This ``Environmental Protection Implementation Plan'' is intended to ensure that the environmental program objectives of Department of Energy Order 5400.1 are achieved at SNL/California. This document states SNL/California's commitment to conduct its operations in an environmentally safe and responsible manner. The ``Environmental Protection Implementation Plan'' helps management and staff comply with applicable environmental responsibilities.

/pdf/environmental-protection-implementation-plan-agpu8kay5g.pdf

Environmental protection Implementation Plan

This Quality Assurance Project Plan documents the quality assurance activities for the Wastewater/Stormwater/Groundwater and Environmental Surveillance Programs. This QAPP was prepared in accordance with DOE guidance on compliance with 10CFR830.120.

/pdf/quality-assurance-project-plan-18sig954qt.pdf

Quality Assurance Project Plan

This Enviromnental Protection Implementation Plan is intended to ensure that the environmental program objectives of Department of Energy Order 5400.1 are achieved at SNL/California. This document states SNL/California’s commitment to conduct its operations in an environmentally safe and responsible manner. The Environmental Protection hnplen-zenfation Plan helps management and staff comply with applicable environmental responsibilities. Environmental Protection Implementation Pian 3 SANDIA NATIONAL LABORATORIES/CALIFORNIA. For the Perioik November 9,1999 to November 9,2000 Prepared: October 1999 Prepared by Environmental Operations Department, 8516 Sandia National Laboratories/ Cal.i.fomia P. O. BOX 969, MS 9221 Livermore, CA 94551-0969.

Portions of this document may be illegible in electronic image products.

Images are produced from the best available original document.

SNL/California incorporates the highest regard for environment, safety, and health (ES&H) into every experiment and all site operations.

The site operates under the scope of Federal, State, and local regulatory authorities and has obtained all applicable operating permits.

Furthermore, SNL/Califomia strives to go beyond compliance with legal requirements by making every effort practical to reduce impacts to the environment to levels as low as reasonably achievable.

DISCLAIMER

The Site Operations Center is responsible for ES&Hat the SNL/Cal.ifornia site.

An important part of the center's mission is to ensure the health and safety of SNL/California employees and the general public, and to protect the environment.

The primary objective of the ES&H departments is to provide guidance and assistance to the line organizations in order that they might meet the requirements of ES&H laws and regulations in the most efficient manner possible.

The Site Operations Center has two departments involved in ensuring workplace safety and protection of the environment Health and Safety, and Environmental Operations.

The ES&H departments receive funding from both direct (programs specifically funded by DOE) and indirect (programs funded from site overhead) sources.

Site Operations Center

The Pollution Prevention Program is responsible for promoting pollution prevention and source reduction of all wastes, for all site activities.

This program performs pollution prevention opportunity assessments  for the site.

Other program activities include gathering process information, .

SNL /California has a waste minimization coordinator to manage this effort.

Pollution Prevention

The Air Quality Program is responsible for the regulatory compliance of all air emission sources at the SNL/California site.

Q Determines and documents compliance requirements., .

Prepares reports and permit applications required by air quality regulations. .

Manages a voluntary Trip Reduction Program, which surveys employee/contractor transportation methods and educates employees and contractors about transportation alternatives.

Air Quality

The Environmental Planning Program is responsible for implementing NEPA at the SNL/California site by evaluating proposed projects, activities, and programs for potential environmental and human impacts.

Key environmental concerns include potential air emissions (through vents or stacks on buildings), water effluents (storm water or sanitary sewer outfall), human exposure to hazardous substances, and waste generation and minimization.

In addition, the Environmental Planning Program acts as the point of contact for the ES&H Interdisciplinary Team (IDT).

The IDT is responsible for providing guidance to the line organizations as they plan and implement projects on or off site.

Q Coordinates and prepares ES&H information for reporting SNL ES&H performance for the DOE/SNL laboratory appraisal agreement.

Environmental Planning

Pursuant to DOE Orders 5400.1 and 232.1A, SNL/California, as a DOE-operating contractor, is responsible for appropriately reporting environmentally significant events.

1/6SNL/California will comply with the notification criteria contained in the DOE emergency preparedness orders (DOE Order 5500 series).

Various Federal, State, and local laws and regulations also require SNL/California to report environmentally significant occurrences.

2.0 NOTIFICATION OF ENVIRONMENTAL OCCURRENCES

Every employee in every line organization has been instructed to report environmental incidents of any type to the ES&H Hotline, ext. 4-ES&H (L3724), at SNL/California.

The Occurrence Reporting Group, in the Security Operations Department, provides training in occurrence reporting procedures and responsibilities to all SNL/California employees and contractors.

2,1.1 Line Organizations

The Occurrence Management Group in the Site Operations Center evaluates incidents and determines the appropriate level of notification.

The Security Operations Department maintains the SNL/California Emergency Preparedness Plan.

This plan includes "Emergency Plan Implementation Procedures," which address notification responsibilities.

