Free Statement of Facts - District Court of Federal Claims - federal

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EXHIBIT 27

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Rockwell~nternational
July 7, 1989 S. F. lacobellis D/710 001-All Aerospace Operations El Segundo
BJ, JBJECT ¯ NO FROM

"D. O. Sanchini ¯ RockyFlatsPlant ¯ ROK 024 ¯ (303) 966-436l

ROCKYFLATSPI_~J~I BI-~EEKLY STATUS REPORT

This reportis the first of a. seriesof bi-weekly statusreports covering initiatives and accomplishments, information and DOE support of Rockwell operations the DOE, RocKYFiatsPlar,t in Golden, at Colorado. The reportwas suggested AdmiralWatkinsin the June 23, by 1989 meetingwith Don Beall and Sam lacobellis. requested him, a As by copy of this reportis to be transmitted AdmiralWatkinsthroughthe to DOE, Rocky Flats OfficeManager, S. Goldberg, E. .The Admiralhas encouraged Rockwell solicithis assistance, to where appropriate, to help solve institutional problems. INITIATIVES MiD ACCOMPLISHMENTS On June 27, 1989, Chairman and ChiefExecutive Officerfor Rockwell, D. R. Beall,established Rocky FlatsOverviewBoard to enhancesenior a Rockwell management visibility into all aspectsat the Rocky Flats Plant.Meetingsof the Board will be held monthlyor as called by the Chairman, F. Iacobellis. S. The first meetingof "the Overview Board was held at Rocky Flats on June 29, ]g89..The next meetingwill be held July 26, ]989 at the Rocky Flats Plant.The meetingagenda will consistof presentations RockyFlats Specialists the statusof by on health,safety and environmental programs.In addition, the Overview Board will reviewthe findings resulting from the Rocky Flats Task Team reviews. On June 27, 1989,S. F. lacobellis, President, Aerospace Operations, established RockyFlats Waste Management a and Environmental Protection Task Team as an advisorybody to the President, Rocky Flats Plant. The Task Team will make independent assessments the subjectareas and in reportfindings and recommendations the President, to RockyFlats Plant and to the President Aerospace of Operations¯ The Task Team also met at the RockyFlatsPlant for a full day reviewon June 29, 1989 along . with S. F. lacobellis, W. Jeffs, Executive 6. Vice President for Strategic Defense& Technology, W. Bohlen,St. Vice President, R. Operations, and T. D. Sumrall, Vice President, Human Resources¯ Presentations were made by RockyFiats Specialists and preliminary recommendations were addressed areas of waste and environmental in

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S. F. lacobe11i.s Page 2 Ouly 7, 1989

protection. July 6, Ig8g, Dr. D. C. Gibbs,the Task Team Chairman, On was at the Rocky Flats Plant to reviewplans with Plant Management for the Task Team activities. is plannedthat the Task Team will meet It at Rocky Flats at least two full days of-every week, starting the week of July 10, 1989. Dr. D. C. Gibbs,~. J. Roberts, J. Bjorklund, A. and E. A. Centerfrom the Corporate Rocky FiatsTask Team and S. F. Iacotellis and D. J. Sanchinimet with PRHP/DOEProjectManagerDon Riley and senior representatives from LANL, including Paul Cunninghzm, discussthe to need for integration the Pu RecoverySpecialists of from all agencies into the PRMP management team. Furtherdiscussion~ were held on July 5, 19B9 with Don Riley, Paul Cunningham and Dom Sanchini. Resolution of this problemis expected July 10, ]989. by In responseto a DOE findingthat DOE visitor's dosimeters were being returned required the completion a visit,an as at of investigation undertaken determine uas to the reasonfor this problem. That reviewfoundthat the DOE at RockyFlats had undertaken the responsibility obtaining for visitordosimeters from Rockwell and issuingthem to their visitors afterthe visitorsigneda form noting acceptance and the responsibility returnthe dosimeter leaving to on the site. To avoid any future problems, however,a new policy has been issuedinitiating improved an systemfor returnof dosimeter badges afterthe completion the visit to Rocky Flats(see attachment). of Production delivery requirements the monthof June ~ere for accomplished ~ith I00 percentperformance. INFORMATION The DOE has requested that the 1601 cubic yard RCRA TRU mixed ~aste storagelimit be viewedas a "TechSpec" ~hichwill not be exceeded. The letterdirectsthat Rocky Flats Plantoperations shutdown be 120 days prior to reachingthe 1601 cubic yard limit.This period,of low wastegeneration, wouldthen allowDOE time to searchfor alternative storageor shipment plans. In order to utilizefullythe TRU mixedwaste permitted spacewithin buildings, certainchanges(such as higherstacking) are necessary and requireapprovals (criticality, safety). Preli~irary estimates are %hat with minimumstacking, the existing building space will be full in December I98g;~ith optimumstacking, the buildin~'s ~ill be full by approximately ~arch 1990. Rockwell Criticality and SafetyEngineers are in the processof determining the levelof optimumstacking that can be allowedin the storageareas.

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S. F. lacobellls Page 3 July T, 1989

The Government investigators conducting the search left plant site on June 24, 1989. Since that date, at the requestof the U. S. Attorney, Hike Norton,a FederalDistrictCourt has authorized specialgrand a jury to be empaneled AugustI, ]98g to considerthe Rocky Flats on Government investigation. The Rocky Flats Plant Waste Characterization Plan, ~hich was originated in late 1986, will now be revisedto reflectthe elimination some of waste streamsand the introduction Bew processes. of DOE Oversight Teamsare at Rocky Flatsconducting cc.mprehensive environmental audits. Althoughno officialfinding~have been released, the preliminary indications from Ed Goldberg, of June 30, as 1989, are that there are no ~show stoppers"being uncovered. status A report debriefing was presented Dom Sanchinion.July7, ]g~9 by the to DOE Team LeaderHark Gilbertson. A team of approximately personnelfrom DOE, Headquarters, six arrived on site July 5, 1989 to conductan audit of Rocky Flats Plant Compliance with the National Environmental Policy Act (NEPA). On July 5, 1989, E. S. Goldberg wrote a letterdesc'ribing unsafe practices DOE had witnessed outsidework of excavation on and construction platforms. of Rockwell~as directedto halt construction jobs of this nature until the Rocky Flats Officewas assuredthat the work could be accomplished a safe manner. The Safety,Support in Organizations the major onsiteconstruction and contractor, A. J. Jones,met and developed plan which was presented DOE on the next a to day, July 6, 1989. With modifications suggestedby the DOE and a resubmittal July 7, 1989, Rockwell on was authorized restart to construction projects July 10, 1989. on DOE SUPPORT On June 30, Igsg, Rockwell submitted requestfor supplemental 8g a FY and FY 90 fundingto supportthe agreement betweenDOE and the State of Colorado concerning health,safety and environment~1 actionsand the additional effortrequired supportof the continuing in Government investigation. This proposalrequestedimmediate approvalof approximately personnel SO and $6.5M for FY Bg alo~e. On July B, IgBg a p~oposalfor additional capitaland expensefunding was submitted for near term improvements Health,Safety& in Environmental Programs supportof Secretary in Wat~ins' ten point initiatives. The initialrough order of magnitudeestimates for FY 'gO

