DRAFT

Contents

Approved by Jim Buehler
Revised 9/21

62.1 Policy
62.2 Scope
62.3 Applicability
62.4 Exceptions
62.5 Roles and Responsibilities
62.6 Definitions
62.7 Required Work Processes

• Work Process A. Environmental Monitoring

62.8 Source Requirements
62.9 Reference Documents

Note:
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62.1 Policy

Berkeley Lab monitors Laboratory activities that have potential to adversely impact public health or environmental quality. Berkeley Lab’s environmental-monitoring program consists of four major activities:

• Effluent monitoring. The collection and analysis of samples or the measurement of liquid and gaseous effluents in order to characterize and quantify contaminants, assess radiation exposures to members of the public, provide a means to control effluents at or near the point of discharge, and demonstrate compliance with applicable standards and permit requirements
• Environmental surveillance. The collection and analysis of samples or the direct measurement of air, water, soil, vegetation, and other media from the Berkeley Lab site and its environs in order to determine compliance with applicable standards and permit requirements, assess radiation exposures to members of the public, and assess the effects, if any, on the local environment
• Meteorological monitoring. The collection of representative meteorological data to characterize atmospheric transport and diffusion conditions in the vicinity of Berkeley Lab, and to support environmental surveillance activities, such as air-quality monitoring and exposure assessments
• Pre-operational monitoring. An environmental study conducted prior to the start-up of a new facility, or a process to establish a baseline for environmental conditions

62.2 Scope

 Environmental monitoring is performed for the following:

• Sewer effluents
• Storm-water effluents
• Stack air emissions
• Ambient air
• Groundwater
• Creek water and sediment
• Soil
• Vegetation
• Penetrating radiation
• Meteorological parameters

62.3 Applicability

All Berkeley Lab employees, visitors, affiliates, and subcontractors who measure potentially harmful environmental discharges or emissions and report the information to the Department of Energy (DOE) or external regulatory agencies

62.4 Exceptions

None

62.5 Roles and Responsibilities

Role	Responsibility
Principal Investigators and Supervisors	Ensure that environmental laws, regulations, and policies are followed Ensure that activities are performed within acceptable emission or discharge standards and that any required records are current Notify the Environment, Health and Safety (EHS) Division immediately of any unplanned accidental releases
Employees	Follow applicable environmental laws, regulations, and policies Must be fully aware of the environmental impact of their activities, and comply with all emission or discharge requirements that govern those activities Adhere to all environmental requirements contained in Berkeley Lab air permits for their facility 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 Take immediate action to stop unplanned releases to the environment, and report all instances of unplanned environmental releases to EHS
Environmental Services Group (ESG)	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 environmental 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 Manages the preparation of environmental operating permit applications Curtails or suspends any operations that pose an immediate danger to 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

62.6 Definitions

Term	Definition
As low as reasonably achievable (ALARA)	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 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 responsible for regulating 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 remedial actions
East Bay Municipal Utility District (EBMUD)	The local municipal agency that accepts and regulates sanitary sewer discharges from Berkeley Lab and that supplies drinking water to the 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
Publicly Owned Treatment Works (POTW)	A general term for sewage-treatment plants. The EBMUD plant is the POTW that accepts sewage from Berkeley Lab.
Radionuclide	A natural or manmade atom that spontaneously undergoes radioactive decay
Regulated air pollutants	Pollutants controlled by standards authorized by the Clean Air Act.  They include the classes of substances defined as nitrogen oxides, volatile organic compounds, toxic air contaminants, and ozone-depleting substances.
State Water Resources Control Board (SWRCB)	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 Bay Regional Water Quality Control Board, with assistance from the city of Berkeley.
Underground storage tank (UST)	A stationary device designed to contain an accumulation of hazardous material or waste. A UST is constructed primarily of non-earthen 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 (EPA)	A federal agency that enforces environmental laws. In California, some of this responsibility is often delegated to state and local regulatory agencies.

