for Work Definition and Hazards Identification

August 23, 1996


CSD EH&S Committee: The committee is managed by Norman Edelstein (Chair, and Division Deputy) and assisted by Linda Maio (Division Safety Administrator). The chair reports directly to the Chemical Sciences Division Director. Membership includes representatives from each research group. Each investigator appoints a group safety representative, who is the on-site contact person in the LBNL group work areas in matters related to Environmental Health and Safety (EH&S). Group safety representatives are part of the CSD EH&S organization along with the Division Safety Administrator (Linda Maio) and the Division Safety Coordinator (Norman Edelstein). The representative directs questions for clarification and guidance of a technical nature to the Division Safety Coordinator and, in his absence, to the appropriate contact within the LBNL. EH&S organization. The representative interfaces with the Division and EH&S on behalf of the group and carries out the day-to-day safety program of the group on behalf of the investigator. The person organizes and holds group safety meetings as needed, keeps current the general EH&S files of the group, keeps the investigator and the group members informed of all essential EH&S activities, and is knowledgeable regarding the state of corrective actions. The representative attends the Division Safety Committee meetings.

For purposes of this hazard analysis, the activities of the Division were grouped into the following organizational units

1. Actinide Chemistry

2. Evaluation of chelating ligands for removing uranium/plutonium deposited in bone and kidneys

3. High Energy Atomic Physics

4. Atomic Physics

5. Characterization of the Li-Electyrolyte Interface

6. Superconducting Properties of High Temperature Oxides

7. Chemical Dynamics

8. Catalytic Conversion of C1 Compounds

The Chemical Sciences Division has approximately 190 total employees and guests. Approximately 75% are located on the University of California Berkeley (UCB) campus. Campus activities are located in the following buildings: Hildebrand, Lewis, Latimer, Gilman, Giauque and Birge. Future activities will also be included in Tam Hall. Research activities are also conducted at other locations such as Brookhaven and Stanford.

Principal investigators (PI) report directly to the Division Director (Charles B. Harris) and are accountable for the scientific excellence, relevance to the DOE mission, and fiscal integrity of their programs, as well as adherence to all administrative and regulatory requirements.


Research Program Management Responsibility for Safety

Line Management is responsible for the protection of the public, the workers, and the environment.

At the Berkeley Laboratory the following documents establish the policy and provide the implementation guidance that makes line management effectively accountable for protection of workers, the public and the environment:

  • Operations Assurance Plan, OAP (1996)

  • Self Assessment Manual (1992) and Supplement (1996)

  • Publication 3000, Environment Health and Safety Manual (1995)

  • Chemical Hygiene and Safety Plan (1992)

  • Waste Generator Guidelines (1996)

  • Employee Performance/Progress Review, Section III (1996)

    Clear Roles and Responsibilities

    Clear and unambiguous lines of authority and responsibility for ensuring safety are established and maintained at all organizational levels within the Department and its contractors.

    Each Division making up the Berkeley Laboratory has clearly defined lines of responsibility down to the working level. Each division designates a research investigator to represent its views and concerns on the Laboratory Safety Review Committee and a full time employee to act as the ES&H Coordinator. This Coordinator acts as the interface between ES&H concerns and compliance in the workplace and the EH&S technical professionals. The organizational information is updated every 60 days and is retained in the Functional/Facility Notebooks as appropriate (see OAP).

    Competence Commensurate with Responsibilities

    Personnel posses the experience, knowledge, skills, and abilities that are necessary to discharge their responsibilities.

    Job assignments, including hires, are reviewed by line management and by the compensation group within Human Resources to ensure that the requirements and responsibilities of a job are matched by the experience, knowledge and skills of individuals selected for assignment. A performance expectation for managers and supervisors in the Division of Environment, Health and Safety is how well the talents, knowledge and skills of staff are matched to work assignments and responsibilities

    The Laboratory's training program ensures that each staff member, including participating guests, is adequately trained to do participate safely in Laboratory activities. Staff, with supervisor participation, fill out the Jobs Hazards Questionnaire (JHQ) describing the hazards associated with their job assignment and work area. Evaluation of the responses by the Training Coordinator and the cognizant supervisor determines the training regimen needed to carry out work in a manner that protects the employee, co-workers, the public and the environment.

