Transition Implementation Guide <ORG> EM <SUMMARY> This draft Transition Implementation Guide was prepared to aid in the planning, decision making and early implementation of facility transition at Department of Energy facilities that have been declared excess to any future mission requirements. This draft guide also defines activities or actions that provide a sequenced risk reduction and seamless transition from operations to the selected disposition path. <DATE_ISSUE> 11/19/1999 <DATE_CLOSE> <TEXT> NOT MEASUREMENT SENSITIVE DOE G 430.1-5 XX-XX-99 DRAFT TRANSITION IMPLEMENTATION GUIDE U.S. Department of Energy Washington, D.C. 20585 DISTRIBUTION: INITIATED BY: All Departmental Elements Office of Field Integration FOREWORD The Department of Energy (DOE) faces an enormous task in the disposition of the nation's excess facilities. Many of these facilities are large and complex and contain potentially hazardous substances. As DOE facilities complete mission operations and are declared excess, they pass into a transition phase that ultimately prepares them for disposition. The disposition phase of a facility's life-cycle usually includes deactivation, decommissioning, and surveillance and maintenance (S&M) activities. DOE has developed four Guides to provide implementation guidance for requirements found in DOE O 430.1A, LIFE CYCLE ASSET MANAGEMENT, specific to the transition and disposition of contaminated, excess facilities. The Guides are DOE G 430.1-2, SURVEILLANCE AND MAINTENANCE DURING FACILITY DISPOSITION; DOE G 430.1-3, DEACTIVATION IMPLEMENTATION GUIDE; DOE G 430.1-4, DECOMMISSIONING IMPLEMENTATION GUIDE; and DOE G 430.1-5, TRANSITION IMPLEMENTATION GUIDE. The goal of the processes described in the Guides is a continuum of hazard mitigation and risk reduction throughout the transition and disposition phases, leading to timely, cost-effective disposition of the facility. Transition activities occur between operations and disposition in a facility's life cycle. Transition begins once a facility has been declared or forecast to be excess to current and future DOE needs. It includes placing the facility in stable and known conditions, identifying hazards, eliminating or mitigating hazards, and transferring programmatic and financial responsibilities from the operating program to the disposition program. Timely completion of transition activities can take advantage of facility operational capabilities before they are lost, eliminating or mitigating hazards in a more efficient, cost-effective manner. In preparation for the disposition phase, it is important that material, systems, and infrastructure stabilization activities be initiated prior to the end of facility operations. Following operational shutdown and transition, the first disposition activity is, usually, to deactivate the facility. The purpose of the deactivation mission is to place a facility in a safe shutdown condition that is economical to monitor and maintain for an extended period, until the eventual decommissioning of the facility. Deactivation of contaminated, excess facilities should occur as soon as reasonable and for as many facilities as possible. In this way, DOE can apply its resources in a manner that will accomplish the greatest net gains to safety and stability in the shortest time. Deactivation places the facility in a low- risk state with minimum S&M requirements. The final facility disposition activity is typically decommissioning, during which the facility is taken to its ultimate end state through decontamination and/or dismantlement to demolition or entombment. After decommissioning is complete, the facility or surrounding area may require DOE control for protection of the public and the environment or for environmental remediation. S&M activities are performed throughout the facility transition and disposition phase, to monitor and document the presence, status, and condition of structures, systems, components, and hazards associated with the facility. S&M is adjusted as transition, deactivation, or decommissioning activities are completed. Continuing S&M ensures, at a minimum, that any contamination is adequately contained and that potential hazards to workers, the public, and the environment are minimized and controlled. S&M is conducted during transition, deactivation, and decommissioning but can also occur during an extended period between deactivation and decommissioning. The technical, managerial, and planning perspectives offered in these Guides can be equally effective in conducting activities other than transition and disposition, such as refurbishment and "clean-up" for reuse. As such, this guidance can be adapted for use at facilities that are not being declared excess. An important objective throughout transition and disposition is to maintain an integrated and seamless process linking deactivation, decommissioning, and S&M with the previous life-cycle phases. Activities of facility transition and disposition should incorporate integrated safety management at all levels to provide cost-effective protection of workers, the public, and the environment. CONTENTS 1. Introduction. . . . . . . . . . . . . . . . . . . . . . . . .1 1.1 Purpose . . . . . . . . . . . . . . . . . . . . . . . . .1 1.2 Alternative Methods . . . . . . . . . . . . . . . . . . .1 1.3 Applicability . . . . . . . . . . . . . . . . . . . . . .2 1.4 Crosswalk, DOE O 430.1A Requirements to DOE G 430.1-5 . .2 2. Transition Activities General Guidance. . . . . . . . . . . .5 2.1 Project Management Principles . . . . . . . . . . . . . .6 2.1.1 Use of Project Management System. . . . . . . . .6 2.1.2 Detailed Engineering Planning . . . . . . . . . .6 2.2 Integrated Safety Management. . . . . . . . . . . . . . .7 2.3 Graded Approach . . . . . . . . . . . . . . . . . . . . .7 3. Transition Program. . . . . . . . . . . . . . . . . . . . . .9 3.1 Transition Objectives and Goals . . . . . . . . . . . . .9 3.2 Transition Cases. . . . . . . . . . . . . . . . . . . . 10 3.2.1 Case 1: Facilities Currently Operating . . . . 11 3.2.2 Case 2: Facilities Not Currently Operating . . 11 3.3 Major Transition Steps. . . . . . . . . . . . . . . . . 12 4. Transition Activities and Processes . . . . . . . . . . . . 15 4.1 Task Focus for Transition Work. . . . . . . . . . . . . 15 4.2 Step 1: Excess Declaration and Transfer Initiation . . 19 4.3 Step 2: Establish Management and Planning Teams. . . . 20 4.4 Step 3: Identify Facility Conditions . . . . . . . . . 22 4.5 Steps 4 and 5: Identify and Perform Early Actions. . . 25 4.6 Step 6: Identify Disposition Path. . . . . . . . . . . 26 4.7 Step 7: Assess and Adjust Authorization Basis. . . . . 26 4.8 Step 8: End-Points . . . . . . . . . . . . . . . . . . 27 4.8.1 End-Point Development . . . . . . . . . . . . . 28 4.8.2 End-Point Allocation. . . . . . . . . . . . . . 30 4.9 Step 9: Project Planning and Execution for End-Point Activities31 4.10 Step 10: Pre-Transfer Review . . . . . . . . . . . 31 4.11 Step 11: Facility Transfer . . . . . . . . . . . . 33 4.12 Transition Planning Tools . . . . . . . . . . . . . 33 Figure 1, Facility Transition. . . . . . . . . . . . . . . . . 13 Table 1, Mapping of Requirements Transition. . . . . . . . . . .2 Table 2, Task Types, Criteria, and End Points. . . . . . . . . 16 Attachment 1: Checklist of Transfer Activities Attachment 2: Pre-Walkdown Survey Attachment 3: Facility Condition Walkdown Checklists 1. INTRODUCTION 1.1 PURPOSE This Guide was prepared to aid in the planning, decision making, and early implementation of facility transition at Department of Energy (DOE) facilities that have been declared excess to any future mission requirements. It is one of four that have been developed to provide guidance for facility transition and disposition activities. The other three Guides are DOE G 430.1-2, SURVEILLANCE AND MAINTENANCE DURING FACILITY DISPOSITION; DOE G 430.1-3, DEACTIVATION IMPLEMENTATION GUIDE; and DOE G 430.1-4, DECOMMISSIONING IMPLEMENTATION GUIDE. Requirements for transition are stated in DOE O 430.1A, LIFE CYCLE ASSET MANAGEMENT (LCAM), which identifies the minimum requirements for disposition of an excess DOE facility. This Guide defines activities or actions that provide a sequenced risk reduction and seamless transition from operations to the selected disposition path. It is part of the DOE Directives System and is consistent with the principles and core functions of DOE P 450.4, SAFETY MANAGEMENT SYSTEM POLICY. Other documents that should be consulted to support the planning and conduct of transition and disposition activities include DOE-STD-1120-98, Integration of Environment, Safety and Health into Facility Disposition Activities, and the Good Practice Guides associated with LCAM, which can be found on the Office of Field Management web site (http://www.fm.doe.gov). 1.2 ALTERNATIVE METHODS This Guide presents acceptable methods for implementing the transition requirements specified in LCAM to ensure effective and efficient management of DOE excess facilities. It does not impose additional requirements. The Department has invested substantial time and effort in developing a transition framework that (1) meets DOE's requirements and expectations, (2) draws on DOE's previous experience, and (3) satisfies the requirements of oversight entities such as the Defense Nuclear Facilities Safety Board (DNFSB). Although alternative methods and approaches to the ones discussed in this Guide may be used, a comparable amount of time and effort may be needed to evaluate the acceptability of those alternatives.1.3 APPLICABILITY This Guide may be applied to transition activities and processes at contaminated DOE facilities. "Contaminated" refers to both radioactive contamination and to hazardous-substance contamination. Nuclear facilities and non-nuclear-contaminated facilities are included in the scope of this Guide. Project personnel are expected to apply a graded approach in planning and conducting transition activities at different types of facilities and with different hazard conditions. 1.4 CROSSWALK, DOE O 430.1A REQUIREMENTS TO DOE G 430.1-5 LCAM requirements that apply to the transition of a contaminated, excess facility are included in Table 1, cross-referenced to the section of this Guide where they are addressed. Although the table quotes the requirements as they appear in LCAM, this Guide addresses only those requirements that apply to the transition process. Parallel tables in the other three LCAM Guides provide crosswalks between requirements and guidance for surveillance and maintenance (S&M), deactivation, and decommissioning, respectively. Table 1. Mapping of Requirements Transition Requirement Where Addressed in Guide DOE O 430.1A, paragraph 6a: DOE elements shall use a value-added, quality driven, graded approach to life cycle asset management. Section 2.3, Graded Approach DOE O 430.1A, paragraph 6f(1): The identification, inventory, and periodic assessment of the condition of physical assets in the maintenance program. Section 4.4, Identify Facility Conditions DOE O 430.1A, paragraph 6f(8): A method to ensure that prior to the completion of mission activities (e.g., production, research, etc.) actions are implemented to place the facility, systems, and materials in stable and known conditions, and to ensure hazards are identified and known, pending transfer or disposition. For facilities that have already completed mission activities and are awaiting transfer or disposition, ensure that actions are taken to eliminate or mitigate hazards and provide adequate protection to workers, the public, and the environment. In both cases, actions shall be based on an assessment of the remaining hazards at the time when mission activities are completed, or prior to transfer or disposition for facilities that have already completed mission activities. Sections 4.5, Identify and Perform Early Actions; and 4.8, End-Points DOE O 430.1A, paragraph 6f(8)(a): Identifying and characterizing hazardous and radioactive materials and wastes remaining in systems/facilities and providing for their stabilization (if necessary), adequate storage until they are removed from the facility, and (unless agreed to prior to facility transfer) removal. Section 4.4, Identify Facility Conditions DOE O 430.1A, paragraph 6f(8)(b): Assessment and adjustment (if necessary) of the facility authorization basis to ensure it continues to reflect conditions in the facility pending disposition. Section 4.7, Assess and Adjust Authorization Basis DOE O 430.1A, paragraph 6f(8)(c): Identifying S&M activities required to maintain the facility and remaining hazardous and radioactive materials, wastes, and contamination in a stable and known condition pending facility disposition. Sections 4.2, Excess Declaration and Transfer Initiation; 4.4, Identify Facility Conditions; and 4.10, Pre-Transfer Review DOE O 430.1A, paragraph 6f(8)(d): Identifying and allocating resources needed to maintain stable and known conditions pending facility disposition. Sections 4.3, Establish Management and Planning Teams; and 4.10, Pre-Transfer Review DOE O 430.1A, paragraph 6g(1): Application, as appropriate, of guidelines contained or referenced in DOE- STD-1120-98, Integration of Environment, Safety and Health into Facility Disposition Activities. Sections 1.1 Purpose; and 2.2, Integrated Safety Management DOE O 430.1A, paragraph 6g(3): A method whereby land and facilities (candidates for transfer) are either transferred to other Program Offices, or are determined excess, available for disposal, and disposal procedures are initiated. Section 4.2, Excess Declaration and Transfer Initiation DOE O 430.1A, paragraph 6g(4): To match the Departmental budget cycle, the normal date of transfer for a facility shall be the first October 1 after the two year anniversary of the date the receiving organization is notified, unless the parties reach another agreement. As land and facilities are transferred from one Program Office to another, the appropriate funding and budget target are transferred with it. Section 4.2, Excess Declaration and Transfer Initiation DOE O 430.1A, paragraph 6g(5)(a): Completion of a Pre- Transfer Review, with participation by the Office of Environment, Safety and Health when requested or directed, for transfer of facilities for disposition whose scope shall be commensurate with the existing hazards. Sections 4.10, Pre-Transfer Review; and 4.11, Facility Transfer DOE O 430.1A, paragraph 6g(5)(b): Development of a signed agreement by relevant Secretarial Officers to document scope, conditions, state of readiness, and associated funding, when transferring facilities between Program Offices. This includes a budget resources plan to manage the facility until funding is provided to the receiving program through the normal budgeting process. Section 4.11, Facility Transfer DOE O 430.1A, paragraph 6i: DOE corporate physical assets databases shall be maintained as complete, current inventories of the DOE physical assets. For real property, the corporate database is Facilities Information Management System. Sections 4.2, Excess Declaration and Transfer Initiation; 4.10, Pre-Transfer Review; and 3.1, Transition Objectives and Goals DOE O 430.1A, paragraph 6j: In the acquisition, operation, maintenance, leasing and disposition of physical assets, DOE elements shall ensure that all applicable Federal, state, and local laws, regulations, and negotiated agreements are followed, and that safeguards and security as well as integrated safety management requirements and policies are followed. Sections 2, Transition Activities General Guidance; and 4.8.1, End-Point Development 2. TRANSITION ACTIVITIES GENERAL GUIDANCE Preparation for the successful disposition (either deactivation or decommissioning) of a contaminated, excess facility can be enhanced greatly by completing certain activities during the transition period. Paragraph 6f(8) of LCAM requires that stabilization activities for facilities, systems, and materials be initiated prior to the end of facility operations, pending transfer or disposition. Activities during this transition period could include, for example draining nonessential systems; removing any remaining hazardous chemicals, spent fuel, and other radioactive materials and wastes; Resource Conservation and Recovery Act (RCRA) closures; and related actions. A commitment to complete these activities during the transition of a facility to the disposition phase of its life-cycle supports the protection of workers, the public, and the environment. To establish safer conditions before proceeding to disposition, it may be prudent to conduct a stabilization campaign at the end of operations for facilities that contain materials, either in inventory or as holdup in areas such as equipment, pipelines, and filters. For example, it may be appropriate to conduct a process/equipment clean-out run to either process quantities of radioactive or chemically reactive liquids, clear process systems, or remove nuclear fuel for the purpose of clearing a storage area. A systems engineering approach should be used throughout transition and disposition activities to ensure that essential elements and activities are integrated at appropriate levels. These elements include safety management as defined in DOE P 450.4, SAFETY MANAGEMENT SYSTEM POLICY, and the application of a graded approach. DOE is committed to conducting all work efficiently, protecting workers, the public, and the environment, and maintaining a safe shutdown configuration. Additional requirements for planning and conducting transition activities may be contained in other documents. It is not the intent of this document to offer guidance for these requirements. In the transfer and disposition of DOE physical assets, the project manager and others involved with the development and/or execution of the disposition project should, in accordance with LCAM, be well versed with other Federal, state, and local laws and regulations as well as those requirements that address integrated safety management, conduct of operations, conduct of maintenance, radiological protection, and other requirements integral to planning, developing, and conducting the work. Throughout the transition period, the facility characterization should be updated for the Pre-Transfer Review, which documents and verifies the completion of transition activities and establishes the new baseline, including a revised authorization basis. S&M activities are adjusted and performed to monitor and document the presence, status, or condition of structures, systems, components, and hazards associated with the facility as transition activities are completed. Continuing S&M ensures, at a minimum, that any contamination is adequately contained and that potential hazards to workers, the public, and the environment are minimized. Further guidance on S&M activities is found in DOE G 430.1-2, SURVEILLANCE AND MAINTENANCE DURING FACILITY DISPOSITION. 2.1 PROJECT MANAGEMENT PRINCIPLES Project management envelopes the entire transition and disposition process including planning, design, execution, and closure. A clear understanding of these phases enables greater control of DOE resources in achieving the transition and disposition goals. Two principles are key to achieving this understanding: (1) use of a project management system and (2) detailed engineering planning. 2.1.1 Use of Project Management System Using a project management system assists in the successful completion of each phase of a transition project, from facility assessment, through technical engineering, to project execution. Project planning establishes the project's requirements and describes how the project will be accomplished. The top- level objectives for project planning of transition activities include the following: protect workers, the public, and the environment; eliminate or mitigate hazards within the facility; facilitate S&M during transition and into disposition; facilitate deactivation and/or ultimate decommissioning work; comply with regulations and requirements, including administrative requirements; and follow through on commitments to stakeholders. 2.1.2 Detailed Engineering Planning The LCAM Order requires that an "end-point" process for detailed engineering planning and plan documentation be used to identify and execute the preferred deactivation and/or decommissioning alternative. During transition, an end-point process is also important for planning and executing stabilization activities. Just as design specifications and drawings are essential to systematically detail a construction project, specifying "transition end-points" is the comparable discipline to planning, implementing, measuring, and knowing when transition activities are complete. The process for identifying transition end-points is discussed in more detail in section 4.8. 2.2 INTEGRATED SAFETY MANAGEMENT Sufficient planning should be done to systematically integrate a safety management system into management and work practices at all levels. DOE's safety management system policy and guidance are identified in DOE P 450.4, SAFETY MANAGEMENT SYSTEM POLICY, and DOE G 450.4- 1, INTEGRATED SAFETY MANAGEMENT SYSTEM GUIDE. The major mechanism for integrating safety and health into transition efforts is the work planning process, during which safety documentation from the facility's operational phase is reviewed and evaluated. Because many early hazard elimination and mitigation actions are operations or "operations like" activities, they are most likely already covered in existing operations safety documentation. Transition activities are identified and evaluated against existing controls, and modification to controls are identified as required by the new activities that were not previously performed during operations. Often, the safety documentation of an older facility, including worker safety and health aspects, fall short of today's standards and requirements. Revisions, comparisons, crosswalks, and other evaluation techniques can be used to determine which transition actions may be covered in existing documentation and which actions require supplemental coverage. Such evaluation efforts, especially if performed by those who know the facility well, are more cost effective and time efficient than the preparation of new safety documentation. Worker involvement in all levels of safety/hazards analysis in the planning of transition activities is key to implementing all elements of transition. DOE-STD-1120-98, Integration of Environment, Safety, and Health into Facility Disposition Activities, provides guidance on integrating health and safety into facility disposition activities and can be useful for conducting transition activities. 