8050 Environmentally Harmful Materials
Various processes at Jefferson Lab use or produce environmentally harmful materials (EHMs) -materials which can have a negative impact on the environment or public health if released improperly. EP Supplement EPS-50 Environmentally Harmful Materials covers the general requirements involving storage, use, and transport of EHMs and the consequences of a release to the environment. Refer to ES&H Manual 6610 Appendix T3 Labeling, Storing, and Transporting Requirements specific requirements for storing EHMs. EHMs include hazardous substances, hazardous wastes, and oil and oil products. By managing EHMs as presented in this Manual, we can protect against and/or minimize both environmental impacts and becoming subject to additional regulatory requirements.
Different types of non-radioactive and radioactive air emissions and waste products are EHMs and are environmental aspects* resulting from Jefferson Lab operations.
* Aspects (as documented in the Jefferson Lab Environmental Management System, (EMS) Plan) are associated with an environmental impact.
2.0 Key Roles
Responsibilities specific to the EHMs program are outlined in EP Supplement EPS-50 Environmentally Harmful Materials of the Environmental Protection (EP) Supplement.
2.1 Everyone at Jefferson Lab
Be familiar with EHMs and each Material Safety Data Sheet (MSDS) for materials in your area.
2.2 Division Safety Officers
Work with ESH&Q Division Staff to:
· Assist staff with identification of EHMs, appropriate handling procedures, and any special concerns, such as proximity to floor drains or discharge points.
· Provide EHM inventory data to the ESH&Q Reporting Manager upon request.
· Assist Supervisors in minimizing possible environmental impacts of potential spill events.
· Assist line manager in preparing a Notable Event Worksheet (ES&H Manual Chapter 5200 Event Investigation and Causal Analysis Process) for all spills.
· Provide assistance in sampling soil and/or water to assist in problem identification and to verify a completed cleanup.
· When practicable, replace EHMs by using less hazardous or non-hazardous alternatives.
· Ensure your staff is aware of emergency response procedures and that they have access to appropriate spill response and first aid equipment.
· Oversee and coordinate with ESH&Q staff proper storage, collection, and disposal techniques for EHMs.
· Ensure spill prevention and control procedures are incorporated into subcontractor safety plans.
2.4 ESH&Q Division and Division ESH&Q Staff
· Assist staff in identifying EHMs, handling procedures, and other special concerns.
· Provide inventory data to the ESH&Q Reporting Manager.
· Assist line management with minimizing the environmental impacts that could result from potential spill events.
· Provide assistance with soil and water sampling as requested.
2.5 Radiation Control Group (RadCon)
· Oversee proper storage, collection, and disposal procedures for radioactive EHMs.
· Provide assistance with soil and water sampling in radioactive areas.
· Respond to all radiation emergencies, and if EHMs are involved, respond under the guidance of the Chemical Spill Team.
2.6 Jefferson Lab Industrial Hygienist (IH)
· Perform duties involving EHMs as noted in ES&H Manual Chapter 6610 Chemical Hygiene Program.
· Review EHM purchases to maintain awareness of large changes in site EHM inventories.
2.7 Jefferson Lab Hazardous Waste Coordinator (HWC)
· Perform duties as detailed in ES&H Manual Chapter 8061 Hazardous Waste Management.
2.8 Public Affairs Officer
· Assist in developing and disseminating news releases concerning EHM spills.
2.9 Facilities Management Director
· Maintain sluice gates and ensure their operation is included in emergency response training.
· Assist line management in control and containment of large spills including those extending beyond a building’s confines.
· Coordinate and contract for cleanups.
2.10 ESH&Q Reporting Manager
· Provide release notification information to Department of Energy (DOE) and other identified regulatory agencies.
· Ensure quantities of EHMs are minimized and inventories are kept below potential reporting thresholds.
· Track releases and maintain spill reports and notable event analyses.
· Assist line management in determining release causes and future preventive measures.
2.11 MSDS Coordinator
· Track incoming chemicals and maintain site chemical inventory.
· Support the ESH&Q Reporting Manager with preparation of Emergency Planning and Community Right-to-Know Act (EPCRA) documentation.
3.0 Program Summary
Preventing use or the accidental release of EHMs requires careful planning – from considering the initial process to disposing of the residual waste. This process includes EHM identification, careful selection to minimize the hazards due to storage, use, transportation, and disposal; and, maintaining material inventory and usage information.
Information about environmentally harmful waste streams may be found in the appropriate waste profile, while environmentally harmful, non-waste items are identified on applicable MSDSs.
Process planning includes identification of EHMs, how they will be used, and preparing an analysis of their hazards. If an identified EHM is an extremely hazardous substance (EHS) and alternative materials are unacceptable, the MSDS should be provided to the IH for review and guidance. (The procedures identified in ES&H Manual Chapter 6610 Appendix T2 Chemical Requisition and Procurement should be reviewed to help the purchaser be aware of all involved hazards and to assist the IH ensure that the quantity on-site remains below the threshold planning quantity (TPQ) for that material.)
The best method for identifying an EHM’s hazards is to review its MSDS. By reviewing hazardous components, implementing handling precautions and spill response requirements, risks associated with spills or accidental releases can be greatly reduced. (Refer to ES&H Manual Chapter 6610 Appendix T1 Material Safety Data Sheets.)
A list of most EHMs that are currently used at Jefferson Lab is presented in EP Supplement EPS-50 Appendix R1 Chemical/Material List of EHMs. Reportable Quantity (RQ) and Threshold Quantity information is also provided in this Appendix.
