Rocky Flats at the request of DOE 

officials at the Savannah River site who were designing a similar facility 

and sought information from the Rocky Flats demolition that might 

improve the design of their building. 

Although DOE has a database of environmental safety and health lessons, it 

does not have a database of broader lessons learned across the DOE 

complex. DOE has a nationwide database managed by the Society for 

Effective Lessons Learned Sharing, a volunteer DOE organization 

dedicated to identifying, sharing, and using lessons learned in order to 

improve the safety, efficiency, and effectiveness of DOE work processes. 

These lessons focus primarily on individual safety incidents and how to 

prevent their recurrence. However, the database generally does not capture 

lessons dealing with broader issues such as contract management, pricing, 

and working with regulatory agencies. Consequently, DOE may not be 

maximizing the use of valuable information that could save time and 

money. 

DOE’s Office of Engineering and Construction Management commissioned 

a study in the fall of 2003 to correlate components of project performance 

with project success, and identify best practices to improve DOE project 

performance. The July 2004 report on the study’s findings identified many 

factors that influenced the success of DOE projects, including the 

importance of an effective lessons learned program. The report did not 

examine the effectiveness of DOE’s lessons learned programs, but it noted 

examples at DOE where lessons were effectively transferred from one 

project to another. It concluded that 

“DOE Headquarters has a responsibility to assure that such lessons are being transferred 

across sites with similar facilities. Sharing lessons learned needs aggressive attention; 

without it valuable savings are lost and frustrations compounded. Lessons learned are 

useful for mitigating risk and providing training material for project directors/managers.64

64Civil Engineering Research Foundation, Independent Research Assessment of Project 

Management Factors Affecting Department of Energy Project Success (Reston, Va., July 12, 

2004).
Page 59 GAO-06-352 Nuclear Cleanup of Rocky Flats

The report also recommended that DOE proactively encourage the sharing 

of lessons learned. According to a DOE headquarters official, a national 

database of lessons learned from closure sites would allow DOE to 

proactively share experiences that would benefit future closure operations.

Rocky Flats Offers 

Additional Lessons That 

May Be Applicable to Other 

DOE Sites

During our review, we gathered additional lessons learned at Rocky Flats 

that could be useful for other DOE sites. These lessons include the 

following:

• Safety is a priority. According to DOE officials, this lesson was 

reinforced throughout Rocky Flats’ cleanup. Early in the cleanup, DOE 

officials recognized that a significant investment in hazard 

identification, safety planning, and safety implementation (i.e., the 

integrated safety management system) during the actual work would 

ensure that the work was performed without unacceptable risks or 

unnecessary delays. Later, DOE officials said they came to understand 

that this focus on safety not only helped work progress, but also 

facilitated efficiency by building trust and engaging the workforce. 

Safety was both consistent with, and essential to, effective project 

execution. 

• Performance-based contract incentives improve results. 

According to DOE officials, the first contract they had with Kaiser-Hill 

demonstrated that attaching incentives to clearly defined performance 

measures vastly improved actual results. The 2000 contract took the 

concept to the next level, providing large incentives to the contractor 

and the workers to safely and compliantly complete the cleanup within 

the target schedule and cost. The additional incentives for schedule and 

cost savings resulted in closure more than a year ahead of schedule and 

$530 million under budget. However, as previously noted, such 

incentives are not always this successful, and the financial incentive 

offered at Rocky Flats was only one of many factors contributing to the 

cleanup’s early completion.

• Take a consultative approach to cleanup decisions. As previously 

discussed, the collaborative process was essential to the cleanup’s early 

completion. According to DOE officials, the cleanup was successful 

because all of the stakeholders were engaged in the process and 

supportive of the ultimate goal. The input of numerous key figures, 

including members of Congress, senior DOE managers, state and local 

elected officials, and officials of federal and state regulatory agencies, 
Page 60 GAO-06-352 Nuclear Cleanup of Rocky Flats

was actively solicited and ultimately met with the convergence of the 

cleanup agreement, the contract, and the desired end state. DOE 

officials said they communicated openly and often with stakeholders to 

seek the best solutions, and they came to value input from formerly 

dogmatic opponents. Moreover, Colorado, EPA, DOE, and the 

contractor worked closely together on cleanup decisions from the 

beginning through the end. As cleanup proceeded on an area, Colorado 

had access to meetings and detailed information about the cleanup. In 

the event that Colorado or EPA considered a particular activity to be 

unsafe, the Rocky Flats cleanup agreement granted them the authority 

to stop work.

• Don’t let unresolved issues delay progress. DOE officials said that if 

they had focused on what they could not do or delayed work until all 

questions were answered, the project would not have been completed 

and the target completion date would probably still be in question. 

Colorado officials emphasized, however, that this does not mean that 

work progressed without the appropriate approvals from Colorado and 

EPA. It is Colorado’s understanding that the consultative process, with 

all of its oversight and meetings to discuss activities and issues, ensured 

that all issues were addressed and resolved in a timely manner before 

activities occurred. 

• Obtain stable project funding. As discussed earlier, consistent 

project funding was a key factor in the cleanup’s early completion. 

According to DOE and EPA officials, congressional and departmental 

commitment to stable funding over the life of the project aided 

tremendously in project planning and execution. Also, the stable 

funding helped in regulatory interactions and credibility with the 

general public.

• Involve the future site manager in remedial decisions. According 

to FWS, when a former DOE site is considered for conversion to a 

wildlife refuge, it is “vastly preferable” for FWS to be involved early in 

the cleanup process and have a decision-making role. DOE officials 

agreed and said they have actively involved FWS since passage of the 

Refuge Act. According to DOE officials, FWS substantially influenced 

cleanup decisions, even in areas of the site that will not become part of 

the future refuge. For example, they said, FWS’s input effected a major 

change in the cover design for the present landfill. Additionally, FWS 

influenced the composition of the revegetation seed mixes sitewide and 

the methods of protecting sensitive habitat and endangered species. But 
Page 61 GAO-06-352 Nuclear Cleanup of Rocky Flats

DOE did not incorporate all of FWS’s suggestions, such as 

characterizing and disposing of waste in the original landfill, 

incorporating barriers around landfills to discourage intrusion by 

burrowing animals, and using irrigation and soil amendment to enhance 

the success of seeded native vegetation. According to DOE officials, the 

two agencies’ different perspectives on cleanup methods highlight the 

difficulty of coordination between two federal agencies that have 

different missions. These difficulties can persist even when staff of the 

two agencies are collocated and interact daily, as was the case at Rocky 

Flats. In retrospect, DOE officials said, it would have been better to 

recognize that difficulty early and obtain an executive–level consensus 

on the vision for the outcome. 

• Be aware of potential beryllium contamination. According to a 

senior contractor official, beryllium was “ubiquitous” at the site; it was 

found even in containers of metals and oxides. In terms of worker 

safety, beryllium was more of a predemolition challenge than other 

contaminants because there is no effective way to monitor beryllium on 

a real-time basis.

• Question accepted technologies. The contractor was able to save 

substantial money and time at Rocky Flats by questioning the usual 

disposal and remediation processes. For example, the accepted practice 

was that a glovebox or any part of one was, by definition, transuranic 

waste. However, the contractor found a way to decontaminate 

gloveboxes and dispose of them much more easily and less expensively 

as low-level waste. According to a senior contractor official, this 

particular technical lesson learned at Rocky Flats may be applicable to 

DOE’s cleanup work at the Hanford site.

• Contain contaminated water. According to an official with the 

Colorado Department of Public Health and Environment, lessons 

learned at Rocky Flats included the importance of ensuring that there 

are no underground drainage systems or conduits when large amounts 

of water are used during a cleanup. This lesson stemmed from an 

unfortunate experience in the cleanup of building 771, when water used 

in decontamination efforts seeped into underground conduits that had 

not been adequately plugged. The water flushed contaminants through 

the conduits, resulting in elevated levels of americium in one series of 

ponds at the site. This turned out to be an expensive lesson, as the 

contractor had to bring in equipment and treat about 26 million gallons 

of americium-contaminated water.
Page 62 GAO-06-352 Nuclear Cleanup of Rocky Flats

Although DOE captured and implemented at other sites some of the 

lessons it learned at Rocky Flats, others risk being lost. For example, 

contractor and DOE officials said that at Rocky Flats, and at other cleanup 

sites, many lessons that could be gleaned from records and data will be lost 

if not recorded, summarized, or otherwise captured and shared. According 

to the Rocky Flats manager, an effort termed the “Legacy Project” was 

begun in 2001 to start collecting the project knowledge and lessons before 

the institutional memory was lost. This effort continued intermittently 

through the summer of 2005, drawing upon record documents, working 

papers, and personal experience. Also, DOE Rocky Flats officials said that 

officials of DOE’s Legacy Management office in Grand Junction, Colorado, 

had shared with them lessons learned from the Grand Junction office’s 

experience working with the long-term management of sites formerly 

contaminated by uranium mill tailings. According to the Rocky Flats 

manager, these lessons will be brought to Rocky Flats as Legacy 

Management executes its responsibilities for site management and 

maintenance. As the mission scope of Legacy Management expands, it will 

continue to carry experience from Rocky Flats to other sites that are 

transferred to it for long-term care. Also, although DOE officials told us in 

March 2005 that they were planning a workshop on lessons learned at 

Rocky Flats in decontamination and demolition, that workshop has not 

been held. According to the Rocky Flats manager, several technical assist 

visits occurred with contractor and DOE personnel from sites in Idaho, 

Ohio, and Washington. These visits were believed to be more focused and 

efficient than a workshop format. At this time, a general workshop is not 

planned; however, technical assist and assessment visits to facilitate the 

sharing of lessons are continuing. 

DOE officials at Rocky Flats have drafted the Rocky Flats Closure Legacy 

report, a lengthy document that captures the 4-year effort of the Legacy 

Project. It is currently at DOE headquarters for review and comment and is 

expected to be released in June 2006. 

Conclusions Strong DOE oversight of data quality is important because accurate and 

complete data are paramount to DOE’s, EPA’s, and Colorado’s decisions 

about the sufficiency of the Rocky Flats cleanup. At Rocky Flats, DOE 

placed undue reliance on the contractor to have appropriate data quality 

controls, and did not complete the required management and independent 

assessments of the data’s quality. Our review showed that the contractor at 

Rocky Flats appeared to have comprehensive data quality controls, but this 

does not negate DOE’s responsibility to independently monitor and assess 
Page 63 GAO-06-352 Nuclear Cleanup of Rocky Flats

those controls throughout the cleanup. Also, although DOE policies call for 

independent verification of cleanup results, the applicability of the policies 

to cleanups conducted under CERCLA or RCRA is unclear. Lacking clear 

and specific guidance on cleanup verification, DOE officials at Rocky Flats 

undertook what they thought was a reasonable approach. However, DOE 

did not complete all of the cleanup verification activities it had planned; it 

also did not publicly explain its rationale for not doing so. As a result, DOE 

lost a valuable opportunity to increase public awareness of, and confidence 

in, the verification results. Ironically, although the verification activities 

were undertaken to increase public confidence in the cleanup, the results 

sparked additional questions from the public. Finally, although DOE has 

implemented at other cleanup sites some of the lessons learned at Rocky 

Flats, DOE does not require that lessons learned at one site be 

implemented, where applicable, at other sites. As a result, DOE stands to 

lose the benefits that such lessons have to offer. 

