By Jerel Nelson
As a facility nears the end of its useful and productive life, options for the final phase of the facility’s lifecycle are evaluated. If the facility is no longer to be used or upgraded then it may be sold, or in most cases, deactivation (i.e. idling/safe shutdown) and decommissioning (D&D) begin, typically in earnest. Suddenly, the asset has become a legacy liability, costing the company more money every year without any revenue in return. At this point, tremendous pressure exists to not only begin decommissioning, but accelerate it as quickly as possible to reduce/eliminate the risk(s), transfer, reduce, or remove the legacy liability completely. Therefore, the overwhelming tendency for many owners/operators is to rush quickly into decommissioning to avoid unnecessary costs, eliminate the legacy liability, and/or demonstrate progress to stakeholders and the community. This drive and motivation is not uncommon for any manager or project as internal and customer pressure to begin the execution phase to either start fieldwork or begin construction, or in this case what is sometimes referred to as ‘de-construction;’ however, planning is what ultimately sets the trajectory of a project directly towards safe and successful completion or down a tumultuous road of risks, changes, and challenges. This tendency is not uncommon to other construction or environmental projects.
In many cases, the transition occurs or deactivation activities begin too quickly without taking the time to properly perform proper and needed D&D planning. This is driven from good intentions and desires including:
- Keeping the existing staff gainfully employed doing productive work as long as possible (good for the employees, site, and community);
- Using remaining operations funds to accelerate deactivation and decommissioning prior to dipping into the decommissioning fund;
- Demonstrating that the site is being decommissioned (changing the mindset of the workers);
- Reducing the current and legacy liability (utility costs, labour costs, etc.);
- Taking advantage of the site knowledge and experience of the operations staff; and
- Accelerating decommissioning.
However, quick acceleration of deactivation or decommissioning can be fraught with new risks challenges, which if not managed properly, can cause:
- Owners and project teams to quickly get out in front of their headlights
- Confidence to quickly become lost or adversely impacted
- Stakeholders to voice many concerns that you may not be yet prepared to answer; and
- Safety performance to become jeopardized and potentially compromised as decommissioning activities pose inherently different risks than operations and maintenance.
Early scope definition, detailed D&D planning, risk assessment and management, along with a phased transition, are essential elements of successful D&D projects, stakeholder support, and safety performance.
D&D planning should be completed before and during the end of operations. Ideally, decommissioning considerations should also take place during initial design as well. In many cases, D&D planning may spill over into the transition phase as operations cease and resources become available. It is critical to utilize the experience and facility knowledge of the operations resources for the facility in this decommissioning planning phase. To help set up a D&D project for success, it is essential to perform the following specific early D&D planning activities:
- Clearly defined D&D end points, driven by specific objectives, which support an agreed upon, demonstrable, and regulatory and physically achievable end state (which may include an interim endstate);
- Solid project-ized organizations with well-defined roles and responsibilities – a fully aligned project team;
- Detailed scope of work and work plans with hazards and controls clearly identified and safety integrated into each step and approach;
- Accurate materials/waste inventories and waste minimization/management plans and strategies, including a clearly waste management plan – as a D&D project is truly just a massive waste generation and management project;
- Solid and defensible cost estimate, basis of estimate, and baseline, and approved budget;
- Realistic and achievable project schedule demonstrating the sequence of activities and critical path;
- Sufficient initial site and facility characterization to identify and control ES&H concerns, determine of the best material removal methodology, and clearly defined waste disposal options;
- Waste management strategy including volume/quantity estimates, treatment, containerization, storage, waste acceptance criteria, and disposition pathways;
- Clear understanding of project risk with active/aggressive and effective mitigations strategies and management in-place, including strategies for opportunities;
- Stakeholder buy-in/concurrent and ongoing local engagements and frequent/open communications; and
- Integrated safety performance – zero loss-time accidents or incidents.
These are clearly some of the same processes, tools, and outputs that make any project destined for success and are equally applicable to D&D projects.
D&D planning tools have been developed and are very useful and efficient to assist and support D&D planning, as well as project planning in general, from scope definition, project planning and organization, cost estimating, prioritization, sequencing, optimization, materials and waste management, risk assessment and management, and commitments management. This promotes consistency, a solid technical basis, utilizes the past experience and best practices of other decommissioning projects, and helps to trigger considerations during planning that help to ensure all aspects are being evaluated and addressed.
