1._N3B-P101-21_Chronic_Beryllium_Disease_Prevention_Program_DRAFT.pdf

CHRONIC BERYLLIUM

DISEASE PREVENTION

PROGRAM

Classification Review Unclassified UCNI Classified

Name (Print) Signature Date

Responsible Manager

Name (Print) Signature Date

Program Manager

Name (Print) Signature Date

Document No.: N3B-P101-21 Revision: 0 Effective Date: MM/DD/YYYY DRAFT

RFP-0000297

N3B-P101-21, Rev. 0 2 of 44 Effective Date: XX/XX/XX

Procedure

N3B-P101-21 Revision: 0

Issued: XX/XX/XX Effective Date: XX/XX/XX

Chronic Beryllium Disease Prevention Program

1.0 PURPOSE

This document describes the Chronic Beryllium Disease Prevention Program (CBDPP) implemented by Newport News Nuclear BWXT-Los Alamos, LLC (N3B) for work performed under the Los Alamos Legacy Cleanup Contract (LLCC). It specifies the requirements and procedures for working with beryllium and is intended to minimize worker exposure to beryllium and meet the requirements of 10 Code of Federal Regulation (CFR) 850, Chronic Beryllium Disease Prevention Program.

2.0 AUTHORITY AND APPLICABILITY

2.1 Authority

This document is issued under the authority of the N3B Program Manager and President to direct the management and operation of N3B, as delegated to the Environment, Safety, and Health (ES&H) Program Manager. This document is derived from 10 CFR 850, Chronic Beryllium Disease Prevention Program, and 10 CFR 851, Worker Safety and Health Program.

▪ Issuing Authority (IA): ES&H Program Manager

▪ Responsible Manager (RM): Safety and Emergency Management Programs Director

▪ Responsible Office (RO): Safety and Emergency Management Programs Director’s

Office

2.2 Applicability

This document applies to N3B workers and specified subcontractors engaging in activities and operations involving beryllium. Subcontract employees are expected to follow the requirements set forth in their contractual agreements. N3B workers engaging in beryllium activities and operations off of N3B controlled sites are subject to the training and medical surveillance requirements of this policy.

Beryllium operations within the scope of this document include machining, sanding, grinding, welding, radiography, inspection, storage, assembly, and other beryllium operations in support of N3B missions. Related support operations include housekeeping, construction, maintenance, repair, decontamination, demolition, decommissioning, environmental restoration, waste operations, sampling, inspections, reviews, and environmental, safety, and health support. The requirements of this document do not apply to beryllium articles as defined herein except where otherwise noted. Requirements specific to beryllium-alloy tools are included as Attachment 3, Use of Beryllium Alloy Tools.

3.0 PROCEDURE DESCRIPTION

The N3B CBDPP is designed to reduce or eliminate worker exposure to beryllium, to prevent beryllium sensitization and chronic beryllium disease, and to meet the requirements of 10 CFR 850, Chronic Beryllium Disease Prevention Program. The overall goals of the N3B CBDPP are to:DRAFT

Chronic Beryllium Disease Prevention Program

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▪ minimize the number of workers exposed and potentially exposed to beryllium;

▪ minimize the number of opportunities for workers to be exposed to beryllium;

▪ minimize the levels of beryllium exposure;

▪ minimize disability and lost work time due to beryllium sensitization, chronic beryllium disease, and associated medical care; and

▪ reduce the number of beryllium-related incidents and occurrences.

Progress toward the achievement and maintenance of these goals will be evaluated through the periodic review of the implementation and effectiveness of the CBDPP in accordance with Section 3.27 of this document. Program data will be evaluated in the periodic review to identify trends and develop recommendations for reasonable and feasible means to further reduce exposures.

3.1 Integrated Work Management

All beryllium work at N3B will be performed in accordance with N3B-P300, Integrated Work Management.

3.2 Beryllium Inventory

The ES&H Beryllium Program Lead will maintain a current beryllium inventory. A Qualified Industrial Hygiene and Safety Professional (QIHSP) will identify the locations and descriptions of beryllium operations, Designated Beryllium Areas, and former beryllium areas by completing N3B-Form-2175, Beryllium Inventory Update.

Any organization conducting beryllium operations on N3B controlled property must provide ES&H with updated information for the beryllium inventory when there are significant changes in existing operations (consult a QIHSP for guidance); when new operations begin;

or when operations terminate. Beryllium Inventory Updates should be coordinated through a

QIHSP.

