Deactivation Completion and Turnover
Deactivation Completion
and Turnover
Subjects of This Chapter
Achieving consensus that deactivation is complete can involve several parties including
the deactivation contractor, the Field Office, DOE Headquarters, the post-deactivation
contractor, regulators, and stakeholders.
- Overview of Turnover
- Turnover Checklists and Documents
- End-Points Closeout and Verification
Overview of Turnover
When facility deactivation activities are complete, some of the possibilities for
the subsequent receiving organization include:
- In cases of facilities that are contaminated, turnover to a remediation organization
for managing post-deactivation surveillance and maintenance, and final disposition.
- Retention by the same organization but with a different budget.
- Turnover to another host agency where the facility is to be used for another purpose
by the U.S. government.
- Granted or sold to a public or private party.
To the extent there is a policy and/or budgetary issue associated with turnover,
both headquarters line and field office should concur on the receiving organization.
The determination of alternatives for, and agreement on the final condition of the
facility must be complete before it is transferred to the receiving organization.
In addition, funds required to perform post-deactivation surveillance and maintenance
must be identified with a lead-time sufficient for any necessary budgetary action.
When the receiving organization is identified, details of the conditions to be achieved
for facility turnover must be agreed to between representatives of the deactivation
organization and the receiving organization. This agreement should occur early for
facility deactivation planning and must be reflected in the end-point process.
The steps to reaching this agreement and achieving turnover are:
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1) |
With respect to the S&M plan:
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The deactivation and the receiving organization look ahead to the likely post-deactivation
surveillance and maintenance requirements during the period following deactivation
and prior to ultimate disposition. These requirements must be explicit and specific
to the facility. |
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The surveillance and maintenance requirements are then used to develop a plan for
the post-deactivation surveillance and maintenance period. The details of this plan
depend on the degree of the facility's potential threat to workers, the public,
and the environment.
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- |
The conditions necessary to conduct the required surveillance and maintenance become
deactivation end-points, among others. Based on appropriate discussion and iteration,
the deactivation organization and the receiving organization field offices and contractors
reach concurrence on those end-points directly affected by surveillance and maintenance
plans. |
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2) |
When feasible to do so, the ultimate approach to decommissioning is examined. When
supported by reasonable or obvious presumptions, the use of existing systems and
equipment (e.g., overhead cranes) in decommissioning is considered in establishing
end-points. |
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3) |
End-Point criteria are established. The field office and receiving contractor participate
in and agree to the end-point specifications at appropriate levels (e. g., field
office at level 1 and 2; deactivating and post-deactivation contractors at level
3). |
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4) |
The field contractor deactivates the facility to the end-points agreed upon by the
deactivating and post-deactivation organizations. If, during deactivation, reasons
arise for modifying the end-point specifications, the receiving organization must
consider that change. Examples of reasons for reconsideration are: costs may be
too high for a marginal benefit; or conversely, for a relatively small incremental
cost, a much-enhanced condition can be achieved for ultimate decontamination and
dismantlement. When appropriate to modify a prior agreement, both organizations
must concur. |
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5) |
A formal turnover process document is utilized to establish completion of the end-points
by the deactivation organization and verification of end-points completion by the
post-deactivation organization. |
Turnover is accomplished when deactivation end-points are achieved, conditions for
surveillance and maintenance are set, and the receiving organization takes responsibility.
Demonstrating completion can lead to several possible types of end-points-related
deactivation documents:
- End-Point Document - Specifies in detail end-points for deactivation of a facility.
- End-Point Work Plans - For specifying how the work was to be accomplished.
- Post-Deactivation S&M Plan (Preliminary) - A post-deactivation Surveillance
and Maintenance (S&M) plan that provides one of the major bases for detailed
end-points specification.
- End-Point Completion Report - A report that verifies and archives the accomplishment
of end-points.
There will be other documents at the completion of the work, for example, as listed
in the three turnover package checklist examples tabulated in this chapter.
Turnover Checklists
Three types of turnover packages are described here. However, the needs will vary
from project to project since the facilities are different. The level of detail
will depend on conditions, requirements, and agreements specific to the facility.
Therefore, each project must determine what needs to be created for purposes
of completion and turnover. As further experience is gained, a standard approach
may evolve. The three types of turnover documentation presented here are:
- Administrative Turnover Package - Administrative turnover consists of a collection
of administrative documents for which example items are in Table 1.
