Work Process A. General Requirements20.8 Source Requirements
Work Process B. Training Requirements
Work Process C. Waste Identification and Characterization
Work Process D. Generator Waste Storage
Work Process E. Generator Waste Treatment
Work Process F. Waste Disposal
Work Process G. Large-Volume and Non-Routine Waste Management
Appendix A. Waste Management Flow Diagrams
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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.
The LBNL waste management programs encompass:
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:
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:
Municipal solid waste and liquid sanitary wastes are typically excluded from the scope of waste management programs.
The waste management programs apply to all employees, affiliates, and subcontractors.
None.
Role |
Responsibility |
All employees, affiliates, and subcontractors |
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Supervisors and work activity owners |
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Facilities Division |
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EHS Division groups |
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Waste Generator Assistants |
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Term |
Definition |
Any wastes defined as acutely hazardous by the California Code of Regulations (CCR), Title 22, Division 4.5, Chapter 11, Article 4. These are the P-listed wastes. |
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Wastes that are asbestos-containing materials, including waste materials that contain friable asbestos in an amount of 1% or greater by weight, area, or count, and asbestos-contaminated materials (e.g., protective clothing and equipment). Wastes containing 1% or greater friable asbestos are California-only hazardous waste. |
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Benchtop treatment |
State of California–authorized hazardous waste treatment activity for treating small quantities of laboratory hazardous waste produced from laboratory chemical procedures conducted for the purposes of education; research; chemical analysis; clinical testing; or product development, testing, or quality control (California Health and Safety Code, Section 25200.3.1(c ). |
Biohazardous waste |
Waste defined in the California Medical Waste Management Act (California Health and Safety Code, Section 117600 – 118360). Examples of bio-hazardous waste include fluid blood or fluid blood products from animals known to be infected with diseases that are highly communicable to humans; waste containing discarded materials contaminated with infectious secretions; microbiology and surgery specimens; cultures or stock wastes from medical, pathology, research, and industrial laboratories; and animal parts or animal fluids contaminated with infectious agents known to be contagious to humans. |
Radioactive waste that also contains California-only hazardous waste |
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Discarded material |
Material that has been relinquished, recycled, or is inherently waste-like. |
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Any hazardous waste or mixture of hazardous wastes whose exposure to humans could likely result in death, a disabling personal injury, or a serious illness because of its quantity, concentration, or chemical characteristics (CCR Title 22, Section 66260.10) |
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Hazardous material |
Any substance or material that could adversely affect the safety of the public, handlers, or carriers during transportation. All Department of Transportation (DOT) hazardous materials are listed in the DOT's Hazardous Material Table. |
Hazardous waste |
Solid wastes designated hazardous by California regulations. (CCR Title 22, Section 66261.3). For the purposes of this definition, a solid can be a solid, semisolid, liquid, or contained gas. Hazardous waste includes acutely hazardous waste, extremely hazardous waste, California-only hazardous waste, RCRA hazardous waste, special waste, and universal waste. |
Medical waste |
Waste defined in the California Medical Waste Management Act (CCR 22, Section 117690 – 118360). |
Mixed waste |
Waste that meets the definition of a radioactive waste and the definition of an RCRA hazardous waste. |
Mixed transuranic waste |
Waste that meets the definition of a transuranic waste and the definition of a RCRA hazardous waste. |
SAA used for the storage of mixed and mixed transuranic waste. |
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Nanomaterial-bearing waste |
A waste material that has come into contact with dispersible engineered nanomaterials (and that has not been decontaminated). |
Non-RCRA hazardous waste |
A waste that does not meet the federal criteria for a hazardous waste, but which meets California specific state regulatory criteria for a hazardous waste. These include waste defined as a corrosive solid in CCR Title 22, Section 66261.22(a)(3) or 66261.22(a)(4); waste defined as toxic for anything except for federal toxicity as defined in CCR Title 22, Section 66261.24(a)(1); waste excluded under federal regulation, but exhibiting any characteristics of a hazardous waste defined in CCR Title 22, Chapter 11, Article 3 (ignitable, corrosive, reactive or toxic); mercury-containing wastes as defined in CCR Title 22, Chapter 11, Article 4.1; and containers that are “RCRA empty” but not empty by California regulation. |
Any waste for which no treatment and/or disposal facility currently exists. |
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Any waste containing PCBs in a concentration meeting or exceeding applicable 40 Code of Federal Regulations (CFR) 761 or CCR Title 22, Section 66261.24 criteria. |
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Peroxide-forming compounds |
Materials that react with oxygen to form peroxides that can explode with impact, heat, or friction. See “Control Procedures for Peroxide-Forming Compounds” in the Chemical Hygiene and Safety Plan. |
Process knowledge (also referred to as acceptable knowledge) |
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Radioactive sealed source |
Radioactive material that is permanently bonded or fixed in a capsule or matrix designed to prevent release and dispersal of the radioactive material under most accidental conditions, normal use and wear for which it was designed. |
Radioactive waste |
Any garbage, refuse, sludge, and other discarded material, including solid, liquid, semisolid, or contained gaseous material that must be managed for its radioactive content. |
