Chapter 55 – Sanitary Sewer Program

DRAFT

Contents

Approved by Brendan Mulholland
Revised 09/21

55.1 Policy
55.2 Scope
55.3 Applicability
55.4 Exceptions
55.5 Roles and Responsibilities
55.6 Definitions
55.7 Required Work Processes

• Work Process A. General Requirements

55.8 Source Requirements
55.9 Reference Documents

Note:
🚩🚩    Denotes a new section

🚩    Denotes the beginning of changed text within a section

🛑    Denotes the end of changed text within a section

___________________

55.1 Policy

The Sanitary Sewer Program ensures that Berkeley Lab remains in compliance with sewer discharge limits imposed by the East Bay Municipal Utility District (EBMUD) by:

• Assisting dischargers by reviewing their potential discharge to see if it is eligible for sanitary-sewer disposal;
• Maintaining sitewide, treatment unit, and other special discharge permits with EBMUD;
• Submitting periodic self-monitoring reports to EBMUD as required by each EBMUD permit;

55.2 Scope

This Sanitary Sewer Program covers discharges to the sanitary sewer from the Berkeley Lab main site.

55.3 Applicability

All Berkeley Lab employees, visitors, affiliates, and subcontractors who intend to discharge hazardous substances into the sanitary sewer.

55.4 Exceptions

None

55.5 Roles and Responsibilities

Role	Responsibilities
East Bay Municipal Utility District (EBMUD) – the local wastewater treatment facility	Accepts and regulates sanitary-sewer discharges from Berkeley Lab
Employees	Follow applicable water-district permits and ordinances; Must be fully aware of the environmental impact of their activities and comply with all requirements that govern those activities; Must take immediate action to stop unplanned releases to the sanitary sewer and report all instances of unplanned sanitary-sewer releases to the Environment/Health/Safety (EHS) Division; Must not discharge paper towels to the sanitary sewer;
Environmental Services Group (ESG)	Prepares and maintains sanitary-sewer permits with EBMUD; Assists in determining whether a discharge is eligible for sanitary-sewer disposal; Prepares special discharge permits with EBMUD for disposing of stormwater to the sanitary sewer at construction sites; Makes presentations and participates in discussions regarding sanitary-sewer-permit compliance matters with Berkeley Lab employees and EBMUD. Curtails or suspends any operations that are not in compliance with water-district permits and ordinances; Monitors laboratory discharges by sampling the sanitary sewer to verify compliance with applicable regulations and permits, and reports results to EBMUD; Investigates reports of unplanned sanitary-sewer releases and notifies water districts in a timely manner, as required; and Coordinates and represents Berkeley Lab activities during water district audits
Principal investigators and supervisors	Ensure that water-district permits and ordinances are followed; Request assistance from the Waste Management Group (Generator Assistant) and the Environmental Services Group for technical advice on questions relating to sanitary-sewer disposal; Notify the EHS Division immediately of any unplanned or accidental releases to the sanitary sewer
State Water Resources Control Board (SWRCB)	Regulates sanitary-sewer discharges to San Francisco Bay from Publicly Owned Treatment Works (POTW)
Waste Management Group	The Generator Assistant aids in determining whether the proposed discharge is a hazardous waste. If so, the discharge is not eligible for sanitary-sewer disposal.

55.6 Definitions

Term	Definition
Effluent	Any treated or untreated liquid discharge from a Berkeley Lab site or facility
Environmental monitoring	The collection and analysis of sanitary-sewer samples
Environmental occurrence	Any sudden or sustained deviation from a regulated or planned performance at an operation that has environmental protection and compliance significance. Specifically, a violation of a water-district permit or ordinance requirement.
Hazardous wastes	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.
Publicly Owned Treatment Works (POTW)	A sewage-treatment plant. The East Bay Municipal Utility District plant is the POTW that accepts sewage from Berkeley Lab. The Central Contra Costa Sanitary District plant is the POTW that accepts sewage from JGI.
Radionuclide	A natural or artificially produced isotope that spontaneously undergoes radioactive decay

55.7 Required Work Processes

Work Process A. General Requirements

1. Discharge Permits
   1. Discharges to the sanitary-sewer system are subject to increasingly complex and restrictive standards imposed by EBMUD at the Berkeley Lab main site.
   2. EBMUD has established a permitting process that mandates operating conditions that must be met for all wastewater discharged into their sanitary-sewer system.
   3. At the Berkeley Lab main site, EBMUD has established three wastewater discharge permits for:
      1. Sitewide activities
      2. Wastewater pretreatment units at the Building 77 Ultrahigh Vacuum Cleaning Facility
      3. Groundwater treatment systems at various locations
   4. EBMUD Special Discharge Permits are required for the discharge of stormwater from construction sites or the discharge of groundwater to the sanitary sewer (e.g., Old Town Demolition Project, Bayview / SURP / BioEPIC Project).
2. Berkeley Lab Discharge Limits. These wastewater discharge permits specify different discharge limits at the site boundary and at the treatment units. Table 1 shows the substances for which Berkeley Lab has EBMUD-specific discharge limits.

Table 1. EBMUD Sanitary Sewer Discharge Limit

* See sitewide discharge limits

1. Terms of the wastewater discharge permits require that Berkeley Lab abide by all applicable provisions of the EBMUD ordinance and any other federal, state, and local regulations.
2. California regulations governing standards for the protection against radiation are found in 17 CCR 30253. Limits for radionuclide discharges are found in 10 CFR 20.2003.
3. Because of EBMUD discharge limits, no discharge may be made to the sanitary-sewer system until the composition and concentration of the discharge is known. The Generator Assistant within the Waste Management Group will assist in determining if the waste to be disposed of is a hazardous waste.
4. In some cases, sampling and analysis must be performed to determine if a discharge can be released to the sewer. ESG will assist employees in determining whether their discharge is eligible for sanitary-sewer disposal.
5. Approval for release to the sewer can be issued only after all required analyses have been conducted and properly evaluated.
6. In addition, ESG performs periodic wastewater discharge sampling and reports the results to EBMUD, as mandated by each permit.
7. All sinks should be labeled to warn againstdisposal of hazardous substances down the drain.

55.8 Source Requirements

• 10 CFR 20.2003, Disposal by Release into Sanitary Sewerage
• EBMUD Ordinance No. 311A.03 (except AEA discharges)

Other Driving Requirements

• EBMUD permit #6600791(main site), #50238911 (B77 FTU), #50347891 (Groundwater Treatment Systems),

55.9 Reference Documents

None

_____________________