This includes procedures, agreements, permits, and other documents not directly
related to the physical facility.
- Technical Turnover Package - Table 2 is an example
list of documents that describe the facility, its equipment, and the conditions
at completion of deactivation.
- S&M Turnover Package/Documents - The surveillance and maintenance turnover
package consists of documents that may have been created; Table 3
is an example list.
It is emphasized that these are examples based on experience of a limited number
of facilities, and that each project must be specifically planned.
Table 1 - Administrative Turnover Package Checklist Items
|
(X) |
Type of Documentation |
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Safe Shutdown and Deactivation Report. This is a management summary of the facility
deactivation completion, general status and conditions, demonstrating conformance
with DOE's specification of the overall end-state. It should identify management
actions needed that are not routine. Unresolved issues should also be described.
The report should reference the End-Point Completion Report (See Table 2),
but not repeat the information there. |
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Emergency response plan revised for the deactivated state. Include response to fire,
flood, severe storms, and other naturally or humanly caused events. |
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Provide the most current safety documentation for each facility, such as a description
of the safety envelope currently in place. Status of planned actions related to
SARs, OSRs, TSRs, process hazards reviews, and implementing procedures covering
the current status of the facility. Copy of TSR surveillance program description
and statement of compliance with TSRs. Definition of the scope and estimate of the
costs to bring the facility into compliance with OSRs in force, or recommended to
be in force, and work packages to accomplish such compliance. |
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Provide the status/compliance of all regulatory commitments; for example, status
of compliance with applicable regulations promulgated pursuant to statutes, such
as Occupational Safety and Health Administration (OSHA), RCRA, CERCLA, and NEPA
and the remediation process in the National Contingency Plan. |
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Provide the status of Interagency Agreements that identify the terms and milestones
of agreements pending and entered into by DOE with Federal, state, and local agencies
and the status of compliance. This includes settlement agreements, administrative
or consent orders, and compliance plans to settle outstanding notices of violation. |
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Provide the status of existing permits, including National Pollutant Discharge Elimination
System (NPDES), air permits, RCRA, and others. |
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Provide the status of Corrective Actions by providing a list of corrective actions,
completed and outstanding, from previous audits, inspections, and other similar
activities (e.g., Tiger Team, Technical Safety Appraisal, Defense Nuclear Facility
Safety Board, regulatory agencies, self-assessments, business systems review), including
identification of those items that need to be evaluated and reviewed with respect
to the facility's excess condition. |
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Provide a list of items and activities that must be performed to complete deactivation
after turnover. It would not be unusual to have work items which for some reason
could not be completed prior to a logical turnover date and that would have been
negotiated with/agreed to by the receiving organization. |
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Deactivation Locks Log and keys - A formally administered "Deactivation Lock System"
may be established. Deactivation locks may be used for facility access, isolation
of electrical components, chaining of valves, and other situations where physical
access is to be controlled. The primary purpose of such a system would be to ensure
control as the work force "backs out" of the facility as specified end-points are
achieved. |
Table 2 - Technical Turnover Package Checklist Items
|
(X) |
Type of Documentation |
|
Complete and document the final deactivation/shutdown of the facility. Include deactivation
work plans and work packages as they were at completion of deactivation. The work
plans may be part of the end-point completion report. |
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End-Point Completion Report - Validation of end-points. For example, using sample
forms provided in this handbook, this report could be primarily all the end-point
forms with completion signatures. |
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End-Point Technical Information - All documented technical criteria bases to which
end-points are referenced. |
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As-Left Condition - Include a summary of the overall physical status of the buildings
and systems, and major equipment. Address access control and isolation of fluid
and electrical systems. Status of fire and flood protection should be stated. If
there are any unique structural anomalies, they should be described. If fixed in
place, potentially hazardous materials that have been left in the facility should
also be mentioned. See Appendix A under "Background" for an example of such a summary. |
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Facility, room, and cell arrangement drawings - to the extent they exist. If significant
changes were made for deactivation, some form of documentation would be useful.