Recommendations for 

Executive Action

To improve DOE’s oversight of cleanup activities, its conduct of cleanup 

verification activities, and its monitoring of lessons learned at DOE cleanup 

sites, we recommend that the Secretary of Energy take the following three 

actions:

• Ensure that DOE independently assesses contractors’ controls over data 

quality.

• Clarify guidance on whether and how to conduct cleanup verification 

activities.

• Assess the costs and benefits of developing a method to track the 

lessons learned from cleanup activities at DOE sites across the nation, 

including methods for determining whether lessons are being applied at 

applicable locations. 

Agency Comments and 

Our Evaluation

We provided a draft of this report to DOE, Interior, EPA, Colorado, and 

Kaiser-Hill for their review and comment. DOE, Interior, Colorado, and 

Kaiser-Hill provided written comments (see apps. V, VI, VII, and VIII, 

respectively). EPA did not provide official written comments but did 

provide editorial and technical suggestions, as did the other agencies, that 

we incorporated, as appropriate.
Page 64 GAO-06-352 Nuclear Cleanup of Rocky Flats

DOE commented that it found the report to be comprehensive, generally 

thorough, clear, and well structured. DOE agreed that a robust and 

effective lessons learned program would be beneficial and said it intends to 

follow through and revitalize such a program within DOE’s Office of 

Environmental Management. DOE reiterated the importance of teamwork 

and agency support in accelerating the cleanup of the Rocky Flats site, 

noting that the regulatory agencies, community groups, and local 

government organizations worked tirelessly along with DOE and 

contractor organizations to overcome obstacles. DOE also emphasized that 

the high priority given the Rocky Flats cleanup within the DOE complex 

and at the congressional level, together with the provision of level annual 

funding, was critical to the success of the project.

DOE did not agree or disagree with our recommendations that it ensure 

independent assessments of data quality and clarify its guidance on 

cleanup verification. In its specific comments, however, DOE noted that 

there is direction and guidance on independent verification and other 

independent assessments, and referenced several documents that provide 

such guidance. We were aware of these documents and had discussed 

several of them with DOE officials at the Rocky Flats Project Office, who 

said the documents were not helpful in guiding their decisions about 

whether to conduct verification activities or how to ensure compatibility 

between available verification strategies and the cleanup strategies 

undertaken at the site.

In its specific comments, DOE also stated that there is an additional 

regulatory step DOE must take before releasing the site to the Department 

of the Interior, pursuant to the requirements of DOE Order 5400.5 

governing the release of real property with residual radioactive material. 

DOE suggested that we reference this regulatory requirement in the report 

section dealing with additional steps to be taken. We did not adopt this 

suggestion because our report’s discussion of regulatory steps focused on 

those that remain to be taken by EPA and Colorado, the regulatory 

agencies at the site. We do, however, reference DOE Order 5400.5 and its 

draft implementing guidance in our discussion of cleanup verification 

activities. We noted that the draft implementing guidance neither contains 

specific guidance about verification techniques nor specifies the goals of 

verification and, consequently, was little help to Rocky Flats officials and 

may have contributed to the inconsistent implementation of the 

verification plan.
Page 65 GAO-06-352 Nuclear Cleanup of Rocky Flats

The Department of the Interior generally agreed with the information that 

pertains to the Fish and Wildlife Service. The department said that at this 

point, it is unable to determine when Rocky Flats will be open to the public, 

due to the uncertainty of the completion of the transfer of the site. We 

incorporated the department’s suggestion that we focus on the transfer of 

administrative jurisdiction from DOE to the department rather than 

focusing on when the public may access the Rocky Flats National Wildlife 

Refuge. Also, as the department suggested, we clarified the discussions of 

actions EPA must take to facilitate the transfer and the acquisition of 

privately owned mineral rights.

Colorado commented that the report provides an appropriate recognition 

of issues and actions occurring during the remedial activities at Rocky 

Flats. Colorado emphasized that it has been an integral participant in 

Rocky Flats’ cleanup and closure; it provided continual in-depth regulatory 

oversight of the investigative and remedial activities for both building 

decontamination and demolition and environmental restoration. Colorado 

cited the dedicated efforts of its staff, along with the consultative process, 

as expediting completion of an accelerated cleanup that resulted in 

significant cost savings for DOE and for U.S. taxpayers.

Kaiser-Hill commented that the report was thorough, well-written, and 

accurate in its description of Kaiser-Hill’s role in the cleanup of Rocky 

Flats. Kaiser-Hill agreed with the report’s focus on the contribution of 

Kaiser-Hill’s workforce, and stated that the incentive contract played an 

important role in the success of the cleanup project. Kaiser-Hill noted that 

the success of the project was also due to the cooperative decision-making 

process that evolved among DOE, Kaiser-Hill, EPA, Colorado, and local 

communities, aided by a firm political commitment to accelerate the 

cleanup.

Kaiser-Hill said it believes that the report’s calculation of the total cost of 

the cleanup is misleading because it includes tangential costs such as 

health and pension benefits, which alone add about $1 billion to the cost 

reported. Kaiser-Hill noted that a significant portion of these benefit costs 

were accrued by previous contractors. Kaiser-Hill acknowledged, however, 

that such costs represent financial obligations to the taxpayer. For our 

purposes, inclusion of these costs was necessary to report total costs of the 

cleanup since 1995, including long-term costs. 

Additionally, Kaiser-Hill commented that because the final disposition of 

trench T-7 (the fourth individual cleanup project we reviewed in depth) 
Page 66 GAO-06-352 Nuclear Cleanup of Rocky Flats

required only minimal cleanup, it was completed through the standard “no 

further accelerated action” justification process. According to the 

contractor, the justification documentation for such areas (those requiring 

minimal cleanup) should include information on data quality and adequacy, 

but not at the same level of detail as was required for other cleanup areas. 

We recognize that areas closed out through the “no further accelerated 

action” process may not necessitate the same level of data quality 

documentation as other areas. Nevertheless, the Rocky Flats Cleanup 

Agreement requires that the justification documentation for “no further 

accelerated action” areas include information on data quality and usability. 

The documentation we reviewed for trench T-7 did not include such 

information.

We are sending copies of this report to the Secretaries of Energy and the 

Interior, the Administrator of the Environmental Protection Agency, the 

Executive Director of the Colorado Department of Public Health and 

Environment, the President and Chief Executive Officer of Kaiser-Hill 

Company, interested congressional committees, and other interested 

parties. We will also make copies available to others upon request. In 

addition, the report will be available at no charge on the GAO Web site at 

http://www.gao.gov.

If you or your staff have any questions about this report, please contact me 

at (202) 512-3841 or aloisee@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix IX.

Gene Aloise

Director, Natural Resources

and Environment
Page 67 GAO-06-352 Nuclear Cleanup of Rocky Flats

Appendix I

Objectives, Scope, and Methodology AAppenednxidexiIs

Our review objectives were to determine the (1) factors that contributed to 

the early completion of the physical cleanup at Rocky Flats; (2) work 

remaining as well as total project costs, including long-term costs; (3) 

measures in place to assess whether the cleanup achieved a level of 

protection of public health and environment consistent with the Rocky 

Flats Cleanup Agreement; and (4) lessons the Rocky Flats project may hold 

for other Department of Energy (DOE) cleanup projects.

In conducting our work, we visited the Rocky Flats site and reviewed 

documents and data prepared by DOE, the Environmental Protection 

Agency (EPA), the Colorado Department of Public Health and Environment 

(Colorado), the Department of the Interior’s Fish and Wildlife Service 

(FWS), the contractor, and various scientific organizations. We also 

interviewed officials of these entities.

To determine the factors that contributed to the physical cleanup’s early 

completion, we interviewed DOE, EPA, Colorado, and contractor officials 

and reviewed agency and contractor documents on cleanup 

accomplishments and techniques, project activity reports, and 

decontamination and demolition accomplishments. Information on 

innovative cleanup techniques is presented in appendix III. 

To determine the work remaining as well as total project costs, including 

long-term costs, we reviewed documents and data prepared by DOE, EPA, 

Colorado, FWS, and the contractor, and interviewed officials of these 

entities. We reviewed documents and discussed issues pertaining to the 

cleanup requirements of the Comprehensive Environmental Response, 

Compensation, and Liability Act of 1980, as amended (CERCLA), and the 

Resource Conservation and Recovery Act of 1976, as amended (RCRA). We 

also reviewed documents and discussed issues pertaining to the plans for 

the Rocky Flats National Wildlife Refuge, cost records and estimates, and 

pension plan provisions. We also analyzed documents related to the costplus-incentive-fee contract, including contract negotiation documents, the 

contract cost and fee structure, and contract modifications, but we did not 

evaluate the cost-effectiveness of the contract.

To determine the measures in place to assess whether the cleanup would 

achieve a level of protection of public health and environment consistent 

with the Rocky Flats Cleanup Agreement, we reviewed documents and 

discussed issues pertaining to cleanup verification strategies and results. 

We also reviewed scientific analyses, such as a study of how contaminants 

migrate through soil and water and an assessment of the public health risk 
Appendix I

Objectives, Scope, and Methodology

Page 68 GAO-06-352 Nuclear Cleanup of Rocky Flats

posed by contaminants remaining at the site. We reviewed the general 

content of these analyses but did not evaluate the science underlying them.

In addition, because decisions about the sufficiency of the cleanup have 

been and will be based on remediation data, we assessed the soundness of 

the agencies’ and contractor’s processes and procedures for ensuring data 

quality. We visited the subcontractor that performed data verification and 

validation activities, and we reviewed the results of audits of the key 

laboratories used by the contractor to analyze samples of radioactively 

contaminated soil.

We also selected a nonprobability sample of four accelerated cleanup 

actions, based on several criteria, including whether EPA or Colorado was 

the lead regulatory agency and whether the contamination was in the 

surface soil or under contaminated buildings.1

 Because radionuclide 

contamination was the primary concern at the site, we selected cleanup 

actions of plutonium-contaminated soil. For each selected cleanup action, 

we reviewed data quality controls pertaining to data quality objectives, data 

quality parameters, and data verification and validation. We did not 

evaluate the remedial data or analyses themselves. Information on our data 

quality review results and details of DOE’s verification activities are 

presented in appendix IV. 

