Chapter 11
ENVIRONMENTAL PROTECTION

Contents

Approved by Ron Pauer
Revised 04/13


11.1  Policy
11.2  Scope
11.3  Program Descriptions

11.3.1 Accidental Releases: See Chapter 51, Environmental Releases.
11.3.2 Air Emissions
11.3.3 Environmental Management System
11.3.4 Environmental Radiological Dose Assessment: See Chapter 50, Environmental Radiological Protection Program.
11.3.5 Environmental Monitoring: See Chapter 62, Environmental Monitoring
11.3.6 Contaminated Vegetation Management
11.3.7 Contaminated Soil and Groundwater Management: See Chapter 61, Soil and Groundwater Management.
11.3.8 Hazardous Wastewater Treatment Units See Chapter 53, Fixed Treatment Units.
11.3.9 Petroleum Products Storage See Chapter 56, Spill Prevention, Control, and Countermeasures Program.
11.3.10 Polychlorinated Biphenyls (PCBs) Management See Chapter 63.
11.3.11 Sanitary Sewer Discharges
11.3.12 Storm Water Discharges
11.3.13 Underground Storage Tanks
11.3.14 Waste Minimization and Pollution Prevention

11.4  Support Organizations
11.5  Responsible Parties

11.5.1  Principal Investigators and Supervisors
11.5.2  Employees
11.5.3  Environmental Services Group

11.6  Glossary
11.7  Standards

11.7.1  Federal
11.7.2  State
11.7.3  Local

11.8  Related LBNL/PUB-3000 Chapters
11.9  References

 

NOTE:
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. . . . . . . . Denotes the beginning of changed text within a section.
. . . . . . . . Denotes the end of changed text within a section.

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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:

11.2  Scope

The Berkeley Lab environmental protection programs are designed to reduce the Laboratory's impacts on air, water, soil, and other environmental media and to conserve natural resources.  Many of these programs are managed by the Environmental Services Group (ESG), including:

11.3  Program Description

11.3.1  Accidental Releases

This program has been moved to Chapter 51, Environmental Releases.

11.3.2  Air Emissions

Operations at Berkeley Lab that emit hazardous (nonradioactive) or regulated air pollutants are subject to the rules and regulations administered by the Bay Area Air Quality Management District (BAAQMD). (Air emissions of radioactive materials are discussed in Section 11.3.4.) BAAQMD rules and regulations are designed to control emissions of particulates, inorganic gases, organic compounds, air toxics, and odors.  They require any person who wishes to build, erect, alter, replace, operate, or use any article, machine, equipment, or other device that might cause the emission of air pollutants to first obtain a permit from BAAQMD, unless it qualifies for one of the agency's specific exemptions. Prior approval is also required for modifications to an already-permitted activity. The types of permitted air pollution sources found at Berkeley Lab and their associated air pollutants are summarized in the table below:

Air Pollution Source(s) Primary Pollutant(s)

Diesel-powered Emergency Standby Generators

Diesel Particulate Matter

Epoxy Mixing Hood

Volatile Organic Compounds

Fuel Dispensing

Gasoline and Ethanol

Paint Spray Booth

Volatile Organic Compounds

Sandblast Booth

Particulates

Soil Vapor Extraction Operations

Volatile Organic Compounds

Solvent Wipe Cleaning

Volatile Organic Compounds

Asbestos Removal

Asbestos Dust

 

The BAAQMD places operating conditions on each permitted air pollution source.  The ESG provides technical assistance to each source owner/operator in meeting these conditions.  More information regarding the current set of air permits and associated operating conditions can be found at:

If it is determined that a permit is required, an application is prepared by ESG with the assistance from the owner of the activity. The application typically consists of an applicable set of BAAQMD forms, a detailed description of the activity, diagrams, and maps. If an activity involves construction or installation of new equipment, an Authority to Construct is first issued by the BAAQMD. When construction or installation has been satisfactorily completed, and operations are ready to begin, the BAAQMD will issue a Permit to Operate. Permits are valid for one year, and require annual renewal.

