LIFE SCIENCES OPERATIONS

1. LIFE SCIENCES OPERATIONS Management Review September 29, 2004

2. INTRODUCTION • Purpose: Provide Senior Managers with enough information to answer the following questions.. • Are the Life Sciences environmental management systems effective in achieving environmental policy commitments? • Is the EMS effective in achieving our objectives and measures? • Is the EMS adequate in terms of : • identifying significant environmental aspects? • resource allocations? • communication? • performance objectives and measures?

3. Operations Management Review Agenda AGENDA: • Life Sciences Organization • EMS • Work Planning and Control • Facility Ops • Training and Qualifications • Environmental Goals/Objectives Progress to Date • Assessment Results • Mgr. evaluation of EMS • S&H, Biosafety Programs, Rad, ORPS • Discussion

4. Life Sciences Operations Organization • Bill Gunther, Special Ass’t ALD • Ann Emrick, EMS, Training, ESR, WCM • Bob Colichio, ESH • Jim Bullis, ESHQ BLIP/TPL, Bldg. Mgr. 801 • Steve Ferrone, Environmental Compliance* • Lori Stiegler, Facility Support 490 & 463* • Nate Foster, Facility Support R&R* • Rich Sautkulis Building Manager, BO • Chris Harris, Bldg. Mgr. 490 • Henry Schnakenberg, Bldg Mgr., 931 *Part/time-matrixed-shared with other orgs.

5. LS EMS Significant Aspects • Industrial Waste • Hazardous Waste • Radioactive Waste • Mixed Waste • Regulated Medical Waste • Radioactive Regulated Medical Waste • Atmospheric Discharges-RTF, BLIP, TPL • Liquid Discharges • Chemical Storage/Use or Radioactive Material • Soil Activation –BLIP • Historical Soil Contamination-Greenhouses

6. Benchtop Experiments (ESRs BO: 21, MO: 16, NASA: 90 ) NASA ESR expansion-need to develop a plan to address these short term expts. Now-very labor intensive for both the researchers and the ESH staff. Walkthrough experiments as part of review process to ensure thorough review is done. ORE for new labs is redundant in many ways to ESR review. Need to do in the future as one process. Routine Processes (Avg. ~2 work permits/bldg/mo) The system is good but the WPs need to be completely filled out (improving) Environmental “Industrial” Processes– 16 evaluations Reviews conducted by ECR annually and upon modification LS Work Control Program LS Work Control Program

7. LS Work Control ProgramBLIP Safety Analysis Document Status BLIP should not require an SAD as it is not an accelerator (G. Shepherd will formulate draft for DOE) • Current SAD still reflects operations • Does not follow new subject area format • Does not use new “SBMS or organizational terminology”. • Efforts in BLIP ESH program have focused on addressing air emissions and groundwater issues. • Current path forward is not to complete SAD but to develop a plan to cover hazard analysis in existing documentation (manual, FUA) and wait for DOE ruling.

8. LS Work Control Program • New Facilities/Experiments • Two CryoEM scopes—two operational • N. Van der Lelie Labs renovated phase II underway • MR Facility- support labs/office underway • Terminated Experiments • BO-463 Chance (Albert Einstein), J. Setlow, Lacks • BO-463 –NCI Lab —in progress. • MO-MR-Chang/Ernst areas.

9. LS Work Control ProgramFY04 Operational- and Exit- Readiness Reviews • Improvement Opportunities: • Redundant to ESRs • Some individual findings are references to other documents with many issues.

10. Facility Operations-GPP • FY02 Upgrades: • 490: Animal MRI Wet Lab (Benveniste) - Completed • Partial Computer network re-wiring in 490 – on schedule • 463: van der Lelie –on schedule TBD 10/02 • 463: cryoEM facility—Engineering complete, construction in progress • 801 New waste tanks • FY03 Upgrades • 490: Animal MR (funded, construction) support areas(need funds) • 490 Complete network re-wiring? • 463: cryoEM Phase II (wet lab and screening facility) • FY04 Upgraded: • Van der Lelie Phase II –underway • MR Support Labs—underway • Additional 463 space to CDIC group to better utilize space and foster collaborations.

