Chapter 11
ENVIRONMENTAL PROTECTION

Contents

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

____________________

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:

• achieving compliance with all applicable laws, regulations and requirements,
• minimizing waste and preventing pollution,
• aggressively correcting and cleaning up existing environmental problems, and
• continually improving environmental performance

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:

• Accidental releases
• Air emissions
• Environmental Management System
• Environmental radiological dose assessment
• Environmental monitoring
• Hazardous wastewater treatment units
• Petroleum products storage
• Sanitary sewer discharges
• Storm water discharges
• Underground storage tanks

11.3  Program Description

11.3.1  Accidental Releases

Various DOE orders and federal, state, and local laws and regulations require Berkeley Lab to report any significant spills or releases of hazardous materials, pollutants, or chemical agents to the environment.  To implement these requirements, the following procedure has been developed:

• The line organization is responsible for immediately reporting accidental releases and spills of any magnitude that enter the environment. For emergency cases, the initial report should be made to the Fire Department by dialing ext. 7911.  For accidental spills or releases that do not require emergency responses by the Fire Department, call the EH&S emergency contact at ext. 6999.  See also Reporting an Emergency and Hazardous Material Spill or Release in Chapter 9 of PUB-3000.
• ESG will investigate all reports of environmental spills or unplanned releases to determine the appropriate reporting level for each instance.  Notification may be sent to DOE and various federal, state, and local agencies. 

For complete descriptions of emergency procedures, refer to the Berkeley Lab Master Emergency Plan, LBNL/PUB-533.

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:

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:

• Main Site
• Joint Genome Institute (Walnut Creek)

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:

• Identifying and notifying ESG of unpermitted existing, new, and planned activities that emit materials to the air, either directly or through exhaust systems.
• Notifying ESG of any upcoming equipment or process modifications, location changes, or changes in chemical usage that may affect permit status.
• Complying with permit conditions and operating standards.
• Submitting related information in a timely manner to ESG for use in evaluating sources, preparing permit/exemption request applications, renewing permits, and responding to violation notices.
• Maintaining complete and accurate records required by regulations and/or the Permit to Operate.
• Being available during both BAAQMD inspections, or DOE and ESG audits, and providing any information requested by ESG personnel.

11.3.3  Environmental Management System

Executive Order 13148, Greening the Government through Leadership in Environmental Management, required all federal agencies to implement an Environmental Management System (EMS) by December 31, 2005. An EMS is simply a systematic approach to achieving environmental goals. DOE Order 450.1, 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 developed and implemented a performance-based EMS a systematic approach to ensuring that environmental stewardship activities are not only well managed but also provide business value. The performance-based approach is one that includes those components of the ISO 14001 EMS Standard that provide real and tangible business value. This approach will allow 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:

• Comply with applicable environmental and public health laws and regulations.
• Prevent pollution and conserve natural resources.
• Continually improve the Laboratory’s environmental performance.

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:

• Identification of aspects and impacts - environmental aspects (activities or services that may produce a change to the environment) resulting from LBNL operations have been identified within the categories of waste generation, emission and discharges to the environment, materials/resources use, and land/building development and use. The impacts associated with each aspect were determined and these aspects/impacts were then ranked according to their environmental significance.
• Development of objectives and targets - The activities with the most significant impacts identified were selected, and objectives and targets were developed for reducing their environmental impacts.
• Preparation of Environmental Management Programs (EMPs) - Action plans were prepared for each of the significant areas of improvement that summarize how the objectives and targets will be achieved, including time-scales and personnel responsible for implementing the appropriate actions.

Internal assessments and external audits will be performed to evaluate the effectiveness of LBNL’s EMS. The EMS program will be audited by the Lab's Office of Contract Assurance and audited by a third party to determine if all programmatic activities were 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 reviews will be reviewed by a Laboratory management team.