To determine the lessons the Rocky Flats project may hold for other DOE 

cleanup projects, we reviewed information and interviewed officials of 

DOE, EPA, FWS, Colorado, and the contractor about lessons learned at 

Rocky Flats and other sites. We reviewed documents related to and reports 

from DOE’s Society for Effective Lessons Learned Sharing database, and 

we interviewed DOE officials involved in various efforts to capture and 

disseminate lessons learned (from Rocky Flats and elsewhere throughout 

the DOE complex).

Further, to obtain citizen views about issues such as community input to 

the cleanup and the effect of various cleanup verification activities, we 

attended monthly meetings of the two local community groups that served 

in an advisory capacity to DOE: the Rocky Flats Citizens Advisory Board 

and the Rocky Flats Coalition of Local Governments. We also surveyed 

1

Results from nonprobability samples cannot be used to make inferences about a 

population, because in a nonprobability sample, some elements of the population being 

studied have no chance or an unknown chance of being selected as part of the sample.
Appendix I

Objectives, Scope, and Methodology

Page 69 GAO-06-352 Nuclear Cleanup of Rocky Flats

current and past members (and current staff) of these two groups to obtain 

their opinions on questions such as how DOE engaged the groups in the 

cleanup process, how DOE used the groups’ input, how satisfied or 

dissatisfied they were with the cleanup’s results, and the degree to which 

DOE’s cleanup verification activities affected their confidence in the 

cleanup. We pretested the survey twice and revised the questions 

accordingly. We documented the responses and verified 100 percent of the 

documentation. Response rates and summary responses are presented in 

appendix II. 

We conducted our work in accordance with generally accepted government 

auditing standards from March 2005 through May 2006.
Page 70 GAO-06-352 Nuclear Cleanup of Rocky Flats

Appendix II

GAO Survey Methodology, Response Rates, 

and Summary Responses ApendxiI

To obtain citizen and local government views on the Rocky Flats cleanup, 

we surveyed current (as of December 2005) and past members and current 

staff of the two local community groups that served in an advisory capacity 

to DOE: the Rocky Flats Citizens Advisory Board and the Rocky Flats 

Coalition of Local Governments.1

 The survey included questions about how 

DOE engaged the groups in the cleanup process, how DOE used the 

groups’ input, what level of confidence group members had in the cleanup’s 

results, the degree to which DOE’s cleanup verification activities affected 

their confidence in the cleanup, and any remaining concerns they might 

have. 

Survey Methodology We designed the survey questions to elicit clear and unbiased responses. 

We pretested the survey twice and revised questions accordingly. We 

transferred the survey responses into a spreadsheet and the comments into 

a narrative document; we then verified that 100 percent of the information 

was transferred accurately from the individual surveys.

In total, we sent surveys to 58 members (current and past).2 We obtained 

group members’ e-mail addresses (or mailing addresses, when e-mail 

addresses were not available) from the directors of the Rocky Flats 

Citizens Advisory Board (Advisory Board) and the Rocky Flats Coalition of 

Local Governments (Coalition). After e-mailing the survey, we e-mailed two 

reminder notices to encourage members to respond. Additionally, we 

attended both groups’ January 2006 meetings and personally encouraged 

members to submit their surveys. 

Survey Response Rates We received a total of 25 responses, or 43 percent of the total surveys sent. 

By subgroup, however (e.g., current members of one group, past members 

of one group), response rates varied widely. For example, the response rate 

for current members of the Advisory Board was 71 percent, whereas the 

1

The Rocky Flats Citizens Advisory Board and the Rocky Flats Coalition of Local 

Governments began phasing out their activities in early 2006; as of March 2006, the Rocky 

Flats Stewardship Council took over as the local oversight group. 

2

Our references to group members include the groups’ staff (two per group), whom we 

included in our survey because of their experience and knowledge about the Rocky Flats 

cleanup. 
Appendix II

GAO Survey Methodology, Response Rates, 

and Summary Responses

Page 71 GAO-06-352 Nuclear Cleanup of Rocky Flats

response rate for current members of the Coalition was 35 percent. Table 1 

shows the response rates by subgroup and in total.

Table 1: Survey Response Rates, by Subgroup

Source: GAO.

Summary Responses Following is a summary of the survey responses, by question, along with 

selected illustrative comments by respondents. Narrative responses are not 

provided in their entirety because we did not wish to introduce a 

perceptual bias. For some questions, that is, a majority of respondents 

offered positive and concise comments, but one or two respondents 

provided negative and lengthy comments. To present all of the comments in 

their entirety would thus give an unfair perception of emphasis, at least by 

sheer volume of narrative, to the negative minority and would diminish 

(again by volume) the positive majority. Accordingly, we summarized the 

comments to reflect the preponderance of responses, whether positive or 

negative.

The summary responses begin with question 5, as questions 1 through 4 

sought information about whether the respondent was a current or former 

member of either the Advisory Board or the Coalition and about the length 

of time the respondent had served as a member of the group.

Subgroup

Number of 

surveys sent

Number of 

responses received

Response rate 

(percent)

Current Advisory Board 14 10 71

Current Coalition 23 8 35

 Subtotal, current members 37 18 49

Past Advisory Board 14 6 43

Past Coalition 7 1 14

 Subtotal, past members 21 7 33

Total 58 25 42
Appendix II

GAO Survey Methodology, Response Rates, 

and Summary Responses

Page 72 GAO-06-352 Nuclear Cleanup of Rocky Flats

5. How satisfied or dissatisfied are you with how DOE engaged the 

[group—the Board or the Coalition] in the cleanup process?

6. Please explain or provide examples of how DOE engaged the 

[group] in the cleanup process.

Comments from 6 of the 21 respondents who reported being “very 

satisfied” or “somewhat satisfied” (in response to question 5) included the 

following: 

• “DOE actively engaged the Coalition and local communities in a variety 

of ways. . . [DOE] provided opportunities for the Coalition to participate 

in certain decision-making processes, provided [a] regular series of 

technical meetings keeping Coalition staff informed on various 

remediation activities, [and] . . . basically interacted with the Coalition 

on an almost daily basis during the course of the site’s cleanup.” 

• DOE’s engagement “varied from one manager to another but was 

generally good. More important, the CDPHE [i.e., Colorado], EPA and 

Kaiser-Hill consistently solicited the advice of the Board. In particular, 

the Board was given access to draft documents and decisions while they 

[were] still being discussed. This permitted the Board to actively 

participate in the decision process and influence the decision instead of 

simply responding to a done deal.”

• The “most important three items [were] board makeup, board decisionmaking process, and board meeting time. The members include a couple 

of ex-nuclear submarine personnel, a couple of college professors, a 

groundwater expert, a mining expert, peace activists, etc.; in addition, 

the attendance and participation of DOE, regulators, cleanup 

contractors, FWS, and the general public provides technical, emotional, 

and general interest review on items. Board decisions require that all 

agree on all formal Board decisions, which forces constructive give and 

Very satisfied 8

Somewhat satisfied 13

Neither satisfied nor dissatisfied 1

Somewhat dissatisfied 2

Very dissatisfied 1

Don’t know/no basis to judge 0
Appendix II

GAO Survey Methodology, Response Rates, 

and Summary Responses

Page 73 GAO-06-352 Nuclear Cleanup of Rocky Flats

take in the decision making process. Meeting in the evening not only 

permits the general public to attend, it also permits regulators, DOE, 

contractors, FWS, etc., etc., to all attend and discuss items—[it] may be 

the only time they all get together and discuss some of the items. DOE 

attends all [Board] meetings, presents data on requested topics, answers 

questions, and provides follow-up data as requested. We may not always 

agree but at least we get the data out there and discuss the issues. 

Operating as [a] federal board is very important.”

• “I believe that the DOE did a good job in answering reasonable requests 

from Board members. [DOE] did not always jump through every hoop 

presented nor should they have. Some requests were unreasonable; 

some would have been impossible, e.g., cleaning up soil to levels that 

technology couldn’t accomplish.”

• DOE “seemed to listen to the Board and take their recommendations 

seriously, when it fit their plan. . . .”

• “For the most part, DOE provided copies of documents for review and 

comment and provided presentations on cleanup and closure issues and 

decisions. But, the closer to completion the site became, the harder it 

was to get documents in a timely fashion. As an example, we were 

usually provided documents at the same time as the regulators, but at 

the end we received them much later than the regulators. Legacy 

Management [LM] completely ignored the city’s input to LM’s Public 

Involvement Plan.”

7. How satisfied or dissatisfied are you with how the [group’s] input 

was used by DOE?

Very satisfied 3

Somewhat satisfied 16

Neither satisfied nor dissatisfied 2

Somewhat dissatisfied 2

Very dissatisfied 2

Don’t know/no basis to judge 0
Appendix II

GAO Survey Methodology, Response Rates, 

and Summary Responses

Page 74 GAO-06-352 Nuclear Cleanup of Rocky Flats

8. Please explain or provide examples of how the [group’s] input 

was used by DOE.

Comments from 5 of the 16 respondents who reported being “somewhat 

satisfied” (in response to question 7) included the following:

• “The RSAL [radionuclide soil action level] issue was one on which the 

DOE listened to the [Advisory Board] and other public groups.”

• “In some cases DOE added information to documents or adjusted 

processes based on the Board’s input.”

• “The Board’s concerns about the original soil action levels were met 

with DOE’s agreement to fund the independent review.”

• “Our input was used on a number of fronts—pond management, 

ensuring [that] the site would not be a disposal site, and [the] strategy 

for remediating the original landfill, to name [a] few. Most important is 

[DOE’s] revising the RFCA [Rocky Flats Cleanup Agreement] to better 

reflect community priorities. The reason I checked ‘somewhat satisfied’ 

instead of ‘very satisfied’ is that we could never get DOE to incorporate 

stewardship planning into the cleanup process in a substantive manner. 

For DOE and the regulators, stewardship was an afterthought that got 

bucked to the end of the project and into regulatory closure space. We 

are now at the end of the project and we are still left wondering how 

DOE will address key questions concerning institutional controls.”

• “In the Independent Verification process, the Coalition pushed, and the 

DOE made some changes to their original proposal.”

9. Overall, what kind of effect, if any, do you believe the [group’s] 

input had on the cleanup process?

Very positive effect 6

Somewhat positive effect 17

Neither negative nor positive effect 1

Somewhat negative effect 0

Very negative effect 0

Don’t know/no basis to judge 1
Appendix II

GAO Survey Methodology, Response Rates, 

and Summary Responses

Page 75 GAO-06-352 Nuclear Cleanup of Rocky Flats

10. Please explain or provide examples of how the [group’s] input 

affected the cleanup process.