2.3 Graded Approach The "graded approach" or the tailored application of requirements to a particular project, activity, or facility is required by LCAM, and by 10 CFR 830, Nuclear Safety Management. Application of the graded approach is appropriate for all steps in facility transition. The preamble of the Nuclear Safety Management rule, published in the Federal Register on April 5, 1994, describes the intent of DOE with respect to the graded approach: "graded approach" was developed to describe the process used to determine which actions would be appropriate for a particular facility. DOE believes that this process should be sufficiently broad and flexible to take into account differences among various facilities. The intent of the graded approach is to permit DOE contractors the flexibility to implement activities and processes, as appropriate, to comply with the nuclear safety requirements for the individual facilities. The graded approach does not exempt a facility from a nuclear safety requirement. In applying a graded approach, however, a determination may be made that certain actions may not be appropriate for a particular facility. (59 FR 15844; April 5, 1994.) Application of the graded approach during transition allows for consideration of differences among facilities and provides a means to determine the extent to which actions are appropriate for transition. The depth of detail required and the magnitude of resources expended for a particular transition element are tailored to be commensurate with that element's relative importance to safety, environmental compliance, safeguards and security, current operational capability, programmatic importance, magnitude of the hazard, financial impact, and/or other facility-specific requirements. Tailoring the integrated safety management system offers another means to grade activities and processes to different hazards associated with individual facilities. Tailoring is used to scale expectations and acceptable performance to the needs of the site, activity, facility, or work to be performed. When applied to the core functions of safety management, tailoring promotes a work management system that is safe, efficient, and cost-effective. 3. TRANSITION PROGRAM 3.1 TRANSITION OBJECTIVES AND GOALS Transition activities occur between operations and disposition in a facility's life cycle. Transition begins once a facility has been declared or forecast to be excess to current and future DOE needs. It includes placing the facility in stable and known conditions, identifying hazards, eliminating or mitigating hazards, and transferring programmatic and financial responsibilities from the operating program to the disposition program. Timely completion of transition activities can take advantage of facility operational capabilities before they are lost, eliminating or mitigating hazards in a more efficient, cost-effective manner. The transfer process from the operating program to the disposition program can take a considerable time, generally, more than 2 years. Therefore, it is important that progress is made during this interval toward supporting the future disposition path. Key objectives and goals during facility transition include the following: an expeditious start of activities to eliminate or mitigate hazards, beginning with those that clearly should be done regardless of the subsequent mode of disposition; completion of activities as defined in the "transition end-points" (described in section 4.8), with priority given to the specified end-points for mitigation and removal of hazards and materials; maximum use and effectiveness of current operations knowledge, personnel, and operating systems/programs to reduce the facility hazards, with emphasis placed on processes and systems for which the skills and knowledge required are unique; effective partnering among all involved parties (in particular, among the operating and disposition program, field elements, and/or contractors); the seamless and integrated transfer of the facility from the operations phase to the disposition phase. The degree to which these goals can be achieved at a facility will vary greatly based on the facility's current conditions, configuration, and status. Early actions to eliminate or mitigate hazards (e.g., to clean out runs of process systems) should receive the highest priority. Early actions are discussed in more detail in section 4.5. For other activities, the transition end-point development process identified in section 4.8 will ensure that the appropriate activities are identified for completion. Typical examples of early actions and transition end-point criteria include the following: As soon as acid in storage is no longer needed, it is either sold or neutralized and disposed of as waste. New nuclear fuel is sold or shipped to a DOE facility for recycling or dismantling. Unstable materials and/or wastes are stabilized, treated, and/or removed. The potential for fire/explosion from violent chemical reactions or nuclear criticality is reduced or eliminated. Tanks are emptied. A final process run is completed for all systems, lines, and other equipment that has potential for significant material holdup. Changes in configuration and status of systems and structures as a result of transition activities are reviewed against the safety basis. Revised controls are provided as appropriate to changed conditions. Barriers are installed and/or verified sufficient to prevent the spread of contamination. Appropriate safeguards and security are provided. 3.2 Transition Cases DOE facilities can broadly be grouped into three general categories (or cases): Case 1 facilities are currently operating in fulfillment of mission objectives (research, weapons production, etc.). Case 2 facilities have ceased mission-related operations. The status of Case 2 facilities can range from facilities with some operational systems (e.g., ventilation) to those that are essentially locked up and/or abandoned with no operational activities. Case 3 facilities have already been accepted into the Office of Environmental Management cleanup program and are outside the bounds of further discussion in this Guide. A thorough understanding of Case 1 and 2 facilities is important due to the difference in facility condition, configuration, and other variables. Implementation of transition activities is bound by different constraints and will require different allocation of approaches to ensure success. 3.2.1 Case 1: Facilities Currently Operating For Case 1 facilities (i.e., those that are still operational), the goals identified in section 3.1 can be accomplished straightforwardly during transition. Through coordination with the affected programs and field elements, the facility is projected to become excess and begin transition while a final operating campaign is still underway. The probable disposition path towards deactivation or decommissioning is identified, and the transition activities are completed. Transition activities can take full advantage of the final operating campaign and the fact that facility resources (i.e., personnel, procedures, systems, etc.) are still available. For example, clean-out runs of process systems and equipment may be appropriate to process quantities of radioactive and/or chemically reactive liquids, clear process systems, remove nuclear fuel, etc. This leveraging of final operations to accomplish transition is advantageous and cost-effective. Once operational capability no longer exists without substantial requalification and/or refurbishment (i.e., Case 2 below), it can be difficult and expensive to perform the necessary transition and subsequent disposition activities. With early planning, the goal of a seamless, integrated transition from the operations to disposition can more readily be accomplished. Depending on the projected time for completion of operations and transition end-point activities, transfer can be timed to meet the 2-year budget planning cycle. Transfer to the receiving Program Office should be planned for the beginning of the fiscal year, 2 years after notification. 3.2.2 Case 2: Facilities Not Currently Operating A non-operational or Case 2 facility is one that is in (1) any condition of standby, (2) shutdown, and/or (3) abandonment (i.e., it is considered "legacy"). A Case 2 facility ceases operation before there is an opportunity to take full advantage of operational capability and resources. As a result, transition activities to meet the above-stated objectives have generally not been accomplished during the final operating campaign. Two undesirable results follow. First, the transition/disposition activities, at substantial cost, may have to rebuild some or all of the operational capabilities required to implement early actions and other transition activities to reduce hazards. Second, the lack of early actions for transition may result in a period of unnecessarily high S&M costs because of the remaining facility hazards. The earlier the transition can occur, the more S&M costs can be reduced. An abandoned or "legacy" facility is one that ceased operation long ago and for which there is little current operating knowledge base. Transition may require a significant effort to identify and evaluate existing conditions before determining appropriate transition activities and taking the requisite actions. 3.3 Major Transition Steps Figure 1 identifies the major transition steps presented in this Guide. These steps are designed to meet the goal of hazard elimination or mitigation and to advance disposition in a cost-effective manner that is seamless and integrated with disposition planning. As Figure 1 shows, transition activities and disposition planning activities begin with the declaration or forecast of the facility as excess. S&M will continue during transition, with modification appropriate to changing hazards and risk. The steps are discussed in detail in Chapter 4. Variation in facility situations leads to numerous possibilities among the characteristics described for Cases 1 and 2. For example, early actions (Step 5) are more likely to occur for Case 1 facilities than they are for Case 2 facilities, which will undoubtedly require a heavier initial emphasis on identification of facility conditions (Step 3). Early planning as part of transition is necessary to sort out these possibilities and define early actions for each facility. Figure 1 - Facility Transition 4. TRANSITION ACTIVITIES AND PROCESSES This section focuses on the interactive and iterative sequence of specific "steps" aimed at supporting and providing a framework for facility transition. As previously noted, the degree of effort for each step depends on the characteristics of each facility (i.e., Case 1, Case 2 variations). A primary goal for transition is to focus on "early actions" that (1) cost-effectively reduce hazards and risk and (2) support a seamless process from the end of facility operations through disposition. 4.1 TASK FOCUS FOR TRANSITION WORK Experience has shown eight general types of deactivation tasks. These tasks are also appropriate for activities within the transition phase, prior to facility transfer to the disposition organization. The task types address the following issues: hazards, radiation fields, contamination, waste, isolation and containment, monitoring and control, refurbishing and installing, and documenting and labeling. DOE has established specific criteria for determining the associated actions to be performed at the facility for each task type. The task types are presented in Table 2 along with example criteria and end-points. These task types, and the examples, can help in determining what early actions focus on hazard elimination or mitigation and end-point specifications that are cost-effective in the ultimate disposition of the facility. The examples in Table 2 are facility-specific and will not apply to all facilities. The challenge is to identify the transition actions appropriate for a particular excess facility prior to transfer and disposition. Table 2. Task Types, Criteria, and End Points. Task Type Example Criteria Example End Points 1. Hazards The elimination or reduction of hazards, nuclear and nonnuclear, is a fundamental action to achieve defense-in-depth protection for the facility. Elimination and/or reduction activities include removing, isolating, draining, and minimizing activities. Administrative reviews of unknown hazardous conditions (e.g., confined spaces) are also included in this task type. Sufficiently remove or disperse held-up material to eliminate the potential for a credible criticality accident and the need for a criticality alarm system. Empty process equipment and piping of process chemicals. Remove lab chemicals and reagents after they are no longer needed. Ensure structural stability. Determine fire protection/ detection in the Fire Hazard Analysis. Ensure no unattached combustible materials remain. Electrically de-energize equipment. Isolate equipment no longer required. Dissolver vessel A has been emptied to less than 25 gm Pu and neutralized. Fuel has been removed from the reactor and placed in the storage pool. Tank X has been emptied of nitric acid and flushed to allowable residual concentration per technical specifications. A limited structural analysis has been conducted to verify structural integrity for a minimum of 5 years. All loose material has been removed from feed pump cubicle. Sprinkler system has been isolated in feed pump cubicle. Existing electrical service to the facility has been disconnected leaving power for surveillance lighting. Leads to abandoned feed pump have been lifted. Lubricants have been drained from abandoned feed pump. 2. Radiation Fields The reduction, shielding, or isolation of radiation fields supports ALARA practices and protects workers while performing activities throughout the facility. Activities associated with this task type include removal, shielding, documenting, and ensuring proper radiological posting of remaining radiation fields. Establish maximum general area dose rates for surveillance corridors using ALARA, cost benefit, and reasonable best efforts. Remove or shield source material to mitigate radiation exposure using reasonable best efforts and in accordance with 10 CFR 835 for fixed surface contamination. Eliminate temporary radiological areas outside process system rooms. Hot spots in ventilation control panel/MCC room 434A have been decontaminated for unrestricted access. Demineralizer A cubicle has been locked and posted as a high- radiation area. Table 2. Task Types, Criteria, and End Points (continued). Task Type Example Criteria Example End Points 3. Contamination The removal, reduction, or isolation/containment of radioactive contamination to mitigate and prevent spreading supports ALARA practices and protects workers while performing activities throughout the facility. Activities associated with this task type include decontaminating, isolating, fixing, documenting, and ensuring proper radiological posting of contaminated areas. Establish maximum non-fixed contamination levels for surveillance corridors using ALARA, cost benefit, and reasonable best efforts, and in accordance with 10 CFR 835. Record remaining contamination levels for future information. Remove/fix/contain source material to mitigate contamination migration using reasonable best efforts. Contaminated ventilation duct 17X in main corridor has been removed. Open ends have been sealed to prevent flow in or out. Survey requirements have been included as part of the turnover package to verify containment of radioactive contamination. Hood face has been isolated/sealed to inhibit contamination migration. Sample box access points have been isolated/sealed. 4. Waste Compliance with regulations and requirements drive the removal and disposal of radioactive, dangerous, and mixed waste items from the plant. Task type activities generated by these regulations and waste minimization practices include removal, tank flushing, excessing, RCRA permitting, and waste disposal. Remove/dispose of radioactive, dangerous, and mixed wastes. Housekeep and remove unattached material/equipment using reasonable best efforts. Contents of out-of-service ethylene glycol closed-loop heat recovery system have been drained. Piping has been cleaned to comply with regulatory commitments for chemical residuals. Cleanup demineralizer media have been removed and disposed of. Mercury switches that no longer serve a function have been removed. 5. Isolate and Contain Effective containment of the facility's remaining hazards and protection from the environment is another fundamental action of the defense-in-depth approach. Task type activities include blanking, plugging, covering, removal, screening, and sealing of doors, windows, pipe penetrations, holes, drains, etc. Prevent the uncontrolled migration of both hazardous substances and radioactive contamination to the surrounding space. Minimize in-leakage of snow and rain water. Roof integrity has been checked to ensure the prevention of in- leakage for a minimum of 5 years. Engineered barriers/seals have been checked to ensure they are in place to inhibit migration of hazardous substance contamination to the environment. Exterior door seals have been checked to ensure they are in proper working order. Floor drains have been isolated/plugged to localize water intrusion. Table 2. Task Types, Criteria, and End Points (continued). Task Type Example Criteria Example End Points 6. Monitor and Control Monitoring and control are the final fundamental actions of the defense- in-depth approach to achieve a safe, stable facility condition. This task type provides the activities required to support and minimize the cost, risk, and hazards involved with the future S&M of the facility. Provide utilities needed for visual and instrumentation surveillance, using existing, new, or portable equipment. Provide ability to monitor all effluents with sufficient lead time to terminate flow and remain within technical specification limits in the event of an upset. Define system discharge monitoring and instrumentation requirements. Capability to energize Corridor X lights from circuit breaker panel has been provided. Drains from auxiliary building to radwaste building have been isolated/sealed. Interim ventilation ducting from Room C exhaust plenum to Ventilation System A has been installed and fixed in place. Ventilation System B and its monitors have been shut down. Passive-level sensor has been provided in drain collection tank Z. 7. Refurbish or Install Issues identified during the stabilization that should be completed to ensure a safe, sound, stable facility are included in this task type. Activities include structural repairs and roof sealing and modification to the facility ventilation system. A simple cost benefit analysis should be performed prior to including an activity under this task type. For example, the cost to repair a small ancillary building's leaking roof may warrant demolition rather than repair. Refurbish industrial safety deficiencies as needed for human surveillance activities. Refurbish facility as required by the structural and roof integrity studies. Reconfigure waste liquid system B for processing rinse water from water abrasive blast decontamination unit. Install access barrier at Elevator B Doors. Repair building A roof to a 10- year standard. 8. Document and Label This task type covers the documentation and labeling required for the specific space or system. Additional supporting documentation not included in the other task types but specific to the space or system is also included here. Provide transfer information package (see section 4.9). Label systems and equipment that are abandoned in place. Ensure that equipment isolation tags for permanently shutdown systems will last 10 years in the local environment without temperature or humidity controls. Amounts and locations of remaining hazardous substances/dangerous wastes have been documented. Identified area industrial hazards have been documented for inclusion in the transfer information package. Amounts and locations of remaining hazardous substances/dangerous wastes have been documented. Table 2. Task Types, Criteria, and End Points (continued). Task Type Example Criteria Example End Points 8. Document and Label (continued) Ventilation system restart and preventive maintenance procedures have been included as part of the turnover package. Space and associated system(s) dose rates and contamination levels have been documented in the final radiological survey report and map per the Site Radiological Control Manual for inclusion in the turnover package. Feedwater systems have been labeled as abandoned in place. 4.2 STEP 1: EXCESS DECLARATION AND TRANSFER INITIATION Paragraph 6g(3) of the LCAM Order drives the need for a method to declare assets excess. DOE Program Secretarial Officers (DP-1, SC-1, NE-1) have programmatic and fiscal accountability for facilities under their "ownership" and, as such, have authority to define and approve the excess status of their facilities. Although the process for identifying a facility as excess can be initiated at any point in the Program Office/Field Office/Contractor organizational structure, the ultimate decision for communicating facility status as excess to program needs rests with the Program Secretarial Officer (PSO), in coordination with the Office of Field Integration (FI). The excess status of a facility should be identified in DOE's Facility Information Management System (FIMS). Decisions to designate facilities as excess are driven primarily by programmatic mission need and budget considerations and secondarily by the advanced age and deteriorating condition of many DOE facilities. Although excess facilities may be reused by other DOE Program Offices, other Federal and state government agencies, and to a lesser extent private concerns, the predominant direction for DOE excess facilities is stabilization, deactivation, and decommissioning. DOE/EM-0285, RESOURCEFUL REUSE, provides guidance for determining facility status for programmatic needs and for coordinating with FI to determine the status of facilities with respect to broader DOE needs (i.e., whether it is needed by other PSOs) and/or if it is subject to transfer via established General Services Administration (GSA) processes identified in 41 CFR 101, FEDERAL PROPERTY MANAGEMENT REGULATIONS. Guidance focuses on acceptable methods to declare facilities as excess to DOE; that is, establishing candidacy for transfer to the DOE receiving program and communicating requests for initiating transition. As discussed in DOE/EM-0285, the primary factor in establishing candidacy for transfer to the DOE Office of Environmental Management (EM) is the presence of contamination and the need to perform deactivation and decommissioning. A secondary consideration involves establishing the facility as a "whole" unit (i.e., not part of a larger facility that is not excess), which is structurally independent with separate utilities and support systems. Additional guidance on excess determination is provided in DOE/EH-413/9712, Cross-Cut Guidance on Environmental Requirements for DOE Real Property Transfers. Once a contaminated facility is determined to be excess to DOE mission needs and a candidate for transfer to EM, PSOs, in coordination with FI, provide transfer notification to EM. Consistent with LCAM requirements, notification should be provided at least 2 years prior to October 1 of the year of desired transfer. To provide adequate financial and resource support for early stabilization and characterization actions, and to evaluate and identify budget and target elements prior to October 1, it will generally be necessary to begin planning and gathering information 6 months or more in advance. It is advisable to establish a Memorandum of Understanding (MOU) between the operating program and EM about 6 months before the 2-year notification date. The MOU should identify roles and responsibilities during transition and empower a Transition Planning Team (see section 4.3). This team can establish specific information objectives that address (1) the physical condition/contamination status of facilities (discussed in section 4.4), (2) early actions needed (discussed in section 4.4), and (3) the administrative/budgeting status of facilities. 