Chronic Beryllium Disease Prevention Program for the ......Beryllium-induced lymphocyte...

PLN-5512 Rev. 1

Chronic Beryllium Disease Prevention Program for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project

U.S. Army Corps of Engineers Buffalo District, Buffalo, New York

Applicability: Luckey FUSRAP Remediation

Effective Date: 09/14/2016 Owner: Project Manager

Signature:

CHRONIC BERYLLIUM DISEASE PREVENTION PROGRAM FOR THE LUCKEY FORMERLY

UTILIZED SITES REMEDIAL ACTION PROGRAM REMEDIATION PROJECT

Identifier: Revision: Page:

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History of Revisions

Revision Issue Date Action Description

0 06/29/2016 New document Initial issue.

1 09/14/2016 Revise document Edits and comments from USACE Buffalo District tech editor(s).




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Table of Contents

1. PURPOSE ..............................................................................................................................9

2. SCOPE ...................................................................................................................................9

3. DEFINITIONS .....................................................................................................................10

4. ROLES AND RESPONSIBILITIES ...................................................................................13

4.1 Portage Executive Management Environmental, Safety, Health and Quality (ESH&Q) Director/President ...................................................................................15

4.2 Luckey Safety and Health Manager .........................................................................15

4.3 Luckey Remediation Program Manager ..................................................................15

4.4 Luckey Remediation Project Manager .....................................................................15

4.5 Luckey Project Occupational Medical Director .......................................................15

4.6 Site Safety and Health Officer .................................................................................16

5. PROGRAM REQUIREMENTS ..........................................................................................16

5.1 Baseline Beryllium Inventory and Activity .............................................................16

5.2 Occupational Exposure Limits .................................................................................20

5.3 Surface and Bulk Concentration Limits ...................................................................20

5.4 Initial Beryllium Hazard Assessment .......................................................................21

5.5 Beryllium Operations – Beryllium Hazard Assessment and Beryllium Work Permit .......................................................................................................................25

5.6 Exposure Monitoring ................................................................................................27

5.6.1 Exposure Categorization .........................................................................31 5.7 Exposure Reduction and Minimization ....................................................................32

5.8 Regulated Areas, and Control Zones ........................................................................32




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5.9 Hygiene Facilities and Practices ..............................................................................36

5.10 Respiratory Protection ..............................................................................................36

5.11 Other PPE .................................................................................................................41

5.12 Training ....................................................................................................................41

5.13 Housekeeping ...........................................................................................................44

5.14 Beryllium Emergency ..............................................................................................44

5.15 Medical Surveillance ................................................................................................45

5.16 Medical Removal .....................................................................................................46

5.16.1 Temporary Removal Pending Final Medical Determination ...................47 5.16.2 Permanent Medical Removal ..................................................................47 5.16.3 Return to Work after Medical Removal ..................................................47

5.17 Counseling ................................................................................................................48

5.18 Postings and Labeling ...............................................................................................48

5.18.1 Posting of Beryllium Areas ......................................................................48 5.18.2 Labeling of Material and Surfaces ...........................................................49

5.19 Recordkeeping and Use of Information ...................................................................49

6. REFERENCES .....................................................................................................................51

Appendixes

APPENDIX A Development of Particulate Emission Factor for Resuspension during Soil Disturbance Activities ..........................................................................................................53

APPENDIX B Task-Specific Beryllium Hazard Assessment Form (Preliminary) .......................56

APPENDIX C Task-Specific Beryllium Work Permit (Preliminary) ...........................................62




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Figures

Figure 4-1. Luckey project organizational chart. .......................................................................... 14 Figure 5-1. Luckey Site Plan Showing 10 Major Work Areas. .................................................... 17 Figure 5-2. Preliminary Profile of Site-Related Surface Soil Be Concentrations by Anticipated Work Area. .................................................................................................................................... 18 Figure 5-3. Initial Estimates of Potential Be Exposures to Workers Involved with Project Soil Excavation and Dumping Activities. ............................................................................................ 22 Figure 5-4. BHA–BWP Operational Relationship........................................................................ 26 Figure 5-5. Conceptual Correlation Between Airborne Be Exposure Concentrations and Real-Time Total Suspended Particulates. .............................................................................................. 28 Figure 5-6. Exposure Monitoring and Estimation Categorization. ............................................... 31 Figure 5-7. General Layout of Control Zones. ............................................................................. 35 Figure 5-8. Relationships Among Measured Air Concentrations, OSHA-Assigned Protection Factors, and Be OEL and AL. ....................................................................................................... 38 Figure 5-9. Examples of Signs to be Used at the Luckey Site. ..................................................... 50

Tables

Table 2-1. Key CBDPP program activities by project phase. ....................................................... 10 Table 5-1. Luckey Site Be Soil Concentrations. ........................................................................... 19 Table 5-2. Conceptual Exposure Risk Profile. .............................................................................. 24 Table 5-3. Monitoring and Respiratory Protection Actions According to Be Exposure Levels/Limits. ............................................................................................................................... 40 Table 5-4. Respirator Types, APFs and Target PPFs. .................................................................. 40 Table 5-5. Beryllium Training Program Profile. .......................................................................... 42




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ACRONYMS AND ABBREVIATIONS

µg/100 cm2 micrograms per 100 square centimeters

µg/m3 micrograms per cubic meter

AIHA American Industrial Hygiene Association

AL action level

APF assigned protection factor

APP accident prevention plan

APR air-purifying respirator

Be beryllium

Be-LPT beryllium-induced lymphocyte proliferation test

BeO beryllium oxide

BeOH beryllium hydroxide

BCA beryllium-controlled area

BHA beryllium hazard assessment

BRA beryllium-regulated area

BWP beryllium work permit

CBD chronic beryllium disease

CBDPP Chronic Beryllium Disease Protection Program

CFR Code of Federal Regulations

CRZ contamination reduction zone

DOE Department of Energy




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ESH&Q environmental safety, health, and quality

EZ exclusion zone

FF fit factor

FUSRAP Formerly Utilized Sites Remedial Action Program

HEPA high-efficiency particulate air

HVAC heating, ventilation, and air conditioning

ICP inductively coupled plasma

mg/kg milligrams per kilogram

NEA negative exposure assessment

NIOSH National Institute for Occupational Safety and Health

OSHA Occupational Safety and Health Administration

OEL occupational exposure limit

PAPR powered air-purifying respirator

PEF particulate emission factor

PgM program manager

PM project manager

POMD project occupational medical director

PPE personal protective equipment

PPF program protection factor

ppm parts per million

SEG similar exposure group




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SHM Safety and Health manager

SSHO site safety and health officer

SSHP site safety and health plan

SZ support zone

TSP total suspended particulate

TWA time-weighted average

TWA8hr 8-hour time-weighted average

USACE United States Army Corps of Engineers




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1. PURPOSE

The purpose of the Chronic Beryllium Disease Protection Program (CBDPP) is to provide the Luckey Formerly Utilized Sites Remedial Action Program (FUSRAP) Remediation Project (the project) with project-specific guidance for controlling workers’ exposures to beryllium (Be) through inhalation, ingestion, or dermal pathways. Exposure to Be, above safe concentrations, can result in adverse health effects. This CBDPP establishes how Portage and its subcontractors must conduct beryllium activities. It will discuss ways to minimize the number of workers potentially exposed to Be, the ways in which exposure can occur, and the roles and responsibilities of all individuals under the CBDPP. Portage will implement the CBDPP by setting and obtaining specific reduction and compliance goals.

2. SCOPE

This section will define the requirements of the CBDPP. Table 2-1 illustrates the main CBDPP activities expected to occur in each phase of the project. As the project evolves and more information is generated and interpreted, CBDPP activities will become more precise. Portage will work closely with the U.S. Army Corps of Engineers (USACE) on all aspects and evolutions of the CBDPP as the project progresses.

In Table 2-1, Phase I is identified as developing remediation work plans and assumes no on-site activity. It is possible that, with USACE concurrence, limited support zone preparation on-site work could begin, including – but not limited to – clearing and grubbing, civil engineering to support infrastructure planning, and installing and repairing fencing. In addition to preparing the support zone, Portage will need to develop and verify for use an area for administrative functions. These include – but are not limited to – equipment storage, breakrooms, toilet facilities, and necessary managerial functions. Verification will be through a final status survey-type assessment addressing not only beryllium but other radiological constituents. If this verification occurs, Portage will implement appropriate Phase II and Phase III CBDPP program activities (e.g., beryllium-induced lymphocyte proliferation test [BeLPT], perimeter and personal monitoring, and the beryllium hazard assessment [BHA] and beryllium work permit [BWP] systems).




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Table 2-1. Key CBDPP program activities by project phase.Phase Key CBDPP Activities

Phase I. Develop Remediation Work Plans

Develop the CBDPP and BHA and BWP approaches, and ensure integration with the project accident prevention plan (APP) and air monitoring and laboratory programs.

Phase II. Infrastructure, Operations and Maintenance

Implement Be-LPT screening and work qualification; initiate worker training; support air monitoring, and determine background airborne perimeter concentrations; perform soil and airborne data correlation and interpretation; perform laboratory coordination; perform support zone (SZ) and S1 area preparation and mobilization; initiate Be exposure monitoring; perform total suspended particulate (TSP) measurements, and correlate with soil contamination (coinciding with SZ characterization and preparation and S1 hot spot removal). Tailor CBDPP and APP/site safety and health plan (SSHP) air monitoring programs in consultation with USACE. Initiate implementation of the BHA and BWP process.

Phase III. Remediation

Full CBDPP implementation. Modify the CBDPP to address changes in conditions, in consultation with USACE.

3. DEFINITIONS

Action level (AL). The level of airborne concentration of Be that, if met or exceeded, requires the implementation of worker protection provisions specified in Section 5. The action level for implementation of all the worker protection provisions specified in Section 5.2 will be 0.1 micrograms per cubic meter (µg/m3), based on the September 12, 2014, Variance Request Memorandum (USACE 2014a).