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S. F. ]acobellts Page 4 July ~, 1989

includethe need to add approximately 1,000 personnel, and add funding of - $200M in operatingexpense~nd - $I75M in capital.Improvements recommended includemajor items such as accelerated trainingto meet requirements the yet to be releasedDOE 5480.XX,improvements of in operational suretyto providedisciplined operations such as existsin commercial nuclearreactorfacilities, increased operations Pu in recoveryfacilities reduceresiduebacklog, to continued acceleration in environmental restoration and waste reduction and an accelerated programto reducemaintenance backlogand improvepreventive maintenance. Since January,]989 we have been submittlng montFlyreport a identifying the employeesat Rocky Flats awaitingDOE clearances. As of July 5, ]989, there are 207 employees awaiting clearances, of 80 which are over eight months.In addition, expedit(~clearances will be requested for C. Harff,R. Reisenweber and J. Tuckerto supportthe Overview Boardand Task Team efforts. A major effortin June has been the acceleration-~ the schedule o for the cleanupof the BBI hillsidearea. The environmental assessment (EA) was recently revisedto incorporate DOE, Albuquerque comments and submittedto DOE, Headquarters for approval.Once the required approvalis obtained, the EA will be issuedfor a 30-daypublicreview and comment period.Then, if a "findingof no significant impact" (FONSI)can be issued,construction for cleanupcan begin. The target construction startdate is September, 19Bg. DOE has issueda letterprohibiting use of the Building 771 Plutonium RecoveryIncinerator until a DOE nuclearsafetyreviewis completed and DOE performs Operational an Readiness Review"with emphasis the on ~ issues identified the reportby the DOE specialteam... The issues in includepotentially upgrading the incinerator RCRA standards to which may not be feasiblewith the existingunit. RFP generates approximately ~rumsof combustible 50 residueper monthwhich are processedby the incinerator. This order will adc to the inventoryof approximately 4~O~drums residuecurrently storage(650 contain of in the typeAbfjmateF~Fals whichcan be incinerated).

Rr.~ident
Eric. CC:

Do R. Beall - Rock~ell, Corporate, E1Segundo E. S. Goldberg DOE, RFO Rocky Fl~tsOvervie~ Board Rocky F~o ' ....

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EXHIBIT 28

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United States Govemr~en~I

C)epartment Energy of Rocky Fiats Office

August17, 1989 OAMO:GJW
SUBJECT:

Bi-Weekly Reportfor RockyFlats OFfice John Lo Meinhardt, Actg Asst Secretary for DefensePrograms, DP-1, HQ Operations the Building374 evaporator of have not resumed.Plant processwastewater ~hat feeds the evaporator currently is being held in storagetanks, capacitywill be depletedin approximately days, The 6 laundrywill be the First affected facility requiredto be shut down if the regulatory issue~remain unresolved. the regulatory In environment of the RCRA,the Building 374 evaporator a hazardous is waste treatment facility, all produc~s whichare technically of considered be hazardto ous wastesuntil the regulatory authority formal~y.removes products the from the list of hazardous wastes associated with that facility, At issue is the subsequent reuse and discharge RFP of the distilled by water producedby the evaporator, the contextof RCRA, the distilled In water reuse and discharge activity technically would constitute discharge of hazardous waste, Today~we receivedword from the ColoradoDepartment of Health(CDH)thatthe State had no problemwith our restarting the evaporator. The regulatory issuesremain~however,and RFO will meet with EPA and CDH staff next week to agree on a course of action.Based on this interimagreement with CDH, we plan to restartthe evaporator as soon as possible, Installation the supercompactor Building of in 776 has been curtailed. Construction activities are to be suspended until an approvedEnvironmentalAssessment completed° is Jonathan Lindgren, Legislative Assistant Congressman to Skaggs(CO), visitedthe Rocky Flats Plant on August 16~ 1989. His visit consisted of both privateconversation briefings and from RFO and Rockwell upper level management topicsrangingfrom Rocky Flats Plant solid and liquid on wastesprograms, radiation protection, effluent monitoring, environmental monitoring and the healtheffectsof radiation employees. addition on In to the abovementioF:ed briefings, drivingtour of the plantwas cona ducted=Specificplant areas that were visited included:the B81 hillside,solarponds,(!rainage pondsand otherareas that have environmental concern. The plannedencirclement demonstration Rocky FlatsPlant on August6 at drew approximately 4200 people,This demonstration was coordinated by the ColoradoFreeze Voter group° Upwardsof 17~000would be neededto

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completethe circle around the plant. Sunday'sdemonstration was peaceful; there were no arrests,and by about4:00 pm most of the crowd had left the area. All demonstrators remainedoutsidethe Federal reservation° EdwardGoldberg and RFO staff met with the Governorof Colorado and Colorado Department Healthstaff on August10 at the StateCapitol. of The topic of discussion ~as Stateinformation supporting Noticeof a Violation characterizing storingcertainclassesof materials in and containing recoverable quantities plutonium. of The State is asserting authority for regula;ion under provisions the Colorado of Hazardous Waste Act all residues tha;: are not in-process secondary materials and which possesshazardous wa:~techaracteristics containlistedhazardous or materials. The Criticality SafetyAssessment Team held their closeout meetingAugust 11 with the RFO and Rockwell° Thelr study is not yet complete; some recordsand files need to be retrieved and analyzed.In examining severallines of evidence, the Team concluded that there is no evidence of past nuclearcriticalities Rocky Flats Plant.With respectto the at currentstatusof criticality safety,the team concluded that, "Thereis no threatto publicsafetyfrom accidental criticality currentoperain tions of the plant°However,plutoniumwas found in situations that requireimmediate attentionby the contractor. Also, there are safety practices that shoul~ be corrected promptly." Roger Mattson,Team Leader~briefedthe ~overnor's Aide~ Tim Holman,on the afternoon of 8/11/89o

