1.0
Introduction
Jefferson
Lab is operated by Jefferson Science Associates, LLC (JSA) under contract with
the Department of Energy (DOE). The
terms and conditions of the DOE/JSA contract address compliance with a variety
of ES&H requirements, including state and local agency environmental
permits and federal, state, and local agency authorizations. One specific example is the initial DOE
authorization to commission and operate Continuous
Electron Beam Accelerator Facility (CEBAF),
which was based upon the DOE determination that the risk to personnel, the
public, and the environment was acceptable.
Information
submitted in various forms, including Jefferson Lab’s permit and authorization
registration packages and update reports on other agreements and contractual
requirements assist the cognizant authorities in
evaluating Jefferson Lab’s compliance status.
This information also helps local authorities review potential sources
of impact that could trigger assistance from local emergency response agencies,
e.g., the follow-up to a chemical spill or a radiation exposure incident.
This
chapter describes the environmental permits, other operational and
ES&H-related authorizations and agreements, the associated internal
processes, and the organizational elements involved.
2.0
Responsibilities
Supervisors/ Subcontracting
Officer’s Technical Representatives (SOTRs)/Sponsors
- Review
permits and authorizations periodically to determine if:
- Your
activity or process is correctly represented
- Any
permit amendments or changes are required
- Staff
need to be updated on requirements
·
Inform the Environmental, Safety, Health, and Quality (ESH&Q)
Reporting Manager or the Environmental Engineer of any identified issues or concerns.
·
Provide required monitoring/sampling data or other required
information to the ESH&Q Reporting Manager within the appropriate time
frame.
·
Provide documentation to management when a permit, license, or
authorization change is needed.
·
Notify the Facility Manager or designee (24-hour phone: 876-1750)
to report permit variances.
·
Notify senior management if variances in operational and
ES&H-related agreements and authorizations are necessary or noted.
·
Ensure
subcontract specifications and any purchasing documents address applicable Lab
permit, license, and authorization requirements.
Senior Line Management/Program
Managers
- Ensure
activities and projects are addressed under appropriate permits, licenses,
and authorizations, including National Environmental Policy Act (NEPA) documentation
- Ensure
responsible staff are aware of the appropriate
permit, license, and authorization terms and conditions, including
performance and quality limitations.
Facilities Management Director
See
Tables 1, 2, and 3
Radiation Control Group Manager
See
Tables 2 and 3
Division Safety Officers
- Assists
line management with compliance with permits, licenses, and other
contract-identified requirements such as NEPA authorizations.
ES&H staff
- Assists
line management and Division Safety Officers with addressing any ES&H
issues.
Jefferson Lab Industrial
Hygienist/Hazardous Waste Coordinator
See
Tables 2 and 3
Legal Counsel
- Reviews
applications and requests for Jefferson Lab licenses, permits, or other
authorizations.
ESH&Q Reporting
Manager/Jefferson Lab Environmental Engineer See Tables 1
and 3
- Provides
oversight and administration for ES&H-related permits, licenses,
authorizations, and other contract-identified ES&H requirements.
- Assists
Division Safety Officers and line management in meeting all applicable
ES&H commitments.
Division Managers
- Interact
with agencies for agreements and authorizations specific to your
operations.
- Provide
oversight and administration for operational and division-specific
agreements and authorizations.
3.0
Program and Procedure
Summary
General
Permits, licenses,
authorizations (including NEPA), and other contractual commitments represent
expected actions. Any change shall be
documented and approved, as required, by the appropriate agency.
Environmental
permitting, notifications, and authorizations are established by local, state,
and federal agencies. The Commonwealth
of Virginia, through the Virginia Departments of Environmental Quality (DEQ)
and Conservation and Recreation (DCR), represent the Environmental Protection
Agency (EPA) with respect to air, water, and waste management programs. The DCR is responsible for all storm water
permits. The Thomas Jefferson Site
Office (TJSO) is the permit holder for all Virginia and Hampton Roads
Sanitation District (HRSD) operational permits. As Jefferson Lab is a DOE facility, Jefferson
Lab has other non-permit but relevant operational and ES&H obligations
established in the DOE/JSA contract.
