Even when measurable exposures are less than the AL, steps shall be taken to reduce exposures further, if practical, although a formal program is not required. The controls in this document constitute the LLNL program to minimize worker exposure to beryllium.

3.3 Standards

The DOE, in 10 CFR 850, has established standards for beryllium airborne exposure and surface contamination allowable in DOE facilities. Additional standards are promulgated by OSHA, in 29 CFR 1910.1000, and are applicable to LLNL as Work Smart Standards. These exposure standards are listed in Table 2. The guidance provided in Appendix C is to be used for determining compliance with the standards. Sampling shall be conducted to ensure statistical confidence of at least 95% in meeting the standards.

Table 2. Occupational exposure, housekeeping, and release standards.

Standard

Limit

Source

Personnel Exposure

Action level (8-hour, time-weighted average concentration)

0.2 µg Be/m3a

10 CFR 850.23

Permissible exposure limit (PEL) (8-hour, time-weighted average concentration)

2 µg Be/m3a

10 CFR 850.22, 29 CFR 1910.1000

PEL (acceptable ceiling concentration)

5 µg Be/m3b

29 CFR 1910.1000

PEL (peak above acceptable ceiling)

25 µg Be/m3, for no more than 30 minutesb

Surface Contamination

(A) Housekeeping

Maximum removable surface contamination for beryllium work areas

3 µg Be/100 cm2c, d

10 CFR 850.30

(B) Release Criteria

Maximum removable surface contamination for release to non-beryllium work areas

0.2 µg Be/100 cm2 d, e

10 CFR 850.31

a Measured without regard to the use of respiratory protection.

b For soluble compounds not subject to 10 CFR 850.

c At the end of operational periods.

d These are the units prescribed in 10 CFR 850; when expressed in the units typically used in analytical laboratory reports, these values are 0.03 µg Be/cm2 and 0.002 µg Be/cm2, respectively.

e When there are visible accumulations of dust on accessible surfaces (for example, if a piece of equipment has been stored outdoors for an extended period of time), the release criteria are based on a bulk sample of the dust, and the applicable standard is the concentration of beryllium in the soil at the point of release [i.e., micrograms of beryllium per gram of soil (m g Be/g)].

Action Level: An AL of 0.2 µg Be/m3 (8-hour, time-weighted average in air) has been established in 10 CFR 850.23. A goal of the LLNL CBDPP is to keep exposures as far below this level as practical.

Permissible Exposure Limit: The OSHA permissible exposure limit (PEL) of 2 µg Be/m3 (8-hour, time-weighted average in air) has been adopted by the DOE in 10 CFR 850, and no worker shall be exposed at levels exceeding this limit. Any change in the OSHA PEL is automatically adopted in 10 CFR 850 and is also applicable to LLNL.

OSHA also established a maximum ceiling limit of 5 µg Be/m3 and a peak (which is greater than the ceiling limit) of 25 µg Be/m3. These values are applicable to LLNL, but only for beryllium compounds (e.g., soluble beryllium compounds) that are not subject to 10 CFR 850.

Housekeeping Standard: Beryllium work areas shall be kept as clean as the nature of the work allows. However, during nonoperational periods, residual contamination shall be verified to be no greater than 3 µg Be/100 cm2 (this is the housekeeping standard). If contamination is found to be greater than this limit, then the area in question shall be recleaned and reevaluated to determine compliance with the housekeeping standard. See Section 3.8 for actions necessary for compliance with this standard.

Release Standard for Contaminated Materials: Material contaminated with beryllium may be released to non-beryllium work areas, provided that the material is first cleaned, the beryllium level is verified to be less than 0.2 µg Be/100 cm2, and the material is labeled as required in Section 3.5.8 (Figure 3). The term "contaminated" means having removable surface contamination that is in excess of whichever of the following is higher:

* 0.2 µg Be/100 cm2.

* The concentration of beryllium in the soil at the point of release (when there is visible accumulation of debris).

Environmental Standards: The U.S. Environmental Protection Agency (EPA) has established the following limits:

* Maximum permissible air concentration level, which is 0.01 µg Be/m3 averaged over a 30-day period (in 40 CFR 61.32, Emission Standard).

* Maximum contaminant level for beryllium in drinking water, which is 4 µg Be/L (in 40 CFR 141.62).

