Subcommittee on Decontamination and Decommissioning

Introduction

The end of the Cold War and the downsizing of the nuclear weapons complex present a major change in emphasis and magnitude of the tasks facing the U.S. Department of Energy (DOE). DOE nuclear facilities no longer in use are being deactivated and need to be decontaminated, and DOE believes many must be decommissioned. As stated in Estimating the Cold War Mortgage: The Baseline Environmental Management Report (BEMR) (USDOE, 1995a), DOE estimates the scope of the current problem includes approximately 7000 contaminated buildings, of which 700 are candidates for decommissioning. Contained in these structures are, reportedly, over 500,000 metric tons of contaminated metal and mixed units over a billion cubic feet of contaminated concrete. DOE-EM's technology-development program is aimed at developing and implementing technologies that will address these problems safely and cost effectively.

The Decontamination and Decommissioning (D&D) Subcommittee was established to assist the Committee on Environmental Management Technologies (CEMT) in assessing/evaluating technological needs in DOE's D&D Focus Area.

Planning Documents

The DOE provided the subcommittee with three principal draft planning documents to convey the foundation of the focus area's efforts and planned approach to date. These documents were DOE's Strategic Plan (USDOE, 1995c), Management Plan (USDOE, 1995e), and Implementation Plan (USDOE, 1995d). DOE D&D and general resources were also transmitted to the subcommittee at various times D&D Focus Area Technology Summary (USDOE, 1995), and Decommissioning Handbook



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--> Subcommittee on Decontamination and Decommissioning Introduction The end of the Cold War and the downsizing of the nuclear weapons complex present a major change in emphasis and magnitude of the tasks facing the U.S. Department of Energy (DOE). DOE nuclear facilities no longer in use are being deactivated and need to be decontaminated, and DOE believes many must be decommissioned. As stated in Estimating the Cold War Mortgage: The Baseline Environmental Management Report (BEMR) (USDOE, 1995a), DOE estimates the scope of the current problem includes approximately 7000 contaminated buildings, of which 700 are candidates for decommissioning. Contained in these structures are, reportedly, over 500,000 metric tons of contaminated metal and mixed units over a billion cubic feet of contaminated concrete. DOE-EM's technology-development program is aimed at developing and implementing technologies that will address these problems safely and cost effectively. The Decontamination and Decommissioning (D&D) Subcommittee was established to assist the Committee on Environmental Management Technologies (CEMT) in assessing/evaluating technological needs in DOE's D&D Focus Area. Planning Documents The DOE provided the subcommittee with three principal draft planning documents to convey the foundation of the focus area's efforts and planned approach to date. These documents were DOE's Strategic Plan (USDOE, 1995c), Management Plan (USDOE, 1995e), and Implementation Plan (USDOE, 1995d). DOE D&D and general resources were also transmitted to the subcommittee at various times D&D Focus Area Technology Summary (USDOE, 1995), and Decommissioning Handbook

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--> (USDOE, 1994). DOE advised that the three major planning documents are being reviewed within the department and may be issued in final form before the end of 1995. Although the three planning documents will change from time to time to reflect the evolving nature of DOE priorities, the following elements seemed to be lacking: a systematic needs assessment; a systematic assessment of available technologies including disposal options; a matching of available technologies with the needs; an identification of technology gaps; development of criteria within appropriate constraints (e.g., acceptable risk, regulatory drivers, stakeholder agreements, cost-benefit analyses) to enable priorities to be established; and guidelines for development and implementation of a comprehensive, integrated program involving a suite of projects from basic and applied research through large-scale demonstration and implementation depending on the maturity level of the technology. As a foundation for the selection, evaluation, and prioritization of candidate D&D technologies, a clearly defined set of criteria for D&D technology application and performance is a necessary first step for the D&D Focus Area. Among the more important attributes of the performance criteria are technical feasibility, compliance with regulatory constraints, worker and public health and safety, economic viability, political/stakeholder acceptability, and end-user satisfaction in addressing specific tasks. The eventual use of DOE sites will determine the end points of the D&D remediation efforts. Establishing quantification criteria for the necessary and sufficient cleanup of DOE sites is certainly a primary factor driving D&D technology development. Whether DOE can develop a system of criteria to yield specific site-cleanup objectives remains to be determined, but DOE should attempt to do so. Remediation of certain sections of DOE sites to pristine levels may well be prohibitively expensive and unnecessary. Many argue that certain sections of DOE sites should be left as "brown fields," suitable for certain kinds of industrial development.

