Chapter 20
WASTE MANAGEMENT

Contents

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20.1 Policy

Lawrence Berkeley National Laboratory (LBNL) applies work controls to ensure wastes are managed in a manner that is protective of human health and the environment and complies with all applicable laws and regulations.
The Waste Management Group (WMG) establishes the programs implementing controls for LBNL wastes. All personnel at the Laboratory must comply with the waste management programs.

20.2 Scope

The LBNL waste management programs encompass:

• Safe and environmentally protective management of wastes generated, including identification, characterization, and accumulation of wastes in the workplace; and the safe and efficient removal of wastes from the generator’s areas
• Avoidance and minimization of wastes generated
• Packaging and transportation of wastes to off-site treatment, storage, and disposal facilities
• Operation of the Hazardous Waste Handling Facility (HWHF) and the treatment and storage of waste in the facility in a manner that complies with the Permit and regulatory requirements.

The WMG is composed of the Waste Services Team and the Waste Operations Team. The Waste Services Team is responsible for the LBNL waste management services provided to LBNL divisions and facilities. Generator Assistants are the primary contact and resource for LBNL waste generators and other staff. These are provided by the Waste Services Team, which also performs waste certification and compliance activities. The Waste Operations Team operates the HWHF and the waste storage, treatment, and shipment activities performed there. HWHF trained technicians perform waste pickup, packaging, and transfer activities at LBNL and at off-site locations.

LBNL waste management services are provided to all facilities/programs on the LBNL campus as well as alloff-site facilities that generate waste. These include (but are not necessarily limited to) the Donner Facility at the University of California at Berkeley, which is contiguous with the LBNL site, and the following noncontiguous facilities:

• Joint Genome Institute (JGI)
• Berkeley West Biocenter (Potter)
• Joint BioEnergy Institute (JBEI)
• Joint Center for Artificial Photosynthesis (JCAP)
• Advanced Biofuels Process Demonstration Unit (ABPDU)

The scope of the waste management programs broadly addresses all LBNL discarded materials to ensure that those identified as wastes will be managed, stored, recycled, treated, and disposed of in compliance with the applicable requirements and regulations for:

• Hazardous waste
• Universal waste
• Radioactive waste
• Mixed waste
• Medical/Biohazardous waste
• Polychlorinated biphenyl (PCB) waste
• Asbestos waste
• Other regulated wastes (e.g., treated wood wastes, empty containers)

Municipal solid waste and liquid sanitary wastes are typically excluded from the scope of waste management programs.

20.3 Applicability

The waste management programs apply to all employees, affiliates, and subcontractors.

20.4 Exceptions

None.

20.5 Roles and Responsibilities

20.6 Definitions

20.7 Required Work Processes

The WMG has developed work processes for personnel to use to compliantly manage wastes and other discarded materials. The Waste Services Group has assigned waste services specialists called Generator Assistants to each LBNL division or facility. The Generator Assistants are available to advise and assist personnel in meeting all of the requirements of the waste management work processes. Click here to see who your Generator Assistant is. Additionally detailed Generator Guidelines have been prepared to assist generators. Click here to find the Generator Guidelines and other waste management resources.

Work Process A. General Requirements

To ensure compliance with applicable regulations, DOE orders, and LBNL policies, personnel must follow these requirements to identify, characterize, store, treat, and dispose of waste.