11. Facility Operations • FY05 needs: • 801 Tanks-desludging—mixed may require more funds? • 463 Office space addition (NASA program) • 463 Lab 164/167 (Plant Scientist recruit) • 490 9-801 upgrade • PuBe (WBC) Source disposal • 463 Freight Elevator • System Issues • Difficult to address needs of new scientists until they arrive but need to secure GPP • Future needs--Infrastructure Issues in the system.. • 801: Stack replacement (ADS)- Bullis supplying engineering contractor data • Legacy materials • Roof leaks (patches are short term fixes)—BLAF roof in progress • Old Labs (ADS) • 463- Library (ADS) • 463 chemical hood stacks—rusting

12. ESH&Q Training and Qualification • FY04 LS Performance Measures: Goal >90% Training Completion Employees MO ~98%; BO ~99%; DJ (Directorate staff) 100% Goal>85% Required Training Completion for Guests MO ~97% (RTF 91%); BO ~99%; DJ N/A • Improvements: • Guest Site Orientation online • Rad I Initial classroom portion shortened by having part 1 online • NSRL Exemption for classroom portion of Rad I initial training. • Linked JTAs for CRC staff to Credentialling forms. • BLIP and TPL Operator JTAs reviewed and updated. • Procurement training requirements clarified—need to consider graded approach? • Issues: • JTA Assessment • Preliminary data good. Issues with Rad training rqmts • Rad I challenge failures? • Need to update animal facility training

13. LS EMSFY04 Objectives & Targets • OBJECTIVES • Maintain compliance • Integrate pollution prevention / waste minimization into all planning & decision making • Implement pollution prevention/waste minimization practices that eliminate, minimize or mitigate environmental impacts. • Correct and Clean Up Existing Environmental Concerns • TARGETS • Maintain compliance through regular Tier I inspections • Close out previous environmental assessment issues • Participate in targeted environmental assessments • Use Work Planning Process to identify Waste Min Opportunities • Submit two Pollution Prevention Proposals and report two successes/other proposals • Maintain Legacy materials in compliant state, disposition as funds allow • Complete Dilution room cleanout

14. LS EMS FY04 Objectives and Targets Operate in Compliance • Maintain and Improve Tier I Inspection Program Status: Ongoing Issue: Competing priorities. Hard to get them completed with existing resources. Attendance was falling off, tunnel-vision Path Forward: PI involvement, Rotate SMEs, increase frequency, decrease duration (MO), OSHA training for Tier I team Current status: OSHA training helped reduce tunnel-vision, scheduling still problematic, PIs are not always present. Tier I Findings: Still have RCRA, Housekeeping, OSHA violations. Need to get more PI involvement. May consider some competition or awards program for good performers?

15. Close out previous assessment issues: Status: Ongoing Outstanding Issues: 801 Legacy waste tanks (ATS)- ADS in progress. BLIP Air Emissions (ATS Item)—enclosure installed for emission reduction, limited monitoring performed (30% decrease at one energy), Admin. Control Limit set and met. LS EMS FY04 Objectives and Targets Operate in Compliance

16. LS EMS FY04 Objectives and Targets Operate in Compliance Bldg 801 Tanks • FY04 GPP-Sample original D-Tanks and F-Tanks and characterize. Tanks are cut open, plan to characterize underway. • Sample 4 tanks this week • Potential mixed waste in project. • FY04 GPP to seal doors. NFPA issue so plan is to install a backflow device—project stalled. Estimated completion? Funding issues? • Dispose of sludge in all tanks—FY05 GPP? May need addition if mixed is identified • Formerly close IAW Health Dept. requirements—FY05 after sludge is removed can close this.