GC~

J. R, Ro B. R° R~

Tuck, S-3, HQ W. Starostecki, EH-30,HQ Eo Erickson: DP-23,MQ 8° Twining, OOM, AL P. Berube,EH-20,HQ W. Barber,EH-34~HQ

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EXHIBIT 29

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.United, States Government

Department of Energy

OAT~: July 21, 1989
REPLYTO

A~rN OF:

MA-512

SU~ECT:Reporting Relationship RockyFlatsArea Office TO:

BruceG. Twining, Manager, Albuquerque Operations Office E. S. Goldberg, ActingAreaManager, RockyFlatsArea Office Effective immediately, AreaManager, the RockyFlatsArea Office, will report to the Assistant Secretary for DefensePrograms. This actionis a follow-up of th~ decision made June 6, 198g,when the Area Manager was temporarily reassigned reportdirectly the UnderSecretary Energy. to to of In assuming line management oversight the RockyFlatsAreaOfficeand of relatedfacilities, Assistant the Secretary will be accountable on-going for operations. is expected It that implementation actionsaffecting the Rocky FlatsFacilities whichalreadyhavebeen approved willcontinue without interruption.

John C. Tuck UnderSecretary

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EXHIBIT 30

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OFFICIALUSEONLY
U. S. Department of Energy Albuquerque Operations Office

AWARD FEE PERFORMANCE EVALUATBON REVIEW E~OARD RECOMMENDATION FOR THE PERIOD: October 1, 1988 Through March 31, 1989 CONTRACT = ACO4 o 76DP03533 DE

ROCKWELL INTERNATIONAL CORPORATION ROCKY FLATS PLANT

Charles Troell E. Assistant Manager ManagementAdministration For & Chairman,Pedormance Evaluation ReviewBoard

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PERFORMANCE APPRAISAL ROCKWELL INTERNATIONAL CONTRACT NO. DE-AC04-76DP03533 FOR THE PERIOD OCTOBER I, 1988 - MARCH 31, 1989

The overall performance of the~ntractor has been maintained at least at a level of "Satisfactory" during the appraisal period. The following is the Performance Evaluation Review Board recommendations for the Functional Performance Areas (FPA's) selected for evaluation. The first section covers plant operations while the second section covers Plutonium Recovery Modification Project (PRMP)/Plutonium Recovery Option Verification Exercise (PROVE). The General Management FPA was evaluated considering performance for both areas. PLANT

FPA:

GENERAL MANAGEMENT Grade: EXCELLENT

Adjectival

Noteworthy Achievements I. Significant improvement has been made simultaneously in many important plant functions during the appraisal-period. These improvements are covered in more detail in the FPA's for Environment, Safety and Hea]th (ES&H), Production Operations, Non-Weapons Qua1~ty, and Chemical Operations. Most notable is the achievement of exemplary standards for operations in Building 771. These standards were achieved on compressed schedules while m~intalning the other plant activities. While continued improvement is sought, Rockwell has done a remarkable job of pushing for and achieving recent improvements under extreme pressure. 2. Interplant schedule compliance continued at 100% for the third consecut2ve rating period. This performance was achieved despite mater2al supply ]imitations generated by the shutdown of Building 771. 3. Rockwell achieved a rapid resolution to the problem of obtaining U. S. Department of Transport@tion (DOT) approval for using a modified ATMX railcar ~for shipping the first shipment o~ Transuranic (TRU) mixed waste in 1989 from the Rocky Flats Plant (RFP) to the Idaho National Engineering Laboratory. Several obstacles existed, both within the Department of Energy (DO~ and DOT, to the granting of appropriate approvals. Due to Rockwell's persistence, the approval was granted for use of the modified ra~lcars at the time proposed by DOE. 4. The Emergency Preparedness Organization was credited in the December 1988 Safety Performance Review wlth having a "...well planned, and effective program Inmeeting emergency readiness needs." In addition, Rockwell's emergency preparedness personnel have sustained a high level of participation in Albuquerque Operations Office (AL)-wlde emergency preparedness coordination

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activities, have supported the development of the AL emergency preparedness appraisal program in a significant manner, and have continued to identify and implement improvements in Emergency Operations Center capabilities and operations. 5. More than 60% (47,000 hours) of the maintenance work order backlog older than 90 days has been worked off. A team of 50 people, under the Rockwell "We Do Care" program, was established for this purpose. 6. Rockwell has already exceeded the I0 year (1986-1995) Energy Conservation Goal of a 10% reduction in energy usage. 7. Rockwell has completed the development and installation of the Personnel Evacuation Logging System in all major production and support buildings. This enhances the security and safety of the bu~~dlngs serviced and provides a data base for emergency actions in specific areas. Notable Deficiencies None Observations I. The Management Oversight Group (MOG) reported needed changes in the management of the PRMP by Rockwell. A Precursor Program has been established with the DOE Project Manager to address the MOG concerns, and significant progress is being made. Further improvements are necessary by Rockwell for this high priority DOE project. 2. The redefinition of the Building Manager responsibllties has been a visible action which has enhanced the integration of functions. The Building Manager position is functioning to exercise responsibilities for all activities in the building. Development of an "in-house" safety program in Production Operations is evidence of the success that can be achieved by Building Managers. The Building Manager position should be further strengthened and supported to insure complete integration of all act~vitles necessary for safety, quality, maintenance~ training, security, and production. 3. The shutdown of production and maintenance activities in Building 771 from October 1988 to January 1989 resulted in a significant impact to plutonium recovery schedules, as well as a slip in ongoing maintenance and facility upgrade schedules. With the exception of electrorefining, Rockwell is significantly behind recovery schedules established at the beginning of the fiscal year. This was the penalty for the shutdown made to correct safety problems. Rockwell's development of a comprehensive plan for plant=wlde application of Building 771 Restart Criteria should continue vigorously. The plan reviews each of the 771 Restart Criteria for potential applicability to other areas on plant site, recommends items that should be implemented, determines the status of each item, determines rough order of magnitude of resources and manpower requirements, and finally recommends an action plan and management scheme. This effort will help preclude future shutdowns and resultant lost production. E 002276

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4. Training of waste generators and improved generation practices have reduced the quantity of reJ.ect waste drums, a major contributor to reducing the supplied air operations in the Size Reduction vault. 5. Rockwell has not made TRUPACT II container when modifications to Building of the budget request was adequate progress to prepare for utilization of the it becomes available. The final definition of 664 for handling TRUPACT II containers and sdbmittal not completed in a timely manner.