11.3.4  Environmental Radiological Dose Assessment

Dose assessment for radiological air emissions conforms to the standard prescribed in the National Emission Standards for Hazardous Air Pollutants (NESHAPs) for radionuclide emissions, promulgated as a result of the Clean Air Act (40 CFR 61, Subpart H). NESHAPs compliance is enforced by the United States Environmental Protection Agency (EPA), Region 9, and inspections are conducted periodically by EPA personnel. Compliance with NESHAPs is also required by DOE, as established in DOE Order 5400.5, "Radiation Protection of the Public and the Environment." DOE personnel can inspect the Berkeley Lab for NESHAPs compliance.

The NESHAPs regulation requires that DOE facilities limit radiation doses tooffsite individuals to less than 10 mrem per year from airborne releases of radionuclides.  Exposures to doses of a hypothetical maximally exposed member of the public are determined, as well as the sum of all exposures to the population within a 80 km (50 mile) radius of Berkeley Lab.  The dose assessments are performed using computer models that have been approved by EPA.

In addition to limiting dose from airborne radionuclides, the DOE (in DOE 5400.5) also limits the dose to members of the public from all exposure pathways affected by Laboratory operations to less than 100 mrem per year. Berkeley Lab must report to DOE doses from any single exposure pathway that exceeds 10 mrem per year.

DOE requirements also provide for the protection of biota in the environment. Specifically, the exposure limit for native aquatic organisms is 1 rad per day (DOE 5400.5), for terrestrial animals the exposure limit is 0.1 rad per day (DOE-STD-1153-2002), and for terrestrial plants the exposure limit is 1 rad per day (DOE-STD-1153-2002). At Berkeley Lab, the dose to biota is assessed annually and is reported in the annual Site Environmental Report.

Berkeley Lab meets radiation dose limits by ensuring that doses to the public and the environment are kept as low as reasonably achievable (ALARA). The Environmental Services Group maintains an Environmental ALARA Program Plan, which implements the DOE’s ALARA policy.
Berkeley Lab employees play an important role in this process by providing accurate and up-to-date information on their radionuclide use. The dose assessment results are reported in the Site Environmental Report and the Annual NESHAPs Report. These reports are distributed to DOE and regulatory agencies and are available on the Web at the ESG Web site.

11.3.5  Environmental Monitoring

The Berkeley Lab's environmental monitoring program helps to ensure that Lab activities are conducted in a manner that will protect public health and maintain environmental quality.  The program is designed to demonstrate compliance with requirements imposed by federal, state, and local regulatory agencies; confirm adherence to DOE environmental protection requirements; and support environmental management decisions.  Regulatory oversight is performed by a number of external agencies, including:  DOE, the United States Environmental Protection Agency, the California Department of Toxic Substances Control, the California Department of Health Services, the Regional Water Quality Control Board, the East Bay Municipal Utility District, the Bay Area Air Quality Management District, and the City of Berkeley.
Environmental monitoring activities at Berkeley Lab consist of four major activities:

• Effluent Monitoring: The collection and analysis of samples, or measurements of liquid and gaseous effluents for the purpose of characterizing and quantifying contaminants, assessing radiation exposures to members of the public, providing a means to control effluents at or near the point of discharge, and demonstrating compliance with applicable standards and permit requirements.
• Environmental Surveillance: The collection and analysis of samples, or direct measurements, of air, water, soil, foodstuff, biota, and other media from the Berkeley Lab site and its environs for the purpose of determining compliance with applicable standards and permit requirements, assessing radiation exposures to members of the public, and assessing the effects, if any, on the local environment.
• Meteorological Monitoring:  The collection of representative meteorological data to characterize atmospheric transport and diffusion conditions in the vicinity of the Berkeley Lab, and to represent conditions that are important to environmental surveillance activities, such as air quality monitoring and exposure assessments.
• Pre-operational Monitoring:  An environmental study conducted prior to the startup of a new facility, or a process for the purpose of establishing a baseline for environmental conditions.

The program is described in detail in the Berkeley Lab publication, Environmental Monitoring Plan.  The ESG prepares, implements, and maintains the Environmental Monitoring Plan, and performs the environmental monitoring activities.

Information regarding environmental monitoring activities is reported annually in the Berkeley Lab Site Environmental Reports.  The more recent reports are separated into two volumes.  Volume I summarizes environmental monitoring results, compares the results to regulatory limits, and discusses environmental impacts to the public and the local environment.  Volume II contains individual data results from effluent and surveillance activities.