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--> DOE seeks to minimize the financial requirements of its D&D programs by promoting the possible resale of recovered metals, the commercialization of technologies that it might develop, and various privatization efforts. Further comment may be made on these matters as additional information is received and analyzed, but the fact that DOE appears to be relying on a domestic and foreign market potential for yet-to-be developed technologies in the absence of any documented assessment of the status of these D&D technologies and needs raises concern. Conclusions and Recommendations Conclusion: DOE EM-50 has stated to the subcommittee that new technologies are needed to perform D&D tasks safer, better, cheaper, and faster than is possible with presently available technologies. However, no documentation of the basis for this premise, which is the justification for the entire technology-development program, has been provided or identified. At the same meeting, the subcommittee heard from EM-40 at headquarters that all necessary technology is in hand. Recommendation: Using external peer review as appropriate, DOE should establish criteria by which to compare and evaluate the effectiveness of existing and candidate technologies and a means by which deficiencies can be evaluated. The basis for projecting the needs for and or the superiority of future technologies then should be stated explicitly. The process should start with a needs assessment for the D&D Focus Area and should identify available technologies, technology gaps, and criteria for establishing priorities. Conclusion: The D&D Focus Area Strategic Plan, with its emphasis on relatively mature technologies and large-scale demonstrations, is too narrowly focused. Recommendation: The D&D Focus Area should revise its strategic plan to provide a basis for a comprehensive D&D technology-development program. This plan should specify a process that will yield a systematic assessment of D&D needs and available technologies, the identification of technology gaps, the development of criteria for establishing priorities, and a justification for demonstration projects that will be funded and executed. The product of this effort should be a balanced program of basic and applied research, exploratory and advanced development, engineering design, demonstration, and implementation.

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--> Conclusion: A strategic plan is best if flexible. Indeed, strategic planners (see e.g., Andrews, 1987; Goold and Quinn 1990; Mintzberg, 1978, 1979, 1981; Mintzberg et al., 1976; Quinn, 1977, 1980) have demonstrated that many of the best strategies emerge without the benefit of a rigid planning document. Although flexibility is very difficult to achieve in the public sector, DOE does not need another formal or rigid plan to follow. It is not evident that any progress on finalizing the draft plans has been made since CEMT's report for 1994 (NRC, 1995), and the goal of producting a "final" plan this year may be unrealistic. Recommendation: The D&D strategic plan should be a living document. If the planning documents are "finalized" by the end of this year, DOE should include provision for future periodic revisions. Conclusion: DOE should address planning in terms of a process and should not have to contract for the drafting of the strategic planning document. In order for the plans to succeed, DOE decision makers themselves (and not their support contractors) should draft the plans. Many organizations have found that the most valuable aspect of any strategic planning exercise is the process of assembling the plan rather than the specific details of the plan. Recommendation: DOE should set aside time for the planning exercise. The plan will succeed best if it has commitment from the highest and broadest levels of management, so it must include the undivided attention of the highest-level decision makers. If three planning documents are developed, different levels of DOE representatives could draft the different plans, but the strategic planning document must include the highest-level decision makers. The Management Plan should include those responsible for managing the plan. The Implementation Plan should include those individuals who will implement the plan. Conclusion: The drafts of the Strategic, Management, and Implementation plans are inconsistent in language, definitions, process structure, and criteria and fail to provide a usable roadmap from which detailed scheduling and milestones can be developed within annually approved budgets.

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--> Recommendation: DOE should establish an action plan that leads to the early revision and issuance of each of the three plans. The plans should incorporate specific language, definitions, process structures, and performance criteria that are consistent across the three principal planning documents. Areas of emphasis should include priorities, discussion and integration of performance criteria, assessment of the scope of work vis-a-vis the other focus areas, and related technology development for D&D within DOE. Conclusion: The D&D Focus Area Management and Implementation plans fail to include adequate recognition of and coordination with appropriate activities underway in other parts of DOE and with independent technology development in the private sector and abroad. Recommendation: The revisions of the Management and Implementation plans should include an evaluation of private sector and non-U.S. technology developments. Conclusion: DOE apparently expects benefits will accrue to it by commercialization of newly developed D&D technologies. No indication of source or market potential to support this expectation could be found. Recommendation: Without a basis for potential commercialization, DOE should not permit consideration of commercial potential to affect the selection, development, or utilization of new technologies. Conclusion: No basis for establishing levels of site cleanup to be achieved, other than the need to comply with statutory, regulatory, and contractual requirements is evident. End-use risk and cost are also major drivers. Recommendation: DOE is in urgent need of defining criteria by which the level of site cleanup on a "necessary and sufficient" basis within regulatory constraints can be determined. Such an exercise might indicate current technologies to be entirely adequate to meet cost and schedule targets.

