EH&S 1996 IFA Final Report: HWHF


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 three 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 is responsible for the day to day operations that articulate Lab policies on protection of the public, and the environment, and eliminate potential compliance exposures to the lab. 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, Health and the Radiation Analytical Measurements Laboratory; Jack Bartley is the manager of the Services Department.

Robin Wendt is the manager of the Waste Management Group.

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

In the normal course of meeting all program objectives LBNL generates Hazardous, mixed and radioactive waste . The LBNL Hazardous Waste Management Group is charged with onsite waste management and ultimate disposition of all hazardous, mixed and radioactive waste in a legally compliant fashion. In this report the term "waste" will be taken to mean Hazardous, mixed and radioactive (i.e. all three types of waste).

The Hazardous Waste Management Group is divided into five teams. The Compliance Team, Certification Team, the Budget and Planning Team, Operations and Waste Minimization And Generator Support. In meeting its obligations to the research community Waste Generator Support is a component of waste management and is staffed in part by personnel working for the Field Support Department. Matrixed EH&S workers provide necessary independent liaison between waste management and the generator.

The Waste Management Compliance team assures that all LBL operations and activities involving waste management are performed in a safe, responsible and fully compliant manner. The team meets its mission through the implementation programs that provide necessary administrative services that assure waste management compliance with permits and DOE contractural obligations.

The Waste Management Budget and Planning Team assures that the group has sufficient fiscal resources to adequately meet its overall mission. This team also initiates and maintains process tracking systems necessary for ongoing operational fiscal management.

The Certification team provides the independent review of wastes to assure that they are properly characterized for subsequent handling, storage, treatment, transportation and disposal. This is accomplished through waste analysis and/or reviewing generator process knowledge.

The compliance team, Budget and Planning Team and Certification Team members are not exposed to hazards associated with direct handling of waste containers. Compliance team members encounter hazards associated with normal office operations such as ergonomic and other hazards of relatively low level safety concerns.

The Waste Minimization and Generator Assistance Team provide field support to operations and the rest of waste management. Generator assistance personnel inspect satellite accumulation areas and waste accumulation areas where there is the potential for exposure to chemical and radioactive hazards.

The Waste Management Operations Team is responsible for collection, transportation, storage, treatment and prepartation for shippment of all LBNL generated waste.

Personnel in the latter two teams may be exposed to hazards associated with their normal work acitivites.

Physical Conditions where the work is performed

Hazardous Waste Management Personnel occupy offices or cubicles in buildings 75, 75B and 26. These offices and cubicles are furnished with the normal complement of office furniture and equipment such as computer work stations, desks and files. There are no waste handling activites in these areas.

HWHF technicians handle waste in the 75 yard, rooms 75-127, 131A, and 131E, in waste pickup and transportation to the waste yard from onsite and offsite locations, and 69-HW.

There is a forklift that is used to move heavy or large containers within the waste yard. In rooms 75-131A 127 there are chemical fume hoods used for waste treatment and characterization. In room 75-127 there are glove boxes used for high level radioactive and mixed waste characterization and packaging. In room 75-131E there is a walk-in or slot hood used for solidification of liquid wastes.

In building there is a 75A a compactor used for volume reduction of dry waste.

Waste generator support personnel, inspect Waste Accumulation Areas (WAA's) and Satellite Accumulation Areas (SAA's).

Materials and conditions that could cause adverse consequences

The following classes of chemicals may be present as waste in the facility at any one time:

Waste chemical classes present

There is a low level chemical exposure potential in 75-127,131A, 75A and the 75 yard. there is a lowlevel asbestos exposure potential in 75A. There is a low level biohazard potential in 75-131A, 131E, and 75A.

There is a medium level of concern for potential direct and indirect radiation exposure to workers in the 75 yard, 75-131A, 131E, 75A and 75-127. Radioactive material contamination potential exists and all the afformentioned areas.

There is a low level concern of heat stress to workers in the 75 yard.

Waste workers are exposed to ergonomic hazards associated with lifting and moving heavy waste containers. A forklift is used in the waste yard. This is a lowlevel of concern.

In building 75 A drums are stacked in two tiers. This poses a seismic hazard that is of a low level concern. A compactor is used in 75A; there is a low level concern that improper use could result in injury to a worker.

Uncertainties about the work

Management of Hazardous and RCRA mixed waste is governed by the part B permit. Currently the lab has applied for an amendment to the permit that would provide greater flexibility in waste management without compromising compliance or the health and safety of the public or environment. As of this report the modifications are pending approval. It is unclear whether all, part or none of the proposed changes will be approved. Either alternative outcome will result in a corresponding change to how the waste management group runs its operations. There is no fixed date for DTSC (the agency responsible for conferring the approval) to make the approval as it seems that approval award is a function of process rather than a mandated schedule.

The Waste Management Group will be moving to a new facility at the end of FY96. The facility will be subject to an operational readiness review. This is due to be complete in late September or early October 1996. Startup of a new facility always incurs a learning curve on the part of the operator, this lays the foundation toward facility familiarity. During this period the potential for accidents or the development of other hazardous conditions may be higher than during normal operations.

The Waste management group is in negotiations with the State of Washington, the Hanford reservation and the State of California concerning the outcome of two waste issues. A more complete summary of these issues may be found in the 1996 Site Environmental Report. To date these issues have precipitated extensive QA surveys by Hanford Personnel whenever an LBNL waste shippment is readied for transportation to Hanford. It is unclear what short or long term effects on waste management the negotiation outcomes will have.

Resource availability and constraints

There is no significant change in support from EH&S anticipated for FY97. If the Part B permit modification is approved, then minor support may be needed to implement procedural changes.

Stakeholder concerns

Waste management operations are licensed under the current RCRA Part B permit. A Permit modification submitted to address waste storage capacities, treatment options and other minor changes has elicited public concern over the way the lab manages its waste. Currently the lab is holding public meetings as part of the permit modification process to address public concern.

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