In addition, meteorological monitoring data is collected every fifteen minutes from a 20-meter weather tower that is located onsite.  The tower measures wind speed, wind direction, temperature, dew point, barometric pressure, solar radiation, and precipitation.  The data can be obtained here in either graphical or tabular form.  Please note that data collected from this site have not been validated and should be considered preliminary.

11.3.6  Contaminated Soil and Groundwater Management

Many types of chemicals have been used or produced as wastes over the more than 60 years of Berkeley Lab operations.  Some of these chemicals were released to the environment, mostly from spills and leaks that occurred decades ago.  Since that time, Berkeley Lab has implemented internal policies and procedures to prevent these types of occurrences and protect the environment.

In May 1993, Berkeley Lab was issued a Hazardous Waste Facility Permit by the California Department of Toxic Substances Control (DTSC).  One of the conditions of the permit required LBNL to investigate and clean up all historical releases of hazardous chemicals in accordance with the requirements of the Resource Conservation and Recovery Act (RCRA).  Berkeley Lab conducted an investigation which determined that contaminants in the soil and/or groundwater included chlorinated volatile organic compounds (CVOCs) used as solvents, polychlorinated biphenyls (PCBs), petroleum hydrocarbons, polynuclear aromatic hydrocarbons (PAHs), semivolatile organic compounds (SVOCs), metals, pesticides, and radionuclides The results of the investigation are documented in the RCRA Facility Investigation (RFI) Report.

In consultation with regulatory agencies, Berkeley Lab implemented cleanup measures at the more seriously contaminated areas.  These measures included removing sources of contamination, stopping discharge of contaminated groundwater to surface waters, eliminating the migration of contaminants, and installing groundwater treatment systems.  Additional details regarding the soil and groundwater cleanup remedies can be found in the Corrective Measures Study Report.  

Based on the results of the investigation and the initial cleanup measures, Berkeley Lab conducted human health and ecological risk assessments (HHRA and ERA) to evaluate whether the remaining contaminants in soil or groundwater had the potential to cause harm to human health or wildlife.  The HHRA was completed based on the assumption that Berkeley Lab would continue to operate as a research laboratory for the foreseeable future.  (However, as required by the regulatory agencies, it also provided a supplemental evaluation of potential risks based on hypothetical and unlikely residential land-use of the site.)  The HHRA concluded that the levels of soil and groundwater contaminants did not present potential health hazards to Berkeley Lab employees and contractors unless: 

• Workers are engaged in ground penetration activities in specific areas where they may come into direct contact with contaminated soil or groundwater, or
• future workers occupy new buildings constructed over these areas, where they could potentially be exposed to migrating soil vapor originating from chemicals in the groundwater. 

The HHRA also identified the areas of groundwater contamination that posed potential risks in the unlikely event that groundwater was used for domestic purposes.  The risk assessments concluded that no hazards existed to plants, animals, or offsite individuals, from exposure to chemicals in the soil, groundwater, or surface water. 

Due to potential health risks from the soil and groundwater contamination, LBNL was required to perform additional clean up of the soil and groundwater.  In addition, LBNL was required to submit a Soil Management Plan and a Groundwater Monitoring and Management Plan to the DTSC.  These management plans describe the nature and extent of the contamination, procedures for the management and disposal of contaminated waste soils, and the institutional controls that are required to reduce potential risk from exposure to the contaminants until the final cleanup goals are reached.  In addition, the Groundwater Monitoring and Management Plan provides the requirements for ongoing groundwater and surface water monitoring, which are performed by EH&S's Environmental Services Group.  Both plans were approved by DTSC in September 2006. 

