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REQUIREMENTS AND POLICIES MANUAL

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    Title:

    Vegetation Sampling and Management

    Publication date:

    8/11/2021

    Effective date:

    6/26/2013

    BRIEF

    Policy Summary

    Only trees in which tritium concentrations are indistinguishable from regional background levels may be removed from the Lawrence Berkeley National Laboratory (Berkeley Lab) site. Additionally, all trees within the designated tritium restricted area (see Environmental Services Group (ESG) Procedure 270, Appendix A) must be authorized by ESG personnel prior to cutting, chipping, relocating within, and/or removing from the designated area.

    Who Should Read This Policy

    Berkeley Lab Facilities employees, construction subcontractors, and their supervisors who:

    • Manage or perform tree trimming or cutting, or
    • Plan construction projects that require tree trimming or cutting.

    To Read the Full Policy, Go To:

    The POLICY tab on this wiki page

    To Read the ES&H Program, Go To:

    ES&H Manual Chapter 59

    Contact Information

    Environmental Risk Assessments (for Radioactivity) Subject Matter Expert
    ESG
    Environment, Health and Safety Division

    Title:

    Vegetation Sampling and Management

    Publication date:

    8/11/2021

    Effective date:

    6/26/2013

    POLICY

    A. Purpose

    The Vegetation Sampling and Management Program at Lawrence Berkeley National Laboratory (Berkeley Lab) ensures that tritium-contaminated trees (either potentially or confirmed to have tritium concentrations above regional background) are not removed from the Berkeley Lab site.

    B. Persons Affected

    Berkeley Lab Facilities employees, construction subcontractors, and their supervisors who:

    • Manage or perform tree trimming or cutting, or
    • Plan construction projects that require tree trimming or cutting.

    C. Exceptions

    If analytical results show tritium concentrations are indistinguishable from regional background in a tree within the designated tritium restricted area, then that tree may be removed from the Berkeley Lab site (Department of Energy (DOE) Berkeley Site Office, 1999).

    D. Policy Statement

    1. Only trees in which the tritium concentration is indistinguishable from regional background levels may be removed from the Berkeley Lab site.
    2. A flowchart of the process for assessing potentially contaminated trees is shown in Work Process A, General Requirements and Flowchart.
    3. The map showing the area where trees may not be removed without sampling for tritium and confirming concentrations are indistinguishable from regional background is in Work Process B, Map of Restricted Area Where Trees May Not Be Removed.

    E. Roles and Responsibilities

    Role

    Responsibilities

    Supervisors
    • Ensure that environmental laws, regulations, and policies are followed.
    • Request assistance from the Environmental Services Group for technical advice on vegetation management operations and what would be an appropriate compliance strategy.
    • Ensure that vegetation management activities are performed within acceptable operating standards and that any required records are current.
    • Notify the Environment, Health, and Safety (EHS) Division immediately of any unauthorized tree removal.

    Employees
    • Follow applicable environmental laws, regulations, and policies.
    • Be fully aware of the environmental impact of their tree removal activities and comply with all requirements that govern those activities.
    • Take immediate action to stop unauthorized tree removal and report all instances of unauthorized tree removal to the EHS Division.

    Environmental Services Group
    • Develops Laboratory policies and procedures to ensure that tree removal 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 tree removal activities and assists in defining environmental protection compliance actions.
    • Reviews planned tree removal operations in accordance with ESG Procedure 270, Assessing Tritium in Trees Slated for Removal on LBNL Property.
    • Provides technical assistance and participates in discussions regarding tree removal operations with Berkeley Lab employees, regulatory agencies, concerned public citizens, community organizations, and the media.
    • Curtails or suspends any operations that pose an immediate danger to members of the public or the environment.
    • Investigates reports of unauthorized tree removal, 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 the 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.

    F. Definitions/Acronyms

    Term

    Definition

    Environmental monitoring

    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.

    Regional background

    Tritium levels in trees in the region beyond the influence of Berkeley Lab activities, which may be less than the lowest activity the analytical laboratory can detect

    Restricted area

    An area surrounding Building 75 where tritium levels in trees may exceed the regional background (where tree removal is restricted), and where tritium sampling is required in order to remove trees

    Unauthorized tree removal

    Removing trees or wood chips from the restricted area without obtaining confirmation from ESG that tritium levels in the trees are indistinguishable from regional background levels

    G. Recordkeeping Requirements

    Supervisors must ensure that vegetation management activities are performed within acceptable operating standards and that any required records are current.

    H. Implementing Documents

    Document Number

    Other Reference Number

    Title

    Type

    07.09.009.001

    N/A

    Vegetation Sampling and Management

    Program

    07.09.009.002

    N/A

    Work Process A, General Requirements and Flowchart

    Process

    07.09.009.003

    N/A

    Work Process B, Map of Restricted Area Where Trees May Not Be Removed

    Process

    N/A

    ESG Procedure 270

    Assessing Tritium in Trees Slated for Removal on LBNL Property

    Procedure

    N/A

    ESG Procedure 266

    Soil and Vegetation Sampling for the Environmental Radiological Protection Program

    Procedure

    N/A

    LBL-27170

    Site Environmental Report (most recent)

    Report

    I. Contact Information

    Environmental Risk Assessments for Radioactivity 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

    6/26/2013

    1

    Wahl

    Rewrite for wiki (policy)

    All

    Minor

    8/11/2021

    1.1

    J. Cummings

    Periodic review: minor clarifications

    All

    Minor

    DOCUMENT INFORMATION

    Title:

    Vegetation Sampling and Management

    Document number

    07.09.009.001

    Revision number

    1.1

    Publication date:

    8/11/2021

    Effective date:

    6/26/2013

    Next review date:

    8/11/2024

    Policy Area:

    Environmental Protection Program

    RPM Section (home)

    ESH

    RPM Section (cross-reference)

    None

    Functional Division

    EHS

    Prior reference information (optional)

    ES&H MANUALES&H Manual Section 11.3.6 moved to Chapter 59

    Source Requirements Documents

    • Department of Energy, Radiation Protection of the Public and the Environment, DOE Order 458.1 (September 15, 2020)

    Other Driving Requirements

    • Nolan, Richard H. "Tree and Vegetation Management Program," memo from DOE Berkeley Site Office to David McGraw, EH&S Division Director, Lawrence Berkeley National Laboratory (April 5, 1999)
    • Retired document, and information contained within it was promulgated to the appropriate ESG plans/procedures. Department of Energy, Environmental Radiological Effluent Monitoring and Environmental Surveillance, DOE-HDBK-1216-2015

    Implementing Documents

    Document number

    Other Reference Number

    Title

    Type

    07.09.009.000

    N/A

    Vegetation Sampling and Management

    Program

    07.09.009.002

    N/A

    Work Process A, General Requirements and Flowchart

    Process

    07.09.009.003

    N/A

    Work Process B, Map of Restricted Area Where Trees May Not Be Removed

    Process

    N/A

    ESG Procedure 270

    Assessing Tritium in Trees Slated for Removal on LBNL Property

    Procedure

    N/A

    ESG Procedure 266

    Soil and Vegetation Sampling for the Environmental Radiological Protection Program

    Procedure

    N/A

    LBL-27170

    Site Environmental Report (most recent)

    Report

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