Comments from 7 of the 23 respondents who believed that their group’s 

input had a “very positive” or “somewhat positive” effect (in response to 

question 9) included the following:

• “Opposition of the [Board] and other entities to the 651 pCi/g RSAL for 

plutonium adopted for [Rocky Flats] in the 1996 [cleanup agreement] 

resulted in DOE funding a citizen oversight panel to hire independent 

scientific specialists to calculate radionuclide soil action levels (RSALs) 

for the site. Out of this study came the recommendation that the 

plutonium RSAL be reduced by 95% from 651 pCi/g to 35 pCi/g. While 

DOE did not accept this recommendation, it did work with the 

regulators to reduce the action level for [plutonium] in surface soil (top 

3 feet) from 651 to 50 pCi/g. DOE and the regulators, however, pushed a 

tradeoff, in that in exchange for this better surface cleanup (top 3 feet) 

the public would have to accept having larger quantities of plutonium 

left in the subsurface environment—between 1000 and 7000 pCi/g at a 

depth of 3 to 6 feet below the surface, with no limit on the concentration 

allowed below 6 feet.”

• “The Board has had an impact on all areas of the cleanup process . . . 

from how the landfill caps were constructed, to the overall level of 

cleanup, to how buildings were safely removed. . . .”

• “I understand that in the beginning the Board had a tremendous impact 

on the cleanup. Because of the Board and community members, the 

surface soil cleanup levels were changed to be more conservative, from 

651 pCi/g to 50 pCi/g. I feel [that] the Board had less of an influence later 

in the process. However, because of the Board, DOE was aware that the 

community was watching, and I believe the community got a better 

cleanup because of that.”

• “DOE solicited a large amount of input from the Coalition over the 

course of the site’s cleanup. Although not all of the Coalition’s input was 

incorporated into cleanup plans, a substantial amount of Coalition 

positions were incorporated into the cleanup. As a result, local 

community buy-in into the process was enhanced. DOE, Kaiser-Hill, the 

regulators, and the Coalition were successful partners in the site’s 

closure.”
Appendix II

GAO Survey Methodology, Response Rates, 

and Summary Responses

Page 76 GAO-06-352 Nuclear Cleanup of Rocky Flats

• “We were able to influence the level of cleanup. We were also able to get 

more cleanup in areas like the 903 pad in exchange for leaving building 

foundations in place—771 & 371.”

• “By the Coalition engaging in depth on matters of technical feasibility, 

schedule, cost, worker safety, D&D [decontamination and demolition] 

design and implementation, contaminant control and monitoring, it 

forced the DOE, regulators and Kaiser-Hill to focus and impart progress 

and planning to the Coalition board and public.”

• “The Coalition affected the cleanup on a number of levels. We were the 

best supporters and the most effective critic. We helped maintain 

congressional support for the project and held DOE, Kaiser-Hill and the 

regulators accountable. We were central to determining the future use of 

the site and to revising the cleanup priorities to better match the needs 

of the community. We brought DOE to the table in a public forum which, 

along principally with the [Citizens Advisory Board], was central to 

ensuring the dialogue remained open. We pushed for a free flow of 

information.”

11. Please explain or provide examples of what, if anything, DOE 

might have done differently to change the effect of the [group’s] 

input on the cleanup process.

Respondents offered a number of suggestions and comments, including the 

following:

• “The only change would be on the future monitoring of the site i.e., LSO 

[the Local Stakeholder Organization] which has been completely 

controlled by politics and not by DOE and the board. . . .” 

• “I always believed that if DOE had approached it more as a partnership 

with their end customer the cleanup process would have been done 

better.”

• “[DOE] did continue with a very active public participation process to 

address [the soil action levels] and all aspects of the cleanup. However, 

rather than doing this process via the [Board, which was] established in 

1993 to advise DOE on the cleanup, DOE created a new body, the RFCA 

[Rocky Flats Cleanup Agreement] Focus Group . . . The value of the 

Focus Group was that it allowed more intense discussion of details than 

was usually possible in a [Board] meeting. But shifting the principal 
Appendix II

GAO Survey Methodology, Response Rates, 

and Summary Responses

Page 77 GAO-06-352 Nuclear Cleanup of Rocky Flats

discussion of the cleanup to the Focus Group . . . had the effect of 

undermining and marginalizing the [Board].” 

• “DOE could have engaged the Board better in terms of budgeting. We 

were never asked to partner with the site in requesting funds for our 

participation through the federal budget process. . . . We also will not be 

funded for what we saw as a valuable project to develop risk 

communication tools to help alleviate concerns about the residual 

contamination at the site. We have heard from citizens who live near the 

site that they are concerned that contamination has been left behind. 

There is no way that these citizens are going to read and understand the 

immense multi-volume Remedial Investigation study and 

Comprehensive Risk Assessment. If there are any further water quality 

exceedences, even if they are not life threatening, they are going to call 

into question the protectiveness of the cleanup. DOE had better hope 

this doesn’t happen, because they appear to have no plan or the tools to 

address concerns that might be raised by the less knowledgeable in the 

community.”

• “DOE at times declined to allow members of the Board to observe 

internal meetings between DOE, [Kaiser-Hill], and the regulators. This 

made it more difficult for the Board to thoroughly understand the 

technical details of a cleanup decision and respond in an educated way.“

• “One recurring Coalition theme was the lack of long-term stewardship 

considerations in remedial action planning and documents. Instead of 

incorporating the long-term stewardship considerations into the 

documents, it was left to post-physical closure documents. . . . The 

Coalition position has always been that long-term stewardship planning 

should be an integral part of the remedial activities and not relegated to 

post-closure status.”

• “As the clean up was underway in early 2005, DOE seemed to agree that 

ORISE should conduct a [Multi-Agency Radiation Survey and Site 

Investigation Manual, or MARSSIM]-based final clean up verification. 

Since this approach was apparently not specified in the contract, KaiserHill balked and DOE was left to fund an over-flight survey by a low flying 

helicopter to, for PR [public relations] purposes, attempt to pick up 

(detect) major hot spots. The overflight technology was not sufficiently 

sensitive to detect exceedences of the clean up level. In addition due to 

soil moisture and shielding in the industrial area, the overflight 

detection approach was of little credible value. By omitting this final 
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verification Kaiser-Hill was able to ‘complete’ physical closure early and 

collect an added 100 million dollar award.” 

We now have a few questions about the results of the cleanup. As 

you know, since 1995, when it was awarded the Rocky Flats cleanup 

contract, Kaiser-Hill has decontaminated and demolished hundreds 

of structures, installed groundwater treatment systems, and 

removed contaminated soil, among other cleanup tasks specified by 

the contract and the Rocky Flats Cleanup Agreement.

12. How confident, if at all, are you that the cleanup will be 

protective of public health and the environment?

13. Please explain or provide examples that illustrate your view.

Comments from 4 of the 11 respondents who were “extremely confident” 

or “very confident” (in response to question 12) in the protective nature of 

the cleanup included the following:

• “I believe that phenomenal effort was very effective in cleaning up those 

sites that needed remediation, e.g., the 903 Pad and uranium trenches.” 

• “I am personally confident that the government will retain possession of 

the land and keep up the controls now in place so that visitors are safe 

and protected. I am convinced we got the best cleanup possible for the 

conditions, political climate, and money spent.” 

• “This process has been open and has benefited from intense public 

oversight, talented and committed regulators (especially at CDPHE 

[Colorado Department of Public Health and Environment]), and 

independent reviews of key assumptions and decisions such as the 

Actinide Migration Panel and the soil action level review. Further, the 

Extremely confident 5

Very confident 6

Somewhat confident 12

Not very confident 1

Not at all confident 1

Don’t know/no basis to judge 0
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surface water quality standards are extremely stringent and with rare 

exception they are getting met. That increases my confidence.” 

• “The main reason I am extremely confident that the cleanup will be 

protective of public health and the environment is because of the 

tremendous amount of excellent oversight work provided by the 

regulators (CDPHE and EPA). I can’t say enough of how impressed I am 

with the technical staff of the regulatory agencies. They were 

everywhere during the course of the cleanup, ensuring that the remedial 

actions performed at the site were properly planned, implemented, and 

executed.”

Comments from 4 of the 12 respondents who were “somewhat confident” 

(in response to question 12) in the protective nature of the cleanup 

included the following:

• “We don’t know everything that is underground (e.g., landfills) and 

might seep out—cleanup is probably the most cost-effective that could 

be done . . .”

• “I think most of the contamination has been removed. However, I am 

concerned about isolated hot spots.”

• “We were very disappointed that DOE changed course on the 

verification of cleanup. We were led to believe that the verification 

would be a MARSSIM based approach; what we really received was a 

process that had never been used for verification purposes (the aerial 

flyover); an ORISE review that was constrained by DOE and a limited 

scope review.”

• “I believe the majority of the buffer area will be very low risk to the 

public. The ponds, the industrial area, the 903 pad, 903 lip and 903 wind 

blown area could expose the unsuspecting public to a higher risk 

depending on individual sensitivities even though the residual Pu 

[plutonium] level is at or below 50 pCi/g.”

One of the 2 respondents who were “not very” or “not at all” confident (in 

response to question 12) about the cleanup’s protectiveness said,

• “I don’t believe that the cleanup was done to be protective of public 

health and the environment. Otherwise, DOE would not have pursued 

the wildlife preserve aspect. Basically, the wildlife preserve is an 
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“administrative” control to limit the future land use, limit public 

exposure to the existing contamination at the site, and allowed DOE to 

leave behind a lot of contamination.”

14. What, if anything, might have been done differently during the 

cleanup that would have increased your confidence?

Respondents offered a number of suggestions and comments, including the 

following:

• “If the original landfill and the deep basements had been removed, my 

confidence would be greatly increased. I do understand the reasons for 

this not occurring.”

• “A 100 percent scan of the DOE-retained lands would give me a 

complete idea of what is out there. . . .”

• “The implementation of our consultants’ recommendations and a 

“TRUE” MARSSIM based final survey.”

• “Only after the Focus Group had been meeting for a full year was it 

finally made clear that the better cleanup sought by some participants 

was not in the cards because decisions placing a cap on what could be 

spent had already been made. To some of us involved in this enormously 

time consuming process, this announcement revealed that the public 

participation process was in large measure a sham. Some DOE 

personnel insist that DOE had been open about the fiscal cap, but the 

DOE official who made the announcement at the Focus Group later said 

that its effect on the meeting was ‘like throwing a dead rat on the table.’”

• “I really do not have any concern about the site per se. I am concerned 

that the legal folderol . . . will continue forever.”

• “Really we are relying on the best science known and so I am not sure 

that anything could have been done better.”

• “The verification could have been performed earlier so that it could have 

been used as a tool in the cleanup.”

• “With unlimited funds a total cleanup could have been accomplished—

in our real world we have better than could have been expected. FWS 

now needs the resources to convert the site.”
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• “DOE and the regulators should have required independent [MARSSIM] 

based protocols to verify complete and comprehensive surface soil 

clean up levels site wide. This should have been done by an independent 

contractor.”

15. At this point in time, do you have any remaining concerns about 

the cleanup?