4.3 STEP 2: ESTABLISH MANAGEMENT AND PLANNING TEAMS Establishing management and planning teams is a means of setting up communications and cooperative action between the facility's operational or custodial organization and the organization that will be responsible for its disposition, which will generally be EM for contaminated, excess facilities. Regardless of whether this interface is accomplished with teaming, the downstream owner should participate in setting the transition goals that will support disposition. From lessons learned throughout the DOE complex, a major factor for successfully completing projects is early involvement of affected organizations. Establishing teams during the transition process is one way to ensure that the affected programs and organizations form working partnerships, participate in development, and concur with the facility transition and disposition path. The intent is not to develop an additional layer between the facility and the DOE Program Offices. The goal is to provide effective access to resources necessary to assist the facility in developing and executing the transition and disposition activities through partnering efforts. The approach discussed here uses two distinct teams: (1) a transition management team to oversee the transition and (2) a transition planning team to plan and direct the conduct of work associated with facility transition and the process identified in this Guide. Typically, the transition management team consists of affected senior level managers from Headquarters programs, the DOE Field or Operations Office, and the contractor representing both the operating and the receiving organizations (if different). The composition, size, and leadership of this team should be determined using the graded approach based on facility complexity, hazards, risks, and programmatic impacts. The purpose of the transition management team is to advise, monitor, and approve plans for the facility transition and disposition activities. Roles and responsibilities of the team may include the following, as appropriate: providing access to the full range of skills within respective organization structures; approving strategies and plans; mediating institutional and financial issues; promptly resolving conflicts that might impede expected results; ensuring schedule and budget for the facility are mutually consistent with overall priorities and allocations; and directing formation of the transition planning team. The transition planning team includes facility and program representatives from the DOE Field Office, as well as operating program and receiving program contractor representatives (if different). Formation of this team should again be based on the use of the graded approach considering hazards, risks, and complexity of the facility and project. The transition planning team is to assist in identifying and implementing early actions and subsequent end-points driven activities for facility transition. 4.4 STEP 3: IDENTIFY FACILITY CONDITIONS The LCAM Order requires that facility maintenance conditions be identified and that hazardous materials and wastes be identified and stabilized (if necessary), stored, and removed. This identification process, which is the responsibility of the operating organization, entails a graded characterization of the facility to establish existing conditions and facility contents. The intent of the identification process is to clearly identify and record what is known and what is not known about facility conditions. Case 1 facilities may not need much effort for this process because up-to-date information probably exists. On the other hand, Case 2 facilities may require more identification activities, especially if the facilities are perceived or are known to contain hazards for which the characterization is not available. Guidance provided in this section focuses on the identification and characterization aspects of the LCAM requirements. The information obtained supports the initiation of early actions and transition end-point activities. In addition, the information obtained will be included as part of the Pre-Transfer Review, as discussed in section 4.10. The primary drivers for the identification and characterization of the facility are (a) deciding and specifying early actions and facility transition end-points, and (b) developing information documenting the revised authorization basis and facility conditions prior to transfer. The LCAM Order requires that chemical and radiological hazards to workers, the public, and the environment be identified and known during transition to the disposition phase; however, facility characterization during transition is generally not intended to achieve the level of information needed for full deactivation or decommissioning. Depending on complexity and level of existing characterization information available, the cost and resources to characterize and prepare facilities for transfer may be substantial and may not be accounted for in program office budgets. As such, issues may arise between the owning program and EM on the level of information needed for unknown contamination conditions. Criteria to use in resolving these cost and resource issues may include, for example: identification of a characterization level that is sufficient to support an S&M program that is consistent with DOE G 430.1-2, pending disposition; least-cost options; and the use of non-invasive/non- destructive analytical procedures where possible. On the other hand, the operating program and EM may agree to work together on a greater level of detailed characterization when near-term deactivation/decommissioning is expected upon receipt by EM and it makes scheduling and economic sense to fully identify facility contamination conditions at an early stage to facilitate planning. The transition planning team, which generally comprises a multi-discipline group of site managers, engineers, safety and health personnel, and workers, can use facility "walkdowns" to satisfy information objectives for planning, characterization, and early actions. Attachment 1, Checklist of Transfer Activities; Attachment 2, Pre-Walkdown Survey; and Attachment 3: Facility Condition Walkdown Checklists, provide tools that may be used by the Planning Team to focus on these information needs. Facility condition identification begins with defining the facility's boundaries for disposition. This should include a list of physical structures and waste sites associated with the facility. Documents essential to the process success include authorization basis documents, environmental documentation, documents containing operating history, and documents detailing process knowledge. The process of characterization should begin with the use of existing knowledge of the facility and its material inventory, including facility condition assessments from the operations phase. Existing information should be relied on with caution, especially for Case 2 facilities. Additional characterization by walkdowns of the facility and hands-on system reviews may be needed to provide a more detailed understanding and also to provide information on changes in hazardous conditions that have resulted from cessation of facility operations. It is equally important in such cases to limit the information sought to that needed for safety and transition activity planning. Identifying facility conditions is one key area where facility status (Case 1 or 2 from section 3.2) will have a significant impact. In application of the graded approach, if facility operations are ongoing, the facility information and inventory will likely be readily available, current, and require only minimal efforts to collect and supplement as necessary. In contrast, if the facility has been non-operational for some time, it can be expected that a significantly greater effort will be required to gather and validate the information necessary in this step. During this assessment, the following activities, among others, should be considered: Assess existing facility knowledge by collecting and reviewing available facility operating information (authorization basis documents, environmental documentation, documents containing operating history of the facility and those providing process knowledge of the facility), and existing hazard baseline documentation. Interview past and present employees as necessary to supplement knowledge of past facility operations, including mishaps and incidents. Identify and document the hazards (material, chemical, radioactive, and others). In particular, focus on hazards that can result from changes in facility operational status and resulting conditions (such as the effect of a chemical process system becoming static). The need for intrusive characterization activities (sampling and analysis) to adequately understand the hazards should be determined on the basis of these activities. The decision should be based on the level of uncertainty that remains regarding hazardous substances and the facility condition. Additional intrusive characterization should be considered if knowledge of hazards is insufficient to support an understanding of hazardous material types, quantities, forms, potential exposures, locations, and methods for hazard reduction or removal, as well as whether such information is needed to support activities for either transition or disposition. Additional information that addresses hazard identification and safety during the conduct of facility characterization can be found in DOE-STD-1120-98, Integration of Safety And Health into Facility Disposition Activities. In identifying the facility conditions, the following items should be addressed: Radiological inventory and associated uncertainties. This should include material form and distribution information. Hazardous material, hazardous waste, chemical inventories, and any associated uncertainty. This should include form and distribution information. Evaluation of current S&M activities, particularly with regard to the current hazards, authorization basis, and commitments. Radiological survey data used to identify the radiological working conditions associated with the facility. Occupational hazards associated with the facility. For this assessment, the occupational evaluation should focus on fixed hazards. Temporary occupational hazards created to support operations and maintenance should be removed by the operations organization. General facility conditions should be evaluated. This assessment should address structures, existing protective barriers, and systems installed to prevent migration of both hazardous and radioactive contamination to the environment and ensure the safety of workers, the public, and the environment. Applicable permits, licenses, and agreements associated with the facility. Commitments to regulatory authorities, stakeholders, and DOE that apply to transition and disposition. 4.5 STEPS 4 AND 5: IDENTIFY AND PERFORM EARLY ACTIONS Early actions can begin without waiting for the completion of the planning process that determines transition completion conditions (i.e., end-points). Early actions generally focus on eliminating or mitigating hazards and taking immediate actions to stabilize unsafe conditions (e.g., through the prevention of deterioration). Decisions as to what activities can begin before planning is complete are (1) those for which the end-point is apparent and work can continue to that point and (2) those that can begin with the anticipation that the end-points process will provide the completion specifications. Responsibility for management and implementation of these early actions is with the operating organization. The operating status of a facility, that is, its condition relative to the earlier Case 1/Case 2 descriptions, will be a factor in deciding the distribution of effort between initiating early actions and the end-point planning process. Case 1 operating facilities will generally be better positioned to use existing personnel and systems to conduct early actions that eliminate or mitigate hazards in a timely, cost-effective manner. Operations should be conducted to reduce hazards, such as by clean-out runs of process systems or ridding the facility of chemicals and explosive hazards that clearly must be eliminated. Examples of policy and operational issues that may affect the priority and need for early actions during transition include the following: Policy Issues disposition path for removing radiological and hazardous materials; material interim storage needs; stakeholder commitments, legal actions, and other requirements; and safeguards and security requirements. Operational Issues availability of personnel with operational expertise; nature, degree, and extent of hazards in the facility; S&M resource burdens if early actions are delayed; heating, ventilation, lighting, electricity, and water required for later work; requirements for fire control; and structural integrity of the facility. Early actions are identified, and work initiated, after the initial facility condition assessment (Step 3) to help ensure that benefits will result from the activities. This sequence of actions safeguards against doing work later found to be unnecessary, or even counterproductive, once the disposition path and end-points are identified. For example, there may be little value in early actions to decontaminate areas that are not expected to be accessed until a facility is dismantled. On the other hand, containing contamination to prevent uncontrolled spread may be of value to future work. In general, structures, equipment, and systems that will likely be required during subsequent transition, deactivation, or decommissioning activities for either safety or future work should not be permanently disabled or removed. Examples include lighting, lifting cranes, elevators, ventilation, and waste processing. 4.6 STEP 6: IDENTIFY DISPOSITION PATH The ability to most effectively specify many of the transition end-points is dependent on whether the facility disposition path is (1) direct to decommissioning type activities, primarily dismantling and demolition, or (2) to deactivation conditions for an extended duration of minimal activity and monitoring. Knowledge of the disposition path is key in the engineering planning process of end-point development and allocation leading to determination of the complete list of transition activities. Knowing the disposition path following transition is especially important to avoid activities that later prove to be unnecessary. Many factors must be considered when determining the disposition path. Foremost are conceptual life- cycle cost projections for deactivation versus decommissioning relative to budgets, the projected cost of ongoing S&M, and agreements among DOE, State regulators, and various other stakeholders. Factors such as facility hazards and physical condition can also be important. In some cases, part of a facility may remain operational for the foreseeable future; this, as well as the presence of other nearby facilities, complicates the decision concerning the disposition path. In identifying the probable disposition path (i.e., deactivation or decommissioning), activities and associated cost for both options should be evaluated as decisions factors, among others. Using hazard information, activities, cost, and other constraints, combined with national priorities and strategies, the probable facility disposition path that is the basis for transition project planning can be identified. 4.7 STEP 7: ASSESS AND ADJUST AUTHORIZATION BASIS The LCAM Order requires an assessment and adjustment (if necessary) of the facility authorization basis to ensure it continues to reflect conditions in the facility pending disposition, as part of transition activities. The guidance in this section provides an acceptable method for performing the authorization basis assessment and maintaining the authorization basis so that it is current with planned activities and facility conditions. The goal of this process is to ensure that facility transition activities are authorized by the authorization basis and that an appropriate authorization basis is provided at transfer to facilitate disposition activities. Assessment and adjustment of the authorization basis are generally performed by the operating organization. Many facilities are not radiologically contaminated, but are contaminated by other hazardous substances. As a result, these non-radiologically contaminated facilities usually do not have an authorization basis developed in accordance with the requirements of DOE 5480.23, NUCLEAR SAFETY ANALYSIS REPORTS. For non-radiologically contaminated facilities, a hazard assessment would be sufficient, but it should be evaluated to ensure that it is current with planned activities and facility conditions. There are two possible authorization basis scenarios regarding transition of radiologically contaminated facilities. In the first scenario, a current authorization basis does not exist. The need to develop authorization basis documentation will be clear and is required by DOE Orders. Detailed guidance on developing authorization basis documents is provided in DOE-STD-3011-94, Guidance for Preparation of DOE 5480.22 (TSR) and DOE 5480.23 (SAR) Implementation Plans; DOE-STD- 3009-94, Preparation Guide for U.S. Department of Energy Nonreactor Nuclear Facility Safety Analysis Reports; DOE-STD-EM-5502-94, Hazard Baseline Documentation; and other related Standards. In the second scenario, a current facility authorization basis document is in place and could be evaluated with regards to transition (and later disposition) activities. An acceptable method of evaluating the adequacy of the authorization basis for activities is through use of the Unreviewed Safety Question (USQ) process defined in DOE 5480.21, UNREVIEWED SAFETY QUESTIONS. If the facility is nonnuclear, a USQ-like process can be applied. Early in the transition, it is likely that all activities for both the transition and disposition will not be defined to the level of detail required for a thorough USQ determination. Based on the preferred or anticipated activity approach, a preliminary or "umbrella" USQ can be performed for major types of tasks (such as tank flushing throughout the facility rather than for a specific tank as will be formally evaluated later in keeping with the USQ Order). The objective here is to determine if, based on the current understanding of the activity/task type, the authorization basis will adequately address the activity. This approach may be used to determine that, for example, the authorization basis for 2 out of a planned 50 major types of activities would require modification and specific DOE approval prior to completion. As a result, a strategy to obtain the authorization for these specific tasks can be developed. In cases like the one in this example, authorization of these activities can likely be accomplished more cost-effectively without developing a completely revised authorization basis document. Specific resolution and authorization of activities should be performed based on DOE Orders (DOE 5480.21) and associated guidance. The focus for authorization basis assessment and adjustment (if necessary) is on the activities to be performed. 4.8 STEP 8: END-POINTS For transition, the LCAM Order requires that actions be implemented to place the facility, systems, and materials in stable and known conditions, to identify hazards, and to eliminate or mitigate hazards. The guidance in this section identifies acceptable methods to fulfill these requirements. Although a number of transition activities will have been identified and initiated as early actions (see section 4.5), additional transition activities requiring more detailed understanding and planning will often be necessary. Because LCAM requires an end-point process in facility deactivation and decommissioning planning, optional use of an end-point process for facility transition activities is suggested to provide a consistent and integrated approach for transition and disposition planning. The end-points methodology is a formal, project management approach that presents proven systems engineering concepts and tools that can be used to plan and implement transition activities. Specifying and meeting "transition end-points" is a systematic, engineering way of proceeding from the existing operational condition to a stated desired set of conditions in which risks have been reduced in the facility. In some cases, it may be advisable to identify a comprehensive set of end-points for both the transition and disposition phases (i.e., deactivation and decommissioning), and to allocate an appropriate subset to the transition phase. More often, only transition end-points and/or early actions need be identified during transition, based on an understanding of the expected disposition path for the facility. Additional guidance for understanding and implementing the end-points methodology is provided in DOE G 430.1-3, DEACTIVATION IMPLEMENTATION GUIDE, and DOE/EM-0318, Facility Deactivation Guide: Methods and Practices Handbook (available on the EM web site). 4.8.1 End-Point Development Operating and receiving program teams** should work together to develop transition end-points, considering the ultimate disposition path to deactivation and decommissioning where possible. For example, the excess facility may be transitioned to deactivation with an interim S&M period prior to decommissioning or may be transferred directly to decommissioning. When a decision is made to identify a combined set of detailed end-points for transition and disposition and to "allocate" an appropriate subset to the transition phase, two benefits are achieved: (1) seamless transition can more readily be achieved because disposition planning can begin based on identified disposition end-points (those not allocated to the transition phase), and (2) the cost associated with end-point development will be required only this one time, resulting in a cost savings to the DOE complex. The decision to identify transition end-points and detailed disposition end-points as a group will likely require a greater level of facility characterization during transition, as discussed in section 4.5. Just as the design specifications are essential to a construction project, specifying the transition end- points for a facility's spaces, systems, and major equipment identifies a facility that has completed transition activities. End-point specifications are also used as input for scheduling and cost estimating, to create detailed work plans for selected spaces and systems in the facility, to document bases for performance-based contracting or out-sourcing of work (where practical), to demonstrate conformance to agreements negotiated with third parties who have a legitimate stake in the condition of the facility after transfer, and to show compliance with Federal, state, and local laws and regulations and other negotiated agreements. Transition end-points planned and achieved vary from facility to facility across the DOE complex. Variations are expected because of the differences among facilities with respect to previous mission requirements, equipment and systems, containment, degree of contamination, ability to isolate the contamination, facility environs, expected disposition path, and a host of other factors. Facility end- points are derived for plant areas, structures, systems, and equipment. Facility end-point specifications must be quantitative, where possible, and in all instances must be explicit. Several guiding principles form the foundation of the end-point process: The decision to specify an end-point should be driven by, and clearly linked to, top-tier program objectives. End-point decisions are integrally linked to decisions (and constraints) on resources and methods. If a proposed end-point is not economically feasible, it should only be specified if mandated by law, applicable regulation, or formal agreement. End-point decisions may consider, but should not be driven by, decommissioning presumptions. The end-point conditions of the facility should use defense-in-depth as a fundamental safety approach. As applied here, defense-in-depth involves three layers of protection: elimination or stabilization of hazards, effective facility containment, and facility monitoring and control. Successful end-point development requires involvement by all affected organizations, including the planners, the work force, and the receiving organization. Work teams in the field need clear, quantitative completion criteria. End-points must be clear, quantitative (when possible), practical, and achievable. Most end-point decisions can be made during the early planning stages; however, some end- points will have to be revised as work proceeds. The transition objective is intended to be achieved within a relatively short time frame using current technology and personnel familiar with the facility's operational processes. Application of the graded approach in the development of end-points is appropriate in order to differentiate between complex facilities with process systems and/or significant hazards and those with relatively simple buildings that are not substantially contaminated and do not have complex equipment or systems. 