J.G. Nelson, Senior Management Consultant, The Delphi Groupe, Inc.
M. Kruzic, Decommissioning Project Manager, PMP, Advisian
M. Morton, Senior Principal Consultant – Decommissioning, Polestar Technical Services
R. Wilkinson, Senior Program Manager, P.E., The Delphi Groupe, Inc.
This 3-part series is exploring a list of the ‘Top 10’ lessons learned including the typical situation, importance, impacts(s), different perspectives (contractor, owner, and stakeholder), along with recommendations for each of the ‘Top 10’ lessons learned in decommissioning planning. After all, planning is the earliest and best opportunity to positively influence scope definition, safety, cost, and schedule.
In Part 2 of this series, we’ll discuss Lessons 5-7. Stay tuned next week to read the final lessons learned.
5. Characterization for Materials Removal and Waste Management
One of the preliminary activities that need to be performed to enable detailed planning is characterization. Characterization includes both ‘desktop’ characterization (level 1) – reviewing of existing and historical facility/site documentation and process knowledge, and field/facility characterization (level 2) – condition assessments, surveys and materials sampling from the structure, systems and surrounding lands. Characterization results are an essential piece of information to perform detailed planning. Full characterization may be both cost and time prohibitive; therefore, targeted characterization may be required. In some cases, process knowledge may be sufficient for initial planning, but will increase residual risks and contingency requirements as planning continues.
Characterization results will support the determination of the methodology, approach, controls (including PPE and dose management), containers (type and quantity), treatment options, and waste disposition pathways. It may also identify the need to perform additional characterization, based on the results to provide better define the extent of the hazards or contamination. It enables planners to utilize definitive knowledge when determining the most cost-effective, safe, and efficient approaches to performing the various D&D activities. It will also limit the number and extent of alternative strategies or contingency plans. It can also provide you with information to define integrated step-up or step-down criteria for controls that need to be put in-place during deactivation, decontamination, decommissioning, or demolition. Good characterization data is essential for productivity, compliance, and safety.
The level and extent of characterization can have a significant impact on the success of the project. Impacts of poorly planned and executed characterization include the potential for personnel exposure and equipment contamination, unplanned generation of mixed waste, work stoppages due to lack of controls or definition, improper waste removal or handling procedures, and development of additional work plans that may not otherwise be required. This is a classic ‘pay now or pay later’ scenario and navigating through it is different for each project and circumstance.
Characterization activities that should be performed during the planning stages include:
- Obtain and review any historical information/documentation or process knowledge, including interviewing personnel who worked at the facility during operations
- Follow the data quality objectives process as an input to the characterization plan development to ensure the right type and quantity of samples are collected, the right tools and equipment are used and the right analytical methods are applied
- Perform sufficient characterization for personnel and environmental protection decision-making, waste identification, waste characterization, waste acceptance criteria demonstration, waste handling, and disposition pathway determination
- Capture base assumptions and characterization results in planning
- Identify if alternative approaches will be required
- Develop a waste management plan, based on the characterization results, that provide flexibility in methodology where possible, and specific controls on removal, handling, containerizing, and disposition
These efforts will improve your technical confidence that the chosen methodologies and tools identified during planning will be safe and effective.
Ben Franklin stated ‘An investment in knowledge pays the best interest.’ George R. R. Martin, American novelist, screenwriter, and producer stated ‘Knowledge is a weapon – Arm yourself well before going to battle.’ Gaining the characterization data we need to determine the appropriate material removal and waste management strategies will pay dividends in safety, cost, and schedule and prepare the project for the upcoming decommissioning battle.
6. Risk Assessment and Management
Risk management is one of the most overlooked and underutilized aspects of project management and particularly on D&D projects. In many cases, early risk assessments are performed and risks and consequences are identified for the project, but active management of the proposed mitigations is often not performed since effort is focused on currently occurring issues. Risks are also typically assessed and managed at the project level only. They are not generally assessed at the program/portfolio and/or site/corporation levels where the risks are often not visible or regularly reviewed. In addition, we often limit risk assessments to one consequence, when multiple consequences exist. Risk management is typically a collateral duty and is not assigned to an individual who has the dedicated time and energy to focus on, manage, mitigate, reduce or eliminate the risks.
Increasingly in industry, key risks have been realized or a combination of inter-related risks occur which cause significant environmental, industry and financial damage at the program and corporate level. Risk is now a major corporate currency and becomes more important as new, never or rarely before, work activities are started. Combinations of risks have yielded catastrophic results. More active and aggressive risk assessment and management needs to be taken at multiple levels for corporations, government agencies and projects of all sizes. Small actions and system or process improvements can be performed to significantly improve risk assessment and management. It also assists professionals, of all backgrounds and experience levels, in managing risk in their disciplines or relevant areas of their projects. Within risk, lie opportunities. Without ongoing risk management, opportunities are not identified or exploited to the maximum benefit. Risk management can be the difference of a safe and successful project or one that fails.