Yes 17

No 8

16. Please provide examples or details of your remaining concerns.

Respondents offered a number of concerns, including the following:

• “The underground “stuff”—landfills and basements. Who knows what, 

when and how it might affect us in the future.”

• “I am not certain how we will maintain control of [the] area for the 

centuries needed given that we did not know for certain that all 

contaminants were removed.”

• “DOE needs to continue water quality monitoring on Woman Creek 

permanently!” 

• “My remaining concerns with the cleanup have to do with how well the 

revegetation and erosion control measures function in the next few 

years. The site needs several good growing seasons to help re-establish 

vegetation covering the remediated portions of the DOE-retained land. 

Without adequate vegetative cover, erosion problems can arise which 

could ultimately result in the mobilization of actinides from the surface 

soil into surface water.”

• “My concerns now lie in the importance of creating a robust 

stewardship plan and assuring that monitoring will continue well into 

the future as well as knowing that if we find that a remedy has failed the 

DOE will do what it takes to address this failure.” 

• “I worry about the magnitude of the long-time stewardship 

responsibilities. There are numerous examples at other sites of where 

controls fail because governments forget that there are institutional 
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and Summary Responses

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controls which carry with them use restrictions. How we will protect 

Rocky Flats over the long-term remains somewhat of a mystery for me.” 

• “What will be done in the coming years, and by whom, to keep the public 

out of the contaminated areas?”

• “Plutonium and uranium take hundreds of thousands of years to decay. 

Even in 100 years, the site can change sufficiently so that subsurface 

contamination is exposed. Also, physical controls may well decay into 

dust by the time the next century rolls around and institutional controls 

could be forgotten. In the future, the site could be used for subsistence 

farming. Who knows what will happen? The uncertainty of the future 

contributes the largest concern I have about the cleanup.”

In the summer of 2005, DOE arranged for a number of cleanup 

verification activities, including Kaiser-Hill’s ground-based scans 

along the boundaries of previously remediated areas where 

contamination was once known to exist; Bechtel Nevada’s3

 aerial 

scan of the site; and the Oak Ridge Institute of Science and 

Education’s (ORISE) sampling and ground-based scanning of the 

903 pad and lip area. We would like your views on the overall 

verification process, as well as your views on each of these three 

specific verification activities.

17. How, if at all, did the overall verification process affect your 

confidence in the site’s cleanup?

3

Bechtel Nevada conducted the aerial survey.

Greatly increased my confidence 3

Somewhat increased my confidence 10

Neither increased nor diminished my confidence 5

Somewhat diminished my confidence 2

Greatly diminished my confidence 1

Don’t know/no basis to judge 4
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and Summary Responses

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18. Please explain or provide examples that illustrate how the 

overall verification process affected your confidence in the site’s 

cleanup.

Comments from 5 of the 13 respondents who believed that the overall 

verification process “greatly increased” or “somewhat increased” their 

confidence (in response to question 17) included the following:

• “Although I felt there was a low probability of contamination being in 

the buffer zone, given the level of suspicion and the recent publication 

of several false and misleading books and articles I felt it was important. 

This is a good time to state that although almost all the public fear 

involved radiologic contamination, it is not the most hazardous.” 

• “Additional testing always adds to the vote of confidence.” 

• “The aerial scan was the most effective. The other parts of the 

verification were too confusing for the majority of the community to 

understand. When the hot spots were discovered in the 903 Pad Lip 

Area, those of us more familiar with statistical sampling methodology 

could understand that it was not that grave of a situation, but those who 

read newspapers I am sure were not comforted.” 

• “ORISE, although paid by DOE, is an independent [entity]. As such, I 

trust their results.”

• “The targeted independent verification areas helped to assure my 

confidence level but did not greatly increase it. I do think the 

verification process was important to other board members and most of 

all to the general public. It probably did very little or nothing to assure 

already skeptical critics of the site cleanup.” 

Comments from 2 of the 5 respondents who said the activities “neither 

increased nor diminished” their confidence (in response to question 17) 

included the following:

• “I feel what was done was a waste of time and money and did not tell us 

anything new.” 

• “Was glad it was in place, but didn’t give me 100% confidence.”
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And of the 3 respondents who said the activities “somewhat diminished” or 

“greatly diminished” their confidence in the cleanup (in response to 

question 17), 1 said,

• “It is by no means clear that the full site has ever been well 

characterized. Former workers are known to say that unknown areas of 

random dumping were never found by the characterizing methods used, 

especially the . . . method that took a very limited number of samples in 

relatively large areas and estimated the contamination in that area based 

on this very limited sampling. Further, . . . the verification methods used 

could not detect all hot spots or areas of unknown subsurface 

contamination.” 

19. How, if at all, did Kaiser-Hill’s targeted ground-based scanning 

activities (using a high-purity germanium, or HPGe, detector 

mounted on a tripod) affect your confidence in the site’s cleanup?

20. Please explain or provide examples that illustrate how KaiserHill’s targeted ground-based scanning activities affected your 

confidence in the site’s cleanup.

Comments from 4 of the 11 respondents who said that Kaiser-Hill’s targeted 

ground-based scanning activities “greatly increased” or “somewhat 

increased” their confidence in the cleanup (in response to question 19) 

included the following:

• “It showed that there was basically no contamination above the cleanup 

levels left on the site.” 

• “I felt that the areas surveyed had a low risk of contamination. While it 

only somewhat increased my personal confidence I feel it was critical in 

increasing the public confidence.” 

Greatly increased my confidence 4

Somewhat increased my confidence 7

Neither increased nor diminished my confidence 7

Somewhat diminished my confidence 3

Greatly diminished my confidence 0

Don’t know/no basis to judge 4
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• “They targeted areas of concern and proved through testing that cleanup 

levels had been achieved.”

• “Showed that the area ‘covered’ by the scan met cleanup criteria.”

Comments from 2 of the 7 respondents who said the activities “neither 

increased nor diminished” their confidence (in response to question 19) 

included the following:

• “There wasn’t enough sampling conducted, and the sampling should 

have been conducted in more areas after remediation was done and 

before backfill took place.” 

• “Kaiser-Hill’s scanning activities were part of the cleanup, not part of an 

independent review. So, I have confidence in what they did, but the 

question suggests that their scans would increase my confidence in their 

work. Independent review would have increased my confidence.” 

And of the 3 respondents who said the activities “somewhat diminished” 

their confidence in the cleanup (in response to question 19), 1 said,

• “DOE and [the contractor] have continued to approach the cleanup 

using methods designed to not find problems. An approach designed to 

verify that no problem exists cannot be used to discover problems.” 

21. How, if at all, did Bechtel Nevada’s aerial scan of the site (using 

a helicopter-mounted array of sodium iodide detectors) affect your 

confidence in the site’s cleanup?

Greatly increased my confidence 3

Somewhat increased my confidence 6

Neither increased nor diminished my confidence 8

Somewhat diminished my confidence 3

Greatly diminished my confidence 1

Don’t know/no basis to judge 4
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and Summary Responses

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22. Please explain or provide examples that illustrate how Bechtel 

Nevada’s aerial scan of the site affected your confidence in the 

site’s cleanup.

Comments from 3 of the 9 respondents who said that Bechtel Nevada’s 

aerial scan of the site “greatly increased” or “somewhat increased” their 

confidence in the cleanup (in response to question 21) included the 

following:

• “The [aerial scan] addressed the entire site, not just where one 

anticipated that contamination could exist.” 

• “The aerial scan just confirmed what DOE had been telling us all along.”

• “Detection capabilities of aircraft scanners was not as sensitive as I 

would have liked. System was designed to detect higher concentrations 

of radionuclides than were expected at Rocky Flats.”

Comments from 2 of the 8 respondents who said the activities “neither 

increased nor diminished” their confidence (in response to question 21) 

included the following:

• “While the technology, if properly applied, might have been sufficient, 

the results were less than reliable because of ground moisture, shielding 

in the industrial area by equipment, debris, etc., and over-lot grading, 

which would have buried contamination. If properly applied, the aerial 

scan could detect major hot spots but is not designed to detect small hot 

spots that exceed the cleanup level. The aerial scan was more a public 

relations ploy than a good science valid verification of site safety and 

reliable cleanup.” 

• [The aerial scan was] “a method that is suited for determining what has 

happened in a Three Mile Island [or] Chernobyl type event, not to verify 

[that] an action did what it was supposed to do.” 

And of the 4 respondents who said the activities “somewhat diminished” or 

“greatly diminished” their confidence in the cleanup (in response to 

question 21), 1 said,

• “The [remedial soil action levels] established for Rocky Flats set 

standards for plutonium and other materials that may remain in place 

according to depth. The aerial scan can only detect what is present on 
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the surface (not surface defined as the top three feet, but surface as 

limited to a small fraction of this amount). Further, the aerial scan 

detects hot spots only if they are quite large in extent and relatively high 

in concentration. The aerial scan is a very valuable tool but also a very 

limited one.”

23. How, if at all, did ORISE’s verification activities (e.g., soil 

sampling and surface scans using sodium iodide “FIDLER” 

scintillation detectors) affect your confidence in the site’s cleanup?

24. Please explain or provide examples that illustrate how ORISE’s 

verification activities affected your confidence in the site’s cleanup.

Comments from 6 of the 16 respondents who said that ORISE’s verification 

activities “greatly increased” or “somewhat increased” their confidence in 

the cleanup (in response to question 23) included the following:

• “Unlike the two [other verification activities], the ORISE verification 

was essential in verifying that [Kaiser-Hill] did in fact perform the work 

they were being paid to do.” 

• [ORISE] “did find some hot spots that [Kaiser-Hill] then addressed, so a 

second check did help to increase belief in [the] cleanup.” 

• “This is the verification activity that turned up the ‘hot spots’ which 

were eventually remediated. I understand that according to the risk 

assessment formulas that were developed and the averaging nature of 

these formulas these ‘hot spots’ technically did not have to be 

remediated. The decision to remediate these, however, was important to 

help assure public confidence in the site cleanup.”

• “The ORISE work ended up raising more questions and concerns by the 

public. Also, we are left with the impression at the end that their work is 

Greatly increased my confidence 5

Somewhat increased my confidence 11

Neither increased nor diminished my confidence 2

Somewhat diminished my confidence 2

Greatly diminished my confidence 0

Don’t know/no basis to judge 5
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and Summary Responses

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incomplete because DOE did not provide them with funding to do the 

final review of the aerial survey. Also, trying to make MARSSIM fit into 

what was needed to verify the cleanup at the site was just too difficult to 

follow. . . . The ORISE work started out with great expectations, but 

things just got too confusing at the end. For the average citizen, I don’t 

think the verification made any difference at all.” 

• “The ORISE budget was very limited—about $250,000—and was not 

sufficient to do an adequate job of site verification because the protocol 

they had to follow was disjointed.” 