4.8.2 End-Point Allocation When an end-point study considers combined, detailed end-points for the transition and disposition phases, as discussed in section 4.8.1, it is necessary to allocate an appropriate subset of transition end- points to the transition phase. Completion and formal closure of the transition end-points demonstrates the readiness to transfer the facility from the operating program to the disposition program. In identifying the transition end-points, it is important to take advantage of the capabilities of existing operational systems and personnel where possible. For example, by performing a final process run and flushing and sampling as part of the last operational activities, the operating program can significantly mitigate hazards, prevent detrimental chemical reactions and systems deterioration due to material holdup, and reduce the total costs of transition and disposition activities. The following guidelines will assist in determining which end-points should be allocated to the transition phase: Activities to complete end-points requiring training and skills that may be lost following cessation of operations. Example: Product/SNM removal and stabilization End-point activities that are natural extensions of operations, such as bulk product removal, flushing, etc. Example: Documented piping and tank flushing after final process runs Removal of radioactive, nuclear, and/or chemically hazardous substances and wastes for which disposition paths are readily available. Example: Disposal of stored hazardous substances and other bulk containerized materials Deferral of the activities necessary to close the end-point, which significantly increases the risk or cost associated with the activities. Example: Organic solvent solution decontamination Completion of the end-point, which is necessary to ensure protection of workers, the public, and the environment at the time of transfer (operating program to disposition program). Example: Stabilization and/or fixation of readily dispersible radioactive or chemically hazardous substances 4.9 STEP 9: PROJECT PLANNING AND EXECUTION FOR END-POINT ACTIVITIES As the end-points are identified, project planning and execution activities are initiated to ensure that they are achieved. To the extent possible, existing management systems should be used to perform and control the work activities safely. Planning should focus on application of the graded approach. The LCAM Good Practice Guides, found on the Office of Field Management web site, provide detailed guidance on project planning and execution. Also, DOE G 430.1-3, DEACTIVATION IMPLEMENTATION GUIDE, provides additional guidance for project planning and execution with specific application to end-point activities. 4.10 STEP 10: PRE-TRANSFER REVIEW For transition, the LCAM Order requires that the management team achieve stable and known conditions; identify hazards; stabilize, store, and remove materials and wastes; assess the authorization basis; establish S&M activities pending disposition; identify needed resources; conduct a Pre-Transfer Review; and sign an agreement for facilities transfer that identifies conditions and funding. The operating organization should conduct an appropriately graded Pre-Transfer Review to ensure that the facility condition, contents, regulatory status, and hazards have been identified and documented. The Pre-Transfer Review also identifies the status of early actions and transition end-points agreed to be completed prior to transfer to the disposition organization. It is expected that the safety and health requirements have been determined and evaluated for appropriateness, that the required safety systems and controls have been identified, and that a determination has been made as to whether they are in place and performing as intended. This documented review establishes a baseline at the time of transfer to provide the disposition program with an adequate understanding of the facility and includes an assessment and graded characterization of the facility, as discussed in section 4.4. The purposes of the review are to (1) ensure that sufficient information has been collected, assembled, and analyzed to provide an understanding of existing conditions and hazards, and especially to document the remaining hazards based on completion of early actions and transition end-points; (2) permit efficient deactivation (or decommissioning) planning; and (3) minimize the possibility of halting the progress of deactivation (or decommissioning) tasks because of significant unforseen circumstances. A Pre-Transfer Review report should be prepared to document the results of the review and should reflect the up-to-date condition of the facility and its contents. To ensure that the scope of the Pre- Transfer Review is commensurate with the existing hazards, each of the following review subjects should be included in the report, as appropriate to the complexity of the facility: An explicit delineation of the physical boundaries of the facility being transferred including a list of physical structures. Drawings, photographs, and other records reflecting the as-built and as- modified condition of the facility and its surrounding grounds should be a part of this element. An operating history (including previous operational records) of the facility giving the process knowledge of the nuclear and chemical materials that were handled and major spills or leaks that occurred. A facility condition assessment of all structures, existing engineered protective barriers, and systems installed to prevent migration of both hazardous and radioactive contamination to the environment and that ensure the safety of workers, the public, and the environment. Data collection and reporting systems such as FIMS and the Condition Assessment Survey can be used for this purpose. A characterization report that describes the nature, levels, and probable extent of the existing hazardous chemical and radiological contamination within and around the facility. This characterization should be based, and its scope developed, on the level of process knowledge available, the risk of incomplete or outdated process knowledge, and the hazards posed by specific chemical and radiological contamination to workers, the public, and the environment. An accurate and complete list of types, forms, quantities, and locations of all remaining special nuclear and fissionable materials. An inventory or estimate and the locations of the existing toxic substances and/or wastes. A list of documents that define the authorization basis and the S&M requirements necessary to maintain the current safety envelope of the facility. The current status of implementation of the facility's safe shutdown plan. The plan, as a minimum, should have addressed the facility safety envelope, S&M requirements, safeguards and security, and the preservation of facility structures, systems, and components. Baseline information on energy utilities systems and services should also be included. A plan to remove personal property and excess equipment and material not required to operate and maintain the facility. List of permits, licenses, and agreements that remain imposed on the facility. List of outstanding commitments to regulatory authorities, stakeholders, and DOE organizations that require action. Budget resources to be provided. Human resources commitments identifying the DOE and contractor personnel to be transferred in order to maintain the safety envelope pending disposition. Information on any other factors such as potential future use, long-range site plans, facility condition, and potential health, safety, and environmental hazards that could influence the selection of decommissioning alternatives (safe storage, entombment, dismantlement, etc.) or deactivation alternatives (thermal stabilization, residue elimination, separation of utilities, etc.). 4.11 STEP 11: FACILITY TRANSFER The LCAM Order requires development of a signed agreement to document scope, conditions, state of readiness, and associated funding. The agreement is to include a budget resources plan to manage the facility until funding is provided to the receiving program through the normal budgeting process. A Memorandum of Agreement (MOA), signed by both the operating program and the receiving program (generally EM for contaminated facilities) is an acceptable method to document the reassignment of management responsibilities for an excess facility. The MOA provides documentation that transition actions have been completed and addresses associated funding for out-year targets. It also documents the condition of the facility, as determined through the completion of the Pre-Transfer Review, and the state of readiness for transfer. If the facility transfer involves changing responsible contractors, a separate MOA can be used to document this transfer as well. 4.12 TRANSITION PLANNING TOOLS This Guide includes three attachments as aids to implementing this guidance. Attachment 1 is a Checklist of Transfer Activities; Attachment 2 is a Pre-Walkdown Survey; and Attachment 3 is a set of Facility Condition Walkdown Checklists. These tools were developed through the lessons learned during a pilot at Oak Ridge, Tennessee, which assessed implementation of the LCAM requirements and guidance for transferring contaminated, excess facilities owned by Defense Programs and the Office of Science to EM. These tools may be used or adapted to the local needs and characteristics of specific facilities, using a graded approach. ATTACHMENT 1 CHECKLIST OF TRANSFER ACTIVITIES # Subject Details 1. Decision to Proceed Excess determination. Identify contacts for interface between operations and disposition organizations. 2. Conduct a Facility Survey Determine status of structures and systems. 3. Cost Evaluation Breakdown the current S&M budget into task listing. Evaluate for sufficiency for moving into deactivation phase. 4. Budget Identify budget and target for S&M to be transferred. 5. Staffing Identify staff who know the plant and would be important to continuity. Where possible, arrange for re-assignment or availability. 6. Physical Boundaries/ Transfer Scope Identify all structures, outbuildings, tanks, etc. that should be in the scope of transfer. Identify any systems that serve other facilities that are not to transferred. 7. Actions to be Tracked: State Regulatory Commitments DNFSB Commitments Others Generate a list. Coordinate with Permits, etc. 8. Permits, Licenses, Agreements, Safety Analysis, Stakeholder Commitments, etc. Coordinate with commitments above. 9. Nuclear & Fissionable Materials Inventory Obtain a listing; remove consistent with LCAM; document removal. 10. Toxic, Hazardous, Radioactive Materials Obtain a listing; remove consistent with LCAM; document removal. 11. Characterization Summarize the radiological conditions that exist. Propose a level of cleanup. CHECKLIST OF TRANSFER ACTIVITIES (continued) 12. Authorization Basis Status, list of defining documents, S&M requirements to maintain the safety envelope. Update as required. 13. Safe Shutdown Implementation Plan (if applicable) Verify safe shutdown needs. Address the configuration and contamination conditions that should be achieved upon transfer. 14. Property Assets Construct a list of excess property assets limited to those of significant value. Identify which should transfer, which should stay. 15. Schedule Integration Develop a conceptual level schedule that integrates initiation of stabilization with completion of operations. 16. Pre-Transfer Operations For stabilization and hazard elimination. Agree and conduct as a condition of transfer. 17. Formal Transfer Documents Transfer Memorandum of Understanding, Transfer Agreement, Facility Use Agreement (for post transfer). Draft, negotiate, revise, finalize. ATTACHMENT 2 PRE-WALKDOWN SURVEY This attachment is a survey that augments the Facility Conditions Walk-Down Checklists (Attachment 3). Questions and related documents represent focus areas to be addressed by the transition planning team, generally prior to the on-site walkdown inspection. GENERAL FACILITY INFORMATION Facility name/number: Site location: Area name/number: Attach information regarding 1. general description of the facility, including a general arrangements drawing; 2. current operational status; 3. current occupancy; 4. description of prior facility missions and any documents that describe the overall history of the facility; 5. current surveillance and maintenance activities and expenditures; 6. to the extent they exist, any planning information/reports or evaluations regarding future use or disposition of the facility; 7. physical boundaries that define the transfer scope (structures, outbuildings, tanks, etc.). Identify integrated systems or components that will not transfer (e.g., integrated utilities). SPECIFIC FOCUS AREAS 1. Facility Structure Purpose: To determine if investment needed to mitigate hazardous conditions or leakage potential. Questions Structural integrity (walls, foundation, roof) Structural tightness for leakage (walls, foundation, roof, doors, windows) Condition of hot cells Condition of pools and sumps Types of Documents Seismic evaluation Inspection reports 2. Process Systems Purpose: To determine if investment needed to use systems for clean out runs, to stabilize them for residual contained material, or to isolate and abandon. Questions Reactor Reactor systems Dissolution and chemical process systems Gloveboxes Process machinery Cleanup and purification Cooling water Process compressed air Process steam Tanks and large equipment Types of Documents Description of overall operation of process systems Condition or status reports, especially as-left conditions 3. Infrastructure and Support Systems Purpose: To determine if investment needed to upgrade systems to maintain a min-safe facility condition, or to retire systems to reduce hazards. Questions Electrical, natural gas, HVAC, water, sewer, steam, service air, communications, fire protection, etc. Cranes and hoists Elevators Types of Documents Condition assessment surveys Maintenance needs studies 4. Nuclear Materials Purpose: To determine the need for material stabilization or transfer prior to deactivation or decommissioning, and associated costs. Questions What kind of materials might have to be dealt with and what is their status? Examples: nuclear materials (thorium, uranium, plutonium) nuclear fuel (new fuel, spent fuel, etc.) deuterium and tritium sealed sources Are there plans or actions to remove any of the material? Types of Documents DNFSB 94-1 reports and status Inventory reports or data sheets Accountability status Studies for disposition, either by processing within the facility, disposal, or transfer for processing or storage Disposition plans 5. Hazardous Material Purpose: To determine the need for removal of hazardous material. Questions What kind of materials might have to be dealt? Examples: process chemicals (solvents, acids, caustics, etc.) worker hazards (asbestos, beryllium, magnesium, chlorine, etc.) environmentally hazardous (lead, PCBs, freon, paints, cleaning chemicals, etc.) fuels or explosive, incendiaries (diesel oil, gasoline, etc.) other (pesticides, herbicides) Are there plans or actions to remove any of the material? Types of Documents Survey reports or other characterization summaries Lists of materials Results of any stabilization efforts Major reportable incidents, such as those reported in ORPS, in the facility's life cycle (radiological, chemical, industrial, etc.) Related plans or project descriptions 6. Radioactive Contamination and Waste Purpose: To determine the need for fixing contamination, or decontamination, and waste removal. Questions Where is the radioactive contamination, what type is it, what is the amount? Has radioactive contamination been covered with a fixative in the past to prevent it from spreading? If so, where? If so, where are the records? Does radioactive contamination extend to the exterior of buildings? If so, what is it and where are the records? How much and what kind of radioactive waste is currently in the facility? Are there plans or actions to decontaminate? Are there plans or actions to remove waste? Types of Documents Contamination survey reports or other characterization summaries Inventory of loose and packaged waste within the facility Historical reports of contamination while the facility was in use Major reportable incidents, such as those reported in ORPS or in the facility's life cycle (radiological, chemical, industrial. etc.) Related plans or project descriptions 7. Characterization Information Questions Have any quantitative characterizations of the facility and its contents been conducted? Where is data archived for radiological and material information? Types of Documents Characterization reports or plans Inspection reports Value assessment surveys 8. Surveillance and Maintenance Purpose: To understand current inspection and maintenance routine and possible need to increase, or potential to decrease In the following, "surveillance" refers to inspections and monitoring activities. Questions What surveillances are conducted? How frequently? What maintenance procedures are conducted? How frequently? What are the direct costs or level of effort (equivalent FTEs) for surveillance and maintenance, including health physics surveys? What is the administrative burden (overhead) on these direct costs? What S&M procedures are not being conducted that should be? What S&M procedures have been recommended, but not implemented? What S&M procedures are being conducted that should not be (waste of time), but are anyway because of a requirement? What monitoring systems are in operation? Where are the closed spaces in the facility? What are their conditions? What is the status of procedures for entry? Types of Documents List of surveillances and maintenance activities Evaluations conducted on this subject List of repair or maintenance order backlogs Lists of equipment and materials to be removed ATTACHMENT 3 FACILITY CONDITION WALK-DOWN CHECKLISTS 1. FACILITY STRUCTURE Facility Identification: Subject Comment Status Exterior Roof integrity Roof leakage (minimum to profuse) Foundation (cracks, crumbling, etc.) Walls structurally sound weather tight air leaks water tight Doors Windows Dock areas Exhaust stack Ladders and stairs Interior Ceilings Floors Mezzanines Load bearing walls Fire doors Air lock doors Sump pits pumps transfer lines Ladders and stairs Elevators and lifts Connecting passage ways Vaults Canyons Remote handling cells 1. FACILITY STRUCTURE (continued) Support Areas Ceilings Floors Walls Direct Support Buildings Water treatment Roof Floors Walls Foundation Transfer piping Cooling towers Coils Transfer piping Overall facility Electric sub-station Functional General condition Transmission lines2. FACILITY SUPPORT SYSTEMS Facility Identification: Subject Comment Status Electrical Normal power Uninterruptible power source Emergency generator High voltage Equipment rooms (e.g., switch gear) Main breaker panels General wiring Emergency lighting - exterior Emergency lighting - interior Normal lighting Service outlets Fire systems Fire suppression (type) Fire detection Life Safety Disaster Warning Fire annunciation Criticality alarms Continuous air monitors Public address Water systems Potable Supply Sanitary drains Septic system Process Supply Process drains De-ionize Mechanical systems Cranes and hoists Moving platforms2. FACILITY SUPPORT SYSTEMS (continued) HVAC Control room Motor control centers Air supply fans motors ductwork Plenums, air supply air wash system roughing filters HEPA filters Air exhaust fans motors ductwork Plenums, exhaust air HEPA filters Exhaust stack monitors Building chillers coils Building heat natural gas supply electric steam supply steam distribution Heat exchanger Communication systems (telephone, etc.) Inert gas supply for welding etc.3. PROCESS SYSTEMS Facility Identification: Subject Comment Status Process control rooms Process exhaust Fans Motors Ductwork Plenums HEPA filters Off-gas scrubber Process vacuum system Pumps Motors Piping Inert gas, (glove boxes, etc,) Supply Distribution Exhaust Laboratory or fume hoods Process containment (glove boxes, cells) Status (shut down, sealed, isolated) Heat detection system Internal lifts within containment Connected piping Windows Glove ports Other openings Criticality system HEPA filters Pumps Conveyor systems/transfer lines Remote handling units Containment vessels 3. PROCESS SYSTEMS (continued) Reactor tank Tank/vessel systems Status (operable, shutdown, blanked) Level indicators in place Ancillary piping Specialized equipment Chemical transfer systems Pumps Piping Storage tanks Status (operable, shutdown, blanked) Level indicators in place Ancillary piping Storage pools Hot lab manipulators Waste handling Evaporators Filter housings Pumps4. NUCLEAR MATERIALS Facility Identification: Subject Comment Status Plutonium Material in storage In solution In equipment In glove boxes In hot cells Uranium or thorium Material in storage In solution In equipment In glove boxes In hot cells Nuclear fuel New in storage In reactor In wet storage TRU (am, cu, bk, cf) In storage Systems with Pu, U, or TRU holdup Fluid system filters Fluid system particulate Ventilation system filters Ductwork plate out Pool sludge Wall or floor contamination Deuterium, tritium, lithium 6 In storage Sealed Sources In labs or storage5. HAZARDOUS MATERIALS Facility Identification: Subject Comment Status Process Chemicals (if present, form, quantity, location) Acids Caustics Sodium Hydrazide Lab reagents Environmental Hazards Lead, heavy metals Potassium Chromate PCBs Solvents, paint thinners Freon, CFCs Paint, sealants, adhesives Cleaning chemicals Industrial Safety Asbestos Beryllium Magnesium Chlorine Other Fuel oil, gasoline, gas, lube oil Explosives, oxidizers Pesticides, herbicides Biological Hazards Toxic6. RADIOACTIVE CONTAMINATION AND WASTE (if present, form, quantity, location) Facility Identification: Subject Comment Status Radioactive Contamination Open Contamination (address currently controlled open areas) Surface Alpha Surface Beta-gamma Airborne Any "infinity rooms" Covered Contamination (describe what has been encased) Surface coatings and/or More substantial covering Outside (describe conditions) Soil Water Past leakage pathways Radioactive Waste Dry active waste (DAW) Class A Packaged Not packaged Dry active waste (DAW) Class B or C Packaged Not packaged TRU waste (WIPP disposal) Packaged Not packaged Sludges, resins, filters Packaged Not packaged Mixed waste Packaged Not packaged

