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Chapter 11 – Environmental Protection

Published on by Heather Madison.

Contents

Approved by Ron Pauer
Revised 04/21

11.1 Policy
11.2 Scope
11.3  Program Descriptions

11.4 Support Organizations
11.5 Responsible Parties

11.6 Glossary
11.7 Standards

11.8  Related LBNL/ES&H Manual Chapters
11.9  References

Note:
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11.1 Policy

It is the Laboratory’s environmental policy to perform work in a manner that protects the health of the public and preserves the quality of the environment. The Laboratory is committed to:

  • complying with all applicable laws, regulations and requirements,
  • preventing pollution, minimizing waste, and conserving natural resources,
  • correcting environmental hazards and cleaning up existing environmental problems, and
  • continually improving the Laboratory’s environmental performance while maintaining operational capability and sustaining the overall mission of the Laboratory.

11.2 Scope

The Berkeley Lab environmental protection programs are designed to reduce the Laboratory’s impacts on air, water, soil, and other environmental media and to conserve natural resources.  Many of these programs are managed by the Environmental Services Group (ESG), including:

  • Accidental releases
  • Air emissions
  • Environmental Management System
  • Environmental radiological dose assessment
  • Environmental monitoring
  • Hazardous wastewater treatment units
  • Petroleum products storage
  • Sanitary sewer discharges
  • Storm water discharges
  • Underground storage tanks
  • Waste Minimization and Pollution Prevention

11.3 Program Description

11.3.1 Accidental Releases

This program has been moved to Chapter 51 Environmental Releases.

11.3.2 Air Emissions

This program has been moved to Chapter 49 Air Quality.

đźš©11.3.3 Environmental Management System

DOE Order 436.1, Departmental Sustainability, requires that DOE contractors develop and implement an EMS that conforms to the ISO 14001 Standard, and that the EMS incorporate the organization’s site sustainability goals. DOE issued guidance in October 2016 on annual reporting and external audits/declaration of conformance of an EMS to the current version of ISO 14001. An EMS is simply a strategic framework for ensuring environmental compliance and achieving federal sustainability goals.

LBNL maintains a risk- and performance-based EMS is designed to ensure that Berkeley Lab activities reduce environmental impacts and are well managed, cost-effective, and compliant with environmental regulations. The EMS strives for continual improvement in environmental performance through the four-step “Plan-Do-Check-Act” framework for management systems.

The key elements of this framework are:

  • Plan – leadership commitment and the Environmental Policy; identifying environmental aspects with opportunities for improvement and potential unacceptable risks; developing environmental action plans for these significant environmental aspects
  • Do – resources; competence; training; communication; documentation
  • Check – monitoring; measurement and analyses; evaluation of compliance including internal and external audits; management review
  • Act – addressing nonconformance and corrective actions; continual improvement

A cross-functional Core Team and subject matter experts participate in the evaluation of environmental aspects and develop objectives and targets for significant aspects. The Core Team then prepares, coordinates, and monitors the process of Environmental Action Plans to address significant environmental aspects.

Internal assessments and external audits are important to evaluating the effectiveness of LBNL’s EMS; they are also required elements of ISO 14001. The EMS program is audited at specified frequencies by the Lab’s Office of Contract Assurance to determine if all programmatic activities have been completed and to determine the effectiveness of the program. A third party audit is also performed every three years to verify the EMS conforms to the current version of ISO 14001 as required by the 2016 DOE guidance letter. In addition, progress in achieving EMS objectives and targets and the results of EMS internal and external audits are reviewed annually by a Laboratory management team for feedback.

The sustainability elements required by DOE Order 436.1 and ISO 14001 are implemented at Berkeley Labs by the Sustainable Berkeley Labs Team, led by the Chief Sustainability Officer. Sustainability activities are described in the Site Sustainability Plan. This ES&H Manual chapter focuses on the regulatory compliance elements of DOE Order 436.1 and ISO 1400. 🛑

More information on Berkeley Lab’s Environmental Management System can be found at the ESG Web site.

11.3.4 Environmental Radiological Dose Assessment

This program has been moved to Chapter 50 Environmental Radiological Protection Program.

11.3.5 Environmental Monitoring

This program has been moved to Chapter 62 Environmental Monitoring.

11.3.6 Contaminated Vegetation Management

This program has been moved to Chapter 59 Vegetation Sampling and Management.