Administrative Area. A defined area on the periphery of the Luckey Site where beryllium airborne exposure is not anticipated, and workers and visitors are not regarded as beryllium workers. Defining the administrative area will be an important activity when site access is available.

Background. Either the local background beryllium soil concentration of 1.13 mg/kg (1.13 ppm) or the background beryllium air concentration (to be determined), depending on the context.

Beryllium. Elemental Be and any insoluble Be compound or alloy containing 0.1 percent Be or greater that may be released as an airborne particulate.




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Beryllium activity. An activity or task performed at a project site that can expose workers to airborne Be, including but not limited to design, construction, operation, maintenance, investigation, or decommissioning.

Beryllium-contaminated material. Material with removable surface Be at greater than 0.2 micrograms per 100 square centimeters (>0.2 µg/100 cm2) after decontamination or cleaning, when characterized by wipe sampling methods, or at levels that exceed the background Be level when characterized by bulk sampling methods.

Beryllium-controlled area (BCA). An accessible area where removable surface Be levels have the potential to exceed the background Be level (1.13 mg/kg) or a removable building surface concentration >0.2 µg/100 cm2. A BCA can be an entire building, room, system, or a geographic area.

Beryllium-regulated area (BRA). An area where the airborne concentration of Be exceeds, or can reasonably be expected to exceed, the AL.

Beryllium emergency. Any occurrence that results in an unexpected and significant release of Be at a project site such as, but not limited to, equipment failure, container rupture, or failure of control equipment or operations.

Beryllium hazard assessment (BHA). Prework evaluation that includes an analysis of existing conditions, exposure data, medical surveillance trends if applicable, and the exposure potential of planned activities. The BHA is the basis for a beryllium work permit work authorization and control system.

Beryllium-induced lymphocyte proliferation test (Be-LPT). A blood test that measures Be sensitization, which is an "allergic" reaction to Be. It is an in-vitro measure of the Be antigen-specific, cell-mediated immune response.

Beryllium work permit (BWP). A written set of controls and work practices required for work in a Be-controlled area or Be-regulated area.

Beryllium worker. A current worker with a reasonable potential for exposure to airborne levels of beryllium. This also includes a worker who is subject to medical removal due to Be exposure at the project site.

Beryllium waste. Equipment, soils, debris contaminated with Be that cannot be decontaminated below 0.2 µg/100 cm2, or personal protective equipment (PPE) and other disposable sampling materials that have been in contact with surfaces within an area considered a BRA.




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Breathing zone. A hemisphere forward of the shoulders, on the mouth and nose, with a radius of 6 to 9 inches.

Bulk criterion. A concentration of bulk soil that may be used to gauge the need for decontamination (1.13 mg/kg [background]).

Certified industrial hygienist. A health and safety professional certified by the American Board of Industrial Hygiene.

Contamination reduction zone (CRZ). A defined buffer zone between the SZ and the exclusion zone (EZ) established to protect workers and prevent spread of contamination. Site work will be managed so that personnel and equipment working in the EZ are required to pass through the CRZ and be decontaminated before moving into the SZ.

Exclusion zone. A project area where historical or sampling data indicate a likely potential to disturb Be-contaminated surfaces, soils, or structures. If analytical data establish the presence of Be, then the area will be classified as a BCA or BRA as defined by the action levels for those areas.

Historical site assessment. A detailed investigation to collect existing information, primarily historical information, on a site and its surroundings to determine what hazardous contaminants were used and may still be present on or adjacent to a property.

High-efficiency particulate air. A filter capable of trapping and retaining at least 99.97 percent of 0.3-micrometer monodispersed particles.

Housekeeping criterion. The removable surface beryllium concentration used to gauge housekeeping effectiveness (3 µg/100 cm2).

Immune response. The series of cellular events by which the immune system reacts to challenge by an antigen.

Medical removal benefits. The employment rights established by Section 5.16 of this program for Be workers who voluntarily accept temporary or permanent medical removal from Be areas following a recommendation by the project occupational medical director.

Negative exposure assessment. An objectively based monitoring review process to adequately characterize exposure as below the AL.




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Occupational exposure limit (OEL). Defined by variance request specified in Memorandum Thru Commander, U.S. Army Corps of Engineers, Lakes and Rivers Division, to Commander, U.S. Army Corps of Engineers, Buffalo District, Subject Variance Request, EM 385-101, Section 06.A.01, Exposure Standards (USACE 2014a). The OEL for Be is 0.2 µg/m3 calculated as an 8-hour time-weighted average.

Operational area. An area where workers are routinely in the presence of Be as part of their work activity.

Project site. The contractually defined geographical and infrastructure areas for work being conducted.

Release criteria. The level of removable contamination for surfaces of equipment or items is less than 0.2 µg/100 cm2 for wipe samples, or the background level for bulk samples.

Removable (beryllium) contamination. Beryllium contamination that can be removed from surfaces by nondestructive means, such as casual contact, wiping, brushing, or washing.

Project occupational medical director (POMD). The physician responsible for the overall direction and operation of the Site Occupational Medicine Program. WorkCare, a company contracted by Portage to provide medical surveillance for its employees, including the Be-LPT test, will provide the POMD for this project.

Support zone. A defined control zone where offices, the break room, and other project support facilities are located. The SZ is not a remediation work area and will be maintained free of Be and other contamination.

Worker exposure (to beryllium). The exposure of a worker to airborne Be that would occur if the worker were not using respiratory and dermal protective equipment.

4. ROLES AND RESPONSIBILITIES

Key roles and responsibilities are identified below. Organizational relationships are illustrated in Figure 4-1.




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Figure 4-1. Luckey project organizational chart.




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4.1 Portage Executive Management Environmental, Safety, Health and Quality (ESH&Q) Director/President

Where requested, the ESH&Q director will identify technical resources for supporting the site program manager (PgM), project manager (PM), and safety and health manager (SHM) in developing and overseeing the site-specific CBPDD program. He works closely with the SHM on programmatic aspects of the CBDPP and is consulted with on all significant policy and implementation issues.

4.2 Luckey Safety and Health Manager

The SHM is responsible for overseeing CBDPP implementation and, where needed, providing technical support for development of the Luckey remediation project implementing procedures. The SHM will perform hazards assessments for Be operations and identify areas to determine applicable controls. He will participate in developing training; participate in evaluating Be restrictions concerning Be-affected workers; evaluate exposure and workplace monitoring results; and communicate findings to program and project management, ES&H personnel, and the project occupational medical director. He will perform periodic CBDPP programmatic assessments and assist project staff in identifying modifications, as necessary.

4.3 Luckey Remediation Program Manager

The PgM is responsible for all program-level decisions and their implementation. In CBDPP implementation, he is responsible for ensuring integration of Be protection requirements with all other Luckey remediation project requirements. Program personnel have policy and oversight perspective.

4.4 Luckey Remediation Project Manager

The PM is responsible for all project-level implementation and integration. In CBDPP implementation, he is responsible for ensuring integration of Be protection requirements with all other on-site Luckey remediation project requirements. Project personnel have a more practical perspective. Project and programmatic personnel will work collaboratively on policy and implementation issues.

4.5 Luckey Project Occupational Medical Director

The POMD will be responsible for administering the medical surveillance aspects of the CBDPP, including interpretation of all clinical tests involving fitness for work and for recommendations on when it is medically appropriate to remove workers from Be exposure.




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4.6 Site Safety and Health Officer

The site safety and health officer (SSHO) is responsible for all aspects of day-to-day CBDPP implementation. He is responsible for implementation of the BWP program and all attendant functions.

5. PROGRAM REQUIREMENTS

The program requirements discussed below generally follow Be program guidance set forth by the U.S. Department of Energy (DOE) in its Implementation Guide for use with 10 CFR Part 850, Chronic Beryllium Disease Prevention Program (DOE 2001). While 10 CFR Part 850 is not applicable at the Luckey Site, many aspects of DOE’s guidance are pertinent to the Luckey remediation project; therefore, the framework of the following sections generally reflects this guidance.

5.1 Baseline Beryllium Inventory and Activity

The intent of the baseline inventory is to provide a listing of the locations where Be soil contamination is known to exist and the extent of contamination, as it is known, and thereby sets the initial physical scope of the CBDPP. The inventory supports the initial BHA and provides data for a preliminary assessment of locations that require posting, establishing beryllium-regulated areas (BRA), conducting work planning, conducting exposure monitoring, and establishing standard operating procedures. The inventory also identifies activities during which workers may be exposed to Be.

The primary focus of the project is soil remediation. It is known that groundwater and existing buildings at the Luckey Site have been impacted with site-related Be; however, they are not within the project scope. If the project scope changes, the inventory, and consequently the BHA, will be updated appropriately.

Figure 5-1 shows the 10 Luckey Site major work areas where remediation activity is anticipated. A preliminary inventory of surface soil Be concentrations, by work area, is provided in Figure 5-2. The data in Figure 5-2 were gleaned from the existing Luckey surface soil concentration postings.




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Figure 5-1. Luckey Site Plan Showing 10 Major Work Areas.




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Notes: ~ Median is the concentration for which half the concentrations are greater than, and half are less than. The

median is a gauge of the expected concentration.

L = Lagoon (e.g., LA = Lagoon A); T = Trench (e.g., T7 =Trench 7); D1 = Drainage Ditch 1, S1 = Storage Area 1.

Figure 5-2. Preliminary Profile of Site-Related Surface Soil Be Concentrations by Anticipated Work Area.

As Figure 5-2 indicates, Be surface soil concentrations at the Luckey Site exceed background soil concentrations (1.13 mg/kg, or 1.13 ppm) in the 10 proposed work areas; however, contamination is not uniform in these areas. It is known that the underlying soils at some of these locations have Be contamination concentrations exceeding background concentrations as well. In most of the proposed work locations, the estimated median surface soil concentration ranges from 40 to 80 mg/kg to as high as 300 mg/kg in area T3. Additionally, maximum surface soil Be concentrations are significantly higher than the medians in all work areas, which indicates that there may be variation from the median, particularly in localized “hot spots.” The available

0.01

0.10

1.00

10.00

100.00

1,000.00

10,000.00

100,000.00

LA LB LC T7 T6 T3 T4/5 T1/2 D1 S1

Be Soil Concentration m

g/kg

Major Work Areas

Low

~ Median

High




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information suggests that surface soil Be concentrations in the proposed support zone (SZ) are notably lower than in the major work areas. However, some SZ concentrations do exceed background (1.13 mg/kg). Additional characterization of the proposed SZ area will be a priority task to enable Phase II operations.