17. LS EMS FY04 Objectives and Targets Operate in Compliance: BLIP Air Emissions • BNL-BAO Audit finding/EPA discussions • EPA history • CEM promises • Radioisotopes not fully characterized • Calculation errors • 2001 extended operating run • FY2003 actions: • EPA inspection-BNL Plan • Enclosure designed and built (P2$) • CEM in-place to test enclosure • Data generation (abbreviated run) • FY2004 actions: • Continuous monitoring implemented • Limited efficacy testing performed • Emission reductions --~30% • Admin. Control Limit met • 11 weeks of operation @ 73 uA • FY2005 : • More data for EPA Performance Track Before Enclosure: Target conveyance electric drives After Enclosure Installation: Enclosed target drives

18. Life Sciences EMS Management ReviewOperate in Compliance: Groundwater Quality Doug Paquette Environmental and Waste Management Services Division September 29, 2004

19. Groundwater Quality at BLIP • Concern: Activated soil shielding surrounding the BLIP target vessel. Rainwater infiltration can carry tritium and sodium-22 to the groundwater • 1998: Detected tritium in groundwater at concentrations >20,000 pCi/L drinking water standard • Controls and monitoring • Improved rainwater controls: gunite cap, sealed roadway, new downspouts • Injected silica grout into soils surrounding the target vessel • Installed seven new wells for improved surveillance • Periodic increases in tritium concentrations

20. Groundwater Monitoring

21. Tritium in Groundwater

22. Water Table Fluctuations • 2003 increase in tritium concentrations may have been linked to rise in water table • 6.5 foot rise from Oct. 2002 to July 2003 • Flushes “older” tritium in zone close to water table – not from the activated shielding • Similar flushing of tritium has been observed at HFBR and g-2 areas • Much lower concentrations associated with the BLIP plume

23. Possible Water Table Effects BLIP …………………………………. …………………………………. …………………………………. …………………………………. EL 100’ Target Vessel Beamline from Linac EL 70’ Monitoring Well Activated Soil – Grouted in 2000 Tritium and Sodium-22 leached prior to cap and during grout injection EL 49’ Water Table fluctuation Groundwater Table EL 43’

24. Additional Concerns • Additional soil activation areas located upgradient of BLIP may not be fully protected by existing cap (the “BLIP Spur”) • Low levels, but slightly above our conservative capping requirements • BLIP Spur cap installed this month (9/04) • Plans are to extend the cap to Linac and tie it into the Booster beam stop cap (“integrated” cap design)

25. New Caps Linac Cap Spur Cap

26. Building 801 • Concern: • Water from December 2001 basement flood contained high levels of Sr-90 (594 pCi/L) and Cs-137 (784 pCi/L). Some water may have seeped into the soils below the building • Actions: • Sampled existing wells downgradient of Building 801 • Installed a new shallow well immediately downgradient of the flooded area of the building • Monitoring Results: • Sr-90 detected in pre-flood monitoring; no Cs-137 • Sr-90 concentrations in post-flood monitoring are consistent with pre-flood concentrations • Monitoring conducted on semiannual frequency

27. Sr-90 in Groundwater

28. LS EMS FY04 Objectives and Targets Operate in Compliance-Audits/Assessments • EWMSD Liquid Effluents Assessment • Nonconformance for RTF photo-processor connection (ATS item) • EWMSD Facility Review Disposition Project Assessment • 4 legacy items (items closed and added to FUA database) • EMS Related Required Self-Assessments: • Records Mgmt-no issues with environmentally significant records. • Energy Mgmt—provided status to EP. EP has lead, could do more in Depts (leaky faucets, turn off lights, etc). • Fire Safety-identified some egress problems (Semiworks filter room)

29. LS EMS FY04 Objectives and Targets Operate in Compliance-Audits/Assessments • RCRA • DEC Surprise inspection (1/04) -no findings for LS • BNL 2004 Assessments – • Nonconformance (BO) for waste being evaporated in hood.Need to address ATS item (discussed with Lab personnel). • Site-wide issues (labeling, aerosol cans, training). • LS 2004 Causal Analysis • Performed root cause analysis with EWMSD, QA, EENS, LS, PO. • Corrective actions identified and in process of implementation. • FY05 goal to finish (modify subject area, training)