    Balanced Priorities

    Resources are effectively allocated to address safety, programmatic, and operational considerations. Protecting the public, the workers, and the environment is a priority whenever activities are planned and performed.

    All environment, safety and health activities in the Laboratory are described in technical terms with budgetary information included. Each year this information is updated, reviewed and prioritized on the basis of risk to workers, public, and the environment by a Laboratory wide committee selected to represent programmatic line management and ES & H professionals. This document is utilized by Laboratory Senior Management in strategically planning the immediate focus and long term goals of the environment, safety and health program at the Laboratory.

    Hazard Controls Tailored to Work Being Performed

    Administrative and engineering controls to prevent and mitigate hazards are tailored to the work and associated hazards being performed.

    Chapter 6 of the Environment, Health and Safety Manual clearly defines the steps for each line manager to develop the appropriate engineering and administrative controls to mitigate hazards in the workplace. The Laboratory's Self Assessment Program, including Functional Appraisals by ES & H professionals, and the UC/DOE Contract 98 Performance Measures provide assurance that implementation of hazards control is adequate to protection the worker, the public and the environment.

    Identification of Safety Standards and Requirements

    Before work is performed, the associated hazards are evaluated and an agreed-upon set of safety standards and requirements are established which, if properly implemented, provide adequate assurance that the public, the workers, and the environment are protected from adverse consequences.

    The Laboratory is dedicated to following the Necessary and Sufficient Closure Process (DOE 450.3) on an iterative basis at all levels of activities in the Laboratory to ensure the Safety Standards are adequate to provide protection to workers, the public and the environment. This process is completed by to commencement of work in those situations where current work is significantly modified, new work is proposed or substantial facility modifications are being made (Chapter 6, Environment Health and Safety Manual).

    Operations Authorization

    The conditions and requirements to be satisfied for operations to be initiated and conducted are clearly established and agreed-upon.

    Conditions and requirements for facilities determined to be of higher risk based on the Preliminary Hazards Analysis are contained in a Safety Analysis Document. Activity Hazard Documents are the basis for meeting this requirement for specific operations and activities falling into the higher risk category at the Berkeley Laboratory. Internal Agreements describing the performance expectations by each party are used for operations between two functional areas where the quality of performance might adversely impact the Laboratory's ability to meet its responsibility to protect workers, the public and the environment.


    The Chemical Sciences Division conducts basic research in chemical physics and the dynamics of chemical reactions, catalysis, electron spectroscopy, photochemistry, atomic photochemistry, theoretical chemistry, atomic physics, and the chemistry of actinide elements. Its mission is several fold: to continue excellence in research ensured by rigorous peer reviews and the highest caliber scientific staff, to conduct and pursue research which is consistent with the National Energy Strategy, and to engage and instruct the next generation of scientists as a part of the Division's research mission.

    1. Actinide Chemistry: Development of new technologies for the use, safe handling, storage, and disposal of actinide materials relies on further understanding of basic actinide chemistry and the availability of trained personnel. This research program is a comprehensive, multifaceted approach to actinide chemistry and to the training of students to address issues in the future. Research efforts include synthetic chemistry to develop new chemical reagents and actinide materials, their chemical and physical elucidation through characterization techniques, and thermodynamic/kinetic studies for evaluation of complex formation. One aspect is the development of complexing agents that specifically sequester actinide ions for the decorporation of actinides in humans and for the separation of actinides in the environment. Extensive studies are underway to prepare organometallic and coordination compounds of the f-block elements showing the differences and similarities among the f-elements and between the f- and d-transition series elements. Optical and magnetic studies on actinides as isolated ions in ionic solids, and in molecules, give information about electronic properties as a function of atomic number. Synchrotron radiation investigations at the Stanford Synchrotron Radiation Laboratory and at the Advanced Light Source provide oxidation state and structural information on actinide material systems of environmental interest.

    2. Evaluation of chelating ligands for removing uranium/plutonium deposited in bone and kidneys. Research includes the study of the potency of new chelating agents for promoting excretion of internal deposited actinides and related heavy metals.