Additional Be soil concentration data provided by USACE (2013) are summarized in Table 5-1.

Table 5-1. Luckey Site Be Soil Concentrations.

Measure Be Soil Concentration

(mg/kg) Background 1.13 Maximum 13,300 Average 227.96

Cleanup goal 131 Source: Presentation by USACE to Beryllium Health and Safety Committee, Spring 2013 Meeting, Oak Ridge Associated Universities.

This summary, which includes all Be soil measurements (not just surface soils), suggests an average overall Be soil concentration of about 228 mg/kg and a maximum of 13,300 mg/kg.

A preliminary list of project activities that may involve exposure to Be-contaminated soils includes the following:

Monitoring.

Laboratories and testing.

Topographic and utility surveys.

SZ and S1 area preparation and mobilization.

Remediation of contaminated waste and disposition of clean soils, including decontamination of equipment.

Decontamination.

Waste handling, packaging, and transport.

Demobilization.

These activities may involve workers’ contact with soils or other materials potentially affected by site-related Be.

In summary, the initial inventory indicates a potential for worker exposure to Be in all of the anticipated work areas.




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5.2 Occupational Exposure Limits

Two primary worker exposure limits will be used to guide the assessment of Be exposure risk:

Occupational exposure limit, 0.2 µg/m3.

Action level, 0.1 µg/m3.

The form of these numeric limits is an eight-hour time-weighted average (TWA8hr). The USACE has specified these values as appropriate for the Luckey project (USACE 2014a).

Exposure is to be measured by a personal monitor in the worker’s breathing zone, which is defined as “a hemisphere forward of the shoulders, centered on the mouth and nose, with a radius of 6 to 9 inches.” The TWA8hr is the worker’s average airborne exposure in any eight-hour work shift of a 40-hour workweek.

The OEL is interpreted as the TWA8hr concentration that workers should not be exposed to in their breathing zone in the absence of respiratory protection. Exposure measurements exceeding the OEL indicate that exposure controls (engineering and administrative) need to be reassessed for their effectiveness. The AL is interpreted as the TWA8hr concentration signifying that exposure control actions (engineering, administrative, and PPE [i.e., respiratory protection]) need to be implemented to avoid exceeding the OEL. Exposure measurements below the AL will be interpreted as indicating that no additional Be-related exposure controls are necessary; however, all measurements will be evaluated for their magnitude and trend in light of the AL, considering activities and conditions they represent.

5.3 Surface and Bulk Concentration Limits

Two surface concentration limits are applicable to the project:

0.2 µg/100 cm2, which is the removable free-release surface criterion. Removable Be contamination should not exceed this criterion at the point where the item is released to the public.

3 µg/100 cm2, which is the removable housekeeping criterion. The removable Be contamination should not exceed this criterion at the point where the item is released for transfer elsewhere on the Luckey Site.

Bulk sampling of equipment may be useful in some instances to help gauge the extent of contamination and or need for decontamination. If bulk sampling is used for these purposes, the results will be compared to the local background concentration of 1.13 mg/kg.




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The USACE field representative will be notified of the intent to release contaminated equipment at least 30 calendar days before the release date. Portage will not release contaminated equipment with levels exceeding the free-release criterion without USACE approval.

5.4 Initial Beryllium Hazard Assessment

Hazard assessments should include a method of identifying and prioritizing beryllium activities with the greatest exposure risk (DOE 2001). This section uses a simple method for gauging the hazards of beryllium activities based on potential beryllium airborne concentrations, the Luckey work areas, and proposed activities.

An initial BHA is appropriate if the baseline inventory establishes the presence of Be in an area. The initial hazard assessment supports planning and flexibility to determine the appropriate risk-based approach for assessing Be-related hazards. As indicated in Figure 5-2, Be in surface soils at concentrations above background have been identified in the major work zones. Initially, these areas will require posting, establishing Be-regulated areas, conducting work planning, and establishing standard operating procedures.

To gain an initial sense for the potential of observed surface soil concentrations to produce worker exposure, a simple resuspension model was used. The resuspension model derives particulate emission factors (PEFs) for mechanically driven activities for on-site workers (see Appendix A). Parameters in the model include wind speed, surface vegetation, area of work, and activity duration. The model generates “average” PEFs, which, when combined with surface soil data, produce order-of-magnitude range estimates of suspended airborne Be concentrations by the following equation:

∗ 1/ ∗ 1000µg/mg

While the model generates average airborne concentrations, key model parameters (such as surface vegetation fraction set to zero) were biased to produce high PEFs, thereby introducing an error on the side of safety (i.e., they are likely high averages).

Figure 5-3 provides initial estimates of the plausible relationship between soil Be concentrations and airborne Be breathing-zone exposure concentrations associated with remediation activities. The figure helps provide an initial hazard assessment of employee exposures to Be respiratory hazard(s). The airborne constituent would most likely be a solid particulate form of Be oxide. The figure is indicative of average exposure concentrations as would be observed over a full shift where there are variations in emissions; it may not represent all conditions – particularly those involving short-term, high-intensity emissions.




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Figure 5-3. Initial Estimates of Potential Be Exposures to Workers Involved with Project Soil Excavation and Dumping Activities.

Figure 5-3 shows that the modeled relationship between soil Be concentrations and the AL and the OEL are as follows:

AL 0.1 µg/m3air ~500 mg/kgsoil.

OEL 0.2 µg/m3air ~1,000 mg/kgsoil.

The relationships in Figure 5-3 will be used for an initial forecast until actual exposure measurement data are obtained and evaluated. The forecast exposure concentration, however,

1.0E-04

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1.0E-02

1.0E-01

1.0E+00

1.0E+01

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1 10 100 1,000 10,000 100,000

Be Air Concentration, µ

g/m

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Be Soil Concentration, mg/kg

PEF ~ 4E6 m3/kg Wind speed 11 m/sec (high) Construction Activities: Excavation and Dumping

AL 0.1 µg/m3

OEL 0.2 µg/m3~

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,000

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will not be used to specify initial PPE requirements. The initial approach to work areas where exposure data are not available will include respiratory and dermal protection and an aggressive exposure measurement. The conceptual relationships in Figure 5-3 (i.e., Besoil vs. Beairborne) will be calibrated with actual data.

Considering the breadth of site-related Be in soils across the site (referring to Figure 5-2), soil-disturbing activities in any of the anticipated work areas have the potential to expose workers to Be.

The BHA process will be ongoing. Additional BHAs will be generated and integrated into the work planning and control process. The ongoing BHA process is discussed in Section 5.5. The BHA process will feed into the BWP approach to managing exposure (also discussed in Section 5.5). The ongoing BHA process is based on an observational approach using systematic examination of existing data and accumulated knowledge, recognition and evaluation of pending conditions, and comparison to exposure limits.

This overall approach will involve starting with less hazardous areas and activities, and proceed to areas where the work may be more hazardous based on Be exposure potential. In this way, the continuous hazard assessment strategy builds upon experience and supports planning of upcoming work activities. Initial work will include developing the SZ and S1 area and will involve only mild surface disturbances, including clearing, grading, grubbing, leveling, and removal of some shallow hot spot areas. Following SZ and S1 preparation, it is anticipated that soil remediation work will begin in the lagoons (A, B, and C) along the southern edge of the site. Following remediation of the lagoons, work will likely proceed to the trenches and ditch area on the eastern side of the site.

Important factors integrated into the ongoing hazard assessments will include the following:

Known or anticipated soil Be concentrations.

Planned activities and the degree of their intrusiveness and potential to generate particulates.

Weather conditions.

Duration of the planned activity.

Acquired experience with similar activities and conditions.

Using this observational approach, it is expected that over time hazard profiles will be developed that will allow the grouping of activities and soil concentrations according to risk of exposure. Table 5-2 is a conceptual exposure risk profile based on some anticipated activities.




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Table 5-2. Conceptual Exposure Risk Profile. Soil Be

Concentration (mg/kg)

Exposure Risk

Surface Work Small-Scale Excavating

Large-Scale Excavating

Soil Sorting

<100 Low Low Low Low 100 to 500 Low Low Moderate Moderate 500 to 750 Low Moderate Moderate Moderate

750 to 1,000 Low Moderate High High 1,000 to 5,000 Moderate High High High

>5,000 Moderate High Very high Very high Profile to be updated using observational approach and data developed through completed work.

Examples of work activities include but are not limited to:

Surface work includes generally nonintrusive activities where significant particulate generation is not expected (material handling without significant dust generation).

Small-scale excavating includes activities such as local hot-spot removal, earth moving with a compact excavator, and digging post holes (localized, small-scale dust generation).

Large-scale excavating involves significant earth moving using a backhoe or diesel-driven equipment (potential for large-scale dust generation).

Soil sorting involves the loading, sorting, transferring, and mechanical disposition of remediation soils (potential for large-scale dust generation).

Note: The term exposure risk is analogous to the term hazard ranking used by DOE in Tables 5 and 6 in DOE (2001).

The categorical risk assessments of low, moderate, high, and very high will be based on an understanding of the mechanisms of exposure, exposure monitoring data, and experience gained through the observational approach. These exposure profiles will be used to help anticipate engineering controls (e.g., wet methods), administrative controls (e.g., adjustments based on wind speed and direction), monitoring (e.g., real time and personal), and PPE (e.g., air-purifying respirators) requirements. This categorical profiling supports the use of a graded approach to risk management. As discussed in DOE guidance (DOE 2001), a graded approach to minimizing Be exposures based on the level of risk of contracting chronic beryllium disease (CBD) means a process of ensuring that the level of analysis, documentation, and actions used to comply with requirements is commensurate with the risk. In this way, higher-risk activities receive more attention than do lower-risk activities.




