EH&S 1996 IFA Final Report: Environmental Protection and Site Restoration


Organization and management

The LBNL Environment, Health and Safety Division's primary mission is to provide professional and technical expertise to support and enhance the Laboratory's research and development program.

The EH&S Division is organized into departments and groups to align closely with Laboratory organizational structure. There are two departments, each representing a major functional area: Environment, Health, and Safety. Reporting to these two departments are seven groups. A division administrator, matrixed to EH&S from the Office of the Associate Laboratory Director, Administration, is charged with overall fiscal and personnel management within the Division.

Reporting to the division director, each department head has leadership responsibility for a major functional unit, usually including two or more subordinate group leaders, plus professionals and technical staff, varying in number from 30 to 50 individuals. Each department head is responsible for management of the department, including planning, staffing, and budgeting, and for the development and implementation of Laboratory policies and procedures in their functional area. Each department head represents the department in contacts with internal and external organizations and individuals on matters of major significance to the success of Laboratory programs and activities. The department head directs the work of subordinate managers in the groups within the department.

Reporting to the division director or a department head, each group leader has supervisory responsibility for an EH&S technical or professional section, project, or function. An EH&S group comprises several professionals and/or technical experts (typically 10 to 25 people), organized to achieve goals in a specific, focused EH&S specialty area.

David Mc Graw is the LBNL EH&S division director. He formulates forward looking strategies and is responsible for the day to day operations that articulate the Division's primary mission. The EH&S divisional Charter provides a roadmap for the rest of the division and is found in the Division Function Notebook.

The two departments are the Field Support Department and the Services Department. The Services Department manages the Environmental Protection Group, the Hazardous Waste Management Group, the Medical facility and the Radiation Analytical Measurements Laboratory; Jack Bartley is the manager of the Services Department.

Ron Pauer is the Manager for the Environmental Protection Group. The Environmental protection Group is partitioned into Environmental monitoring unit, Air and water quality unit, Hazardous Materials Management Unit and the Site Restoration Unit. The Site Restoration Group is managed by Iraj Javandel.

Performance Expectation and objectives

1) Research Program Management Responsibility for Safety.

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

Operations Assurance Plan (OAP) - 1996

Self Assessment Manual - 1992
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

2) Clear Roles and Responsibilities.

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).

3) Competence Commensurate with 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.

4) Balanced Priorities.

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.

5) Hazard Controls Tailored to Work 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.

6) Identification of Safety Standards and Requirements.

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).

7) Operations Authorization.

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.

What Actions will be performed

The environmental protection policy of LBL is to conduct its operations in a manner that preserves the quality of the environment. The LBL Environmental Protection Group is committed to good environmental management of all its potential risks, minimizing risks to the environment and public health, and anticipating and addressing potential environmental problems before they pose a threat to the quality of the environment or the public welfare.

The Environmental Protection Group mission is to support the EH&S division charter through well designed programs. Program objectives are to protect the public and the environment from effects of operations conducted at the lab. The Environmental Protection Group will implement programs that are aimed at elimination of Environmental compliance exposures to the lab and articulate all applicable DOE orders.

Environmental Restoration, a function of Environmental Protection, is to ensure those risks to human health and the environment from past releases of hazardous materials and/or radioactive materials are either reduced to allowable levels or eliminated.

Physical Conditions where the work is performed

All Environmental Protection Personnel (EP) are housed in buildings 75 and 75B. Environmental monitoring equipment is stored in 75D. The EP workshop is located in Building 17.

All EP personnel housed in building 75B, occupy typical office space accommodating computer work stations, desks and files. Building 75 B work activities are consistent with a normal office environment. There is a small kitchen furnished with a microwave oven, toaster, refrigerator (for storage of food only) and sink. There is a copy center with distributed (networked) printer present.

EP personnel working in building 75 occupy cubicles in room 75-124. Cubicle configurations conform to the normal office environment as described above for 75B.

Building 75 D serves as storage area for environmental monitoring. Environmental monitoring personnel access the area two or three times per week. There are two sample refrigerators in this area used for low temperature storage of samples. The area is furnished with storage racks, cabinets and a table. No normal day to day operations are conducted in this area.

The EP workshop, building 17, is equipped with a full complement of light wood and metal fabrication equipment. There is a hood used for oxyacetylene brazing. There is a small office space furnished with routine office equipment and a computer.

Environmental monitoring activities are conducted throughout the site on a daily basis. Air exhaust samplers are located on roof tops, sewer samplers are located in one of two site sewer discharge stations, most ambient air samplers are located at ground level (one located on the roof of building 69). The setup and operation of monitors may constitute unattended running equipment.

Environmental Restoration (ER) Personnel occupy buildings 51, 14 and 90. Building 31 is used for equipment storage; there is a groundwater treatment unit located outside building 7, treated water from this unit drains to the sanitary sewer.

ER personnel occupy typical offices or cubicles buildings 51, 14 and 90. Normal office activities include data entry and filing ect.

Environmental restoration field activities are almost exclusively associated with drilling and development of groundwater monitoring wells and subsequent sampling. There are approximately 120 active wells throughout the site. Other site activities include treatment of groundwater, soil (surface and subsurface) sampling.