11.3.7 Contaminated Soil and Groundwater Management

This program has been moved to Chapter 61 Soil and Groundwater Management.

11.3.8 Hazardous Wastewater Treatment Units

This program has been moved to Chapter 53 Fixed Treatment Units.

11.3.9 Petroleum Products Storage

This program has been moved to Chapter 56 Spill Prevention, Control, and Countermeasures Program.

11.3.10 Polychlorinated Biphenyls (PCBs) Management

This program has been moved to Chapter 63 Polychlorinated Biphenyl (PCB) Management

11.3.11 Sanitary Sewer Discharges

This program has been moved to Chapter 55 Sanitary Sewer Program.

11.3.12 Storm Water Discharges

This program has been moved to Chapter 57 Storm Water Pollution Prevention

11.3.13 Underground Storage Tanks

This program has been moved to Chapter 58 Underground Storage Tanks.

11.3.14 Waste Minimization and Pollution Prevention

LBNL is required by the US Environmental Protection Agency, the California Environmental Protection Agency, and the US Department of Energy to reduce the generation of hazardous, non-hazardous, and radioactive wastes; prevent pollution of air, water and land; and conserve energy, water and natural resources.

Under DOE Order 450.1A, Environmental Protection Program and DOE Order 430.1B, Departmental Energy, Renewable Energy and Transportation Management, DOE requires LBNL to meet goals with objectives and measurable targets that accomplish the following:

  • Reduce or eliminate the generation and/or toxicity of waste and other pollutants at the source through pollution prevention
  • Reduce or eliminate the acquisition, use, and release of toxic and hazardous chemicals and materials
  • Maximize the acquisition and use of environmentally-preferable products and services in the conduct of operations
  • Reduce or eliminate the environmental impacts of electronic assets
  • Reduce degradation and depletion of environmental resources through post- consumer material recycling
  • Develop environmental, energy, and transportation measures that contribute to sustainable practices

Waste minimization and pollution prevention are implemented site-wide by all staff at LBNL in accordance with the environmental policy stated earlier in this chapter. Strategies, measures development, and implementation guidance on waste minimization is provided through the Waste Management Group with the Environmental Services Group providing similar support on pollution prevention.

Waste minimization and pollution prevention strategies and measures help reduce the environmental impact of LBNL research and operational activities, as well as reduce the burden of compliance with environmental regulations. Waste minimization and pollution prevention strategies and measures may include performing pollution prevention opportunity assessments and life-cycle cost analyses. Failure to minimize waste and prevent pollution can increase exposures to hazards and toxic chemicals in the workplace, increase liabilities under federal and state laws and regulations, and increase costs associated with air pollution control, wastewater treatment, waste generation, waste disposal, and site remediation.

As part of its Environmental Management System, LBNL is committed to integrating waste minimization, pollution prevention, resource conservation, and environmental compliance into all planning and decision-making and applying cost-effective practices to eliminate, minimize, or mitigate environmental impacts.

Waste minimization and pollution prevention concerns can be reasonably addressed as follows:

  • Develop good practices for routine day-to-day activities that can have an environmental impact (e.g., turning off lights and electronic equipment to save energy, shutting faucets to conserve water, recycling paper and cardboard products).
  • For large quantities of non-hazardous waste and recyclable materials, plan ahead and work with the Facilities Department and Property Management to obtain adequately sized containers for disposal of waste and proper management of recyclable materials that are under their control.
  • If procuring products or services, your Purchasing and ESG can assist in the identification of environmentally-preferable products and services.
  • If generating hazardous or radioactive wastes, plan ahead and work with WMG to develop the best measures for handling and minimizing these wastes.
  • If involved in construction and building projects, plan ahead to develop sustainable designs and identify environmentally-preferable products and subcontract services.

Additional information on waste reduction and pollution prevention measures are found on the ESG and WMG web sites.

11.4 Support Organizations

  • Facilities Division
  • Engineering Division

11.5 Responsible Parties

11.5.1 Principal Investigators and Supervisors

  • Ensure that environmental laws, regulations, and policies are followed.
  • Request assistance from the Environmental Services Group for technical advice on what environmental requirements apply to their operations and what would be an appropriate compliance strategy.
  • Provide training for employees in operational requirements pertaining to environmental protection, and maintain records of such training.
  • Ensure that activities are performed within acceptable operating standards and that any required records are current.
  • Notify the EH&S Division immediately of any unplanned accidental releases or spills.

