Sanitary Sewer System Management Plan

Sanitary Sewer System Management Plan Prepared by: Environment, Health and Safety Division Environmental Services Group October 2009 Ernest Orlando Berkeley, CA 94720 This work was supported by the Director, Office of Science, U.S. Department of Energy under Contract Number DE- AC02-05CH11231

LBNL SSMP TABLE OF CONTENTS SSMP Section Tab / Page # Section 0: Introduction 0 Section i: Goals i Section ii: Organization ii ii-a: Authorized representative ii-2 ii-b: Organizational chart ii-3 ii-c: SSO reporting chain of communication ii-6 Section iii: Legal Authority iii iii-a: Authority to prevent illicit discharges iii-2 iii-b: Authority to properly design and construct sewer iii-6 iii-c: Authority to ensure access iii-8 iii-d: Authority to limit FOG iii-9 iii-e: Authority to enforce any violation iii-10 Section iv: Operation and Maintenance Program iv iv-a: System mapping iv-2 iv-b: Routine preventative O&M activities iv-6 iv-c: Prioritization program for impaired sewer assets iv-10 iv-d: Training iv-17 iv-e: Equipment and critical replacement parts iv-20 Section v: Design and Performance Provisions v v-a: Design and construction standards and specifications v-2 v-b: Procedures and standards for inspecting and testing v-6 Section vi: Overflow Emergency Response Plan vi vi-a: Proper notification procedures vi-2 vi-b: Program to ensure appropriate response vi-4 vi-c: Notification of regulatory agencies vi-6 vi-d: SSO response plan distribution and training vi-7 vi-e: Procedures for emergency operations vi-9 vi-f: Program to minimize effects of sewage discharge to waters of the U.S. vi-10 Section vii: FOG Control Program vii vii-a: FOG public outreach program vii-2 vii-b: FOG disposal vii-4 vii-c: Legal authority vii-5 vii-d: Requirements for grease removal devices vii-6 vii-e: Inspection vii-9 vii-f: Identification of FOG problem areas vii-11 vii-g: FOG source control measures vii-12 Section viii: System Evaluation and Capacity Assurance viii viii-a: Identification of areas of hydraulic deficiency viii-2 viii-b: Hydraulic design criteria viii-7 viii-c: Capacity enhancement capital improvement program viii-10 viii-d: Schedule of completion dates for capital improvement projects viii-13

TABLE OF CONTENTS (CONTINUED) SSMP Section Tab / Page # Section ix: Monitoring, Measurement, and Program Modifications Ix ix-a: Information maintained to prioritize SSMP activities ix-2 ix-b: Monitoring and measurement of SSMP element effectiveness ix-5 ix-c: Assessment of success of preventative maintenance program ix-9 ix-d: SSMP program updates based on performance evaluations ix-11 ix-e: SSO trend analysis ix-12 Section x: SSMP Audits X Section xi: Communication Program Xi xi-a: Plan of communication with public xi-2 xi-b: Plan of communication with satellite collection systems xi-4

LIST OF ATTACHMENTS Section 0: Introduction Attachment 0-1: LBNL CIWQS Sewer System Questionnaire Attachment 0-2: LBNL Facility Sanitary Sewer Collection System Overview Map Section i: Goals None Section ii: Organization Attachment ii-1: LBNL Notice of Intent for GWDR Coverage Attachment ii-2: Organization Chart for SSMP Implementation Responsibilities Attachment ii-3: SSMP Implementation Responsibilities by Division and Contact Information for Key Personnel Attachment ii-4: Sanitary Sewer Overflow Off-Hours Notification Procedure Attachment ii-5: Reporting Requirements for Sanitary Sewer Overflows Section iii: Legal Authority None Section iv: Operation and Maintenance Program Attachment iv-1: Example Sewer Asset Database Format Section v: Design and Performance Provisions None Section vi: Overflow Emergency Response Plan None Section vii: FOG Control Program Attachment vii-1: Cafeteria FOG Control Inspection Form Section viii: System Evaluation and Capacity Assurance Attachment viii-1: I/I Analysis Spreadsheet Example Section ix: Monitoring, Measurement, and Program Modifications None Section x: SSMP Audits None Section xi: Communication Program None

0 Introduction / Document Use SSMP Requirement Background This Sanitary (SSMP) has been prepared by the Lawrence Berkeley National Laboratory (LBNL) in compliance with the requirements of California State Water Resources Control Board (SWRCB) Order No. 2006-0003, dated May 2, 2006. The order consists of general waste discharge requirements (GWDRs) which prohibit the discharge of untreated wastewater which may reach waters of the United States or cause a public nuisance as defined in California Water Code Section 13050(m). The order requires that all publicly owned wastewater collection system utilities owning more than one mile of pipe prepare a written SSMP to address the proper operation, maintenance, and funding of the system to ensure the prevention of sanitary sewer overflows (SSOs). The LBNL sanitary sewer collection system consists of approximately 5.5 miles of gravity sewer pipe; therefore LBNL is required to develop an SSMP. In addition to the GWDRs, the SWRCB order established a monitoring and reporting program (MRP No. 2006-0003-DWQ) for all SSOs. The purpose of this program is to characterize and track SSO occurrence for the purpose of future prevention. The MRP defines specific information which must be included with each SSO report that is entered into the online SSO reporting system (California Integrated Water Quality System, or CIWQS). The MRP defines three categories of SSOs: A Category 1 SSO is any sewage spill in excess of 1,000 gallons or that is discharged to a drainage channel, surface water, or storm water pipe (if not captured and returned to the sanitary sewer system). Category 1 SSOs must be reported within 2 hours to the State Office of Emergency Services (OES), Regional Water Quality Control Board (RWQCB), and Local Department of Public Health, accompanied by a 24 hour certification to the RWQCB that all 2- hour notifications have been made. Category 1 SSOs must be reported using the online CIWQS system initially within three business days of occurrence. A final SSO report is submitted within 15 days using the CIWQS system when all response and follow-up activities for the SSO event have been closed-out. A Category 2 SSO is any sewage spill from the publicly owned portion of the collection system that is not a Category 1 SSO and must be reported through the online CIWQS system within 30 days after the end of the calendar month in which the SSO occurred. The final category encompasses SSOs originating from private laterals, which may be reported at the discretion of the agency. LBNL was enrolled in the San Francisco Bay RWQCB online SSO ereporting Program following its inception in December 2004, and switched over to the SWRCB s CIWQS system in compliance with MRP No. 2006-003-DWQ at the time it was implemented. The RWQCB ereporting program is still used to submit 2-hour notification / 24-hour certifications of SSOs to Last Revision: 09-30-09 Page 0-1

