Chapter 53 – Fixed Treatment Units

Contents

Approved by Jim Buehler
Revised 9/21

53.1 Policy53.2 Scope
53.3 Applicability
53.4 Exceptions
53.5 Roles and Responsibilities
53.6 Definitions
53.7 Required Work Processes

• Work Process A. General Requirements

53.8 Source Requirements
53.9 Reference Documents

Note:
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53.1 Policy

Berkeley Lab maintains Fixed Treatment Units (FTUs) to protect the surrounding environment, minimize waste handling, and maintain compliance with East Bay Municipal Utility District (EBMUD) discharge limits. The Laboratory achieves this by:

• Maintaining permits for the FTUs on site
• Maintaining operating records required by the state of California
• Submitting periodic compliance reports to EBMUD
• Ensuring that operators are properly and adequately trained
• Informing EBMUD and the city of Berkeley of new waste streams, new treatment units, or other changes to the process or treatment units

53.2 Scope

FTUs treat hazardous waste and are permitted by the city of Berkeley under California’s tiered permitting program. FTUs are located at Buildings 2, 67, 70A, and 77. FTUs may have a specific permit with EBMUD (Building 77 FTU) or may fall within EBMUD’s permit for the Berkeley Lab site.

53.3 Applicability

All Berkeley Lab employees, visitors, affiliates, and subcontractors who discharge to, or maintain records for, the FTUs located in Buildings 2, 67, 70A, and 77.

53.4 Exceptions

None

53.5 Roles and Responsibilities

Role	Responsibilities
Principal investigators and supervisors	Ensure that environmental laws, regulations, and policies are followed Request technical advice from the Environmental Services Group (ESG) on applicable environmental requirements and an appropriate compliance strategy Train employees in operational requirements on environmental protection; maintain records of such training (including 24-hour Occupational Safety and Health Administration [OSHA] Hazardous Waste Operations and Emergency Response Standard [HAZWOPER] training with annual eight-hour refresher) Ensure that activities are performed following acceptable written operating procedures and that any required records are current (daily logs, monthly calibration) Notify EBMUD and the Environment, Health and Safety (EHS) Division within 30 minutes of any unplanned accidental releases to the sanitary sewer Prepare budget requests for and manage environmental-protection upgrades and corrective actions for institutional projects
Employees	Follow applicable environmental laws, regulations, and policies Remain fully aware of the environmental impact of their activities, and comply with all requirements that govern those activities Perform activities that conform to written operating procedures, and maintain current records whenever required Participate in energy-conservation, recycling, pollution-prevention, and waste-minimization programs Take immediate action to stop unplanned releases to the sanitary sewer, and report all instances of unplanned sanitary sewer releases to EHS within 30 minutes of the release Complete all required training provided by supervisors and the EHS Division
Environmental Services Group (ESG)	Develops Laboratory policies and procedures to assure that operations are conducted in an environmentally safe manner and that they fully comply with all applicable environmental laws and regulations and DOE orders Prepares environmental compliance reports as required by the city of Berkeley and EBMUD Assesses current and planned Berkeley Lab programs, and helps define environmental-protection compliance upgrades and corrective actions Makes presentations and participates in discussions regarding FTU matters with Berkeley Lab employees, the city of Berkeley, EBMUD, and the California Department of Toxic Substances Control (DTSC) Manages the preparation of environmental FTU operating permit applications, permit amendments, and permit renewals with the city of Berkeley and EBMUD Curtails or suspends any operations that pose an immediate danger to members of the public or the environment Monitors laboratory sanitary sewer discharges to verify compliance with applicable regulations and permits and provides written reports to EBMUD Investigates reports of unplanned environmental sanitary sewer 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 the city of Berkeley and EBMUD

53.6 Definitions

Term	Definition
Acutely hazardous wastes	Any wastes defined as acutely hazardous by 22 CCR, Division 4.5, Chapter 11, Article 4
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 are 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 hazardous-waste management 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, 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	Any sudden or sustained deviation from a regulated or planned performance at an operation that has environmental protection and compliance significance
Environmentallypreferable products and services	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	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	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 EPA has listed specific wastes as hazardous that do not necessarily exhibit these characteristics.
Life-cycle cost analysis	A procurement evaluation technique that determines the total cost of acquisition, operation, maintenance, and disposal of items being acquired
Pollution prevention	Reducing or eliminating waste at the source by modifying production processes, promoting the use of nontoxic or less-toxic substances, implementing conservation techniques, and reusing materials rather than putting them into the waste stream
Pollution prevention opportunity assessment	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
Publicly Owned Treatment Works (POTW)	A general term used for sewage-treatment plants. The EBMUD plant is the POTW that accepts sewage from Berkeley Lab.
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, including the classes of substances defined as nitrogen oxides, volatile organic compounds, toxic air contaminants, or 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.
Sustainable design	A systems approach to design and construction of facilities, systems, and equipment that considers the optimization of ecological and human issues in light of acceptable economic constraints. Considerations include 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)	A stationary device designed to contain an accumulation of hazardous material or waste. The tank 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 responsible for enforcing environmental laws. In California, some of this responsibility is typically delegated to state and local regulatory agencies.
Waste minimization	The EPA has 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.