To avoid operational delays, advanced planning is essential in obtaining either a new or modified permit from BAAQMD, since it can take several months for the agency to review and approve an application. BAAQMD is authorized specific lengths of time by its regulations to both determine if an application is complete, and to then evaluate and decide whether to approve the request. The permit-review process may take even longer if BAAQMD requests additional information at any stage of the process, or if a risk assessment is required because of hazardous air pollutants emitted by the source.

Annually, BAAQMD will send permit renewal forms to ESG to update information on permitted sources. Renewed permits are issued after the forms are returned and annual fees are paid. BAAQMD conducts periodic inspections of permitted sources. The inspection frequency depends on the risk posed by the source, and is determined by BAAQMD.

Berkeley Lab employees play an important role in this program by:

11.3.3  Environmental Management System

Executive Order 13423, Strengthening Federal Environmental, Energy, and Transportation Management, requires all federal agencies to implement an Environmental Management System (EMS). An EMS is simply a systematic approach to achieving environmental goals. DOE Order 450.1A, Environmental Protection Program, established the EMS requirement for all DOE facilities and, in addition, mandated that the EMS be integrated with existing Integrated Safety Management (ISM) systems.

LBNL maintains a performance-based EMS a systematic approach to ensuring that environmental stewardship activities are not only well managed but also provide business value while implementing sustainable practices. The performance-based approach includes all program elements of the ISO 14001 EMS Standard with emphasis given to elements that provide real and tangible business value. This approach allows the Lab to focus its resources on those activities that have the most environmental benefit while maintaining and building on the strengths of the current environmental compliance programs.

The goals of the LBNL EMS approach are to:

A continual cycle of planning, implementing, evaluating, and improving processes is performed to achieve these EMS goals.

A cross-functional Core Team was formed to implement the EMS. The EMS Core Team is currently composed of representatives from the Environmental Health & Safety (EH&S), Facilities, and Procurement organizations, with team leadership provided by EH&S. The Core Team has been working on the following implementation tasks:

Internal assessments and external audits are performed to evaluate the effectiveness of LBNL’s EMS. The EMS program is audited at specified frequencies by the Lab's Office of Contract Assurance and audited by a third party to determine if all programmatic activities have been completed and to determine the effectiveness of the program. In addition, progress in achieving EMS objectives and targets and the results of EMS internal and external audits are reviewed annually by a Laboratory management team.

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

11.3.4  Environmental Radiological Dose Assessment

This program has been moved to Chapter 50, Environmental Radiological Protection Program.

11.3.5  Environmental Monitoring

This program has been moved to Chapter 62, Environmental Monitoring.

11.3.6  Contaminated Vegetation Management

Trees at some locations near the former National Tritium Labeling Facility (Building 75) may contain tritium at very low, but measurable, levels. Although they present no health hazard, these trees may not be removed from the Berkeley Lab site. They may be cut down, but they must remain on-site near the location were they grew. Facilities Division personnel must contact the EHS Environmental Services Group before cutting trees within 300 m (1000 ft) of Building 75.

11.3.7 Contaminated Soil and Groundwater Management

This program has been moved to Chapter 61, Soil and Groundwater Management.

11.3.8 Hazardous Wastewater Treatment Units

This program has been moved to Chapter 53, Fixed Treatment Units.

11.3.9 Petroleum Products Storage

This program has been moved to Chapter 56, Spill Prevention, Control, and Countermeasures Program.

11.3.10 Polychlorinated Biphenyls (PCBs) Management

This program has been moved to Chapter 63.

11.3.11 Sanitary Sewer Discharges

Discharges to the sanitary sewer system are subject to increasingly complex and restrictive standards imposed by the East Bay Municipal Utility District (EBMUD) at the main LBNL site, and by the Central Contra Costa Sanitary District (CCCSD) at the Joint Genome Institute (JGI).  Both water districts have established a permitting process that mandates operating conditions that must be met for all wastewater discharged into their sanitary sewer systems.

