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

2. 2 Outline 1.Consultation Services 2.NEPA Review 3.Safety Assessment Document 4.Construction Safety Surveillance 5.Readiness Review 6.Lessons Learned

3. 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. 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. 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 No A 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 No A.

6. 6 2. NEPA  Start Early!  “Connected Actions”, i.e., NSF/DUSEL-Homestake need planning NuMI and No A 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. 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. 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. 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. 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. 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. 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 13

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 14

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 15

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 16

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 17

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 18

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) 19

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 20

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 21

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. 22

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! 23