Materials and conditions that could cause adverse consequences

Building 75, 75B and 75D: EP personnel occupy routine office space where there are low level hazards of concern relating to repetitive motion injury and ergonomic issues. Since 1994 there have been two workers compensation claims in this area relating to these issues. The toaster is not heat protected and there is a low level hazard from hot surfaces when this is in use (about once perday). Environmental monitoring equipment and miscellaneous office furniture is stored in B75D. Storage of some items is unsecured and may pose a seismic hazard. This is a low level of concern.

Environmental protection monitoring personnel: EP monitoring personnel travel to and from on and offsite locations, transporting environmental samples, samplers or monitors and maintenance equipment. Approximately 50% of the time spent monitoring is devoted to driving, and of that there is an 80/20% split between onsite and offsite travel respectively. There are low level hazards associated with vehicular transportation. Many of the samplers are located on roofs. Roof access is via ladder (no cage) where the ladder length is less than 20 ft but the fall distance is greater than 20 ft (building 55). Other samplers are located in confined spaces. Storm water samplers are located in areas where there is poor lighting and are remote. EP personnel access these areas equipped with a cell phone, however there is a low level hazard concern that incapacitated personnel would not be able to use the phone.

Some of the samples use hazardous materials. Stack air samples may contain sodium hydroxide (approx. 400ml) , a corrosive, or Silica Gel (approx 250ml) , which may pose a respiratory hazard. These hazards are a low level of concern.

There is no direct radiation exposure hazard potential in the course of the monitors normal daily activities. During roof access of the stack samplers there is a low level hazard concern that monitors may be exposed to exhaust air contaminated with radioactivity and/or hazardous chemicals.

Building 17 workshop: Hazards associated with work in this area are related to the use of light metal and wood fabrication activities. There is a spot welder that could cause thermal or arcflash burns; this is a low voltage (12 to 24 volts) high amperage piece of equipment. There is a hood used for brazing, using oxygen and acetylene gases. These are a low level of concern.

There are grinding and sanding machines that are serviced with an exhaust system. The exhaust system is permitted under BAAQMD.

Buildings 51, 14 and 90: Site restoration personnel occupy routine office space where there are low level hazards of concern relating to repetitive motion injury and ergonomic issues. There have been no recorded worker's compensation cases for this population in the last year.

Site Restoration Field Personnel: Site restoration field personnel are exposed to low level hazards associated with drilling, developing and sampling groundwater wells. Well drilling poses a noise hazard and other hazards associated with the operation of heavy rotating equipment. Well development and sampling may result in repetitive motion or ergonomic injuries. In the past year there have been two worker's compensation claims for repetitive injuries. This is a medium level of concern. There is a vehicular hazard potential. There have been a number of minor fender benders over the last couple of years.

During the course of soil investigations or excavations workers may be exposed to volatile toxic or hazardous chemicals. This is a medium level of concern.

There were 6 out of 40 (15%) SAAR reports attibutable to the Environmental Protection Group (5 to site restoration and 1 to EP) from 1994 to present.

In 1995 there was one noise exposure above the OSHA PEL to a drilling subcontractor.

Uncertainties about the work

EP is charged with ensuring the Lab's ongoing environmental compliance and adherence to applicable DOE orders. Recent local scrutiny of the lab's operations and performance adds additional loads to normal daily compliance activities, resources are redirected away from direct compliance issues to the preparation of briefs, reports and appearance at public forums. It is unknown how long this activity will continue.

Completion of the Necessary and Sufficient process will probably result in some changes to the way EP conducts business. This is an unknown variable.

Much of the DOE orders relating to Protection of the Environment are being codified into 10 CFR 834 where they will attain the status of a regulation, supported by the full force of the law. The date for implementation is pending.

Resource availability and constraint

Most of the EP activities are funded from overhead sources. All EP program needs have been identified in the Five Year Plan which is reviewed and updated annually.

In the current environment of fiscal restraint year to year fiscal support of a constant or increasing level of effort is not guaranteed. Recent years have seen a decline in annual budget forcing a reduction in personnel and level of environmental monitoring. The impact to the success of current environmental programs is unknown.

EH&S support needs for the forseeable future should remain relatively constant.

Site Restoration efforts are funded from EM40 sources and are stable for the forseeable future. A five year management plan is updated and submitted annually. The near term fiscal projections are flat based on FY 96 (adjusted for inflation).

Stakeholder concerns

The Lab houses the National Tritium Labelling Facility. This NIH funded arm of the Life Sciences Division releases between 50 and 100 curies of tritium per year, (mostly as HTO, the tritiated analog of water) into the atmosphere. Small amounts of tritium are detected in local streams and groundwater. Local citizen concern has been raised over this issue. Environmental Protection has responded by participating in a number of public forums and monthly meetings with the City of Berkekely. Site restoration conducts technical meetings with the City of Berkely, the California Department of Health Services and the Regional Water Quality Control Board as well as conducting Quarterly technical progress report meetings to DOE and other stakeholders.

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