Beryllium operations and areas that are repurposed, demolished, transferred, cleaned, and/or released will be retained as archived records in the inventory.

3.3 Hazard Assessment

No beryllium operations may be initiated without a hazard assessment to determine if the proposed operation can be adequately controlled. Additionally, no beryllium operation determined to be outside the scope of this CBDPP may be initiated until an updated CBDPP has been reviewed and approved by the Department of Energy (DOE) Environmental Management Los Alamos Field Office (EM-LA). A current inventory of beryllium operations is maintained by the ES&H Beryllium Program Lead.

A QIHSP is required to perform a Beryllium Hazard Assessment for beryllium operations and for any other work activities involving airborne beryllium or beryllium contamination as defined in this procedure. This assessment is performed to determine the potential for employee exposure to airborne beryllium and/or surface beryllium associated with the planned activities and ensure controls are identified to minimize the exposure risk, minimize number of workers involved, and minimize the number of exposure events.

The hazard assessment must meet requirements of N3B-P300, Integrated Work Management. All Beryllium Hazard Assessments shall be performed and documented on N3B-Form-2061. DRAFT

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Note: Some hazard controls, temporary changes to postings and beryllium-related training requirements specific to a given task may be specified in other work control documents such as an Integrated Work Document (IWD). Applicable controls for beryllium activities, including non-routine or high hazard tasks, should be addressed in associated work documents. Guidance for content of IWDs is found in Attachment 1, Beryllium Work Activity Control Specification Guidance.

The hazard assessment may determine that the operation meets the definition of working with beryllium articles. Such operation will not fall under the requirements of one of the Designated Beryllium Areas.

A QIHSP should be consulted when working with an item containing or made of beryllium if it is suspected the item may no longer meet the definition of a beryllium article. While a Beryllium Hazard Assessment is not required for activities that do not involve airborne beryllium, beryllium contamination, or that do not meet the definition of a beryllium operation, a QIHSP may require a Beryllium Hazard Assessment for any activity involving beryllium.

3.4 Sampling Plans

A sampling plan must be developed and documented on N3B-Form-2061 for beryllium operations and Designated Beryllium Areas. A QIHSP will determine the required sampling type and frequency. If the QIHSP determines sampling is not required for a beryllium operation or Designated Beryllium Area, the rationale for not sampling must be documented as part of the Beryllium Hazard Assessment or Beryllium Inventory Update.

A QIHSP must develop a sampling plan for the release of potential beryllium-contaminated areas from beryllium-contaminated status. For release or demolition of rooms or buildings that have been associated with (other than temporary) beryllium-contaminated Designated Beryllium Areas, the Beryllium Program Lead must concur with the sampling plan. See Section 3.23 for additional details.

3.5 Permissible Exposure Limit and Action Level

N3B will observe the airborne exposure limits for beryllium established in 10 CFR 850, Chronic Beryllium Disease Prevention Program:

Table 1. Exposure Limits Exposure Limit Type Airborne Limit

Action Level (AL) 0.2 μg/m3, 8-hr time-weighted average Permissible Exposure Limit (PEL)* 0.2 μg/m3, 8-hr time-weighted average

*See Notes below.

Note: Worker exposure will be determined by personal monitoring in the worker’s breathing zone. Worker exposure is that exposure to airborne beryllium which would occur if the worker were not using respiratory protective equipment.

Note: Feasible engineering controls must be implemented as necessary to control potential exposures to below the Permissible Exposure Limit (PEL). 10 CFR 850.22, Permissible Exposure Limit, specifies compliance with the beryllium Time-Weighted Average (TWA) PEL promulgated by Occupational Safety and Health Administration (OSHA). In addition to the TWA PEL of 0.2 μg/m3, OSHA has a Short Term Exposure Limit (STEL) of 2.0 μg/m3 measured over a 15 minute period; however, this is not included in the 1910.1024 definition of TWA PEL or in this policy. DRAFT

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3.6 Exposure Monitoring

Exposure monitoring is required for operations when a hazard assessment indicates the potential for airborne beryllium. A QIHSP must perform representative exposure monitoring in accordance with 10 CFR 850.24, Exposure Monitoring. Worker exposures must be periodically monitored, especially when high hazard or non-routine work is performed. If the QIHSP determines exposure monitoring is not required for an operation, the decision must be documented in the Beryllium Hazard Assessment.

