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Title:	Vegetation Sampling and Management
Publication date:	6/26/2013
Effective date:	6/26/2013

BRIEF

Policy Summary

Only trees in which tritium levels are not distinguishable from regional background levels may be removed from the Berkeley Lab site.

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:

http://www.lbl.gov/ehs/pub3000/CH59.html

Contact Information

Vegetation Sampling (for Radioactivity) Subject Matter Expert
Environmental Services Group
EHS Division

Title:	Vegetation Sampling and Management
Publication date:	6/26/2013
Effective date:	6/26/2013

POLICY

A. Purpose

The Vegetation Sampling and Management Program at Berkeley Lab ensures that tritium-contaminated trees 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 levels that are not distinguishable from regional background levels in a tree within the area where tree removal is restricted, then that tree may be removed from the Berkeley Lab site (DOE Berkeley Site Office, 1999).

D. Policy Statement

Only trees in which tritium levels are not distinguishable from regional background levels may be removed from the Berkeley Lab site.
A flowchart of the process for assessing potentially contaminated trees is shown in Work Process A, General Requirements and Flowchart.
The map showing the area where trees may not be removed is shown 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 EHSS 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 EHSS 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 for Removal 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 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 are typically less than the lowest activity the analytical laboratory can detect
Restricted area	An area surrounding Building 75 where tritium levels in trees exceed the regional background (and where tree removal is restricted)
Unauthorized tree removal	Removing trees or wood chips from the restricted area without obtaining confirmation from the Environmental Services Group that tritium levels in the trees are not distinguishable 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 for Removal	Procedure
N/A	ESG Procedure 266	Soil, Sediment, and Vegetation Sampling	Procedure
N/A	LBL-27170	Site Environmental Report (most recent)	Report

I. Contact Information