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REQUIREMENTS AND POLICIES MANUAL

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    Title:

    Waste Management

    Publication date:

    9/25/2020

    Effective date:

    9/25/2020

    BRIEF

    Policy Summary

    The Waste Management Program at Lawrence Berkeley National Laboratory (Berkeley Lab) defines generator accumulation processes and ensures compliance with all laws and regulations governing the disposal of the following types of wastes:

    • Hazardous waste.
    • Radioactive waste.
    • Mixed waste.
    • TSCA waste (polychlorinated biphenyl [PCB] waste and asbestos waste).

    • Universal waste.
    • Medical/biohazardous waste.
    • Other regulated wastes (e.g., used sharps, preserved wood, empty containers, scrap metal).

    Who Should Read This Policy

    Berkeley Lab employees, visitors, affiliates, and subcontractors who generate these types of wastes.

    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 CH20 — Waste Management.

    Contact Information

    Waste Management Group
    EHS Division

    Title:

    Waste Management

    Publication date:

    9/25/2020

    Effective date:

    9/25/2020

    POLICY

    A. Purpose

    This policy provides general requirements for the management of the following types of wastes:

    • Hazardous waste: Wastes that are regulated by the U.S. Environmental Protection Agency (EPA) or the state of California as hazardous.
    • Radioactive waste: Wastes that contain radioactivity that is distinguishable from background or that have been induced to be radioactive. Radioactive waste can be solid or liquid.
    • Mixed waste: Waste containing both hazardous and radioactive components.
    • Medical/biohazardous waste: Waste that requires inactivation of the biological material in an approved manner prior to final disposal.
    • Universal waste: Wastes that are regulated by the EPA or the state of California but are not fully regulated as hazardous wastes and are subject to Standards for Universal Waste Management.

    B. Persons Affected

    Lawrence Berkeley National Laboratory (Berkeley Lab, LBNL) employees, visitors, affiliates, and subcontractors who generate these types of wastes.

    C. Exceptions

    This policy does not apply to municipal solid waste and liquid sanitary wastes.

    D. Policy Statement

    Berkeley Lab applies work controls to ensure that wastes are managed in a manner that is protective of human health and the environment and complies with all applicable laws and regulations and DOE orders. The Waste Management Group (WMG) establishes the programs implementing controls for LBNL wastes, and advises and assists affected personnel in meeting all of the requirements of the waste management work processes.

    D.1 Hazardous, Radioactive, Mixed, Medical Waste/Biohazardous, and Universal Waste Guidelines at Berkeley Lab (Work Process A)

    Waste generators are responsible for characterizing their wastes accurately and completely, managing waste in the workplace compliantly, and minimizing the amount of waste generated. Consult the following publications and the WMG for additional information:

    • PUB-3092, Guidelines for Generators to Meet HWHF Acceptance Requirements for Hazardous, Radioactive, and Mixed Wastes at Berkeley Lab
    • PUB-3093, Hazardous Waste Accumulation Area Guidelines
    • PUB-3095, Medical and Biohazardous Waste Generator's Guide (part of the Biosafety Program)

    D.2 Storing Waste at the Site of Generation (Work Process D)

    All generators are required to set up waste storage/accumulation areas and follow all applicable regulations while the waste is in the generator area, such as the following:

    • Ensuring that only the maximum volumes allowed for any particular hazardous-waste stream are stored.
    • Ensuring that incompatible wastes are segregated according to their hazard category.
    • Ensuring that ignitable wastes are accumulated in accordance with the National Fire Protection Association (NFPA) and Occupational Safety and Health Administration (OSHA) safety guidelines, and that they are stored in the appropriate containers.
    • Maintaining adequate primary and secondary containment.
    • Ensuring that every container of hazardous waste is properly and compliantly labeled and packaged.
    • Ensuring that every container of hazardous waste is securely closed except when adding waste.
    • Storing waste within allowable time frames.
    • Storing at or near the site of generation.
    • Storing under control of the waste generator or other designated personnel.