11.5.2 Employees

  • Follow applicable environmental laws, regulations, and policies.
  • Be fully aware of the environmental impact of their activities, and comply with all requirements that govern those activities.
  • Adhere to all environmental requirements contained in operating permits.
  • Perform activities within acceptable operating standards, and maintain current records whenever required.
  • Ensure that exposures of the public and the environment to radioactive emissions are kept as low as reasonably achievable.
  • Participate in energy conservation, recycling, pollution-prevention, and waste minimization programs.
  • Take immediate action to stop unplanned releases to the environment, and report all instances of unplanned environmental releases to the EH&S Division.
  • Complete all required training provided by supervisors and the EH&S Division.

11.5.3 Environmental Services Group

  • Develops Laboratory policies and procedures to assure that operations are conducted in an environmentally safe manner and in full compliance with all applicable environmental laws and regulations and DOE orders.
  • Prepares environmental compliance plans and reports as mandated by laws and regulations and DOE orders.
  • Assesses current and planned Berkeley Lab programs, and assists in defining environmental protection compliance upgrades and corrective actions.
  • Identifies significant institutional environmental compliance issues, and develops cost-effective mechanisms for resolving them.
  • Performs environmental dose assessments to document that radiation doses to the public and environment are maintained well below the applicable standards and regulations. 
  • Prepares budget requests for, and manages, environmental protection upgrades and corrective actions for institutional projects.
  • Provides training, makes presentations, and participates in discussions regarding environmental protection matters with Berkeley Lab employees, regulatory agencies, concerned public citizens, community organizations, and the media.
  • Manages the preparation of environmental operating permit applications.
  • Curtails or suspends any operations that pose an immediate danger to members of the public or the environment.
  • Monitors laboratory emissions and discharges to the environment to verify compliance with applicable regulations and permits.
  • Investigates reports of unplanned environmental releases, and notifies federal, state, and local authorities in a timely manner, as required.
  • Coordinates and represents Berkeley Lab activities during environmental audits and inspections by regulatory agencies and DOE.
  • Responds to information requests from the public.
  • Participates in DOE audits of off-site analytical laboratories to ensure the quality of analytical results received for environmental monitoring programs.

11.6 Glossary

Acutely hazardous wastes are any wastes defined as acutely hazardous by 22 CCR, Division 4.5, Chapter 11, Article 4.

As low as reasonably achievable (ALARA) is an approach to radiological management and control that aims to keep exposures (individual and collective) to the general public and the environment at levels as low as is reasonable, taking into account social, technical, economic, practical, and public policy considerations. As used in this manual, ALARA is not a dose limit but a process that has the objective of attaining doses as far below the applicable controlling limits as is reasonably achievable.

Bay Area Air Quality Management District (BAAQMD) is the local agency responsible for regulating stationary sources of regulated or hazardous air pollutants in the San Francisco Bay Area.

Department of Toxic Substances Control (DTSC) is a Department within the California Environmental Protection Agency that regulates hazardous waste management and remedial actions.

East Bay Municipal Utility District (EBMUD) is the local municipal wastewater treatment

facility that accepts and regulates sanitary sewer discharges from Berkeley Lab.

Effluent is any treated or untreated liquid discharge from Berkeley Lab or from a Laboratory facility.

Emission is any filtered or unfiltered substance released to the air from Berkeley Lab or from a Laboratory facility.

Environmental monitoring is the collection and analysis of environmental samples or direct measurements of environmental media.  Environmental monitoring consists of three major activities:  effluent monitoring, environmental surveillance, and meteorological monitoring.

Environmental surveillance is the collection and analysis of samples, or direct measurements of air, water, soil, foodstuff, biota, and other media from Berkeley Lab and its environs, for the purpose of determining compliance with applicable standards and permit requirements, assessing radiation exposures of members of the public, and assessing the effects, if any, on the local environment.

Environmental occurrence is any sudden or sustained deviation from a regulated or planned performance at an operation that has environmental protection and compliance significance.

Environmentally-preferable products, and services are goods and services that have a lesser or reduced effect on human health and the environment when compared with other goods and services that serve the same purpose.

Extremely hazardous waste is any hazardous waste or mixture of hazardous wastes that, if human exposure should occur, may result in death, disabling personal injury, or serious illness because of its quantity, concentration, or chemical characteristics (22 CCR Section 66261.110).

