Chapter 51 – Environmental Releases

DRAFT

Approved by Jim Buehler
Revised 9/21

51.1 Policy
51.2 Scope
51.3 Applicability
51.4 Exceptions
51.5 Roles and Responsibilities
51.6 Definitions
51.7 Required Work Processes

Work Process A. General Requirements

51.8 Source Requirements
51.9 Reference Documents

Note:
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51.1 Policy

Berkeley Lab’s Environmental Releases Policy ensures that significant unplanned releases of hazardous materials, pollutants, or chemical agents are properly reported, investigated, and cleaned up.

51.2 Scope

Reporting, investigating, and cleaning up environmental releases of hazardous materials

51.3 Applicability

Berkeley Lab employees, visitors, affiliates, and subcontractors

51.4 Exceptions

None

51.5 Roles and Responsibilities

Role	Responsibilities
Employees	Take immediate action to stop unplanned releases to the environment, and report all instances of unplanned environmental releases to the EHS Division Follow applicable laws, regulations, and policies on environmental protection and release reporting Must 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 regulatory agency permits for their activities 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 Complete all required training provided by supervisors and the EHS Division
Environmental Services Group	Investigates reports of unplanned environmental releases and notifies federal, state, and local authorities in a timely manner, as required by regulatory agencies and DOE Develops Laboratory policies and procedures to assure operations are conducted in an environmentally safe manner and in full compliance with all applicable environmental laws and regulations and DOE orders Assesses current and planned Berkeley Lab programs, and assists in defining environmental protection compliance controls and practices. Provides training, makes presentations, and participates in discussions regarding environmental protection and releases with Berkeley Lab employees, regulatory agencies, concerned public citizens, community organizations, and the media Curtails or suspends any operations that pose an immediate hazard to members of the public or the environment Evaluates environmental releases to determine the potential impacts to environmental and public health and the appropriate compliance actions Coordinates and represents Berkeley Lab activities during follow-up inspections by regulatory agencies and DOE Responds to information requests from regulatory agencies and the public Ensures Berkeley Lab uses properly qualified analytical laboratories to ensure the quality of analytical results received for environmental release samples
Principal Investigators and Supervisors	Notify the Environment, Health and Safety (EHS) Division immediately of any unplanned environmental releases Ensure that laws, regulations, and policies pertaining to environmental protection and release reporting are followed Request technical advice from the Environmental Services Group on environmental protection requirements that apply to their operations and on appropriate compliance strategies Provide employee training in operational requirements for preventing environmental releases, and maintain records of such training Ensure that activities are performed within acceptable operating standards and that any required records are current

51.6 Definitions

Term	Definition
As low as reasonably achievable (ALARA)	An approach to radiological management and control intended 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 with the objective of attaining doses as far below the applicable controlling limits as is reasonably achievable.
Bay Area Air Quality Management District (BAAQMD)	The local agency that regulates stationary sources of regulated or hazardous air pollutants in the San Francisco Bay Area
Department of Toxic Substances Control (DTSC)	The department within the California Environmental Protection Agency that regulates hazardous waste management, environmental investigations, and remedial actions
East Bay Municipal Utility District (EBMUD)	The local municipal wastewater treatment facility that accepts and regulates sanitary sewer discharges from Berkeley Lab
Effluent	Any treated or untreated liquid discharge from Berkeley Lab or from a Laboratory facility
Emission	Any filtered or unfiltered substance released to the air from Berkeley Lab or from a Laboratory facility
Environmental monitoring	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	The collection and analysis of samples, or direct measurements of air, water, soil, foodstuff, biota, and other media from Berkeley Lab and its environs in order to determine compliance with applicable standards and permit requirements, assess radiation exposures of members of the public, and assess the effects, if any, on the local environment
Environmental occurrence	Any sudden or sustained deviation from a regulated or planned performance at an operation that has environmental protection and compliance significance
Hazardous air pollutant	Any pollutant listed in Section 112(b) of the Clean Air Act
Hazardous wastes	Wastes exhibiting any of the following characteristics: ignitability, corrosivity, reactivity, or toxicity. In addition, the Environmental Protection Agency has listed specific wastes as hazardous that do not necessarily exhibit these characteristics.
Radionuclide	A natural or man-made atom that spontaneously undergoes radioactive decay
Regulated air pollutants	Pollutants for which standards have been promulgated under the authority of the Clean Air Act. They include the classes of substances defined as nitrogen oxides, volatile organic compounds, toxic air contaminants, or ozone-depleting substances.
U.S. Environmental Protection Agency	A federal agency responsible for enforcing environmental laws. In California, some of this responsibility is typically delegated to state and local regulatory agencies.

51.7 Required Work Processes

Work Process A. General Requirements

Various DOE orders and federal, state, and local laws and regulations require Berkeley Lab to report any significant spills or releases of hazardous materials, pollutants, or chemical agents into the environment.
To implement these requirements, the following procedure has been developed:
- The line organization is responsible for immediately reporting accidental releases and spills of any magnitude that enter the environment.
- For emergency cases, the initial report should be made to the Fire Department by dialing ext. 7911.
- For accidental spills or releases that do not require emergency responses by the Fire Department, call the EHS emergency contact at ext. 6999.
See also Chapter 9 Emergency Management in the ES&H Manual Emergency Services Program.
The Environmental Services Group will investigate all reports of environmental spills or unplanned releases to determine the appropriate reporting and clean-up requirements for each instance. Notifications may be sent to DOE and various federal, state, and local agencies.
For complete descriptions of emergency procedures, refer to the Berkeley Lab Master Emergency Program Plan, PUB-533.

51.8 Source Requirements

Clean Water Act: Section 307, Toxic and Pretreatment Effluent Standards; and Section 311, Oil and Hazardous Substance Liability
Comprehensive Environmental Response, Compensation and Liability Act, Section 102, Hazardous Substances Releases, Liability, Compensation – Reportable Quantities and Additional Designations
Resource Conservation and Recovery Act, Section 3001, Identification and Listing of Hazardous Waste
Clean Air Act, Section 112, Air Pollution Prevention and Control – Air Quality and Emission Limitations – Hazardous air pollutants
Toxic Substances Control Act, Section 7, Control of Toxic Substances – Imminent hazards
California Health and Safety Code, Section 25501

51.9 Reference Documents

Document number	Title	Type
07.06.02.001	Emergency Response	Program
LBNL/PUB-533	Berkeley Lab Master Emergency Plan	Plan

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