    Specific waste storage areas include satellite accumulation areas (SAAs), mixed waste satellite accumulation areas (MWSAAs), and waste accumulation areas (WAAs).
    Solid medical and biohazardous waste is stored and managed at the generator's site in accordance with the Medical and Biohazardous Waste Generator's Guide.
    Radioactive waste is accumulated and managed at generator areas in accordance with all applicable work authorizations.

    E. Roles and Responsibilities

    Roles

    Responsibilities

    Waste generators

    • Complete all appropriate training.
    • Ensure that wastes are generated, handled, and stored in a compliant manner that is protective of human health, the environment, and LBNL/DOE property.
    • Accurately and completely characterize their wastes for compliant management within their workplaces.
    • Meet Hazardous Waste Handling Facility (HWHF) acceptance requirements.
    • Reduce waste through prevention, minimization, and recycling.
    • Submit disposal requisitions for hazardous, radioactive, and mixed wastes requiring removal from the work area.

    EHS Waste Management Group

    • Administers the LBNL Waste Management Program (WMP).
    • Develops, updates, and maintains the WMP, including policies and procedures, ensuring that program components are made available to all users.
    • Provides training related to the WMP, as necessary.
    • Assists generators in all aspects of managing wastes, including characterization, labeling, packaging, and safe and compliant management in the workplace.
    • Ensures that generators have properly characterized their waste and have correctly packaged and labeled the waste before it is picked up.
    • Initiates review and authorizes use of laboratory benchtop treatment procedures.
    • Periodically inspects generator SAAs, WAAs, and medical/biohazardous waste storage areas to assist waste generators with compliant accumulation and storage of waste in work areas.
    • Removes all hazardous and mixed waste from the generator's site in a safe and timely manner.
    • Operates the HWHF in a manner that ensures safety and compliance with all applicable regulations.
    • Ensures that all off-site facilities used for the treatment and disposal of radioactive, mixed, and hazardous wastes have been reviewed and approved for waste handling activities.
    • Prepares all waste profiles and shipping documents.
    • Transports hazardous material in accordance with the HazMat Transport/Shipping guidelines.
    • Maintains all records and provides “cradle-to-grave” tracking of all regulated wastes.

    F. Definitions and Acronyms

    Term

    Definition

    Biohazardous waste

    Waste that requires biological inactivation in an approved manner prior to final disposal, and includes the following discarded items:

    • Primary human cell lines and tissue cultures.
    • Organisms with recombinant DNA.
    • Cultures and stocks of infectious agents.
    • Potentially infectious agents (e.g., bacteria, viruses, fungi, spores).
    • Toxins.
    • Live and attenuated vaccines.
    • Blood, blood products, and other potentially infectious materials that may contain human blood-borne pathogens.
    • Carcasses.
    • Tissue specimens.
    • Recognizable human or animal body parts.
    • Soil, plants, and pathogens controlled by the U.S. Department of Agriculture (USDA).
    • Labware (not defined as a sharp) that has come into contact with the aforementioned waste streams (e.g., contaminated plastic pipettes, pipette tips, petri dishes, centrifuge tubes, Eppendorf tubes, disposable gloves, and wipes).

    Extremely hazardous waste

    Any hazardous waste or mixture of hazardous wastes whose exposure to humans could likely result in death, a disabling personal injury, or a serious illness because of its quantity, concentration, or chemical characteristics (22 CCR § 66260.10).

    Hazardous waste

    Solid wastes designated hazardous by California regulations. (22 CCR § 66261.3). For the purposes of this definition, a solid can be a solid, semisolid, liquid, or contained gas. Hazardous waste includes acutely hazardous waste, extremely hazardous waste, California-only hazardous waste, RCRA hazardous waste, special waste, and universal waste.