1. Identify work scope and determine if waste will be generated.
2. Waste Identification and Characterization. The owners of work activities, facility operations, or experimental procedures must identify the types of wastes they are or will be generating.
   1. Identify discarded materials or wastes generated by your work activities.
      1. Materials not discarded may also be waste.
         1. If the material is mislabeled or inadequately labeled, it is considered waste unless the label is corrected within 10 days.
         2. If a container is deteriorated or damaged, it is considered a waste unless the container is repackaged within 96 hours.
   2. Evaluate identified discarded materials and waste from your work processes, using Work Process C, Waste Identification and Characterization.
   3. Ensure that the evaluation is adequate to
      1. Determine how you must contain, label and store your waste in the work area
      2. Determine whether the discarded materials or wastes are hazardous wastes.
      3. Identify and plan implementation of waste minimization and prevention strategies.
   4. An unlabeled and unidentifiable discarded material it is considered an “unknown.”
      1. Management and disposal of unknowns is expensive and can pose safety risks. Avoid the potential for unknowns by
         1. Maintaining inventory control of the products and chemicals used in the work area.
         2. Ensuring all containers of products and chemicals are labeled with information on the contents.
         3. Frequently doing physical inspections of the product and chemical containers to ensure they are legibly labeled.
      2. If you find an container of unknown material you suspect is hazardous,
         1. Contact your safety representative if the container cannot be safely handled.
         2. If it is safe to do so, mark the container with
            1. the date of discovery
            2. the words “Unknown Waste - pending characterization”
            3. any known compositional or hazards characteristics (e.g. “liquid” or “oily solid with solvent odor”)
         3. Contact your Generator Assistant
            1. As directed by the Generator Assistant put the labeled container in a designated Waste Accumulation Area.
            2. Provide the Generator Assistant as much assistance as possible in determining the generator and identity of the unknown waste.
         4. The Generator Assistant will initiate any required sampling and analysis of the waste and ensure proper management of the waste upon completion of the waste characterization and hazardous waste determination.
3. Waste Training. Waste generators and other staff must complete specified training for their anticipated wastes to ensure safe and compliant management of those wastes.
   1. See Work Process B, Training Requirements.
   2. The Waste Services Team develops and provides training to waste generators and other staff. These include online and classroom-based courses, as well as individual training.
   3. Additional training may be required by divisions.
   4. On-the-job, procedure-specific training is required for performing laboratory benchtop treatment of hazardous waste.
4. Waste Storage. Waste generators are responsible for setting up and maintaining waste storage or accumulation areas.
   1. See Work Process D, Generator Waste Storage.
   2. The Generator Assistants will, as needed, help waste generators in identifying, setting up, and maintaining waste storage areas.
5. Waste Inspections. All waste storage areas should be periodically inspected for housekeeping, safety, and compliance. For some types of waste, environmental or health and safety regulations define waste and storage area inspection frequencies and criteria.
   1. The WMG performs waste container and storage area inspections that are specified in state and federal regulations.
   2. Waste generators and line management are encouraged (and sometimes required by individual divisions) to perform inspections of SAAs and MWSAAs for compliance with LBNL requirements.
      1. Document inspections as required by the division.
   3. Generator Assistants perform periodic medical/biohazardous waste area and SAA/MWSAA inspections for quality assurance purposes.
6. Waste Transportation. Some types of waste, including radioactive, hazardous, biohazardous, and medical wastes, may be classified as hazardous materials for the purposes of transportation by the DOT.
   1. For transportation of DOT hazardous materials other than waste, see the Transporting and Shipping Hazardous Materials policy in the Requirements and Policy Manual (RPM).
   2. DOT-regulated wastes will be packaged in compliance with DOT requirements.
      1. For DOT-regulated wastes to be placed in shipping containers by the waste generator, use containers obtained and filled per Generator Assistant instructions to ensure DOT compliance.
   3. Wastes will be transported from waste generator storage areas only by Waste Operations Team personnel or WMG-contracted or approved vendor personnel.
   4. Where WMG shipments deviate from any applicable DOT requirements, the WMG will generate an approved Transportation Safety Document as required by DOE and/or obtain a Special Permit from DOT to specifically authorize the deviation.
      1. In addition to transporting waste, the WMG assists Transportation Services and LBNL personnel by transporting previously opened containers of other hazardous materials between non-adjacent buildings on the LBNL campus and between the UC Berkeley Donner facility and the buildings on the LBNL campus.
      2. Contact your Generator Assistant for more information.
7. Waste Treatment
1. Laboratory hazardous wastes may be treated near the point of generation, using a benchtop treatment procedure to safely and most efficiently manage some wastes.
2. See Work Process E, Generator Waste Treatment, for information on how to perform benchtop treatments, including those required to treat certain nitric acid waste posing a safety hazard when stored in SAAs.
8. Waste Disposal. Removal of most wastes from generator areas is initiated by the waste generators using waste requisitions.
1. See Work Process F, Waste Disposal.
9. See Appendix A for flow diagrams illustrating generator management of the following wastes:
   1. Hazardous waste
   2. Radioactive waste
   3. Mixed waste
   4. E-waste
   5. Medical/biohazardous waste

