TITLE:

ES&H Manual

 

DOCUMENT ID:

3110 ES&H Assessments of New Facility Plans

 

 

1.0          Introduction

 

It is less expensive and less disruptive to plan and integrate safety or environmental protection features into a new design than it is to retrofit an existing facility.  Good engineering and architectural design practices easily accommodate the special features or considerations that may be required to meet our ESH&Q objectives. Thus, it is essential to identify any environmental, health, or safety requirements or potential liabilities associated with a new facility early in the concept and design phases.  Early identification will provide ample opportunity to manage, control, and mitigate such impacts and assess the effectiveness of those efforts.

 

This usually means a team approach. Several people have legitimate and important contributions to make early in the life of a new facility’s design: the customer or primary user, the designer of the structure, the designer of the utilities and apparatus within the structure, and experts about the Environment, Health, Safety, and Quality implications of the facility. All need to collaborate and seek effective and economical solutions for any anticipated ESH&Q concerns or problems and to identify ES&H goals as opportunities for improvement.

 

This process will promote the design of facilities that:

·       are environmentally responsible — during construction and use

·       avoid unnecessary costs and promote timely agency review and/or permits

·       provide for life safety and fire protection

·       minimize built-in problems that impair the facility’s usefulness or require expensive future modifications

 

This chapter describes the general approach for assessing new facility plans for ESH&Q implications. It is useful for anyone who specifies or designs:

·       a new structure

·       structural, mechanical, or electrical system modifications to an existing facility

·       changes in use of a building related to its technical/scientific purposes

 

Depending on the nature of the project, the ESH&Q review will range from an informal determination by qualified staff to more rigorous research and analysis.

 

2.0          Hazard Avoidance

 

We can be reasonably assured that we will not violate our ESH&Q-related permits, facility operating parameters, nor endanger people and the environment if we:

 

3.0          Responsibilities

 

Manager-Owner/Customer of New Facilities or Proposed Modifications

 

Facility Designers

 

ESH&Q & Systems Experts

 

4.0          Procedure

 

No standard set of detailed review procedures can reasonably anticipate all possible new or modified facilities that may be considered at Jefferson Lab.  A general approach is described here that, with a graded application, will be useful in nearly all situations.

 

4.1            Anticipate

ESH&Q assessment of a proposed facility should occur before design criteria or other, less formal work-description documents are drafted, ideally even before initial concepts are finalized. The customer, the designer, or the user may identify a potential ESH&Q implication. If there is any hint about a possible ESH&Q situation that should be addressed, it is advisable to get expert review.

 

4.2            Assess and Review

The table below provides a summary of the most probable ESH&Q issues that would likely trigger the need for expert review. If the proposed facility appears to have one or more of these aspects, involve the designated expert(s) early in the planning or preliminary design stages of the facility.

 

Table 1: Potential ESH&Q Issues for New Facilities or Proposed Modifications

ESH&Q Issue

Facility Aspect

Jefferson Lab Expert(s)

Regulation-Based ESH&Q Permits, and Similar Operational Issues

Accelerator safety envelope/facility safety,

Accelerator Readiness,

 

Changes to facility design and operational assumptions used in the Final Safety Assessment Document (FSAD)

ESH&Q/QA Officer, Accelerator Division for beam energy concerns

National Environmental Policy Act (NEPA)

Environmental impact other than items covered under Jefferson Lab’s Categorical Exclusions to NEPA (NEPA review is required for all facilities to be built or modified.)

Environmental Engineer, ESH&Q Division, ESH&Q/QA Officer, Accelerator Division for beam energy concerns

Clean Air Act

Discharge of regulated pollutants including radionuclides into the atmosphere or alterations to existing pollution sources or controls

Environmental Engineer, ESH&Q Division, Radiation Concerns: Radiation Control (RadCon) Manager, ESH&Q Division

Other Regulation or Code-Related Issues

Generation of hazardous waste

(Resource Conservation and Recovery Act)

Significant increase in hazardous waste quantities: > 100 kg/3 mos

Hazardous Waste Coordinator, ESH&Q Division

Clean Water Act

Discharge of chemicals, oil, radionuclides, or sediment to surface water or sanitary sewer

Environmental Engineer, ESH&Q Division, Radiation Concerns: Radiation Control (RadCon) Manager, ESH&Q Division

Life-safety code

Appropriate use of space relative to its designated occupancy; means of egress, integrity of structures in fire.

Project Architect, Facilities Management & Logistics Division

Fire protection

Fire detection, suppression, alarm, and other fire-safety and loss-mitigation systems; fire exposure to existing nearby structures, combustion systems in buildings

Fire Protection Engineer, Facilities Management & Logistics Division

Occupational radiation protection

Radiation-producing apparatus or materials, physical design features, and administrative controls

Radiation Control (RadCon) Manager, ESH&Q Division

Community Right-to-Know and other chemical inventory reporting

Hazardous chemical use and storage, changes to potential for accidental release of existing chemicals

Environmental Engineer, ESH&Q Division, Industrial Hygienist, ESH&Q Division

Oil-Spill Prevention Control and Countermeasures (SPCC)

Oil use and storage on site in areas not already equipped with engineered controls, or in excess of spill-control capacity; modifications to engineered control measures; changes to need and type of spill response

Environmental Engineer, ESH&Q Division, Facilities Management Director, Facilities Management & Logistics Division

Other Important ESH&Q Issues

Oxygen deficiency

Addition or alteration of cryogenics and related systems or structures that change classification of ODH regulated areas

Deputy Division Manager for System Support, Accelerator Division

Industrial hygiene

Chemical-handling and storage areas, exhaust ventilation requirements, noisy environments, non-ionizing radiation, lasers

Industrial Hygienist, ESH&Q Division,

 

Industrial safety

Machinery, cranes, special hazard environments

ESH&Q staff in respective owner division ???????(see listing at front of Jefferson Lab telephone directory or Appendix 2210-R1 Current ES&H Staff Assignments)

Land-use Management

Potential disturbance (removal or destruction) of site features including: 

§  Natural resources (biological, etc.)

§  Cultural resources

Facilities Management Director, Facilities Management & Logistics Division

Buried utilities

Excavation, soil drilling or disturbance anywhere on site

Utility Location Coordinator, Facilities Management, Facilities Management & Logistics Division

Electrical service

Significant changes to loads on transformers and switchgear, construction in vicinity of high-voltage switchgear and lines

AC Power Coordinator, Facilities Management, Facilities Management & Logistics Division

HVAC systems

Energy efficiency; adequacy of ventilation and temperature control; refrigerant selection

Systems Operation’s Maintenance Manager, Facilities Management, Facilities Management & Logistics Division

Environmentally Preferable Products

Building Materials

Design Engineer/Project Manager, Facilities Management & Logistics Division

 

The scope of the expert’s review should be well understood by the customer and designer. Do not assume that a given reviewer will be alert to ESH&Q aspects of the facility other than her or his focus area, although he or she may well highlight areas that appear to need additional assessment.

 

4.3            Document

Records of ESH&Q reviews (in whatever form they occur) should be preserved as part of the overall project design documentation. This may be as simple as the reviewer initialing a preliminary drawing or a set of specifications. For large, complex facility design, there will likely be a more formal design review process that elevates the detail of the ESH&Q review documentation.

 

There are several reasons for documenting review. It preserves our methods and rationale so that we are able to undertake a comparable review more efficiently in the future. It may be an aid if permitting or agency review is necessary. It augments the customary discipline found in good engineering and architectural design practices, particularly when the facility is modified or when its use changes.