As a laboratory that researches the physical and chemical properties of matter, some of Lawrence Livermore National Laboratory's programmatic activities can produce hazardous pollutants or wastes as byproducts. LLNL works diligently to abide by the environmental regulations set forth by the Department of Energy and nearly 30 external regulators such as the Environmental Protection Agency (EPA) and local entities such as the Bay Area Air Quality Management District and the San Francisco Bay Regional Water Quality Control Board to ensure the environment is properly protected. In addition to agency regulations, LLNL is subject to federal laws such as the Endangered Species Act and Clean Water Act.
Merely navigating this complex web of regulations and interagency relationships requires domain-specific expertise to understand how different entities are involved with different steps of the Lab's waste-management processes. For example, the Certified Unified Program Agencies regulates LLNL's waste generator areas, and the Department of Toxic Substances Control regulates the permitted waste facilities.
"It requires a comprehensive understanding of many different sets of environmental regulations to ensure proper implementation of work controls onsite," said Gino Aluzzi, group leader for the Laboratory's 16 field environmental analysts. "Despite such extensive regulatory protocols, we are still left with the challenge of applying those regulatory requirements to the activities conducted here given the uniqueness of the Laboratory's work."
With so many cutting-edge research programs handling materials that do not fall squarely into guidance categories sufficient for other industries, the Lab needs staff with a broad knowledge base who can understand diverse environmental risks, precautions and mitigation techniques. Field Environmental Analysts (EAs) serve as environmental generalists with broad regulatory understanding, providing a direct link between individual Laboratory programs and the Environment, Safety and Health (ES&H) environmental policies and procedures. As part of a broader ES&H Integrated Safety Team (IST), field EAs advise on strategies to help maintain environmentally safe site operations and prescribe controls or sampling and analysis plans to characterize wastes to ensure regulatory compliance.
Managing legacy materials
To begin, field EAs must determine which materials are deemed environmentally hazardous. Ignitability, corrosivity, reactivity, toxicity and radioactivity are all characteristics that could qualify a material as hazardous or radioactive waste upon its disposal.
"As Field EAs, we provide comprehensive support for everything environmental. We consider all potential sources for pollution and contamination, including hazardous and radioactive waste, air emissions and sewer discharges to prevent any incidents. In my previous role outside of LLNL, I specialized solely on wastewater and storm water, but as a field EA here, I have the opportunity to consider all environmental sub-fields," Adrian Garibay said.
Garibay works on the Institutionally Managed Facilities/Transition and Disposition IST and primarily supports the stewardship of excessed buildings and their demolition to enable mission growth at LLNL. When assessing buildings slated for demolition, he pays particular attention to uncovering substances that were historically used in construction materials but which are now known to be contaminants of concern. The most common problem substances include: asbestos, used for insulation and fireproofing; lead, added to paint to accelerate drying and increase durability; and PCBs (polychlorinated biphenyls), which were added to paint and caulking materials to improve temperature resistance. Field EAs work to ensure these substances are not released into the surrounding environment during demolition and that contaminated materials are properly managed and handled en route to appropriate disposal facilities.
Some materials are easier to spot than others. In older buildings, standard environmental contaminants of concern include air conditioning refrigerant and universal waste such as lightbulbs and mercury thermometers that must be removed prior to building demolition. But to know for sure whether more innocuous substances are present, field EAs plan environmental sampling campaigns.
"The job is like piecing together a puzzle," Garibay said. "We consult historical documents and interview researchers who worked in that location to determine a sampling plan and tackle the unknown."
The more extensive a sampling campaign proves to be, the longer and costlier it becomes. Field EAs therefore want to target their efforts with the most relevant tests for each campaign. Garibay pores over historical records to ascertain what types of contaminants may still be present based on the type of work performed in each building decades ago. Sampling efforts are then carried out with the support of the IST, program leads, Radioactive and Hazardous Waste Management, and roofers from the Carpenter Shop.
Monitoring modernization
While field EAs like Garibay are helping clear the way for seamless demolition efforts, others are focused on what will fill those reclaimed spaces. David Herrera is a field EA for the IST supporting the Project Management Office working to ensure that construction complies with environmental regulations. In recent years, LLNL has taken on dozens of new construction efforts to modernize facilities, house new experimental capabilities and support a growing workforce. And more projects are coming down the pipeline.
"Field EAs serve as the primary link between specific programs and the Environmental Functional Area, where our subject matter experts reside," Herrera said. "We're well equipped to help them locate the resources they need because we're familiar with the type of work they will carry out."
Herrera has spent much of his recent time on the future site of the Digital Infrastructure Capability Expansion (DICE) building, which will be a hub for networking and digital communication as further buildings spring up across the Laboratory. Herrera explained that much of the testing he recommends involves soil sampling. As an EPA-designated Superfund site, sampling is needed to make determinations on how soil should be managed. In the soil, field EAs typically sample and analyze for metals, radiological substances and volatile organic compounds such as benzene, which could change the soil management strategy if levels exceed certain thresholds.
Herrera conducts weekly field walks at the site, donning personal protective equipment and filling out an "environmental absolute" to record observations. Field walks also present a good opportunity to check on stormwater best management practices, for instance assessing stormwater drain protection integrity and checking for any sediment leaving the project site.
"I find playing a role in environmental protection incredibly rewarding," Herrera said. "My previous roles have been on the side of protecting the environment through fighting air pollution. Now, as a field EA at Livermore, I've gained more familiarity with regulations in other domains, too."
Familiarity with such a wide range of environmental considerations is necessary for the Laboratory to continue to perform its unique programmatic activities while ensuring the land it occupies is spared from hazardous materials.
"In my experience working in outside industry in the Bay Area, there are very few - if any - organizations out there that have the same number of different environmental aspects that we have here," Aluzzi said. "We are fortunate to have a very talented field EA group with strong environmental work backgrounds. Many are former regulatory inspectors and others have worked previously as environmental managers or specialists. By partnering with our programs and helping them navigate the complex world of environmental compliance, our teams are ultimately helping to protect the environment."
~Elliot Jaffe