• “ORISE’S work showed that for the area they reviewed, the statistical 

approach Kaiser-Hill used was valid. However, given that DOE limited 

ORISE’s work it is hard to extrapolate their findings over a larger area of 

the site. So, their work was of a limited value.” 

Of the 2 respondents who said that the activities “neither increased nor 

diminished” their confidence (in response to question 23), 1 said:

• “The review became less and less than promised as time went by: from 

a MARSSIM-based approach, to an approach greatly restrained by DOE 

as to what would be reviewed and how the review would be conducted.”

And of the 2 respondents who said that the activities “somewhat 

diminished” their confidence in the cleanup (in response to question 23), 1 

said,

• “I believe the FIDLER device is a very good way to detect contamination 

in the surface soil. But its use by ORISE again was limited to areas of 

known contamination rather than to characterize portions of the site 

that have not been adequately characterized.”

25. Do you have any additional comments you would like to 

provide?

Among the respondents’ additional comments were the following:

• “[The Board] provides the only forum that has provided for the public, 

regulators, DOE, and contractor to discuss the issues and for everyone 

to have an equal voice. Hope there is someplace in the future (for a 

couple of years) for such activities to continue. The proposed LSO [longterm stewardship organization] appears to be a waste of government 
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funds—too large of a staff, restricted membership, and too little 

technical expertise. . . .”

• “I believe the lessons learned at Rocky Flats could be put to good use at 

other sites, especially Hanford.”

• “In the future on any similar rad[iologically] contaminated sites, DOE 

should require as a contractual condition that an independent 

verification of the clean up be implemented using [MARSSIM] 

principles. In the 903 pad area where a [MARSSIM] sampling verification 

was implemented—hot spots substantially exceeding 50 pCi/g were 

found and picked up. It would seem reasonable to conclude that other 

areas of the 903 pad and the industrial area would have similar 

exceedences.”

• “DOE, other state agencies, and communities should study what we did 

at Rocky Flats because we were on the cutting edge of how to work 

within the regulations but allow great latitude in engaging the 

community and for remediating a complex nuclear site.”

• “Standley Lake Cities still have serious concerns about Woman Creek’s 

risk from [the original landfill and the fact that] Woman Creek has no

terminal testing control pond!”

• “ORISE should have been allowed to survey more of the area and to do 

some surveying of the Buffer Zone.”
Page 90 GAO-06-352 Nuclear Cleanup of Rocky Flats

Appendix III

Additional Information on Decontamination 

and Demolition Activities at Rocky Flats ApendxiI

The contractor used a number of innovative techniques to accomplish 

decontamination and demolition tasks at Rocky Flats. One of these, as 

discussed in the report, was the use of a cerium nitrate solution to 

decontaminate large pieces of equipment. Another innovative 

decontaminating technique was the contractor’s use of InstaCoteTM to 

encapsulate large surface-contaminated tanks and other equipment. 

InstaCote is a polyurea plastic coating that was sprayed on equipment. The 

InstaCote not only sealed in the contamination, but also served as the 

shipping conveyance and disposal package. According to DOE officials, use 

of the InstaCote saved “easily thousands of hours” and increased worker 

safety, as it eliminated the difficult and dangerous job of cutting 

contaminated equipment and packaging it for shipment. The InstaCote 

could be used even with extremely large pieces of contaminated 

equipment, such as a super-compacter used to reduce waste volume by 

crushing drums containing radioactive waste and drums that were empty 

but had formerly contained radioactive waste. Figure 14 shows the supercompacter before InstaCote was applied and with the InstaCote awaiting 

transport to a disposal facility.

Figure 14: Super-Compacter without (Left) and with InstaCote

One of the most difficult decontaminating challenges DOE and the 

contractor overcame was decontaminating concrete. When concrete 

became contaminated with liquid radioactive waste (e.g., by spills during 

nuclear material processing or waste disposal), the past practice was to fix 

Source: DOE.
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and Demolition Activities at Rocky Flats

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the contamination in place using sometimes several layers of an epoxy 

paint. Before a building containing contaminated concrete could be 

demolished, this paint had to be removed down to the base material, and 

the base material had to be decontaminated. The contractor removed the 

contaminated paint using various methods such as scabbling, shaving, or 

hydolasing. Scabbling chipped away the first layer of the surface with a 

pneumatic hammer; however, this option created dust and increased the 

potential for the release of contaminants into the air. Shaving removed 

layers of concrete with a machine, and was considered more efficient and 

less hazardous than hydrolasing for decontaminating concrete surfaces 

with deeper contamination. Hydrolasing, the preferred method for 

removing paint and shallow surface contamination, involved blasting away 

paint and the initial layer of the surface material with water, then selfcontaining the water and resulting debris. Figure 15 shows the hydrolase 

system in use in building 886 at Rocky Flats, a former nuclear laboratory 

known to have light contamination under painted surfaces. 
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and Demolition Activities at Rocky Flats

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Figure 15: Hydrolase System at Work Removing Contaminated Paint and Underlying 

Surface Contamination

But in some cases, according to a senior contractor official, contaminated 

liquid had seeped so deeply into the concrete that it could not be removed 

using any of these three methods. This was the case, for example, in the 

“infinity room” (so called because the level of radioactive contamination in 

the room was greater than instruments could measure) of building 771, 

which had often been referred to as “the most dangerous building in 

America.” When concrete was contaminated to the core, the only option 

Source: DOE.
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and Demolition Activities at Rocky Flats

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was to cut it out and remove it. The entire “infinity room” floor had to be 

cut out and shipped as transuranic waste, as shown in figure 16.

Figure 16: Workers Cut Contaminated Concrete from Building 771’s ‘Infinity Room’

In other cases, when the contaminated concrete was far underground (i.e., 

in building foundations), it was decontaminated to the lowest levels 

reasonably achievable and left in place. DOE and the regulatory agencies 

agreed to decontaminate and leave in place the foundations of buildings 

371 and 771/774, and cover them with clean fill dirt. According to DOE and 

contractor officials, leaving the foundations in place poses little risk to 

human health and safety because the foundations and the soil around them 

were decontaminated to specified levels before being covered.1

 Also, they 

1

Specifically, contamination on the surface of the foundations’ concrete had to be 

remediated to less than 100 nanocuries per gram, and contamination by volume (measured 

through calculations of the foundations’ depth) had to be remediated to less than 7 

nanocuries per gram. If contaminated sections of the concrete could not be remediated to 

these levels, those sections had to be removed. 

Source: DOE.
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and Demolition Activities at Rocky Flats

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said, leaving the foundations in place was safer for the workers at the site 

than removing them, which would have required workers wearing 

respiratory protection systems that constrain movement and visibility to 

winch up massive, multiton pieces of concrete from a confined space. A 

Colorado official said he had agreed to the decision to leave the 

foundations in place after carefully considering the balance between the 

potential future risk of exposure with the real and immediate risk of 

worker safety. In lieu of removal, the contractor treated the foundations 

with a fixative to prevent contaminants from migrating during demolition 

activities, then covered them with a cushion of sand and a layer of clean fill 

dirt. According to DOE and contractor officials, plutonium should not 

migrate out of the foundations, and if it does, it should not migrate beyond 

the surrounding soil. This contention is supported by the results of the 

actinide migration study, which concluded that fixed actinide 

contamination does not readily move in the environment. Also, neither 

humans nor wildlife would be exposed unless a future major excavation 

activity were to take place. However slight it may be, the potential risk to 

human health and safety posed by leaving the foundations in place is the 

reason that controls such as groundwater monitoring wells and treatment 

systems will remain in place, according to Colorado officials. 

Another innovative decontaminating and demolition strategy the 

contractor developed in conjunction with DOE and the regulatory agencies 

involved dividing the site into areas and completing most or all of the work 

in one area—from building decontamination to demolition—so that 

environmental remediation could begin in that area while decontamination 

and demolition work was being done in the next area. This strategy enabled 

the cleanup to proceed more quickly by allowing the earlier start of 

environmental restoration work and by allowing workers more time to 

address any unforeseen circumstances. The strategy also achieved 

economies of scale, as site services—such as water, steam, and power—

could be eliminated throughout an entire area, rather than on a building-bybuilding basis.
Page 95 GAO-06-352 Nuclear Cleanup of Rocky Flats

Appendix IV

Additional Information on the Quality of 

Remediation Data at Rocky Flats and on 

DOE’s Planned and Actual Verification ApendxiIV

This appendix presents additional information on our review of the 

processes and procedures in place at Rocky Flats to evaluate the quality of 

remediation data. It also presents additional information on DOE’s planned 

and actual verification of the contractor’s cleanup work.

Information on 

Controls over Data 

Quality 

A critical aspect of the cleanup process was ensuring the validity of the 

data used to assess whether the site had been remediated to the agreedupon levels. Accordingly, we reviewed the processes and procedures in 

place to ensure data quality, and we identified four key controls: (1) 

establishing data quality objectives, (2) using data quality parameters, (3) 

verifying and validating data, and (4) auditing laboratories that analyzed 

samples for Rocky Flats. Our review showed that, overall, the contractor 

generally followed these data quality controls and clearly documented its 

compliance with them for the four accelerated cleanup actions we 

reviewed in depth. For these four cleanup actions—at building 771, the 903 

pad, the 903 lip area, and trench T-7—we assessed the closeout reports and 

the data supporting them to determine the extent to which the data 

collection and laboratory analyses adhered to data quality standards and 

procedures. We did not, however, evaluate the remedial data or laboratory 

analyses themselves. 

To assess the use of the first key control—establishing data quality 

objectives—we identified the criteria documented in the Industrial Area 

and Buffer Zone Sampling and Analysis Plan. We then reviewed the cleanup 

project sampling plan addenda, remedial action plans, and cleanup project 

closeout reports for each of the four projects to determine whether the 

data quality objectives had been established and were considered during 

the projects’ cleanup. To assess the use of the second control, we reviewed 

the four projects’ closeout reports to verify that the data had been checked 

against the data quality parameters in accordance with the criteria located 

in both the Rocky Flats Implementation Guidance Document and the 

Industrial Area and Buffer Zone Sampling and Analysis Plan. These 

documents establish the guidelines for evaluating analytical data and 

address the overall quality of the data quality control. We examined the 

closeout reports for each of the four projects to ensure that the projects 

met the criteria for the third control—data verification and validation. And 

finally, to assess the use of the fourth control, we reviewed reports on 

audits of laboratories that analyzed data for the site’s cleanup. Specifically, 

we reviewed source documentation from audits conducted by DOE’s 

consolidated audit program and DOE’s mixed analyte performance 

evaluation program. We concentrated our review on laboratory audit 
Appendix IV

Additional Information on the Quality of 

Remediation Data at Rocky Flats and on 

DOE’s Planned and Actual Verification 

Page 96 GAO-06-352 Nuclear Cleanup of Rocky Flats

results relevant to detecting plutonium for the 3-year period during which 

cleanup was under way for the four projects. 