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5.5 Beryllium Operations – Beryllium Hazard Assessment and Beryllium Work Permit

Day-to-day CBDPP implementation in the field will be through a BWP process. A BWP will be issued on a task-specific basis after completion of a task-specific BHA. A typical BHA is provided in Appendix B. A typical BWP is provided in Appendix C. The BWP may be modified to meet project needs as the work progresses. As the work and site operations evolve, BHAs and BWPs will be modified as necessary.

The BWP will outline the set of controls and work practices required for work in a BRA or BCA or other circumstance where there is a potential for exposure to exceed the AL or where there is potential for items with surface contamination exceeding release limits (e.g., soil, tools, equipment) to be transferred out of project control.

Figure 5-4 illustrates the operational relationship between the activity-specific BHA and BWP.

As indicated in Figure 5-4, the risk-based operational concept is that all Be work with a risk profile indicating a significant risk (e.g., greater than low risk [Table 5-2]) will be governed by a BWP; each BWP will be supported by a BHA. The preliminary roster of activities that may generate exposure to Be from soils indicated a limited number (Section 5.1). Additionally, there are a finite number of operations (e.g., excavation, loading, sorting) associated with Be emissions. Thus, it is envisioned that as work progresses, there will be a reduced burden associated with administering this approach by reference, updating it, and integrating existing “core” BHAs and BWPs. The conceptual risk profile (Table 5-2) will be modified and vetted with personal sampling results.

It is likely that as the work progresses, the BWP and radiological work permit processes may be integrated since many of the procedural steps will be similar. Radiological work permits are discussed in the Radiation Protection Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (USACE 2016a).




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Figure 5-4. BHA–BWP Operational Relationship




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5.6 Exposure Monitoring

Exposure monitoring is a key component of the CBDPP. The primary exposure monitoring methods for determining worker exposure to Be will be one of the following:

National Institute for Occupational Safety and Health (NIOSH) 7303.

NIOSH 7300 or 7301.

These methods use breathing-zone samples and inductively coupled plasma (ICP) analytical techniques. They differ mainly in the extraction method: NIOSH 7303 is modified to use hydrofluoric acid; NIOSH 7300 uses nitric/perchloric acid ashing; NIOSH 7301 uses aqua regia ashing. These methods provide sufficient sensitivity to assess the OEL and AL discussed previously. Other methods (e.g., preparation, certification, and interlaboratory analysis of workplace air filters spiked with high-fired beryllium oxide) may be considered. Portage will consult with USACE and determine which method(s) best suits the project needs. The American Industrial Hygiene Association (AIHA) laboratory accredited for metals analysis will perform NIOSH method exposure monitoring analysis. The goal is for the on-site laboratory to be AIHA-accredited.

One inherent shortcoming of using these methods is that they are ex post facto indicators of exposure and the effectiveness of exposure controls techniques. The expected turnaround for ICP analysis is approximately 24 to 48 hours, which may exceed operational needs. As work progresses, additional monitoring techniques may be introduced to support the observational and graded approaches and represent near-real-time field decision-making.

Through planned observation, it is probable that a correlation may be developed among measured TSP, Be concentrations on the suspended particulates, and the Be concentration in the soils (see Figure 5-2). Developing this correlation and affirming its reliability as a predictive tool could give near-real-time assessment capability of field conditions and would be useful in situations where exposure conditions vary dynamically due to variations in soil concentrations, atmospheric (wind) conditions, soil remediation and handling methods, and remediation production levels. Figure 5-5 shows a conceptual correlation that could be drawn from pair-wise regression analysis. Data collection and correlation activities (i.e., soil, breathing zone, and TSP), with the objective of developing these correlations, will accompany personal sampling. Portage will combine the use of a TSP-based indicator approach with NIOSH personal sampling techniques and implement this after discussion with and acceptance by USACE.




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Figure 5-5. Conceptual Correlation Between Airborne Be Exposure Concentrations and Real-Time Total Suspended Particulates.

The exposure monitoring techniques discussed above will serve multiple roles, including:

Monitoring field conditions versus AL and OEL.

Supporting development of the exposure risk profile (Figure 5-2), including continued verification of negative exposure assessments (NEAs) and other exposure-related management decisions.

Helping to determine the effectiveness of engineering control measures. Wet methods such as Dry Fog™ are expected to be used widely.

Gauging the impact of administrative controls such as worker proximity and directional relationship to spatial emission sources (e.g., dumping and wind profile).

Assessing the effectiveness of respiratory protection by comparing breathing-zone concentrations with assigned and actual protection factors.

Providing timely feedback on the effectiveness of the engineering and administrative measures in controlling exposures.




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The conceptual approach to using surrogate measurements of related contaminants may be expanded to include measuring radiation types if they are correlated with Be in soils. For example, it is possible that gross alpha measurement could be correlated with Be concentrations on the same collection media. Gross alpha measurement can often be reported after several hours (versus 24 to 48 hours for Be ICP analyses). Portage will work closely with the USACE on any approaches of this nature.

In general, exposure and monitoring approaches will reflect good industrial hygiene practice as discussed in Strategies for Managing Occupational Exposures (AIHA 2006). Exposure monitoring will follow the two-point strategy suggested by DOE (2001) and identified below.

Initial Monitoring. Initial monitoring will occur in areas that may have airborne Be, as indicated by the baseline inventory and initial hazard assessment and relevant BHA(s). These initial exposure data are necessary for determining compliance with the OEL, exposure level status with respect to the AL.

Periodic and Additional Monitoring. There will be periodic and additional exposure monitoring of workers who work in areas where airborne Be concentrations are at or above the AL. Monitoring will be guided by a risk-based, observational, graded approach to determining the frequency of monitoring.

Monitoring will begin during Phase II (see Table 2-1) with off-site background and perimeter air monitoring. The purpose will be to establish response and action levels. Some personal exposure measurements will be made during the background and perimeter monitoring to ensure that the AL is not exceeded; to advance the understanding of the relationships among soil concentrations, work activities, and air concentrations; and to gauge the effectiveness of controls. Additionally, initial monitoring personal samples will be collected during preparation of the SZ and S1 to determine Be exposure levels associated with this nominally intrusive work (e.g., hot-spot removal) and to initiate correlation with TSP measurements.

Periodic and additional monitoring during Phase II will be guided by the risk-based, observational approach. Initial, periodic, and additional exposure monitoring will continue through Phase III, which is the soil remediation, sorting, stockpiling, and shipping portion of the work. Based on anticipated higher Be soil concentrations and emission-producing activities, Phase III initial exposure monitoring will involve more workers and activities than will Phase II. Portage anticipates there will be exposure measurements of most workers expected to have exposure at or approaching the AL—e.g., equipment operators, laborers, and material-handling workers – that is, workers involved in intrusive disturbance of soils approaching 500 mg/kg Be. Exposure data developed during Phase II, particularly hot-spot removal in S1, will be




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incorporated into this assessment. In general, the strategy will be to collect TWA8hr samples from workers until data demonstrate that exposures are below the AL.

Periodic and additional monitoring during Phase II will be guided by the risk-based, observational approach. It is expected that in time, with the accumulation of data and categorization of remediation activities and equipment, “similar exposure groups” (SEGs) will emerge and fewer samples will be necessary to characterize worker exposures and the use of periodic representative sampling in areas for activities where the AL may be challenged. An SEG is a group of workers having the same general exposure profile for the agent(s) being studied because of the similarity and frequency of the tasks they perform, the materials and processes with which they work and the similarity of the way they perform those tasks (AIHA 2006). Based on the limited number of activities, and the similarities in the activities, Portage envisions that developing SEGs and sampling representative members of the SEGs will enhance efficiency. Additionally, Portage envisions that, as work progresses, the real-time surrogate techniques (e.g., TSP) will take on a more prominent role in the exposure monitoring program.

Portage will provide workers with monitoring results through common area posting (e.g., in the lunch room, without personal identifiers) after the results have been reviewed for quality assurance and data consolidation. Portage will individually notify workers with monitoring results that exceed the OEL (0.2 µg/m3, TWA8hr), or whose identity could be compromised by the posting of their results. Additionally, monitoring results, their relationships to operational practices, and worker suggestions of ways to reduce exposures will be discussed frequently at operation/safety meetings. Portage will accommodate worker requests for air monitoring, to the extent practicable. Monitoring results will be examined for trends and correlations to assess the effectiveness of engineering controls and work practices, and to evaluate the effectiveness of respiratory protection. Results indicating exceedance of the AL will draw greater scrutiny, and trends of AL exceedances will be examined so that engineering controls and work practices can be assessed and controls adjusted, as necessary. Workers with exposure measurements exceeding the OEL will be informed through an OEL standard exceedance notification form.

Through the evolution of data collection and interpretation, the assessment of control measures, and consequent refinement of engineering controls and work practices, Portage expects to be able to demonstrate NEAs. An NEA will be demonstrated when, through repeated sampling of conditions that closely resemble the same process, type of material including Be soil concentrations, control methods, work practices, and environmental conditions, a series of 5 to 8 exposure measurements (TWA8hr) of less than 20 percent of the AL (TWA8hr ≤0.02 µg/m3) are completed. Such a trend signifies that the exposure levels associated with processes and controls have stabilized at concentrations below the action level. Monitoring of the NEA SEG may be terminated if exposure levels are consistent and sufficiently low (e.g., TWA8hr ≤0.01 µg/m3). An example of an SEG where an NEA should be readily demonstrated is the on-site laboratory




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where personnel handle small quantities of Be in samples under controlled conditions using local exhaust ventilation engineering controls.

NEAs will be used as the basis to consider a reduction in the number or frequency of personal samples required, and to reduce exposure controls, such as, but not limited to downgrading respiratory protection.

5.6.1 Exposure Categorization

The results of exposure monitoring and estimation will be categorized to guide workplace safety decision-making. Figure 5-6 identifies the categories for exposure monitoring or estimation results. These results will be fed directly into the BHA and BWP operational framework.