6. The identification and timely resolution of problems by Rockwell is often slow. Examples include pondcrete storage monitoring, ana]ysis of National Pollutant Dlscharge Elimination System (NPDES) violations, complete dissemination of incident information within Rockwell, and TRU waste storage data. For example, in October the Governor of Idaho curtailed shipments to Idaho of TRU waste from Rocky Flats. The curtailment resulted in an immediate need for information on the TRU mixed waste at Rocky Flats available for shipment. The time required to obtain accurate information on the types and quantities of stored waste was too long for an issue of this importance. 7. Rockwell has recently violated DOT regulations on two shipments to the Nevada Test Site (NTS) (RF890154 and RF880951). One involved miscounting number of waste containers on a shipment to the NTS on 9/3/88, and the other involved incorrect drum numbers (due to exchange of a drum which was listed on. the bill of lading with a drum which was not listed on the bill of lading) on 1/17/89. 8. Despite the knowledge that nitrate concentrations on the 750 pad have increased, little action has been taken to contain sa]tcrete (which has been identified as a major contr~butor to storage pad nitrate concentrations) after precipitation events. Data provided in March of 1989 lh~dJcated the highest nitrate concentrations ever observed on the pads. 9. Rockwel] is still not placing sufficient emphasis on the timely establishment of the Rocky Flats Institute. The DOE considers this program, along with the Rocky Flats School, to be essential to enhancing the capabilities of building management personnel at Rocky Flats. I0. The Waste Isolation Pilot Plant Waste Acceptance Criteria Committee performed an audit on Rocky Flat's TRU waste activities. The posltlve results of this audit reflect diligence in waste analysis and quality assurance in packaging. iI. Several waste minimization efforts have led to reductions in waste produced. The most dramatic effort has been the waste paper recyc]~program whlch has exceeded all expectations for the quantities of waste paper recycled. This has the added benefit of extending the useful llfe of the sanitary landfill.

E 002277

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FPA: COST MANAGEMENT Adjectival Grade: EXCELLENT Noteworthy Achievements i. Rockwell performed well in providing data and narratives to define DOE's unfunded ES&M requirements in support of a FY89 supplemental budget request. A significant portion of this data was used to support DOE requests to Congress for additional FY90 funding. 2. Rockwell has done an extraordinary Job of tracking information and preparing responses to a large variety of budget information requests and of maintaining the current status of its requirements, The quality and conslstency of information provided to the DOE has been exceptional considering the number of different funding options that have been addressed. Support provided for the on-slte DOE review of requests for additional funding was excellent. 3. Rockwell construction project data.sheets and conceptual design reports supporting its requests for the FY91/92 Capital Budget were of high quality and were completed ahead of schedule. Rockwell is well prepared for DOE Headquarters reviews of FY91 projects. 4. The FY91 budget narratives were improved and expanded by Rockwell. Detailed identification of program cost growth and impacts of Production and Surveillance target guidance was par~~c9]arly helpful in DOE's analysis of Rockwell's resource requirements. Notable Deficiencies None Observations i. Rockwell's SACNET submission of budget schedules was late and its PY88 Schedule I and 2 actual costs were late and were also inaccurate in regard to New Material Flight Tests/Stockpile Flight Test~ and New Mater~al Laboratory Tests/Stockpile Laboratory Tests costs. 2. In deciding on final General Plant Project (GPP) allocations for the year, AL has reviewed the status of committed funds, The larg~ dollar amount of unco~itted funds has adversely affected the support for the plant's FY89 GPP requirements. 3. Rockwell continues to be responsive to OCAD requirements and initiatives including indirect Cosi Management, the Work Load Model initiative and Baseline Cost Management (particularly the W 89 Cost Call). Although Indirect Cost Management packages were submitted late, the quality of the packages was very good. E 00Zp'7 8

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Adjectival Grade: EXCELLENT

Especially Noteworthy Achievement The Non-Weapons Quality Assurance (NWQA) surveillance activities conducted during the Building 771 restart have been especlally noteworthy in that they have resulted in the identlflcat~on of and provide for corrective actions necessary for a more viable quality program. This early detection and correction of deflclencJes in operations will provide for a greater assurance of.the quality of our product. Noteworth~ Achievements

I. After two years of accomplishments, the continual improvement in the Rockwell Quality program has leveled off. As anticipated, a new phase of the Quality Improvement Plan is currently being implemented. This new phase is now being referred to as Phase 2 and will incorporate a new culture in quality practices. Rockwell has aggressively entered into Phase 2 with a Program Manager and a Continual Improvement Steering Committee to guide the effort. The steering committee is further supported with technical personnel, one being closely associated with Dr. W. Edward Demlng. 2. Significant progress has been made towards imp~ementlng the NQA-I Standard at Rocky Flats. The NWQA program office now has three reporting managers with established responsib~lltles. The Management Plan has been updated-and II new positions added to the NWQA office. The Plant Level Control Systems portion of the implementation plan is divided into four parts and ~s mostly in place. Also, a manager has been assigned to facilitate the implementation of the Non-War Reserve (WR) Calibration Program. Q~a]ity personnel associated with procurement of needed services and commodities for the plant, within the Quality Directorate and outside the Quality Directorate, have recently been reorganized into one group within the NWQA program office. This reorganization should increase the consistency of Non-WR and WR procurement activities. 3. Because of his exceptlonal attention to detail, a technician in the Nondestructive Testing (NDT) Department was able to have defective material that was received from Pinellas removed from the production llne before it could be further processed into the system. During a routine NDT examination of a Rocky Flats production process, the technician detected a suspected anomaly in a reservoir while evaluating X-ray film of a weld Joint performed at Rocky Flats. After sectioning the suspehted unit, it was learned tha~ a weld, unrelated to the Rocky Flats weld, had been completed unsatlsfactorily at the Pimellas Plant. The unsatisfactory weld was not detected during ND~ at Pinel]as and was accepted and forwarded to Rocky Flats for continued processing. The discovery of this defect is very praiseworthy because the Rocky Flats N~T set up was not optimized to evaluate the Pine]las weld Joint. The alertness, attention to detail, atti~ude, and discipline shown here depicts a work ethic that ensures a quality product.