Work Process B. Training Requirements

Work Process C. Waste Identification and Characterization

1. During work planning activities identify materials that will be discarded and wastes that will be generated.
   1. Identify and plan implementation of waste minimization and prevention strategies.
   2. Identify how you must contain, label and store your waste in the work area.
2. Discarded materials that are reused, salvaged for reuse, or recycled (including e-waste) are generally managed through the Facilities Division in coordination with the Waste Services Team.
   1. Contact your Generator Assistant or review the salvage guidelines found on the Facilities Division Property Reuse Web page.
   2. Review the E-Waste Management flow diagram in Appendix A.4.
3.  Characterize waste based on process knowledge.
   1. If the process knowledge is not adequate to completely characterize a waste (or if a waste generator cannot be identified), the waste must be sampled for laboratory analysis.
      1. Contact your Generator Assistant to initiate this process.
      2. The WMG identifies the sampling and analysis requirements for characterizing a waste or a waste stream, performs the required sampling and sample shipments, and evaluates/validates the analytical results produced.
      3. The division generating a waste is responsible for any costs associated with sampling and analysis to characterize the waste.
4. If the waste is from an area where radioactive contamination or activation may occur, certify the waste as "nonradioactive" OR manage it as a radioactive waste.
   1. Certification is done in accordance with applicable WMG and Radiation Protection Group procedures. See more information here.
5. Use the links and information below for characterizing (and managing) different types of wastes.
6. Asbestos waste (See also Chapter 36 of the ES&H Manual)
7. Empty containers
8. Epoxy waste materials
9. Gas cylinders are typically returned to the supplier. For gas cylinders that cannot be returned, contact your Generator Assistant for assistance.
10. Hazardous waste
    1. Typical hazardous wastes include:
       1. Corrosive waste
       2. Ignitable waste
       3. Reactive waste
       4. Toxic waste
       5. Listed waste
    2. Ensure characterization of hazardous waste includes all required information to requisition a waste for disposal.
    3. Characterization of hazardous waste may also need to include identification of underlying hazardous constituents.
       1. These are waste constituents other than those causing the waste to be hazardous, but by regulation also require treatment.
11. Medical/biohazardous wastes
    1. Sharps waste is managed under the medical/biohazardous waste program.
12. Nanomaterial-bearing wastes are typically managed as a hazardous waste.
13. Over-the-counter drugs, pharmaceuticals and controlled substances:
    1. Contact your Generator Assistant if you have over-the-counter drugs or pharmaceuticals you no longer need.
    2. Contact the Industrial Hygiene organization for requirements applicable to disposal of controlled substances.
14. PCB waste (See also Chapter 63 of the ES&H Manual)
    1. If you have or suspect you have a PCB waste, contact your Generator Assistant.
    2. Waste oils and all liquids suspected of containing PCBs must be sampled and analyzed to determine the PCB concentrations.
       1. Contact your Generator Assistant to initiate the sampling and analysis.
15. Peroxide-forming compounds
    1. Peroxide-forming compounds that have been stored either beyond useful shelf life or for which age and history cannot be determined are considered unsafe and must be characterized and managed as a hazardous waste.
       1.  Click here for more information on peroxide-forming compounds.
       2. Contact the Industrial Hygiene Group for assistance with testing these materials and your Generator Assistant for help dispositioning the tested materials.
16. Radioactive wastes
    1. Prior to generating a nondefense-related transuranic waste or a no-path-to-disposal waste, obtain authorization from the Waste Services Team.
       1. Contact your Generator Assistant to initiate the process.
    2. Identify and characterize other components of radioactive wastes such as medical/biohazardous, PCB, asbestos, sharps, or hazardous waste components.
    3. Links for characterization of typically generated radioactive wastes:
       1. Radioactive dry waste
       2. Radioactive liquid waste
       3. Scintillation vials
       4. Radioactive lead waste
       5. High-efficiency particulate air (HEPA) Filters
       6. Radioactive animal tissue
       7. Radioactive empty containers
       8. Combined wastes — These are radioactive California-only hazardous wastes.
       9. Mixed wastes, including transuranic mixed wastes
       10. Radioactive sealed sources — If a radioactive sealed source that is no longer needed cannot be transferred to a new owner or returned to the vendor, it is a waste.
           1. Characterize the sealed source for disposal as a radioactive or mixed waste (EWRP02 Technical Note: Sealed Source Classification and Disposal).
17. Treated wood wastes
18. Universal wastes are:
    1. Aerosol cans (with exceptions)
    2. Batteries (with exceptions)
    3. Fluorescent lamps
    4. Mercury-containing equipment
    5. E-waste — Find more information on e-wastes in the Generator Guidelines, and see the E-Waste Management flow diagram in Appendix A.4 of this program.
19. Used (waste) oils. Used oil is a California-only hazardous waste.
    1. Examples of used oils are crankcase, transmission, hydraulic, turbine, transformer, and compressor oils.
    2. Examples of what are not used oils include antifreeze, solvents, brake fluid, fuels, grease, and cooking oils.
    3. Oil containing 5 parts per million (ppm) or more PCBs or more than 1,000 ppm total halogens are not used oils. These are, however, also hazardous wastes.
    4. Never mix your used oil with any other waste.
    5. Contact your Generator Assistant for more information on classification of used oil and oil filters.
20. Contact your Generator Assistant as needed to complete characterization of your waste.