53.7 Required Work Processes

Work Process A. General Requirements

1. Fixed Treatment Unit Locations and Responsible Owners
   1. Berkeley Lab operates four hazardous-wastewater-treatment units, or Fixed Treatment Units (FTUs). These are:
      1. Building 2 — acid wastewater — Facilities
      2. Building 67 — acid or alkaline wastewater — Materials Sciences
      3. Building 70A — acid wastewater — Facilities
      4. Building 77 — acid wastewater with metals — Engineering
2. Compliance
   1. The wastewater is treated to meet the East Bay Municipal Utility District’s (EBMUD’s) discharge limits and then is discharged to the sanitary sewer.
   2. State law requires all facilities treating hazardous waste to obtain authorization from the California Department of Toxic Substances Control (DTSC) and the city of Berkeley. 

3. Tiered Permitting
   1. The state of California (AB 1771) has created a tiered permitting program, based on environmental risk, as the permitting process to gain authorization to operate.
      1. The FTUs at Buildings 67 and 77 have received authorization to operate under thePermit-by-Rule tier. 
      2. The FTUs at Buildings 2 and 70A and are permitted to operate under theConditional-Authorization tier.
   2. The Environmental Services Group (ESG) has prepared and maintains permit documentation, including notifications and plans required by the tiered permit program.
      1. It has also provided oversight of construction upgrades to these units to verify that the engineering standards have been met. An annual renewal is prepared and submitted to the California Electronic Reporting System (CERS).
   3. Permit-by-Rule and Conditional-Authorization FTUshave the following operation requirements, for which the operators of these units are responsible:
      1. Recording dates, amounts, and types of waste treated; submitting a quarterly report of wastewater treated to ESG
      2. Preparing inspection logs that document maintenance activities
      3. Complying with hazardous-waste-generator operating standards
      4. Ensuring that primary operators have received OSHA 24-hour training for hazardous-waste workers and that these operators annually take an eight-hour refresher training course for hazardous-waste workers (Ref. 1990 DTSC, Corrective Action Response)
      5. Maintaining worker training files
      6. Informing ESG of any new process waste streams or new treatment processes
      7. Providing information needed to prepare an annual report for all Permit-by-Rule FTUs, including treatment methods, composition and characteristics of the influent hazardous waste, days of operation, wastewater volume, and amount of solid waste generated (filter cake)

4. New Permits
   1. When a new FTU is planned, the city of Berkeley and EBMUD must be notified 60 days before the first treatment of waste begins.
   2. The permit submission must include:
      1. A completed Facility Specific Notification form
      2. A completed Unit Specific Notification form
      3. A description of the treatment process
      4. Drawings of the treatment system, including tanks, containers, secondary containment, and leak detection (as-built drawings preferred)
      5. Tank and containment system certification obtained from an independent, qualified professional engineer, registered in California
      6. A certification specifying the local agencies that have been notified
   3. Planning should take into account the 60-day lag time that the city of Berkeley requires to process the permit. 
   4. In practice, a permit cannot be submitted until construction has been completed, the system leak tested, and the treatment unit certified by an independent, qualified professional engineer. 
   5. In addition, planning should allow two to four months for the preparation of the permit. 
   6. Preparation time will vary depending on the complexity of the treatment unit and whether the independent engineer identifies that upgrades are needed.
5. Permit Changes
   1. When there is a change to an existing treatment unit, a permit amendment must be submitted to the city of Berkeley and EBMUD (for Building 77 FTU only).
   2. The permit amendment submission may include all the items listed for a new permit.
   3. Planning should allow two to four months for the preparation of the permit amendment.
   4. Once proof of receipt of the permit amendment has been received from the city of Berkeley, treatment of the waste may begin.

53.8 Source Requirements

• H&SC 25200.3, Permitting of Facilities
• 22 CCR 67450, Requirements for Units and Facilities Deemed to Have a Permit by Rule
• 22 CCR 66260.10 et. seq., Hazardous Waste Management System: General — Definitions
• 22 CCR 66265.190 et. seq., Interim Status Standards for Owners and Operators of Hazardous Waste Transfer, Treatment, Storage, and Disposal Facilities — Tank Systems

53.9 Reference Documents

Title	Type
Hazardous Wastewater Treatment Units	Program

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