At the institutional level, the core ES&H functions are addressed through Laboratory-wide policies and procedures. The most significant publications in this context are:
LBNL/PUB-201, the Regulations & Procedures Manual (RPM);
http://www.lbl.gov/Workplace/RPM/
LBNL/PUB-3000, the Health & Safety
Manual;
http://www.lbl.gov/ehs/pub3000
LBNL/PUB-3111, the Operating and Assurance
Plan (OAP);
http://www.lbl.gov/ehs/oap/oap_home.htm
LBNL/PUB-5344, the Environment, Safety & Health Self-Assessment Program; http://www.lbl.gov/ehs/oaa/02prog_docs/pub_53440201.pdf
The Operating & Assurance Plan (OAP) and the Self-Assessment programs are themselves ES&H integrating mechanisms. They ensure line management knowledge and accountability at all levels of the organization. The OAP (see Appendix C) provides broad guidance for work planning of new initiatives, and the Self-Assessment Program provides assurance for the safe operation of new and continuing operations and feedback for their improvement.
The mission of Berkeley Lab as negotiated with DOE determines the work of the Laboratory. In general, each of the scientific divisions at the Laboratory has established a set of core competencies that roughly define the kind of work performed by that division. These core competencies evolve according to needs and changes in the underlying science, and they are updated annually through the Berkeley Lab Institutional Plan. Each of the support divisions has a set of responsibilities that likewise define the programs and processes that take place or are contracted for. Operationally, the overall nature of physical activities and the associated hazards and risks are fairly stable and do not change significantly from year to year.
Each year, all unmet institutional needs are identified through a call to all research and support divisions. Sitewide future work planning for institutional issues is addressed annually through the Unified Project Call Process (http://www.lbl.gov/Workplace/RPM/R1.26.html). This process provides the following:
The Project Coordinating
Committee (PCC) provides the institutional review and prioritization of projects
involving Non-Capital Alterations (NCA), Line Item Projects (LIP), and General
Plant Project (GPP) requests, and is composed of the following members:
The General Purpose Equipment (GPE) Committee provides institutional review and prioritization of GPE requests and is composed of the following members:
The Deputy Director for Operations, in consultation with the Facilities Department Head and Director of the EH&S Division, reviews requests referred through the Unified Project Call Process, confirms that they are consistent with institutional priorities, and finalized funding recommendations for NCA, GPE, and GPP projects. The Director’s Action Committee (DAC) provides final review and approval.
Included in this process each year is an Environment, Safety, and Health Infrastructure Plan that identifies the activities necessary to ensure the health and safety of employees and the public and the protection of the environment. It contains separate Activity Data Sheets that provide detailed information regarding all outstanding environment, safety, and health needs. Each need is scoped and then evaluated using three prioritization criteria—a value ranking by the customer division, the Capital Asset Management Process (CAMP), and the Risk-Based Priority Matrix (RPM) rating system. All candidate projects are reviewed by the Laboratory committees listed above and by senior management (see Appendix A). The final list is prepared in coordination with the DOE Berkeley Site Office (BSO) and the Oakland Operations Office (OAK). Management adjustments to the Risk-Based Priority Matrix scoring are discussed and made jointly by Berkeley Lab and DOE management. The list also includes a “below-the-line” listing of prioritized items for which funds are not currently available. When additional funds become available, the highest ranked “below-the-line” projects are moved up and completed. The Deputy Director for Operations also reviews this list periodically throughout the year to determine appropriate mid-course corrections.
Four institutional programs are implemented by the Waste Management Group (WM), the Environmental Restoration Program (ERP), and the Radiation Protection Program within the EH&S Division: the Berkeley Lab hazardous/radioactive waste management program, Waste Minimization/Pollution Prevention Program (WMin/PP), and the Resource Conservation and Recovery (RCRA) Corrective Action provisions of the HWHF RCRA permit. DOE directly funds the operations of ERP and WMin/PP through its Environmental Management (EM) program. The Office of Science (SC) directly funds the hazardous/radioactive waste management program.
Within ERP, activities are based primarily
on agreements reached with the California Environmental Protection Agency’s
Department of Toxic Substances Control (Cal/EPA DTSC) and DOE over RCRA Corrective
Action at Berkeley Lab. ERP activities are also guided by EM Plan 2006 commitments
to accelerate site restoration activities and “reduce the mortgage,” i.e., to
reduce longer-term costs of Berkeley Lab's restoration activities. Some contingency
funds are available each year to address new discoveries attributable to past
contamination. DOE directly funds environmental restoration activities and
can make additional funding available when necessary, especially where DOE and
Berkeley Lab agree that some corrective measures should be implemented ahead
of schedule to more effectively address contamination.
