Environmental, Safety and Health Directives Applicable to Facility Disposition Activities cont'd

DOE-STD-1120-2005/Vol. 2

ENVIRONMENT, SAFETY, AND HEALTH DIRECTIVES APPLICABLE TO FACILITY

DISPOSITION ACTIVITIES

As directed by DOE P 450.2A, Identifying, Implementing and Complying with Environment, Safety and

Health Requirements, and 48 CFR 970.5204-78 (DEAR clause on laws, regulations, and DOE directives),

information resulting from planning and hazard identification activities should be used to determine the

set of ES&H directives applicable to a facility disposition and environmental restoration project.

Applicable requirements should be conveyed within project plans, which are required for disposition

projects in accordance with DOE 430.1B, Real Property Asset Management.

This appendix provides a compilation of ES&H requirements that are potentially applicable to facility

disposition and environmental restoration projects. Candidate requirements are considered from DOE

regulations and directives, and Occupational Safety and Health Administration (OSHA) and

Environmental Protection Agency (EPA) regulations. This compilation will assist DOE project

managers, contractors, and subcontractors in identifying the applicable ES&H requirements that must be

considered to ensure the protection of workers, the public, and the environment during facility disposition

and environmental restoration activities. This Appendix may be a source of input for determining

Applicable or Relevant and Appropriate Requirements (ARARs) for projects subject to the CERCLA

process (note: it should not be considered an exhaustive list of all possible potential ARARs).

Additionally, RCRA corrective actions may be underway at facilities undergoing environmental

restoration activities and, in some cases, both statutes may be applicable. Appendix A may also be used

as a tool to help in tailoring specific requirements such as those uses in Work Smart Standards or similar

other approaches.

Table A-1 lists mandatory and nonmandatory ES&H directives and briefly summarizes the intent for each

directive. This list is not intended to represent the set of directives that should be applied to all

disposition and environmental restoration activities. The specific directives applicable to a facility or

work activity depend upon the facility's or activity's work scope and associated hazards. For example,

the set of directives applicable to deactivating a plutonium processing facility may differ entirely from the

set for decommissioning a guard house containing asbestos.

As shown in Figure A-1, the list of directives is organized by type of hazard. This is intended to facilitate

the identification of hazard-specific requirements. For example, if the work involves interaction with lead

and radiological materials, the table provides reference(s) to the specific directive(s) that need to be

considered for each of these hazards. Directives that are not strictly driven by hazard type are identified

as "crosscutting" directives, which are applicable regardless of the hazards and work scope.

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