Work Process D. Generator Waste Storage

1. When wastes are first generated, they are accumulated or stored at or near where they were generated and are the under control of the waste generator or other designated personnel.
2. Perform waste-generating processes and waste-handling activities in accordance with applicable health and safety requirements.
   1. Contact the Industrial Hygiene Group if your waste-generating activities involve asbestos or finely divided or powdered toxic metals (e.g., lead, beryllium, cadmium).
      1. For health and safety purposes, additional labeling and, in some cases, packaging requirements apply to waste containing asbestos, loose lead, beryllium, or cadmium contamination.
   2. Contact Radiation Protection Group personnel if your waste generating activities involve radioactive materials.
   3. Consult the Chemical Hygiene and Safety Plan and the Laboratory safety coordinator to determine safety requirements applicable to your laboratory activities.
3. Medical/Biohazardous Waste Storage. Store as outlined in the Medical and Biohazardous Waste Generator’s Guide (part of the Biosafety Manual).
4. Hazardous and Mixed-Waste Storage. Store hazardous waste in closed containers in one of the following:
   1. SAA
   2. WAA — see WAA Guidelines.
   3. Store mixed waste in an MWSAA.
   4. Place hazardous/mixed waste in an SAA, WAA, or MWSAA container with a properly completed “HAZARDOUS WASTE” label as soon as possible following generation. Mixed waste also require a radioactive material tag.
   5. Use only SAA, WAA, or MWSAA containers and secondary containment that are in good condition and made of materials compatible with the stored waste.
      1. Container compatibility information can be found at http://www.coleparmer.com/techinfo/chemcomp.asp and in the Chemical Hygiene and Safety Plan.
   6. Segregate and separate incompatible waste according to its hazard category.
      1. Chemical compatibility information can be found at http://response.restoration.noaa.gov/oil-and-chemical-spills/chemical-spills/response-tools/chemical-reactivity-worksheet.html and in the Chemical Hygiene and Safety Plan.
   7. Store all glass hazardous waste containers and all liquid hazardous waste in secondary containment.
   8. Do not store any hazardous/mixed waste that poses a safety hazard in an SAA, WAA, or MWSAA.
      1. Ensure the wastes are accumulated in compliance with applicable National Fire Protection Association (NFPA), Cal OSHA regulations, and LBNL health and safety requirements.
      2. Contact the Division Safety Coordinator with questions regarding safety issues.
   9. Ensure containers of hazardous waste are securely closed except when adding or removing waste.
   10. Ensure hazardous-waste accumulation quantity limits are not exceeded.
       1. Do not exceed the maximum storage quantities allowed in an SAA or MWSAA. These are 55 gallons of each compatible hazardous-waste stream or 1 quart of each compatible acutely or extremely hazardous waste.
       2. Store larger quantities of hazardous waste in WAAs.
   11. Store hazardous wastes within applicable time limits.
       1. LBNL policy dictates that hazardous and mixed wastes stored in SAAs or MWSAAs on the LBNL campus must be requisitioned for pickup within 275 days of initial generation, and
       2. Hazardous waste stored in WAAs on the LBNL campus must be requisitioned for pickup within 60 days of generation.
5. Universal Waste Storage
   1. Store each type of universal waste (e.g., batteries, aerosol cans, etc.) separately.
   2. Complete and attach a universal waste label to each container of universal waste.
   3. Keep universal waste containers closed except when adding or removing wastes.
   4. Do not store universal waste in the work area for more than one year from the date of generation.
6. Radioactive Waste Storage
   1. Attach (or post nearby) a radioactive material tag, properly filled out, on each container of radioactive or combined waste once the first item is placed inside the container. 
      1. Contact your Generator Assistant for radioactive material tags.
   2. Keep containers of radioactive waste securely closed when not in use.
   3. Contact the Radiation Protection Group regarding other requirements applicable to radioactive material storage.
   4. Do not store radioactive and combined waste in the work area for more than one year after initial generation.
7. PCB Waste Storage
   1. Label and store PCB wastes as hazardous waste in an SAA or WAA.
   2. Do not store PCB wastes (>50 ppm) for more than 30 days in the work area.
   3. Mark PCB waste (>50 ppm) containers and the entrances to the buildings where they are stored with a PCB mark.
8. Asbestos Waste Storage
   1. Label and store friable asbestos wastes as a hazardous waste in an SAA or WAA.
   2. Additional packaging and labeling requirements for asbestos wastes are given in Chapter 36 of the ES&H Manual.
9. Used Oil Waste Storage.Label and store used oil as a hazardous waste in an SAA or WAA.
10. Contact your Generator Assistant for guidance on storage of other wastes.