In WM, DOE directly funds activities to meet commitments made in the EM 2006 plan and to address current-year needs, including the operation of the RCRA-permitted Hazardous Waste Handling Facility, a state-of-the-art waste handling facility. In both cases, issues identified outside of established plans are generally identified and resolved.
The Radiation Safety Program implements DOE radiation protection regulations, which are enforced via the Price-Anderson Amendments Act (PAAA). The program is implemented by a DOE-approved Radiation Protection Program document (RPP). An institutional committee, appointed by the Laboratory Director and the Radiation Safety Committee (RSC), oversees the radiation safety program. The RSC authorizes all use of radiation at Berkeley Laboratory. The RSC Charter is found in Appendix L.
ERP, WM, and Radiation Safety performance is measured by performance-based measures in the contract with DOE.
The work of the entire Berkeley Lab (at the levels of divisions/departments, projects, and bench top) was reviewed and catalogued from an ES&H perspective in 1996 through the Integrated Hazard Assessment (IHA), as part of the WSS process. The Hazards, Equipment, Authorization and Review (HEAR) database has superceded the IHA. The WSS process is conducted annually (see Section 3, Establishment of Controls).
A comprehensive hazard analysis was included as part of the 1996 IHA effort for Berkeley Lab. Each work activity identified was evaluated for hazards, and each hazard found was determined to represent either a low, medium, or high level of concern. The determination considered both the underlying risk and the probability of occurrence in light of the quality of controls present. The IHA was actually performed at the division/department level; the institutional assessment is merely a rollup. Divisions and departments also update this process (see below) and are rolled up for Berkeley Lab as a whole. Continuous improvement is expected in the depth and breadth of hazard and risk assessments.
The underlying processes associated with the hazard- and risk-analysis element of ISM have matured. The IHA database has been superseded by the Hazards, Equipment, and Authorization Review (HEAR) system. This Web-based tool allows division users direct access to information relevant to the evaluation and identification of hazards and areas of risk associated with their operations. The emphasis is on division-user maintenance and use of the data.
The HEAR system, in conjunction with the revised Chapter 6 of LBNL/PUB-3000 (EH&S Documentation and Approvals), constitutes the framework for institutional hazard and risk analysis. Chapter 6 provides the basis for formal work authorizations (AHDs, RWA, RWPs, SSAs, etc.). These authorizations implicitly embed the concept of high and medium levels of concern associated with facilities and spaces into the HEAR system.
The most fundamental control on the work carried out by Berkeley Lab is the contract between Regents of the University of California and the U. S. Department of Energy. This contract is the underlying work authorization for Berkeley Lab, and it enumerates the conditions under which Berkeley Lab must operate through management orders and negotiated Work Smart Standards (WSS). Berkeley Lab also has a current EIR with an addendum provided as part of the latest contract revision, and there are formal SADs for the many facilities. As part of the long-range planning process, Berkeley Lab is also reviewing the appropriateness of creating SADs.
The 1996 IHA provided the basis for the Berkeley Lab WSS set, which was incorporated into the UC/DOE contract in November 1996. These standards are now in effect, and they define the controls that must be implemented at Berkeley Lab. Because of the dynamic nature of the Berkeley Lab’s research activities and the changes that may occur in the regulatory environment, Berkeley Lab has adopted a formal two-pronged process for updating and maintaining the WSS set (see Appendix D). As the work changes at the division/department level, the changes are analyzed to determine if additional standards need to be identified, and this information is rolled up to the institutional level (see below). EH&S division technical staff has been identified and charged with monitoring regulatory requirements to ensure that significant revisions are incorporated into the WSS set. Proposed changes to the WSS set will be rolled up annually. They will then be discussed at one of the quarterly Operational Awareness (OA) meetings with DOE counterparts prior to proposal for formal adoption. Responsibility for formal notification of the DOE Contracting Officer rests with the LBNL Manager, Office of Institutional Programs (Contracting Officer). If errors are discovered with the WSS set during its implementation, the EH&S Division technical staff will form an internal review team to evaluate and correct any inaccurate information, prepare a memo to file, and provide notification to BSO and the LBNL Contracting Officer.
The WSS set provides the basis for the policies and procedures contained in Berkeley Lab’s EH&S guidance documents, principally LBNL/PUB-3000 and subordinate documentation. Berkeley Lab has revised LBNL/PUB-3000 to remove outdated references and to reflect the requirements of the WSS set accurately. The manner in which the WSS set flows down and interacts with other requirements is illustrated in the following chart, using radiation safety concerns as an example.