    Medical waste

    According to the California Health and Safety Code, Division 104, Part 14, 117600–118360, waste that is generated or produced as a result of the diagnosis, treatment, or immunization of humans or animals; in research pertaining to the treatment, diagnosis, or immunization of humans or animals; or in the production or testing of biologicals (medicinal preparations made from living organisms and their products including serums, vaccines, and antitoxins) and is either a biohazard or a sharp (device with sharp edges capable of piercing or cutting the skin).

    Metal waste

    Fine powder metals, having a particle size ≤100 microns (0.004 inch) in diameter, generated by grinders, band saws, and sanders, and metal pieces with oils or other contaminants, that should be managed as hazardous waste. Uncontaminated (clean) scrap metal cuttings, trimmings, stampings, grindings, shavings, and turnings can be collected for recycling in a clearly marked container (e.g. “Recyclable Metals”).

    Mixed waste

    Waste that meets the definitions of both a radioactive waste and a RCRA hazardous waste.

    Mixed Waste Satellite Accumulation Area (MWSAA)

    Designated area within a Radioactive Materials Area used for the accumulation of mixed wastes. Additional details include:

    • Has the same volume and time limits as satellite accumulation areas (SAAs).
    • Boundaries must be clearly delineated with tape, signs, and arrows.
    • Must be either in a room where waste was generated or in a room immediately adjacent, clearly designated with a purple MWSAA sign.

    Radioactive waste

    Wastes that contain radioactivity distinguishable from background or that have been induced to be radioactive. Additional details include:

    • Can be solid or liquid.
    • Will be accumulated in accordance with all applicable work authorizations.

    Satellite Accumulation Area (SAA)

    An area in an individual laboratory, shop, or other facility designated by the generator for the accumulation of waste not to exceed 208 liters (55 gallons) of hazardous waste, or 0.95 liter (1 quart) of extremely or acutely hazardous waste. The area must be at or near the point of waste generation and under the control of the person generating the waste.

    Universal waste

    Hazardous wastes that are exempted from the traditional hazardous waste management requirements, provided generators follow regulatory-defined management requirements for ensuring safe handling, recycling, and disposal. Universal wastes are defined in 22 CCR § 66261.9, and include batteries, cathode ray tubes (CRTs), CRT glass, electronic devices, aerosol containers, and mercury-containing devices (thermometers, thermostats, relay switches).

    Waste Accumulation Area (WAA)

    An officially designated area for the accumulation and storage of large quantities of hazardous waste

    Waste characterization

    The identification of waste components and properties (hazardous and nonhazardous) such that applicable storage, treatment, handling, transportation, and disposal requirements are met. Characterization can include process knowledge, sampling and analysis, or written documentation (logbooks, Material Safety Data Sheets, etc.).

    G. Recordkeeping Requirements

    The care, maintenance, and disposition of Waste Management records will be handled in accordance with Berkeley Lab records management policies and procedures, as listed in the Requirements and Policies Manual (PUB-201).

    H. Implementing Documents

    Document Number

    Title

    Type

    07.08.001.001

    Radiation Safety

    Program

    07.10.002.001

    Waste Management

    Program

    07.10.002.002

    Work Process A, Hazardous, Radioactive, Mixed, and Medical Waste/Biohazardous Guidelines at Berkeley Lab

    Process

    07.10.002.003

    Work Process D, Storing Waste at the Site of Generation

    Process

    PUB-3092

    Guidelines for Generators to Meet HWHF Acceptance Requirements for Hazardous, Radioactive, and Mixed Wastes at Berkeley Lab