At the Berkeley Lab main site, EBMUD has established three wastewater discharge permits.  They are for:

  1. Sitewide activities
  2. Wastewater pretreatment units at the Building 25 Photofabrication Facility and the Building 77 Ultrahigh Vacuum Cleaning Facility
  3. Groundwater treatment systems at various locations

These wastewater discharge permits specify different discharge limits at the site boundary and at the treatment units. Table 11-1 shows the substances for which Berkeley Lab has EBMUD-specific discharge limits.

Table 11-1.  EBMUD Sanitary Sewer Discharge Limit


 


Site Limit

Wastewater Treatment
Unit Limit

Treated Groundwater Limit


Parameter

(daily
maximum)

(daily
maximum
25/77)

(monthly average
25/77)

(daily
maximum)

Arsenic

2 mg/L

2 mg/L

—

—

Cadmium

1 mg/L

0.69 mg/L
0.55 mg/L

0.26 mg/L
0.21 mg/L

—

Chlorinated Hydrocarbons
(Total Identifiable)

0.5 mg/L

—

—

—

Chromium

2 mg/L

2.77 mg/L
2.22 mg/L

1.71 mg/L
1.37 mg/L

—

Copper

5 mg/L

3.38 mg/L
2.71 mg/L

2.07 mg/L
1.66 mg/L

—

Cyanide

5 mg/L

1.2 mg/L
0.96 mg/L

0.65 mg/L
0.52 mg/L

—

Iron

100 mg/L

100 mg/L

—

—

Lead

2 mg/L

0.69 mg/L
0.55 mg/L

0.43 mg/L
0.34 mg/L

—

Mercury

0.05 mg/L

0.05 mg/L

—

—

Nickel

5 mg/L

3.98 mg/L
3.19 mg/L

2.38 mg/L
1.91 mg/L

—

Total Toxic Organics

—

2.13 mg/L
1.71 mg/L

—

—

Carbon Tetrachloride

—

—

—

0.005 mg/L

Chloroform

—

—

—

0.014 mg/L

1,1-dichloroethane

—

—

—

0.005 mg/L

1,1-dichloroethene

—

—

—

0.005 mg/L

Cis-1,2-dichloroethene

—

—

—

0.005 mg/L

Trichloroethene

—

—

—

0.005 mg/L

1,1,1-trichloroethane

—

—

—

0.005 mg/L

1,1,2-trichlorofluoroethane

—

—

—

0.005 mg/L

Tetrachloroethene

—

—

—

0.005 mg/L

Polychlorinated biphenyls (PCBs)

—

—

—

0.0002 mg/L

Oil and Grease

100 mg/L

100 mg/L

—

—

Phenolic compounds

100 mg/L

100 mg/L

—

—

Silver

1 mg/L

0.43 mg/L
0.34 mg/L

0.24 mg/L
0.19 mg/L

—

Zinc

5 mg/L

2.61 mg/L
2.09 mg/L

1.48 mg/L
1.19 mg/L

—

pH

5.5 – 12.4 S.U.

5.5 – 12.4 S.U.

—

—

Temperature

150°F

150°F

—

—

Closed-Cup Flashpoint

140°F (60°C)

140°F (60°C)

140°F (60°C)

—

The terms of the wastewater discharge permits require that Berkeley Lab abide by all applicable provisions of the EBMUD Ordinance or any other federal, state, and local regulations. Limits for radionuclide discharges are established based on the limits specified in Title 17 of the California Code of Regulations (17 CCR, Section 30253).  Because of these requirements, no discharge may be made to the sanitary sewer system until the composition and concentration of the discharge is known.  In some cases, sampling and analysis must be performed in order to determine if a discharge can be released to the sewer. ESG will assist employees in making this determination.  Approval for release to the sewer can be issued only after all required analyses have been conducted and properly evaluated.  In addition, ESG performs periodic wastewater discharge sampling and reports the results to EBMUD, as mandated by each permit.   All sinks should be labeled to warn against disposal of hazardous substances down the drain.