Figure 5-6. Exposure Monitoring and Estimation Categorization.




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5.7 Exposure Reduction and Minimization

The objectives of exposure reduction and minimization are to reduce the number of workers exposed to airborne Be in the course of their work at the Luckey Site and minimize their potential for, and actual, exposure to airborne Be. The worker exposure minimization goal for all project sites is as low as practicable considering project objectives. However, if airborne exposure levels to Be meet or exceed the OEL, a review of Be work practices and controls shall be conducted by the SSHO in conjunction with the PM and appropriate modifications made to reduce exposures to below the OEL. This review will include establishing goals for reducing and minimizing exposure.

In addition, showers will be provided, and personnel who have worked in the EZ and CRZ are required to shower before putting their street clothes back on (e.g., at the end of their work shift or when leaving the site). Personnel who have worked in the EZ and CRZ and who are staying on-site are not required to shower when entering the AA or SZ for lunch or other breaks. Personnel will remove shoe covers, outer coveralls, and gloves, and be subject to radiological whole-body frisking before exiting the EZ and CRZ and entering the SZ or AA while wearing their scrubs. Before reentering the work area, workers will redress in new shoe covers, outer overalls, and gloves.

The hierarchy of goals is as follows:

Reducing exposures that exceed OEL.

Reducing exposures that exceed the AL.

Further reducing exposures, as practicability and project goals permit.

The applicable controls would be addressed in task/work activity BWPs.

5.8 Regulated Areas, and Control Zones

Regulated areas will be established to limit the number of individuals exposed and potentially exposed, to provide formality of operations for persons who enter the location, and to limit the spread of contamination to uncontrolled areas. If airborne concentrations of Be in areas at the Luckey Site are measured at or above, or can reasonably be expected to exceed the action level, the SSHO will establish BRAs for those areas to alert workers to the boundaries of such areas and to limit access to regulated areas to approved persons. A BCA is an area accessible to workers where removable surface Be levels have the potential to exceed the background Be soil concentration (1.13 mg/kg [1.13 ppm]) or a removable building surface concentration >0.2 µg/100 cm2.




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There will be three defined control zones. Project activities will be planned so that there is an exclusion zone (EZ), a contamination reduction zone (CRZ), and a support zone (SZ), as shown in Figure 5-7. There will also be a fourth administrative area for personnel and equipment that will not come into contact with site-related Be (essentially all areas outside the SZ).

The EZ will be the area on the site where Be-contaminated material is actively handled, processed, and treated. Activities in the EZ will be governed by BWPs.

The CRZ will be a buffer zone between the SZ and EZ. Site work will be managed so that personnel and equipment working in the EZ must pass through the CRZ and be decontaminated before moving into the SZ.

The SZ will be the outermost area. Within the SZ, normal site activities (e.g., administrative) will be conducted.

A beryllium-regulated area (BRA) – an area where the airborne concentration of Be exceeds, or can reasonably be expected to exceed, the AL – may be established within any of the three areas or a zone may be defined as a BRA for administrative efficiency (e.g., the EZ). Equipment will be tested to assure that free-release criteria for surface contamination are met before release for use by the general public. As noted, the free-release criterion for Be contamination is 0.2 µg/100 cm2, removable. As an example, initially, the EZ will be considered a BCA because the soil concentrations exceed background (Figure 5-2). Within the EZ may be one or more work areas established as BRAs because of the potential for worker exposure concentrations to exceed the AL.

A localized BCA may be established by the SSHO in areas where there is potential that Be contamination exceeding release limits (e.g., soil, tools, equipment) could be transferred out of project control. For example, using the observational approach, isolated segments of the EZ may be identified where only the immediate work areas need to be governed as a BCA.

The CRZ will be set up with decontamination and monitoring equipment and requirements for personnel who have been in the EZ to perform gross decontamination, and remove PPE, before moving into the SZ. Personnel who have worked in the EZ and CRZ and who are staying on-site are not required to shower or remove inner scrubs when entering the AA or SZ for lunch or other breaks. Personnel will remove shoe covers, outer coveralls, and gloves, and be subject to radiological whole-body frisking prior to exiting the EZ and CRZ and entering the SZ or AA while wearing their scrubs. “Clean rooms” (see access control point shower/change trailers in Figure 5-7) will be provided that will allow workers to exit the shower area and change into clean street clothing.

Personnel entering the EZ to perform cleanup activities will, at least initially, and until exposure levels are defined for the activity, wear PPE, including powered air-purifying respirators




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(PAPRs). The PAPR must be high efficiency with an assigned protection factor (BCA) of 1,000. Portage will have documentation provided by the respirator manufacturer that testing of these respirators demonstrated at a level of protection of 1,000 or greater to receive an APF of 1,000. Personal protective equipment provided by Portage will address dermal exposure risk.

As the work progresses and Portage collects more exposure data correlating work activities and soil concentrations, Portage may deviate from using PAPRs to and use other respirators with protection factors sufficient to keep actual exposure concentrations to no greater than 0.02 µg/m3. Note that this is contrary to the variance request (USACE 2014a), which specifies the use of supplied-air respirators in this case. The rationale for this difference is presented in Section 5.10. Portage will seek authorization from the USACE in advance before deviating from the use of PAPRs.

Figure 5-7 illustrates the conceptual approach to establishing three zones and administering contamination control. The physical configuration of the EZ and CRZ will vary with the operations. Key features of the proposed three zone configurations include:

The decontamination (decon) pad and shower/change facilities at the west end of the EZ opening into the CRZ. Workers and equipment will pass through these facilities for decontamination and verification.

Variety of storage, staging, and transportation locations within the CRZ.

Access control points, including shower trailer and change trailers at the west end of the CRZ, and analytical lab access portals.

The SZ, where offices, the break room, and other project support facilities (e.g., offices) are located.

As indicated above, Portage anticipates that its initial work will be preparation of area S1. At the outset, S1 will be in the EZ, and all activities will lock through the CRZ to the SZ. Once S1 is cleared, it will become part of the CRZ. Work will then shift to the lagoons on the south side of the site, and EZ will shift along with the EZ to CRZ portal arrangement. Signage denoting Be work areas and the need to obtain a BWP will be placed appropriately.




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Figure 5-7. General Layout of Control Zones.




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5.9 Hygiene Facilities and Practices

The use of food, beverages, and tobacco products and the application of cosmetics in areas where exposures are at or above the action level will be prohibited. For purposes of CBDPP, this will be obligatory at the entry to the CRZ, even though we do not expect exposures at or above the action level within the CRZ. This area (i.e., S1) will be fenced, which will support administration of this requirement.

Worker dehydration and rehydration are concerns, particularly during the warmer months. During warmer months, heat stress and related conditions may become an issue. This situation is complicated by the personnel restrictions imposed by the EZ, CRZ, SZ protocols. Section 10.8.1 of the Accident Prevention Plan/Site Safety and Health Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (APP/SSHP; USACE 2016b) discusses the management of heat-related issues.

Portage will assess the hydration needs and will likely assess the feasibility of having workers rehydrate within the CRZ or at the edge of the EZ without risk of exposure. Hydration needs will vary with weather and work conditions. Workers entering the CRZ and EZ (note that the CRZ will essentially surround the EZ) will be prevented from exiting through the CRZ to the SZ without passing through the shower trailer and change trailers at the west end of the CRZ. All workers who have worked in the EZ will shower at the completion of the shift and will change into street clothes. This procedure will control the potential for workers leaving the site with site-related Be contamination. Personnel who have worked in the EZ and CRZ and who are staying on-site are not required to shower or remove inner scrubs when entering the AA or SZ for lunch or other breaks. Personnel will remove shoe covers, outer coveralls, and gloves, and be subject to radiological whole-body frisking before they exit the EZ and CRZ and entering the SZ or AA while wearing scrubs. Workers will eat and rest in the break trailer, which can be accessed only from the SZ. The shower trailer, change trailers, and break trailer will be sampled twice weekly initially, at a minimum, for removable Be. The results will be compared to the 0.2 µg/100 cm2

free-release criterion, and affected surfaces cleaned as necessary. As data and the location of remediation dictate (see Table 5-2, Conceptual Risk Profile), this frequency may be adjusted.

The analytical lab will be subject to a similar periodic wipe sampling for removable Be. Likewise, removable Be levels in the office trailers and other SZ structures frequented by personnel will be periodically verified and cleaned, as appropriate.

5.10 Respiratory Protection

Portage will provide respiratory protection (respirators) to all workers potentially exposed to airborne Be at or above the AL (0.1 µg/m3; TWA8hr). The respirators will be available to workers




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seeking additional protection even when they are not exposed at or above the AL. Respiratory protection will be provided and administered in accordance with Occupational Safety and Health Administration (OSHA) 1910.134, as discussed in detail in the APP/SSHP (USACE 2016b).

Use, maintenance, and selection of respirators for protection of the workers from airborne Be will be in accordance with the site-specific respiratory protection procedures established in the APP/SSHP. The respiratory protection required for a specific work task shall be specified in the applicable BWP.

In general, it is anticipated that NIOSH-certified, tight-fitting, full-face, air-purifying respirators (APRs) with P100 filtration cartridges (i.e., high-efficiency particulate air [HEPA] filter) will be suitable for use during most remediation at the Luckey Site. In some work activities, half-face APRs may also be suitable. However, in accordance with USACE direction, work will begin using full-face PAPRs with P100 filtration cartridges.

Portage will rely on exposure measurement data, field experience, and overall respirator program performance to guide respirator selection as work proceeds. Portions of the work will occur during periods when it is warm (summertime highs average in the 80s and relative humidity ~70 percent). It is possible that work will also occur in the wintertime when tight-fitting respirator use can be challenging. The goal will be to provide respiratory protection meeting the exposure control need, while at the same time minimizing worker discomfort and movement restriction. For example, there could be occasions when hood-style PAPRs could achieve the best balance between protection and comfort.