E 002279 5

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Deficiencies In three incidents~ Rockwell failed to provide the necessary measures to adequately control nonconforming product material. I) During the period, it was discovered that Rockwell had cancelled deviation for a nonconforming component that had been properly deviated when accepted and released from Rocky Flats in FY88. Rockwell also failed to notify all affected DOE organizations that this action had taken place. 2) Five reject components were mistakenly accepted and released from Rocky Flats into the complex and subsequently had to be retrieved. 3) An acceptable reservoir was mistakenly reworked for defectiveness. A defective reservoir was then mistakenly accepted without being reworked and shipped to the next user. The analysis of these incidents revealed that all these errors happened either from a breakdown of an existing system or that an inadequate system was in place. Observations I. The DOE is concerned with the low level of quality performance being displayed by the beryllium supplier. Deficiencies such as lack of subcontracting controls, poor manufacturing instructions, and failure to identify root causes of nonconformances were identified in a recent Rockwell survey of the beryl]ium supplier. Beyond these findings, a recent DOE, AL survey of the beryllium supplier found that the supplier's configuration management and product traceability systems were also operating poorly. 2. Approximately 272 Quality Assurance Survey (QAS) 2, 3 and 4 surveys were conducted during the period resulting in 55 complimentary observations and 66 findings. However, all II QC-I elements were evaluated to be satisfactory or better. Four findings were considered to be significant. Three findings involved paperwork problems and the fourth was assigned for a part which failed the DOE verification inspection of the component. No findings were identified in two of the QC-I elements and no negative trends were identified. 3. Rockwell continues to make excellent progress towards implementing the complete Quality Information System. Shortly, the f~fth module will be complete. Three additional modules are planned and scheduled to be complete during FYgo. 4. Duplicate serial numbers have become an issue during the performance period. Three DOE plants have identified product from Rocky Flats with serial numbers which have been used twice. After significant investigation by the DOE and Rockwell, it has been found that only a small quantity of the identified serial numbers have actually been duplicated. The resolution of this issue will be completed in a future meeting between contractor, design agency, and DOE personnel. E 002280

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FPA: CHEMICAL OPERATIONS Grade: EXCELLENT Achievements Adjectival Noteworth7

I. The Plutonium Operations effort to implement an Operational Readiness Review (ORR) program is excellent. Progress toward implementation has been demonstrated through ORR's for the Building 771 Incinerator, Part V, and the Dicesium Hexachloroplutonate (DCHP) Molten Salt Extraction (MSE) processes. These efforts support the top priority goal for excellence in facility operations and should be further.developed and continued on a plant-wlde bases. 2. Rockwell has successfully c0mp]eted the development of a new extractant compound for use in the MSE process. Diceslum Hexachloroplutonate has the advantage of substantially reducing the gamma and neutron exposures to MSE operations personnel, eliminating magnesium contamination of the product plutonium buttons, and increasing the efficiency of the process to a single pass process. These last two changes also reduce the recycle residues produced. Th~s development work was performed concurrently with the Building 771 shutdown, safety improvements, and the Building 771 restart activities. Notable None Observations I. DOE intends to evaluate the productivity of Chemical Operations in terms of Base Recovery Units (BRU's). Using this approach, Rockwell appears to regaining productivity while concurrently executing new safety requirements. Because of the Building 771 shutdown, the most current metal production period was only three months in length. A comparison of that production period was made against the two previous periods as shown below: Period July 86 - July 87 Aug 87 - June 88 Current Months 13 II 3 %Change Base -12% +8% ~ --Base +22.6% Def~ciencles

When using the 13 month period as the base for comparison, the efficiency of recovery for the three month period increased by 8.0%. Using the ii month period as the base for comparison shows an increase in efficiency o~ 22.6% for the three month period. In the first comparison, the 12% drop for the ii month period resulted from the initiation of ES&H and facility upgrades. The "*dramatlc improvement seen when comparing the three mo~th period against the ii month period as base reflects an adjustment to the new ES&H requirements and increased efflciencles resulting from facility upgrades.

E 002281

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2. The establishment of a Se~f-Assessment Audit Program in Building 771 has enabled Rockwell to take a proactive role in identifying and correcting housekeeping and safety concerns. The emphasis on immediate corrective action and recurrence control is a positive step toward implementing the surety of operations concept in Building 771. Rockwell's vigorous proactive self-assessment efforts in Building 771 are to be highly con~nended and encouraged throughout the plant-slte. 3. The Building 771 Contamination Control Committee has continued to work at determining the root cause of mechanical and administrative failures which ]ed to contamination incidents. New decontamination methods, new anti-contamination clothing, safer work methods, trend analyses, and engineering enhancements are all measures being utilized by .the Committee. During the last six months, there has been only one possible inhalation case which was confirmed as negative. In addition, the number of contamination incidences appears to be staying how as production increases under the Restart Plan. However, further reductions in the number of contamination incidences are necessary. 4. Identification of process information has promoted identification of process shortcomings. Further an@]ysls requires instrumentation, which has been delayed in some cases by the Building 771 shutdown. Continued process improvements through the Recovery Improvement Program add Process Technology Development support have also been impacted by the shutdown and some shifts in goals. However, there is still a need for continued efficiency and process improvements and these programs should be rsvlta]ized in some form. 5. Rockwell has successfully completed initial experiments with an electrolytic decontamination technique for use on fixed contamination on stainless steel and some other metals. The technique, coined electrodecontamination, has been highly successful on flat stainless steel surfaces in the first few trials. Further development of this technique for the decontamination of large surface areas, uneven surfaces and welds, without detrimental effects to the equipment decontaminated, would constitute a significant achievement. 6. The development of a budget planning process for chemical operations is considered to be essential to the improvement of the efficiency of the plutonium recovery processes, increased metal purity, decreased residue recycle, and waste minimization. To date, Rockwell management has provided excellent support for establishing a budget development process. However, it is essential that Plutonium Operations line management provide a leadership role and be involved in the entire budget development process, not Just provide support to the budget development process. ~