At the JGI, the CCCSD has established a single wastewater discharge permit for this facility.  It also specifies discharge limits for specific substances, which are shown in Table 11-2.

Table 11-2.  CCCSD Sanitary Sewer Discharge Limits


Parameter

Site Limit
(daily maximum)

Antimony

5 mg/L

Arsenic

0.8 mg/L

Cadmium

0.3 mg/L

Chromium

1.5 mg/L

Copper

0.09 mg/L

Cyanide

0.5 mg/L

Lead

0.4 mg/L

Mercury

0.003 mg/L

Nickel

3 mg/L

Selenium

0.3 mg/L

Silver

1 mg/L

Thallium

1.5 mg/L

Zinc

4.5 mg/L

Phenol

10 mg/L

pH

5.5 - 11.5 S.U.

Oil and Grease - Mineral

100 mg/L

Oil and Grease - Animal & Vegetable

300 mg/L

Total Toxic Organics

2.1 mg/L

Radioactivity

Refer to 10CFR20.2003

Closed-Cup Flashpoint

140°F (60°C)

Lower Explosive Limit - single reading

10%

Lower Explosive Limit - successive readings

5%

Temperature

150°F (65°C)

The terms of this permit require that the JGI comply with the CCCSD Code as well as any other federal, state and local regulations.  Periodic compliance sampling is not required at the JGI.  Instead, the CCCSD has established a requirement for Periodic Compliance Reports where the JGI demonstrates that it has adequate procedures in place to protect sanitary sewer drains from the discharge of prohibited or restricted materials.  JGI staff prepare the reports and submit them to the CCCSD on a semi-annual schedule.

11.3.12  Storm Water Discharges

In accordance with EPA regulations, Berkeley Lab has notified the State Water Resources Control Board (SWRCB) in 1992 that it will comply with the National Pollutant Discharge Elimination System’s General Permit for discharges of storm water associated with industrial activity. This permit requires Berkeley Lab to implement the best available technology that is economically achievable and the best conventional pollution control technology to reduce or eliminate storm water pollution. As a result, Berkeley Lab must:

To implement these requirements, Berkeley Lab has identified and eliminated all unauthorized connections to the storm drains. In addition, outdoor chemical storage areas and transformer pads have been equipped with secondary containment basins. Storm water is monitored during two storms per year, in accordance with the permit, to determine whether the practices employed to reduce and control pollutants are effective. Berkeley Lab also conducts training relevant to storm water concerns for appropriate employees.

As a practical matter, employees must adhere to the above requirements for any outdoor operations involving water, oil, chemicals, or soils. Indoor operations must be designed to preclude escape of contaminants to the exterior, and spills must be reported promptly to allow immediate containment and cleanup.

This program is described in detail in two Berkeley Lab publications, Storm Water Pollution Prevention Plan and the Storm Water Monitoring Plan, which are available on the ESG Web site.

In addition, Berkeley Lab will notify and secure a General Construction Permit from the SWRCB for any projects exceeding one acre in size. Such projects require their own Storm Water Pollution Prevention Plan and the implementation of Best Management Practices that are appropriate for the project.

11.3.13  Underground Storage Tanks

Underground storage tanks (USTs) and systems are stringently regulated by federal and state laws. Regulatory elements address the following aspects of UST system management:

The City of Berkeley enforces the UST regulatory program, consolidating federal, state, and local UST requirements.  Berkeley also coordinates UST requirements with applicable fire code provisions.  In addition, Berkeley Lab’s UST program must also conform to DOE policies.

ESG provides UST compliance support, maintains a documented program, including a UST Monitoring Plan and a UST Emergency Response Plan, and ensures that LBNL’s UST Designated Operators are provided UST compliance training, as required by law.  The Facilities Department, as the tank operator, plays a major role in implementing plans and procedures to ensure compliance with UST and City of Berkeley regulations.  Certified “Designated UST Operators” within the Facilities Division are responsible for conducting monthly inspections of the UST systems and scheduling annual monitor certification, annual product precision line testing, annual mechanical line leak detection testing, annual spill bucket testing, tri-annual secondary containment testing, and annual training to specific facility employees which support UST systems.