    3. High Energy Atomic Physics: The goals of this program are (1) to achieve an understanding of the physics of electron-positron pair production and heavy particle capture from pair production using theory and experiment and (2) to search for a charge-parity violating permanent electric dipole moment (EDM) of the electron as small as 10-30 e-cm (thousands of times smaller than the present limit). Recent results include the discovery of a new atomic collision process, electron capture from pair production. In this process, an electron-positron pair is produced by the transient electromagnetic field of a relativistic ion-atom collision, and the electron from the pair emerges from the collision bound to the projectile ion. Capture from pair production is predicted to be an important beam loss mechanism at the Relativistic Heavy Ion Collider. Present activities include (1) extending the measurement of electron capture from pair production to 10 GeV/nucleon collision energies and the capture of particles heavier than electrons, (2) performing calculations of capture from pair production using parallel computing, and (3) constructing a new experiment to search for an electron EDM using laser trapping and cooling.

    4. Atomic Physics: Studies of the structure and interactions of atomic systems are conducted to provide the most detailed description of their behavior and to stimulate theoretical understanding of the observed phenomena. The approach to this work emphasizes research topics that are best addressed with unique tools and expertise available at Lawrence Berkeley Laboratory (LBNL). Currently the program exploits the ability of two state-of-the-art, electron cyclotron resonance (ECR) ion sources at LBNL to produce intense, highly charged beams for the conduct of low-energy (v < 1.0 au) ion-atom collision studies. Current emphasis is on multiple electron transfer to bare, one, and two electron ions. This includes measurement of magnetic substrates populated in double electron capture, and the production of low-energy (<20 eV) continuum electrons accompanied by transfer to bound projectile states in collisions with He and more complex targets. Auger electron spectra, and photon spectra from multiply charged ion-atom collisions are used to gain insight into population mechanisms and the structure of highly excited states. The program benefits substantially from collaborative efforts with colleagues from outside LBNL.

    5. Characterization of the Li-Electyrolyte Interface: A detailed understanding of the reactions that occur between metallic Li and the individual molecular constituents of electrolytes used in Li batteries will be developed. Ultrahigh vacuum (UHV) deposition methods are used to prepare ultraclean Li surfaces of preferred orientation. Molecular films of solvent and/or solute molecules are deposited onto the clean surfaces in UHV at a very low temperature. The reaction between Li and the molecular films is followed using a combination of UHV surface analytical techniques, including Auger electron spectroscopy (AES), secondary ionization mass spectroscopy (SIMS), vacuum UV and X-ray photoelectron spectroscopy (UPES and XPS), and the recently developed variant of XPS termed photoelectron diffraction. The connection between films formed on Li in UHV and films formed at ambient temperature and pressure on Li in liquid electrolyte is made by the use of a common spectroscopy, ellipsometry. Using the fingerprint method, the ellipsometric signatures obtained in UHV for different surface layers having various known structures and compositions are used to identify the structure and composition of the film formed on the Li electrode in liquid electrolyte.

    6. Superconducting Properties of High Temperature Oxides: Theoretical studies: correlation between structure and properties, electromagnetic and transport properties, doping and non-adiabaticity, vortex structure. Applications are: transmission lines, microwave losses, interface phenomena, and proximity effect.

    7. Chemical Dynamics: The objectives of this program are to develop the basic knowledge and understanding of the mechanisms and dynamics of elementary chemical reactions that have a major impact on combustion and advanced energy production technologies. Recent emphasis has been to determine the structure and chemical behavior of free radicals, unusual transient species, clusters, and highly-excited polyatomic molecules, and to provide microscopic details of primary dissociation and bimolecular processes. These objectives are achieved with a strongly coupled experimental and theoretical-computational approach, using emerging technologies. Dynamical studies use advanced molecular beam and laser techniques, photofragmentation translational spectroscopy, and ion imaging. Kinetics studies employ IR laser flash kinetic spectroscopy and high-resolution UV-VUV laser spectroscopy. New theoretical methods and models are developed both to provide insight into chemical reactivity and the dynamics of reactive processes and also to allow one to carry out forefront calculations to guide and model several of these experimental studies. There are several significant recent advances: lifetime measurements of high-n Rydberg states of NO and Xe reveal the dependence of these lifetimes on collisions and weak electric fields that mix some high-l character with the prepared state. These studies for the first time place the widely used Zero-Electron Kinetic Energy (ZEKE) photoelectron spectroscopy technique on a firm ground. The photodissociation of ozone at 193 nm revealed a range of excited products, and a substantial yield of highly excited ground electronic state O2 was observed, recently suggested to play an important role in the stratospheric ozone budget. Photochemistry of numerous radical systems have been studied using flash pyrolysis and fast beam techniques; these include methoxy, methyl, acetyl, and allyl radicals; the results yield new information on thermochemistry and dissociation dynamics for these important combustion intermediates. Combined theoretical and experimental studies have been used to probe the properties of the transition state in ketene dissociation, providing a strong test of the basic tenets of unimolecular reaction theories. Theoretical methods continue to be advanced, allowing efficient calculation of the rate of a chemical reaction directly and without approximation. Theoretical and experimental approaches have been combined in an investigation of energy transfer processes in collisions of electronically excited hydrogen molecules. New studies in the coming years will take advantage of the Chemical Dynamics Beamline soon to be commissioned at the Advanced Light Source. This beamline will be a national User Facility promising a new era in the study of primary photochemistry, spectroscopy, and reaction dynamics, making use of the intense ultraviolet light provided by the ALS. The Chemical Dynamics Beamline comprises several dedicated molecular beam machines, a specially developed high-intensity laser.