Work Process E. Generator Waste Treatment

1. Waste of any kind cannot be treated without first consulting your Generator Assistant. Even if allowable by law, changes in a waste’s physical or chemical characteristics or composition may make the waste more expensive or difficult to dispose of, or create an unacceptable environmental, health, or safety hazard.
2. California regulations allow hazardous-waste treatment without a permit under limited scenarios and only in accordance with stringent regulations.
   1. Laboratory benchtop treatment is one such allowable treatment that can be utilized within laboratory facilities.
3. It is LBNL policy that benchtop treatment be used to treat any laboratory experimental-reaction waste mixture or waste aqueous solution that contains nitric acid (HNO3) if the following conditions occur:
   1. The nitric acid solution is >5% by weight (0.8 M or pH<1).
   2. Organic constituents are present and the solution contains nitric acid at any concentration.
4. Consider using a laboratory benchtop treatment in cases where it will:
   1. Reduce the hazards and facilitate handling of a hazardous or mixed waste
   2. Reduce the costs of treatment and disposal of a hazardous or mixed waste
   3. Eliminate generation of a hazardous or mixed waste with no-path-to-disposal
5. Plan, obtain authorization, and perform laboratory benchtop treatments of hazardous waste as outlined on the Waste Management Group home page.
   1. Perform benchtop treatment within 10 calendars days following the day the hazardous waste was initially generated.
   2. Treat wastes (using an approved benchtop treatment procedure) posing a safety hazard when placed in an SAA untreated as soon as possible following generation and before transfer to a SAA container.

Work Process F. Waste Disposal

1. Removal of most wastes from generator’s work locations is initiated by the generator (or designee) and coordinated through the Waste Management Group.
   1. Sink disposal of hazardous materials is strictly prohibited unless specifically authorized.
   2. Medical/Biohazardous Waste Disposal. Follow the instructions in the Medical and Biohazardous Waste Generator’s Guide (part of the Biosafety Manual).
   3. Hazardous Waste Disposal. Use the Electronic Hazardous Waste Requisition System to initiate waste disposal.
      1. You must have completed EHS-604 Hazardous Waste Generator Training to submit a completed hazardous waste requisition. .
   4. Radioactive and Mixed Waste Disposal. Use the Radioactive/Mixed Waste Disposal Requisition form.
   5. Use the Generator Guidelines or contact your Generator Assistant for information necessary to disposal of other wastes (e.g., universal waste).
2. The WMG encourages personnel to periodically remove unwanted chemicals from the work area.
   1. Peroxide-forming compounds that have been stored either beyond useful shelf life, or for which age and history cannot be determined, are considered unsafe.
      1. If found, have these tested and then requisition as a hazardous waste for pickup. Contact your Generator Assistant for help.
   2. Personnel leaving LBNL must determine the fate of any remaining work chemicals they used (see the LBNL Space Management Policy).
      1. Abandoned chemicals present compliance and safety liabilities.
      2. Characterization of abandoned chemicals or unknowns may incur significant costs to the division.
      3. Be aware of any specific rules and requirements the division has regarding disposal of unwanted chemicals before you leave LBNL.
   3. General procedure to remove unwanted chemicals:
      1. Determine whether any other researcher in the area wants the chemicals. If so, transfer custody to them and update the Chemical Management System.
      2. If the chemicals are to be disposed of, use the Chemical Management System link to the electronic hazardous waste requisition system to initiate the waste disposal process.
      3. Contact Waste Services Generator Assistants for additional guidance.
3. When buildings or areas within a building are to be decommissioned or demolished, all building materials must be assessed and managed appropriately.
   1. Supplies, products, apparatuses and equipment, trash, hazardous and other regulated wastes, and waste containers must be removed prior to vacating the space. This includes:
      1. All chemicals and chemical-related products such as cleaning compounds, surplus chemicals, stock solutions, and experimental products
      2. Waste and waste containers including hazardous waste SAA containers, universal waste containers, and containers for sharps, medical wastes, etc.
      3. Radioactive equipment, sealed sources, radioactive waste, mixed-wastes and radioactive waste containers, etc.
   2. For transportation of materials other than waste, contact Transportation Services.
      1. For transportation of DOT hazardous materials other than waste, see the LBNLTransporting and Shipping Hazardous Materials policy.
   3. For building construction, renovation, and demolitions, control and management of hazardous materials and wastes must be addressed in the demolition scope of work.  
      1. Contact the Waste Services Team Leader for assistance.
4. Manage cleanup materials from a spill or decontamination (e.g., wipes, absorbent pigs, etc.) as a hazardous waste.