Element 0. Introduction / Document Use the RWQCB. A completed online Collection System Questionnaire for LBNL is included in Attachment 0-1. The questionnaire displays the information provided by LBNL to the SWRCB during registration in the MRP through the CIWQS system, and must be updated annually. Purpose of the SSMP Any prohibited SSO originating from a publicly owned sanitary sewer collection system constitutes a violation of the California Water Code and is subject to enforcement action. The purpose of this document is to ensure that the LBNL has a plan in place to reduce or eliminate SSOs and protect public health. The SSMP accomplishes this purpose by defining specific procedures and programs in 11 categories defined by the SWRCB GWDRs. The SSMP procedures and programs are specifically designed to maximize the functionality of LBNL s capital and human resources to manage the sanitary sewer collection system in a way that minimizes SSOs, and to ensure that LBNL is in compliance with the GWDRs. The SSMP also helps to advance LBNL s broad-based environmental policies with respect to the sanitary sewer collection system as stated in the LBNL Environmental Management System Plan (EMS Plan): 1. Comply with applicable environmental, public health, and resource conservation laws and regulations. 2. Prevent pollution, minimize waste, and conserve natural resources. 3. Correct environmental hazards and clean up existing environmental problems. 4. Continually improve the Laboratory s environmental performance while maintaining operational capability and sustaining the overall mission of the Laboratory. Document Organization The SWRCB GWDRs require that the SSMP address 11 specific aspects of the agency s responsibility regarding its management, operation and maintenance of the sanitary sewer collection system. These sections address the following: i. Goals ii. Organization iii. Legal Authority iv. Operation and Maintenance v. Design and Performance Provisions vi. Overflow Emergency Response vii. Fats, Oils, and Grease (FOG) Control viii. System Evaluation and Capacity Assurance ix. Monitoring, Measurement, and Program Modifications x. SSMP Program Audits xi. Public Communication Page 0-2

Element 0. Introduction / Document Use The SSMP describes the actions of LBNL pertaining to all 11 required sections. Each section of the SSMP begins with the presentation of the specific requirements of that section per the SWCRB GWDRs as well as a narrative providing additional background on the section. Following that, a sub-section exists for each sub-requirement within the section. Each subsection presents the following: a. The exact language of the SWRCB sub-requirement. b. A discussion of specific actions performed by LBNL which satisfy the requirement. c. A list of related documents in support of the discussion. d. A plan and schedule for implementing any actions that LBNL is not currently performing that are needed to meet the sub-requirement, or that are planned to be completed in the future to implement any programs described in the SSMP subsection. An appendix is included at the end of each main SSMP section that contains all attached related documents for that section. Sanitary Sewer Collection System Overview The LBNL is a member of the national laboratory system supported by the U.S. Department of Energy (DOE) through its Office of Science. Unclassified research across a wide range of scientific disciplines is conducted at LBNL. The LBNL facility is located on a 200 acre site in the hills above the University of California (UC) Berkeley campus and currently employs approximately 4,000 scientists, engineers, support staff and students. The LBNL facility property is owned by UC and leased to the DOE. All LBNL facilities, equipment, and supporting infrastructure (including the on-site sanitary sewer collection system) is owned and funded by the DOE. However, day-to-day operation and management of the LBNL is conducted by UC through a contract with DOE (Contract No. DE-AC02-05CH11231, also referred to as Contract 31). The East Bay Municipal Utility District (EBMUD), through the City of Berkeley, provides wastewater collection service to the LBNL. All wastewater discharged to the LBNL sanitary sewer collection system exits the facility at two outfall locations that connect to the EBMUD (via Hearst Monitoring Station) or UC sanitary sewer collection systems (via Strawberry Monitoring Station). Each of the perimeter outfall locations has a monitoring facility, which is used for continuous flow monitoring and for extraction of samples for chemical and radioisotope analysis as required by the EBMUD and the DOE (refer to SSMP section iii-a). The average wastewater flow from the LBNL site is approximately 135,000 gallons per day. The LBNL sanitary sewer collection system consists of approximately 29,000 feet of pipeline (5.5 miles), ranging in size from 3-inches to 10-inches in diameter. Presently, there are 68 occupied structures at LBNL that discharge to the system. In addition, the Strawberry system Page 0-3