Early D&D planning should also include transitioning from operations to D&D – this is not to be overlooked or underestimated. Transitioning is essential during this early planning period in order to set up a decommissioning project for success integrating safety, containing costs, maintaining worker respect, and just doing things right. Transition activities typically include:
- Developing workforce reduction and/or reskilling plans;
- Performing D&D cross-training, which may include stakeholder education;
- Capturing and disseminating industry lessons learned and best practices;
- Transitioning/updating work process and procedures from operations/maintenance to decommissioning – reducing and increasing rigor where required;
- Change management – streamlining and updating work processes and procedures for a decommissioning focus;
- Communicating early and often to the workforce;
- Capturing facility and process knowledge;
- Determining and approval of the final end state;
- Performing shutdown and site reconfiguration activities to maximize safety and efficiency of D&D activities;
- Development or updating of the existing decommissioning provisioning cost estimate;
- Development of decommissioning project proposal documentation; and
- Identifying all regulatory and stakeholder commitments.
Early planning and transition activities help to ensure the success of a decommissioning project:
- Well-defined scope and end-state, including specific end points
- Detailed strategy and plan, using proven and effective decommissioning methods
- Realistic cost estimate and project schedule for completion
- Stakeholder agreement and consensus
- Integration of safety
In addition, decommissioning planning tools can be of a great assistance in helping D&D project managers to remember key elements and apply the appropriate level of rigor. I’ve been involved with the development, implementation, and use of D&D planning tools that help to identify and determine project end points, organize a project, develop the cost estimate and schedule – ensuring they are aligned, capture materials and waste, determine disposition pathways, prioritize and sequence decommissioning activities and projects, identify and manage D&D project risks and mitigation actions at multiple levels, and capture and manage regulatory and stakeholder commitments. These custom D&D tools, and other similar industry applications, have demonstrated their usefulness and value during planning and execution as well as capture and provide the lessons learned and best practices of previous D&D projects.
Borrowing an analogy from a close colleague of mine who has also performed and experienced D&D projects with varying level or preparedness – he described it as follows:
Imagine standing at one end of the building that is cold and dark. At the other end, you can see the light emanating from the door on the other side that you need to get to; however, everything from where you are standing to the point you need to get to is black. There are blades, protrusions, and other hazards that are there along your route that you can’t see. You have two choices:
- Methodically study the drawings, walk the route with the appropriate tools and gear, including a flashlight, talk to those that have walked from point A to point B before, and develop a plan to get there; or
- Make a mad dash for the light.
The first approach will get you there safely, successfully, and mostly unscathed (from a safety, cost, schedule, and risk perspective), as you’ll be prepared. The pace may be a little slower, but it will be worth it. The second approach with be fraught with cuts, stumbles, injuries, headaches, stoppages, and cost you in time, efficiency, reputation, and physical challenges – you might make it to the door, but you’ll be battered and bruised. Which route are you going to take? I’ve been down both. I’ll take the detailed planning route of reduced risk and high likelihood for success for all stakeholders.
Now is the time to plan for success by: incorporating the lessons learned and best practices from those that have been through the dark building and emerged relatively unscathed; using the planning and management tools that have captured and provide D&D experience; ensuring that your planning produces the previously identified elements; and accepting nothing less, so that you are on the right course to perform your D&D project and are ultimately destined for success. If you rush into D&D, you’ll ultimately be faced with a stoppage of some kind to take the time to do the planning you have overlooked, so do it up front.
To assist you in planning your next or current D&D project, please see next month’s issue where we present a series on the “Top 10 Decommissioning Planning Lessons Learned and Recommendations.” You’ll gain valuable insight into necessary planning elements that will provide greater definition on many of the above essential decommissioning planning aspects.
About the Author:
Jerel Nelson is a senior management consultant with expertise and international experience in nuclear facility decommissioning, environmental restoration, process improvement, site infrastructure planning, portfolio management, and business development. He specializes in the development, implementation, and use of proactive, custom tools and applications, to perform and improve planning, estimating, scheduling, waste management, risk assessment and management, issues management, commitments management, stakeholder management, portfolio management, operations, communications, and work management. Nelson has worked internationally on projects in the U.S., Canada, U.K., and Australia. He brings innovation, efficiency, rigor, cost and time savings, continuous improvement, performance metrics, and added value in every aspect of his work for project, companies, and customers.