DOE Order 151.1c Comprehensive Emergency Management System

1. DOE Order 151.1c Comprehensive Emergency Management System Implementation Plan Update 1/11/2013

2. Background Implementation Plan was developed to address deficiencies in compliance identified by BSO • 2011 Emergency Planning Hazards Assessment (EPHA) was not defensible and therefore not approved. • Business Continuity Program was insufficient • Accurate and timely notification of Hazardous Chemicals • Corrective Action Plans were developed for all three of these issues Environment / Health / Safety / Security DIVISION

3. Emergency Planning Hazards Assessment A facility specific screening for facilities involved in producing, processing, handling, storing, or transporting hazardous materials that have the potential to pose a serious threat to workers, the public, or the environment. • As required by DOE Order 151.1c, LBNL is to assess hazardous materials and screen all chemicals that: • Represent National Fire Protection Association (NFPA) health hazard 3 or 4 and; • Are in quantities greater than those which can be easily and safely manipulated by one person (lab safety quantity); or • Are stored in multiple containers where the room total exceeds 5 times the lab safety quantity. • * If there is the possibility that a potential release may cause a classified Operational Emergency, then an EPHA is required. • The results of the EPHA will then determine if the release of each identified material will cause a hazard significant enough to be included as part of the Hazardous Material Program planning basis. Environment / Health / Safety / Security DIVISION

4. Emergency Planning Hazards Assessment Corrective Action Plan • LBNL staff reviewed and evaluated a screening methodology developed by the DOE Emergency Management Issues Special Interest Group (EMI SIG). Used the methodology to evaluate our existing EPHA (B 77). • The results of the evaluation indicate we have effectively mitigated the risk associated with our existing EPHA, but we are awaiting BSO approval of the findings. • Should result in a DOE planning status of “Base Program” rather than “OE Hazardous Materials Program”. • Lessens the requirements related to emergency planning, notifications, response capabilities, etc. Environment / Health / Safety / Security DIVISION

5. Hazardous Materials Awareness Corrective Action Plan • Review Purchasing Line Summary Report • Rad Protection Group require select purchase to receive “authorization”. • CMS report now generating a “sub-report” on items with potential to exceed the lab safety quantity. • Procurement has worked with Ebuy vendors to code certain products to generate an automated notification. Environment / Health / Safety / Security DIVISION

6. Hazardous Materials Awareness Corrective Action Plan • Automatic notification out to purchasers with dual appointment status • Spot checks incorporated into Chemical, Health & Safety program lab inspection • Still need to address blanket purchase orders • Still need to socialize and develop lab work process/policy through RMP Environment / Health / Safety / Security DIVISION