    Guidance

    PUB-3093

    Hazardous Waste Accumulation Area Guidelines

    Guidance

    PUB-3095

    Medical and Biohazardous Waste Generator's Guide

    Guidance

    Supporting Documents

    • EH&S Procedure 817, Waste Characterization Quality Assurance Program
    • LBNL PUB-3000, ES&H Manual, Chapter 26, Biosafety Program
    • LBNL PUB-3000, ES&H Manual, Chapter 36, Asbestos Hazards and Controls
    • LBNL PUB-3000, ES&H Manual, Chapter 37, Lead Hazards and Controls
    • LBNL PUB-3000, ES&H Manual, Chapter 38, Beryllium Hazards and Controls
    • LBNL PUB-3000, ES&H Manual, Chapter 63, Polychlorinated Biphenyls (PCB)
    • LBNL PUB-3000, ES&H Manual, Chapter 45, Chemical Hygiene and Safety Plan
    • LBNL PUB-3000, ES&H Manual, Chapter 21, Radiation Safety

    I. Contact Information

    Waste Management Group

    EHS Division

    J. Revision History

    Date

    Revision

    By Whom

    Revision Description

    Section(s) Affected

    Change Type

    1/2/2012

    0

    M. Kassis

    Re-write for wiki (brief)

    All

    Minor

    12/17/2013

    1

    M. Kassis

    Re-write for wiki (policy)

    All

    Minor

    9/25/2020

    2

    M. Kassis

    Updated policy summary and policy statement. Updated Section D.2 with additional guidance for ensuring compliant storage of waste; verified links to web addresses. Updated Section E to reflect current roles and responsibilities. Verified regulatory references and clarified definitions in Section F. Verified and updated implementing and supporting documents.

    All

    Minor

    DOCUMENT INFORMATION

    Title:

    Waste Management

    Document number

    07.10.002.000

    Revision number

    2

    Publication date:

    9/25/2020

    Effective date:

    9/25/2020

    Next review date:

    9/25/2024

    Policy Area:

    Waste Management

    RPM Section (home)

    ESH

    RPM Section (cross-reference)

    none

    Functional Division

    EHS

    Prior reference information (optional)

    ES&H Manual Chapter 20

    Source Requirements Documents

    • DOE Order 414.1D, Admin Change 1, Quality Assurance
    • DOE Order 435.1, Admin Change 1, Radioactive Waste Management
    • DOE Manual 435.1-1, Admin Change 2, Radioactive Waste Management Manual
    • DOE Order 450.1, Environmental Protection Program
    • DOE Order 458.1, Admin Change 3, Radiation Protection of the Public and the Environment
    • DOE Order 460.1D, Hazardous Material Packaging and Transportation Safety

    Other Driving Requirements

    • 22 CCR 66261.1, Identification and Listing of Hazardous Waste
    • 22 CCR 66262.34, Standards Applicable to Generators of Hazardous Waste
    • 22 CCR 66273.1, Standards for Universal Waste Management
    • 40 CFR Part 261.3, Definition of Hazardous Waste
    • 40 CFR Part 261.31, Hazardous Wastes from Non-specific Sources
    • 40 CFR Part 261.32, Hazardous Wastes from Specific Sources
    • 40 CFR Part 261.33, Discarded Commercial Chemical Products, Off-Specification Species, Container Residues, and Spill Residues Thereof
    • California Health and Safety Code 117600, California Medical Waste Management Act

    Implementing Documents

    Document Number

    Title

    Type

    07.08.001.001

    Radiation Safety

    Program

    07.10.002.001

    Waste Management

    Program

    07.10.002.002

    Work Process A, Hazardous, Radioactive, Mixed, and Medical Waste/Biohazardous Guidelines at Berkeley Lab

    Process

    07.10.002.003

    Work Process D, Storing Waste at the Site of Generation

    Process

    PUB-3092

    Guidelines for Generators to Meet HWHF Acceptance Requirements for Hazardous, Radioactive, and Mixed Wastes at Berkeley Lab

    Guidance

    PUB-3093

    Hazardous Waste Accumulation Area Guidelines

    Guidance

    PUB-3095

    Medical and Biohazardous Waste Generator's Guide

    Guidance

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