DOE G 430.1-5 Draft 430.1-5 Transition Implementation Guide <ORG> EM <SUMMARY> This draft Transition Implementation Guide was prepared to aid in the planning, decision making and early implementation of facility transition at Department of Energy facilities that have been declared excess to any future mission requirements. This draft guide also defines activities or actions that provide a sequenced risk reduction and seamless transition from operations to the selected disposition path. <DATE_ISSUE> 11/19/1999 <DATE_CLOSE> <TEXT> NOT MEASUREMENT SENSITIVE DOE G 430.1-5 XX-XX-99 DRAFT TRANSITION IMPLEMENTATION GUIDE U.S. Department of Energy Washington, D.C. 20585 DISTRIBUTION: INITIATED BY: All Departmental Elements Office of Field Integration FOREWORD The Department of Energy (DOE) faces an enormous task in the disposition of the nation's excess facilities. Many of these facilities are large and complex and contain potentially hazardous substances. As DOE facilities complete mission operations and are declared excess, they pass into a transition phase that ultimately prepares them for disposition. The disposition phase of a facility's life-cycle usually includes deactivation, decommissioning, and surveillance and maintenance (S&M) activities. DOE has developed four Guides to provide implementation guidance for requirements found in DOE O 430.1A, LIFE CYCLE ASSET MANAGEMENT, specific to the transition and disposition of contaminated, excess facilities. The Guides are DOE G 430.1-2, SURVEILLANCE AND MAINTENANCE DURING FACILITY DISPOSITION; DOE G 430.1-3, DEACTIVATION IMPLEMENTATION GUIDE; DOE G 430.1-4, DECOMMISSIONING IMPLEMENTATION GUIDE; and DOE G 430.1-5, TRANSITION IMPLEMENTATION GUIDE. The goal of the processes described in the Guides is a continuum of hazard mitigation and risk reduction throughout the transition and disposition phases, leading to timely, cost-effective disposition of the facility. Transition activities occur between operations and disposition in a facility's life cycle. Transition begins once a facility has been declared or forecast to be excess to current and future DOE needs. It includes placing the facility in stable and known conditions, identifying hazards, eliminating or mitigating hazards, and transferring programmatic and financial responsibilities from the operating program to the disposition program. Timely completion of transition activities can take advantage of facility operational capabilities before they are lost, eliminating or mitigating hazards in a more efficient, cost-effective manner. In preparation for the disposition phase, it is important that material, systems, and infrastructure stabilization activities be initiated prior to the end of facility operations. Following operational shutdown and transition, the first disposition activity is, usually, to deactivate the facility. The purpose of the deactivation mission is to place a facility in a safe shutdown condition that is economical to monitor and maintain for an extended period, until the eventual decommissioning of the facility. Deactivation of contaminated, excess facilities should occur as soon as reasonable and for as many facilities as possible. In this way, DOE can apply its resources in a manner that will accomplish the greatest net gains to safety and stability in the shortest time. Deactivation places the facility in a low- risk state with minimum S&M requirements. The final facility disposition activity is typically decommissioning, during which the facility is taken to its ultimate end state through decontamination and/or dismantlement to demolition or entombment. After decommissioning is complete, the facility or surrounding area may require DOE control for protection of the public and the environment or for environmental remediation. S&M activities are performed throughout the facility transition and disposition phase, to monitor and document the presence, status, and condition of structures, systems, components, and hazards associated with the facility. S&M is adjusted as transition, deactivation, or decommissioning activities are completed. Continuing S&M ensures, at a minimum, that any contamination is adequately contained and that potential hazards to workers, the public, and the environment are minimized and controlled. S&M is conducted during transition, deactivation, and decommissioning but can also occur during an extended period between deactivation and decommissioning. The technical, managerial, and planning perspectives offered in these Guides can be equally effective in conducting activities other than transition and disposition, such as refurbishment and "clean-up" for reuse. As such, this guidance can be adapted for use at facilities that are not being declared excess. An important objective throughout transition and disposition is to maintain an integrated and seamless process linking deactivation, decommissioning, and S&M with the previous life-cycle phases. Activities of facility transition and disposition should incorporate integrated safety management at all levels to provide cost-effective protection of workers, the public, and the environment. CONTENTS 1. Introduction. . . . . . . . . . . . . . . . . . . . . . . . .1 1.1 Purpose . . . . . . . . . . . . . . . . . . . . . . . . .1 1.2 Alternative Methods . . . . . . . . . . . . . . . . . . .1 1.3 Applicability . . . . . . . . . . . . . . . . . . . . . .2 1.4 Crosswalk, DOE O 430.1A Requirements to DOE G 430.1-5 . .2 2. Transition Activities General Guidance. . . . . . . . . . . .5 2.1 Project Management Principles . . . . . . . . . . . . . .6 2.1.1 Use of Project Management System. . . . . . . . .6 2.1.2 Detailed Engineering Planning . . . . . . . . . .6 2.2 Integrated Safety Management. . . . . . . . . . . . . . .7 2.3 Graded Approach . . . . . . . . . . . . . . . . . . . . .7 3. Transition Program. . . . . . . . . . . . . . . . . . . . . .9 3.1 Transition Objectives and Goals . . . . . . . . . . . . .9 3.2 Transition Cases. . . . . . . . . . . . . . . . . . . . 10 3.2.1 Case 1: Facilities Currently Operating . . . . 11 3.2.2 Case 2: Facilities Not Currently Operating . . 11 3.3 Major Transition Steps. . . . . . . . . . . . . . . . . 12 4. Transition Activities and Processes . . . . . . . . . . . . 15 4.1 Task Focus for Transition Work. . . . . . . . . . . . . 15 4.2 Step 1: Excess Declaration and Transfer Initiation . . 19 4.3 Step 2: Establish Management and Planning Teams. . . . 20 4.4 Step 3: Identify Facility Conditions . . . . . . . . . 22 4.5 Steps 4 and 5: Identify and Perform Early Actions. . . 25 4.6 Step 6: Identify Disposition Path. . . . . . . . . . . 26 4.7 Step 7: Assess and Adjust Authorization Basis. . . . . 26 4.8 Step 8: End-Points . . . . . . . . . . . . . . . . . . 27 4.8.1 End-Point Development . . . . . . . . . . . . . 28 4.8.2 End-Point Allocation. . . . . . . . . . . . . . 30 4.9 Step 9: Project Planning and Execution for End-Point Activities31 4.10 Step 10: Pre-Transfer Review . . . . . . . . . . . 31 4.11 Step 11: Facility Transfer . . . . . . . . . . . . 33 4.12 Transition Planning Tools . . . . . . . . . . . . . 33 Figure 1, Facility Transition. . . . . . . . . . . . . . . . . 13 Table 1, Mapping of Requirements Transition. . . . . . . . . . .2 Table 2, Task Types, Criteria, and End Points. . . . . . . . . 16 Attachment 1: Checklist of Transfer Activities Attachment 2: Pre-Walkdown Survey Attachment 3: Facility Condition Walkdown Checklists 1. INTRODUCTION 1.1 PURPOSE This Guide was prepared to aid in the planning, decision making, and early implementation of facility transition at Department of Energy (DOE) facilities that have been declared excess to any future mission requirements. It is one of four that have been developed to provide guidance for facility transition and disposition activities. The other three Guides are DOE G 430.1-2, SURVEILLANCE AND MAINTENANCE DURING FACILITY DISPOSITION; DOE G 430.1-3, DEACTIVATION IMPLEMENTATION GUIDE; and DOE G 430.1-4, DECOMMISSIONING IMPLEMENTATION GUIDE. Requirements for transition are stated in DOE O 430.1A, LIFE CYCLE ASSET MANAGEMENT (LCAM), which identifies the minimum requirements for disposition of an excess DOE facility. This Guide defines activities or actions that provide a sequenced risk reduction and seamless transition from operations to the selected disposition path. It is part of the DOE Directives System and is consistent with the principles and core functions of DOE P 450.4, SAFETY MANAGEMENT SYSTEM POLICY. Other documents that should be consulted to support the planning and conduct of transition and disposition activities include DOE-STD-1120-98, Integration of Environment, Safety and Health into Facility Disposition Activities, and the Good Practice Guides associated with LCAM, which can be found on the Office of Field Management web site (http://www.fm.doe.gov). 1.2 ALTERNATIVE METHODS This Guide presents acceptable methods for implementing the transition requirements specified in LCAM to ensure effective and efficient management of DOE excess facilities. It does not impose additional requirements. The Department has invested substantial time and effort in developing a transition framework that (1) meets DOE's requirements and expectations, (2) draws on DOE's previous experience, and (3) satisfies the requirements of oversight entities such as the Defense Nuclear Facilities Safety Board (DNFSB). Although alternative methods and approaches to the ones discussed in this Guide may be used, a comparable amount of time and effort may be needed to evaluate the acceptability of those alternatives.1.3 APPLICABILITY This Guide may be applied to transition activities and processes at contaminated DOE facilities. "Contaminated" refers to both radioactive contamination and to hazardous-substance contamination. Nuclear facilities and non-nuclear-contaminated facilities are included in the scope of this Guide. Project personnel are expected to apply a graded approach in planning and conducting transition activities at different types of facilities and with different hazard conditions. 1.4 CROSSWALK, DOE O 430.1A REQUIREMENTS TO DOE G 430.1-5 LCAM requirements that apply to the transition of a contaminated, excess facility are included in Table 1, cross-referenced to the section of this Guide where they are addressed. Although the table quotes the requirements as they appear in LCAM, this Guide addresses only those requirements that apply to the transition process. Parallel tables in the other three LCAM Guides provide crosswalks between requirements and guidance for surveillance and maintenance (S&M), deactivation, and decommissioning, respectively. Table 1. Mapping of Requirements Transition Requirement Where Addressed in Guide DOE O 430.1A, paragraph 6a: DOE elements shall use a value-added, quality driven, graded approach to life cycle asset management. Section 2.3, Graded Approach DOE O 430.1A, paragraph 6f(1): The identification, inventory, and periodic assessment of the condition of physical assets in the maintenance program. Section 4.4, Identify Facility Conditions DOE O 430.1A, paragraph 6f(8): A method to ensure that prior to the completion of mission activities (e.g., production, research, etc.) actions are implemented to place the facility, systems, and materials in stable and known conditions, and to ensure hazards are identified and known, pending transfer or disposition. For facilities that have already completed mission activities and are awaiting transfer or disposition, ensure that actions are taken to eliminate or mitigate hazards and provide adequate protection to workers, the public, and the environment. In both cases, actions shall be based on an assessment of the remaining hazards at the time when mission activities are completed, or prior to transfer or disposition for facilities that have already completed mission activities. Sections 4.5, Identify and Perform Early Actions; and 4.8, End-Points DOE O 430.1A, paragraph 6f(8)(a): Identifying and characterizing hazardous and radioactive materials and wastes remaining in systems/facilities and providing for their stabilization (if necessary), adequate storage until they are removed from the facility, and (unless agreed to prior to facility transfer) removal. Section 4.4, Identify Facility Conditions DOE O 430.1A, paragraph 6f(8)(b): Assessment and adjustment (if necessary) of the facility authorization basis to ensure it continues to reflect conditions in the facility pending disposition. Section 4.7, Assess and Adjust Authorization Basis DOE O 430.1A, paragraph 6f(8)(c): Identifying S&M activities required to maintain the facility and remaining hazardous and radioactive materials, wastes, and contamination in a stable and known condition pending facility disposition. Sections 4.2, Excess Declaration and Transfer Initiation; 4.4, Identify Facility Conditions; and 4.10, Pre-Transfer Review DOE O 430.1A, paragraph 6f(8)(d): Identifying and allocating resources needed to maintain stable and known conditions pending facility disposition. Sections 4.3, Establish Management and Planning Teams; and 4.10, Pre-Transfer Review DOE O 430.1A, paragraph 6g(1): Application, as appropriate, of guidelines contained or referenced in DOE- STD-1120-98, Integration of Environment, Safety and Health into Facility Disposition Activities. Sections 1.1 Purpose; and 2.2, Integrated Safety Management DOE O 430.1A, paragraph 6g(3): A method whereby land and facilities (candidates for transfer) are either transferred to other Program Offices, or are determined excess, available for disposal, and disposal procedures are initiated. Section 4.2, Excess Declaration and Transfer Initiation DOE O 430.1A, paragraph 6g(4): To match the Departmental budget cycle, the normal date of transfer for a facility shall be the first October 1 after the two year anniversary of the date the receiving organization is notified, unless the parties reach another agreement. As land and facilities are transferred from one Program Office to another, the appropriate funding and budget target are transferred with it. Section 4.2, Excess Declaration and Transfer Initiation DOE O 430.1A, paragraph 6g(5)(a): Completion of a Pre- Transfer Review, with participation by the Office of Environment, Safety and Health when requested or directed, for transfer of facilities for disposition whose scope shall be commensurate with the existing hazards. Sections 4.10, Pre-Transfer Review; and 4.11, Facility Transfer DOE O 430.1A, paragraph 6g(5)(b): Development of a signed agreement by relevant Secretarial Officers to document scope, conditions, state of readiness, and associated funding, when transferring facilities between Program Offices. This includes a budget resources plan to manage the facility until funding is provided to the receiving program through the normal budgeting process. Section 4.11, Facility Transfer DOE O 430.1A, paragraph 6i: DOE corporate physical assets databases shall be maintained as complete, current inventories of the DOE physical assets. For real property, the corporate database is Facilities Information Management System. Sections 4.2, Excess Declaration and Transfer Initiation; 4.10, Pre-Transfer Review; and 3.1, Transition Objectives and Goals DOE O 430.1A, paragraph 6j: In the acquisition, operation, maintenance, leasing and disposition of physical assets, DOE elements shall ensure that all applicable Federal, state, and local laws, regulations, and negotiated agreements are followed, and that safeguards and security as well as integrated safety management requirements and policies are followed. Sections 2, Transition Activities General Guidance; and 4.8.1, End-Point Development 2. TRANSITION ACTIVITIES GENERAL GUIDANCE Preparation for the successful disposition (either deactivation or decommissioning) of a contaminated, excess facility can be enhanced greatly by completing certain activities during the transition period. Paragraph 6f(8) of LCAM requires that stabilization activities for facilities, systems, and materials be initiated prior to the end of facility operations, pending transfer or disposition. Activities during this transition period could include, for example draining nonessential systems; removing any remaining hazardous chemicals, spent fuel, and other radioactive materials and wastes; Resource Conservation and Recovery Act (RCRA) closures; and related actions. A commitment to complete these activities during the transition of a facility to the disposition phase of its life-cycle supports the protection of workers, the public, and the environment. To establish safer conditions before proceeding to disposition, it may be prudent to conduct a stabilization campaign at the end of operations for facilities that contain materials, either in inventory or as holdup in areas such as equipment, pipelines, and filters. For example, it may be appropriate to conduct a process/equipment clean-out run to either process quantities of radioactive or chemically reactive liquids, clear process systems, or remove nuclear fuel for the purpose of clearing a storage area. A systems engineering approach should be used throughout transition and disposition activities to ensure that essential elements and activities are integrated at appropriate levels. These elements include safety management as defined in DOE P 450.4, SAFETY MANAGEMENT SYSTEM POLICY, and the application of a graded approach. DOE is committed to conducting all work efficiently, protecting workers, the public, and the environment, and maintaining a safe shutdown configuration. Additional requirements for planning and conducting transition activities may be contained in other documents. It is not the intent of this document to offer guidance for these requirements. In the transfer and disposition of DOE physical assets, the project manager and others involved with the development and/or execution of the disposition project should, in accordance with LCAM, be well versed with other Federal, state, and local laws and regulations as well as those requirements that address integrated safety management, conduct of operations, conduct of maintenance, radiological protection, and other requirements integral to planning, developing, and conducting the work. Throughout the transition period, the facility characterization should be updated for the Pre-Transfer Review, which documents and verifies the completion of transition activities and establishes the new baseline, including a revised authorization basis. S&M activities are adjusted and performed to monitor and document the presence, status, or condition of structures, systems, components, and hazards associated with the facility as transition activities are completed. Continuing S&M ensures, at a minimum, that any contamination is adequately contained and that potential hazards to workers, the public, and the environment are minimized. Further guidance on S&M activities is found in DOE G 430.1-2, SURVEILLANCE AND MAINTENANCE DURING FACILITY DISPOSITION. 2.1 PROJECT MANAGEMENT PRINCIPLES Project management envelopes the entire transition and disposition process including planning, design, execution, and closure. A clear understanding of these phases enables greater control of DOE resources in achieving the transition and disposition goals. Two principles are key to achieving this understanding: (1) use of a project management system and (2) detailed engineering planning. 2.1.1 Use of Project Management System Using a project management system assists in the successful completion of each phase of a transition project, from facility assessment, through technical engineering, to project execution. Project planning establishes the project's requirements and describes how the project will be accomplished. The top- level objectives for project planning of transition activities include the following: protect workers, the public, and the environment; eliminate or mitigate hazards within the facility; facilitate S&M during transition and into disposition; facilitate deactivation and/or ultimate decommissioning work; comply with regulations and requirements, including administrative requirements; and follow through on commitments to stakeholders. 2.1.2 Detailed Engineering Planning The LCAM Order requires that an "end-point" process for detailed engineering planning and plan documentation be used to identify and execute the preferred deactivation and/or decommissioning alternative. During transition, an end-point process is also important for planning and executing stabilization activities. Just as design specifications and drawings are essential to systematically detail a construction project, specifying "transition end-points" is the comparable discipline to planning, implementing, measuring, and knowing when transition activities are complete. The process for identifying transition end-points is discussed in more detail in section 4.8. 2.2 INTEGRATED SAFETY MANAGEMENT Sufficient planning should be done to systematically integrate a safety management system into management and work practices at all levels. DOE's safety management system policy and guidance are identified in DOE P 450.4, SAFETY MANAGEMENT SYSTEM POLICY, and DOE G 450.4- 1, INTEGRATED SAFETY MANAGEMENT SYSTEM GUIDE. The major mechanism for integrating safety and health into transition efforts is the work planning process, during which safety documentation from the facility's operational phase is reviewed and evaluated. Because many early hazard elimination and mitigation actions are operations or "operations like" activities, they are most likely already covered in existing operations safety documentation. Transition activities are identified and evaluated against existing controls, and modification to controls are identified as required by the new activities that were not previously performed during operations. Often, the safety documentation of an older facility, including worker safety and health aspects, fall short of today's standards and requirements. Revisions, comparisons, crosswalks, and other evaluation techniques can be used to determine which transition actions may be covered in existing documentation and which actions require supplemental coverage. Such evaluation efforts, especially if performed by those who know the facility well, are more cost effective and time efficient than the preparation of new safety documentation. Worker involvement in all levels of safety/hazards analysis in the planning of transition activities is key to implementing all elements of transition. DOE-STD-1120-98, Integration of Environment, Safety, and Health into Facility Disposition Activities, provides guidance on integrating health and safety into facility disposition activities and can be useful for conducting transition activities. 