 

62.7 Required Work Processes

Work Process A. Environmental Monitoring

1. Compliance
   1. Berkeley Lab’s environmental-monitoring program helps ensure that Laboratory activities are conducted in a manner that protects public health and maintains environmental quality. The program is designed to demonstrate compliance with requirements imposed by federal, state, and local regulatory agencies; confirm adherence to DOE environmental-protection requirements; and support environmental management decisions.
   2. Several external agencies provide regulatory oversight. They include: DOE, the U.S. Environmental Protection Agency (EPA), the California Department of Toxic Substances Control, the San Francisco Bay Regional Water Quality Control Board, the East Bay Municipal Utility District, the Bay Area Air Quality Management District, and the City of Berkeley.
2. Environmental-monitoring activities at Berkeley Lab consist of four major activities:
   1. Effluent monitoring. The collection and analysis of samples or the measurement of liquid and gaseous effluents in order to characterize and quantify contaminants, assess radiation exposures to members of the public, provide a means to control effluents at or near the point of discharge, and demonstrate compliance with applicable standards and permit requirements
   2. Environmental surveillance. The collection and analysis of samples, or the direct measurements of, air, water, soil, vegetation, and other media from the Berkeley Lab site and its environs in order to determine compliance with applicable standards and permit requirements, assess radiation exposures to members of the public, and assess the effects, if any, on the local environment
   3. Meteorological monitoring. The collection of representative meteorological data to characterize atmospheric transport and diffusion conditions in the vicinity of the Berkeley Lab, and to support environmental surveillance activities, such as air quality monitoring and exposure assessments.
   4. Pre-operational monitoring. An environmental study conducted prior to the start-up of a new facility, or a process to establish a baseline for environmental conditions

3. Reports. Information on environmental-monitoring activities is reported annually in the Berkeley Lab Site Environmental Reports. The more recent reports are separated into two volumes. Volume I summarizes environmental-monitoring results, compares the results with regulatory limits, and discusses environmental impacts to the public and the local environment. Volume II contains individual data from effluent and surveillance activities.
4. Meteorological monitoring. An on-site 20-meter weather tower collects meteorological data — wind speed, wind direction, temperature, dew point, barometric pressure, solar radiation, and precipitation — every 15 minutes. The data can be obtained at the Berkeley Lab Weather site in either graphical or tabular form. Note: Data displayed on this site have not been validated and should be considered preliminary.

62.8 Source Requirements

Regulations, Requirements, Guidelines	Topic	Oversight Agency
10 CFR 20.2003	Disposal by Release into Sanitary Sewerage	EPA
17 CCR 30253	Radiation protection standards of radionuclides in sewer discharge and water	EBMUD, DPH
22 CCR 64443	Domestic Water Quality Maximum Contaminant Level for Radioactivity	RWQCB
23 CCR 2550 and 2610	USTs	RWQCB
23 CCR 2610-2727	USTs	City of Berkeley
40 CFR Part 122-125	National Pollutant Discharge Elimination System Regulations, including Stormwater Discharge (Clean Water Act)	SWRCB, RWQCB
40 CFR Part 136	Guidelines Establishing Test Procedures for the Analysis of Pollutants (under the Clean Water Act)	EPA
40 CFR Part 280	Technical Standards and Corrective Action Requirements for Owners and Operators of Underground Storage Tanks (UST)	City of Berkeley
40 CFR Part 403	General Pretreatment Regulations for New and Existing Sources of Pollution	EBMUD
40 CFR Part 50	National Primary and Secondary Ambient Air Quality Standards	EPA
40 CFR Part 58	Ambient Air Quality Surveillance	EPA
40 CFR Part 60	Standards of Performance for New Stationary Sources	BAAQMD
40 CFR Part 61	National Emission Standards for Hazardous Air Pollutants	EPA
40 CFR Subchapter N	Effluent Guidelines and Standards (Clean Water Act)	EBMUD
California Health and Safety Code 25280-25299	USTs	City of Berkeley
DOE Order 450.1A	Environmental Protection Program	DOE
DOE Order 5400.5	Radiation Protection of the Public and the Environment	DOE
DOE/EH-0173T	Environmental Regulatory Guide for Radiological Effluent Monitoring and Environmental Surveillance	DOE
DOE-STD-1153-2002	A Graded Approach for Evaluating Radiation Doses to Aquatic and Terrestrial Biota	DOE
SW-846	Test Methods for Evaluating Solid Waste, Physical/Chemical Methods	EPA

62.9 Reference Documents

Document Number	EH&S Reference	Title	Type
07.09.011.002	PUB-3180-2009	Environmental Management System Program Manual	Plan

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