The soil and groundwater management plans specify that the following institutional controls will be used to reduce potential risks from exposures to contaminated soil and groundwater, and from impacts to the environment:

• Groundwater Use:  Where groundwater contaminant concentrations exceed detectable levels, groundwater may not be used for drinking or other domestic purposes.  Unless treated prior to use, contaminated groundwater may not be used for industrial, irrigation, or other nondomestic purposes.
• Land Use:  Areas considered potentially unsuitable for institutional use and for residential use have been identified.  New buildings intended for human occupancy cannot be constructed in those areas unless measures are implemented (e.g., building vapor barriers or completing additional cleanup) to mitigate the potential risks, or additional data are collected to show that the risks are within acceptable levels.  Soil-gas sampling, for example, is a method that may be used to help document that risks to indoor workers would be within acceptable levels should a new building be constructed.  DTSC may eventually impose a land use covenant (LUC) (deed restriction) for the areas considered unsuitable for residential land use.  No residential construction would be permitted in those areas without a modification to the LUC.
• Soil Excavation:  Prior to surface penetrations, a Permit to Penetrate Ground or Existing Surfaces of LBNL Property must be obtained in accordance with the requirement of Facilities' Administrative Procedure (ADMN-053).  This permit requires that the responsible individual/project manager notify the EH&S Environmental Services Group (ESG) to initiate a preconstruction site evaluation.  The ESG will then determine:

• The nature and extent of any contamination known or suspected to be present in the soil; and
• Whether any preconstruction soil sampling is required.

Soil cleanups have been completed, eliminating the known hazards to construction workers.  However, if contaminated soil is unexpectedly encountered, excavation must be stopped, and ESG must be contacted to perform a hazard evaluation. 

• Soil Disposal:  Soil that is contaminated, but below hazardous thresholds, will be disposed of in a Class II or other acceptable landfill, depending on the acceptance criteria of the landfill.  A Class III landfill may accept the soil depending on the type and concentration of the contaminant.  The landfill may require analytical testing of the soil to document that chemical concentrations do not exceed their waste acceptance criteria. Clean excavated soil will be reused onsite to the extent practicable.  When not practicable, clean soil should be sent to a Class III or other acceptable landfill. It is not anticipated that soil containing contaminants at hazardous levels will be encountered; however, should that be the case, the Waste Management Group should be contacted for instructions on waste handling and disposal requirements.

• Groundwater Extraction: Activities that may encounter contaminated groundwater must have written procedures for site monitoring, spill contingency and treatment, and discharge for any extracted groundwater.  If contaminated groundwater must be extracted, it should be captured and treated prior to being routed to a permitted discharge point.  Discharges to the sanitary sewer must comply with the provisions of the East Bay Municipal Utility District wastewater discharge permit.   Where ESG determines there is a potential risk to construction workers from the groundwater, plans must be prepared to document worker protection and training requirements.

In parallel with the DTSC RCRA process, the Department of Energy (DOE) also required the Lab to investigate and address historical releases of radionuclides.  A Summary of Radionuclide Investigations report was prepared and submitted to DOE in September 2003.  Based on the investigation results, DOE determined that no corrective actions were required; however, DOE specified restrictions on the use of eight identified units or areas.  For the two inactive and abandoned radioactive waste storage tanks at Building 74, a prohibition was placed on the release of the structure, equipment, or area from any existing controls.  For five other radiological units (units at Buildings 71, 5 [2 units], 4, and 75), release of these areas to the general public was prohibited.  The eighth area, the Building 75A Radioactive Waste Storage Area, was specifically designated for reuse by the Berkeley Lab Radiation Protection Group. 

The only radionuclides detected in the soil that are above background levels are tritium and curium-244.  These contaminants were detected at concentrations below levels that pose risks to human health or the environment.  Soil with concentrations of radionuclides above background levels, however, should be disposed of in a facility licensed for Class A low-level radioactive wastes.  Approval for disposal of radioactive contaminated soil must be obtained from DOE prior to offsite transport.  The only radionuclide contaminant detected in the groundwater is tritium.  The tritium levels in the groundwater have been declining and are currently less than the allowable Maximum Contaminant Level (MCL) for drinking water. (Note: Groundwater at LBNL is not used as a public drinking water source).

