The NuMI ES&H Experience with Application to DUSEL

Don Cossairt & Mike Andrews

September 22, 2008

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Outline

1. Consultation Services

2. NEPA Review

3. Safety Assessment Document

4. Construction Safety Surveillance

5. Readiness Review

6. Lessons Learned

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1. Consultation Services ES&H Section regularly provides consultations. Present program usually works well for the following

topics:Fire protection/life safetyRadiation safety Environmental protection Industrial hygieneWaste management/minimization Construction safetyNow have much more experience with underground

safety drawn from NuMI

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1. Consultation Services Tips for success

Use the services available and external resources with experience at Fermilab and elsewhere - Don’t “reinvent the wheel”

Early hazard assessment (combines with safety assessment process)

Identify early needed environmental permitsBe prepared for extensive DOE scrutinyProject management requirements result in a separate

structure - Don’t let the project isolate from Fermilab ES&H personnel in both ES&H Section and affected line organizations

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2. NEPA NEPA = National Environmental Policy Act - Related

policies are in FESHM 8060. NuMI had an Environmental Assessment (EA).

An EA either results in a Finding of No Significant Impact (FONSI) or

A decision to prepare an Environmental Impact Statement (EIS) EA’s & EIS’s are DOE, not Fermilab, documents. NuMI and NoA had EAs/FONSIs, the likely and desired,

but not guaranteed, outcome for DUSEL. Directorate/FSO initiating work to improve NEPA process;

we can do better than with NoA.

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2. NEPA Start Early!

“Connected Actions”, i.e., NSF/DUSEL-Homestake need planningNuMI and NoA both had such “connected actions”.DOE cannot “make” other entities/agencies move along!

Early involvement of DOE crucialDifficulty: Starting “early” means project details not completely

formulated E.g., NuMI EA speaks of two on-site experimental halls, one for the

cancelled COSMOS experiment!Perhaps early citizen involvement needed – Office of

Communications discussing the creation of a new task force to give input

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2. NEPA The WritingEA’s are written in “NEPA-ese”.

A special “conditional” style sometimes difficult for project enthusiasts to adopt!

EA’s are “decisional”, they document a choice.

EAs are large documents, with many inputsWriting team leader should have experience with NEPA documents, there

is a “learning curve”Good “quality control” on content is needed“Patience” is needed with seemingly endless iterations – strongly suggest

“author-date” referencesAvoid too many url’s that we don’t control (and may disappear!)

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2. NEPA The Review of the EA

There will be several interactions with DOE and perhaps NSF for DUSEL.

The “connected action” with NSF, another Federal agency is an unknown – Who leads?

Be prepared for “public involvement”Will be reviewed by regulatory agencies

With NuMI, met with state regulators, worked wellBe prepared for more interest in the “post-tritium” era

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3. Safety Assessment Document Provisions are found in FESHM 2010

Includes radiation shielding assessment/radiological design features

The DUSEL SAD must be reviewed by: Relevant line organization(s) ES&H Section Director Concurrence by DOE-FAO Often have some back-and-forth

with drafts, etc. DUSEL will require a Preliminary SAD (PSAD)

Good place to do initial hazard assessmentResult should dovetail with NEPA document Use as tool to address problems as they are identified rather than

in an “ad hoc” way later

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3. Safety Assessment Review Lessons-Learned from NuMI

NuMI started early, tracked work throughout project life Involve DOE from the beginning, this helped with NuMINeed to use as a real tool, not just as a task to completeNuMI created a website as a “virtual library” of reference

documentsHelped keep SAD document short, readableAllowed for revisions to references without changing the

document as work proceededBut, need to maintain for later reference

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4. Construction Safety Surveillance Done by ES&H or line organizations Complements FESS civil engineering supervision “High profile” to DOE Likely one or more FTEs, based on NuMI Monitor to assure:

Adequate environmental protection features including any permit compliance matters