    8. Catalytic Conversion of C1 Compounds: The purpose of this program is to develop an understanding of the fundamental processes involved in the catalytic conversion of C1 compounds such as CO, CO2, and CH4 to fuels and chemicals. The effects of metal oxides on the Fischer-Tropsch activity of metals such as Ru and Rh have been investigated. Electron microscopy together with 1H nuclear magnetic resonance (NMR) reveal that metal oxide promoters decorate the surface of the metal. Cationic vacancies at the perimeter of the oxide islands interact with oxygen atoms in either CO or HXCO facilitating their further reaction to products. Promoter effectiveness correlates with the Lewis acidity of the cations in the metal oxide. In situ IR studies show that the hydrogenation of CO2 to methane proceeds via the dissociation of CO2 to produce CO. The higher rate of methane formation from CO2 than CO under identical partial pressures of H2 and COX is attributable to the lower coverage of the catalyst surface by adsorbed CO in the former case. Methane is activated on Ru at low temperatures (623 K) to produce CHX and C2HX species. These species can be polymerized to produce higher molecular weight hydrocarbons or used to alkylate other organic compounds.



    Building 2: One laboratory on the 1st Floor contains experiments supported by the Characterization of the Li-Electrolyte Interface program of CSD. Safety of the laboratory is managed by the Materials Sciences Division and was included in the IHA evaluation of that division. Also, the Chemical Dynamics program occupies space on 3rd Floor. Research activities in the area have stopped and the equipment is being moved to Building 6.

    Building 6: The Chemical Dynamics program has research activities on one of the beamlines in the ALS. Safety of the activities is managed by the ALS staff and was included in the IHA evaluation of the ALS.

    Building 62: The Superconducting Properties of High Temperature Oxides program occupies office space on the 3rd Floor. All of the research activities are computer analysis and there are no ES&H issues except ergonomics. Also, The Catalytic Conversion of C1 Compounds program occupies space on the 3rd Floor. The program is moving to Tam Hall on the UCB campus. Safety of the program was reviewed in the Material Sciences Division IHA.

    Building 70A: The Actinide Chemistry program occupies space on the 1st and 2nd Floors. Also, the Evaluation of Chelating Ligands for Removing Uranium/Plutonium Deposited in Bone and Kidney occupies space on the 2nd Floor.

    Building 71: The High Energy Atomic Physics program occupies space in Building 71.

    Building 74: The Evaluation of Chelating Ligands for Removing Uranium/Plutonium Deposited in Bone and Kidney program jointly uses one lab on the 3rd floor with the Life Science Division.

    Building 88: The Atomic Physics group conducts experiments in Building 88. A Memorandum of Understanding is in place between the Nuclear Science Division and the Chemical Science Division which establishes safety responsibility for research activities with NSD.

    UCB Campus activities are located in the following buildings: Hildebrand, Lewis, Latimer, Gilman, Giauque and Birge. Future activities will also be included in Tam Hall. Research activities and hazards in UCB facilities are similar to hazards on the LBNL site. Research activities are also conducted at other locations such as Brookhaven and Stanford. The safety of activities at Brookhaven and Stanford are covered by ES&H requirements of those institutions



    General: Most of the laboratories use potentially hazardous chemicals and radionuclides. Several of the laboratories make use of non-ionizing radiation sources, cryogens, lasers and magnetic fields. Biohazardous materials are not used. Small vacuum systems and compressed gasses (including toxic gases) are used in several laboratories.