As appropriate, Site Operations Center notifies DOE/KAO, SNL/New Mexico organizations, and other agencies of any incidents.

2.1,2 Site Operations Center

DOE/KAO is responsible for reporting events to the DOE/AL Emergency Operations Center (EOC).

DOE/KAO acts as a liaison between SNL/California and Federal, State, and local agencies.

2.1.3 DOE Kirtland Area Office

Occurrence reports (ORS) are required for any off-normal or unplanned event having programmatic significance, such that it adversely affects or potentially affects performance, reliability, or safety of a facility.

The Occurrence Reporting Program is responsible for complying with the OR requirements * described in DOE Order 232.1A.6 .

SNL/California reports events or conditions significant enough to require an OR to the DOE, in accordance with the time requirements specified in DOE Order 232.

All reportable incidents require the facility manager to submit a written report to the DOE within 24 hours.

Occurrence Reports

An unplanned air release that requires reporting to the BAAQMD is reportable to the DOE under DOE Order 232.1A requirements.

The Air Quality Program will notify the Environmental Operations Department manager and the OM Rep., who will ensure that the DOE is informed.

2.2.3 State of California Bay Area Air Quality Management District

Following an environmental occurrence, SNL/Califomia will prepare a written report in accordance with the requirements of DOE Order 232.1A.6.

The appropriate facility manager is responsible for ensuring that the reports are transmitted electronically to the Occurrence Report and Processing System database.

The Environmental Operations Department is responsible for maintaining evidence files and copies of all reports.

These reports are made available to auditors and regulatory agencies.

2.3.1 DOE Requirements

DOE Order 5400.1 requires each DOE site to prepare an annual summary environmental report.

It presents effluent and environmental monitoring data and discusses the Environmental Restoration Program and other environmental protection activities.

The report's major emphasis is environmental management performance, which is evaluated by how well SNL/California's environmental protection activities comply with environmental laws and regulations.

A quality section expresses Sandia's efforts to continually improve its corporate citizenship.

In addition, SNL/California works to make the document easy for the general public to understand.

3.2.1 Purpose

The first principle of waste minimization is eliminating or minimizing waste generation through source reduction.

If possible, waste materials that cannot be eliminated or minimized are reused and/or q recycled (i.e., reclaimed).

Besides ensuring that release limits are not exceeded, SNL/California uses these data as a warning system to ensure that pollutants are not released in concentrations sufficient to affect operations at the LWRP.

SNL/California does not discharge wastewater directly to the ground, arroyo, or any surface water body.

Stormwater runoff is monitored twice per year for constituents required by the State's General Industrial Stormwater Permit.

3.2.4 Organizations Involved in Report Production

SNL/California has a database for tracking and archiving environmental data.

This system manages field and analytical information generated by environmental monitoring, environmental restoration, and groundwater protection activities.

In addition, the responsible program maintains hard copies of the data for about one year.

Each year, these data are summarized in the Site Environmental Report (see Section 3.2).

SNL/California has a Quality Assurance Management Plan for the Site Operations Center (see Section 6.0),18 as well as a Quality Assurance Project I%z19 and operating procedures for data verification and management for the Environmental Surveillance Program.

Environmental Data Management

In accordance with DOE Order 5400.1, SNL/California implemented all environmental monitoring requirements within three years of the issuance of the order.

The Environmental Operations Department submitted the plan to the DOE, and DOE approved it on April 7,1992.

Environmental Operations personnel review it annually and update it at least every three years.

(DOE must approve the report every three years.).

If needed to complete the report, additional budget and resources will be requested through the regular budgetary process.

5.2.2 Environmental Monitoring Plan Schedule

SNL/California's Environmental Surveillance and Wastewater/Stormwater Programs examine the significant pathways by which contaminants can enter the environment.

These pathways, from which samples are taken, include ambient air, surface water, soil, sewage, groundwater, storm-water runoff, vegetation, and local foodstuffs.

An extensive network of environmental dosimeters also measures external radiation levels.

SNL/California also monitors all potentially contaminated liquid effluents by: 1. Sampling storm-water runoff from the site.

Monitoring external radiation at the site perimeter.

5,3.1 Implementation

The Environmental Operations Department is responsible for managing the effluent monitoring and environmental surveillance data and preparing the summary reports.

Contract laboratories doing analyses for SNL/California's environmental monitoring program are accredited by the Cal-EPA.

To receive accreditation, the laboratory must have an implemented quality assurance plan.

Periodically, the Cal-EPA inspects accredited laboratories to make sure they are operating within quality assurance requirements.

5.3.2 Reporting

All environmental samples collected for regulatory compliance purposes are collected using guidance issued by the EPA.

They are analyzed by off-site contract laboratories certified by the Cal-EPA.

SNL/California permanently retains the analytical data and associated quality assurance documentation.

6,2 Laboratory Certification

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