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FPA: PRODUCTIO~ OPERATIONS Grade: OUTSTANDING

Adjectival

Noteworthy Achievements I. The number one priority for this period has been excel]en6e in facility operations. The effort toward development of a Nuclear Facility Operations Manual (NFOM) dlrect]y supports the facility excellence goal. The NFOM Task Team has drafted and approved all procedures for the NFOM based on the original outline. The Task Team is commited and has an appropriate mix of members to insure a balanced perspective. With continued emphasis, this effort is expected to create a model document for the AL complex. 2. Rockwell has been very supportive of the AL effort to develop an Operational Surety Program. They have actively participated in meetings, presented briefid~s on request, and provided documents for application by other sites. Rocky Flats Plant is currently recognized as a leader in Operational Surety within AL. 3. Rockwell has taken several steps to reduce work in process inventories and process times. Among these are: a. Reduced planned process times by approximately 25%"across the board" in the production control system in Building 460. The result has been roughly a 50% reduction in work in process inventories in the building, measured by the number of components. b. Reduced pit assembly process time in Building 707 by six weeks, eight weeks total to two weeks. c. Reduced lot sizes approximately 24 to.reduce Notable Deficiencies on the 3T bodies backlogs at the from four approximately and five axis 50 to mills. from

Observations I. Utilization of direct labor, as measured by productive time, efficiency, and realization, has declined during this period. This decline is a result of changes required to implement new plant safety procedures. Rockwell's Industrial Engineering Group has conducted a study of possible approaches to improve labor utilization. In the long term, utilization should improve as experience is gained in the new operating procedures, and as the emphasis on training results in yield improvements. In addition, greater safety consciousness should result in fewer process interruptions.

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2. Rockwell has responded effectively to DOE's Inltlat~ves on make or buy policy. Rockwell will soon be submitting their revised Capability Maintenance Plan, now called the Make Or Buy Plan, and the supporting Baseline Capability Plan. They have also complied with the requirement to submit a "Buy Rate" calculation. The calculation for the first quarter in FY89 showed that the buy rate declined in comparison with FY88, but this is attributed to the "buy ahead" of a slgnif~cant quantity of beryllium parts in FY88. 3. During March, Rockwell hosted a seminar to share information on their experience in el~mlnat~ng halogenated solvents. Thlrty-two representatives from 12 corporations attended. Feedback was positive and enthusiasm was expressed for continued information exchanges. This seminar was a constructive first step in the program for technology transfer from Rocky Flats to private industry and has significant potential for building a positive image for Rocky Flats within local communities.

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FPA: -ENVIRONMENT~ SAFETY AND HEALTH Adjectival Grade: .GOOD Noteworth~ Achievements

I. Rockwell has made slgnif~cant progress towards achieving a high qua]ity radiation protection training program for Radiation Monitors which meets the requirements of DOE 5480.11. Other significant initiatives in radiation protection training have also occurred during this period, most notable being a new pilot radiation safety course for Radiation Worker Supervisors and plant Building Management. Rockwell has successful]y completed many improvements and started several new initiatives above and beyond the DOE requirements in their radiation protection training programs. 2. Rockwell has demonstrated responsiveness in the preparation and coordination on National Emissions Standards fop Hazardous Air Pollutants (NESHAP) issues specific to the RFP. Rockwell has also demonstrated a thorough understanding of the regulatory requirements through its contributions to the DOE-wide review of the NESHAP (Subpart H) regulation. 3. Rockwell has made significant progress towards reducing the rate of radlologlcal incidents. The average monthly rate for Possible Inhalations (Pl's) during FY88 was approximately seven per month. During the first five months of FY89, the rate of Pl's was less than three per month. The FY88 monthly average rate for exceeding contamination limit criteria, in both controlled and uncontrolled areas, Was about 37 occurrences each month. However, for the first five months of FY89, the monthly rate for this type of contamination incident has dropped well below the RFP FY88 rate. Progress to date in reducing incidents is noteworthy and is indicative of a positive trend. The DOE encourages continued improvement in this area. ~. Rockwell has taken several positive steps toward achievement of permanent reduction in plant personnel radiation exposure. A full-tlme As Low As Reasonably Achieveable (ALARA) Program Manager was hired, and completed the development of a basic plant-wlde ALARA program. A Rem Reduction Plan describing various plant and building initiatives being taken to effect a permanent decreasing trend in radiation exposure is in its final stages of completion. During the first four months of the rating perlod, progress was achieved in reducing personnel radiation exposure in the seml-monthly and monthly badge exchange groups. These groups had a projected goal of about 143 Rem during this period, however, they accumulated 102 Rem; this is 41Rem below the goal. Although some of this exposure decrease occurred due to ~ curtailment of Bu~Idlng 771 process operations, this was counterbalanced by the fact that during the same timeframe, Building 776 increased their production, and significant decontamination efforts were~ accomplished in Bul]dlng 771.

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5. The comprehensive review of the Technlcsl Safety Appraisal (TSA) showed that Rockwell's safety program is in transition and open to change.. Rockwell was commended for improvements in ~nlon/management rel~tlons and for developments in an integrated safety program. A definite change in culture was ¯ observed. Substantial corrective actions are underway which, when properly implemented, should result in an exemplary safety program in the future. Rockwell also submitted it's TSA response document to DOE two weeks ahead of the schedule set by DOE. 6. In establlshlng the Safety Review Group (SRG), Rockwell has developed dedicated investigative group that prsvldes a coordinated systems approach to unplanned event investigations that ensures that such events are investigated in a timely manner and enhance the safety awareness throughout the plant. Rockwell should be commended for the establishment of this group as well as for the SRG's efforts to date. Notable Deficiencies I. The shutdown of Building 771 created major disruptions to the commitments for processing of plutonium, with resultant downstream and upstream impacts on nuclear material throughout the weapons complex. The shutdown was made to allow Rockwell time to correct safety related problems in the building, most of which had been identified before the period began. Although Rockwell's corrective action during shutdown was noteworthy, management should not have permitted the situation to degrade to the point of shutdown. Much work needs to be done to export lessons learned from Building 771 to other Rocky Flats facilities. 2. There was an unintentional release of dilute chromic acid on February 22, 1989. The chromic acid upset the organic balance of the RFP's sanitary wastewater treatment plant. Subsequent to the release, water containing the chromic acid was spray irrigated on plantslte. Chromic acid contaminated water from the spray irrigation field was carried by runoff into Pond B-5, which was discharged offslte. There are inadequate incident reporting procedures or operating procedures governing the coordination of the discovery of releases to the sewage treatment plant with downstream control of contamination. Furthermore, the incident shows the need for the development and implementation of adequate Spill Prevention Control and Countermeasures procedures and practices. 3o Although Rockwell has shown improvement in housekeeping of production bu/Idlngs, housekeeping is still inadequate. ~ousekeeplng in the balance of the plant does not approach the standard set in Building 771. Rockwell is attempting to correct this, hut has not yet established a successfuL approach. 4. The rate of wound occurrence in radiation controlled areas averaged about 60 per month during FY88. Although a slight downward trend was achieved during the first five months of FY89, the rate of wound occurrence must still be significantly reduced during the remainder of the fiscal year.