However, except in unique circumstances, as-builts of such changes should not be
necessary! |
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Description/photos of spaces for which access is not anticipated during S&M. |
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Establish and archive records for:
- Reactivating future decommissioning essential systems
- Characterization useful for future decommissioning
Include equipment Technical Manuals and other information for equipment that remains
operational or is mothballed - to the extent that it exists - do not create new
material if it does not exist.
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Provide current status (including drawings) of the deactivation/safe shutdown (if
applicable). The documentation should address systems, such as the water, sewer,
air, electric, gas, process (mechanical and chemical) and fire protection systems. |
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Location of fixed hazardous materials, wastes, and contamination with characterization
information. |
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Inventory and Safeguards and Security provision for nuclear or other material remaining
in the facility for which there is a requirement for accountability or protection
from diversion. |
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Inventory of chemical and hazardous substances remaining, if any, and characterization
information. |
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Inventory of radioactive and fissile material remaining as contamination with characterization
information. |
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For structures at the facility, provide the final radiological/hazardous materials
survey records, final configuration and surveillance and maintenance requirements,
available drawings, specifications, procedures, manuals, and unplanned occurrences
records applicable to the facility. |
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For soil, surface water, and groundwater conditions at the facility, provide all
available data and reports that describe those conditions and the nature and extent
of contamination therein. Also identify any known assessment requirements. |
Table 3 - S&M Turnover Package Checklist Items
|
(X) |
Type of Documentation |
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Post-Deactivation S&M Plan |
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Post-Deactivation S&M Updated Effluent Monitoring Plan |
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Post-Deactivation S&M Updated Safety Equipment List |
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Post-Deactivation S&M Procedures |
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Post-Deactivation S&M Recommendations (Inspections, maintenance, etc.) |
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Post-Deactivation photographic and/or video & audio record of the facility as-left
conditions |
End-Points Closeout Method
As stated in DOE G 430.1-3, DEACTIVATION IMPLEMENTATION GUIDE , the
completion of the deactivation project will be determined by verifying that the
end state has been achieved and the end-points have been met. End-Point files provide
evidence of the facility deactivation and contain historical information pertaining
to its as-left condition. "Closeout" refers to the method for verifying that each
end-point has been achieved. The purpose of end-point closeout is to formally demonstrate
completion to support possible audits and regulatory oversight, and to demonstrate
progress toward commitments to stakeholders. Such verification can also serve to
support quality control and quality assurance provisions when appropriate (Personnel
reviewing the files for closeout need to have a basic understanding of the End Point
Process, Facility Layout, Radiological Practices, Hazardous Materials, Industrial
Safety, and other related subjects).
One of the tasks of the end-point coordinator should be to establish the method
of end-point closeout. The purpose here is to provide an example of how to do this.
Acceptance that conditions stated by end-point specifications have been achieved
is recorded in the end-point document by the signatures of representatives of both
the deactivation and receiving organizations. The method(s) by which closeout of
each end-point is verified, as discussed here, should also be indicated in the end-point
document. For example, a closeout method "key" as described later can be written
in the reference space on the signature block. The method description, such as the
example here, should also be kept with the end-point closeout files.
An end-point may be closed using one or more of the methods that follow. Deciding
the type of closeout depends on the nature of the actual end-point (risk or hazards
involved). In most cases, the decision is left to the individuals or team that are
conducting the closeout verifications (or inspections). In some cases, the type
of closeout to use should be decided by facility management. Designating which end-point
closeouts require management decisions should be done when the end-point document
is being approved.
End-Point Files
Description
The end-point files should be arranged consistent with the order of the table of
contents for the end-point document. (Example; at PUREX, the document is arranged
by numerical building number and then alphabetically for the remainder of the facility
spaces or systems. The facility was broken down into 56 separate areas. Each area
is made up of distinct spaces and/or systems. Each area has its own file folder
that contains the specific end-point files for the designated space or system within
the area. For example, the Aqueous Make-up area file folder contains 5 individually
marked files containing the set of applicable end-points for the space or system
designated.)
Table 4 is a description of individually assigned drawers or sections of the end-point
file cabinets and a description of their contents. Additional drawers are used to
file the remaining documentation that will be generated or are references for turnover
of the facility.
Table 4 - End-Point Files
|
Drawer |
Typical Contents |
|
Workplan |
All of the work plans referenced for end-point closeout. The drawer is indexed for
ready retrieval.