Element 0. Introduction / Document Use carries wastewater from the University of California s Lawrence Hall of Science, Botanical Gardens, Space Science Laboratory, and Mathematical Sciences Research Institute. The sanitary sewer collection system is completely dependent upon gravity flow; no pumping stations exist at LBNL. An overview map of the LBNL facility, sanitary sewer collection system, and sewage outfall locations is provided in Attachment 0-2. Responsibilities of the Authorized Representative The representative(s) of LBNL responsible for the maintenance and implementation of this SSMP will be required to perform the following tasks: I. Submission and endorsement of all reports required by SWRCB Order No. 2006-0003 II. Management of the LBNL CIWQS SSO reporting system account III. Completion of the certification portion of the CIWQS SSO Database Questionnaire IV. Completion of bi-annual program audits V. Completion of 5-year SSMP re-certifications It should be noted that the LBNL representatives authorized to perform the tasks described above (as identified through the LBNL CIWQS system account) are not the only individuals responsible for the overall implementation of the SSMP. SSMP implementation is a shared responsibility between the LBNL Facilities Division and Environmental Health and Safety (EH&S) Division, as described in SSMP section ii-b. The LBNL authorized representatives are identified in SSMP section ii-a. Governing Body SSMP Certification and Re-Certification Requirements In order to certify the SSMP, the LBNL s governing body, the DOE, must review the document and ensure that it fully meets all of the requirements of the GWDR and includes actions and procedures to be taken by LBNL that are generally feasible and acceptable to DOE. Prior to certification, an overview of the programs proposed in the SSMP and any potential budgetary impact will be presented to the LBNL Chief Operating Officer (COO). Every 5 years, the SSMP must be reviewed by DOE and re-certified, to ensure that it remains up-to-date with changing management, operation, and maintenance programs and objectives. Related Documents o Refer to UC-DOE Prime Contract No. DE-AC02-05CH11231 http://labs.ucop.edu/labprimecontracts/ o Refer to LBNL Environmental Management System Plan (Latest Revision) http://www.lbl.gov/ehs/esg/ems%20plan/assets/ems%20plan_0309.pdf o Attachment 0-1: LBNL CIWQS Collection System Questionnaire o Attachment 0-2: LBNL Facility Sanitary Sewer Collection System Overview Map Page 0-4

Element 0. Introduction / Document Use Glossary The following is a list of abbreviations and acronyms used in this document: Abbreviation ADWF ASTM BACWA BMP CCR CCTV CDFG CEQA CFR CIP CIWQS CSI COO CUPA DOE EBMUD ECAAP EH&S EMS FOG gpm GWI/I GWDR I/I ID ISDHH ISM LBNL MGD MRP NEPA NOI NPDES OCA OERP OES O&M OSHA PDWF Meaning Average Dry Weather Flow American Society for Testing and Materials Bay Area Clean Water Agencies Best Management Practices California Code of Regulations Closed Circuit Television California Department of Fish and Game California Environmental Quality Act Code of Federal Regulations Capital Improvement Plan California Integrated Water Quality System Construction Specifications Institute Chief Operating Officer Certified Unified Program Agency Department of Energy East Bay Municipal Utility District Environmental Compliance Audit and Assessment Plan Environmental Health and Safety Environmental Management System Fats, Oils and Grease Gallons Per Minute Groundwater Infiltration and Inflow General Waste Discharge Requirements Infiltration and Inflow Identification Imminent and Substantial Danger to Human Health Integrated Safety Management Lawrence Berkeley National Lab Million Gallons per Day Monitoring and Reporting Program National Environmental Policy Act Notice of Intent National Pollution Discharge Elimination System Office of Contract Assurance Overflow Emergency Response Plan Office of Emergency Services Operation and Maintenance Occupational Safety and Health Administration Peak Dry Weather Flow Page 0-5

Element 0. Introduction / Document Use Abbreviation PI PMT POSM POTW PWWF RDI/I RP RWQCB SECAP SIU SOP SSMP SSO SWRCB TM UC UM UPC WDR Meaning Performance Indicators Plant Maintenance Technician Pipeline Observation System Management Publicly Owned Treatment Works Peak Wet Weather Flow Rainfall-Dependent Infiltration and Inflow Responsible Person Regional Water Quality Control Board System Evaluation and Capacity Assurance Plan Significant Industrial User Standard Operating Procedure Sanitary Sewer Overflow State Water Resources Control Board Technical Memorandum University of California Utilities Manager Uniform Plumbing Code Waste Discharge Requirements Page 0-6

Attachment 0-1: LBNL CIWQS Collection System Questionnaire

Attachment 0-2: LBNL Facility Sanitary Sewer Collection System Overview Map

Sanitary Sewer Collection System Overview Map

i Goals SWRCB Requirement: The goal of the SSMP is to provide a plan and schedule to properly manage, operate, and maintain all parts of the sanitary sewer system. This will help reduce and prevent sanitary sewer overflows (SSOs), as well as mitigate any SSOs that do occur. Taken from SWRCB GWDR Order No. 2006-0003 adopted May 2, 2006. Background This SSMP section describes the goals of the LBNL for the management, operation, and maintenance of the sanitary sewer collection system. These broad goals help to shape programs developed within the SSMP and executed by the LBNL to meet the objectives of the GWDR. This section fulfills the requirements of the GWDR SSMP mandatory element i. Last Revision: 09-30-09 Page i-1

Element i. Goals i. Goals Requirement: The goal of the SSMP is to provide a plan and schedule to properly manage, operate, and maintain all parts of the sanitary sewer system. This will help reduce and prevent sanitary sewer overflows (SSOs), as well as mitigate any SSOs that do occur. Discussion The SSMP will guide the LBNL Facilities Division and EH&S Division in accomplishing the following 3 goals: 1. Identify, prioritize, and continuously renew and replace sewer system facilities to maintain reliable service now and in the future. 2. Cost-effectively minimize infiltration and inflow. 3. Properly manage and operate the Laboratory s facilities to minimize the number and impact of SSOs. Related Documents o None Plan & Schedule No further efforts are projected for this element at the present time. Page i-2

