Fixed Treatment Units

Title:	Fixed Treatment Units
Publication date:	9/13/2021
Effective date:	3/27/2013

BRIEF

Policy Summary

Lawrence Berkeley National Laboratory (Berkeley Lab) maintains Fixed Treatment Units (FTUs) to protect the surrounding environment, minimize waste handling, and maintain compliance with East Bay Municipal Utility District (EBMUD) discharge limits. The Laboratory achieves this by:

Maintaining permits for the FTUs on-site.
Maintaining operating records required by the state of California.
Submitting periodic compliance reports to EBMUD.
Ensuring that operators are properly and adequately trained.
Informing EBMUD and the city of Berkeley of new waste streams, new treatment units, or other changes to the process or treatment units.

Who Should Read This Policy

All Berkeley Lab employees, visitors, affiliates, and subcontractors who discharge to, or maintain records for, the FTUs located in Buildings 2, 67, 70A, and 77

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 53

Contact Information

Waste: Water Treatment Units Subject Matter Expert
Environmental Services Group
EHS Division

Title:	Fixed Treatment Units
Publication date:	9/13/2021
Effective date:	3/27/2013

POLICY

A. Purpose

Lawrence Berkeley National Laboratory (Berkeley Lab) maintains Fixed Treatment Units (FTUs) to protect the surrounding environment, minimize waste handling, and maintain compliance with East Bay Municipal Utility District (EBMUD) discharge limits. The Laboratory achieves this by:

Maintaining permits for the FTUs on-site, and entering permit information into the California Environmental Reporting System (CERS).
Maintaining operating records required by the state of California.
Submitting periodic compliance reports to EBMUD.
Ensuring that operators are properly and adequately trained.
Informing EBMUD and the city of Berkeley of new waste streams, new treatment units, or other changes to the process or treatment units.

B. Persons Affected

All Berkeley Lab employees, visitors, affiliates, and subcontractors who discharge to, or maintain records for, the FTUs located in Buildings 2, 67, 70A, and 77

C. Exceptions

None

D. Policy Statement

Berkeley Lab operates four hazardous-wastewater-treatment units, or FTUs.
State law requires all facilities treating hazardous waste to obtain authorization from the Department of Toxic Substances Control (DTSC) and the city of Berkeley.
The Environmental Services Group (ESG) has prepared and maintains permit documentation, including notifications and plans required by the tiered permitting program.
When a new FTU is planned, the city of Berkeley and EBMUD must be notified 60 days before the first treatment of waste begins.
When there is a change to an existing treatment unit, a permit amendment must be submitted to the city of Berkeley and EBMUD (Work Process A, General Requirements).

E. Roles and Responsibilities

Role	Responsibilities
Principal investigators and supervisors	Ensure that environmental laws, regulations, and policies are followed. Request technical advice on environmental requirements and appropriate compliance strategies from ESG. Provide employee training in operational requirements for hazardous waste treatment and maintain records of such training. Training must include the 24-hour Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) with an annual eight-hour refresher. Ensure that FTU operation follows acceptable written operating procedures and that any required records are current (FTU daily log and monthly calibration records). Notify EBMUD and the EHS Division within 30 minutes of any unplanned accidental releases to the sanitary sewer. Take immediate action to stop the release. Prepare budget requests for and manage environmental protection upgrades and corrective actions for institutional projects
Employees	Follow applicable environmental laws, regulations, and policies. Remain 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 the Laboratory's city of Berkeley and EBMUD permits for their facility. Perform activities within acceptable operating standards, and maintain current records whenever required. Participate in energy-conservation, recycling, pollution-prevention, and waste-minimization programs. Take immediate action to stop unplanned releases to the sanitary sewer, and report all instances of unplanned wastewater discharges to EBMUD and EHS within 30 minutes of the release. Complete all required training provided by supervisors and EHS.
Environmental Services Group	Develops Laboratory policies and procedures to assure that operations are conducted in an environmentally safe manner and that they fully comply with all applicable environmental laws and regulations. Prepares environmental compliance reports as required by the city of Berkeley and EBMUD; prepares EBMUD permit. Assesses current and planned Berkeley Lab programs, and helps to define environmental protection compliance upgrades and corrective actions. Makes presentations and participates in discussions regarding FTU matters with Berkeley Lab employees, the city of Berkeley, DTSC, and EBMUD. Manages the preparation of FTU operating permit applications, permit amendments, and permit renewals with the city of Berkeley and EBMUD. Curtails or suspends any operations that pose an immediate danger to members of the public or the environment. Monitors Laboratory wastewater discharges to the sanitary sewer to verify compliance with applicable regulations and permits. Investigates reports of unplanned sanitary sewer discharges and notifies EBMUD in a timely manner, as required. Coordinates and represents Berkeley Lab activities during environmental audits and inspections by the city of Berkeley and EBMUD.
Primary FTU Operator	Responsible for the overall operation of the FTU. Maintains daily log and monthly calibration records. Receives 24-hour OSHA training.

F. Definitions/Acronyms

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

Term	Definition
Department of Toxic Substances Control (DTSC)	The department within the California Environmental Protection Agency that regulates hazardous waste management and remedial actions
East Bay Municipal Utility District (EBMUD)	The local municipal wastewater treatment facility that accepts and regulates sanitary sewer discharges from Berkeley Lab
Fixed Treatment Unit (FTU)	A treatment unit that treats hazardous waste and discharges treated wastewater to the sanitary sewer under a permit with the city of Berkeley and possibly EBMUD
Hazardous wastes	Wastes exhibiting any of the following characteristics: ignitability, corrosivity, reactivity, or toxicity. In addition, the EPA has listed specific wastes as hazardous that do not necessarily exhibit these characteristics.
Pollution prevention	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

G. Recordkeeping Requirements

Discharge permits are maintained by the ESG of EHS.
Daily logs and monthly calibration records are maintained by the Primary FTU Operator.

H. Implementing Documents

Document number	Title	Type
07.09.004.001	Fixed Treatment Units	Program
07.09.004.002	Work Process A, General Requirements	Process
N/A	City of Berkeley permit	Permit
N/A	EBMUD permit, specific or site-wide	Permit

I. Contact Information