11.3.7  Hazardous Wastewater Treatment Units

Berkeley Lab operates five hazardous wastewater treatment units, or fixed treatment units (FTUs). These are: 

• Building 2 — acid wastewater
• Building 25 — acid wastewater with metals
• Building 70A — acid wastewater
• Building 76 — oily wastewater
• Building 77 — acid wastewater with metals

The wastewater is treated to meet the East Bay Municipal Utility District’s discharge limits and then is discharged to the sanitary sewer.
State law requires all facilities treating hazardous waste to obtain authorization from DTSC and the City of Berkeley.  DTSC has created a tiered permitting program, based on environmental risk, as the permitting process to gain authorization to operate.  The FTUs located at Buildings 25 and 77 have received authorization to operate under the Permit-by-Rule tier.  The FTUs located at Buildings 2, 70A, and 76 are permitted to operate under the Conditional Authorization tier.

ESG has prepared and maintains permit documentation, including notifications and plans required by the tiered permit program.  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 DTSC.

Permit-by-Rule and Conditional Authorization FTUs have the following operation requirements for which the operators of these units are responsible:

• Recording dates, amounts, and types of waste treated; and submitting a quarterly report of wastewater treated to ESG.
• Preparing inspection logs that document maintenance activities.
• Complying with hazardous waste generator operating standards.
• Ensuring that primary operators have received OSHA 24-hour training for hazardous-waste workers and that these operators annually take an 8-hour refresher training course for hazardous waste workers.
• Maintaining worker training files.
• Informing ESG of any new process waste streams or new treatment processes.
• 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).

When a new FTU is planned, DTSC, the City of Berkeley, and the East Bay Municipal Utility District (EBMUD) must be notified 60 days before the first treatment of waste begins. The permit submission must include:

• A completed Facility Specific Notification form
• A completed Unit Specific Notification form
• A description of the treatment process
• Drawings of the treatment system, including tanks, containers, secondary containment, and leak detection (as-built drawings preferred)
• Tank and containment system certification obtained from an independent, qualified professional engineer, registered in California
• A certification specifying the local agencies that have been notified

Planning should take into account the 60-day lag time that DTSC requires to process the permit.  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.  In addition, planning should allow two to four months for the preparation of the permit.  Preparation time will vary depending on the complexity of the treatment unit and whether the independent engineer identifies that upgrades are needed.

When there is a change to an existing treatment unit, a permit amendment must be submitted to DTSC, the City of Berkeley, and EBMUD. The permit amendment submission may include all the items listed for a new permit. Planning should allow two to four months for the preparation of the permit amendment. Once proof of receipt of the permit amendment has been received from DTSC, treatment of the waste may begin.

11.3.8  Petroleum Products Storage

Petroleum product storage requirements are prescribed by federal regulations, which are driven by the Clean Water Act; hazardous material storage requirements, which are determined by DOE orders; and best management practices. Petroleum products stored in 55-gallon drums or tanks are governed by these requirements. The principal requirements include:

• The material must be stored in tanks or containers of approved design and construction.
• The tanks or drums must have approved double containment capable of holding the entire contents of the largest single tank plus sufficient freeboard to allow for precipitation. (Berkeley Lab uses a 25-year, 24-hour, storm event of 4.78 inches as sufficient freeboard.)
• Berkeley Lab Facilities Department has a formal rainwater disposal procedure for inspecting and testing accumulated rainwater prior to discharge.
• The storage facility must be covered by routine maintenance and inspection programs.
• Users of bulk storage facilities must receive annual training.

The details of the petroleum storage requirements are described in the Berkeley Lab Spill Prevention, Control and Countermeasures Plan, which is available on the ESG Web site.

11.3.9  Polychlorinated Biphenyls (PCBs) Management

In general, oil-filled electrical equipment of unknown content should be assumed to contain polychlorinated biphenyls (PCBs). Oil-filled electrical equipment that may contain PCBs includes (but is not limited to) transformers, capacitors, circuit breakers, reclosures, voltage regulators, switches, motor starters, and electromagnets. If a piece of oil-containing equipment is to be disconnected and not reused, please contact Waste Management early in the planning stages so Waste Management can set up the waste accumulation area (WAA) and arrange shipment to meet regulatory requirements.

If the waste is known to have PCBs at a concentration of 50 parts per million (ppm) or greater, or contains waste from a PCB spill cleanup, the accumulation time in the generator satellite accumulation area (SAA) or WAA is 30 days.