ii Organization SWRCB Requirement: The SSMP must identify: (a) The name of the responsible or authorized representative as described in Section J of this Order. (b) The names and telephone numbers for management, administrative, and maintenance positions responsible for implementing specific measures in the SSMP program. The SSMP must identify lines of authority through an organization chart or similar document with a narrative explanation; and (c) The chain of communication for reporting SSOs, from receipt of a complaint or other information, including the person responsible for reporting SSOs to the State and Regional Water Board and other agencies if applicable (such as County Health Officer, County Environmental Health Agency, Regional Water Board, and/or State Office of Emergency Services (OES)). Taken from SWRCB GWDR Order No. 2006-0003 adopted May 2, 2006. Background This section of the SSMP identifies the individuals responsible for implementation of the SSMP and for signing and certifying all reports and documents required by the GWDRs. The organizational structure for the LBNL employees that have responsibility for implementing the SSMP is clearly presented along with essential job functions and contact information for each employee. The chain of command for the identification, reporting, and mitigation of SSOs is established. This section fulfills the requirements of the GWDR SSMP mandatory element ii. Last Revision: 09-30-09 Page ii-1

Element ii. Organization ii-a. Authorized representative Requirement: The SSMP must identify the name of the responsible or authorized representative as described in Section J of the GWDR s. Discussion The EH&S Division Environmental Manager and SSO Program Manager are LBNL s authorized representatives registered with the SWRCB through the CIWQS system to submit, sign, and certify all reports required by SWRCB Order No. 2006-0003 and MRP No. 2006-0003-DWQ. The Environmental Manager and SSO Program Manager may also submit SSO reports (i.e. 2- hour notification / 24-hour certification) to the RWQCB through the ereporting Program. The original Notice of Intent (NOI) for LBNL s coverage under the Statewide GWDR is included in Attachment ii-1. It should be noted that the LBNL authorized representatives identified above are not the only individuals responsible for the overall implementation of the SSMP. SSMP implementation is a shared responsibility between the LBNL Facilities Division and EH&S Division, as described in SSMP section ii-b. Related Documents o Attachment ii-1: LBNL Notice of Intent for GWDR Coverage Plan & Schedule No further efforts are projected for this element at the present time. Page ii-2

Element ii. Organization ii-b. Organizational chart Requirement: Identify the names and telephone numbers for management, administrative, and maintenance positions responsible for implementing specific measures in the SSMP program. The SSMP must identify lines of authority through an organization chart or similar document with a narrative explanation. Discussion Compliance with the GWDR is a shared responsibility between two LBNL organizations: 1. The LBNL Facilities Division is responsible for sanitary sewer collection system operation, repairs, improvements, and modifications. In addition, it manages the operating budget, secures funding for improvement/repair/survey projects, and maintains records of the underground sanitary sewer collection system infrastructure. 2. The LBNL EH&S Division is responsible for environmental programs, site security, and emergency operations. Activities include SSO compliance, sampling, testing, and reporting sanitary sewer overflow volume and content as required by the EBMUD wastewater discharge permit for the LBNL site. In the event of a sanitary sewer overflow, the EH&S Division manages site access and emergency response activities and emergency notifications to all regulatory agencies per MRP No. 2006-0003-DWQ. The organization chart for employees responsible for implementation of the SSMP is included in Attachment ii-2. Roles and responsibilities specific to responsible positions are described below: Utilities Manager (UM): Reporting to the Facilities Operations Department Head, the Utilities Manager (UM) operates a comprehensive operation and maintenance plan to ensure a sufficient and dependable sanitary sewer collection system, minimizing SSOs and meeting the requirements of the DOE. The UM organizes multiple maintenance efforts including: periodic high-pressure water jetting, root control, grease interceptor maintenance, CCTV inspections, condition assessments, and capital improvement projects. The UM oversees the maintenance of a detailed sanitary sewer collection system Asset Database which includes pertinent asset physical data, historical maintenance records, and condition assessment data. The UM is also responsible for overseeing hydraulic analysis of the sanitary sewer collection system to ensure that adequate capacity is provided as described in the System Evaluation and Capacity Assurance Plan (see SSMP section viii). The UM secures funding, allocates expenditures, and develops and plans infrastructure projects. The UM annually updates (typically April 1st) the Collection System Questionnaire and provides responses to the Wastewater Discharge Program Manager for input into the on-line CIWQS database. The UM is involved with monitoring and measuring the performance of specific SSMP programs, and recommending updates to the SSMP as needed as part of the audit process. Page ii-3

Element ii. Organization Cafeteria Manager: Reporting to the Facilities Operations Department Head, manages the cafeteria support subcontract and subcontractor activities. Business Manager: Under general direction of the Facilities Division Director, the Business Manager is responsible for the planning and supervision of LBNL s accounting and financial record keeping activities. Inspector: Under general supervision of the Project Support Services, the Inspector personally performs a variety of inspection activities relating to sanitary sewer collection system facility construction to ensure compliance with approved plans and enforcement of LBNL s design and construction standards and specifications relating to construction of the system. The Inspector may be an employee contracted on a project-specific basis. Civil Engineer (Infrastructure): Under general direction of the UM, the Civil Engineer plans, organizes, administers and directs the maintenance, repair, installation and upgrading of LBNL s sanitary sewer collection system infrastructure and is involved with the maintenance of the sanitary sewer collection system Asset Database. The Civil Engineer is responsible for maintaining and periodically updating the LBNL design and construction standards and specifications. Plant Maintenance Technician (PMT): Under supervision of the Maintenance Superintendent, the Plant Maintenance Technician (PMT) performs a variety of tasks related to the maintenance, cleaning, and repair of LBNL s sanitary sewer collection system, Fixed Treatment Units, and related appurtenances. The PMT is a primary responder to any SSO events that may occur. Environmental Manager: Plans, directs and manages the environmental protection programs within the LBNL facility. Performs accidental release (SSO) notifications and prepares reports to Federal, State, and local agencies. Monitors and reviews LBNL activities for compliance with environmental laws and regulations. The Environmental Manager is involved with monitoring and measuring the performance of specific SSMP programs, and recommending updates to the SSMP as needed as part of the audit process. Security Manager: Plans, directs and manages site access and emergency response activities. Sanitary Sewer Overflow Program Manager: Designs and coordinates the sanitary sewer overflow (SSO) compliance program for LBNL. Assists Facilities Division management in interpreting and applying SSO requirements at the Page ii-4

