RPM | REQUIREMENTS AND POLICIES MANUAL

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    Title:

    Environmental Release

    Publication date:

    9/17/2021

    Effective date:

    3/27/2013

    BRIEF

    Policy Summary

    Lawrence Berkeley National Laboratory's (Berkeley Lab's) Environmental Release Policy ensures that significant accidental releases of hazardous materials, pollutants, or chemical agents are properly reported, investigated, and cleaned up.

    Who Should Read This Policy

    Berkeley Lab employees, visitors, affiliates, and subcontractors who work with hazardous materials and wastes, including personnel who transport hazardous materials

    To Read the Full Policy, Go To:

    The POLICY tab on this wiki page

    To Read the ES&H Program Details, Go To:

    ES&H Manual Chapter 51

    Contact Information

    Environmental Release Subject Matter Expert
    Environmental Services Group
    EHS Division

    Title:

    Environmental Release

    Publication date:

    9/17/2021

    Effective date:

    3/27/2013

    POLICY

    A. Purpose

    The Environmental Release Policy at Lawrence Berkeley National Laboratory (Berkeley Lab) ensures that significant accidental releases of hazardous materials, pollutants, or chemical agents are properly reported, investigated, and cleaned up.

    B. Persons Affected

    Berkeley Lab employees, visitors, affiliates, and subcontractors who work with hazardous materials and wastes, including personnel who transport hazardous materials

    C. Exceptions

    None

    D. Policy Statement

    1. Berkeley Lab must report any significant environmental spills or releases of hazardous materials, pollutants, or chemical agents to the appropriate federal, state, and/or local agencies. 
    2. Line organization is responsible for immediately reporting accidental releases and spills of any magnitude that enter the environment.
    3. The Environmental Services Group will investigate all reports of environmental spills or unplanned releases to determine the appropriate reporting and clean-up requirements for each instance (Work Process A, General Requirements).

    E. Roles and Responsibilities

    Role

    Responsibilities

    Principal Investigators and Supervisors

    • Notify the Environment/Health/Safety (EHS) Division immediately of any unplanned environmental releases.
    • Ensure that laws, regulations, and policies pertaining to environmental protection and release reporting are followed.
    • Request technical advice from the Environmental Services Group on appropriate environmental protection requirements and compliance strategies.
    • Provide employee training in operational requirements for preventing environmental releases, and maintain records of such training.
    • Ensure that activities are performed within acceptable operating standards and that any required records are current.

    Employees

    • Take immediate action to stop unplanned releases to the environment, and report all instances of unplanned environmental releases to the EHS Division.
    • Follow applicable laws, regulations, and policies on environmental protection and release reporting.
    • Must be fully aware of the environmental impact of their activities, and comply with all requirements that govern those activities.
    • Adhere to all environmental requirements contained in regulatory agency permits for their activities.
    • 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.
    • Complete all required training provided by supervisors and the EHS Division.

    Environmental Services Group

    • Investigates reports of unplanned environmental releases, and notifies appropriate federal, state, and/or local authorities in a timely manner, as required by regulatory agencies and the DOE.
    • Develops Laboratory policies and procedures to assure that operations are conducted in an environmentally safe manner and fully comply with all applicable environmental laws and regulations and DOE orders.
    • Assesses current and planned Berkeley Lab programs, and assists in defining environmental protection compliance controls and practices.
    • Provides training, makes presentations, and participates in discussions regarding environmental protection practices and releases with Berkeley Lab employees, regulatory agencies, concerned public citizens, community organizations, and the media.
    • Curtails or suspends any operations that pose an immediate hazard to members of the public or to the environment.
    • Evaluates environmental releases to determine the potential impacts to environmental and public health, and the appropriate compliance actions.
    • Coordinates and represents Berkeley Lab activities during follow-up inspections by regulatory agencies and DOE.
    • Responds to information requests from regulatory agencies and the public.
    • Participates in DOE audits of off-site analytical laboratories to ensure the quality of analytical results received for environmental samples.

    F. Definitions/Acronyms

    See the ES&H Manual Environmental Release program for technical terms related to the details of this policy and its implementation.

    Term

    Definition

    As low as reasonably achievable (ALARA)

    An approach to radiological management and control intended 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 is reasonably achievable.

    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

    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 Environmental Protection Agency has listed specific wastes as hazardous that do not necessarily exhibit these characteristics.

    U.S. Environmental Protection Agency

    A federal agency responsible for enforcing environmental laws. In California, some of this responsibility is typically delegated to state and local regulatory agencies.

    G. Recordkeeping Requirements

    Incident reports maintained by the EHS Division

    H. Implementing Documents

    Document Number

    Other Reference Number

    Title

    Type

    07.03.003.001


    Environmental Release

    Program

    07.03.003.002


    Work Process A, General Requirements

    Process

    07.06.002.001


    Emergency Response

    Program


    LBNL/PUB-533

    Berkeley Lab Master Emergency Program Plan (MEPP)

    Plan

    I. Contact Information

    Environmental Release Subject Matter Expert
    Environmental Services Group
    EHS Division

    J. Revision History

    Date

    Revision

    By Whom

    Revision Description

    Section(s) Affected

    Change Type

    1/2/2012

    0

    Pauer

    Rewrite for wiki (brief)

    All

    Minor

    3/27/2013

    1

    Pauer

    Rewrite for wiki (policy)

    All

    Minor

    12/9/2016

    1.1

    Madison

    Minor edits (program name change)

    All

    Minor

    9/1/2021

    1.2

    J. Buehler

    Periodic review

    All

    Minor

    DOCUMENT INFORMATION

    Title:

    Environmental Release

    Document number

    07.03.003.000

    Revision number

    1.2

    Publication date:

    9/17/2021

    Effective date:

    3/27/2013

    Next review date:

    9/17/2026

    Policy Area:

    Incident Review and Reporting

    RPM Section (home)

    ESH

    RPM Section (cross-reference)

    None

    Functional Division

    EHS

    Prior reference information (optional)

    ES&H Manual Section 11.3.1 moved to Chapter 51

    Source Requirements

    • Clean Water Act: Section 307, Toxic and Pretreatment Effluent Standards; and Section 311, Oil and Hazardous Substance Liability
    • Comprehensive Environmental Response, Compensation and Liability Act, Section 102, Hazardous Substances Releases, Liability, Compensation – Reportable Quantities and Additional Designations
    • Resource Conservation and Recovery Act, Section 3001, Identification and Listing of Hazardous Waste
    • Clean Air Act, Section 112, Air Pollution Prevention and Control – Air Quality and Emission Limitations – Hazardous air pollutants
    • Toxic Substances Control Act, Section 7, Control of Toxic Substances – Imminent Hazards
    • California Health and Safety Code, Section 25501

    Implementing Documents

    Document Number

    Other Reference Number

    Title

    Type

    07.03.003.001


    Environmental Release

    Program

    07.03.003.002


    Work Process A, General Requirements

    Process

    07.06.002.001


    Emergency Response

    Program


    LBNL/PUB-533

    Berkeley Lab Master Emergency Program Plan (MEPP)

    Plan



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