However, the EPA has not yet set water quality criteria for beryllium in ambient water (40 CFR 131.38). The regulations specify that individual National Pollutant Discharge Elimination System permits shall address beryllium under the EPA's narrative criteria for toxics. In addition, LLNL has established reuse criteria for soils generated and reused at LLNL (see Document 33.3, "Management of Soils and Debris," in the ES

3.4 Engineering Controls

This section specifies the engineering controls applicable to the handling of beryllium and its compounds. Maintenance of systems used to control beryllium are subject to all the controls established in this document to minimize worker exposure to beryllium and to minimize opportunities for exposure.

Section 3.7, Facilities and Equipment, provides additional requirements for facility design and layout.

3.4.1 Exhaust Ventilation

All repetitive indoor operations that may generate airborne beryllium equaling or exceeding the AL shall be enclosed and shall be equipped with local exhaust ventilation. Exhaust systems used to control beryllium work shall comply with Document 12.2 and 12.4. The ES

3.4.2 HEPA Filtration

Required HEPA filter exhaust systems shall comply with Document 12.5 which implements "HEPA Filter and In-place Leak Testing Standard," (UCRL-AR-133354, Rev. 2). Required HEPA filter systems shall be visually inspected semiannually and be evaluated for performance annually.

Vacuums used for cleaning up beryllium contamination shall be equipped with HEPA filters. Such vacuums shall be labeled (see Section 3.5.8) and controlled and shall not be used for non-hazardous materials.

3.5 Administrative Controls

This section describes the administrative controls applicable to the handling of beryllium and its compounds.

3.5.1 Population at Risk

The population at risk for beryllium sensitization or CBD is referred to as beryllium-associated workers. This population includes persons currently working with beryllium and potentially exposed to airborne beryllium (i.e., beryllium workers, defined below), persons formerly or currently potentially exposed, and individuals with signs or symptoms of beryllium sensitization or CBD.

A beryllium worker is a current worker who is regularly employed in an activity that can expose him or her to airborne beryllium. (Although not defined in 10 CFR 850, the term "regular" is defined in this document to mean "customary, usual, or normal." The intent of the definition is to include individuals assigned to work with beryllium or in beryllium work areas, not individuals who are present in a beryllium work area transiently or who work with beryllium irregularly or intermittently.) Although no exposure threshold is specified in 10 CFR 850, examples of situations that would classify someone as a beryllium worker include the following:

* Regularly working with beryllium in a process or operation that can produce airborne beryllium.

* Regularly working at tasks (regardless of the level of airborne concentration) such as:

o Machining, milling, polishing, grinding, drilling, or welding beryllium.

o Repairing or servicing equipment that has removable beryllium contamination exceeding release levels.

o Maintenance of systems used to contain and control beryllium.

o Working in an area where dispersible beryllium exceeding release levels is present.

o Working with or handling contaminated items.

o Other operations that disturb or abrade beryllium in a way that results in contamination exceeding release levels.

3.5.2 Visitors and Other Ancillary Personnel

The Responsible Individual shall review and approve visitors and other ancillary personnel in beryllium work areas and shall inform such personnel of the hazards and controls of the area. Visitors to beryllium work areas should be discouraged unless essential to the mission in question.

3.5.3 Hazard Assessments

All beryllium operations, unless exempt from this document, shall be reviewed with an Integration Work Sheet (IWS) as described in Document 2.2. Work with beryllium shall not be considered as work commonly performed by the public. Such review shall take into consideration the following:

* The amount and nature of work to be performed, including preparation, maintenance, and cleanup.

* The amount of beryllium and chemical form to be used.

* The potential for aerosol production, including emergency response for spills and unplanned events.

* Historical air, swipe, or other data for similar operations.

* The number of workers involved.

* The number of co-located workers not involved in the work.

The hazard assessment that is performed as part of the IWS evaluation shall determine the controls (i.e., engineering, administrative, and PPE) necessary to keep airborne exposures below the AL and as low as practical. If there is a potential for airborne exposure to beryllium, then the Responsible Individual and the cognizant ES

Welding or torch-cutting beryllium indoors, outdoors, or in a confined space is a presumptive task that may result in high exposures to airborne beryllium. Workers shall use local exhaust ventilation and airline respirators until personal air sampling conducted under worst-case conditions shows that exposures are within acceptable levels. Co-located workers who are not part of the operation shall be similarly protected.

In addition, all workers involved in a beryllium operation shall be evaluated to determine if they are beryllium workers. The operation shall be evaluated to determine if a regulated area is required; see Section 3.5.7 for specifics.

The basic principle for mitigating beryllium hazards is to establish controls to minimize both the number of workers exposed and the opportunities for exposure and to keep the exposure potential as low as practical.

3.5.4 Beryllium Inventories