The work performed at the institutional level is to guide and promote the mission of Berkeley Lab. The Berkeley Lab Director sets the broad vision for Berkeley Lab, based on the policies of the Regents of the University of California and of the U. S. Department of Energy as expressed in the prime contract. For the institutional staff, the actual work consists of developing guidance for the divisions and departments, and implementing institutional decision-making processes needed to implement the mission. (Actual work is performed at the project or activity level, and work performance is discussed under Section D, Core EH&S Functions at the Project or Activity Level.)
As far as ES&H issues are concerned, the guidance is developed by Berkeley Lab staff functions [EH&S Division, Office of Assessment and Assurance (OAA), and National Environmental Protection Act–California Environmental Quality Act (NEPA-CEQA) Office] and is contained in the RPM (LBNL/PUB-201), in LBNL/PUB-3000, and in the OAP. Responsibility for developing this guidance has been assigned to the EH&S Division Director and to the NEPA-CEQA coordinator.
Decision-making responsibility and authority for ES&H issues is clearly defined in Chapter 1 of LBNL/PUB-3000 (see Appendix E). Most decisions are not of an institutional nature, but rather occur at the project or activity level and are discussed below.
Decision making for institutional ES&H issues has been delegated to the EH&S Division Director and is exercised in consultation with Berkeley Lab Director’s Action Committee (DAC). Institutional issues addressed include the contents of LBNL/PUB-3000 and other Berkeley Lab EH&S policies, and negotiation of performance measures with UC and the Department of Energy.
Also important in determining the quality of work performance are budgeting and prioritization of institutional projects that may have an ES&H impact. These issues were more completely discussed earlier in Section B-1, Work Planning.
The institution is under close scrutiny and review by internal and external authorities. Institutional ES&H issues are reviewed by numerous external entities, including the public. Some of the agencies with the more significant roles include:
The interaction with DOE-OAK/BSO is specifically focused on OA and oversight to assure appropriate stewardship and compliance with the requirements of the UC-DOE contract (see Appendix F). These activities are in part designed to help provide feedback to Berkeley Lab concerning ES&H performance for the purpose of continuous improvement. Many of these agencies also oversee more specific ES&H issues at the division/department and project/activity levels. The combined set of reviews by these agencies constitutes the external feedback on the adequacy of EH&S programs.
The major internal functions that provide feedback and information for continuous improvement include:
Of particular note here are the Appendix F self-assessments and the ES&H IFA. Several ES&H performance measures have been incorporated into the prime contract for Berkeley Lab; performance in these areas is continually tracked, publicized internally, and reviewed annually by the UC Office of the President (UCOP) and DOE. Specific individuals have been identified for each performance measure; they are responsible for ensuring that upgrades to institutional efforts are proposed and implemented to obtain the best possible performance under these measures. Clear lines of responsibility thus have been established to assure feedback and improvement or sustained excellence for ES&H efforts at the institutional level.
While the ES&H IFAs are carried out at the division or project level, they are also used to identify and address new hazards and corresponding needs for new standards to be incorporated into the WSS set. A mechanism for incorporating these changes at the institutional level has been developed.
Aside from external and internal institutional assessments, institutional issues are raised during various assessments of individual activities or select divisions, giving opportunity to improve various aspects of the institutional program. An annual institutional summary of the divisions’ self-assessment efforts is prepared for and reviewed by the Berkeley Lab Director. This summary provides additional insight into the strengths and weaknesses of institutional programs. This has been and will continue to be used to improve the institutional ES&H programs. Finally, the adequacy of Berkeley Lab ES&H management systems is reviewed periodically by Berkeley Lab senior management for suitability, adequacy, and effectiveness. Mechanisms for conducting this review include independent peer reviews and the annual roll-up of contract performance measures.
Berkeley Lab also maintains a Lessons Learned program, designed to ensure that applicable lessons learned in any part of the Laboratory or at other facilities are efficiently brought to the attention of divisions and individuals who may benefit from this information. The lessons-learned Web site is http://www.lbl.gov/ehs/html/lessons_learned.htm.
This Berkeley Lab ISM plan undergoes an annual internal review, coordinated by the EH&S Division, to ensure that its ISM description is current, valid, and appropriately reflecting the system’s implementation procedures and practices. Any changes are discussed, reviewed, and approved jointly between the Berkeley Lab EH&S Division Director and the BSO Manager prior to formal incorporation into the plan. Effective October 1, 2001, a newly negotiated Appendix F Process Measure, encompassing a set of ISM leading indicators, will be used to gauge Berkeley Lab performance toward systematically integrating ES&H into management and work practices at all levels of the organization and activities. Meeting this performance objective will demonstrate accomplishment of mission while protecting worker, public and the environment (see Appendix N).