Work Process G. Large-Volume and Non-Routine Waste Management

The generation of large volumes of waste or non-routine waste often requires specialized consideration. During routine operations, when waste is generated, it is accumulated or stored at or near where it was generated, under the control of the waste generator or designated personnel. However, activities that result in the generation of non-routine waste or waste in large volumes require planning and approval prior to generation, and must be managed during and post generation to ensure compliance with Berkeley Lab policy and waste regulations in order to efficiently support Laboratory operations. Preparation, provisions, communication, and scheduling requirements may vary, depending on the type of waste and nature of the project or effort generating the waste. Prior to the commencement of project activities and during the very initial planning phases, coordination with the EHS Waste Services Team (WST) and subject matter experts (SMEs) is of paramount importance to ensure a reliable and compliant outcome. The information provided below offers general guidance for use during project planning, and focuses on the types of waste most commonly generated in large volumes at the Laboratory.

1. Prerequisites
1. If there is a potential to generate non-routine waste or waste in large volumes, the cognizant waste generator shall promptly notify and coordinate project activities with the WST Generator Assistants (GA) and other EHS Division SMEs.
2. The waste generator will label the waste or containers and work with the GA to establish a Satellite Accumulation Area (SAA) or a Waste Accumulation Area (WAA), as needed (see Guidelines for Generators to Meet HWHF Acceptance Requirements for Hazardous, Radioactive, and Mixed Wastes at Berkeley Lab [PUB-3092]).
3. The waste generator, or a division-assigned project manager and/or a work supervisor (PM/WS), will ensure preparation of either a Work Plan or Waste Management Plan (see Section 20.6 for definitions of Work Plan and Waste Management Plan) and oversee and coordinate its peer review and approval.
4. Prior to beginning work activities, a Waste Services Request Form shall be submitted by the project to the GA for approval by the WST leader prior to work.
5. The waste generator and/or PM/WS takes primary responsibility for completing planned work in accordance with the submitted plan, with support from i) the waste generator, who is responsible for the proper generation, packaging, labeling, staging, and requisitioning of the generated wastes; ii) the GA, who will assist with identifying and sourcing required containers, and will provide guidance on compliant storage, labeling, and disposition; and iii) other SMEs, as appropriate.
6. The waste generator, with assistance from the Waste Services Team GA, will arrange for the transfer of the generated wastes from the job site to an existing SAA or WAA, or will set up a compliant SAA or WAA for staging prior to disposition. The GA will ensure that all project personnel are aware of the regulatory timing and restrictions on the SAA or WAA areas (three days for large-volume storage at SAAs [>50 gallons], and 60 days per LBNL policy for WAAs) and, if the waste is to be dispatched directly to disposal, prepare shipping papers for transport.
7. The PM/WS, coordinating with the assigned GA, will work to ensure that there is an LBNL representative at the work site at all times during waste handling and transfer activities, and that the work site is confirmed safe and environmentally sound at the end of each workday.
8. The flowchart presented in Figure G-1 is provided to guide the waste generator in the planning stages preparing for waste disposal. It forwards the waste generator to flowcharts providing additional guidance focusing on the special handling and added compliance requirements when generating and planning the disposition of asbestos, demolition waste, waste from laboratory cleanouts, polychlorinated biphenyls (PCBs), soil, waste from specials projects, and treated wood waste. Additional resources for disposal of these wastes can be found as described in the following sections of this work process.
2. Asbestos. If large or non-routine quantities of asbestos wastes will be generated in a work activity, contact the WST and follow the workflow process in Figure G-1 and Figure G-2.
1. See Work Process B, Asbestos Identification Process, of the ES&H Manual Asbestos Hazards and Controls program for more information on identifying and characterizing asbestos waste.
2. See Work Process D, Class I and II Asbestos Work Procedures, of the ES&H Manual Asbestos Hazards and Controls program for more information on management of asbestos waste.
3. Demolition Waste
1. If large volumes of demolition wastes will be generated, contact the WST and follow the workflow process in Figure G-1 and Figure G-3.
2. See Work Process F, Waste Disposal, of this ES&H Manual program for more information on demolition waste disposal.
4. Laboratory Cleanouts. A “laboratory cleanout” is defined as the removal of unwanted, unused, abandoned, or expired chemicals from a laboratory. Waste generators are encouraged to perform laboratory cleanouts to reduce and control the amount of chemicals in use and in inventory. Lab cleanouts frequently generate a large volume of a variety of hazardous waste, and although the individual quantities may be small, the volume of waste generated by a lab cleanout can be considered a large volume. If a lab cleanout is planned, follow the workflow process in Figure G-1 and Figure G-4.
1. See Other Waste Disposal on the EHS Waste Management webpage for general guidance on how to handle laboratory waste.
2. See Work Process C, Waste Identification and Characterization, of this ES&H Manual program for more information.
5. Polychlorinated Biphenyl (PCB). If there is a potential to generate a large quantity of PCB waste or equipment contaminated with PCBs, timing is critical — from the time PCBs are identified to the time they are transported off site. Additional information is provided in Procedure WMG02, Classification and Handling of PCB Waste.  
1. To ensure compliance, follow the work process in Figure G-1 and Figure G-5.
2. For detailed guidance, see Procedure WMG 02, Classification and Handling of PCB Waste.
6. Soil. If there is a potential to generate more than a small quantity of a contaminated soil, the handling and disposal of the soil must adhere to requirements of the Soil Management Plan (SMP), a regulatory requirement overseen by the EHS Environmental Services Group. Refer to the workflow process in Figure G-1 and Figure G-6.
1. See the ES&H Manual Soil and Groundwater Management Program for more information on the identification and characterization of waste soil.
2. See Work Process A, General Requirements and Flowchart, of the ES&H Manual Soil and Groundwater Management Program.
3. See Work Process B, Preparing a Soil Management Plan, of the ES&H Manual Soil and Groundwater Management Program, for more information on the preparation of an SMP.
7. Special Projects. Special projects are defined as those LBNL activities that generate non-routine waste, and which are not specifically discussed in other categories here. An example would be a small demolition or refurbishment project performed by personnel on site (rather than subcontracted, as larger demolition projects usually are). Special projects have the potential to generate unusual wastes requiring special handling and/or large volumes of a variety of hazardous wastes. Examples include oversized pieces of equipment and large volumes of debris wastes. If a special project is planned, refer to the workflow process in Figure G-1 and Figure G-7.
1. See Other Waste Disposal on the EHS Waste Management webpage for general guidance on how to handle lab waste.
2. See Work Process C, Waste Identification and Characterization, of this ES&H Manual program for more information.
8. Treated Wood. If treated wood waste (TWW) will be generated in a work activity, contact the WST and refer to the workflow process in Figure G-8. For additional information, refer to the Requirements for Generators of Treated Wood Waste (TWW) Fact Sheet located in Generator Resources on the EHS Waste Management webpage.
1. See Work Process C, Waste Identification and Characterization, of this ES&H Manual program for more information on identification and characterization of TWW.
2. See Work Process D, Generator Waste Storage, of this ES&H Manual program for more information on accumulation of TWW.