    Electrical and Mechanical Hazards: A limited array of electrical and mechanical hazards are present in the CSD. These include high voltage electrical systems, high current electrical systems, repetitive trauma associated with office work, a few small vacuum systems, some pressurized gas systems, belt driven equipment and ovens.

    Electrical Hazards

  • The overall level of concern associated with high voltage/high current equipment is low.

  • High voltage power supplies are also associated with a laser system (Building 70A, Room 1159 and Building 71, Room 117) and two x-ray machines (Rooms 1145 and 1159).

  • There are few high amperage systems in CSD. High current is provided to the EPR magnet system in Room 1159, Building 70A. There is also a NMR magnet in 70A-2215.

    Pressure and Vacuum Hazards

  • The overall level of concern associated with pressure and vacuum systems in CSD is low.

  • The main pressure hazards are the compressed gas cylinders, mostly nitrogen, argon and carbon dioxide.

  • Toxic gas cylinders are also used (see section on health hazard gasses).

  • Vacuum systems are present in Building 70A-1165, 71-226 and 71-146R. A glass bell jar with an expanded metal shield is located in 71-146R. A steel vacuum chamber (COW) is located in 71-226.

  • There are a few glass vacuum and inert atmosphere systems that are filled from a compressed gas cylinder (Rooms 2217 and 2211 of Building 70A).

  • Several vacuum pumps have exposed belt drives.


  • The overall level of concern associated with the use of ovens in CSD is low.

  • A high temperature oven is located in Building 71, Cave R.

  • Low temperature (<100 degrees C) ovens are widely used in CSD.

    Repetitive Mechanical Trauma

  • Office operations include the usual array of ergonomic issues, notably those associated with the use of computers and workstations.

    Chemical Hazards: A variety of toxic, flammable, corrosive, reactive or otherwise dangerous chemicals are used in the CSD. In almost all cases, the quantities used at any time are quite small, consistent with typical laboratory operations. Examples of hazardous chemicals in use in CSD are provided below.

    Flammable Gases:

  • The level of concern relating to the use of flammable gasses in CSD is low.

  • Flammable gases are used in several labs.

  • Flammable gasses include hydrogen, deuterium, methane and butylene.

    Flammable Liquids:

  • The level of concern associated with the use of flammable liquids in CSD is low to moderate overall.

  • Flammable liquids are used throughout CSD in small quantities.

  • Three rooms were identified as having a moderate level of concern associated with flammable liquids, in all cases because the quantities in storage were unusually large.

  • Typical flammable liquids include toluene, THF, diethyl ether and hexane.

    Inert Cryogens:

  • The level of concern associated with the use of inert cryogens is low.

  • Liquid helium is used in 70A-1151 and 1159 in dewers.


  • The level of concern associated with the use of corrosives in CSD is low overall, with two labs identified as representing a "moderate" level of concern.

  • Most of the CSD laboratories store or use small amounts of corrosive materials.

  • Common corrosives include lithium hydroxide, glacial acetic acid, nitric acid, and ammonium hydroxide.


  • The level of concern associated with the use of reactives in CSD is low overall, with only one lab identified as representing a moderate level of concern .

  • Although a large number of reactive chemicals are used, they are used in only quite small quantities in most cases.

  • Small amounts of reactive chemicals are used in most of the laboratories in CSD.

  • Common reactive chemicals include magnesium perchlorate, phosphorous pentachloride, lithium, hydrazine, perchloric acid and glacial acetic acid.

    Reproductive Toxins:

  • The overall level of concern associated with the use of reproductive toxins in CSD is low.

  • No labs were identified with a level of concern of moderate of high.

  • Common reproductive toxins include lead compounds and toluene.


  • The overall level of concern associated with the use of carcinogens in CSD is low.

  • One lab was identified as representing a moderate level of concern with respect to carcinogens (Building 70A, Room 2217).

  • Small quantities of organic carcinogens such as methylene chloride, chloroform, benzene and carbon tetrachloride are used.

  • Similarly, small quantities of inorganic carcinogens such as nickel are present.


  • The overall level of concern associated with the use of pyrophorics in CSD is low.

  • Only very small quantities of pyrophoric materials are present. A variety of powdered, potentially pyrophoric metals are present, including alkali metals.