Figure 5-8 shows that relationship between measured exposure concentrations and the corresponding actual worker exposure concentrations inside the respirator using OSHA’s conservative assigned protection factor (APFs) from OSHA 1919.134 for three classes of APF that may be used during remediation activities.

Figure 5-8 illustrates that when using full-face PAPRs, with an OSHA APF of 1000, when the measured concentration outside the respirator equals the OEL (0.2 µg/m3), the implicit worker exposure concentration inside the respirator is 0.0002 µg/m3. In the case of full-face APRs (APF 50), when the measured concentration outside the respirator equals the OEL, the concentration equivalent inside the respirator is 0.004 µg/m3. For a half-face APR (APF 10), when the measured concentration outside the respirator equals the OEL, the concentration equivalent inside the respirator would be on the order of 0.02 µg/m3. Figure 5-2 shows the same values corresponding to the AL (0.1 µg/m3): 0.0001, 0.002, and 0.01 µg/m3 for the full-face PAPR, full-face APR, and half-face APR, respectively.




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0.000001

0.00001

0.0001

0.001

0.01

0.1

1

10

100

1000 100 10 1 0.1 0.01 0.001

Measured Be, µg/m3

Breathing Zone

In th

e R

espi

rato

r B

e, µ

g/m

3 , a

t OS

HA

AP

F

AL

OE

L

0.0002

0.004

0.02

µg/m3 in FF_PAPR

µg/m3 in FF_APR

µg/m3 inHF_APR

Figure 5-8. Relationships Among Measured Air Concentrations, OSHA-Assigned Protection Factors, and Be OEL and AL.




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Portage’s rationale that NIOSH-certified, tight-fitting, full-face APRs with P100 filtration cartridges will be appropriate for most remediation activities stems from the initial BHA (Section 5.4) and the relationships shown in Figure 5-8. The basis for the rationale is as follows:

Recognition of an NEA threshold concentration (with repeated representative measurements) ~0.02 µg/m3 TWA8hr. Note that 0.02 µg/m3 is a factor of 10 less than the OEL and a factor of 5 below the AL. Assuming that an exposure concentration of 0.02 µg/m3 TWA8hr corresponds to acceptable exposure conditions, then:

The nominal TWA equivalent challenge concentration outside a properly fitted full-face APR would be 1 µg/m3 (0.02 µg/m3 × 50)

The soil concentration associated with a TWA challenge concentration outside a properly fitted full-face APR of 1 µg/m3 would be ~4,000 mg/kg, based on preliminary estimates depicted in Figure 5-2 and shown below:

4,000

13∗ , 4 6

3∗

11000

The first work area where ~4,000 mg/kg is expected is Lagoon C (maximum = 4,847; median ~75 µg/kg) from Figure 5-2. Note also that none of the work areas profiled in Figure 5-2 have central tendency surface soil concentrations in the range of 4,000 mg/kg.

Based on the workflow beginning in SZ and S1 (soil maxS1 ~2,850 mg/kg, median ~55 mg/kg) and proceeding through Lagoons A and B (see Figure 5-2), Portage will develop a body of exposure measurements that express actual site conditions, remediation operations, controls (e.g., wet methods), and individual fit factors (FFs). This rationale coincides with the risk-based observational approach discussed in the Section 5.4.

Technical analysis such as that provided above is important and informative from a planning perspective. However, the analysis is based on unverified assumptions that may not be realized when actual field measurements and data correlations are assembled. Portage plans to err on the side of safety and provide workers with more respiratory protection than could be rationalized by this analysis, until sufficient data are collected to change the respiratory protection plan of initially using full-face PAPRs. Portage will confer with USACE on substantive changes to the selection of respiratory protection equipment.

In general, each work area (e.g., SZ, S1, L1) will have one or more BWPs specifying respiratory protection requirements developed before beginning work. Unless there are compelling data, embarkation respiratory protection will be tight-fitting PAPRs with P100 filtration. As the work begins, initial monitoring (Section 5.4) will begin as well; data will be collected, evaluated, and




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correlated with the combination of soil contamination levels, work activities, environmental conditions, and controls. The respiratory protection assessment will lead to appropriate actions for the conditions, as listed in Table 5-3.

Table 5-3. Monitoring and Respiratory Protection Actions According to Be Exposure Levels/Limits.

Be Exposures in Relation to AL/OEL

Remark Action

TWA8hr ≥ OEL Reliant on respirators to ensure workers are not overexposed.

Ensure that APFs and FFs are adequate; verify respirator use procedures; evaluate effectiveness of controls to achieve OEL; and continue monitoring.a

≥ AL TWA8hr ≤ OEL Above the AL Ensure that respirators are in use; verify respirator use procedures; evaluate control improvement; and continue monitoring.

TWA8hr ≤ AL Below the AL Continue monitoring as appropriate. a. Note that the FF is intended as a risk management tool, not a compliance assessment component.

In accordance with 10 CFR 134, a quantitative fit test will be an important part of the Be respiratory protection program. As work progresses and supportive exposure and operational data are obtained, Portage will apply the respirator program protection factor (PPF), which estimates the protection provided by a respirator within a specific respirator program.

The PPF focuses not only on the respirator’s performance (e.g., APR), but also the effectiveness of the complete respirator program. The PPFs are affected by all factors of the program, including respirator selection and maintenance, user training and motivation, work activities, and program administration. The PPFs will derive from repeated successful demonstration of a factor 10 or greater above the nominal APR FFs, as illustrated in Table 5-4.

Table 5-4. Respirator Types, APFs and Target PPFs. Respirator Nominal OSHA APFa Target PPFa

Full-face PAPR (P100) 1,000 10,000 Full-face APR (P100) 50 500 Half-face APR (P100) 25 250 PPFs are affected by all factors of the respirator program, including respirator selection and maintenance, user training and motivation, work activities, and program administration.

a. Discussed in OSHA (2009).




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Application of the target PPFs will take place according to a graded approach and only after appropriate site-specific experience is gained. This experience will include the correlation of soil concentrations with activity-specific processes, measured worker exposure concentrations, and established respiratory protection program practices.

5.11 Other PPE

Protective clothing will be used where particulate forms of Be may contact a worker’s skin, enter openings in the worker’s skin, or contact the worker’s eyes. It is believed that the Be found in the Luckey contaminated soils is beryllium oxide (BeO) and beryllium hydroxide (BeOH). This will be confirmed during the early stages of Phase II. The BeO and BeOH are not particularly water soluble (BeO ~0.2 ppm). Protective clothing and equipment will be employed when airborne concentrations of Be are at or above the action level or when surface contamination levels are measured or presumed to be at or above the 3 μg/100 cm2 housekeeping level. In general, Tyvek overalls, leather gloves, inner nitrile gloves, and safety glasses with side shields used to address other exposure hazards will be the Be-based PPE ensemble for work in the EZ, initially. This general PPE ensemble may be modified as the result of a BHA. Worker heat stress risk and the physical hazards of using Tyvek in the vicinity of moving equipment will be taken into consideration, and opportunities to minimize the use of full-body-coverage PPE will be sought.

Any special guidance for donning/doffing of PPE for operations in EZ and CRZ will be documented and workers will be trained regarding the process. Beryllium-contaminated PPE and clothing will be handled in a manner to prevent the Be from becoming airborne (e.g., it cannot be shaken, air-cleaned, or otherwise disturbed before bagging). Disposable PPE (e.g., Tyvek) will be bagged, labeled, and disposed of as waste. If an external laundry facility is used to clean PPE, the laundry facility will be notified by the SSHO that potentially Be-contaminated PPE is being sent.

5.12 Training

Anyone who enters, or plans on entering, the Luckey Site will receive training on the hazards of Be, commensurate with their risk of exposure. Table 5-5 identifies the Be training profile.

Workers will also receive site-specific chemical hazard identification and control training in accordance with 29 CFR 1910.1200, “Hazard Communication.”

Portage will provide the Be worker training before or at the time of the worker’s initial assignment to the job and at least every two years thereafter. Mandatory Be Worker Training will be required annually. Portage will provide retraining whenever there is reason to believe that Be workers lack the proficiency, knowledge, or understanding to work safely in the presence of Be. Signed training rosters will be kept as documentation of attendance.




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Table 5-5. Beryllium Training Program Profile.

Title Target

Audience Topics

Medium (~ duration)

Awareness Training 1

Ad hoc (transient) visitors who infrequently enter only the AA and SZ and do not enter the CRZ or EZ (escorted access only)

Scope of Luckey Site and work Hazards of Be Access limitations ‒ signage Q&A

Verbal (10 minutes)

Regular visitors who enter only the AA and do not enter the SZ, CRZ or EZ Vendors and service personnel who enter only the AA, do not enter the SZ, CRZ or EZ, and perform hands-on work

Awareness Training 2

Regular visitors who enter the SZ and do not enter the CRZ or EZ

Scope of Luckey Site and work Roles and responsibilities Hazards of Be (CBD and

sensitization) CBDPP – main topics Be-LPT testing and medical

clearance Exposure limits and controls Access limitations Q&A

PowerPoint presentation

Handout (60 minutes) Vendors and service

personnel who enter the SZ, do not enter the CRZ or EZ, and perform hands-on work

Be Worker Training

All full-time Luckey Site workers, including:

o Workers who enter the SZ, CRZ, or EZ.

o Laboratory workers o Workers who work

only in the AA

Scope of Luckey Site and work Hazards of Be (CBD and

sensitization) Be-LPT testing Medical program CBDPP – in detail with emphasis on:

Monitoring & exposure limits Exposure controls

Operations and procedures BHA & BWP Signs, labels, warnings

PowerPoint presentation

Handouts Videos Hands-on PPE

and stepoff pad training

(3–4 hours) Regular visitors who enter the CRZ, or EZ Vendors and service personnel who enter the CRZ or EZ to perform hands-on work




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Table 5-5. (continued).

Title Target

Audience Topics

Medium (~ duration)

Offsite emergency responders

PPE use (why, when, where, how)

EZ, CRZ, SZ – movement through

Waste handling Worker rights and

responsibilities Q&A

Special Training

Various Any re-emphasis, program development, or related topic as needed

Tailgate or ad hoc circle-up meeting

Additional Training Notes Awareness Training 1 ‒ Visitors and occasional vendors who are beryllium-associated workers whose duties and activities at the Luckey Site are not likely to expose them to site-related airborne beryllium.