The reference block on the end-point signature page should contain the index, identifier,
or number of the workplan used to record closeout of the end-point.
|
|
Video Tapes |
All of the video tapes (or other visual recording media) that have been referenced
for end-point closeout as well as others that may have value for future reference.
The drawer is indexed for ready retrieval.
The reference block on the end-point signature page should contain the index, identifier,
or number of the video used to record closeout of the end-point. |
|
Turnover Package |
Information generated to comply with the global administrative turnover package
end-state. Examples found here can include documents such as a Confined Space index,
a Hazardous Material Remaining list, an Asbestos Summary, and Hazard Communication
Program Information. The intent of filing the turnover package information separately
from the individual space or system closeout information is to allow the information
to be available for quick reference by the S&M planners and workers.
The reference block on the end-point signature page will indicate the Turnover Package
used to record closeout of the end-point. |
Radiological Maps
And Postings |
Binders containing the Final Radiological Maps and surveys that are generated to
give radiological characterization of a specific space. In addition, a binder containing
verification of proper radiological status for the applicable space is stored here.
Prior to turnover of the facility the Radiological Posting book and Fixed contamination
logs will also be stored here. |
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EPTI |
The End-Point Technical Information (EPTI) book is stored here. EPTI information
is a compilation of documentation that is intended to support end-point conclusions.
Items found here include current revisions of procedures and/or documents to capture
information referenced in the specific end-points. |
Administrative
End-Point |
Documentation collected to close the Administrative End-Points. These end-points
are global to the entire deactivation project or apply to every space and system
of the facility. |
Examples of End-Point Closeout Methods
Visual
Visual verification is defined as a walkthrough or visual inspection of the space
or system verifying the stated condition or intent of the end-point has been met.
This method is used if documentation is not required to perform and/or indicate
the full scope of work required to achieve closeout. Examples where visual verification
would be used as closeout are housekeeping, fire extinguisher removal, vermin isolation
etc.
In addition visual verification by Subject Matter Experts (SME) may be used to verify
field conditions (i.e., Asbestos) prior to the closeout of the administrative end-points
listed under the "Turnover Package" end-point.
Work Plans
A signed copy, or portions applicable, of the work plan that was written to provide
detailed work instructions of the work scope necessary to achieve the stated condition
or intent of the end-point specification. Because multiple end-point completion
can be achieved with a single work plan, a common indexed Work Plan file should
be used for closeout records.
Work Orders
A work order is usually one or two pages, which distinguishes it from a work plan.
A signed copy of the work order, or applicable portions of the work package, that
accomplishes the end-point is placed in the applicable end-point file for easy reference.
Drawings/ECNs
Copies of the essential drawing indicating "redlined" portions that reflect as-left
configurations and or Engineering Change Notices (ECNs) can be used to record acceptable
conditions. These copies are placed in the applicable end-point file for easy reference.
ECN copies used to record completion of the stated end-point condition are placed
in the file folder for the space or system. These copies may indicate redline configuration
changes.
Letters/Summaries/Memos
Specific letters, summaries, or memos recording concurrence, explanations or descriptions
of activities leading up to closeout of the stated condition or intent of the end-point.
They are uniquely identified for traceability throughout the filing system. They
are placed in the applicable end-point file for easy reference.
Audits/Assessments/Inspections
Reports, letters, or electronic messages written to record audits, inspections or
assessments performed to support closeout of the stated condition or intent of the
end-point. Examples include the Confined Space Audit and Asbestos survey. Note:
Visual verification may be used as the reference to indicate that field conditions
are acceptable prior to turnover of the administrative portion of the end-point.
Video/Photos
Video tapes are used in some cases to record that the end-point stated condition
or intent has been achieved. Videos or photographic descriptions are prudent for
most spaces where access is not expected by the post-deactivation surveillance workers.
Note: Upon viewing of the tape visual verification may be used as the reference
to indicate that field conditions are acceptable. Video viewing is used to minimize
waste and ALARA concerns created by additional manned entries to a space.
Waiver/Justification Of Change
Waivers written to justify changes of intent or work scope stated by the end-point
are written and concurred by both deactivation and post-deactivation receiving representatives.
Major modifications to the end-point document require a revision or page change
to be completed. Copies of the waiver memo are placed in the specific space or systems
file and used as the documentation to support closeout of the end-point.