For additional information, also refer to the Fact Sheet located in Generator Resources (http://www2.lbl.gov/ehs/waste/index.shtml) listing the requirements for generators of treated wood waste

Figure G-1. Flow Diagram for Large Volume and Non-Routine Waste Streams

Notes for Figure G-1:

1. Large volume of waste means more than one 55 gallon container.
2. Work planning is performed prior to waste generation and is coordinated with the Waste Services Team (and other EHS subject matter experts as required).

 
Figure G-2. Flow Diagram for Large-Volume and Non-Routine Asbestos Waste Disposal

Note:
1. Or as directed by a Work Plan and/or GA; some forms of non-friable asbestos are not hazardous waste.

 
Figure G-3. Flow Diagram for Large-Volume and Non-Routine Subcontracted Demolition Project Waste

NOTES:

1. May require handling as MLLW depending on receiving facility.
2. Any salvage, reuse, recycling must be in accordance with applicable regulations, best management practices and facility acceptance criteria. EHS concurrence is required.
3. Examples of alternate management are those used for universal and treated wood waste.

Figure G-4. Flow Diagram of Large-Volume and Non-Routine Laboratory Clean-Out Waste

NOTES:
1. Large quantity of laboratory waste applies to volumes of 40 or more items for disposition.
2. The chemical owner must ensure that all chemicals that have been disposed, used up, or taken off site or reassigned are updated in CMS as soon as possible.

Figure G-5. Flow Diagram for Large-Volume and Non-Routine PCB Waste

Notes:
 1. See EHS Waste Management WMG02 “Classification and Handling of PCB Wastes.”
 2. Or as negotiated and approved by EPA/DTSC and/or directed by Waste Services.

   
Figure G-6. Flow Diagram for Large Volume and Non-Routine Soil

 Notes:
 1. See EH&S Manual, Chapter 20 Waste Management Work Process A
 2. Other (non-waste related) approvals may also be required to begin work.
 3. Or as negotiated and approved by EPA/DTSC and/or directed by Waste Services.