    Toxic Materials:

  • The overall level of concern associated with the use of toxic and extremely toxic materials in CSD is low.

  • No labs were identified as having a moderate or high level of concern associated with the use or storage of toxic materials.

  • Typical highly toxic chemicals include cyanide salts.

    Health Hazard Gases:

  • The overall level of concern associated with health hazard gasses in CSD is low.

  • Toxic gases were identified in five laboratories.

  • Toxic gases in use include anhydrous ammonia, and trimethyl amine and carbon monoxide.


  • The overall level of concern associated with the use of oxidizers in CSD is low.

  • No laboratories were identified as having a moderate level of concern associated with oxidizers.

  • Approximately 1/4 of the laboratories store or use oxidizers.

  • Typical oxidizers include potassium permanganate, hydrazine, and nitric acid,

    Physical Agents: Physical agents present in CSD include ultraviolet radiation, lasers, magnetic fields and microwave radiation. Each of these is discussed below.

    Ultraviolet Radiation

  • The overall level of concern associated with the use of ultraviolet radiation in CSD is low.

  • No facilities were identified where the level of concern is judged to be moderate.

  • Only one lab uses a UV source, and it is an unmodified commercial product.

    Radiofrequency/Microwave Radiation

  • The overall level of concern associated with the use of radiofrequency/microwave radiation in CSD is low.

  • CSD uses several small home-built RF induction heaters.

  • There is an RF source associated with the EPR facility in Room 1159 of Building 70A and with the NMR facility in 2215.


  • The overall level of concern associated with the use of lasers in CSD is low.

  • Two lasers are located in Building 71, Room 117.

  • There are a number of lasers in Room 1159 of Building 70A.

    Magnetic Fields

  • The overall level of concern associated wit the use of magnetic fields in CSD is low. Strong DC magnetic fields are present in only two places, Rooms 1151, 1159 and 2215 of Building 70A.

    Infectious/Biohazardous Agents: The CSD does not use biohazardous agents.

    Accelerators and Radiation: Accelerator activities are conducted offsite at Stanford or Brookhaven except for the Atomic Physics activities at Building 88. Hazard and safety information for Building 88 is covered in the Nuclear Science Division report. Below is a description of activities on the LBNL site with respect to radionuclides.

    Actinide Chemistry: Experimental activities with radionuclides include: Stabilization of Radioactive Waste; Magnetic Measurements on Uranium Compounds; Actinide Spectroscopy: Measurement of fluorescence or absorption spectra of various actinides; Preparation of Plutonium, Thorium, Neptunium and Curium for various experiments; Synthesis and characterization of inorganic and organometalic compounds containing uranium, thorium and group IVA transition metals; Electron Spectroscopy of Actinides (Synchrotron radiation investigation of oxidation state and structural information on actinide material systems of environmental interest).

    Evaluation of Chelating Ligands for Removing Uranium/Plutonium deposited in Bone and Kidneys. Experimental activities with radionuclides include studies of the potency of new chelating agents for promoting excretion of internally deposited actinides and related heavy metals through injection of mice with actinides.

    High Energy Atomic Physics: Experimental activities with radionuclides include: Laser trapping and cooling of Francium and Cesium and relativistic atom collisions.


    There are no unique uncertainties which will impact hazard identification and selection of applicable and appropriate standards and requirements.


    No significant changes in CSD resources dedicated to ES&H activities are planned.

    Representatives of the CSD offered the following evaluation of the EH&S Division past and future resources and support:

  • The need for EH&S resources and support for the coming year should be roughly the same as last year except that laboratories in B70A which are currently being remodeled will be put back in service. Additional monitoring will be required in the next year to support those laboratories.

    The following concerns were raised by CSD:

  • Additional coverage of monitors for handling radionuclides is needed to improve research activity efficiency. For activities that need monitors it is difficult to arrange support in a timely manner because of the monitor's workload.

    Suggestions for improvements:

  • The Job Hazards Questionnaire needs to be further streamlined. Required training should be offered in a variety of forms in addition to courses (mentoring, videos, etc.) and alternatives should be created to verify competency, such as verifying adequate competency via challenge exams.


    There are no stakeholder concerns unique to CSD. CSD has managed, controlled, and permitted (as required) air, water, hazardous, and solid waste streams.

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