Resource Conservation and Recovery Act (RCRA) hazardous waste |
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An area where, following initial generation, 55 gallons of each compatible hazardous waste stream or 1 quart of each compatible acutely or extremely hazardous waste are accumulated in compliance with CCR Title 22, Section 66262.34. |
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Devices having acute rigid corners, edges, or projections capable of piercing or cutting the skin. These include sharps regulated as medical waste, sharps with non-medical waste contamination and un-regulated, un-contaminated sharps that pose a safety hazard. Examples include drill bits capable of piercing or cutting the skin (thin bits like hypodermic needles), needles, razor blades, scalpel blades, syringes with needles, small shards of plastic, and glass. |
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Transuranic waste |
Waste containing 100 nCi/g or more alpha-emitting transuranic isotopes (atomic number >92) with half-lives greater than 20 years. Excepted from this definition are: (1) high-level radioactive waste; (2) waste that the Secretary of Energy has determined, with the concurrence of the Administrator of the Environmental Protection Agency, does not need the degree of isolation required by the 40 CFR 191 disposal regulations; or (3) waste that the Nuclear Regulatory Commission has approved for disposal on a case-by-case basis in accordance with 10 CFR 61. |
Treated wood waste (TWW) |
Wood treated with a chemical preservative for protection against pests and environmental conditionals. Treated wood may be regulated as a hazardous waste in California. |
Universal waste |
Hazardous wastes that are exempted from the traditional hazardous waste management requirements, provided generators follow regulatory-defined management requirements for ensuring safe handling, recycling, and disposal. Universal wastes are defined in CCR Title 22, Section 66261.9, and include batteries, cathode ray tubes (CRTs), CRT glass, electronic devices, aerosol containers, and mercury-containing devices (thermometers, thermostats, relay switches). |
Oil refined from crude oil, or synthetic oil, that has been used, and, as a result of use, extended storage, or spillage is contaminated with physical or chemical impurities. |
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A regulated storage area designed for the accumulation of hazardous wastes for up to 90 days in quantities that can exceed the quantities allowed for storage in an SAA. |
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Waste characterization |
The identification of waste components and properties through a review of process knowledge or by nondestructive examination, nondestructive assay, or sampling and analysis, as necessary to comply with applicable storage, treatment, handling, transportation, and disposal requirements. |
Any person, by site, whose act or process produces reusable property, recyclable material or waste, or whose act first causes a hazardous waste to become subject to regulation. It is the individual responsible for the process that generates the waste, typically the principle investigator, project manager, or qualified designee. The generator brings a waste stream to the attention of the Generator Assistant and provides waste process knowledge information to that person. Generally, the Waste Management Group then assumes many of the responsibilities of the generator as defined in RCRA and state of California regulations. Where subcontractors are performing work at LBNL, the facility or project manager who requested the work assumes responsibilities of the generator, and assumes ownership of all waste generated by the subcontractor as a result of that work. |
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Waste Management Plan | Typically prepared by the project team for large or complex activities or projects detailing work to be performed by a subcontractor. |
Work Plan |
Typically prepared by the project manager/work supervisor outlining the work scope and including the waste generation and handling process to support LBNL activities generating non-routine waste and atypical volumes. The Work Plan will describe the process involved in the generation of the waste as well as the staging and transport activities. At a minimum the Work Plan shall provide: 1) a characterization of the waste(s) to be generated; 2) the expected quantity of the waste to be generated; 3) names and contact information of LBNL individuals, subcontractors, vendors, etc. who will be involved; 4) description of work tasks in sufficient detail to ensure work is adequately planned and can be performed compliantly; and 5) the sequence and schedule of the planned tasks. The Work Plan must be approved and signed by all involved parties prior to start work. |
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.
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.
Role |
Specified Training |
Generators of hazardous waste |
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Generators of radioactive and/or mixed wastes |
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Waste Accumulation Area managers |
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Personnel who handle universal waste |
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Generators of medical/biohazardous waste at LBNL |
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Personnel who perform benchtop treatment of laboratory hazardous waste |
EHS-348, Chemical Hygiene and Safety Training and EHS-353 refresher as needed; EHS-604, Hazardous Waste Generator Training; and benchtop treatment procedure-specific training on how to conduct the treatment, manage treatment residuals, and respond effectively to emergency situations |
Personnel who either handle or who may be exposed to particularly hazardous substances |
EHS-348, Chemical Hygiene and Safety Training and EHS-353 refresher as needed, or EHS-345 for Facilities personnel |
Personnel managing asbestos (including asbestos waste) |
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Personnel managing lead- or beryllium-metal-contaminated materials (including wastes, e.g., PPE) |
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Personnel managing radioactive materials (including wastes) |
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.
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:
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:
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:
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