* Document 10.2, "LLNL Health Hazard Communication Program."

* Document 11.1, "Personal Protective Equipment."

* Document 12.2, "Ventilation."

* Document 12.4, "Work Enclosures and Local Exhaust Systems for Toxic and Radioactive Materials."

* Document 12.5, "High-Efficiency Particulate Air (HEPA) Filter System Design for LLNL Applications."

* Document 21.2, "Onsite Hazardous Material Packaging and Transportation Safety Manual."

* Document 30.1, "Waste Minimization and Pollution Prevention."

* Document 32.1, "Managing Discharges to Water and Land."

* Document 32.4, 'Discharges to the Sanitary Sewer System."

* Document 36.1, "Hazardous, Radioactive, and Biological Waste Management Requirements."

3.1.1 DOE/NNSA Review of Beryllium Work Out of the Scope of the CBDPP

Appendix B of LLNL Chronic Beryllium Disease Prevention Program (UCRL-AR-144636 Rev. 1.1) lists specific approved operations. New work that is outside the operations listed in the CBDPP must meet the requirements of the ES

Under 10 CFR 850, DOE/NNSA Oakland is permitted a 90-day review period, except in cases of emergency response. To allow for an appropriate period of time for review and approval the ES

3.2 Exposure Reduction and Minimization Program

When exposures as determined without accounting for respiratory protection equal or exceed the AL (see Section 3.3), a formal, operation-specific exposure reduction and minimization program shall be established. This operation-specific program, which is incorporated into the Laboratory's CBDPP and then approved by the DOE, shall include the following:

* Annual goals for exposure reduction and minimization.

* The rationale for the goals.

* Strategies for meeting the goals.

* Actions to be taken to achieve the goals.

* A means for tracking progress towards meeting the goals and demonstrating that the goals have been met.

When a formal exposure reduction and minimization program is required, the authorizing organization is responsible for developing the program in concert with the Hazards Control and Health Services Departments.

The following sections of this document shall be addressed as part of a formal exposure reduction and minimization program:

* Engineering controls (Section 3.4, "Engineering Controls").

* Periodic monitoring (Section 3.5.5, "Exposure Monitoring").

* Regulated areas (Section 3.5.7, "Beryllium Work Areas and Regulated Beryllium Work Areas").

* Warning signs (Section 3.5.8, "Labeling and Posting").

* Hygiene facilities and practices (Section 3.7, "Facilities and Equipment").

* Respiratory protection (Section 3.6.1, "Respiratory Protection").

* Protective clothing and equipment (Section 3.6.2, "Other Personal Protective Equipment").

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.