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Chapter 11 – Environmental Management Programs

Published on by Heather Madison.

Contents

Approved by Jim Buehler
Revised 5/25

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,
  • mitigating environmental hazards and managing legacy environmental impacts, and
  • continually improving the Laboratory’s environmental performance while maintaining operational capability and sustaining the overall mission of the Laboratory.

Berkeley Lab assures the implementation of this policy through its Environmental Management System (EMS).

11.2 Scope

The Berkeley Lab environmental compliance programs are designed to reduce the Laboratory’s impacts on the environment, including impacts to air, water, soil, and other environmental media and meet regulatory and stakeholder requirements. Many of these programs are managed by the Environmental Services Group (ESG), including:

  • Chapter 49 Air Quality
  • Chapter 50 Environmental Radiological Protection Programs
  • Chapter 51 Environmental Releases
  • Chapter 53 Fixed Treatment Units
  • Chapter 55 Sanitary Sewer Program
  • Chapter 56 Spill Prevention, Control, and Countermeasures Program
  • Chapter 57 Storm Water Pollution Prevention
  • Chapter 58 Underground Storage Tanks
  • Chapter 61 Soil and Groundwater Management
  • Chapter 62 Environmental Monitoring
  • Chapter 63 Polychlorinated Biphenyl (PCB) Management

Berkeley Lab’s Waste Management Program is described in Chapter 20 and managed by the Waste Management Group.

This chapter provides an overview of the EMS assurance activities that Berkeley Lab performs to meet Contract 31 requirements. It also provides an overview of the waste minimization and pollution prevention program that support the Environmental Compliance Programs policy.

11.3 Program Description

11.3.1 Environmental Management System

LBNL maintains a risk- and performance-based EMS designed to assure that Berkeley Lab activities improve environmental performance and are well managed, cost-effective, and compliant with applicable environmental regulations.

The key elements of the EMS are:

  • Engaging senior leadership to perform a continual cycle of process improvement.
    EHS annually meets with a core of senior leadership to review the status of environmental regulatory compliance and provide and receive feedback on activities to improve performance.
  • Identifying potential environmental impacts.  ESG maintains a list of potential environmental impacts associated with environmental compliance programs listed in Section 11.2 above. Potential environmental impacts can include emission to air, release to water, release to land, use of raw materials and natural resources, use of energy, etc.
  • Assessing the health of environmental programs to manage these impacts.  ESG maintains a register of potential risks to Berkeley Lab’s environmental compliance programs. This assessment uses the methodology described in the Lawrence Berkeley National Laboratory (LBNL) Institutional Assessment Process Description, Document Number 04.03.009.001, Rev. 2. Where risk severity is moderate, ESG evaluates whether processes and controls are sufficient to mitigate potential risk, and determines program health.
  • Developing and implementing Environmental Action Plans (EAPs).  Where processes and controls are insufficient to mitigate potential risk, environmental action plan(s) are developed and implemented to improve program health.
  • Performing independent assessments to ensure the effectiveness of the compliance program. Internal assessments are important to evaluating the effectiveness of Berkeley Lab’s environmental compliance program.

The process to assess the health of environmental programs is illustrated in Figure 1 below. By utilizing a risk-based approach when implementing the EMS, Berkeley Lab is able to focus resources on activities that have stronger environmental benefits and builds upon the strengths of current environmental compliance programs. 

Figure 1


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

11.3.2 Waste Minimization and Pollution Prevention

Berkeley Lab 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 O 430.1C Chg 2 (AdminChg), Real Property Asset 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. Strategies, measures development, and implementation guidance on waste minimization is provided by the Research Support Team and the Waste Management Group. Sustainable Berkeley Lab maintains the wasteguide.lbl.gov which includes guidance for the disposition of common waste at Berkeley Lab.

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. 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.

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 is reinforced via policy in the Waste Management Program Manual (ES&H Manual Chapter 20). 

11.4 Support Organizations

  • Facilities Division 
  • Engineering Division 
  • Sustainable Berkeley Lab

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 EHS 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
  • Participate in pollution-prevention and waste minimization programs
  • Minimize the amount of waste generated
  • Complete all required training provided by supervisors and the EHS 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 compliance improvements and corrective actions
  • Identifies significant institutional environmental compliance issues, and develops cost-effective mechanisms for resolving them 
  • Provides training, makes presentations, and participates in discussions regarding environmental program matters with Berkeley Lab employees, regulatory agencies, concerned public citizens, community organizations, and the media 
  • Curtails or suspends any operations that pose an immediate danger to members of the public or the environment
  • 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

11.5.4 Waste Management Group

  • Educate Berkeley Lab employees about their responsibility to incorporate waste reduction strategies into work planning and controls and operating procedures
  • Incorporate waste minimization strategies into relevant EHS courses
  • Submit the annual Waste Minimization Certification to the California Department of Toxic Substances Control
  • Comply with the Hazardous Waste Source Reduction and Management Review Act (SB 14), and California Health and Safety Code Sections 25244.9 and 25244.20

11.6 Glossary

Environmental Management System is a structured process designed to assure Berkeley Lab complies with environmental laws and regulations.

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 

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

Federal, state, and local standards applicable for the environmental programs are described in their respective chapters (see Section 11.2).

11.8 Related LBNL/ES&H Manual Chapters

  • See RPM Chapter, Emergency Management  
  • See Chapter 12 Fire Prevention and Protection   
  • See Chapter 20 Waste Management 

11.9 References

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