Line management is
responsible for compliance with all applicable requirements established by
these agencies. ESH&Q Division and Radiation
Control Group (RadCon) staff provide oversight and assistance to line
managers.
[Work performed in
non-Jefferson Lab tenant-occupied space in the ARC must adhere to the terms and
conditions of any applicable permits.]
The ESH&Q Reporting Manager and the ESH&Q Division Associate
Director, in conjunction with the TJSO, coordinate ES&H actions with the
regulatory agencies. Radiological programs are
also administered in this manner. The
ESH&Q Division Associate Director and the Lab Director provide oversight on
the relevant contract requirements.
Refer to ES&H Manual Chapter 6710
Environmental Protection Program for environmental program-related
roles and general responsibilities.
Maintenance of Permits, Authorizations, and Agreements
See Table
1 for NEPA authorizations, Table 2 for permits, Table 3 for other environmental authorizations, and Table 4 for other operational related authorizations.
The line managers
listed in Tables 1, 2, and 3 are responsible for complying with the permits,
authorizations, and agreements listed.
This includes providing required information to appropriate agencies,
addressing regulatory or program
developments, and incorporating new activities as identified. Line management shall also identify the need
for new permits or authorizations.
The ESH&Q Reporting Manager
and Environmental Engineer, provides the agency and DOE liaison function, will
keep the responsible managers and their division ES&H support staff
appraised of relevant regulatory developments, especially those involving site
permits and authorizations. The
ESH&Q Reporting Manager will also assist line management by coordinating
concerns with the respective agency representative, in conjunction with the TJSO. Radiation Control Manages radiological program
authorizations through the ESH&Q Reporting Manager.
The contractual commitments
listed in Table 4 are the responsibility of Jefferson Lab
senior management. This charge includes
working with the TJSO to coordinate and update existing requirements and to
provide assistance with the development of new commitments.
Non-Compliance with Agreements
Non-compliance with environmental
permits or agreements may yield a warning, a Notice of Deficiency, or a Notice
of Violation from the authorizing agency.
Non-compliances can also occur with operational requirements contained
in Appendix E of the DOE/JSA Contract.
In all cases, the responsibility for follow-up is with line management.
- If
a problem or concern is identified, notify line management and Division
Safety Officer, who will work with their own line management and the
ESH&Q Reporting Manager to resolve the problem or concern. The ESH&Q Division Associate
Director (AD) will assist the DOE in submitting any identified requisite
report(s) to appropriate agencies.
- If
an external party, such as the DEQ or the DOE, identifies a problem or
concern, then line management is responsible for the corrective
actions. The Facility Manager
designee, at 876-1750, will assist line management in determining and
fulfilling the necessary notification requirements.
Table 1: NEPA Authorization List Applicable
Law: NEPA
Agency: DOE as mandated by EPA
|
NEPA
Authorization
|
Title
|
Purpose
|
Effective
Dates
|
Status
|
Manager
|
|
DOE/
EA-0257 (1987)
|
CEBAF, Newport News, Virginia
|
Take environmental considerations into account for construction
and operations.
|
Life of laboratory
|
fixed
|
Lab Director
|
|
DOE/
EA-1204
(1997)
|
Change in Operating
Parameters of the CEBAF and Free Electron Laser (FEL), Thomas Jefferson
National Accelerator Facility, Newport News, Virginia
|
Take environmental
considerations into account for CEBAF upgrade and FEL operation.
|
Life of laboratory
|
fixed
|
AD-Acc
|
|
DOE/
EA-1384 (2002)
|
Proposed
improvements at the Thomas Jefferson National Accelerator Facility, Newport News, Virginia
|
Assess
environment and other factors for CEBAF
Center expansion, an
FEL addition, new refrigeration, tech support, and storage buildings on the
accelerator site and installation and operation of Helios
|
Life of Laboratory
|
fixed
|
FMD
|
|
DOE/EA-1
534 (2007)
|
Proposed Upgrade and
Operation of the CEBAF and FEL Accelerators and Construction and Use of
Buildings Associated with the 2005 Ten Year Site Plan at the Thomas Jefferson
National Accelerator Facility, Newport
News, Virginia
|
16GeV CEBAF accelerator
upgrade, FEL upgrade, and Helios/FEL operation Hall D and other support
buildings, two retention ponds
|
Life of Laboratory
|
fixed
|
AD-Acc and FMD
|
|
Active CXs and internal authorizations
|
various
|
Take
environmental considerations into account for standard ongoing Jefferson Lab
activities.