Establishing data quality objectives. DOE and the contractor 

established data quality objectives to act as planning tools for collecting 

data and for making decisions. The data quality objectives process is 

specified in the site’s quality assurance project plan.1

 The process is 

intended to provide a systematic procedure for defining criteria for data 

collection, including when and where to collect samples, what level of 

decision error is tolerable, and how many samples to collect. In our review 

of the four selected cleanup areas, we found general adherence to the data 

quality objectives process. For three of the four projects we selected, we 

verified that both the characterization and confirmation sampling were 

planned according to the data quality objective process as defined in the 

Industrial Area and Buffer Zone Sampling and Analysis Plan. Because the 

fourth project required only minimal cleanup, it was completed through the 

standard “no further accelerated action” justification process. According to 

the contractor, the justification documentation for such areas (those 

requiring minimal cleanup) should include information on data adequacy, 

but not at the same level of detail as was required for other cleanup areas. 

We recognize that areas closed out through the “no further accelerated 

action” process may not necessitate the same level of data quality 

documentation as other areas. Nevertheless, the Rocky Flats Cleanup 

Agreement requires that the justification documentation for “no further 

accelerated action” areas include information on data quality and usability. 

The documentation we reviewed for trench T-7 did not include such 

information.

Applying PARCC parameters. EPA’s policy requires it to apply data 

quality parameters for precision, accuracy, representativeness, 

completeness, and comparability—known as the PARCC parameters. 

Because radionuclides were involved, an additional data quality 

parameter—sensitivity—was used at Rocky Flats. These parameters 

provided information to the contractor and the regulatory agencies about 

the acceptability or utility of the data. For example, precision measures 

whether using the same analytical technique will result in the same results 

for a particular sample (i.e., analyzing the same sample twice and

1

The Rocky Flats Quality Assurance Project Plan is included in the Industrial Area and 

Buffer Zone Sampling and Analysis Plan.
Appendix IV

Additional Information on the Quality of 

Remediation Data at Rocky Flats and on 

DOE’s Planned and Actual Verification 

Page 97 GAO-06-352 Nuclear Cleanup of Rocky Flats

comparing the results).2 According to the sampling and analysis plan, 

assessments of the data according to the PARCC parameters are 

documented in the closeout reports for the accelerated cleanup actions 

and, according to EPA officials, are checked through the verification and 

validation process discussed next. Our review of the four selected cleanup 

areas indicated that the PARCC parameters were consistently applied. For 

three of the four projects we selected, we verified that the data were 

reviewed in accordance with each of the data quality parameters. The 

fourth project required only minimal cleanup and was completed through 

the standard “no further accelerated action” justification process for which 

no formal data quality discussion was required. 

Verifying and validating laboratory data. Data verification was 

required for 100 percent of the laboratory data at Rocky Flats. Data 

validation was required for 25 percent of the data, but because this 

requirement pertained to the Rocky Flats site as a whole, the percentage of 

data validated could vary considerably from one cleanup area to another. 

Data verification is a review of a laboratory’s electronic data package 

summary to evaluate the extent to which the laboratory met specified 

quality control and reporting criteria. Data validation is a more in-depth 

review that includes not only verifying the data, but also examining the raw 

data and manually verifying calculations done by the laboratory. After a 

laboratory analyzed samples, it sent the results to a subcontractor that 

reviewed the data according to either the verification or the validation 

criteria and assigned codes indicating the data’s quality. For example, one 

code would be assigned to data for which no problems were observed, 

whereas another code would be assigned to data that did not meet the 

quality control requirements. 

Our review of the closeout reports on the four cleanup projects we selected 

indicated general adherence to the verification and validation 

requirements. Specifically, for three of the four projects, at least 98 percent 

of the overall data had been verified, and between 23 percent and 50 

percent had been validated. The contractor provided several explanations 

for why 100 percent of the data had not been verified. For example, at the 

903 lip area, because a number of samples were collected close to the time 

that the closeout report was submitted, verification and validation 

occurred after the report was completed. Additionally, the large number of 

2

At Rocky Flats, the contractor was required to take duplicate samples for 5 percent of all 

field samples.
Appendix IV

Additional Information on the Quality of 

Remediation Data at Rocky Flats and on 

DOE’s Planned and Actual Verification 

Page 98 GAO-06-352 Nuclear Cleanup of Rocky Flats

samples collected in September 2004 (from the 903 lip area and other areas 

around the site) overloaded the verification and validation staff. Most of 

these records were verified or validated in late November or early 

December 2004, and all had been verified or validated by early 2005, 

according to the contractor. 

Auditing laboratories. The 32 laboratories that analyzed samples 

collected from Rocky Flats were required to undergo annual technical 

audits to ensure the accuracy of their analytical results. Since 2000, 

contractor officials said they have largely satisfied the audit requirement by 

voluntarily participating in DOE’s consolidated audit program,3

 with the 

exception of one on-site laboratory that the contractor audited. A typical 

DOE laboratory audit, according to the audit program manager, includes a 

3-day visit to the laboratory by a team of five to six people. DOE certifies 

laboratory auditors in particular areas, including chemistry (e.g., 

radiochemistry or organic chemistry), and uses a standardized checklist to 

verify that laboratory practices meet DOE standards. When auditors 

identify problems, they can provide comments or issue priority I or priority 

II findings. Priority I findings are the most severe; they represent a serious 

breakdown in management controls that could render the laboratory 

unacceptable for use or unfit to perform services for DOE. Laboratories 

that receive priority I and II findings are required to develop and implement 

corrective action plans, and the contractor’s policy stipulated that 

laboratories receiving priority I findings could do no more work for Rocky 

Flats until they had rectified the problem. Of the 118 audits conducted of 

laboratories analyzing Rocky Flats cleanup samples, only 10 priority I 

findings were issued, according to the subcontractor official responsible 

for laboratory audits at Rocky Flats. 

We reviewed the performance of the two primary laboratories that 

analyzed confirmatory samples for plutonium 239 for the four selected 

cleanup areas and found no areas of concern with the laboratories’ quality. 

To limit our review, we focused on two performance criteria: (1) laboratory 

audit findings from DOE’s consolidated audit program documents on alpha 

spectroscopy, which is used to analyze confirmatory samples for 

plutonium; and (2) results from DOE’s mixed analyte performance 

evaluation program, which assesses a laboratory’s analytical abilities by 

3

DOE created the consolidated audit program in response to mid-1990s audit reports that 

cited inefficiency, redundancy, and ineffectiveness regarding DOE audits of analytical 

laboratories. 
Appendix IV

Additional Information on the Quality of 

Remediation Data at Rocky Flats and on 

DOE’s Planned and Actual Verification 

Page 99 GAO-06-352 Nuclear Cleanup of Rocky Flats

sending the laboratory a sample of a known quantity of a contaminant and 

comparing the laboratory’s results with the actual quantity. Our review 

showed that the audit findings for alpha spectroscopy resulted in one audit 

observation.4

 Our review of the second performance criteria of the tests of 

the two laboratories’ analytic ability found that, from 2002 through 2004, 

the two laboratories analyzed a combined total of 16 samples of plutonium 

239, or alpha samples, and received acceptable test results in all but 3. Of 

those 3 samples, 2 samples were considered acceptable but were off by 20 

percent to 30 percent, and 1 sample was not acceptable. 

Additional Information 

on DOE’s Planned and 

Actual Verification 

Activities

DOE revised two of the planned verification activities at Rocky Flats. First, 

due to time and cost constraints, DOE reduced the scope of the 

contractor’s planned scanning and sampling activities. Second, DOE 

revised the Oak Ridge Institute for Science and Education’s (ORISE) 

planned assessment of the contractor’s scans of the 903 lip area. The 

revision incorporated an approach consistent with the Multi-Agency 

Radiation Survey and Site Investigation Manual (MARSSIM). The actual 

verification activities conducted by both the contractor and ORISE 

identified “hot spots” of radionuclide-contaminated soil; these hot spots 

were subsequently remediated. 

DOE Reduced Size and 

Scope of Scanning and 

Sampling Portion of 

Planned Verification

The first part of DOE’s cleanup verification effort—the contractorconducted scanning and sampling5

—was reduced in scope due to time and 

cost constraints. In September 2004, the Rocky Flats site manager 

requested that the contractor develop a sitewide surface radiological 

survey using the Multi-Agency Radiation Survey and Site Investigation 

Manual (MARSSIM). MARSSIM is the outcome of a joint effort by DOE, 

EPA, the Department of Defense, and the Nuclear Regulatory Commission 

to develop uniform guidance for conducting final surveys to demonstrate 

compliance with specified radiological cleanup levels. It recommends 100 

percent scanning of areas most likely to be contaminated with 

radionuclides.

4

DOE was unable to provide source documentation for 1 year for one of the two 

laboratories.

5

Our use of the term “scanning” refers to both stationary in situ measurements taken via 

high-purity germanium detectors and mobile scans taken via sodium iodide scintillation 

detectors.
Appendix IV

Additional Information on the Quality of 

Remediation Data at Rocky Flats and on 

DOE’s Planned and Actual Verification 

Page 100 GAO-06-352 Nuclear Cleanup of Rocky Flats

Scanning can be conducted through use of devices known as high-purity 

germanium (HPGe) detectors, as shown in figure 17, or sodium iodide 

scintillation detectors, known as FIDLERs. These devices can scan entire 

areas to determine whether certain radionuclides are present in a given 

area.

Figure 17: A High-Purity Germanium Detector Can Detect Certain Radionuclides

This scanning approach had been used several times by ORISE at Rocky 

Flats to demonstrate the sufficiency of radiological cleanup of buildings 

prior to their demolition. However, according to the contractor, DOE had 

limited experience using this approach to characterize surface soil and 

sediment. In its October 2004 letter responding to DOE, the contractor 

concluded that applying MARSSIM across the site would cost 

approximately $7.5 million and would take 19 months after the site cleanup 

had been completed. Further, the contractor said that implementing 

Source: DOE.
Appendix IV

Additional Information on the Quality of 

Remediation Data at Rocky Flats and on 

DOE’s Planned and Actual Verification 

Page 101 GAO-06-352 Nuclear Cleanup of Rocky Flats

MARSSIM at the site could constitute a “significant contract change,” and 

could postpone completion of the cleanup. In essence, the difficulty was 

that the MARSSIM approach was inconsistent with the cleanup strategy. 

The approved site cleanup strategy was to remove contamination to a 90 

percent confidence level, meaning confidence that at least 90 percent of the 

contamination had been remediated to agreed-upon levels. In contrast, 

MARSSIM, which was developed years after the Rocky Flats cleanup 

strategy had been approved and begun, recommends applying a 100 

percent verification strategy—that is, scanning areas most likely to contain 

residual radionuclide contamination. Accordingly, MARSSIM was sure to 

find “hot spots”—particularly at the 903 pad and lip area, the extent and 

severity of which would then require investigation and potentially cleanup 

action. Not having anticipated the implications of applying MARSSIM at the 

site, in terms of both cost and schedule, DOE subsequently rejected that 

approach.