1. Ad hoc (transient visitors) – AA/SZ (delivery/pickup personnel; mail, water, supplies, fuel, waste containers)

2. Regular visitors – AA (not full time or daily; hands off; note-taking and observation, and office type work; audits, inspections, USACE and Portage team personnel, regulators)

3. Vendors and service personnel – AA (hands on; copy repair, phone/internet repair, electrical substation maintenance, pest control, PPE vendor, HVAC servicing)

Awareness Training 2 ‒ Regular visitors, vendors, and service personnel who work in the support zone full time or daily in the support zone and whose potential for exposure to site-related airborne beryllium above the action level is very small.

1. Regular visitors – SZ (not full time or daily; hands off; note-taking and observation; audits, inspections, USACE and Portage team personnel, regulators)

2. Vendors and service personnel – SZ (hands on; calibration of truck scale, pest control, HVAC servicing)

Be Worker Training – Beryllium workers, visitors, vendors, and service personnel who might reasonably be expected to be exposed to site-related airborne beryllium at the action level, including individuals who work full time or daily in the support zone.

1. Full-time site workers – AA/SZ/CRZ/EZ 2. Regular visitors – CRZ/EZ (not full time or daily; hands off; note-taking and observation; audits,

inspections, USACE and Portage team personnel, regulators) 3. Vendors and service personnel – CRZ/EZ (hands on; water treatment system repair/

troubleshooting, off-site mechanics) 4. Off-site emergency responders




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5.13 Housekeeping

Controlling Be emissions at the source is the most effective way to control potential secondary exposures. Portage will assess the effectiveness of “housekeeping” by using a standard of visibly clean. Additionally, Portage will use the common housekeeping benchmark of 3 µg/100 cm2 within the EZ to gauge the need for additional precautionary measures and housekeeping when there is potential for the buildup of settled dust or soil material, coupled with the potential for worker exposure from inhalation of the resuspended material. Examples could include equipment cabs and/or the soil sorter control room. There will also be situations where the 3 µg/100 cm2 gauge cannot be practicably relied upon due to the nature of the Luckey work; for example, caked or thick accumulation of soils on equipment such as excavation equipment and the soils sorter. In instances like these, coarse scale decontamination, probably with water, will be required before samples are collected for analysis. Within the CRZ/SZ, Portage will use the free-release criterion of 0.2 µg/100 cm2 as a housekeeping gauge.

Portage will implement procedures and work practices to control and minimize the tracking of visible dust that contains Be outside the EZ where the dust was generated. Portage will implement project-wide engineering controls using water cannons, water trucks, and Dry FogTM dust-suppression systems to control emissions at the source, to the extent practicable. In addition, Portage will implement an administrative program that emphasizes good housekeeping to reduce the potential for secondary exposure of workers, contractors, and visitors. Site workers will use wet cleaning methods or a vacuum cleaner equipped with HEPA filters to manage dust accumulations due to the remediation process. Additionally, project personnel will perform routine surface-wipe surveys of work areas to assess contamination levels and ensure that work areas are below the project action levels.

5.14 Beryllium Emergency

Portage does not envision Be-related emergencies occurring during remediation. However, it is possible that waste handling and transportation could involve incidents requiring emergency response and notifications. Portage will have on-site individuals who are 40-hour-HAZWOPER-trained and can respond to incidents on or near the Luckey Site. The on-site PM will be the incident commander.

Emergency responders (e.g., local agencies responding to a medical incident) will be aware of the hazards of Be exposure and contamination transfer and will implement procedures to control the hazards, as described in Section 10.14 of the APP/SSHP (USACE 2016b).




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5.15 Medical Surveillance

Note: This section has been prepared in consultation and with concurrence of our project medical provider, WorkCare.

The Be medical surveillance program is intended to achieve several goals:

Identify workers at higher risk from the adverse effects of Be exposure.

Prevent Be-induced disease by linking health outcomes to Be-related tasks.

Provide early detection of Be-induced disease, which allows for early treatment.

Our project medical provider, WorkCare, will be contracted to manage the Be medical surveillance program for the Luckey project under the direction of the ESH&Q director. WorkCare is licensed in all 50 states and has more than 3,500 domestic clinic providers. WorkCare will assign a POMD.

The following outlines the minimum requirements of the Be medical surveillance program:

The POMD is responsible for administering the medical surveillance program.

The POMD must be a licensed physician who is familiar with the health effects of Be exposure and will provide oversight for all medical examination protocols and records.

A list of Be-associated workers who may be eligible for protective measures under this program will be maintained by the POMD and SSHO.

o The list will be adjusted at regular intervals based on periodic evaluations for Be-associated workers.

The POMD will be provided with the information needed to operate and administer the medical surveillance program, including the following:

o List of Be-associated workers.

o Baseline inventory.

o Hazard assessment and exposure monitoring data.

o Identity and nature of activities or operations on the site that are covered under this CBDPP.

o Related duties of Be-associated workers.

o A copy of this CBDPP.

o A description of the worker’s duties as they pertain to Be exposure.




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o Records of the worker’s Be exposure and equipment used (or to be used) by the worker in the past, present, or future.

The Be medical surveillance program will include baseline periodic medical evaluations.

The baseline medical evaluation will include the following:

A detailed medical and work history with emphasis on past, present, and anticipated future exposure to Be.

A respiratory symptoms questionnaire.

A physical examination with special emphasis on the respiratory system, skin, and eyes.

A Be-LPT.

Negative Be-LPT results are required for all Be workers prior to entering the site. Any other tests deemed appropriate by the examining physician for evaluating Be-related

health effects.

The periodic (i.e., annual) medical evaluation will include the following:

A detailed medical and work history with emphasis on past, present, and anticipated future exposure to Be.

A respiratory symptoms questionnaire.

A physical examination with emphasis on the respiratory system.

A Be-LPT.

Any other medical evaluations deemed appropriate by the examining physician for evaluating Be-related health effects.

In consultation with the SSHO and H&S manager, the POMD will make fitness-for-duty determinations, including aspects related to potential Be exposure. Privacy and security of personal medical records will be maintained in accordance with the Health Insurance Portability and Accountability Act and related medical and privacy requirements by the POMD.

5.16 Medical Removal

The POMD shall provide a written recommendation when it is medically appropriate to remove a worker from Be exposure. A removal recommendation of the POMD must be based on one or more positive Be-LPT results, the POMD’s diagnosis of CBD, or any other symptoms/signs/ testing that the POMD deems medically appropriate to warrant removing the worker.




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When the POMD determines that a Be-affected worker should be temporarily or permanently removed from exposure to Be, the POMD must advise the Be-affected worker of the determination that medical removal is necessary to protect the worker’s health. The POMD shall provide the Be-affected worker with information about this program document (CBDPP) and the risks of continued exposure to Be.

The Be-affected worker will have the opportunity to obtain answers to any questions concerning medical removal. The POMD shall obtain the Be-affected worker’s signature acknowledging that the worker has been advised to accept medical removal from Be exposure as provided in this section, and has been provided with the information specified in this paragraph on the effects of removal and the risks of continued exposure to Be.

5.16.1 Temporary Removal Pending Final Medical Determination

A Be-affected worker will be offered temporary medical removal from exposure to Be on each occasion that the POMD recommends, in a written determination, that the worker should be temporarily removed from such exposure pending a final medical determination on whether the worker should be removed permanently.

5.16.2 Permanent Medical Removal

If the POMD recommends permanent medical removal for a Be-affected worker, then the employee’s company policies (i.e., Portage’s or Portage subcontractor’s) regarding employment and compensation will be followed for that removal.

5.16.3 Return to Work after Medical Removal

Following permanent medical removal of a Be-affected worker, Portage or its subcontractor(s) will not return the worker to his or her former job status unless the POMD first concludes, in a written determination, that continued medical removal is no longer necessary to protect the worker’s health.

If the POMD determines that continued exposure to Be will not pose an increased risk to the Be-affected worker’s health, and medical removal is an inappropriate remedy under the circumstances, then the POMD must fully discuss these matters with the worker.

Following the discussion between the POMD and the Be-affected worker, the POMD, in a written determination, may authorize Portage to return the worker to his or her former job status. Thereafter, the returned Be-affected worker must continue to be provided with medical surveillance under the criteria outlined in this program document (CBDPP).




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5.17 Counseling

Counseling will be provided to Be-affected workers by both the POMD and the employee’s designated Human Resources representative. Counseling from the POMD should be at the time of confirmed diagnosis of sensitization, CBD, or medical removal.

Each participating company’s Human Resources representatives will provide counseling to Be-affected workers on the following subjects:

Why has the worker become Be affected?

What is going on in the worker’s body?

Medical/diagnosis process/treatment.

Percentage of people who go from being Be sensitized to contracting CBD.

Risk of continuing Be exposure.

The purpose of the action and control levels established in this CBDPP.

The POMD opinion letter to the contractor.

Portage Human Resources representatives will provide counseling to Be-affected workers on the following subjects:

Career counseling.

Applicable worker’s compensation laws and regulations.

Long-term, short-term, and Social Security disability benefits.

5.18 Postings and Labeling

5.18.1 Posting of Beryllium Areas

The SSHO is responsible for ensuring placement of the postings. Initially, those areas designated as EZ or CRZ will be posted with a “Beryllium Controlled Area” sign or one with equivalent information. In addition, on a precautionary basis, postings will be initially made at the entrance to the Luckey Site and entrance to the SZ until the extent of the areas exhibiting site Be contamination are delineated.

Signs will be posted as follows:

At each access/entry point so that they are clearly visible.

To ropes/chains and/or posts as necessary to control access.




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In a manner to minimize inadvertent removal of the sign by environmental conditions.

In a manner so that they remain visible if changes in configuration should occur, such as opening/closing doors.