Radiation shielding meeting specifications Fire protection design features incorporationConstruction worker safety compliance including worker

trainingAdequate safety during any "beneficial occupancy"

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5. Readiness Review

Projects with SADs require accompanying formal readiness reviews

Led by ES&H with special teams appointed, tailored to the project

Line organization(s) participate, this is crucial. DOE-FSO will be included Required before routine operations

ESH Lessons Learned• Three Phases of NuMI

– Tunnels and Halls• Sub-Contractor did not understand ESH Goals• Not enough structured ESH Oversight to promote

the ESH Program for the Sub-Contractor, Project, or Lab

– Service Buildings and Outfitting• Sub-Contractor Understood the Goals but had

lapses.

– Component Installation• Got it plus

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ESH Lessons Learned

• ESH Contractual Wording– Need to specify ESH expectations clearly

• Sub-Contractor Bid Selection Process– Review of ESH Manual and Project ISM Plan– Review of 3 yrs of OSHA Accident Rate – Review of 3 yrs Workers Comp History– 5 yrs disclosure of any serious accidents & OSHA

violations– Resumes & References for Project Manager,

Superintendent, and ESH Manager

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ESH Lessons Learned• ESH Oversight Responsibilities Defined

from Start– Sub-Contractors

• Project Manager• Superintendent, Foremen• ESH Manager

– NuMI Project• Project Manager• Construction Project Manager• Construction Coordinator• Project ESH Coordinator• Field Safety Coordinator 15

ESH Lessons Learned• Fermilab ESH Section Oversight

– Safety Inspector– Directorate– FNAL Board of Overseers– Director Review Committee

• DOE– FNAL Area Office– DOE Project Reviews– Independent Investigations-Type A

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ESH Lessons Learned

• Sub-Contractor ESH Program– Comprehensive ESH program needs to be in

place at start construction– ESH Program needs to been fully

implemented on all levels from the start– Responsibility for ESH needs to be

understood on all management levels– ESH Manager needs to provide proactive

support to both management and workforce

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ESH Lessons Learned

• Workforce Communication equals ISM– Provide Task and ESH Training

• ESH Orientation Training including HA Program• Hazard Specific Training (LOTO, PPE, Etc.)• New Employee Task Orientation with Foremen

– Daily Work Planning & Safety Huddle– Implement Hazard Analysis Program– Safety Stand downs for Accident Review– Make them aware of the ESH Expectations

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ESH Lessons Learned

• Management Communication Equals ISM– Daily Project Construction Management

Meeting– Weekly Sub-Contractor and Project

Management Meetings– Daily Communication Between Sub-Contractor

and Project ESH Personnel– Significant ESH Field Presents for all levels of

Management (Sub-Contractor, Project, DOE)

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ESH Lessons Learned

• ESH Performance Measurements– Tunnel Workers are a High Risk Occupation– Very Labor Intensive– Fermilab Accident Goal Very Aggressive– OSHA Incident Rates for Tunneling & Heavy

Construction are not goals but reality and much higher than FNAL goals

– Need to promote a zero tolerance BUT…need to be realistic

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ESH Lessons Learned

• Environmental– Water permitting well thought out– Mining Permit vs. No Mining Permit– Water Treatment

• Sub-Contractor management

– Concrete Washouts– Spills (Oil, Glycol)– Site Erosion Control– Need for Sub-Contractor Environmental Expert

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ESH Lessons Learned

• Radiation Safety– PSAD, Shielding Assessment, SAD

• Tritium Generation• Hydrogen Embrittlement

– Remote Handling Procedure & Repairs– Water & Air Emissions– Maintenance of RAW systems– Storage of Hot Targets, Horns Strip lines, etc.

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ESH Lessons Learned

• Conclusions– Starting with the pre-bid meetings be CLEAR

on the ESH expectations– Meet with the workforce and explain the

Project and the need to work safely and that we REALLY mean it! Workforce Buy In.

– ESH incentives on all workforce levels do work and help to promote working Safely!

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