30. LS EMS FY04 Objectives and Targets Compliance/Cleanup –Regulated Medical Waste Mgmtand R-RMW • The Medical Dept manages the RMW program for the site. ECR assists and is SME: • 226 containers shipped • 5500 lbs. total • $3500 disposal costs (direct) • 0.2 FTE FS tech support/0.2FTE Infection Control/ECR • Radioactive Regulated Med Waste shipped on 5/15/04 • 39 items shipped (3 yr. accumulation) • 358 lbs. total • Negotiated cost down by $3500 to $17,700 • Joint effort (ECR, WMR, RCD, MO)

31. LS EMS FY04 Objectives and Targets Compliance/Cleanup –Controlled Substances Destruction • The Clinical Research Center manages the Controlled Substances program for the site. CRC and EWMSD/ECR disposal projects: • Inventory of legacy controlled substances • U.S. DEA discussions, documentation and approvals • Sharps and non-sharps destruction (2 different waste streams) • Sharps went to a Reg. Med. Waste incinerator • Non-sharps went to a DEA-approved destruction facility • Coordination with destruction facility • Witnessed destruction • Follow-up documentation (cradle-to-grave) • Cost of approx. $1200 plus labor

32. LS EMS FY04 Objectives and TargetsClean Up Existing: Disposition Excess Materials Life Sciences provided resources (labor, waste costs for both WMR and disposal, FS costs) to dispose of the following: • Biology • CERF Sources sent to HWM. • >500 bar coded legacy chemicals were disposed of in 463 as part of consolidation of lab space. • ~120 Chemicals transferred to new owners • 1 Rad Area identified to be surveyed and deposted (leaves only 3 dispersibles work areas). • Medical • Disposal of legacy controlled substances (sharps and non-sharps) • Disposal of RMW, Rad-RMW • 9-807, 9-931 Clean out, • Cleanout 9-436…

33. LS EMS FY04 Objectives and TargetsClean Up: Disposition Excess Materials Dilution/Carcinogen Rooms 9-436, 9-432, 9-434 COMPLETE 9/10/04

34. LS EMS FY04 Objectives and TargetsClean Up: Disposition Excess Materials • LS has committed resources to excess materials • $17,700 Rad RMW • $3,500 RMW • $1,200 Controlled Subs • $10,000 (WMR, FS) for: • Dilution Room • 463 WMR cleanout of chemicals • 801 Vault cleanout (ESH, FS time) • ESH, ECR, FS, Bldg Mgrs, other resources • Still have legacy items and need to continue cleanouts. • List with EWMSD • Labs, 490 basement • PuBe Sources (ADS)

35. LS EMS FY04 Objectives and Targets Waste Minimization Lab closures

36. LS EMS FY04 Objectives and Targets Waste Minimization

37. LS EMS FY04 Objectives and Targets Waste Minimization

38. LS EMS FY04 Objectives and Targets Waste Minimization

39. LS EMSWaste Min: Work Ahead (Goals FY05) Path Forward: Continue to look for waste minimization opportunities. Minimize disposal costs. • Strategies: • EWMS Pilot Project Results • Most inexpensive approach = utilize EWMSD personnel and RCRA-haz. waste storage facilities to combine shipments • Continue to explore disposal options (e.g. Formaldetox for non-haz. waste) • Continue to discuss waste min in ESRs • Reduction in Legacy Footprint (labs) - WMR Special Projects

40. LS EMS FY04 Objectives and TargetsAchieve integration of ESS&H into all facets of work • Submit at least two P2 Proposals and/or report two P2 successes. Completed! • Submitted 4 proposals: 2 funded

41. LS EMS FY04 Objectives and TargetsFY04 Funded P2 Proposal: MW Peptide Synthesizer Title:Significant Reduction of Hazardous Organic Waste with a Microwave Peptide Synthesizer Cost: $36.5K Annual Savings: $26K Benefits: • Safer (decreased quantity/handling of organic solvents) • Productivity increase • Facilitates compliance Status:Purchased and installed in 8/04

42. LS EMS FY04 Objectives and Targets FY04 Funded P2 Proposal: Replacement of Mercury Devices Title: Replacement of Mercury Based Utility Switches, Thermometers and Thermostats in Buildings 463 and 490. • Cost: $2500 • Annual Savings: $1750 • Benefits: • Reduces haz. waste (spills) • Decrease safety hazards • Risk reduction • Less toxic alternatives • (alcohol vs. mercury) • Status: Completed. 50 lbs Mercury!!