Prior to ordering EHMs, reasonable efforts should be made by the responsible line manager to locate excess materials that might be available on-site or explore less hazardous substitutes through Industrial Hygiene. EHMs shall be ordered only if justified by the responsible line manager with the concurrence from the Lab’s IH.
Refer to ES&H Manual Chapter 6610 Appendix T2 Chemical Requisition and Procurement for additional guidance.
Use EHMs as initially intended. For maintenance activities that may disturb an EHM, contact the Facilities Management Maintenance Systems and Operations Manager for assistance. Subcontractors must comply with all subcontract requirements as specified in ES&H Manual Chapter 3410 ES&H Aspects of Procurements.
Proper storage of applicable EHMs is essential. All EHMs should be stored in appropriate containers and secondary containment should be provided. Weatherproof secondary containment is required if an EHM is to be kept outdoors. As well, secondary containment shall also be used if an EHM is to be stored near a floor drain inside. All containers and piping shall be inspected at least annually to ensure structural integrity. Do not use containers that are structurally unsound or made of inappropriate material. Ensure that the contents are clearly identified on the container’s label in indelible ink. (Note that there may be more than one label on a container, such as a NFPA label.) Safety Lab and local division ESH&Q staff are available to assist.
Transfer of significant quantities of EHMs (e.g., from a container to a compressor) shall be performed by qualified personnel following the appropriate standard operating procedures. Such transfers will be performed only in designated locations with appropriate containment and response equipment in place or easily accessible.
Prior to any transfer, all equipment, especially hoses, shall be visually inspected for defects. If defects are found they should be corrected or the equipment replaced prior to use.
Disposal of EHMs is performed in compliance with government regulations and Jefferson Lab policy. Guidelines for proper disposal can be found in EP Supplement EPS-60 Waste and Recyclable Materials Management and EP Supplement EPS-61 Hazardous Waste Management. All hazardous and EHMs (such as oil and ethylene glycol) are handled through the Jefferson Lab Hazardous Waste Coordinator (HWC).
3.8 Spill Prevention Program
EHMs should only be used for the purpose for which they are intended. Using an EHM in any other manner could result in an unexpected release of the material and personnel exposure. Containment measures should be in place to minimize release of the materials, and spill response equipment should be easily accessible.
Employees can minimize the potential for an accidental release by being trained for the specific work situation. Training should include proper use of equipment, how to recognize potential release situations, safety precautions, spill response procerdures, and reporting requirements.
Containers, piping, equipment, and transportation vessels containing EHMs shall be inspected on a regular basis to check for leaks or structural defects.
All Lab staff and subcontractors that work around oil or manage oil are required to take SAF123 Oil Worker Training
3.9 Planned Releases
Planned releases are deliberate and arranged so as to be in compliance with valid permits. Such releases include air emissions of NOx (Nitrous oxides), wastewater discharge to the sanitary sewer, and the discharge of groundwater to surface water. All of these releases need to be addressed under the appropriate regulatory agency.
For new processes or if you expect anything unusual, a review shall be conducted to determine if an EHM can be released to the environment and, if so, in what quantity. The responsible line manager should inform the appropriate Division Safety Officer who will assist the ESH&Q Reporting Manager in applying for special arrangements under the applicable Lab permits.
3.10 Accidental Releases, including those requiring emergency response
Jefferson Lab takes all precautions possible to prevent releases, especially those that could result in an emergency situation. However, when an incident occurs, respond to the incident depending on your level of training and expertise.
3.11 Immediate Response Actions
Per ES&H Manual Chapter 6610 Appendix T7 Clean-Up of Chemical Spills Procedure, an individual discovering an emergency should take the following steps (if you can do so without endangering yourself or others):
3.11.1 Warn others in the area of the hazard.
3.11.2 Evacuate the area as necessary, note the release size and location. Be aware of the wind direction and move up wind of the release. [If in doubt, maintain a minimum distance of 150 feet upwind from the release.]
3.11.3 If there are injuries or immediate off site expertise is needed, call 911.
3.11.4 Call x5822 immediately and provide the following information:
· location of spill
· approximate quantity and identity of chemical or other product.
· other hazards and emergency conditions (traffic or personnel concerns)
3.11.5 If within the Accelerator Site fence, contact the on-duty Crew Chief at ext. 7050.
3.11.6 Notify the respective line manager (or your supervisor if unsure of whom to contact).
3.11.7 Meet the responders at a safe distance from the release and direct them to it. Provide the appropriate MSDS for their use, if possible.
If the spill involves (or is suspected to involve) EHMs – then contact IH x6381
If there might be a radiological concern, notify the RadCon at x7551.
3.12 Release Notification
Releases must be recorded and notification to the Division Safety Officer and Facility Manager Designee (876-1750) should be made and a Notable Event Worksheet (ES&H Manual Chapter 5200 Event Investigation and Causal Analysis Process) completed. The Facility Manager Designee will determine if Thomas Jefferson Site Office (TJSO) notification is required. If so, the TJSO and the Facility Manager will jointly contact the appropriate agency or agency representatives.
Specific regulatory information as well as the site program and procedures are covered in EP Supplement EPS-50 Environmentally Harmful Materials
4.0 Revision Summary
Revision 0.1 – 03/30/11 – Removed reference to Chemical Assistance Team.
REVIEW REQUIRED DATE