Actively and aggressively managing risk at multiple levels includes identifying and managing risks at the project/facility, program, and site/corporation level rather than just the project level as it is most commonly applied. The consequences and impacts at the program and site/corporation levels are different and of much greater magnitude. This provides opportunities for program or corporate-wide initiatives and efforts to address common risks across numerous projects in a cost-effective manner. It also helps program and corporate managers to take actions at their level to avoid or guard against negative risks and consequences. The risk management program/process should provide the project manager the opportunity to elevate risks to the appropriate level once identified by the project team. Some risks are low at the project level, but become increasingly more severe at the program and corporation level. Conversely, there are high risks at the project level that are increasing less severe at the program or corporate level and do not require action or active management at these levels. Knowing the right level of which to act or manage is critical.
To improve your risk assessment and management on decommissioning projects, consider the following:
- Identify and assess risks and opportunities early and at the project, program, and site/corporate level
- Evaluate multiple consequences
- Don’t stop identifying and managing risks after the initial risk assessment
- Assign accountability of risks to the appropriate level (project, program, and site/corporation) and individual that has authority to manage and mitigate them
- Hold regular risk reviews
- Include identified risks and management strategies in your decommissioning execution plans
- Actively and aggressively manage risks and combinations of risk
- Provide the ability to actively monitor and trend risk management for the project
- Include risk and contingency costs in cost estimate and days in the schedule
- Identify and exploit opportunities early
- Use a risk assessment and management tool
In a recent effort to improve corporate-level risk assessment and management for two different energy corporations, a multi-level risk assessment and management tool was developed, customized for the companies, and implemented. It had the following desired effects:
- Proactively addressed and improved the risky activities that were previously identified
- Led to the development of a more active risk management process where risks and opportunities were actively managed, monitored, and controlled by each site operator more aggressively and frequently
- Improved individual accountability by risk owners as well as improving the regular reviews of these risks
- Provided a greater understanding of risks at the program level
- Enhanced and improved the ability of program managers to make solid, informed decisions on priorities and funding to maximize risk reduction
Theodore Roosevelt stated ‘Risk management is about people and processes and not like fire: If controlled, it will help you; if uncontrolled, it will rise up and destroy you.’ Roger VanScoy, and executive consultant, stated ‘Knowing our risks provides opportunities to manage and improve our chances of success.’ It is up to us to identify and control our risks so that we are prepared for them, as you’ll encounter numerous decommissioning risks on every decommissioning project.
In a future 3-part series, you can learn more about the ‘Top 10’ Decommissioning Risks and Strategies to Mitigate Them Effectively.
7. Materials/Waste Management
Decommissioning and demolition of a facility can be considered a massive materials/waste management project. Massive quantities of different types of materials (waste, debris, equipment, and soil) are generated. The majority of project effort is focused on their safe and efficient removal and disposition. The cost of disposition alone of these materials can be upwards of 30% of the project costs, or more in some circumstances. Different disposition pathways are possible, such as reuse, resale, recycle, or disposal. Some items will have resale or scrap value and can help to offset costs depending on the current metals market, however, other materials must be removed and disposed of properly, including radiologically-impacted materials, PCB-containing materials, mercury, lead, solvents, light ballasts, asbestos, and other controlled wastes.
Many types of waste have specific removal, handling, inspection, and storage requirements driven by regulations. In addition, materials and equipment used for demolition can also become waste if contaminated or just during regular use (i.e. Personal Protective Equipment [PPE] & Clothing). In some cases, treatment may be required prior to final disposal and/or interim storage may be required until sufficient quantities exist or the disposition pathway becomes clear. Different options are available for volume reduction, such as segregation, compaction, solidification, size reduction, incineration, and other derivations. From previous experience when dealing with the decommissioning and demolition of experimental facilities that have a combination of radiological, hazardous, mixed, and regulated materials/wastes, early waste characterization and a comprehensive waste management strategy and plan was essential. A clear disposition pathway should be established before the waste is generated.
Without clear definition and understanding of the waste management requirements the likelihood and potential for double-handling increases, non-compliance of storage can occur, waste may sit idle onsite awaiting a disposal pathway, costs can unexpectedly increase, mixing of waste can occur creating unanticipated mixed waste, and additional sampling may be required. All of these elements adversely impact project success.
These negative consequences can be eliminated or reduced by performing materials and waste management in the early planning stages:
- Performing early characterization
- Conduct cost-benefit and trade-off studies comparing size reduction, decontamination, personnel exposure safety, container/disposal costs to determine and the optimal waste management strategy
- Plan work such that it avoids double-handling of wastes
- Develop a well-defined waste management plan that specifies requirements for removal, handling, storage, compliance, containerization, size reduction, and expected disposition of each type of waste
- Utilize a materials/waste management tool/software
A database to track and manage waste, debris, and equipment through the generation, storage/monitoring, and disposition phases is extremely valuable. This enables accurate tracking of waste and container quantities, supports waste forecasting, and management of generated/staged wastes. Waste management tools also help to track inspections, surveillances, and other regulatory actions and can provide automatic reminders. This type of tool also helps for quick and accurate auditing and demonstration of compliance. In short, a waste management tool will help to implement the materials/waste management plan successfully to address one of the biggest challenges on any decommissioning/demolition project.
Will Rogers stated ‘When you find yourself in a hole, stop digging’. D&D projects are one massive materials and waste management project; therefore it is imperative to plan, control and manage the generation, storage and disposition of materials so as to never put the project is a position to deal with a big pile of waste with nowhere to go.