8010 Appendix T1
Communication Related to Environmental Management
This procedure ensures that all internal and external communications of environmentally related information are performed consistently at Jefferson Lab and that external communications involve interface with the Thomas Jefferson Site Office (TJSO).
This procedure applies to all internal and external (including National Environmental Policy Act (NEPA) and Emergency Planning and Community Right-to-Know Act (EPCRA)) communications regarding Jefferson Labís Environmental Protection Program, its Environmental Management System (EMS), and other environmental issues as covered in the overarching Jefferson Lab EMS Plan.
This procedure is reviewed and updated as called out in ES&H Manual Chapter 1300 Content Review Policy.† (For EMS-specific information, see Section 5.5.1 of EMP-07 in the Environmental Protection Supplement.)
ES&H Manual Chapter 8010 Environmental Protection Program summarizes environmental protection responsibilities.† The following responsibilities apply specifically to goals and objectives involving internal and external communication related to environmental concerns.
3.1 Internal Communications
3.1.1 Everyone at Jefferson Lab
∑ Direct concerns to your Associate Director, the Directorís Safety Council, the EMS Committee, or to other Jefferson Lab departments, or resources outside of Jefferson Lab, before responding.
∑ Communicate environmental information to employees as necessary through regular department meetings, e-mails, memos, or other means of correspondence.
3.1.3 EMS Management Representative
∑ Communicate environmental issues to Jefferson Labís Directorís Council on at least an annual basis.
3.1.4 Public Affairs Department
∑ Assist as needed in helping to develop and review environmental messages, and advise on and assist with the distribution of these messages.
3.2 External Communications
3.2.1 Jefferson Lab Director,
∑ Through the ESH&Q Division, prepares and approves external communications.
∑ Provides external communications to the TJSO Manager.
3.2.2 Thomas Jefferson Site Office (TJSO) Manager
∑ Sign environmentally related external correspondence and permit applications.†
∑ In conjunction with Jefferson Labís ESH&Q Associate Director, respond to environmentally related queries from regulatory agencies.
3.2.3 Public Affairs Department
∑ Respond to environmentally related queries from the public, and if necessary, passes those queries on to the ESH&Q Associate Director and/or the EMS Committee for internal review, and logging public queries.
∑ In conjunction with the ESH&Q Reporting Manager (or ESH&Q Professional), maintain a public reading area in CEBAF Center and a virtual public reading area on Jefferson Labís visitor web site.
3.2.4 ESH&Q Associate Director
∑ Coordinate responses to requests for environmentally related communications for submittal to the Laboratory Director.
3.2.5 ESH&Q Professionals
∑ Support the ESH&Q Associate Director to address any ESH&Q topic or concern received from the Department of Energy (DOE) or regulatory agency.
3.3 Regulatory Reporting Specifics
∑ Represent Jefferson Lab in the local emergency planning process.
∑ Keep the Newport News Fire Department informed on chemicals of concern
∑ Support the ESH&Q Reporting Manager as needed to fulfill EPCRA reporting requirements.
220.127.116.11 ESH&Q Reporting Manager
∑ Ensure all EPCRA notification and reporting requirements are met.
∑ Work with the Emergency Management (EM) to provide additional requested information to exercise planning groups (EPGs).
18.104.22.168 ESH&Q Division Environmental Engineer
∑ Coordinate NEPA preparation and documentation arrangements in conjunction with the TJSO and Public Affairs Department.
3.3.3 National Emission Standards for Hazardous Air Pollutants (NESHAPs)
22.214.171.124 Radiation Control Group Manager
∑ Coordinate NESHAPs preparation and documentation arrangements in conjunction with the TJSO, the ESH&Q Reporting Manager, and Public Affairs Department.
4.1 Internal Communications Flow
∑ Jefferson Lab communicates information about hazards, including environmental issues, in ES&H Manual Chapters 3220 Communication of Hazards to Employees and Users and ES&H Manual Chapter 1400 Communicating Safety to Visitors.
∑ Everyone at Jefferson Lab communicates their environmentally related concern or idea through their supervisor, SOTR, or sponsor and then with ESH&Q Professionals, or the ESH&Q Division.† It is understood that, in the event of an emergency or potential emergency situation, employees first make notifications for on and offsite response as trained.
∑ If the supervisor, SOTR, or sponsor is capable of addressing the concern(s), he/she does so.† If not, they contact: their DSO or Associate Director, the Directorís Safety Council, the EMS Committee, or other resources such as the ESH&Q Reporting Manager, or external contacts, for guidance before responding.
∑ During regular department meetings, supervisors and managers communicate any necessary environmental information to their employees.
∑ Other internal, general-information communication modes at Jefferson Lab include newsletters, posters, memos, and other means of communication.
∑ For internal communications meant to be distributed across the Jefferson Lab complex, those responsible for generating messages to be communicated advise the Public Affairs Department in advance of dissemination of these messages.
