Decommissioning: Five critical steps to minimize risk and cost
By Robert Barnes
When I walked into the SEMI Environmental Health & Safety (EH&S) European Standards Meeting at a recent SEMICON Europa, I already knew there was considerable global interest in the safe decommissioning and decontamination of cleanroom manufacturing facilities.
What I was not yet aware of was the number of issues that have been compounding over the years, including: the high level of international concern regarding the potential risk to personnel, equipment and facilities; the overall lack of industry-wide best practices; and the ultimate issue of corporate and personal liability.
Fifteen months after the EUROPA meeting, the SEMI EH&S Decommissioning and Decontamination Task Force submitted its draft report to the SEMI EH&S Standards Committee at SEMICON West. More than 150 international industry representatives from more than 75 device manufacturers, OEMs and service providers participated in the report's creation.
Their experiences, both good and bad, were collected in the form of 375 personal concerns, which were then organized into 24 key issues and four specific action recommendations. And I was honored to have the opportunity to lead the task force.
A technician disassembles a stepper before performing decontamination of individual components.
The general consensus of task force participants was that current industry guidelines are inadequate and that they need to be re-written to provide useful operational specifics rather than general philosophy. In addition, the task force understood that the revised guidelines should include specifics concerning the training and qualification of specialized service providers who are needed to safely accomplish a decommissioning project.
As a result of this activity, SEMI International Standards is moving forward to improve the content and usefulness of industry guidelines relating to decommissioning projects. In turn, Arizona State University is developing a program to improve the global understanding of decommissioning issues, including the training and qualification of specialized service providers.
These are positive industry-wide steps and will improve the overall safety and efficiency of future decommissioning projects. But what can a company do today to minimize both the risk and cost of such a project down the road?
Take the steps
A company must initially complete five critical steps to prepare for a safe and cost-effective decommissioning project:
- Clearly defining the desired end-state;
- Developing a decommissioning plan;
- Preparing a detailed scope-of-work;
- Identifying the resources required;
- Hiring qualified specialized service providers.
Defining the end-state. No project will ever be successful without a clear goal; therefore, defining the desired end-state of the facility should be the first step in any decommissioning project.
What will be the final "appearance" of the facility, including the extent of decommissioning to take place? Will just one tool be removed while all other items stay in place and in normal operation? Or, will all tools, facility systems and chemical distribution lines be removed, creating a clean shell?
Once the final disposition of all items has been determined, the four principal priorities become a combination of cost, schedule, the expected process reliability of used equipment, and regulatory compliance. You must clarify the appropriate balance of these priorities in your decommissioning plan.
Developing a plan. The decommissioning plan describes the specific objectives of the facility's owner relating to every activity involved in the decommissioning. It should include details as to the disposition of all items at the site and how the stated objectives are to be achieved.
The overall goal is to ensure that the facility is left safe for its next intended use by describing how all used items will be rendered safe for human health and the environment. It should also describe how the value of items destined for re-use will be protected.
The decommissioning plan should provide management with a method to evaluate cost-saving alternatives by addressing such questions as "why are we decontaminating this item?" For example, general regulatory guidance requires that an item will be decontaminated to the level appropriate for its intended disposition. Balancing the cost of specific decontamination techniques versus intended disposition can save dollars and protect asset value. But the impact of each disposition decision needs to be understood in terms of dollars and compliance.
The decommissioning plan should, therefore, detail the correct handling of each item in the facility by its intended disposition. That includes the recommended general and equipment-specific decontamination protocols to be used by specialized service providers.
Some facility management teams have the expertise required to develop such a plan in house, but most do not. You should seek to retain a specialized consulting team to assist in preparing of the decommissioning plan.
Preparing a Scope-of-Work. Once the decommissioning plan has been drafted and approved by management, it's time to prepare a detailed scope-of-work (SOW) describing exactly what needs to be done to achieve the plan's objectives.
Some of the actual work can be accomplished by staff personnel and current vendors, but certain tasks will need to be accomplished by specialized service providers with experience in decommissioning projects. Due to the mix of personnel involved with any decommissioning, it's imperative that the SOW be sufficiently detailed so that management can make appropriate decisions as to the required qualifications of personnel assigned to each task.
Experience has shown that it is not uncommon for management to feel that a decommissioning is simply the reverse of an installation process. This could not be farther from the truth. For example, consider the basic issues surrounding the "simple" decommissioning of just one process tool—the tool has been exposed to process chemistry and the working environment of the facility. How is it contaminated both internally and externally? What level of decontamination needs to be accomplished to ensure both safe transportation and its future process integrity after storage and/or shipping? What are industry best practices regarding the decontamination and preparation for removal of this particular tool?
Identifying the resources required. Once the tasks to be accomplished have been defined, who will be accomplishing each task? And more importantly, who will be providing management oversight to ensure efficiency, safety and regulatory compliance?
Developing a decommissioning plan, detailing the scope-of-work, and matching available resources against this SOW make it possible to quickly and accurately define tasks that will need to be performed by specialized service providers. A request-for-proposal (RFP) can then be easily prepared that itemizes the required services and management's performance expectations regarding the specific delivery of those services.
This approach makes it possible for qualified service providers to respond to the RFP with a minimum of uncertainty, thereby ensuring more accurate costing and bids that are representative of the project's requirements.
Unfortunately, it is far too common for an RFP to be too general and leave major concerns unaddressed until well after the project begins. This forces bidders to include the cost of uncertainty as part of their bid, consequently, increasing the project's overall cost. Failing to include specific performance expectations in the RFP increases the risk and liability for the owner, since the contractor is left to evaluate and define the necessary compliance, safety, and quality standards.
Hiring qualified specialized service providers. It's imperative that management fully understands the implications of the following statement: Decommissioning is not simply the reverse of the installation process.
Preparing the site, erecting a building, installing necessary infrastructure and equipment, then qualifying the various manufacturing systems is a logical and generally clean process.
Once the facility has been used for production, especially production that requires hazardous materials or creates hazardous by-products, the environmental complexity increases dramatically and the issue of legacy liability needs to be given serious consideration by management.
The inherent risks associated with the decommissioning of such manufacturing equipment can pose significant liability and workman compensation exposures for the original equipment owners, contractors and the new equipment owners. Put very simply, the overall responsibility for ensuring the safe and legal disposition of all assets cannot be entirely delegated to a contractor or purchaser.
What's the solution? Management should properly define the project and then hire specialized service providers with both the professional certifications and experience required for the tasks management expects them to perform. Until there is a professional certification program for decommissioning specialists, management should mitigate any potential liability by preparing a detailed SOW that includes contractor performance expectations, and then hire the best qualified specialist service companies available.
Decommissioning is a complex activity; however, with proper management planning and the right combination of qualified personnel, it can be accomplished with safety, efficiency, quality and peace of mind.
ROBERT BARNES is president of Robert B. Barnes Associates, Inc., of Scottsdale, Arizona, and specializes in assisting companies with both decommissioning and disaster recovery projects. He can be contact at: RBarnesAZ@att.net