Radiological Surveys
Specific radiological surveys are used to record the stated condition or intent
of the end-point. For example, a survey performed to verify that contamination is
fixed in place can be used to close a "mitigate contamination migration" end-point.
Copies of the survey are attached to a memo explaining the relationship of the survey
to the end-point. Copies of the memo are placed in both the specific space or system
file and the radiological records for easy reference.
Closeout
Method
The method(s) by which closeout of each end-point is verified should be indicated
in the end-point document. One way to do this is to use a closeout method in a reference
space on the signature block, and described here. In addition all documents written
to close a specific end-point should be assigned a unique number for traceability
throughout the files. Where applicable, the document reference should also be written
on the reference space to provide linkage.
The abbreviations in Table 5 are used to signify the closeout method and/or document
used to closeout (verify) the end-points.
Table 5 - Abbreviations for Closeout Signoff
|
Reference |
Description |
|
C. S. Index |
The Confined Space Index was field verified prior to closeout of the individual
space end-points. This index will be used for a final Confined Space report to be
completed prior to closeout of the Turnover Package administrative end-point. |
|
ECN |
Engineering Change Notices (ECN) copies used to document completion of the stated
end-point condition will be placed in the space or system file folder. These copies
may indicate redline configuration changes. |
|
I. S. Cklst |
An Industrial Safety Checklist filled out in the field by the industrial safety
experts for the deactivation and receiving organizations. Copies are placed in the
space or system file folders. The originals are retained by the industrial safety
representative and will be used for a final industrial safety report to be completed
prior to closeout of the Turnover Package administrative end-point. |
|
Ltr |
Uniquely numbered letters written to summarize the completion of activities or conditions
required to close the end-point. |
|
Memo |
Uniquely numbered memo written to summarize the completion of activities or conditions
required to close the end-point. |
|
None |
"None" is used as a statement-of-fact as determined by the SME of the applicable
end-point. For example if no asbestos is present in a space "None" would be referenced
and the end-point would be closed. |
|
Photos |
Photos taken to record the stated condition or intent of the end-point. These are
either collected in album and indexed to allow linkage to the space or system end-point,
or copies are placed in the space or system file folder. |
|
Rad Posting Book |
Memos are written verifying the radiological postings of the space or system. Copies
of these memos are collected in a "Radiological Posting End-Point Book." |
|
S&M Plan |
Refers to the Surveillance and Maintenance Plan in the Turnover Package drawer. |
|
SD |
Copies of Supporting Documents (SD) written to provide detailed descriptions or
explanations supporting completion of the stated end-point condition are placed
in the specific space or system file folders. |
|
Structural Cklst |
Checklist documenting structural adequacy. The checklist is completed by a qualified
structural engineer. Copies are placed in the space or system file folder. |
|
Survey # |
Uniquely numbered radiological surveys taken to specifically support closeout of
a radiological end-point. Record copies are sent to Records holdings with copies
placed in the specific space or system file folders. |
|
Survey Book |
Survey maps are created to support closeout of the Final radiological survey and
map end-point. These maps are collected in the Radiological Survey/Map book along
with a copy of the radiological survey from which the data was taken from. Record
copies of the surveys are sent to Records holdings. |
|
T. Package |
Turnover Package Items will be field verified prior to closeout of the administrative
Turnover Package end-point. Documentation for end-point items requiring field verification
for closeout i.e. Confined Space, Asbestos and Remaining Hazardous Materials lists
will be placed in a separate Turnover Package file drawer. |
|
Video |
Video tapes taken to record the stated condition or intent of the end-point. These
video tapes are collected in the video tape drawer and indexed to allow linkage
to the space or system end-point. |
|
Visual |
Visual verification is defined as a walkthrough or visual inspection of the space
or system verifying the stated condition or intent of the end-point has been met.
If supporting documentation was available this information was placed in the space
or system file folder. |
|
W. Order |
Work Orders written to perform activities that support closeout of a specific end-point
or that records the stated condition will be placed in the space or system file
folder. |
|
WP-xx-xxx |
Work Plans written to perform activities to support closeout of specific end-points
or that record stated conditions will be placed in a separate file drawer due to
multiple end-point closeout by the same work plan. |
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