The NuMI ES&H Experience with Application to DUSEL

1. The NuMI ES&H Experience with Application to DUSEL Don Cossairt & Mike Andrews September 22, 2008

2. Outline • Consultation Services • NEPA Review • Safety Assessment Document • Construction Safety Surveillance • Readiness Review • Lessons Learned

3. 1. Consultation Services • ES&H Section regularly provides consultations. • Present program usually works well for the following topics: • Fire protection/life safety • Radiation safety • Environmental protection • Industrial hygiene • Waste management/minimization • Construction safety • Now have much more experience with underground safety drawn from NuMI

4. 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 permits • Be prepared for extensive DOE scrutiny • Project 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

5. 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 NonA 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 NonA.

6. 2. NEPA • Start Early! • “Connected Actions”, i.e., NSF/DUSEL-Homestake need planning • NuMI and NonA both had such “connected actions”. • DOE cannot “make” other entities/agencies move along! • Early involvement of DOE crucial • Difficulty: 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

7. 2. NEPA • The Writing • EA’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 inputs • Writing 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” references • Avoid too many url’s that we don’t control (and may disappear!)

8. 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 well • Be prepared for more interest in the “post-tritium” era

9. 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 assessment • Result should dovetail with NEPA document • Use as tool to address problems as they are identified rather than in an “ad hoc” way later

10. 3. Safety Assessment Review • Lessons-Learned from NuMI • NuMI started early, tracked work throughout project life • Involve DOE from the beginning, this helped with NuMI • Need to use as a real tool, not just as a task to complete • NuMI created a website as a “virtual library” of reference documents • Helped keep SAD document short, readable • Allowed for revisions to references without changing the document as work proceeded • But, need to maintain for later reference

11. 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 incorporation • Construction worker safety compliance including worker training • Adequate safety during any "beneficial occupancy"

12. 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

13. 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

14. 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

15. 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

16. 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

17. 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

18. 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

19. 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)

20. 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

21. 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

22. 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.

23. 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!