Berkeley Lab currently has six operating UST systems.  Four of them store diesel fuel for emergency generators, and the other two are used for unleaded and diesel fuel storage at the Building 76 motor pool.

11.3.14 Waste Minimization and Pollution Prevention

LBNL 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 Order 450.1A, Environmental Protection Program and DOE Order 430.1B, Departmental Energy, Renewable Energy and Transportation Management, DOE requires LBNL to meet goals with objectives and measurable targets that accomplish the following:

Waste minimization and pollution prevention are implemented site-wide by all staff at LBNL in accordance with the environmental policy stated earlier in this chapter. Strategies, measures development, and implementation guidance on waste minimization is provided through the Waste Management Group with the Environmental Services Group providing similar support on pollution prevention.

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. Waste minimization and pollution prevention strategies and measures may include performing pollution prevention opportunity assessments and life-cycle cost analyses. 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.

As part of its Environmental Management System, 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 concerns can be reasonably addressed as follows:

Additional information on waste reduction and pollution prevention measures are found on the ESG and WMG web sites.

11.4  Support Organizations

11.5  Responsible Parties

11.5.1  Principal Investigators and Supervisors

11.5.2  Employees

11.5.3  Environmental Services Group

11.6  Glossary

Acutely hazardous wastes are any wastes defined as acutely hazardous by 22 CCR, Division 4.5, Chapter 11, Article 4.

As low as reasonably achievable (ALARA) is 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 that has the objective of attaining doses as far below the applicable controlling limits as is reasonably achievable.

Bay Area Air Quality Management District (BAAQMD) is 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) is a Department within the California Environmental Protection Agency that regulates hazardous waste management and remedial actions.

East Bay Municipal Utility District (EBMUD) is the local municipal wastewater treatment facility that accepts and regulates sanitary sewer discharges from Berkeley Lab.

Effluent is any treated or untreated liquid discharge from Berkeley Lab or from a Laboratory facility.

Emission is any filtered or unfiltered substance released to the air from Berkeley Lab or from a Laboratory facility.

Environmental monitoring is 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 is 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 is any sudden or sustained deviation from a regulated or planned performance at an operation that has environmental protection and compliance significance.

Environmentally-preferable products, and services are 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 is 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 is any pollutant that is listed in Section 112(b) of the Clean Air Act.

Hazardous wastes are 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.

Life-cycle cost analysis is a procurement evaluation technique that determines the total cost of acquisition, operation, maintenance, and disposal of items being acquired.

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

Public Owned Treatment Works (POTW) is a general term used for sewage treatment plants.  The East Bay Municipal Utility District plant is the POTW that accepts sewage from Berkeley Lab.

Radionuclide is a natural or manmade atom that spontaneously undergoes radioactive decay.

Regulated air pollutants are pollutants for which standards have been promulgated under the authority of the Clean Air Act, and include the classes of substances defined as nitrogen oxides, volatile organic compounds, toxic air contaminants, or ozone-depleting substances.

State Water Resources Control Board (SWRCB) is 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 Regional Water Quality Control Board, with assistance from the City of Berkeley.

Sustainable design means taking a systems approach to design and construction for facilities, systems, and equipment that insures consideration of the optimization of ecological and human issues in light of acceptable economic constraints. Considerations include measures such as 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) is a stationary device designed to contain an accumulation of hazardous material or waste.  A tank is constructed primarily of nonearthen 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 is 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 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

11.7.1  Federal

11.7.2  State

11.7.3  Local

11.8  Related LBNL/PUB-3000 Chapters

11.9  References

All of the above references can be found in the Environmental Services Group offices, located in Building 85B. Several are available on the Web, as noted in this chapter.

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