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8010
Appendix T1 Communication
Related to Environmental Management |
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1.0
Purpose
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).
2.0
Scope
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 Lab’s 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.)
3.0
Responsibilities
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 your
environmental concerns through your supervisor, Subcontracting
Officer’s Technical Representative (SOTR), sponsor, or Environment, Health, Safety, and Quality (ESH&Q)
Professional.
3.1.2
Supervisor/Subcontracting Officer’s Technical
Representative (SOTR)/Sponsor, Managers, and Division Safety Officers (DSO)
· Direct concerns to your Associate Director, the Director’s 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 Lab’s Director’s 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 Lab’s 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
Lab’s 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
3.3.1 EPCRA
3.3.1.1 Emergency Manager/Fire Protection Engineer
·
Represent Jefferson Lab in the
local emergency planning process.
·
Keep the Newport News Fire
Department informed on chemicals of concern
3.3.1.2 Material Safety Data Sheet (MSDS)
Coordinator
·
Maintain Jefferson Lab’s MSDS library in the on-line MSDS database.
·
Support the ESH&Q
Reporting Manager as needed to fulfill EPCRA reporting requirements.
3.3.1.3 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).
3.3.2
NEPA
3.3.2.1
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)
3.3.3.1
Radiation Control Group Manager
· Coordinate NESHAPs preparation and documentation arrangements in conjunction with the TJSO, the ESH&Q Reporting Manager, and Public Affairs Department.
4.0
Procedure
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 Director’s 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 Lab’s Director’s Safety Council during the annual management review of the EMS. Other communication occurs during regular Director’s 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 Lab’s 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 Director’s Command
Staff, and provides information to all entities in
accordance with DOE and the Jefferson Lab management contractor’s policy. This includes any information disseminated to
news media/journalists.
4.4
Public
Reading Area Coordination
4.4.1
NEPA
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
Lab’s 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.
·
A Radiation
Control Group procedure describes how the NESHAPs program is managed.
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 3220 Communication of Hazards to Employees and
Users
ES&H Manual 8010 Appendix T2 Emergency
Planning and Community Right-to-Know
ES&H Manual Chapter 8011 Environmental
Monitoring Program
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
EPS
50-T1 Spill and Release Reporting Requirements
Web sites:
EPA www.epa.gov
CFR http://www.gpoaccess.gov/cfr/index.html
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ISSUING
AUTHORITY |
TECHNICAL POINT-OF-CONTACT |
APPROVAL
DATE |
REVIEW
REQUIRED DATE |
REV. |
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ESH&Q Division |
12/09/09 |
12/09/12 |
0 |
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