43. LS EMSStakeholder Concerns • BLIP Soil Activation • Working with CAD and EWMS (quarterly monitoring) • LINAC cap construction started in 4Q04 • 2 Spills Reported to DOE • BLIP beam window—2 failures: • April 28, 2004 • May 8, 2004 • Spill of activated cooling water into secondary containment (no leak to ground) • DOE and Health Dept. notified • 600gal Rad Waste water drummed and removed by HWM. • Cause—LINAC beam wandered

44. LS EMS FY04 EMS Assessments • FY04 Internal EMS Assessment Conducted on 2/04 by BNL and Oak Ridge rep. • Identify EMS strengths and weaknesses • Assess conformance of EMS to the ISO 14001 Standard • Assess EMS effectiveness in achieving the commitments in the BNL Environmental Stewardship policy Findings: • OFI:Awareness of e-policy • Other site-wide issues • FY04 EMS External NSF Re-registration Audit • Complete site review (intensive) • 7/04 Directorate surveillance audit successful!! • No non-conformances or observations for LS!! • Site-Wide applicable—will address in FY05 • Communicate Environmental policy • Evaluate aspects of products and services

45. LS EMSWork Ahead (Goals FY05) • Replace ESSH policy with EMS policy in EMS program. • Identify evaluation of products/services as part of WP process • Continue to Improve Tier I program (link to ORE & ESR process) • Schedule thorough Tier I of 490 basement to identify excess materials. • Bldg. 801 Legacy tanks (DO responsibility, in LS EMS)- • Install backflow device • Obtain GPP funding to desludge tanks. • Continue to submit monthly Health Dept. non-conformance reports. • Implement corrective actions from RCRA causal analysis • Update Subject Area (EWMSD Lead) and implement (Depts) • Update Training module (EWMSD Lead) • BLIP Air • Generate more data to test effectiveness of enclosure, data collection, data modeling, EPA submissions, equipment calibrations

46. LS EMSWork Ahead (Goals FY05) • Participate in EWMSD Assessments • Environmental Monitoring • NEPA • Waste Characterization • P2 proposals and success reporting • Inventory mercury containing devices (EPA Performance Track) • Identify Ozone Depleting Substances (EPA Performance Track) • Routine Waste-continue to evaluate for waste minimization opportunities. • Non-Routine Waste-continue to seek funding for disposal, sampling, FS costs. • Continue to dispose of excess materials- FY05 Resources? • Excess Materials List (e.g. Bldg. 490 basement)– • Need to characterize unknowns (sampling costs), packout waste chemicals (WMR), rad waste (FS), RMW (ECR), etc. (WBC, 801 vault, tanks) have ADSs.

47. Senior Management EMS Program Evaluation • Purpose: Identify improvement actions and assign responsibility and resources to implement

48. Senior Management EMS Program Evaluation-Question 1 • Is the EMS program effective in achieving policy commitments? • Compliance • Tier Is, Work Planning, assessments • Pollution Prevention • Work planning, P2 program success • Community Outreach • CAC, Summer Sundays, tours • Clean Up • Lab cleanouts, ERE process • Continual Improvement • Assessments, lessons learned

49. Senior Management EMS Program Evaluation-Question 2 • Is the EMS program effective in achieving objectives and performance measures? • Compliance • Tier Is, Work Planning, assessments • Pollution Prevention • Work planning, P2 program success • Community Outreach • CAC, Summer Sundays, tours • Clean Up • Lab cleanouts, Dilution Rooms, ERE process • Continual Improvement • Assessments, incorporating lessons learned

50. Senior Management EMS Program Evaluation-Question 3 • Is the EMS program adequate in terms of: • Identifying significant environmental aspects and impacts? • Work planning, process assessments • Note: need to address aspects of products/services • Resource Allocation? • ESH staff, FS, ECR, funding for cleanouts • Communication? • Training, work planning, emails • Goals and Objective • Do we do enough or too much? Are we missing anything important? • Information systems? • Staff expertise? • ESH, ECR, SMEs • Procedural requirements?