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--> Conclusion: DOE does not have a fully integrated ''D&D Technology Needs Evaluation Document'' that justifies the large-scale demonstration projects that DOE is scheduled to fund. Four D&D large-scale demonstrations that will showcase specific D&D operations are scheduled for the next two years; however, it is not clear how these demonstrations will be evaluated and documented to capitalize on their successes and failures in future D&D activities. Recommendation: A cost-benefit study is needed for the three or four most critical D&D technologies expected to reduce the cost of decommissioning significantly without compromising safety. The study should evaluate the status of current technologies nationally and internationally, using external peer review as appropriate, and assess how many dollars can be saved throughout the DOE Complex for each research and development dollar spent to develop new technology or improve existing technology. Current technology-development programs that do not have a return on investment for the development dollars being spent should be terminated. For the scheduled large-scale demonstrations, specific evaluation and analysis procedures should be developed before further funding is committed. Conclusion: Systemic DOE-wide issues, such as the lack of an "end-use" standard or policy, the ongoing debate between a "national" versus a more region-based management strategy, or the impacts from highly prescriptive regulations or DOE orders, place significant burdens on the successful achievement of technology development by the D&D Focus Area. While such systemic problems are beyond the immediate control of the focus area, the draft documents offer little recognition of these significant concerns and do not propose alternative strategies to compensate for these issues in the development of D&D technologies. Recommendation: The D&D Focus Area should address these significant larger issues in its planning process, supporting documentation, and structured interaction with DOE, other agencies, its industrial partners, and stakeholders. The draft documents should be re-assessed to highlight areas affected by these systemic problems and to include decision points that address specific issues affecting planned technology development.

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--> References Andrews, K. R. 1987. The Concept of Corporate Strategy. Homewood Ill: Irwin. Goold, M., and J. J. Quinn, 1990. The Paradox of Strategic Controls, Strategic Management. Mintzberg, H., 1978. Patterns in Strategy Formation: Management Science , 2:934-948. Mintzberg, H., 1979. The Structuring of Organizations. Englewood Cliffs, N.J: Prentice-Hall. Mintzberg, H., 1981. Research Notes and Communications, What is Planning Anyway?, Strategic Management. Mintzberg, H., D. Raisinghani, and A. Theoret 1976. The Structure of "Unstructured" Decision Processes, Administrative Science Quarterly, 21:246-275. National Research Council. 1995. Committee on Environmental Management Technologies Report for the Period Ending December 31, 1994. Washington, D.C.: National Academy Press. Quinn, J.B., 1977. Strategic Goals: Process and Politics, Sloan Management Review, 21-37. Quinn, J.B., 1980. Strategies for Change: Logical Incrementalism. Homewood, Ill.: R.D. Irwin. U.S. Department of Energy (USDOE). 1994. Decommissioning Handbook, Department of Energy Office of Environmental Restoration, DOE/EM-0142P. March. U.S. Department of Energy (USDOE). 1995a. Estimating the Cold War Mortgage: The 1995 Baseline Environmental Management Report, Department of Energy Office of Environmental Management Technology Development, DOE/EM-0232, vols. 1-3, March.

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--> U.S. Department of Energy (USDOE). 1995b. Decontamination and Decommissioning Focus Area: Technology Summary, Department of Energy Office of Environmental Management Technology Development, DOE/EM-0253. June. U.S. Department of Energy (USDOE). 1995c. Strategic Plan, Decontamination and Decommissioning Focus Area, Pre-Decisional Draft. July 14. U.S. Department of Energy (USDOE). 1995d. Implementation Plan, Decontamination and Decommissioning Focus Area, prepared by USDOE Morgantown Energy Technology Center. July 18. U.S. Department of Energy (USDOE). 1995e. Management Plan, Decontamination and Decommissioning. Pre-Decisional Draft. August.