2.3 Graded Approach The "graded approach" or the tailored application of requirements to a particular project, activity, or facility is required by LCAM, and by 10 CFR 830, Nuclear Safety Management. Application of the graded approach is appropriate for all steps in facility transition. The preamble of the Nuclear Safety Management rule, published in the Federal Register on April 5, 1994, describes the intent of DOE with respect to the graded approach: "graded approach" was developed to describe the process used to determine which actions would be appropriate for a particular facility. DOE believes that this process should be sufficiently broad and flexible to take into account differences among various facilities. The intent of the graded approach is to permit DOE contractors the flexibility to implement activities and processes, as appropriate, to comply with the nuclear safety requirements for the individual facilities. The graded approach does not exempt a facility from a nuclear safety requirement. In applying a graded approach, however, a determination may be made that certain actions may not be appropriate for a particular facility. (59 FR 15844; April 5, 1994.) Application of the graded approach during transition allows for consideration of differences among facilities and provides a means to determine the extent to which actions are appropriate for transition. The depth of detail required and the magnitude of resources expended for a particular transition element are tailored to be commensurate with that element's relative importance to safety, environmental compliance, safeguards and security, current operational capability, programmatic importance, magnitude of the hazard, financial impact, and/or other facility-specific requirements. Tailoring the integrated safety management system offers another means to grade activities and processes to different hazards associated with individual facilities. Tailoring is used to scale expectations and acceptable performance to the needs of the site, activity, facility, or work to be performed. When applied to the core functions of safety management, tailoring promotes a work management system that is safe, efficient, and cost-effective. 3. TRANSITION PROGRAM 3.1 TRANSITION OBJECTIVES AND GOALS Transition activities occur between operations and disposition in a facility's life cycle. Transition begins once a facility has been declared or forecast to be excess to current and future DOE needs. It includes placing the facility in stable and known conditions, identifying hazards, eliminating or mitigating hazards, and transferring programmatic and financial responsibilities from the operating program to the disposition program. Timely completion of transition activities can take advantage of facility operational capabilities before they are lost, eliminating or mitigating hazards in a more efficient, cost-effective manner. The transfer process from the operating program to the disposition program can take a considerable time, generally, more than 2 years. Therefore, it is important that progress is made during this interval toward supporting the future disposition path. Key objectives and goals during facility transition include the following: an expeditious start of activities to eliminate or mitigate hazards, beginning with those that clearly should be done regardless of the subsequent mode of disposition; completion of activities as defined in the "transition end-points" (described in section 4.8), with priority given to the specified end-points for mitigation and removal of hazards and materials; maximum use and effectiveness of current operations knowledge, personnel, and operating systems/programs to reduce the facility hazards, with emphasis placed on processes and systems for which the skills and knowledge required are unique; effective partnering among all involved parties (in particular, among the operating and disposition program, field elements, and/or contractors); the seamless and integrated transfer of the facility from the operations phase to the disposition phase. The degree to which these goals can be achieved at a facility will vary greatly based on the facility's current conditions, configuration, and status. Early actions to eliminate or mitigate hazards (e.g., to clean out runs of process systems) should receive the highest priority. Early actions are discussed in more detail in section 4.5. For other activities, the transition end-point development process identified in section 4.8 will ensure that the appropriate activities are identified for completion. Typical examples of early actions and transition end-point criteria include the following: As soon as acid in storage is no longer needed, it is either sold or neutralized and disposed of as waste. New nuclear fuel is sold or shipped to a DOE facility for recycling or dismantling. Unstable materials and/or wastes are stabilized, treated, and/or removed. The potential for fire/explosion from violent chemical reactions or nuclear criticality is reduced or eliminated. Tanks are emptied. A final process run is completed for all systems, lines, and other equipment that has potential for significant material holdup. Changes in configuration and status of systems and structures as a result of transition activities are reviewed against the safety basis. Revised controls are provided as appropriate to changed conditions. Barriers are installed and/or verified sufficient to prevent the spread of contamination. Appropriate safeguards and security are provided. 3.2 Transition Cases DOE facilities can broadly be grouped into three general categories (or cases): Case 1 facilities are currently operating in fulfillment of mission objectives (research, weapons production, etc.). Case 2 facilities have ceased mission-related operations. The status of Case 2 facilities can range from facilities with some operational systems (e.g., ventilation) to those that are essentially locked up and/or abandoned with no operational activities. Case 3 facilities have already been accepted into the Office of Environmental Management cleanup program and are outside the bounds of further discussion in this Guide. A thorough understanding of Case 1 and 2 facilities is important due to the difference in facility condition, configuration, and other variables. Implementation of transition activities is bound by different constraints and will require different allocation of approaches to ensure success. 3.2.1 Case 1: Facilities Currently Operating For Case 1 facilities (i.e., those that are still operational), the goals identified in section 3.1 can be accomplished straightforwardly during transition. Through coordination with the affected programs and field elements, the facility is projected to become excess and begin transition while a final operating campaign is still underway. The probable disposition path towards deactivation or decommissioning is identified, and the transition activities are completed. Transition activities can take full advantage of the final operating campaign and the fact that facility resources (i.e., personnel, procedures, systems, etc.) are still available. For example, clean-out runs of process systems and equipment may be appropriate to process quantities of radioactive and/or chemically reactive liquids, clear process systems, remove nuclear fuel, etc. This leveraging of final operations to accomplish transition is advantageous and cost-effective. Once operational capability no longer exists without substantial requalification and/or refurbishment (i.e., Case 2 below), it can be difficult and expensive to perform the necessary transition and subsequent disposition activities. With early planning, the goal of a seamless, integrated transition from the operations to disposition can more readily be accomplished. Depending on the projected time for completion of operations and transition end-point activities, transfer can be timed to meet the 2-year budget planning cycle. Transfer to the receiving Program Office should be planned for the beginning of the fiscal year, 2 years after notification. 3.2.2 Case 2: Facilities Not Currently Operating A non-operational or Case 2 facility is one that is in (1) any condition of standby, (2) shutdown, and/or (3) abandonment (i.e., it is considered "legacy"). A Case 2 facility ceases operation before there is an opportunity to take full advantage of operational capability and resources. As a result, transition activities to meet the above-stated objectives have generally not been accomplished during the final operating campaign. Two undesirable results follow. First, the transition/disposition activities, at substantial cost, may have to rebuild some or all of the operational capabilities required to implement early actions and other transition activities to reduce hazards. Second, the lack of early actions for transition may result in a period of unnecessarily high S&M costs because of the remaining facility hazards. The earlier the transition can occur, the more S&M costs can be reduced. An abandoned or "legacy" facility is one that ceased operation long ago and for which there is little current operating knowledge base. Transition may require a significant effort to identify and evaluate existing conditions before determining appropriate transition activities and taking the requisite actions. 3.3 Major Transition Steps Figure 1 identifies the major transition steps presented in this Guide. These steps are designed to meet the goal of hazard elimination or mitigation and to advance disposition in a cost-effective manner that is seamless and integrated with disposition planning. As Figure 1 shows, transition activities and disposition planning activities begin with the declaration or forecast of the facility as excess. S&M will continue during transition, with modification appropriate to changing hazards and risk. The steps are discussed in detail in Chapter 4. Variation in facility situations leads to numerous possibilities among the characteristics described for Cases 1 and 2. For example, early actions (Step 5) are more likely to occur for Case 1 facilities than they are for Case 2 facilities, which will undoubtedly require a heavier initial emphasis on identification of facility conditions (Step 3). Early planning as part of transition is necessary to sort out these possibilities and define early actions for each facility. Figure 1 - Facility Transition 4. TRANSITION ACTIVITIES AND PROCESSES This section focuses on the interactive and iterative sequence of specific "steps" aimed at supporting and providing a framework for facility transition. As previously noted, the degree of effort for each step depends on the characteristics of each facility (i.e., Case 1, Case 2 variations). A primary goal for transition is to focus on "early actions" that (1) cost-effectively reduce hazards and risk and (2) support a seamless process from the end of facility operations through disposition. 4.1 TASK FOCUS FOR TRANSITION WORK Experience has shown eight general types of deactivation tasks. These tasks are also appropriate for activities within the transition phase, prior to facility transfer to the disposition organization. The task types address the following issues: hazards, radiation fields, contamination, waste, isolation and containment, monitoring and control, refurbishing and installing, and documenting and labeling. DOE has established specific criteria for determining the associated actions to be performed at the facility for each task type. The task types are presented in Table 2 along with example criteria and end-points. These task types, and the examples, can help in determining what early actions focus on hazard elimination or mitigation and end-point specifications that are cost-effective in the ultimate disposition of the facility. The examples in Table 2 are facility-specific and will not apply to all facilities. The challenge is to identify the transition actions appropriate for a particular excess facility prior to transfer and disposition. Table 2. Task Types, Criteria, and End Points. Task Type Example Criteria Example End Points 1. Hazards The elimination or reduction of hazards, nuclear and nonnuclear, is a fundamental action to achieve defense-in-depth protection for the facility. Elimination and/or reduction activities include removing, isolating, draining, and minimizing activities. Administrative reviews of unknown hazardous conditions (e.g., confined spaces) are also included in this task type. Sufficiently remove or disperse held-up material to eliminate the potential for a credible criticality accident and the need for a criticality alarm system. Empty process equipment and piping of process chemicals. Remove lab chemicals and reagents after they are no longer needed. Ensure structural stability. Determine fire protection/ detection in the Fire Hazard Analysis. Ensure no unattached combustible materials remain. Electrically de-energize equipment. Isolate equipment no longer required. Dissolver vessel A has been emptied to less than 25 gm Pu and neutralized. Fuel has been removed from the reactor and placed in the storage pool. Tank X has been emptied of nitric acid and flushed to allowable residual concentration per technical specifications. A limited structural analysis has been conducted to verify structural integrity for a minimum of 5 years. All loose material has been removed from feed pump cubicle. Sprinkler system has been isolated in feed pump cubicle. Existing electrical service to the facility has been disconnected leaving power for surveillance lighting. Leads to abandoned feed pump have been lifted. Lubricants have been drained from abandoned feed pump. 2. Radiation Fields The reduction, shielding, or isolation of radiation fields supports ALARA practices and protects workers while performing activities throughout the facility. Activities associated with this task type include removal, shielding, documenting, and ensuring proper radiological posting of remaining radiation fields. Establish maximum general area dose rates for surveillance corridors using ALARA, cost benefit, and reasonable best efforts. Remove or shield source material to mitigate radiation exposure using reasonable best efforts and in accordance with 10 CFR 835 for fixed surface contamination. Eliminate temporary radiological areas outside process system rooms. Hot spots in ventilation control panel/MCC room 434A have been decontaminated for unrestricted access. Demineralizer A cubicle has been locked and posted as a high- radiation area. Table 2. Task Types, Criteria, and End Points (continued). Task Type Example Criteria Example End Points 3. Contamination The removal, reduction, or isolation/containment of radioactive contamination to mitigate and prevent spreading supports ALARA practices and protects workers while performing activities throughout the facility. Activities associated with this task type include decontaminating, isolating, fixing, documenting, and ensuring proper radiological posting of contaminated areas. Establish maximum non-fixed contamination levels for surveillance corridors using ALARA, cost benefit, and reasonable best efforts, and in accordance with 10 CFR 835. Record remaining contamination levels for future information. Remove/fix/contain source material to mitigate contamination migration using reasonable best efforts. Contaminated ventilation duct 17X in main corridor has been removed. Open ends have been sealed to prevent flow in or out. Survey requirements have been included as part of the turnover package to verify containment of radioactive contamination. Hood face has been isolated/sealed to inhibit contamination migration. Sample box access points have been isolated/sealed. 4. Waste Compliance with regulations and requirements drive the removal and disposal of radioactive, dangerous, and mixed waste items from the plant. Task type activities generated by these regulations and waste minimization practices include removal, tank flushing, excessing, RCRA permitting, and waste disposal. Remove/dispose of radioactive, dangerous, and mixed wastes. Housekeep and remove unattached material/equipment using reasonable best efforts. Contents of out-of-service ethylene glycol closed-loop heat recovery system have been drained. Piping has been cleaned to comply with regulatory commitments for chemical residuals. Cleanup demineralizer media have been removed and disposed of. Mercury switches that no longer serve a function have been removed. 5. Isolate and Contain Effective containment of the facility's remaining hazards and protection from the environment is another fundamental action of the defense-in-depth approach. Task type activities include blanking, plugging, covering, removal, screening, and sealing of doors, windows, pipe penetrations, holes, drains, etc. Prevent the uncontrolled migration of both hazardous substances and radioactive contamination to the surrounding space. Minimize in-leakage of snow and rain water. Roof integrity has been checked to ensure the prevention of in- leakage for a minimum of 5 years. Engineered barriers/seals have been checked to ensure they are in place to inhibit migration of hazardous substance contamination to the environment. Exterior door seals have been checked to ensure they are in proper working order. Floor drains have been isolated/plugged to localize water intrusion. Table 2. Task Types, Criteria, and End Points (continued). Task Type Example Criteria Example End Points 6. Monitor and Control Monitoring and control are the final fundamental actions of the defense- in-depth approach to achieve a safe, stable facility condition. This task type provides the activities required to support and minimize the cost, risk, and hazards involved with the future S&M of the facility. Provide utilities needed for visual and instrumentation surveillance, using existing, new, or portable equipment. Provide ability to monitor all effluents with sufficient lead time to terminate flow and remain within technical specification limits in the event of an upset. Define system discharge monitoring and instrumentation requirements. Capability to energize Corridor X lights from circuit breaker panel has been provided. Drains from auxiliary building to radwaste building have been isolated/sealed. Interim ventilation ducting from Room C exhaust plenum to Ventilation System A has been installed and fixed in place. Ventilation System B and its monitors have been shut down. Passive-level sensor has been provided in drain collection tank Z. 7. Refurbish or Install Issues identified during the stabilization that should be completed to ensure a safe, sound, stable facility are included in this task type. Activities include structural repairs and roof sealing and modification to the facility ventilation system. A simple cost benefit analysis should be performed prior to including an activity under this task type. For example, the cost to repair a small ancillary building's leaking roof may warrant demolition rather than repair. Refurbish industrial safety deficiencies as needed for human surveillance activities. Refurbish facility as required by the structural and roof integrity studies. Reconfigure waste liquid system B for processing rinse water from water abrasive blast decontamination unit. Install access barrier at Elevator B Doors. Repair building A roof to a 10- year standard. 8. Document and Label This task type covers the documentation and labeling required for the specific space or system. Additional supporting documentation not included in the other task types but specific to the space or system is also included here. Provide transfer information package (see section 4.9). Label systems and equipment that are abandoned in place. Ensure that equipment isolation tags for permanently shutdown systems will last 10 years in the local environment without temperature or humidity controls. Amounts and locations of remaining hazardous substances/dangerous wastes have been documented. Identified area industrial hazards have been documented for inclusion in the transfer information package. Amounts and locations of remaining hazardous substances/dangerous wastes have been documented. Table 2. Task Types, Criteria, and End Points (continued). Task Type Example Criteria Example End Points 8. Document and Label (continued) Ventilation system restart and preventive maintenance procedures have been included as part of the turnover package. Space and associated system(s) dose rates and contamination levels have been documented in the final radiological survey report and map per the Site Radiological Control Manual for inclusion in the turnover package. Feedwater systems have been labeled as abandoned in place. 4.2 STEP 1: EXCESS DECLARATION AND TRANSFER INITIATION Paragraph 6g(3) of the LCAM Order drives the need for a method to declare assets excess. DOE Program Secretarial Officers (DP-1, SC-1, NE-1) have programmatic and fiscal accountability for facilities under their "ownership" and, as such, have authority to define and approve the excess status of their facilities. Although the process for identifying a facility as excess can be initiated at any point in the Program Office/Field Office/Contractor organizational structure, the ultimate decision for communicating facility status as excess to program needs rests with the Program Secretarial Officer (PSO), in coordination with the Office of Field Integration (FI). The excess status of a facility should be identified in DOE's Facility Information Management System (FIMS). Decisions to designate facilities as excess are driven primarily by programmatic mission need and budget considerations and secondarily by the advanced age and deteriorating condition of many DOE facilities. Although excess facilities may be reused by other DOE Program Offices, other Federal and state government agencies, and to a lesser extent private concerns, the predominant direction for DOE excess facilities is stabilization, deactivation, and decommissioning. DOE/EM-0285, RESOURCEFUL REUSE, provides guidance for determining facility status for programmatic needs and for coordinating with FI to determine the status of facilities with respect to broader DOE needs (i.e., whether it is needed by other PSOs) and/or if it is subject to transfer via established General Services Administration (GSA) processes identified in 41 CFR 101, FEDERAL PROPERTY MANAGEMENT REGULATIONS. Guidance focuses on acceptable methods to declare facilities as excess to DOE; that is, establishing candidacy for transfer to the DOE receiving program and communicating requests for initiating transition. As discussed in DOE/EM-0285, the primary factor in establishing candidacy for transfer to the DOE Office of Environmental Management (EM) is the presence of contamination and the need to perform deactivation and decommissioning. A secondary consideration involves establishing the facility as a "whole" unit (i.e., not part of a larger facility that is not excess), which is structurally independent with separate utilities and support systems. Additional guidance on excess determination is provided in DOE/EH-413/9712, Cross-Cut Guidance on Environmental Requirements for DOE Real Property Transfers. Once a contaminated facility is determined to be excess to DOE mission needs and a candidate for transfer to EM, PSOs, in coordination with FI, provide transfer notification to EM. Consistent with LCAM requirements, notification should be provided at least 2 years prior to October 1 of the year of desired transfer. To provide adequate financial and resource support for early stabilization and characterization actions, and to evaluate and identify budget and target elements prior to October 1, it will generally be necessary to begin planning and gathering information 6 months or more in advance. It is advisable to establish a Memorandum of Understanding (MOU) between the operating program and EM about 6 months before the 2-year notification date. The MOU should identify roles and responsibilities during transition and empower a Transition Planning Team (see section 4.3). This team can establish specific information objectives that address (1) the physical condition/contamination status of facilities (discussed in section 4.4), (2) early actions needed (discussed in section 4.4), and (3) the administrative/budgeting status of facilities. 