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5. Rockwell has not been able to resolve the i~88 NPDES permit violations for five-day biochemical oxygen demand. Although there were several reasons for the violations, the lack of adequate sludge handling capacity and operation and maintfnance deficiencies are foremost concerns. Rockwell's inability to comply with the limitations of the NPDES permit is considered serious because the discharges from the RFP go directly into the city of Broomfleld's raw drinking water reservoir. Also, the policy of the Environmental Protection Agency (EPA) is to not renew NPDES permits which have outstanding vio]atlons, and the NPDES permit for the RFP expires on June 30, 1989. Unless these violations are resolved expeditiously, the renewal of the NPDES permit will be delayed. It is recognized that Rockwell has hired an outside consultant to identify .the causes of the violations and the corresponding corrective actions which should correct the situation. 6. The DOE has been concerned about the safe operation of the East Firing Range. Rockwell has taken no actions to date to rectify the situation. 7. Rockwell ES&H management provided inadequate oversight of Building 771 operations after the January 19, 1989, phased restart. The overall assessment of the implementation of this radiologica] program indicated that the full intent of the comprehensive and multilevel operational assurances were not performed in an integrated and disciplined manner. Observations I. Rockwell, for the first lime, has a 100% glove change compliance across the plant-slte. The Y-12 Plant has requested a Rockwell employee visit their plant so that a review of their operations and recommendations on development of a glove change program similar to that at RFP can be made'. 2. Rockwell has been proactlve in establishing a National Environmental Policy Act (NEPA) compliance committee. Rockwell has reviewed the appropriate NEPA guidance documents and has established a logical method for reviewing plant projects in order to determine the level of NEPA action required for the project. Although the committee has Just been established , its cross section of divisions will enable it to consider a wide range of plant projects with minimal chance of leaving out a project. The system for documenting the review of projects, the Judgements made, and the recommendation for NEPA action are thorough and track in a logical fashion. 3. The Colorado Department of Health and the EPA conducted six waste storage audits under Resource Conservation and Recovery Act (RCRA) during the last three and a half months, and only minor findings resulted. Because of consistently good audit results, TRU mixed shipments to the INEL were reinstated and the frequency of future inspections will be reduced. 4. Rockwell has established a strategy for upgrading the air monitoring system at RFP. The strategy was the result of excellent analysis, successful peer review, and resulted in a significant reduction in projected costs. 5. Rockwell continues to successfully complete the requirements of RCRA and Comprehensive Environmental Response Compensation and Liability Act. E 002287

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6. Rockwell has made significant improvement in responsiveness to the AL safety appraisals. Although'none to date have beeh turned in on time, the amount of tardiness has steadily decreased to the point that Rockwell has no outstanding responses at this time. Rockwell has initiated "Completion Certificates" for completed actions. 7. Rockwell established proposed plutonium and uranium maximum permissible contamination levels in oils and solvents which are defensible and practical for analytical evaluation. Although this is only a proposed method for estab]ishlng limits for a llmited type of contaminated vs. non-contaminated waste materials, the need for these limits to be established has bees indicated by the Environment & Health Program. 8. Rockwell has developed a Radlat~on Monltor~ng work schedule pilot program. This program is expected to cut Radiation Honitors overtime by 30-50~. The program was completed three weeks ahead of schedule in Building 776. Survey schedules have been maintained up to date. Plans are being developed for Imp]ementatlon of the work scheduling program across the plant-site. 9. Rockwell has responded well in initial implementation of.the more stringent requirements of DOE Order 5480.11, "Radiation Protection For Occupational Workers". Rockwell is developing an implementation plan to accurately assess the impact of ~ul] implementation. tO. Routine surveillance and characterization of potential occupational exposures to hazardous chemicals and carcinogens in the work place are not being performed on a regular basis. As more Industrial Hygiene staff are hired and cleared, this must be a high priority. II. Preparation and submissio~ of the final report on radon in the NDT Vault in BuJldlng 771 has taken excessively long. In that it was Just received, there has not been~enough time for a thorough review of the report by AL. 12. A 1985 Fire Protection Appraisal 'by AL had a finding regarding the rep]aeemenz/hiring of a second fire protection engineer. Each AL appraisal since has ~dentifled the same need. No response to date has been provided by Rockwell to close out this finding.

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PRMP/PROVE

PRMP/PROVE FPA: PROJECT ~tANAGEMENT Adjectival Achievements I. Rockwell has given PROVE renewed emphasSs. Rockwell has separated the responsibility for PROVE from that of the PRMP and placed it under a full time project manager. In addition, the Rockwell Plutonium Operations directorship has committed a top staff member to be the Chief PROVE Project Engineer. 2. Rockwell has recently developed and implemented a "Precursor Plan." This plan represents a marked improvement in direction for the entire project. Theplanning has been both detailed and complete. This "Precursor Plan" has been implemented by Rockwell with professionalism and enthusiasm. Notable Si~nlflcant Deficlenc 7 Overall PRMP management attention to project technical, cost, schedule, and manpower needs was inadequate. Notable Deficiency Inadequate project staffing continues to influence Rockwell PRMP performance. The above referenced "Precursor Plan" has made the staffing shortage obvious to all parties concerned. Observations I. The task of eval'uating and incorporating PROVE's "Lessons Learned" is now a Precursor Plan activity with the anticipation that full benefit wl]l be realized. 2. The degree to which Rockwell appropriately manages the Precursor Plan will directly impact PRMP's future success technically and admlnistratlve]y. Grade: SATISFACTORY

