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Fixed Treatment Units

    Title:

    Fixed Treatment Units

    Publication date:

    3/28/2013

    Effective date:

    3/27/2013

    BRIEF

    Policy Summary

    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:

    http://www.lbl.gov/ehs/pub3000/CH53.html

    Contact Information

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

    Title:

    Fixed Treatment Units

    Publication date:

    3/28/2013

    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

    1. Berkeley Lab operates four hazardous-wastewater-treatment units, or Fixed Treatment Units (FTUs).
    2. State law requires all facilities treating hazardous waste to obtain authorization from the Department of Toxic Substances Control (DTSC) and the city of Berkeley.
    3. The Environmental Services Group (ESG) has prepared and maintains permit documentation, including notifications and plans required by the tiered permitting program.
    4. When a new FTU is planned, the city of Berkeley and EBMUD must be notified 60 days before the first treatment of waste begins.
    5. 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 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 EHSS 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 EHSS within 30 minutes of the release
    • Complete all required training provided by supervisors and EHSS

    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 Environmental Services Group of EHSS.
    • 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

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

    J. Revision History

    Date

    Revision

    By whom

    Revision Description

    Section(s) affected

    Change Type

    1/2/2012

    0

    R. Fox

    Rewrite for wiki (brief)

    All

    Minor

    3/28/2013

    1

    R. Fox

    Rewrite for wiki (policy)

    All

    Minor

    DOCUMENT INFORMATION

    Title:

    Fixed Treatment Units

    Document number

    07.09.004.000

    Revision number

    1

    Publication date:

    3/28/2013

    Effective date:

    3/27/2013

    Next review date:

    3/27/2016

    Policy Area:

    ESH

    RPM Section (home)

    Environmental Protection Program

    RPM Section (cross-reference)

    None

    Functional Division

    EHSS

    Prior reference information (optional)

    PUB-3000 Section 11.3.8 moved to Chapter 53

    Source Requirements Documents

    • H&SC 25200.3, Permitting of Facilities
    • 22 CCR 67450, Requirements for Units and Facilities Deemed to Have a Permit by Rule
    • 22 CCR 66260.10 et. seq., Hazardous Waste Management System: General — Definitions
    • EBMUD Permit #6600791 (Berkeley Lab main site), #50238911 (B77 FTU)
    • EBMUD Ordinance 311
    • 22 CCR 66265.190 et. seq., Interim Status Standards for Owners and Operators of Hazardous Waste Transfer, Treatment, Storage, and Disposal Facilities — Tank Systems

    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

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