Element ii. Organization LBNL site. Performs accidental release SSO notifications and reporting to Federal, State, and local agencies. Submits monthly no spill report through the on-line CIWQS database. The LBNL Division responsible for implementing each SSMP section is included in Attachment ii-3. Names and contact information for key staff responsible for GWDR compliance is also included in Attachment ii-3. Related Documents o Refer to Overall LBNL Organizational Chart http://www.lbl.gov/workplace/lab-support/org-chart.html o Attachment ii-2: Organization Chart for SSMP Implementation Responsibilities o Attachment ii-3: SSMP Implementation Responsibilities by Division and Contact Information for Key Personnel Plan & Schedule No further efforts are projected for this element at the present time. Page ii-5

Element ii. Organization ii-c. SSO reporting chain of communication Requirement: Identify the chain of communication for reporting SSOs, from receipt of a complaint or other information, including the person responsible for reporting SSOs to the State and Regional Water Board and other agencies if applicable (such as County Health Officer, County Environmental Health Agency, Regional Water Board, and/or State Office of Emergency Services). Discussion Chain of Communication for Responding to SSOs The SSO chain of communication usually begins when the PMT responds to a reported release, assesses the situation, and determines that a SSO has occurred. Within the first 2 hours, the PMT will notify both his supervisor and EH&S Security and provide the following information: Description of what happened Location of release and of threatened or involved waterway(s) or storm drains Date and time the unauthorized discharge is known to have started Estimated quantity and duration of the unauthorized discharge Identity of person reporting the unauthorized discharge Facilities PMT personnel will use the emergency contact list to notify a Plumbing Shop employee to respond to the SSO. If unable to contact a Plumbing Shop employee, the secondary resource shall be a sewer maintenance contractor currently under blanket purchase order. Depending on the severity of the SSO, the PMT Supervisor may also notify the Utilities Manager, Facilities Director, Operations Department Head, and the Chief Operations Officer. The SSO Off Hours Notification Procedure flowchart can be found in Attachment ii-4. Chain of Communication for Reporting SSOs The initial notification of SSOs to the various regulatory agencies is conducted by the EH&S Environmental Services Group (normal business hours) or Security Group (off hours). The following information should be provided to the State OES, RWQCB, and City of Berkeley as soon as possible but within the first 2 hours of discovering an SSO that impacts a drainage channel or surface water (per SWRCB Order No. WQ 2008-0002-EXEC): Description of what happened Location of threatened or involved waterway(s) or storm drains Date and time the unauthorized discharge is known to have started Estimated quantity and duration of the unauthorized discharge Identity of person reporting the unauthorized discharge Page ii-6

Element ii. Organization As soon as possible but within 24 hours, the EH&S Environmental Services Group will provide a certification report to the RWQCB that the State OES and the City of Berkeley have been notified. If the SSO meets the SWRCB s Category 1 reporting requirement, then the Environmental Services Group will submit a report via CIWQS within 3 business days. If the SSO meets the Category 2 reporting requirement, then a report will be submitted within 30 calendar days after the end of the calendar month in which the SSO occurs. A summary of SSO reporting requirements is included in Attachment ii-5. Related Documents o Attachment ii-4: Sanitary Sewer Overflow Off-Hours Notification Procedure o Attachment ii-5: Reporting Requirements for Sanitary Sewer Overflows Plan & Schedule No further efforts are projected for this element at the present time. Page ii-7

Attachment ii-1: LBNL Notice of Intent for GWDR Coverage

Attachment ii-2: Organization Chart for SSMP Implementation Responsibilities

Facilities Division and Environmental Health and Safety Division Organization Chart for SSMP Implementation Responsibilities Chief Operating Officer Facilities Division Director Business Manager EH&S Director Operations Department Head Environmental Manager Security Manager Utilities Manager Wastewater Discharge Program Manager Inspector Plant Maintenance Technician Civil Engineer

Attachment ii-3: SSMP Implementation Responsibilities by Division and Contact Information for Key Personnel

SSMP Implementation Responsibility By Division and Contact Information for Key Personnel SSMP Section i Goals ii Organization iii Legal Authority iv Operation and Maintenance Program v Design and Performance Provisions vi Overflow Emergency Response Plan vii FOG Control Program viii System Evaluation and Capacity Assurance ix Monitoring, Measurement and Program Modifications x SSMP Audits xi Communication Plan Responsible Division(s) Facilities Facilities/EH&S EH&S Facilities Facilities Facilities Facilities Facilities Facilities/EH&S Facilities/EH&S EH&S OFFICE PHONE NUMBER CELL PHONE NUMBER POSITION NAME FACILITIES DIVISION: Operations Department Head Ken Fletcher (510) 486-5770 (510) 502-0290 Utilities Manager Mike Dong (510) 486-6458 (510) 734-3711 EH&S DIVISION: Environmental Manager Ron Pauer (510) 486-7614 (510) 289-9324 Wastewater Program Manager Robert Fox (510) 486-7327 (510) 425-0451 (pager)