4.3 STEP 2: ESTABLISH MANAGEMENT AND PLANNING TEAMS Establishing management and planning teams is a means of setting up communications and cooperative action between the facility's operational or custodial organization and the organization that will be responsible for its disposition, which will generally be EM for contaminated, excess facilities. Regardless of whether this interface is accomplished with teaming, the downstream owner should participate in setting the transition goals that will support disposition. From lessons learned throughout the DOE complex, a major factor for successfully completing projects is early involvement of affected organizations. Establishing teams during the transition process is one way to ensure that the affected programs and organizations form working partnerships, participate in development, and concur with the facility transition and disposition path. The intent is not to develop an additional layer between the facility and the DOE Program Offices. The goal is to provide effective access to resources necessary to assist the facility in developing and executing the transition and disposition activities through partnering efforts. The approach discussed here uses two distinct teams: (1) a transition management team to oversee the transition and (2) a transition planning team to plan and direct the conduct of work associated with facility transition and the process identified in this Guide. Typically, the transition management team consists of affected senior level managers from Headquarters programs, the DOE Field or Operations Office, and the contractor representing both the operating and the receiving organizations (if different). The composition, size, and leadership of this team should be determined using the graded approach based on facility complexity, hazards, risks, and programmatic impacts. The purpose of the transition management team is to advise, monitor, and approve plans for the facility transition and disposition activities. Roles and responsibilities of the team may include the following, as appropriate: providing access to the full range of skills within respective organization structures; approving strategies and plans; mediating institutional and financial issues; promptly resolving conflicts that might impede expected results; ensuring schedule and budget for the facility are mutually consistent with overall priorities and allocations; and directing formation of the transition planning team. The transition planning team includes facility and program representatives from the DOE Field Office, as well as operating program and receiving program contractor representatives (if different). Formation of this team should again be based on the use of the graded approach considering hazards, risks, and complexity of the facility and project. The transition planning team is to assist in identifying and implementing early actions and subsequent end-points driven activities for facility transition. 4.4 STEP 3: IDENTIFY FACILITY CONDITIONS The LCAM Order requires that facility maintenance conditions be identified and that hazardous materials and wastes be identified and stabilized (if necessary), stored, and removed. This identification process, which is the responsibility of the operating organization, entails a graded characterization of the facility to establish existing conditions and facility contents. The intent of the identification process is to clearly identify and record what is known and what is not known about facility conditions. Case 1 facilities may not need much effort for this process because up-to-date information probably exists. On the other hand, Case 2 facilities may require more identification activities, especially if the facilities are perceived or are known to contain hazards for which the characterization is not available. Guidance provided in this section focuses on the identification and characterization aspects of the LCAM requirements. The information obtained supports the initiation of early actions and transition end-point activities. In addition, the information obtained will be included as part of the Pre-Transfer Review, as discussed in section 4.10. The primary drivers for the identification and characterization of the facility are (a) deciding and specifying early actions and facility transition end-points, and (b) developing information documenting the revised authorization basis and facility conditions prior to transfer. The LCAM Order requires that chemical and radiological hazards to workers, the public, and the environment be identified and known during transition to the disposition phase; however, facility characterization during transition is generally not intended to achieve the level of information needed for full deactivation or decommissioning. Depending on complexity and level of existing characterization information available, the cost and resources to characterize and prepare facilities for transfer may be substantial and may not be accounted for in program office budgets. As such, issues may arise between the owning program and EM on the level of information needed for unknown contamination conditions. Criteria to use in resolving these cost and resource issues may include, for example: identification of a characterization level that is sufficient to support an S&M program that is consistent with DOE G 430.1-2, pending disposition; least-cost options; and the use of non-invasive/non- destructive analytical procedures where possible. On the other hand, the operating program and EM may agree to work together on a greater level of detailed characterization when near-term deactivation/decommissioning is expected upon receipt by EM and it makes scheduling and economic sense to fully identify facility contamination conditions at an early stage to facilitate planning. The transition planning team, which generally comprises a multi-discipline group of site managers, engineers, safety and health personnel, and workers, can use facility "walkdowns" to satisfy information objectives for planning, characterization, and early actions. Attachment 1, Checklist of Transfer Activities; Attachment 2, Pre-Walkdown Survey; and Attachment 3: Facility Condition Walkdown Checklists, provide tools that may be used by the Planning Team to focus on these information needs. Facility condition identification begins with defining the facility's boundaries for disposition. This should include a list of physical structures and waste sites associated with the facility. Documents essential to the process success include authorization basis documents, environmental documentation, documents containing operating history, and documents detailing process knowledge. The process of characterization should begin with the use of existing knowledge of the facility and its material inventory, including facility condition assessments from the operations phase. Existing information should be relied on with caution, especially for Case 2 facilities. Additional characterization by walkdowns of the facility and hands-on system reviews may be needed to provide a more detailed understanding and also to provide information on changes in hazardous conditions that have resulted from cessation of facility operations. It is equally important in such cases to limit the information sought to that needed for safety and transition activity planning. Identifying facility conditions is one key area where facility status (Case 1 or 2 from section 3.2) will have a significant impact. In application of the graded approach, if facility operations are ongoing, the facility information and inventory will likely be readily available, current, and require only minimal efforts to collect and supplement as necessary. In contrast, if the facility has been non-operational for some time, it can be expected that a significantly greater effort will be required to gather and validate the information necessary in this step. During this assessment, the following activities, among others, should be considered: Assess existing facility knowledge by collecting and reviewing available facility operating information (authorization basis documents, environmental documentation, documents containing operating history of the facility and those providing process knowledge of the facility), and existing hazard baseline documentation. Interview past and present employees as necessary to supplement knowledge of past facility operations, including mishaps and incidents. Identify and document the hazards (material, chemical, radioactive, and others). In particular, focus on hazards that can result from changes in facility operational status and resulting conditions (such as the effect of a chemical process system becoming static). The need for intrusive characterization activities (sampling and analysis) to adequately understand the hazards should be determined on the basis of these activities. The decision should be based on the level of uncertainty that remains regarding hazardous substances and the facility condition. Additional intrusive characterization should be considered if knowledge of hazards is insufficient to support an understanding of hazardous material types, quantities, forms, potential exposures, locations, and methods for hazard reduction or removal, as well as whether such information is needed to support activities for either transition or disposition. Additional information that addresses hazard identification and safety during the conduct of facility characterization can be found in DOE-STD-1120-98, Integration of Safety And Health into Facility Disposition Activities. In identifying the facility conditions, the following items should be addressed: Radiological inventory and associated uncertainties. This should include material form and distribution information. Hazardous material, hazardous waste, chemical inventories, and any associated uncertainty. This should include form and distribution information. Evaluation of current S&M activities, particularly with regard to the current hazards, authorization basis, and commitments. Radiological survey data used to identify the radiological working conditions associated with the facility. Occupational hazards associated with the facility. For this assessment, the occupational evaluation should focus on fixed hazards. Temporary occupational hazards created to support operations and maintenance should be removed by the operations organization. General facility conditions should be evaluated. This assessment should address structures, existing protective barriers, and systems installed to prevent migration of both hazardous and radioactive contamination to the environment and ensure the safety of workers, the public, and the environment. Applicable permits, licenses, and agreements associated with the facility. Commitments to regulatory authorities, stakeholders, and DOE that apply to transition and disposition. 4.5 STEPS 4 AND 5: IDENTIFY AND PERFORM EARLY ACTIONS Early actions can begin without waiting for the completion of the planning process that determines transition completion conditions (i.e., end-points). Early actions generally focus on eliminating or mitigating hazards and taking immediate actions to stabilize unsafe conditions (e.g., through the prevention of deterioration). Decisions as to what activities can begin before planning is complete are (1) those for which the end-point is apparent and work can continue to that point and (2) those that can begin with the anticipation that the end-points process will provide the completion specifications. Responsibility for management and implementation of these early actions is with the operating organization. The operating status of a facility, that is, its condition relative to the earlier Case 1/Case 2 descriptions, will be a factor in deciding the distribution of effort between initiating early actions and the end-point planning process. Case 1 operating facilities will generally be better positioned to use existing personnel and systems to conduct early actions that eliminate or mitigate hazards in a timely, cost-effective manner. Operations should be conducted to reduce hazards, such as by clean-out runs of process systems or ridding the facility of chemicals and explosive hazards that clearly must be eliminated. Examples of policy and operational issues that may affect the priority and need for early actions during transition include the following: Policy Issues disposition path for removing radiological and hazardous materials; material interim storage needs; stakeholder commitments, legal actions, and other requirements; and safeguards and security requirements. Operational Issues availability of personnel with operational expertise; nature, degree, and extent of hazards in the facility; S&M resource burdens if early actions are delayed; heating, ventilation, lighting, electricity, and water required for later work; requirements for fire control; and structural integrity of the facility. Early actions are identified, and work initiated, after the initial facility condition assessment (Step 3) to help ensure that benefits will result from the activities. This sequence of actions safeguards against doing work later found to be unnecessary, or even counterproductive, once the disposition path and end-points are identified. For example, there may be little value in early actions to decontaminate areas that are not expected to be accessed until a facility is dismantled. On the other hand, containing contamination to prevent uncontrolled spread may be of value to future work. In general, structures, equipment, and systems that will likely be required during subsequent transition, deactivation, or decommissioning activities for either safety or future work should not be permanently disabled or removed. Examples include lighting, lifting cranes, elevators, ventilation, and waste processing. 4.6 STEP 6: IDENTIFY DISPOSITION PATH The ability to most effectively specify many of the transition end-points is dependent on whether the facility disposition path is (1) direct to decommissioning type activities, primarily dismantling and demolition, or (2) to deactivation conditions for an extended duration of minimal activity and monitoring. Knowledge of the disposition path is key in the engineering planning process of end-point development and allocation leading to determination of the complete list of transition activities. Knowing the disposition path following transition is especially important to avoid activities that later prove to be unnecessary. Many factors must be considered when determining the disposition path. Foremost are conceptual life- cycle cost projections for deactivation versus decommissioning relative to budgets, the projected cost of ongoing S&M, and agreements among DOE, State regulators, and various other stakeholders. Factors such as facility hazards and physical condition can also be important. In some cases, part of a facility may remain operational for the foreseeable future; this, as well as the presence of other nearby facilities, complicates the decision concerning the disposition path. In identifying the probable disposition path (i.e., deactivation or decommissioning), activities and associated cost for both options should be evaluated as decisions factors, among others. Using hazard information, activities, cost, and other constraints, combined with national priorities and strategies, the probable facility disposition path that is the basis for transition project planning can be identified. 4.7 STEP 7: ASSESS AND ADJUST AUTHORIZATION BASIS The LCAM Order requires an assessment and adjustment (if necessary) of the facility authorization basis to ensure it continues to reflect conditions in the facility pending disposition, as part of transition activities. The guidance in this section provides an acceptable method for performing the authorization basis assessment and maintaining the authorization basis so that it is current with planned activities and facility conditions. The goal of this process is to ensure that facility transition activities are authorized by the authorization basis and that an appropriate authorization basis is provided at transfer to facilitate disposition activities. Assessment and adjustment of the authorization basis are generally performed by the operating organization. Many facilities are not radiologically contaminated, but are contaminated by other hazardous substances. As a result, these non-radiologically contaminated facilities usually do not have an authorization basis developed in accordance with the requirements of DOE 5480.23, NUCLEAR SAFETY ANALYSIS REPORTS. For non-radiologically contaminated facilities, a hazard assessment would be sufficient, but it should be evaluated to ensure that it is current with planned activities and facility conditions. There are two possible authorization basis scenarios regarding transition of radiologically contaminated facilities. In the first scenario, a current authorization basis does not exist. The need to develop authorization basis documentation will be clear and is required by DOE Orders. Detailed guidance on developing authorization basis documents is provided in DOE-STD-3011-94, Guidance for Preparation of DOE 5480.22 (TSR) and DOE 5480.23 (SAR) Implementation Plans; DOE-STD- 3009-94, Preparation Guide for U.S. Department of Energy Nonreactor Nuclear Facility Safety Analysis Reports; DOE-STD-EM-5502-94, Hazard Baseline Documentation; and other related Standards. In the second scenario, a current facility authorization basis document is in place and could be evaluated with regards to transition (and later disposition) activities. An acceptable method of evaluating the adequacy of the authorization basis for activities is through use of the Unreviewed Safety Question (USQ) process defined in DOE 5480.21, UNREVIEWED SAFETY QUESTIONS. If the facility is nonnuclear, a USQ-like process can be applied. Early in the transition, it is likely that all activities for both the transition and disposition will not be defined to the level of detail required for a thorough USQ determination. Based on the preferred or anticipated activity approach, a preliminary or "umbrella" USQ can be performed for major types of tasks (such as tank flushing throughout the facility rather than for a specific tank as will be formally evaluated later in keeping with the USQ Order). The objective here is to determine if, based on the current understanding of the activity/task type, the authorization basis will adequately address the activity. This approach may be used to determine that, for example, the authorization basis for 2 out of a planned 50 major types of activities would require modification and specific DOE approval prior to completion. As a result, a strategy to obtain the authorization for these specific tasks can be developed. In cases like the one in this example, authorization of these activities can likely be accomplished more cost-effectively without developing a completely revised authorization basis document. Specific resolution and authorization of activities should be performed based on DOE Orders (DOE 5480.21) and associated guidance. The focus for authorization basis assessment and adjustment (if necessary) is on the activities to be performed. 4.8 STEP 8: END-POINTS For transition, the LCAM Order requires that actions be implemented to place the facility, systems, and materials in stable and known conditions, to identify hazards, and to eliminate or mitigate hazards. The guidance in this section identifies acceptable methods to fulfill these requirements. Although a number of transition activities will have been identified and initiated as early actions (see section 4.5), additional transition activities requiring more detailed understanding and planning will often be necessary. Because LCAM requires an end-point process in facility deactivation and decommissioning planning, optional use of an end-point process for facility transition activities is suggested to provide a consistent and integrated approach for transition and disposition planning. The end-points methodology is a formal, project management approach that presents proven systems engineering concepts and tools that can be used to plan and implement transition activities. Specifying and meeting "transition end-points" is a systematic, engineering way of proceeding from the existing operational condition to a stated desired set of conditions in which risks have been reduced in the facility. In some cases, it may be advisable to identify a comprehensive set of end-points for both the transition and disposition phases (i.e., deactivation and decommissioning), and to allocate an appropriate subset to the transition phase. More often, only transition end-points and/or early actions need be identified during transition, based on an understanding of the expected disposition path for the facility. Additional guidance for understanding and implementing the end-points methodology is provided in DOE G 430.1-3, DEACTIVATION IMPLEMENTATION GUIDE, and DOE/EM-0318, Facility Deactivation Guide: Methods and Practices Handbook (available on the EM web site). 4.8.1 End-Point Development Operating and receiving program teams** should work together to develop transition end-points, considering the ultimate disposition path to deactivation and decommissioning where possible. For example, the excess facility may be transitioned to deactivation with an interim S&M period prior to decommissioning or may be transferred directly to decommissioning. When a decision is made to identify a combined set of detailed end-points for transition and disposition and to "allocate" an appropriate subset to the transition phase, two benefits are achieved: (1) seamless transition can more readily be achieved because disposition planning can begin based on identified disposition end-points (those not allocated to the transition phase), and (2) the cost associated with end-point development will be required only this one time, resulting in a cost savings to the DOE complex. The decision to identify transition end-points and detailed disposition end-points as a group will likely require a greater level of facility characterization during transition, as discussed in section 4.5. Just as the design specifications are essential to a construction project, specifying the transition end- points for a facility's spaces, systems, and major equipment identifies a facility that has completed transition activities. End-point specifications are also used as input for scheduling and cost estimating, to create detailed work plans for selected spaces and systems in the facility, to document bases for performance-based contracting or out-sourcing of work (where practical), to demonstrate conformance to agreements negotiated with third parties who have a legitimate stake in the condition of the facility after transfer, and to show compliance with Federal, state, and local laws and regulations and other negotiated agreements. Transition end-points planned and achieved vary from facility to facility across the DOE complex. Variations are expected because of the differences among facilities with respect to previous mission requirements, equipment and systems, containment, degree of contamination, ability to isolate the contamination, facility environs, expected disposition path, and a host of other factors. Facility end- points are derived for plant areas, structures, systems, and equipment. Facility end-point specifications must be quantitative, where possible, and in all instances must be explicit. Several guiding principles form the foundation of the end-point process: The decision to specify an end-point should be driven by, and clearly linked to, top-tier program objectives. End-point decisions are integrally linked to decisions (and constraints) on resources and methods. If a proposed end-point is not economically feasible, it should only be specified if mandated by law, applicable regulation, or formal agreement. End-point decisions may consider, but should not be driven by, decommissioning presumptions. The end-point conditions of the facility should use defense-in-depth as a fundamental safety approach. As applied here, defense-in-depth involves three layers of protection: elimination or stabilization of hazards, effective facility containment, and facility monitoring and control. Successful end-point development requires involvement by all affected organizations, including the planners, the work force, and the receiving organization. Work teams in the field need clear, quantitative completion criteria. End-points must be clear, quantitative (when possible), practical, and achievable. Most end-point decisions can be made during the early planning stages; however, some end- points will have to be revised as work proceeds. The transition objective is intended to be achieved within a relatively short time frame using current technology and personnel familiar with the facility's operational processes. Application of the graded approach in the development of end-points is appropriate in order to differentiate between complex facilities with process systems and/or significant hazards and those with relatively simple buildings that are not substantially contaminated and do not have complex equipment or systems. 