Chapter 6
SAFE WORK AUTHORIZATIONS

APPENDIX C
Facility-based Authorizations

Approved by John Seabury
Revised 02/08

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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.

Chapter 6 SAFE WORK AUTHORIZATIONS

APPENDIX C Facility-based Authorizations

Chapter 6
SAFE WORK AUTHORIZATIONS

APPENDIX C
Facility-based Authorizations