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3110 ES&H
Assessments of New Facility Plans |
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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 |
|
|
Regulation-Based ESH&Q Permits, and Similar
Operational Issues |
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|
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 |
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|
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 |
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|
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.