|
Renewable
annually if still applicable
|
fixed, but can
be modified
|
LM
|
|
Generic CXs
|
various
|
Exclusions that address environmental considerations for some routine
activities that are applicable at all Oak Ridge
Operations facilities.
|
Life of laboratory
|
fixed, new ones can be added
|
LM
|
|
Project CXs,
as identified
|
various
|
Take environmental considerations into
account for particular projects, usually construction-related, on an
as-needed basis.
|
Life of project
|
fixed, new ones can be added
|
LM
|
Notes: Copies of CXs and EAs are on file in Room
602 of ARC. ESH&Q Reporting will
assist line management to evaluate and document projects and activities under NEPA. Contact ESH&Q Reporting at ext. 7308.
Table 2: Environmental Permit List
|
Program Document
|
Agency Purpose
|
Agency
|
Effective Dates
|
Permit Conditions
|
Site Issues
|
Applicable Law & ES&H Manual Reference
|
Program Manager
|
|
Industrial Wastewater Discharge Permit No. 0117
|
Prohibit discharges of any material that may disrupt the treatment
plant’s operation or are hazardous to the environment.
|
HRSD
|
Through 3/1/2012
(5-year renewals)
|
Quarterly sampling and reporting for pH;
monthly and quarterly sampling and reporting for radionuclides;
maintain and track meters; maintain neutralization tanks; provide
notification of unusual cooling tower discharges; and provide monthly flow
calculations.
|
Identify and limit waste to be discharged to sewerage. Discharges include activated water.
Reports:
· Monthly
rad and flow info and pH reports- 10th of the following month.
· Quarterly
rad reports- 45 days after end of quarter.
|
Clean
Water Act; HRSD
Industrial Wastewater Discharge Regulations; VA Radiation Protection
Regulations
See Ref. 1
|
FM
Director,
ext.
7589
(radiological
portion- RadCon
Manager, ext. 7551)
(neutralization tanks-JLab IH, ext. 7039)
|
|
Virginia
Pollutant Discharge Elimination System (VPDES) Permit No. VA0089320
|
Ensure
quality of on-site groundwater, cooling water, and dewatering
discharges. Assure groundwater
unaffected at and beyond site boundary.
|
DEQ
|
Through
7/16/2011
(5-year
renewals)
|
Radiological
and non-radiological sampling for operational monitoring;
quarterly, semi-annual, & annual reporting; notify the DEQ of unusual
discharges or events; and, upon request, submit a report addressing any areas
of concern. Perform quarterly sampling
and reporting; obtain permission from the DEQ prior to changes in chemicals
or treatment process; maintain and calibrate equipment and meters; and
perform annual inspection.
|
Ensure
Jefferson Lab operations do not degrade the quality of off-site groundwater
and that on-site impacts are minimized.
Ensure the quality of the designated cooling tower discharges remain
within the permit limits. Quarterly
Reports- 10th of month following end of the quarter.
|
Clean
Water Act;
Safe
Drinking Water Act (SDWA); Virginia
State Water Control
Laws
See Ref. 2
|
RadCon
Manager,
ext.
7551
and
FM
Director,
ext.
7589
|
|
VPDES
General Permit for Storm Water Discharges of Storm Water from Construction
Activities
General
Permit No. DCR 01-08-100332
|
Authorize
discharge of storm water from construction activities affecting 1 or more
acres.
|
DCR
|
8/15/2007
through
6/30/2009
(will
reapply as needed)
|
Maintain
Storm Water Pollution Prevention Plan (SWP3) and appendices to meet all
permit conditions.
Implement
erosion and sediment control measures as identified in SWP3.
|
Ensure
storm water quality is not affected by construction site activity.
Reports:
·
Unusual
discharges to be provided to DCR
·
No
monitoring.
|
Clean
Water Act;
SDWA;
Virginia State Water Control Laws
See Ref. 2
VPDES
Permit DCR01
|
FM
Director,
ext.