Attachment ii-4: Sanitary Sewer Overflow Off- Hours Notification Procedure

Sanitary Sewer Overflow Off-Hours Notification Procedure

Attachment ii-5: Reporting Requirements for Sanitary Sewer Overflows

Reporting Requirements for Sanitary Sewer Overflows

iii Legal Authority SWRCB Requirement: Each Enrollee must demonstrate, through sanitary sewer system use ordinances, service agreements, or other legally binding procedures, that it possesses the necessary legal authority to: (a) Prevent illicit discharges into its sanitary sewer system (examples may include I/I, stormwater, chemical dumping, unauthorized debris and cut roots, etc.); (b) Require that sewers and connections be properly designed and constructed; (c) Ensure access for maintenance, inspection, or repairs for portions of the lateral owned or maintained by the Public Agency; (d) Limit the discharge of fats, oils, and grease and other debris that may cause blockages, and (e) Enforce any violation of its sewer ordinances. Taken from SWRCB GWDR Order No. 2006-0003 adopted May 2, 2006. Background LBNL s legal authority to perform all of the necessary management, operation, and maintenance functions for the sanitary sewer collection system is derived from the DOE s Prime Contract with the University of California, Contract No. DE- AC02-05CH11231, also referred to as Contract 31, as discussed in section 0 of the SSMP. Section C.3.1.4 of Contract 31 states that the Consultant (LBNL) shall manage and operate the Laboratory through best-in-class management practices designed to foster world-class research while assuring the protection and proper maintenance of DOE research and information assets, the health and safety of Laboratory staff and the public, and the environment. The Contractor is expected to operate the Laboratory so as to meet all applicable laws, regulations, and requirements. LBNL does not experience many of the legal authority issues that most municipal utility agencies typically experience, because a majority of the sewage discharged to a municipal sanitary sewer collection system is contributed from private property not owned or operated by the municipality. Therefore, the municipal utility must develop a sanitary sewer system use ordinance to control discharges from private property to the public system to ensure that the utility can comply with applicable regulations. However, all property, facilities, and equipment located at LBNL are managed and operated under the authority of LBNL staff who are able to maintain full control over all discharges to the sanitary sewer collection system at all times. Therefore, LBNL is not in need of a sanitary sewer system use ordinance, but has instead established various management plans and operating procedures to ensure compliance with applicable regulations. This section fulfills the requirements of the GWDR SSMP mandatory element iii. Last Revision: 09-30-09 Page iii-1

Element iii. Legal Authority iii-a. Authority to prevent illicit discharges Requirement: Possess the necessary legal authority to prevent illicit discharges into the sanitary sewer system (examples may include I/I, stormwater, chemical dumping, unauthorized debris and cut roots, etc.) Discussion Regulations Applicable to the LBNL Sewer Collection System Appendix I of Contract 31 includes an attachment entitled Environment, Safety, and Health Standards Set for LBNL. This attachment includes a list of all Federal, State, and Local regulations that govern activities at LBNL. The key regulations specifically applicable to sewage discharges are: i. 10 CFR 20, Subpart K, Section 20.2003 - regulates the discharge of radioactive wastes; ii. 40 CFR 403, Subpart N - establishes sewage discharge pretreatment requirements; iii. EBMUD Ordinance NO. 311A-13 - governs sewage discharge to the EBMUD sewage collection and treatment systems. LBNL Policy Documents LBNL has established an Integrated Safety Management (ISM) Plan, which is the core policy governing environmental, safety, and health processes, and is required to be implemented per Section C.4.d.2 of Contract 31, and per DOE Order 450.1A. Compliance with the regulations applicable to the discharge of sewage listed above is monitored primarily by the LBNL under the Environmental Management System (EMS) Plan, which is established under the ISM Plan. The EMS Plan describes the LBNL s overarching strategy for protecting environmental resources and complying with all applicable laws and regulations in a cost-effective manner. EMS Plan Section 2.2 establishes two specific areas of environmental compliance that may be affected by the operation and maintenance of the sewer collection system, which are surface water protection, and environmental and effluent monitoring. To help ensure compliance in these areas, an Environmental Monitoring Plan was established, which specifically describes sewage effluent pretreatment and monitoring programs (chapter 4) executed by LBNL. LBNL has also established a Health and Safety Manual under the ISM Plan in order to achieve the goal of performing all work safely and in a manner that strives for protection for employees, participating guests, visitors, subcontractors, the public, and the environment, commensurate with the nature and scale of work. Chapter 11 of the Health and Safety Manual (Environmental Protection) also describes LBNL policies and programs designed to reduce environmental Page iii-2

Element iii. Legal Authority impacts and ensure regulatory compliance, which includes sewage effluent monitoring and spill prevention / response policies. Sewage Discharge Permits LBNL has in place three sewage discharge permits, issued under EBMUD s Industrial Waste Pretreatment Program per 40 CFR 403, Subpart N and EBMUD Ordinance NO. 311A-13, which establish local pollutant discharge concentrations and prohibit illicit discharges. Permits have been issued for the following discharges from the LBNL: Site-wide sewage discharges from the Hearst and Strawberry outfall sites to the City of Berkeley and EBMUD sanitary sewer collection systems: Wastewater Discharge Permit No. 0660079 1 Site-specific discharge permits from Building 25 (Photo Fabrication Facility) and Building 77 (Ultra High Vacuum Cleaning Facility): Wastewater Discharge Permit No. 5023891 1 Site-specific discharge permit for treated groundwater from 5 sites at LBNL: Wastewater Discharge Permit No. 5034789 1 LBNL is classified by EBMUD as a Significant Industrial User (SIU) according to Ordinance NO. 311A-13 Title I Section 3-ee because LBNL discharges in excess of 25,000 gallons per day of sewage from the Hearst and Strawberry outfall sites combined (total daily average discharge of 135,000 gallons). All SIUs require a site-specific discharge permit per Title IV Section 1 of the Ordinance. The LBNL site-wide discharge permit (No. 0660079 1) establishes local discharge limits and a self monitoring and reporting program. LBNL is required to deliver monitoring reports to EBMUD within 30 days of the required sampling dates as specified in the permit. The LBNL has 6 buildings where hazardous wastes are handled or treated, which are regulated by the California Department of Toxic Substances Control (DTSC) under the Wright-Polanco- Lempert Hazardous Waste Treatment Permit Reform Act of 1992, which establishes a 5-tiered permitting system for the treatment or storage of hazardous wastes. Enforcement of the Hazardous Waste Treatment Permit Reform Act and permitting authority has been delegated to the City of Berkeley as a Certified Unified Program Agency (CUPA) by DTSC. The processes at Buildings 25 and 77 operate under the Permit-by-Rule tier, which is the third priority tier that allows on-site treatment of wastes in compliance with CCR Title 22, Chapter 12. The general practice across the LBNL is to prevent the discharge of hazardous materials to the sanitary sewer collection system by isolating and storing spent wastes as part of the applicable process, and removing and disposing of those wastes off-site at a hazardous waste disposal facility. However, at Buildings 25 and 77, process rinse water may become acidic and contaminated with metals, and thus wastewater discharge is regulated under the Metal Finishing Point Source Category per 40 CFR Part 433. Fixed Treatment Units (FTUs) are in place at these facilities to pre-treat Page iii-3