In March 2005, the contractor proposed a less expensive, less timeconsuming plan for demonstrating the cleanup’s compliance with the 

cleanup agreement. The plan’s objectives were to verify, with reasonable 

certainty, that no unknown areas of radiological contamination remained at 

the site, that all remedial actions were complete, and that existing sampling 

data remained valid. The verification approach included scanning, 

sampling, and reviewing historical and existing data. Through such 

activities, the contractor intended to increase DOE’s and the community 

groups’ confidence that the cleanup objectives had been achieved. The plan 

purported to exceed the guidance laid out in MARSSIM, although an ORISE 

official refuted this claim. Further comments provided by a contractor 

hired by the Rocky Flats Coalition of Local Governments to provide input 

on the process added to DOE’s concerns and resulted in DOE’s rejecting 

the contractor’s sampling methodology.

The contractor’s final scanning and sampling plan, issued in May 2005, 

included two actions to meet the verification objectives. First, the entire 

site would be scanned with sodium iodide detectors affixed to a helicopter. 

According to the contractor, the detectors would detect, within the top 

several inches of surface soil, gamma rays indicating the existence of any 

residual plutonium that exceeded 50 picocuries per gram of soil, over a
Appendix IV

Additional Information on the Quality of 

Remediation Data at Rocky Flats and on 

DOE’s Planned and Actual Verification 

Page 102 GAO-06-352 Nuclear Cleanup of Rocky Flats

range of 80 square meters—roughly the size of a two-car garage.6 Figure 18 

shows electrical poles that were felled to allow the helicopter to fly as low 

as possible over the site and the aerial scan of the site for residual 

plutonium in surface soil.

Figure 18: Felled Electrical Poles Allow Lower Flight; Helicopter Scans Rocky Flats 

for Residual Plutonium in Surface Soil

Of the 21 community group survey respondents who expressed an opinion 

on the aerial scan, 9 said the scan greatly or somewhat increased their 

confidence in the site’s cleanup. Another 8 said the scan neither increased 

nor diminished their confidence, and the other 4 said the aerial scan greatly 

or somewhat diminished their confidence in the site’s cleanup. 

Another component of the contractor’s final plan was targeted groundbased scanning around the perimeter of previously remediated areas, 

including the perimeter of the major plutonium buildings and the 903 lip 

area. These scans were conducted with a high-purity germanium detector, 

as described earlier. Of the 21 community group survey respondents who 

expressed an opinion on the contractor’s ground-based scans, 11 said these 

scans greatly or somewhat increased their confidence in the site’s cleanup. 

6

The sodium iodide detectors on the helicopter can detect only gamma radiation, which 

does not directly measure plutonium 239/240 concentrations. However, it does measure 

americium-241, which can be multiplied by 5.7 to estimate plutonium 239/240. This 

conversion factor is based on a Rocky Flats Cleanup Agreement Contact Record (an 

agreement among DOE, EPA, and Colorado). 

Sources: GAO; DOE.
Appendix IV

Additional Information on the Quality of 

Remediation Data at Rocky Flats and on 

DOE’s Planned and Actual Verification 

Page 103 GAO-06-352 Nuclear Cleanup of Rocky Flats

Another 7 said the scans neither increased nor diminished their confidence, 

and the other 3 said the ground-based scans greatly or somewhat 

diminished their confidence in the site’s cleanup.

DOE Revised ORISE’s 

Portion of Planned 

Verification to Incorporate 

MARSSIM

The second part of DOE’s cleanup verification effort—ORISE’s review of 

contractor-conducted scans for remaining radiological contamination—

was revised to apply MARSSIM to the 903 lip area. ORISE’s initial plan did 

not incorporate MARSSIM. However, the Rocky Flats Coalition of Local 

Governments’ contractor suggested using MARSSIM at the 903 lip area 

because it had been one of the most contaminated areas. ORISE’s proposed 

final plan included assessing the performance of the contractor’s aerial and 

targeted ground-based scanning and the adequacy and completeness of the 

contractor’s closeout reports for the 903 lip area using MARSSIM. 

Results of the Contractor’s 

Final Scanning and 

Sampling Cleanup 

Verification Plan and 

ORISE’s Independent 

Verification

Both the contractor’s and ORISE’s verifications identified radionuclidecontaminated soil. At a September 1, 2005, public meeting hosted by the 

Rocky Flats Citizens Advisory Board, DOE and the contractor presented 

the results of the contractor’s and ORISE’s verifications. DOE and the 

contractor reported that the aerial scan had identified known areas of 

radionuclide contamination, such as areas where contaminated soil was 

stored pending its shipment off site. (The scan also identified an off-site 

area, but subsequent investigation found no contamination there.) 

However, the aerial scan did not achieve its projected sensitivity. Whereas 

detection of 50 picocuries of plutonium per gram of soil over 80 square 

meters was the criterion for success, according to the contractor’s final 

plan, the scanner achieved this detection level for only 25 percent of the 

site, owing to the moisture content in the ground and the altitude of the 

helicopter’s flyover. They also reported that the contractor’s ground-based 

scan found five areas on the perimeter of the 903 lip area that contained 

contamination in excess of 50 picocuries per gram of soil, which were 

subsequently remediated. 

In addition, DOE and the contractor reported that ORISE’s MARSSIM 

sampling had identified 13 “hot spots,” or areas with contamination above 

the cleanup agreement’s action level of 50 picocuries of plutonium per 

gram of soil. Contamination in these 13 hot spots ranged from 65 to 425 

picocuries of plutonium per gram of soil. However, a DOE official said that 

DOE would not remediate those areas because the regulatory agencies had 

already approved the accelerated cleanup actions, and those actions had 

been conducted in accordance with the cleanup methodology agreed to by 
Appendix IV

Additional Information on the Quality of 

Remediation Data at Rocky Flats and on 

DOE’s Planned and Actual Verification 

Page 104 GAO-06-352 Nuclear Cleanup of Rocky Flats

DOE and the regulatory agencies. The cleanup methodology required that 

at least 90 percent of any given area be remediated to the required levels; 

accordingly, there was a 10 percent chance that areas of elevated 

contamination remained. Even though the cleanup had been conducted in 

accordance with the approved methodology (which allowed for the chance 

of such elevated contamination remaining), DOE’s initial refusal to 

remediate the hot spots caused concern for the Rocky Flats Coalition of 

Local Governments, according to the Coalition’s executive director. Within 

2 weeks, after consulting with EPA and Colorado, DOE agreed to have the 

contractor remediate the hot spots.

Overall, hundreds of samples were taken at the 903 pad and lip area, 

including initial and confirmatory samples. Figure 19 shows 

postremediation (confirmatory) samples taken by the contractor, as well as 

verification samples taken by ORISE. 
Appendix IV

Additional Information on the Quality of 

Remediation Data at Rocky Flats and on 

DOE’s Planned and Actual Verification 

Page 105 GAO-06-352 Nuclear Cleanup of Rocky Flats

Figure 19: Confirmation and Independent Verification Samples Taken at the 903 Lip Area

Note: This figure does not show the samples taken on the pad itself (the white square at the left). 

According to a contractor official, so many samples were taken within the pad that a depiction of them 

would appear as a solid mass.

Although DOE had agreed to ORISE’s final independent verification plan, 

DOE did not have ORISE fully implement the plan, and it did not publicly 

explain its reasoning. Specifically, DOE did not have ORISE complete the 

planned assessment of the aerial and ground-based scanning or the planned 

assessment of the contractor’s investigations of the results of the aerial and 

Source: DOE.
Appendix IV

Additional Information on the Quality of 

Remediation Data at Rocky Flats and on 

DOE’s Planned and Actual Verification 

Page 106 GAO-06-352 Nuclear Cleanup of Rocky Flats

targeted ground-based scans. According to a DOE official, DOE decided 

that the results of these remaining assessments would not justify their 

completion, particularly because the aerial survey had failed to find any 

anomalies.

Of the 20 community group survey respondents who expressed an opinion 

on ORISE’s soil sampling and surface scans (using a FIDLER—a sodium 

iodide scintillation detector), 16 said the scan greatly or somewhat 

increased their confidence in the site’s cleanup. Another 2 said the scan 

neither increased nor diminished their confidence, and the other 2 said the 

aerial scan greatly or somewhat diminished their confidence in the site’s 

cleanup.
Page 107 GAO-06-352 Nuclear Cleanup of Rocky Flats

Appendix V

Comments from the Department of Energy ApendxiV
Appendix V

Comments from the Department of Energy

Page 108 GAO-06-352 Nuclear Cleanup of Rocky Flats

Page numbers in the draft 

report may differ from 

those in this report.
Appendix V

Comments from the Department of Energy

Page 109 GAO-06-352 Nuclear Cleanup of Rocky Flats
Page 110 GAO-06-352 Nuclear Cleanup of Rocky Flats

Appendix VI

Comments from the Department of the 

Interior ApendxiVI
Appendix VI

Comments from the Department of the 

Interior

Page 111 GAO-06-352 Nuclear Cleanup of Rocky Flats

Page numbers in the draft 

report may differ from those 

in this report.
Appendix VI

Comments from the Department of the 

Interior

Page 112 GAO-06-352 Nuclear Cleanup of Rocky Flats
Page 113 GAO-06-352 Nuclear Cleanup of Rocky Flats

Appendix VII

Comments from the Colorado Department of 

Public Health and Environment ApendxiVI
Page 114 GAO-06-352 Nuclear Cleanup of Rocky Flats

Appendix VIII

Comments from Kaiser-Hill Company L.L.C. ApendxiVI
Appendix VIII

Comments from Kaiser-Hill Company L.L.C.

Page 115 GAO-06-352 Nuclear Cleanup of Rocky Flats
Page 116 GAO-06-352 Nuclear Cleanup of Rocky Flats

Appendix IX

GAO Contact and Staff Acknowledgments ApendxiIX

GAO Contact Gene Aloise, (202) 512-3841 or aloisee@gao.gov

Staff 

Acknowledgments

In addition to the contact named above, Dan Feehan, Assistant Director; 

Keith Rhodes, GAO’s Chief Technologist; Claire Cyrnak; Glenn Fischer; 

Tom Kingham; and Pam Tumler made significant contributions to this 

report. Others who made important contributions included Kevin Bailey, 

Michael Derr, Doreen Eng, Tom Denomme, Tim DiNapoli, Alison O’Neill, 

Judy Pagano, Kim Raheb, and Omari Norman. Also, Brandon Haller, 

Mehrzad Nadji, and Judy Pagano made important contributions to the 

methodologies used in this report.

(360559)
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