7589
|
|
VPDES
General Permit for Small Municipal Separate Storm Sewer Systems General
Permit No. VAR040079
(DCR02
Pending)
|
Allows
operators of municipal separate storm sewer systems to discharge to surface
waters.
|
DCR
|
6/13/2003
through
12/9/2007
(5-year
renewals)
|
Provide
an annual report in years 1, 2, and 4 before June 13 of those years; Perform
Best Management Practices and track goals identified in the registration
documents; Develop a comprehensive storm water pollution prevention plan; and
provide staff and Lab community education to prevent pollution.
|
Ensure
the quality of surface water leaving the site.
|
Clean
Water Act;
SDWA;
Virginia State Water Control Laws
See Ref. 2
|
FM
Director,
ext.
7589
|
|
Permit
to Withdraw Groundwater No. GW 0047200
|
Authorize
the discharge of water from under the end stations within permit limits.
|
DEQ
|
4/11/2005
through
3/31/2015
(10-year
renewals)
|
Record
daily withdrawal amounts; report amounts quarterly; and maintain and
calibrate equipment.
|
Monitoring
for water quality is performed under the VPDES Permit No. VA0089320.
Reports:
· Quarterly Reports- 10th of month
following end of the quarter.
· Annual Report-provide in January at DEQ
request
|
Groundwater
Management Act of 1993; Virginia
State Water Control Laws
See Ref. 1
|
FM
Director,
ext.
7589
|
|
Permit
No. 4724-45-06
(2007
Permit Pending)
|
Authorize
transport within the state
|
South Carolina Dept. of Health and Environ-mental
Control
|
1/13/2006
through 12/31/2006
|
Authorize
movement of radioactive
wastes within South Carolina
|
Ensure
proper packaging for transport.
|
Regulation
No. 61-83 Transportation of Radioactive Waste into or within South Carolina
|
RadCon
Manager,
ext.
7551
|
|
|
|
|
|
|
|
|
|
Ref. 1: ES&H
Manual Chapter 6730 Appendix
T1 Discharges to the Sanitary Sewer System and ES&H Manual Chapter
6730 Appendix T2
Activated Water Management.
Ref. 2: ES&H Manual Chapter 6730 Water Quality and Conservation Program and ES&H Manual Chapter 6731 Groundwater Protection.
Notes: For copies of permits or additional
information contact the Jefferson Lab Environmental Engineer at ext. 7308. This staff member will assist line managers for new permit registration and with permit
maintenance and modification actions.
Table 3: Other Environmental Authorization List
(Authorized to operate as we have registered for or
complied with the following programs.)
|
Program Document
|
Agency Purpose
|
Agency(ies)
|
Effective
Dates
|
Site Issues
|
Applicable Law &
ES&H Manual
Reference
|
Line Manager
|
|
Emergency
|
|
|
|
|
|
|
|
Preparedness
|
Alert regional and local planning and response groups of
“potential” hazards involving hazardous and extremely hazardous substances.
|
VA Emergency Response Council, Peninsula Local Emer.
Planning Comm., Newport News
Fire Dept. (NNFD)
|
ongoing
|
Being alert to possible emergency situations involving
hazardous materials and keeping community emergency planning groups (EPGs)
informed.
|
EPCRA
See Ref. 1
|
ESH&Q Reporting Manager,
ext. 7007
|
|
Planning
|
|
|
|
When above threshold planning quantity: Submittal of chemical hazard
info. to EPGs; tracking of chemical inventories.
|
|
Inventory: JLab IH, ext. 7039
Reporting: JLab Environmental Engineer, ext. 7308
|
|
Notification
|
|
|
|
Notification of releases off site above listed
quantities; inform NNFD of chemicals of special concern.
|
|
NNFD Information-Fire Protection Engineer, ext. 7674
|
|
Right-to-Know Reporting
|
|
|
|
Submittal of annual Tier II report by March 1; Annual review of toxic
chemical use by July 1.
|
|
|
|
Waste
|
|
|
|
|
|
|
|
Hazardous Waste Activity ID No. VA7750090030
|
Manage generation of hazardous waste as a Small Quantity Generator.