Element iii. Legal Authority wastewater prior to discharge from the building to comply with EBMUD s local limits. The EBMUD site-specific discharge permit for these facilities (No. 5023891 1) requires self monitoring and reporting of wastewater prior to discharge to the LBNL sanitary sewer collection system. The other 4 buildings which handle hazardous waste at LBNL are permitted under the Conditional Authorization tier (fourth priority), and may discharge wastewater that is acidic, but not contaminated with metals. These facilities are not regulated under 40 CFR Part 403, but have FTUs in place to meet EBMUD local limits. Additional documentation and reporting is required by the City of Berkeley for all 6 buildings regulated under the Hazardous Waste Treatment Permit Reform Act as described in Section 11.3.8 of LBNL s Health and Safety Manual. LBNL is permitted as a Hazardous Waste Handling Facility under the Resource Conservation and Recovery Act (RCRA) by the DTSC. This permit requires that LBNL undergo a facility assessment to determine if any previous releases of hazardous wastes have occurred, and if any corrective measures are required to remediate those releases. LBNL has an Environmental Restoration Program in place, which includes monitoring and treatment of contaminated soil and groundwater at 5 locations at LBNL due to releases that have occurred over the life of the research facility. LBNL is permitted (No. 5034789 1) by EBMUD to discharge treated groundwater to the sanitary sewer collection system from these 5 locations. This permit also requires specific monitoring and reporting to EBMUD. Although none of the EBMUD discharge permits described above contain limits specific to radioactive wastes, LBNL monitors wastewater radioactivity to comply with 10 CFR 20, Subpart K, Section 20.2003, the results of which are regularly reported to the DOE. Related Documents o Refer to LBNL Contract 31 Appendix I http://labs.ucop.edu/labprimecontracts/lbnl/esh_std_lbnl.pdf o Refer to EBMUD Wastewater Control Ordinance NO. 311A-13 http://www.ebmud.com/wastewater/industrial_&_commercial_permits_&_fees/wastewat er_control_ordinance/default.htm o Refer to DOE Order 450.1A http://www.directives.doe.gov/pdfs/doe/doetext/neword/450/o4501a.pdf o Refer to LBNL Integrated Safety Management Plan (Latest Revision) http://www.lbl.gov/ehs/ism/ism_06.pdf o Refer to LBNL Environmental Management System Plan (Latest Revision) http://www.lbl.gov/ehs/esg/ems%20plan/assets/ems%20plan_0309.pdf o Refer to LBNL Environmental Monitoring Plan (Latest Revision) http://www.lbl.gov/ehs/esg/reports/assets/emp2006.pdf Page iii-4

Element iii. Legal Authority o Refer to LBNL Health and Safety Manual (Latest Revision) http://www.lbl.gov/ehs/pub3000/pub3000c.html o Refer to LBNL Environmental Restoration Program Documents http://www.lbl.gov/ehs/erp/html/documents.shtml o Refer to EBMUD LBNL Site-Wide Discharge Permit No. 0660079 1 o Refer to EBMUD LBNL Building 25 and 77 Discharge Permit No. 5023891 1 o Refer to EBMUD LBNL Treated Groundwater Discharge Permit No. 5034789 1 Plan & Schedule No further efforts are projected for this element at the present time. Page iii-5

Element iii. Legal Authority iii-b. Authority to properly design and construct sewer Requirement: Possess the necessary legal authority to require that sewers and connections be properly designed and constructed. Discussion Established Design and Construction Standards The LBNL has the authority to establish design and construction standards for sanitary sewer collection system infrastructure owned by the DOE as the "Prime Contractor" in control of the LBNL property and infrastructure per Contract 31 with the DOE. Because the Laboratory is owned by DOE, a Federal entity, it is not subject to local design and construction standards or ordinances. LBNL has established a list of applicable State and National infrastructure design and construction standards and codes within the LBNL Construction Standards and Design Requirements - Volume 1 Part 1 Administrative Requirements, which are adhered to by LBNL employees and hired subcontractors (refer to Section 1 General Codes). Additionally, LBNL has established site-specific design requirements within the Construction Standards and Design Requirements - Volume 1 Part 2 Design Requirements, Standard Project Specifications, and Standard Construction Details, which are adhered to where applicable. The Construction Standards and Design Requirements - Volume 1 Part 1 Administrative Requirements describes in detail LBNL's rigorous infrastructure design review and approval process, which includes design review milestones and LBNL employees who must review and approve plans. Specific submittal content and format requirements are described for preliminary design phase, final design phase, construction document phase, and bidding and construction phase plans, specifications, and estimates for any infrastructure project. All infrastructure projects for the LBNL are either completed in-house by Facilities Division Engineers, or under the direction of a Project Manager from the LBNL Facilities Division who ensures that LBNL's established design requirements are adhered to through contract management and the review and approval of all project submittals. Construction Completed by Licensed Contractors Per LBNL Standard Specification Section 0101 General Requirements, Section 1.12, contractors are required to hold general licenses, or specialty licenses applicable to the specific work to be completed in compliance with the California Business and Professions Code. LBNL Facilities Division Project Managers confirm appropriate contractor licenses during the bidding and contract award phases of each project. Page iii-6