∑ At a minimum, the Jefferson Lab EMS Management Representative communicates environmental issues to Jefferson Labís Directorís Safety Council during the annual management review of the EMS.† Other communication occurs during regular Directorís Safety Council meetings as needs arise.
4.2 External Communications
∑ Generally consists of permit applications and required submissions to regulatory agencies, inquiries from regulatory agencies, or queries from the general public.
∑ Environmental queries from the general public are directed to the Public Affairs Department.†
o Receipt of the query is documented in a log.†
o Input is requested from the ESH&Q Reporting Manager before a response is submitted.
o Copies of all correspondence are kept on file, including responses.†
∑ The ESH&Q Reporting Manager and the Public Affairs Department agree upon EMS information available to the public.
o The Jefferson Lab website, the public reading area, and news releases, are used as required.†
o EMS information is published in Jefferson Labís annual site environmental report and other public environmental documents.†
o Public Affairs Department provides the final review before any information is released to the public.
∑ All non-radiological and most radiological communications are normally handled or reviewed by the ESH&Q Reporting Manager, via the TJSO.† This includes, but is not limited to, permitting and other regulatory activities, monitoring, and reporting.
∑ Miscellaneous radiological communication involving non-regulatory issues is normally handled by the Radiation Control Department through the TJSO after review by the ESH&Q Reporting Manager.
4.3 Regulatory Communications†
∑ The ESH&Q Reporting Manager, using ESH&Q Professionals as a resource, assists the EMS Management Representative in responding to regulatory agency concerns and inspections regarding environmental issues and/or the EMS and maintains copies of any communication records.† Note: all communication involving regulatory agencies is handled through interface with the TJSO.
4.3.1 Environmentally Related Mishap Response Communications:
∑ In the event of a mishap, interaction with employees and/or the public is defined in Emergency Management Plan and its appendices.
∑ Requirements for communications with DOE and other regulatory agencies in the event of a mishap are described in the EPS 50-T1 Spill and Release Reporting Requirements.
∑ The Public Affairs Department clears all public releases of information about the mishap with the Jefferson Lab Facility Manager.
∑ As necessary, the Jefferson Lab Facility Manager coordinates news releases with the DOE.
∑ The Public Affairs Department, serves in support of the Directorís Command Staff, and provides information to all entities in accordance with DOE and the Jefferson Lab management contractorís policy.† This includes any information disseminated to news media/journalists.
4.4 Public Reading Area Coordination
The Public Reading Area for Jefferson Lab NEPA documents, i.e. Environmental Impact Statements, is in the main lobby of CEBAF Center (Building 12).
Paper copies of required documents reside on the Jefferson Lab ES&H Manual podium shelf adjacent to the CEBAF Center main entrance and reception desk.† Tables and chairs and good lighting in the area provide a good environment for reading such documents.† This arrangement allows Public Affairs to keep copies of required documents readily available for public perusal.† And Public Affairs is close by and readily available to handle any public queries that might arise.
Also, the Public Affairs Department has a virtual Jefferson Lab public reading area on Jefferson Labís website.† In coordination with the ESH&Q Division, a Public Reading Area link on the Visitor Center web page and the ESH&Q Links web page holds pdf versions of required documentation, so people with Internet connectivity can access specified documentation electronically.
∑ Main Location of Virtual Reading Area link:† http://www.jlab.org/visitors/Secondary
∑ Location of Virtual Reading Area link:† http://www.jlab.org/ehs/links.html
4.5 Other Programs
Other documents identified to be added to the Public Reading Area are managed same as shown under the above NEPA section.
4.6 Other Regulatory/Public Information Coordination
The provision of other information to regulatory agencies or to the public, including that through the non-NEPA TJSO, such as the annual Site Environmental Report, is described under the External Communication flow section above.
∑ ES&H Manual 8010 Appendix T2 Emergency Planning and Community Right-to-Know provides the Lab's EPCRA program and how Jefferson Lab interacts with this regulation.
5.0 Records and Associated Documentation
The digital version of this document resides with other EMPs on DocuShare.† The original-signature paper copy resides in the ESH&Q Division's EMS records library.
The external communications log and copies of environmental query responses, correspondence and messages publicly released also reside in the 3-ring binder with the working copy of this appendix in the Public Affairs Manager's office.
Paper copies of Jefferson Lab publications on environmental actions, activities or impacts meant for public comment (i.e. current annual site environmental report, NEPA documents such as environmental assessments and environmental impact statements) are kept at the ES&H Manual podium at the CEBAF Center reception desk for public perusal.
6.0 Associated Documentation
ES&H Manual Chapter 1400 Communicating Safety to Visitors and appendices
ES&H Manual Chapter 5300 Occurrence Reporting and appendices
ES&H Manual Chapter 6610 Chemical Hygiene Program and appendices
ES&H Manual Chapter 8050 Environmentally Harmful Materials and appendices
REVIEW REQUIRED DATE