4.8.2 End-Point Allocation When an end-point study considers combined, detailed end-points for the transition and disposition phases, as discussed in section 4.8.1, it is necessary to allocate an appropriate subset of transition end- points to the transition phase. Completion and formal closure of the transition end-points demonstrates the readiness to transfer the facility from the operating program to the disposition program. In identifying the transition end-points, it is important to take advantage of the capabilities of existing operational systems and personnel where possible. For example, by performing a final process run and flushing and sampling as part of the last operational activities, the operating program can significantly mitigate hazards, prevent detrimental chemical reactions and systems deterioration due to material holdup, and reduce the total costs of transition and disposition activities. The following guidelines will assist in determining which end-points should be allocated to the transition phase: Activities to complete end-points requiring training and skills that may be lost following cessation of operations. Example: Product/SNM removal and stabilization End-point activities that are natural extensions of operations, such as bulk product removal, flushing, etc. Example: Documented piping and tank flushing after final process runs Removal of radioactive, nuclear, and/or chemically hazardous substances and wastes for which disposition paths are readily available. Example: Disposal of stored hazardous substances and other bulk containerized materials Deferral of the activities necessary to close the end-point, which significantly increases the risk or cost associated with the activities. Example: Organic solvent solution decontamination Completion of the end-point, which is necessary to ensure protection of workers, the public, and the environment at the time of transfer (operating program to disposition program). Example: Stabilization and/or fixation of readily dispersible radioactive or chemically hazardous substances 4.9 STEP 9: PROJECT PLANNING AND EXECUTION FOR END-POINT ACTIVITIES As the end-points are identified, project planning and execution activities are initiated to ensure that they are achieved. To the extent possible, existing management systems should be used to perform and control the work activities safely. Planning should focus on application of the graded approach. The LCAM Good Practice Guides, found on the Office of Field Management web site, provide detailed guidance on project planning and execution. Also, DOE G 430.1-3, DEACTIVATION IMPLEMENTATION GUIDE, provides additional guidance for project planning and execution with specific application to end-point activities. 4.10 STEP 10: PRE-TRANSFER REVIEW For transition, the LCAM Order requires that the management team achieve stable and known conditions; identify hazards; stabilize, store, and remove materials and wastes; assess the authorization basis; establish S&M activities pending disposition; identify needed resources; conduct a Pre-Transfer Review; and sign an agreement for facilities transfer that identifies conditions and funding. The operating organization should conduct an appropriately graded Pre-Transfer Review to ensure that the facility condition, contents, regulatory status, and hazards have been identified and documented. The Pre-Transfer Review also identifies the status of early actions and transition end-points agreed to be completed prior to transfer to the disposition organization. It is expected that the safety and health requirements have been determined and evaluated for appropriateness, that the required safety systems and controls have been identified, and that a determination has been made as to whether they are in place and performing as intended. This documented review establishes a baseline at the time of transfer to provide the disposition program with an adequate understanding of the facility and includes an assessment and graded characterization of the facility, as discussed in section 4.4. The purposes of the review are to (1) ensure that sufficient information has been collected, assembled, and analyzed to provide an understanding of existing conditions and hazards, and especially to document the remaining hazards based on completion of early actions and transition end-points; (2) permit efficient deactivation (or decommissioning) planning; and (3) minimize the possibility of halting the progress of deactivation (or decommissioning) tasks because of significant unforseen circumstances. A Pre-Transfer Review report should be prepared to document the results of the review and should reflect the up-to-date condition of the facility and its contents. To ensure that the scope of the Pre- Transfer Review is commensurate with the existing hazards, each of the following review subjects should be included in the report, as appropriate to the complexity of the facility: An explicit delineation of the physical boundaries of the facility being transferred including a list of physical structures. Drawings, photographs, and other records reflecting the as-built and as- modified condition of the facility and its surrounding grounds should be a part of this element. An operating history (including previous operational records) of the facility giving the process knowledge of the nuclear and chemical materials that were handled and major spills or leaks that occurred. A facility condition assessment of all structures, existing engineered protective barriers, and systems installed to prevent migration of both hazardous and radioactive contamination to the environment and that ensure the safety of workers, the public, and the environment. Data collection and reporting systems such as FIMS and the Condition Assessment Survey can be used for this purpose. A characterization report that describes the nature, levels, and probable extent of the existing hazardous chemical and radiological contamination within and around the facility. This characterization should be based, and its scope developed, on the level of process knowledge available, the risk of incomplete or outdated process knowledge, and the hazards posed by specific chemical and radiological contamination to workers, the public, and the environment. An accurate and complete list of types, forms, quantities, and locations of all remaining special nuclear and fissionable materials. An inventory or estimate and the locations of the existing toxic substances and/or wastes. A list of documents that define the authorization basis and the S&M requirements necessary to maintain the current safety envelope of the facility. The current status of implementation of the facility's safe shutdown plan. The plan, as a minimum, should have addressed the facility safety envelope, S&M requirements, safeguards and security, and the preservation of facility structures, systems, and components. Baseline information on energy utilities systems and services should also be included. A plan to remove personal property and excess equipment and material not required to operate and maintain the facility. List of permits, licenses, and agreements that remain imposed on the facility. List of outstanding commitments to regulatory authorities, stakeholders, and DOE organizations that require action. Budget resources to be provided. Human resources commitments identifying the DOE and contractor personnel to be transferred in order to maintain the safety envelope pending disposition. Information on any other factors such as potential future use, long-range site plans, facility condition, and potential health, safety, and environmental hazards that could influence the selection of decommissioning alternatives (safe storage, entombment, dismantlement, etc.) or deactivation alternatives (thermal stabilization, residue elimination, separation of utilities, etc.). 4.11 STEP 11: FACILITY TRANSFER The LCAM Order requires development of a signed agreement to document scope, conditions, state of readiness, and associated funding. The agreement is to include a budget resources plan to manage the facility until funding is provided to the receiving program through the normal budgeting process. A Memorandum of Agreement (MOA), signed by both the operating program and the receiving program (generally EM for contaminated facilities) is an acceptable method to document the reassignment of management responsibilities for an excess facility. The MOA provides documentation that transition actions have been completed and addresses associated funding for out-year targets. It also documents the condition of the facility, as determined through the completion of the Pre-Transfer Review, and the state of readiness for transfer. If the facility transfer involves changing responsible contractors, a separate MOA can be used to document this transfer as well. 4.12 TRANSITION PLANNING TOOLS This Guide includes three attachments as aids to implementing this guidance. Attachment 1 is a Checklist of Transfer Activities; Attachment 2 is a Pre-Walkdown Survey; and Attachment 3 is a set of Facility Condition Walkdown Checklists. These tools were developed through the lessons learned during a pilot at Oak Ridge, Tennessee, which assessed implementation of the LCAM requirements and guidance for transferring contaminated, excess facilities owned by Defense Programs and the Office of Science to EM. These tools may be used or adapted to the local needs and characteristics of specific facilities, using a graded approach. ATTACHMENT 1 CHECKLIST OF TRANSFER ACTIVITIES # Subject Details 1. Decision to Proceed Excess determination. Identify contacts for interface between operations and disposition organizations. 2. Conduct a Facility Survey Determine status of structures and systems. 3. Cost Evaluation Breakdown the current S&M budget into task listing. Evaluate for sufficiency for moving into deactivation phase. 4. Budget Identify budget and target for S&M to be transferred. 5. Staffing Identify staff who know the plant and would be important to continuity. Where possible, arrange for re-assignment or availability. 6. Physical Boundaries/ Transfer Scope Identify all structures, outbuildings, tanks, etc. that should be in the scope of transfer. Identify any systems that serve other facilities that are not to transferred. 7. Actions to be Tracked: State Regulatory Commitments DNFSB Commitments Others Generate a list. Coordinate with Permits, etc. 8. Permits, Licenses, Agreements, Safety Analysis, Stakeholder Commitments, etc. Coordinate with commitments above. 9. Nuclear & Fissionable Materials Inventory Obtain a listing; remove consistent with LCAM; document removal. 10. Toxic, Hazardous, Radioactive Materials Obtain a listing; remove consistent with LCAM; document removal. 11. Characterization Summarize the radiological conditions that exist. Propose a level of cleanup. CHECKLIST OF TRANSFER ACTIVITIES (continued) 12. Authorization Basis Status, list of defining documents, S&M requirements to maintain the safety envelope. Update as required. 13. Safe Shutdown Implementation Plan (if applicable) Verify safe shutdown needs. Address the configuration and contamination conditions that should be achieved upon transfer. 14. Property Assets Construct a list of excess property assets limited to those of significant value. Identify which should transfer, which should stay. 15. Schedule Integration Develop a conceptual level schedule that integrates initiation of stabilization with completion of operations. 16. Pre-Transfer Operations For stabilization and hazard elimination. Agree and conduct as a condition of transfer. 17. Formal Transfer Documents Transfer Memorandum of Understanding, Transfer Agreement, Facility Use Agreement (for post transfer). Draft, negotiate, revise, finalize. ATTACHMENT 2 PRE-WALKDOWN SURVEY This attachment is a survey that augments the Facility Conditions Walk-Down Checklists (Attachment 3). Questions and related documents represent focus areas to be addressed by the transition planning team, generally prior to the on-site walkdown inspection. GENERAL FACILITY INFORMATION Facility name/number: Site location: Area name/number: Attach information regarding 1. general description of the facility, including a general arrangements drawing; 2. current operational status; 3. current occupancy; 4. description of prior facility missions and any documents that describe the overall history of the facility; 5. current surveillance and maintenance activities and expenditures; 6. to the extent they exist, any planning information/reports or evaluations regarding future use or disposition of the facility; 7. physical boundaries that define the transfer scope (structures, outbuildings, tanks, etc.). Identify integrated systems or components that will not transfer (e.g., integrated utilities). SPECIFIC FOCUS AREAS 1. Facility Structure Purpose: To determine if investment needed to mitigate hazardous conditions or leakage potential. Questions Structural integrity (walls, foundation, roof) Structural tightness for leakage (walls, foundation, roof, doors, windows) Condition of hot cells Condition of pools and sumps Types of Documents Seismic evaluation Inspection reports 2. Process Systems Purpose: To determine if investment needed to use systems for clean out runs, to stabilize them for residual contained material, or to isolate and abandon. Questions Reactor Reactor systems Dissolution and chemical process systems Gloveboxes Process machinery Cleanup and purification Cooling water Process compressed air Process steam Tanks and large equipment Types of Documents Description of overall operation of process systems Condition or status reports, especially as-left conditions 3. Infrastructure and Support Systems Purpose: To determine if investment needed to upgrade systems to maintain a min-safe facility condition, or to retire systems to reduce hazards. Questions Electrical, natural gas, HVAC, water, sewer, steam, service air, communications, fire protection, etc. Cranes and hoists Elevators Types of Documents Condition assessment surveys Maintenance needs studies 4. Nuclear Materials Purpose: To determine the need for material stabilization or transfer prior to deactivation or decommissioning, and associated costs. Questions What kind of materials might have to be dealt with and what is their status? Examples: nuclear materials (thorium, uranium, plutonium) nuclear fuel (new fuel, spent fuel, etc.) deuterium and tritium sealed sources Are there plans or actions to remove any of the material? Types of Documents DNFSB 94-1 reports and status Inventory reports or data sheets Accountability status Studies for disposition, either by processing within the facility, disposal, or transfer for processing or storage Disposition plans 5. Hazardous Material Purpose: To determine the need for removal of hazardous material. Questions What kind of materials might have to be dealt? Examples: process chemicals (solvents, acids, caustics, etc.) worker hazards (asbestos, beryllium, magnesium, chlorine, etc.) environmentally hazardous (lead, PCBs, freon, paints, cleaning chemicals, etc.) fuels or explosive, incendiaries (diesel oil, gasoline, etc.) other (pesticides, herbicides) Are there plans or actions to remove any of the material? Types of Documents Survey reports or other characterization summaries Lists of materials Results of any stabilization efforts Major reportable incidents, such as those reported in ORPS, in the facility's life cycle (radiological, chemical, industrial, etc.) Related plans or project descriptions 6. Radioactive Contamination and Waste Purpose: To determine the need for fixing contamination, or decontamination, and waste removal. Questions Where is the radioactive contamination, what type is it, what is the amount? Has radioactive contamination been covered with a fixative in the past to prevent it from spreading? If so, where? If so, where are the records? Does radioactive contamination extend to the exterior of buildings? If so, what is it and where are the records? How much and what kind of radioactive waste is currently in the facility? Are there plans or actions to decontaminate? Are there plans or actions to remove waste? Types of Documents Contamination survey reports or other characterization summaries Inventory of loose and packaged waste within the facility Historical reports of contamination while the facility was in use Major reportable incidents, such as those reported in ORPS or in the facility's life cycle (radiological, chemical, industrial. etc.) Related plans or project descriptions 7. Characterization Information Questions Have any quantitative characterizations of the facility and its contents been conducted? Where is data archived for radiological and material information? Types of Documents Characterization reports or plans Inspection reports Value assessment surveys 8. Surveillance and Maintenance Purpose: To understand current inspection and maintenance routine and possible need to increase, or potential to decrease In the following, "surveillance" refers to inspections and monitoring activities. Questions What surveillances are conducted? How frequently? What maintenance procedures are conducted? How frequently? What are the direct costs or level of effort (equivalent FTEs) for surveillance and maintenance, including health physics surveys? What is the administrative burden (overhead) on these direct costs? What S&M procedures are not being conducted that should be? What S&M procedures have been recommended, but not implemented? What S&M procedures are being conducted that should not be (waste of time), but are anyway because of a requirement? What monitoring systems are in operation? Where are the closed spaces in the facility? What are their conditions? What is the status of procedures for entry? Types of Documents List of surveillances and maintenance activities Evaluations conducted on this subject List of repair or maintenance order backlogs Lists of equipment and materials to be removed ATTACHMENT 3 FACILITY CONDITION WALK-DOWN CHECKLISTS 1. FACILITY STRUCTURE Facility Identification: Subject Comment Status Exterior Roof integrity Roof leakage (minimum to profuse) Foundation (cracks, crumbling, etc.) Walls structurally sound weather tight air leaks water tight Doors Windows Dock areas Exhaust stack Ladders and stairs Interior Ceilings Floors Mezzanines Load bearing walls Fire doors Air lock doors Sump pits pumps transfer lines Ladders and stairs Elevators and lifts Connecting passage ways Vaults Canyons Remote handling cells 1. FACILITY STRUCTURE (continued) Support Areas Ceilings Floors Walls Direct Support Buildings Water treatment Roof Floors Walls Foundation Transfer piping Cooling towers Coils Transfer piping Overall facility Electric sub-station Functional General condition Transmission lines2. FACILITY SUPPORT SYSTEMS Facility Identification: Subject Comment Status Electrical Normal power Uninterruptible power source Emergency generator High voltage Equipment rooms (e.g., switch gear) Main breaker panels General wiring Emergency lighting - exterior Emergency lighting - interior Normal lighting Service outlets Fire systems Fire suppression (type) Fire detection Life Safety Disaster Warning Fire annunciation Criticality alarms Continuous air monitors Public address Water systems Potable Supply Sanitary drains Septic system Process Supply Process drains De-ionize Mechanical systems Cranes and hoists Moving platforms2. FACILITY SUPPORT SYSTEMS (continued) HVAC Control room Motor control centers Air supply fans motors ductwork Plenums, air supply air wash system roughing filters HEPA filters Air exhaust fans motors ductwork Plenums, exhaust air HEPA filters Exhaust stack monitors Building chillers coils Building heat natural gas supply electric steam supply steam distribution Heat exchanger Communication systems (telephone, etc.) Inert gas supply for welding etc.3. PROCESS SYSTEMS Facility Identification: Subject Comment Status Process control rooms Process exhaust Fans Motors Ductwork Plenums HEPA filters Off-gas scrubber Process vacuum system Pumps Motors Piping Inert gas, (glove boxes, etc,) Supply Distribution Exhaust Laboratory or fume hoods Process containment (glove boxes, cells) Status (shut down, sealed, isolated) Heat detection system Internal lifts within containment Connected piping Windows Glove ports Other openings Criticality system HEPA filters Pumps Conveyor systems/transfer lines Remote handling units Containment vessels 3. PROCESS SYSTEMS (continued) Reactor tank Tank/vessel systems Status (operable, shutdown, blanked) Level indicators in place Ancillary piping Specialized equipment Chemical transfer systems Pumps Piping Storage tanks Status (operable, shutdown, blanked) Level indicators in place Ancillary piping Storage pools Hot lab manipulators Waste handling Evaporators Filter housings Pumps4. NUCLEAR MATERIALS Facility Identification: Subject Comment Status Plutonium Material in storage In solution In equipment In glove boxes In hot cells Uranium or thorium Material in storage In solution In equipment In glove boxes In hot cells Nuclear fuel New in storage In reactor In wet storage TRU (am, cu, bk, cf) In storage Systems with Pu, U, or TRU holdup Fluid system filters Fluid system particulate Ventilation system filters Ductwork plate out Pool sludge Wall or floor contamination Deuterium, tritium, lithium 6 In storage Sealed Sources In labs or storage5. HAZARDOUS MATERIALS Facility Identification: Subject Comment Status Process Chemicals (if present, form, quantity, location) Acids Caustics Sodium Hydrazide Lab reagents Environmental Hazards Lead, heavy metals Potassium Chromate PCBs Solvents, paint thinners Freon, CFCs Paint, sealants, adhesives Cleaning chemicals Industrial Safety Asbestos Beryllium Magnesium Chlorine Other Fuel oil, gasoline, gas, lube oil Explosives, oxidizers Pesticides, herbicides Biological Hazards Toxic6. RADIOACTIVE CONTAMINATION AND WASTE (if present, form, quantity, location) Facility Identification: Subject Comment Status Radioactive Contamination Open Contamination (address currently controlled open areas) Surface Alpha Surface Beta-gamma Airborne Any "infinity rooms" Covered Contamination (describe what has been encased) Surface coatings and/or More substantial covering Outside (describe conditions) Soil Water Past leakage pathways Radioactive Waste Dry active waste (DAW) Class A Packaged Not packaged Dry active waste (DAW) Class B or C Packaged Not packaged TRU waste (WIPP disposal) Packaged Not packaged Sludges, resins, filters Packaged Not packaged Mixed waste Packaged Not packaged