Element iii. Legal Authority All New Infrastructure Inspected and Approved Per Construction Standards and Design Requirements - Volume 1 Part 1 Administrative Requirements Section 6: Construction Phase, a Project Inspector is assigned by LBNL to each project to verify that construction of the project complies with the contract documents, applicable codes, and LBNL design and construction standards. The Project Inspector is responsible for documenting inspections, and bringing any instances of non-compliance to the attention of the LBNL Project Manager, so that those issues may be resolved prior to completion of the project. LBNL typically contracts with third party testing laboratories to complete any materials testing that is recommended or required in the contract documents. Record Drawing Submittal Per Construction Standards and Design Requirements - Volume 1 Part 1 Administrative Requirements Section 6: Construction Phase, record drawings must be prepared by the Project Engineer based on changes noted during construction by the Contractor and Project Inspector. All record drawings are submitted in AutoCAD format to the Facilities Division, which are used to update the site-wide infrastructure mapping system. Related Documents o Refer to LBNL Construction Details and Design Guidelines Home http://fac.lbl.gov/dandc/cddg_home/ o Refer to LBNL Construction Standards and Design Requirements Volume 1 Part 1: Administrative Requirements (Latest Revision) http://fac.lbl.gov/dandc/cddg_home/volume1- Admin_&_Design_Guidelines/LBNL%20CS&DR%20- %20Admin%20Requirements%2021706.pdf o Refer to LBNL Construction Standards and Design Requirements Volume 1 Part 2: Design Requirements (Latest Revision) http://fac.lbl.gov/dandc/cddg_home/volume1- Admin_&_Design_Guidelines/LBNL%20CS&DR%20- %20Design%20requirements_20060502.pdf o Refer to LBNL Standard Project Specifications http://fac.lbl.gov/dandc/cddg_home/volume2- Construction_Guidelines/Standard_Project_Specifications.html o Refer to LBNL Standard Construction Details http://fac.lbl.gov/dandc/cddg_home/volume3-construction_details/ Plan & Schedule No further efforts are projected for this element at the present time. Page iii-7

Element iii. Legal Authority iii-c. Authority to ensure access Requirement: Possess the necessary legal authority to ensure access for maintenance, inspection, or repairs for portions of the lateral owned or maintained by the Public Agency. Discussion LBNL Facilities Division Staff have full access to all on-site infrastructure, including the sanitary sewer collection system and wastewater pre-treatment works located at various research facility buildings. There is no publicly or privately owned infrastructure at LBNL which could present an access issue. All infrastructure is owned by the DOE, and operated by LBNL Facilities Division Staff. Related Documents None. Plan & Schedule No further efforts are projected for this element at the present time. Page iii-8

Element iii. Legal Authority iii-d. Authority to limit FOG Requirement: Possess the necessary legal authority to limit the discharge of fats, oils, and grease (FOG) and other debris that may cause blockages. Discussion LBNL is required to comply with EBMUD Ordinance No. 311A-03 Title II Section 3a, which limits the discharge concentration of oil and grease to 100 mg/l to the sanitary sewer collection system. There is one food handling facility at LBNL, which is the on-site cafeteria. The cafeteria has a grease interceptor installed to control the discharge of FOG to the sanitary sewer collection system. This facility has not been required to obtain an EBMUD "Food Handling Facility Wastewater Discharge Permit", as these permits apply only to newly constructed facilities, remodeled facilities, or facilities which have caused or contributed to the cause of sewer blockages or SSOs related to FOG discharge. Currently, LBNL's site-wide discharge permit, as described in SSMP section iii-a, addresses FOG discharges from the cafeteria and other on-site grease producing facilities as a whole. It is possible that LBNL may be required by EBMUD to obtain a Food Handling Facility Wastewater Discharge Permit in the future if a new food handling facility is constructed, if the existing cafeteria is significantly remodeled, or if the existing cafeteria discharges excessive amounts of FOG to the sanitary sewer collection system that are determined to have caused a blockage or SSO, per subsequent EBMUD investigations. Additionally, there is a vehicle fueling (motor pool) facility at LBNL, which is served by two oil/ water separators which has been installed to comply with EBMUD's Pollution Prevention Program for automotive facilities, and the LBNL General Industrial Permit for stormwater discharges. One device discharges into the storm drain system, and the other discharges into the sanitary sewer collection system. The motor pool area is used only for vehicle refueling, and all vehicle maintenance is conducted off-site. All oil and fuel accumulated in the oil / water separators is regularly removed and disposed of by Facilities Division staff off-site. LBNL ensures that any new or modified automotive service or food handling facilities are served by Oil and Flammable Liquid Interceptors or Grease Interceptors conforming to the requirements of the California Plumbing Code (or Uniform Plumbing Code), Chapter 10. Related Documents o Refer to EBMUD Pollution Prevention Program Website http://www.ebmud.com/wastewater/industrial_&_commercial_permits_&_fees/pollution _prevention_program/ Plan & Schedule No further efforts are projected for this element at the present time. Page iii-9