When new large capacitors are purchased, it is recommended that the owner place a “non-PCB” label on the capacitor. A large capacitor is a capacitor that contains more than 3 pounds or 30 liquid ounces of dielectric fluid. When a new transformer is purchased, it is recommended that a “dry type” transformer be specified over an oil-filled transformer whenever possible. If an oil-filled transformer is purchased, it is recommended that the owner place a “non-PCB” label on the transformer. If a used transformer is obtained from another facility, the transformer must not contain PCBs greater than 5 ppm, and the transformer must have supporting documentation proving that the transformer does not have any PCBs above this threshold.

11.3.10  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 units 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

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

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 for the discharge of prohibited or restricted materials.  JGI staff prepare the reports and submit them to the CCCSD on a semi-annual schedule.

11.3.11  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:

• Maintain an effective and appropriate storm water drainage system.
• Assure that no water other than storm water enters the storm water drainage system other than SWRCB-approved non–storm water discharges from activities such as irrigation, fire sprinkler testing, and air conditioner condensate.
• Collect, monitor, and properly dispose of all non–storm water.
• Identify all operations that could cause contamination of storm waters, and take appropriate corrective measures.

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.

11.3.12  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:

• Registration and operating permits
• Construction standards—double containment and overfill protection
• Monitoring and leak detection
• Integrity testing
• Release recording and reporting
• Closure — temporary and permanent
• Cleanup of contaminated sites

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 and Emergency Response Field Manual, and provides 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, and tri-annual secondary containment testing.

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.

11.4  Support Organizations

• Facilities Division
• Engineering Division

11.5  Responsible Parties

11.5.1  Principal Investigators and Supervisors

• Ensure that environmental laws and regulations 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 EH&S Division immediately of any unplanned accidental releases or spills.

11.5.2  Employees

• Are fully aware of the environmental impact of their own 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.
• Ensure that exposures of the public and the environment to radioactive emissions are kept as low as reasonably achievable (ALARA).
• Participate in energy conservation, recycling, and pollution-prevention programs.
• Take immediate action to stop unplanned releases to the environment, and report all instances of unplanned environmental releases to the EH&S Division.
• Complete all required training provided by supervisors and the EH&S 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 protection compliance upgrades and corrective actions.
• Identifies significant institutional environmental compliance issues, and develops cost-effective mechanisms for resolving them.
• Performs environmental dose assessments to document that radiation doses to the public are maintained well below the applicable standards and regulations. 
• Prepares budget requests for, and manages, environmental protection upgrades and corrective actions for institutional projects.
• Provides training, makes presentations, and participates in discussions regarding environmental protection matters with Berkeley Lab employees, regulatory agencies, concerned public citizens, community organizations, and the media.
• Manages the preparation of environmental operating permit applications.
• Curtails or suspends any operations that pose an immediate danger to members of the public or the environment.
• Monitors laboratory emissions and discharges to the environment to verify compliance with applicable regulations and permits.
• Investigates reports of unplanned environmental 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 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.

11.6  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.

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.

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.

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.

11.7  Standards

11.7.1  Federal

• Office of Management and Budget, Circular A-106, Pollution Abatement
• 40 CFR, Part 61, Subpart H, National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities
• 40 CFR, Part 112, Oil Pollution Prevention
• 40 CFR, Part 122, Federal Storm Water Discharge Requirements
• 40 CFR, Part 136, Guidelines Establishing Test Procedures for the Analysis of Pollutants (under the Clean Water Act)
• 40 CFR, Part 141, Safe Drinking Water Act
• 40 CFR, Parts 260-272, Resource Conservation and Recovery Act (Hazardous Waste Regulations)
• 40 CFR, Part 403, Federal Pretreatment Regulations
• 40 CFR, Part 433, Metal Finishing Point Source Category
• Clean Air Act (42 U.S.C. Section 7401 et seq.)
• Clean Water Act (33 U.S.C. Section 1151 et seq.)
• Comprehensive Environmental Response, Compensation, and Liability Act (42 U.S.C. Section 1601 et seq.)
• Resource Conservation and Recovery Act (42 U.S.C. Section 6901 et seq.)
• Toxic Substance Control Act (15 U.S.C. Section 2601 et seq.)
• DOE Order 5000.3A, Occurrence Reporting and Processing of Operations Information
• DOE Order 450.1, General Environmental Protection Program, paragraph 1 - Objectives
• DOE Order 5400.5, Radiation Protection of the Public and the Environment, Chapter II, paragraphs 1 (not including 1.a.3.c and 1.c), 2, 5, 6 (not including 6.a), 7, and 8.a, and Chapter IV
• DOE Order 414.1, Quality Assurance