Figure G-7. Flow Diagram of Large-Volume and Non-Routine Special Project Waste

Notes:
1. May require handling as MLLW depending on receiving facility.
2. Any salvage, reuse, recycling must be in accordance with applicable regulations, best management practices and facility acceptance criteria. EHS concurrence is required.

Figure G-8. Flow Diagram Large-Volume and Non-Routine Treated Wood Waste
Notes:

1. Regulatory approval may be required for any reuse of removed treated wood since it is a hazardous waste. Treated wood CANNOT be burned.
2. Because TTW contains hazardous chemicals, at elevated levels, it is subject to California’s Hazardous Waste Control Law. Alternative Management Standards set by the state lessen storage requirements, extend accumulation periods, allow shipments without a hazardous waste manifest and a hazardous waste hauler, and allow disposal at specific non- hazardous waste landfills.
3. Training briefing required for all individuals who handle TWW.

20.8 Source Requirements

• 15 USC, Chapter 53, 2601-2692, Toxic Substances Control Act
• 42 USC, Chapter 82, 6901 et seq., Resource Conservation and Recovery Act (RCRA), as amended
• 10 CFR 20, Subpart K, Section 20, 2005, Disposal of Specific Wastes
• 40 CFR 260 - 279, Hazardous Waste
• 40 CFR 761, Polychlorinated Biphenyls (PCB)
• 49 CFR, Subtitle B, Other Regulations Relating to Transportation, Chapter I, Research And Special Programs Administration, Department Of Transportation (for waste, have to comply with packaging, marking, labeling, and shipping document requirements)
• 22 CCR Division 4.5, Chapter 10, Article 2, 66260.1 et seq., Hazardous Waste Regulation
• California Health and Safety Code, Division 20, Chapter 6.5, Hazardous Waste Control
• California Health and Safety Code, Division 104, Part 14, 117600-118360 California Medical Waste Management Act
• DOE O 414.1D, Quality Assurance
• DOE O 435.1, Chg 1, Radioactive Waste Management, Attachment 1, Contractor Requirements Document
• DOE M 435.1-1 Admin Chg 2, Radioactive Waste Management Manual, applicable chapters and sections listed below:
• Chapter I - General Requirements and Responsibilities: All sections except that DOE orders incorporated by reference are applicable only to the extent they were adopted site-wide in the Berkeley Lab Necessary and Sufficient Set of standards.
• Chapter III - Transuranic Waste Requirements sections: A and B, D except for (4) relative to disposal facility requirements, F, G, H and I, (J, K, O, and P only when an off-site option for Berkeley Lab TRU waste has been identified by DOE and the off-site facility has established a WAC applicable to Berkeley Lab), L, N(1), N(2), N(3), Q(1), Q(2) except that ventilation exhaust monitoring is limited to MW6 and MW7 as specified in the HWHF SAD.
• Chapter IV - Low Level Waste Requirements sections: A, B, D, and F, G except for 1(d) relative to disposal facility requirements, H(1), H(2), I, J, K and L, M, N, N(2), O and R(1) except that ventilation exhaust monitoring is limited to MW6 and MW7 as specified in the HWHF SAD.
• DOE O 458.1 Change 2, Radiation Protection of the Public and Environment.
• DOE O 460.lC, - Packaging and Transportation Safety, Attachment 1, Contractor Requirements Document sections: 1, 2, 3, and 6.b

Other Driving Requirements

• FFCA Order for LBNL HWCA 95/96-016, Site Treatment Plan for Mixed Waste
• Bay Area Air Quality Management District Regulation 11, Rule 2 – Asbestos Demolition, Renovation and Manufacturing
• Berkeley Municipal Code, Chapter 11.52, Hazardous Materials Management as applied to generator areas
• Waste Treatment, Recycling and Disposal Facilities Waste Acceptance Criteria
• Hazardous Waste Treatment and Storage Permit Application for the Lawrence Berkeley Laboratory Hazardous Waste Handling Facility (also known as the Part B Permit)

Appendix A. Waste Management Flow Diagrams

1. Overview – Generator Management of Hazardous Waste
2. Overview – Generator Management of Radioactive Waste
3. Overview – Generator Management of Mixed Waste
4. E-Waste Management
5. Medical/Biohazardous Waste Management

A.1. Overview – Generator Management of Hazardous Waste

A.2. Overview – Generator Management of Radioactive Waste

A.3. Overview – Generator Management of Mixed Waste

A.4. E-Waste Management

A.5. Medical/Biohazardous Waste Management

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