Hazardous air pollutant is any pollutant that is listed in Section 112(b) of the Clean Air Act.

Hazardous wastes are wastes exhibiting any of the following characteristics:  ignitability, corrosivity, reactivity, and toxicity.  In addition, EPA has listed specific wastes as hazardous that do not necessarily exhibit these characteristics.

Life-cycle cost analysis is a procurement evaluation technique that determines the total cost of acquisition, operation, maintenance, and disposal of items being acquired.

Pollution prevention is reducing or eliminating waste at the source by modifying production processes, promoting the use of non-toxic or less-toxic substances, implementing conservation techniques, and re-using materials rather than putting them into the waste stream.

Pollution prevention opportunity assessment is a systematic, structured appraisal of a process, activity, or operation to identify and evaluate potential activities that will eliminate or reduce waste, conserve natural resources, reduce toxic chemical or hazardous material use, and recycle materials

Public Owned Treatment Works (POTW) is a general term used for sewage treatment plants.  The East Bay Municipal Utility District plant is the POTW that accepts sewage from Berkeley Lab.

Radionuclide is a natural or manmade atom that spontaneously undergoes radioactive decay.

Regulated air pollutants are pollutants for which standards have been promulgated under the authority of the Clean Air Act, and include the classes of substances defined as nitrogen oxides, volatile organic compounds, toxic air contaminants, or ozone-depleting substances.

State Water Resources Control Board (SWRCB) is the agency responsible for promulgating the California General Permit for Storm Water Discharge Associated With Industrial Activities.  At Berkeley Lab, this permit is administered and enforced by the San Francisco Regional Water Quality Control Board, with assistance from the City of Berkeley.

Sustainable design means taking a systems approach to design and construction for facilities, systems, and equipment that ensures consideration of the optimization of ecological and human issues in light of acceptable economic constraints. Considerations include measures such as optimizing site potential, minimizing energy consumption, protecting and conserving water, using environmentally preferable products, and services, enhancing indoor environmental quality, and optimizing operational and maintenance practices.

Underground storage tank (UST) is a stationary device designed to contain an accumulation of hazardous material or waste.  A tank is constructed primarily of nonearthen material, but the entire surface area of the tank is totally below the surface of, and covered by, the ground.

United States Environmental Protection Agency is a federal agency responsible for enforcing environmental laws.  In California, some of this responsibility is typically delegated to state and local regulatory agencies.

Waste minimization is defined by the US EPA as measures that reduce the volume and toxicity of hazardous waste disposed to landfills. California defines waste minimization as measures that reduce, eliminate, or recycle hazardous waste at the point in a process where such waste may be generated.

11.7 Standards

11.7.1 Federal

  • Office of Management and Budget, Circular A-106, Pollution Abatement
  • 40 CFR, Part 61, Subpart H, National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities
  • 40 CFR, Part 112, Oil Pollution Prevention
  • 40 CFR, Part 122, Federal Storm Water Discharge Requirements
  • 40 CFR, Part 136, Guidelines Establishing Test Procedures for the Analysis of Pollutants (under the Clean Water Act)
  • 40 CFR, Part 141, Safe Drinking Water Act
  • 40 CFR Part 247, Comprehensive Procurement Guideline for Products Containing Recovered Materials
  • 40 CFR, Parts 260-272, Resource Conservation and Recovery Act (Hazardous Waste Regulations)
  • 40 CFR Part 370, Hazardous Chemical Reporting: Community Right-to-Know
  • 40 CFR Part 372 Toxic Chemical Release Reporting: Community Right-to-Know
  • 40 CFR, Part 403, Federal Pretreatment Regulations
  • 40 CFR, Part 433, Metal Finishing Point Source Category
  • Clean Air Act (42 U.S.C. Section 7401 et seq.)
  • Clean Water Act (33 U.S.C. Section 1151 et seq.)
  • Comprehensive Environmental Response, Compensation, and Liability Act (42 U.S.C. Section 1601 et seq.)
  • Pollution Prevention Act (42 USC 13001 et seq.)
  • Resource Conservation and Recovery Act (42 U.S.C. Section 6901 et seq.)
  • Toxic Substance Control Act (15 U.S.C. Section 2601 et seq.)
  • DOE Order 5000.3A, Occurrence Reporting and Processing of Operations Information
  • DOE Order 450.1A, Environmental Protection Program
  • DOE Order 430.2B, Departmental Energy, Renewable Energy, and Transportation Management
  • DOE Order 5400.5, Radiation Protection of the Public and the Environment, Chapter II, paragraphs 1 (not including 1.a.3.c and 1.c), 2, 5, 6 (not including 6.a), 7, and 8.a, and Chapter IV
  • DOE Order 414.1, Quality Assurance
  • Executive Order 13423, Strengthening Federal Environmental, Energy, and Transportation Management