11.7.2  State

• CCR, Title 17, Section 30253, Standards for Protecting Against Radiation
• CCR, Title 17, Section 30287 and 30288, Disposal by Release into Sanitary Sewers (Radionuclides)
• CCR, Title 22, Division 4.5, Environmental Health Standards for the Management of Hazardous Waste, Sections 66001-67800.5
• CCR, Title 23, Division 3, Chapter 16, Underground Storage Tank Regulations
• Air Toxics “Hot Spots” Information and Assessment Act (California Health and Safety Code Section 44300 et seq.)
• California Clean Air Act (California Health and Safety Code Section 39000 et seq.)
• Hazardous Waste Control Law (California Health and Safety Code Section 25100 et seq.)
• Hazardous Waste Source Reduction and Management Review Act (California Health and Safety Code Section25244.12 et seq.)
• Petroleum Storage Act (California Health and Safety Code Section 25270 et seq.)
• Petroleum Underground Storage Tank Cleanup (California Health and Safety Code Section 25299.10 et seq.)
• Porter-Cologne Water Quality Control Act (Water Code Section 13000 et seq.)
• Safe Drinking Water and Toxic Enforcement Act (California Health and Safety Code Section 25249.5 et seq.)
• Toxic Air Contaminants Law (California Health and Safety Code Section 44300 et seq.)
• Underground Storage of Hazardous Substances (California Health and Safety Code Section 25280 et seq.)

11.7.3  Local

• Bay Area Air Quality Management District Rules and Regulations
• City of Berkeley Toxics Management Program
• San Francisco Bay Basin Plan and Amendments, Regional Water Quality Control Board
• East Bay Municipal Utility District Waste Water Control Ordinance No. 311A-03
• City of Berkeley Storm Water Pollution Reduction Ordinance No. 6216

11.8  Related LBNL/PUB-3000 Chapters

• Emergency Management  (Chapter 9)
• Fire Prevention and Protection  (Chapter 12)
• Hazardous Waste Disposal  (Chapter 20)

11.9  References

• Accidental Spill Prevention and Containment Plan, Environmental Services Group, Berkeley Lab
• Air Emission Permits to Operate, Bay Area Air Quality Management District
• Corrective Measures Study Report, Environmental Restoration Program, Berkeley Lab
• Environmental Monitoring Plan, Environmental Services Group, Berkeley Lab
• General Permit for Discharges of Storm Water Associated with Industrial Activity, State Water Resources Control Board
• Groundwater Monitoring and Management Plan, Environmental Restoration Program, Berkeley Lab
• Berkeley Lab Master Emergency Plan, Berkeley Lab, LBNL/PUB-533
• Performance-Based Environmental Management System Plan, LBNL/PUB-3180, Environmental Services Group, Berkeley Lab
• RCRA Facility Investigation Report, Environmental Restoration Program, Berkeley Lab
• Site Environmental Report, Environmental Services Group, Berkeley Lab
• Soil Management Plan, Environmental Restoration Program, Berkeley Lab
• Spill Prevention, Control, and Countermeasures Plan, Environmental Services Group, Berkeley Lab
• Storm Water Monitoring Plan, Environmental Services Group, Berkeley Lab
• Storm Water Pollution Prevention Plan, Environmental Services Group, Berkeley Lab
• Summary of Radionuclide Investigations, Environmental Restoration Program, Berkeley Lab
• UST Monitoring and Emergency Response Manual, Environmental Services Group, Berkeley Lab
• Wastewater Discharge Permits, East Bay Municipal Utility District

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.

_____________________

<< Chapter 10 || Table of Contents || Chapter 12 >>