Signs will be large enough to be seen from a distance. The configuration of the zones and areas will be considered in establishing the distance from which the sign must be readable. Examples of signage to be used at the Luckey Site are illustrated in Figure 5-9.

5.18.2 Labeling of Material and Surfaces

Materials and surfaces contaminated or potentially contaminated with Be will be labeled in the following manner:

Items removed from an EZ or CRZ without decontamination verification shall be labeled as potentially Be-contaminated.

Potential Beryllium Contamination Caution labels will be used to identify equipment or items used in a EZ or CRZ that are potentially contaminated. This includes items such as respirators that are being transferred to the on-site laundry facility or to contracted laundry facilities off-site. Beryllium samples controlled under a chain-of-custody do not need to be labeled.

Warning labels will be affixed to all containers of Be (including waste shipping containers used to transport Be waste), Be compounds, or Be-contaminated clothing, equipment, waste, scrap, or debris.

5.19 Recordkeeping and Use of Information

In accordance with project quality control and recordkeeping procedures, Portage will establish and maintain accurate, confidential records of all Be inventory information, hazard assessments, exposure measurements, and exposure controls.




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Figure 5-9. Examples of Signs to be Used at the Luckey Site.




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6. REFERENCES

10 CFR 850, “Chronic Beryllium Disease Prevention Program,” Code of Federal Regulations.

10 CFR 851, “Worker Safety and Health Program,” Code of Federal Regulations.

29 CFR 1910, “Occupational Safety and Health Standards,” Code of Federal Regulations.

American Industrial Hygiene Association, 2006, A Strategy for Managing Occupational Exposures, Third Edition, AIHA, Fairfax, Virginia.

DOE, 2001, Implementation Guide for use with 10 CFR Part 850, Chronic Beryllium Disease Prevention Program, DOE G 440.1-7A, U.S. Department of Energy.

EPA, 2002, Risk Assessment Guidance for Superfund, Supplemental Guidance for Developing Soil Screening Levels for Superfund Sites, OSWER 9355.4-24, U.S. Environmental Protection Agency, Washington, D.C.

NIOSH 7300, “Elements by ICP (Nitric/Perchloric Acid Ashing),” Method 7300, NIOSH Manual of Analytical Methods, Fourth Edition, National Institute for Occupational Safety and Health.

NIOSH 7301, “Elements by ICP (Aqua Regia Ashing),” Method 7301, NIOSH Manual of Analytical Methods, Fourth Edition, National Institute for Occupational Safety and Health.

OSHA 29 CFR 1910.134, “Respiratory Protective Equipment,” Code of Federal Regulations, Occupational Safety and Health Administration.

OSHA, 2009, “Assigned Protection Factors for the Revised Respiratory Protection Standard,” OSHA 3352-02 2009.

USACE, 2016a, Radiation Protection Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5513, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

USACE, 2016b, Accident Prevention Plan/Site Safety and Health Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5501, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.




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USACE, 2014a, September 12, 2014, Memorandum Thru Commander, U.S. Army Corps of Engineers, Lakes and Rivers Division, to Commander, U.S. Army Corps of Engineers, Buffalo District, Subject Variance Request, EM 385-101, Section 06.A.01, Exposure Standards, included in Appendix B of the Scope of Work.

USACE, 2014b, EM 385-1-1, Safety and Health Requirements Manual, U.S. Army Corps of Engineers, Department of the Army, November 30, 2014.

USACE, 2013, Presentation by USACE to Beryllium Health and Safety Committee, Spring 2013 Meeting, Oak Ridge Associated Universities.




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APPENDIX A Development of Particulate Emission Factor for Resuspension during Soil Disturbance Activities




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This appendix provides information used to develop the particulate emission factor (PEF) for resuspension during soil disturbance activities. The PEF is widely used in planning and scoping remediation activities (e.g., Risk Assessment Guidance for Superfund, Supplemental Guidance for Developing Soil Screening Levels for Superfund Sites [EPA 2002]).

The PEF was computed using the online air transport calculator from Oak Ridge National Laboratory Risk Assessment Information Center’s PEFsc using the “Mechanically driven by other than unpaved road traffic (at center of source) for on-site receptor (Subchronic)” model; (http://rais.ornl.gov/cgi-bin/prg/air_transport_pef#other). Figure A-1 identifies the parameters used to compute the PEF.

Figure A-1. PEF calculation parameters.




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Table A-1 summarizes the main input variables and provides a rationale for their selection.

Table A-1. PEF Calculation Parameters. Parameters Value Remark

EDcw (exposure duration – construction worker) yr

0.5 year High-end estimate of work in one location

ETcw (exposure time – construction worker) hr/day

10 hr/day Estimated work day

Um (mean annual wind speed) m/s 11 m/second High-end estimate from Akron Canton meteorology data

V (fraction of vegetative cover) 0 percent Bare soil Days (number of days per week construction occurs)

4 days/week Planned activity period

Frequency (weeks per year construction occurs)

26 weeks/yr Match EDcw

As (acres) 0.5 acre Small work area give higher concentration

These variables generate a PEF of 4.607919 E6 m3/kg.

Note that in the equation below, PEF is in the denominator. Thus, estimated air concentration is inversely proportional to PEF (small PEF ~ larger air concentration).

Equation A-1 – Soil to air concentration via PEF

3 ∗ 1/

3∗ 1000

Rounding PEF down to ~ 4E6 m3/kg and assuming a soil concentration of 1,000 mg/kg:

0.23

1000

∗ 1/ 400000 3

∗ 1000




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APPENDIX B Task-Specific Beryllium Hazard Assessment Form

(Preliminary)




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LUCKEY PROJECT BERYLLIUM HAZARD ASSESSMENT FORM

Luckey Job-Specific Beryllium Work Permit (BWP) No.:

Rev. No.:

BE Baseline Inventory ID:

Start Date: Expiration Date:

Location: Area: ____________________________________________________________________________ Building: Other: _____________________

Site Condition Walk-down Date: Site Condition Walk-down: Author: Reviewer: Authorization to work:




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1.0 Work Activity Description

Task Description:

Describe dust-generating activities Intrusive Work:

Non-Intrusive Work:

Other (e.g., Soil Sorting) Estimated number of potentially exposed employees involved in the activity

Estimated time and duration of the work

Is the work recurring?

Other comments or pertinent data

2.0 Location Description and Relevant Data Reference and summarize characterization data (max., min., avg. concentrations)

Existing baseline hazard assessment data (e.g., Industrial Hygiene Plan, IH Baseline Hazard Assessment, Health and Safety Plan)




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Employee reports of potential exposure sources (past and current)

Reference documentation from previous work

Location status. Reference characterization data if available

Other comment or pertinent data

Figure Attached Yes No

3.0 Hazard Description Known exposure sources/types

Suspected exposure sources/types

Airborne: Surface: Other:

Activities that have the potential to cause exposure

Dermal: Airborne: Other:

Employee exposure monitoring and area sampling data collected during similar work

Conditions that have the potential to increase the risk of




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exposure (e.g., weather) Existing BHA used? Y N

Special conditions/hazards (e.g., confined space, falls, uncharacterized material, remote location)


4.0 Controls Engineering Controls

Access Controls Training & Medical Surveillance/Trend

Respiratory Protection

Protective Clothing

Posting Requirements

Decontamination of Items

Decontamination of Personnel

Waste Labeling/Handling

Equipment Labeling/Handling





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5.0 IH Sampling Contact Name(s): Additional surface characterization sampling

Bulk samples: Wipe samples: Other:

Air sampling Personal breathing zone: Area/Perimeter:

Additional Figure Showing Location of Be Work




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APPENDIX C Task-Specific Beryllium Work Permit

(Preliminary)




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LUCKEY TASK-SPECIFIC BERYLLIUM WORK PERMIT (BWP) 1. Luckey Task-Specific Beryllium Work Permit (BWP) No.: Rev. No.:

2. Beryllium Hazard Assessment (BHA):

3. Date Effective: 4. Date Expires: 5a) Prime Contractor 5b) Sub-Contractor

6. Location: Area: Building: Room: Other:

7. Work Activity Description:

ENTRY REQUIREMENTS (A) Only employees who have received and are current on training, and medically cleared by the Project Occupational Medical Director

and verified by management to perform beryllium activities are qualified to work in a BCA or BRA. (B) A review and update/revision of the BWP shall be conducted when changes occur in the field that could impact the validity of the Activity

Hazard Analysis (or equivalent) and/or the Hazard Assessment the BWP supports. (C) Support personnel who are required to handle or may be required to handle potentially contaminated material (e.g., undress

assistance, upset condition response, and reaching across the boundary to receive items/material) shall be Beryllium Worker trained and medically cleared to perform beryllium activities.

BERYLLIUM CONTROL INFORMATION

8. Area Posting: Beryllium Controlled Area Other

Special Instructions:

9. Access Control EZ Step Off Fencing Rope Specify Other:


10. Engineering Controls: Dry Fog General Ventilation Wet Method Fixative

HEPA Vac Area Prior to Working Containment/Enclosure None


11. Respiratory Protection: Full-Face APR or Half-Face APR PAPR

None Cartridge Type:


12. Protective Clothing: Work Gloves; Type: _______ Impermeable Gloves Shoe Covers

Disposable Booties Disposable Coveralls Hood Tape Openings


13. Air Sampling: Breathing Zone Personal Area Perimeter


14. Surface Sampling: Surface Wipe Bulk


15. Decontamination of Items: Wet-Wipe HEPA VAC


16. Decontamination of Personnel: HEPA Vac Wet-Wipe Undress Assistance Hand and Face Wash

Shower


17. Waste Labeling/Handling: Contaminated with Beryllium Bag/Wrap Double Bag

Designated Container


18. Equipment Labeling/Handling: Double Bag Bag/Wrap Special




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Instructions:

19. Additional Information:

APPROVALS

20. Prepared: Date/Time:

21. Reviewed: Date/Time:

22. Approval : Date/Time:




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BWP Number _________________________________________________________________

I understand the hazards of, and controls for, beryllium exposure.

Name (Printed) Signature Date

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