11.7.2 State

  • CCR, Title 17, Section 30253, Standards for Protecting Against Radiation
  • CCR, Title 17, Section 30287 and 30288, Disposal by Release into Sanitary Sewers (Radionuclides)
  • CCR, Title 22, Division 4.5, Environmental Health Standards for the Management of Hazardous Waste, Sections 66001-67800.5
  • CCR, Title 23, Division 3, Chapter 16, Underground Storage Tank Regulations
  • Air Toxics “Hot Spots” Information and Assessment Act (California Health and Safety Code Section 44300 et seq.)
  • California Clean Air Act (California Health and Safety Code Section 39000 et seq.)
  • Hazardous Waste Control Law (California Health and Safety Code Section 25100 et seq.)
  • Hazardous Waste Source Reduction and Management Review Act (California Health and Safety Code Section 25244.12 et seq.)
  • Petroleum Storage Act (California Health and Safety Code Section 25270 et seq.)
  • Petroleum Underground Storage Tank Cleanup (California Health and Safety Code Section 25299.10 et seq.)
  • Porter-Cologne Water Quality Control Act (Water Code Section 13000 et seq.)
  • Safe Drinking Water and Toxic Enforcement Act (California Health and Safety Code Section 25249.5 et seq.)
  • Toxic Air Contaminants Law (California Health and Safety Code Section 44300 et seq.)
  • Underground Storage of Hazardous Substances (California Health and Safety Code Section 25280 et seq.)

11.7.3 Local

  • Bay Area Air Quality Management District Rules and Regulations
  • City of Berkeley Toxics Management Program
  • San Francisco Bay Basin Plan and Amendments, Regional Water Quality Control Board
  • East Bay Municipal Utility District Waste Water Control Ordinance No. 311A-03
  • City of Berkeley Storm Water Pollution Reduction Ordinance No. 6216

11.8 Related LBNL/ES&H Manual Chapters

11.9 References

  • Accidental Spill Prevention and Containment Plan, Environmental Services Group, Berkeley Lab
  • Air Emission Permits to Operate, Bay Area Air Quality Management District
  • Corrective Measures Study Report, Environmental Restoration Program, Berkeley Lab
  • Environmental Management System Program Manual, Environmental Services Group, Berkeley Lab
  • Environmental Monitoring Plan, Environmental Services Group, Berkeley Lab
  • General Permit for Discharges of Storm Water Associated with Industrial Activity, State Water Resources Control Board
  • Groundwater Monitoring and Management Plan, Environmental Restoration Program, Berkeley Lab
  • Berkeley Lab Master Emergency Plan, Berkeley Lab, LBNL/PUB-533
  • Performance-Based Environmental Management System Plan, LBNL/PUB-3180, Environmental Services Group, Berkeley Lab
  • RCRA Facility Investigation Report, Environmental Restoration Program, Berkeley Lab
  • Site Environmental Report, Environmental Services Group, Berkeley Lab
  • Site Sustainability Plan, Sustainable Berkeley Lab, Berkeley Lab
  • Soil Management Plan, Environmental Restoration Program, Berkeley Lab
  • Spill Prevention, Control, and Countermeasures Plan, Environmental Services Group, Berkeley Lab
  • Storm Water Monitoring Plan, Environmental Services Group, Berkeley Lab
  • Storm Water Pollution Prevention Plan, Environmental Services Group, Berkeley Lab
  • Summary of Radionuclide Investigations, Environmental Restoration Program, Berkeley Lab
  • UST Monitoring and Emergency Response Manual, Environmental Services Group, Berkeley Lab
  • Wastewater Discharge Permits, East Bay Municipal Utility District

All of the above references can be found in the Environmental Services Group offices, located in Building 75B. Several are available on the Web, as noted in this chapter.

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