Chapter 6
SAFE WORK AUTHORIZATIONS

APPENDIX C
Facility-based Authorizations

Approved by John Seabury
Revised 02/08

NOTE:
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Hazard/Concern


Trigger Level

Formal Authorization Type

Additional Information

General onsite and/or offsite environment, health, or safety risks

In excess of those already accounted for in LBNL’s NEPA and CEQA documentation

SEIR, addendum to the SEIR, and other NEPA and CEQA documents

Contact Facilities Planning Group for NEPA/CEQA analysis

Acquisition is covered by DOE Capital Asset Acquisition Process DOE O 413.3A

Hazard Analysis Report[1]

DOE Order 413.3A

Air emission of pollutant(s) into the environment

Non-radioactive material

Bay Area Air Quality Management District permit requirements review; possible specialized training

PUB-3000 — Chapter 11.3.1

Radioactive material

Permit (regulatory)
EPA National Emission Standard for Hazardous Airborne Pollutants (NESHAPs) offsite dose assessment

PUB 3000 — Chapter 11.3.2

Asbestos removal/abatement

>100 sq ft or >100 linear ft or > 35 cu ft

BAAQMD (NESHAPS) 10 day notification

Bay Area Air Quality Management District Regulation 11, Rule 2

Chemicals

Discharges to the sanitary sewer system (sink, drain) in excess of permitted limits

East Bay Municipal Utility District Discharge Permit

PUB 3000 — Chapter 11.3.8
Contact EH&S Division, Environmental Services Group

Emissions/use in excess of listed quantities in Bay Area Air Quality Management District regulations

BAAQMD Permit to Operate
Process Hazards Analysis

Bay Area Air Quality Management District regulations

Storage/use in excess of Threshold Quantities listed in the OSHA Process Safety Management regulation

Process Hazard Analysis

29 CFR 1910.119 — Chemical Process Safety Management

Storage/use in excess of planning quantities listed in the State of California Accidental Release Program (CalARP) (Note: includes federal substances)

Risk Management Plan (RMP)

California Regulated Substances and Quantities

Use/handling/emissions in excess of National Emission Standard for Hazardous Air Pollutants or Stationary Source limits

NESHAPS permit (Environmental Protection Agency)

Contact EH&S Division, Environmental Services Group

Radiation or radioactive materials

Accelerators - External radiation level thresholds listed in DOE Order 420.2

Accelerator-based Safety Analysis Document (SAD)

PUB 3000 — Chapter 21
DOE Order 420.2B

Discharges to the sanitary sewer system (sink, drain) in excess of permitted limits

East Bay Municipal Utility District Discharge Permit

PUB 3000 — Chapter 11.3.8
Contact EH&S Division, Environmental Services Group

Storage/use in excess of Category 3 limits (Nuclear Facility Limits)[2]

Safety Analysis Review

DOE STD 1027.92 (advisory)
Contact EH&S Division, Radiation Protection Group, for radionuclides not included in DOE STD 1027.92

Use/handling/emissions in excess of National Emission Standard for Hazardous Air Pollutants or Stationary Source limits

NESHAPS permit (Environmental Protection Agency)

PUB 3000 — Chapter 11
Contact EH&S Division, Environmental Services Group

Storm drain discharge

Any discharge (including pollutants and sediments) to the storm drain system other than rainwater

State Water Resources Control Board General Industrial Permit

PUB 3000 — Chapter 11.3.9
Use best management practices

Waste, generation or treatment of

Hazardous or hazardous component of mixed

Storage in excess of 90 days in a Waste Accumulation Area or storage of > 55 gal for > 1 year in a Satellite Accumulation Area

Treatment, Storage, and Disposal Facility (California Department of Toxic Substances Control)

California Code of Regulations, Title 22, Section 66260.1 et seq. (Hazardous Waste Regulations)

Radioactive or radioactive component of mixed

Radioactive Waste Management Basis (Department of Energy)

DOE Order 435.1 (only those sections/ subchapters adopted in the current LBNL Work Smart Standards set) Mixed waste is subject to the Hazardous Waste regulations (see above) in addition to the radioactive waste regulations

On-line treatment (e.g., acid neutralization)

Fixed Treatment Unit permit (various types) – City of Berkeley

Contact EH&S Division, Environmental Services Group
PUB 3000 — Chapter 11
29 CFR1910.120 — Hazardous Waste Operations and Emergency Response



Notes:

1. The term “Hazard Analysis Report” was finalized under the 2006 revision of DOE O 413.3A and specifically applies to non-nuclear facilities (below Hazard Category 3 threshold as defined in 10CFR 830, Supbart B). In previous versions of this order and the repealed DOE O 5481.1B the term varied, and documents prepared at LBNL over the years have been named “Safety Analysis Document” and “Operational Hazards Analysis Report”. None of these documents are “Safety Analysis Document” in the context of nuclear facilities (LBNL is not and does not have nuclear facilities), and functionally, they are the same as the “Hazard Analysis Report” per DOE O 413.3A.

2. For any facility in which radionuclides will be stored and/or used, it must be specifically documented that these limits (individually and sum of fractions) will or will not be exceeded. EH&S and the division will prepare this analysis, which is submitted to Facilities to become part of the permanent planning record for that facility.

 

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