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PRMP/PROVE AdJectlval Noteworthy FPA: COST MANAGEMENT Grade: MODERATELY Achievements GOOD

I. The cost development and basellning of those costs for the "Precursor Plan" has been handled w~th the highest degree of quality. Subcontractors have been integrally involved in this development and baselinlng. 2. Rockwell has redirected J. A. Jones' manpower planning on PROVE which has resulted in reduced costs and apparent increased construction productivity. Notable S~$nificant Deficiency

PROVE continues to demonstrate cost growth. Rockwell has increased their forecast for the Total Estimate at Completion on PROVE from less than $43 million at the beginning of FY89 to the current $~5.5 Notable Deficiency

PRMP cost planning did not take into account allocated funding availability, resulting in a disconnect in project activities. Observations I. Rockwell has r~structured PROVE cost estimates to be able to use a realistic $45.6 million baseline. 2. The PROVE Cost Performance Reports have been timely and of a consistently high quality. Changes to the Performance Measurement Baseline have been ~ incorporated accurately and in a timely fashion. 3. Rockwell's management of the Construction Plan, Cost and Schedule Reduction, System Design Descriptions, and Cost and Schedule Baseline Precursor Plan activities can have a favorable cost impact on PRMP.

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PRMP/PROVE FPA: SCHEDULE PERFORMANCE Adjectival Noteworth~ Grade: VERY GOOD Achievements

I. Rockwell has addressed several problems impacting schedule in the PROVE area and brought them to successful resolution. Among these problems were the additional requ2rements imposed on the health phys2cs monitors and engineering support to provide on-the-spot resolutions and aid to the construction personnel. 2. The diligent effort by Rockwell, Bechtel, and J. A. Jones in the Joint development of the Precursor planning has resulted in a comprehensive schedule that should provide a smooth transitlon from PROVE to the receipt of capital funding for PRM2. Notable Deficiency The PROVE schedule has deteriorated during the reporting period. The PROVE end date was extended from 1/90 to 8/90. The Service Module redesign will reduce the material and work required and improve operability. Present activlt~es shou]d result in schedules that will be met. Observations: I. The intermediate Level PRMP Schedule was completed during this reporting period. 2. The direction Rockwell has given J. A. Jones in the PROVE area of manpower p~anning already has J. A. Jones working toward a potential schedule reduction of two months. 3. Rockwel]'s management of the Construction Plan, Cost and Schedule Reduction, System Design Description, and Cost and Schedule Baseline Precursor Plan activities can have a favorable schedule performance impact on PRMP.

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PRMP/PROVE FPA: SUBCONTRACT, MANAGEMENT AdjectivalGrade: GO0__.~D Noteworthy Achievements 1. Rockwell, consistent with project technical needs and evolved cost and schedules, has provided rapid and effective subcontract redirection of Bechtel. The redirection included contractual changes, a rescheduling of resources, and the cost rebasellning. 2. Rockwell subcontract management of J. A. Jones has ensured J. A. Jones' participation in construction planning. J. A. Jones' PROVE productivity has shown noticeable improvement since their inclusion in the teaming concept. 3. Rockwell has been successful in obtaining active participation and commitment from National laboratories and other Rockwell organizations on the PRMP Precursor Program. Notable Deficiencies I. The subcontract work with the PROVE glovebox manufacturer has resulted in the need for s~gnlflcant rework to the glovebox piping and p~plng penetration welds, 2. Rockwell has still not provided c~ntlnuous site representation at Bechtel's location. The partlclpation_of Bechtel in the Precursor Program does not eliminate the necessity for such coverage to coordinate llne item and cost/schedule activities. Observation~ I. The construction subcontractor on PROVE has been asked by Rockwell to develop a Performance Measurement System (PMS). The DOE Project Management Office (PMO) anticipates demonstration of the PMS early in t~e next six month evaluation period. 2. Rockwell management of the PROVE glovebox manufacturer, has resulted in favorable and timely response to redirection and changes to both schedule and configuration.

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PRMP/PROVE FPA: DESIGN qUALITY Adjectival Grade: MODERATELY GOOD

Noteworthy Achievements i. A significant effort, the PRMP Precursor Program, has been initiated by Rockwell with broad based involvement of subcontractors, other Rockwell operations, and the National laboratories. The Precursor Program is geared toward improving PRMP design quality and should result in improved design quality and the ability to maintain that quality over the life of PRMP. 2. Use of the Configuration Control System for PROVE was greatly improved. The Engineering Review Board has met regularly and a timely dlsposlt~on of the engineering changes has been accomplished, consistent with Rockwell procedures and the needs of the project. Notable Significant Def~ciencz The quality of the existing PROVE engineering has been poor. This quality condition continues to be felt at this late hour in the project. Change orders to correct poor initial design quality are reflected in cost growth of Design Engineering and PROVE construction, Observations I. The Technical Management Discipline (TMD) approach being undertaken Rockwell through the Precursor Program and on PRMP/Line Items, should lead to improved design quality through time phased baselining, technical reviews, and appropriate change control. 2. PRMP project and PROVE design quality wl]] be enhanced by the generation of a complete System-Design Description for PROVE during the next period. 3. The recently added Configuration Management manager should add to TMD capability and Design Quality through the change control process. 4. Rockwell has completed and distributed the PROVE System Operational Test, Cold Test, and Hot Test procedures, and Test Plans have been completed and forwarded to this PMO. 5. PROVE Operations Procedures and Job Task Analysis are proceeding according to schedule. ~

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PRMP/PROVE FPA: TECHNICAL PRODUCT QUALITY Adjectival Grade: MODERATELY GOOD

Noteworthy Achievement PROVE activities in addressing and rectifying glovebox weldlng problems are directed towards, and should significantly improve, technical product quality. Specifically, the drive to fully understand the problem, root administrative and technical causes, and to implement needed changes in a timely manner, should'result.in improved technical product quality. Notable Significant Deficiency Welding problems recently surfacing on the PROVE glovebox indicates a significant lack of technical product quality success, Observations I. It is anticipated PROVE wil'l take advantage of the most recent "Lessons Learned" in order to insure that similar significant deficiencies are not repealed on PRMP. 2. It is anticipated PROVE wlll take advantage of recent problems, w~ll assess other vendor supplied areas for potential problems, and will shake down modules (dry) withoperations and maintenance personnel as they are completed, in order to surface potential problems early.

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