|
DEQ
|
ongoing
|
Handle, collect, and dispose of hazardous wastes in accordance with
the regulations.
|
RCRA; VA Hazardous Waste Management Regulations
See Ref. 2
|
Hazardous Waste Coordinator, ext. 7039
|
|
Radioactive
Waste
|
Manage disposal of low level waste.
|
DOE
|
ongoing
|
Collect and dispose of radioactive
wastes in accordance with program.
|
DOE O 435.1
See Ref. 3
|
RadCon
Manager,
ext. 7551
|
|
Water Issues
|
|
|
|
|
See Ref. 4
|
|
|
Spill Prevention, Control, and Countermeasure (SPCC) Plan
|
Prevent and control spills of oil and petroleum-based
substances.
|
U.S. EPA
|
8/2004
Ongoing (5-year reviews)
|
Identification of oil sources; spill prevention and
control strategies including use of division specific procedures;
response and cleanup
activities; plan review and reporting actions.
|
Clean Water Act; Oil Pollution Control Act
|
Line Management (Oversight: SPCC Coordinator, ext. 7308)
|
|
Cross-Connection and
Backflow Prevention
Control
|
Provide protection of potable water
supply.
|
City of Newport News
|
ongoing
|
Coordinate an annual
inspection of all backflow
prevention devices with the
City.
|
Safe Drinking
Water Act
|
FM Director,
ext. 7589
|
|
Air Issues
|
|
|
ongoing
|
|
See Ref. 5
|
FM Director,
ext. 7589
|
|
Emission Source Notification (non-radiological)
|
Maintain records on emission sources that could impact the
environment.
|
DEQ
|
|
Registration and record keeping of emission data; and reporting of
equipment information upon request.
|
Clean Air Act; VA Air Pollution Control Law
|
|
|
Ozone-Depleting
Substances (ODSs)
|
Discontinue and minimize to extent possible the purchase
of ODSs;
and limit handling of ODSs to
EPA-certified subcontractors and personnel.
|
EPA, DOE
|
|
Limit purchases of ODS-containing
materials; ODS purchases to be approved by FM Director; maintain
EPA-certifications.
|
Clean Air Act; VA Air Pollution Control Law; Executive
Order 13148
|
|
|
Radiation
|
|
|
|
|
See Ref. 6
|
RadCon
Manager,
ext. 7632 7551
|
|
NESHAPs
|
Monitor hazardous air pollutants from accelerator
operations.
|
EPA, DOE
|
life of laboratory
|
Monitoring program is
in effect; Report annually to EPA by June 30th
|
Clean Air Act
|
|
|
Notification of Planned
Radionuclide
Release,
Registration No. 61062
|
- Identify new source of radionuclide
emissions, included notification of construction, start of CEBAF
operations, and planned upgrades.
|
EPA
|
life of laboratory
|
CEBAF start-up as a source of emissions.
|
NESHAPs; VA Radiation Protection Regulations
|
|
|
Planned Radiation
Source
|
Registration of planned radiation
source.
|
Dept. of Health, Bureau of Radiological Health
|
Exemption issued 5/88
|
Jefferson Lab produces radionuclides,
but is exempt from the Health Dept. Ionizing
Radiation Rules and Regulations
|
VA Radiation Protection Regulations
|
|
Ref. 1: ES&H Manual 6710 Appendix T2 Emergency Planning and Community
Right-to-Know
Ref. 2: ES&H Manual Chapter 6761 Hazardous Waste Management
Ref. 3: ES&H Manual Chapter 6760 Waste and Recyclable Materials Management
Ref. 4: ES&H Manual Chapter 6730 Water Quality
and Conservation Program and ES&H Manual Chapter 6732 Oil-Spill Prevention, Control, and Countermeasures
Ref. 5: ES&H Manual Chapter 6720 Outdoor Air Quality Management Program
Ref. 6: ES&H Manual Chapter 6315 Environmental Monitoring of Ionizing Radiation
Notes: Additional information can be obtained from
the ESH&Q Reporting Manager at ext. 7007.
The ESH&Q Reporting Manager and the Jefferson Lab Environmental Engineer at ext. 7308 will assist line
management to maintain authorizations.
Table 4: Other ES&H, Operational, and Licensing
Obligations