The goal of the CBDPP is to prevent worker exposures above the PEL and action level (AL).

If a sample exceeds ten times the action level, or a sample exceeds the action level and no respiratory protection was used, the QIHSP shall direct the operation to be stopped in accordance with N3B-P101-18, Procedure for Pause/Stop Work, and the cause of the exceedance, as well as any needed corrective actions, determined. The RM and a QIHSP must evaluate the activity and approve resumption of the work.

Note: For some beryllium work where engineering controls cannot further reduce airborne beryllium levels, the potential to exceed the PEL or action level is anticipated and the appropriate administrative controls/Personal Protective Equipment (PPE) are used to control exposure. Exceeding exposure limits in these situations would not require shutdown of operations, but will necessitate careful continued monitoring and strict adherence to procedures and PPE requirements. Such situations must be kept to a minimum, and are only acceptable when all other control means have proven infeasible.

For new operations or major changes in operations or maintenance activities, the RLM and QIHSP must determine if additional monitoring is required.

3.7 Reporting Results of Personal Exposure Monitoring

QIHSPs must ensure affected workers and their RLM are notified in writing of personal exposure monitoring results within 10 working days of the receipt of analytical results and results are documented. Worker notification of sampling results must include a report of the calculated 8-hr TWA exposure without having been adjusted by the assigned protection factor of the respirator, if worn. A copy of the notification must be sent to Occupational Medicine for inclusion in the employee’s medical record.

When results are below the action level, notification to affected workers will be made in one of the following ways:

▪ writing to the affected workers and Responsible Line Manager (RLM)

(e.g., memorandum), or

▪ posting the exposure monitoring results in a location readily accessible to the workers in a manner that does not identify the individual to other workers.

When results are at or above the action level, the ES&H Manager, Safety and Emergency Management Programs Director, and Beryllium Program Lead must be notified as soon as reasonably practicable. Notification to the affected workers and RLM must be in writing and include a description of any actions being taken to reduce the worker’s exposure to below the action level.

3.8 Exposure Reduction and Minimization

3.8.1 Exposure Reduction and Minimization Plans

An Exposure Reduction and Minimization Plan (ERMP) must be developed when worker exposures are shown to be at or above the action level. At a minimum, the plan must include:

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▪ annual goals for exposure reduction and minimization,

▪ rationale and strategy for meeting the goals,

▪ actions to be taken to achieve the goals,

▪ means of tracking progress towards meeting the goals, or demonstrating the goals have been met, and

▪ periodic exposure monitoring must be performed at least quarterly, or at a frequency that matches a worker’s exposure (e.g., less than quarterly when work is not performed within a 3-month period).

After approval by the Facility Operations Director (FOD) or Operations Manager (OM), RLM, and Beryllium Program Lead, the ERMP will be recognized as an addendum to the N3B CBDPP. If at some time the operations that exceeded the action level are no longer performed or a hierarchy of controls are implemented to consistently reduce exposures to below the action level (without regard to respiratory protection as determined by an analysis/evaluation of sampling data by a QIHSP), exposure reduction and minimization plans may be formally archived and removed from the N3B CBDPP. Until archived, the ERMP shall be reviewed annually by the Beryllium Program Lead.

3.8.2 Beryllium Worker Minimization

RLMs shall make every effort to minimize the number of workers exposed and potentially exposed to beryllium. Prior to authorizing and enrolling new workers into the Beryllium Medical Surveillance Program, RLMs must consult with a QIHSP and Occupational Medicine to determine if the worker’s duties will involve actual or potential exposure to beryllium. This decision should be based on personal air sampling data if available.

3.9 Housekeeping

Accessible surfaces in Designated Beryllium Areas must be kept free of excess accumulations of beryllium contamination. Surface sampling results will be used to monitor the effectiveness of controls; evaluate housekeeping efforts; identify beryllium-contaminated surfaces; verify the effectiveness of cleaning and decontamination; and confirm beryllium contamination is not spreading and is controlled to acceptable levels.

Surface samples shall be collected from the following locations:

▪ in Designated Beryllium Areas;

▪ in areas adjacent to Designated Beryllium Areas (as appropriate);

▪ where beryllium contamination may exist due to past operations; and

▪ on other work area surfaces when it is determined there is a potential for beryllium contamination above trigger levels.

Surface sampling requirements will be documented in the sampling plan for the operation (see Section 3.4).

Table 2 provides trigger levels and required actions for beryllium contamination in Accessible Beryllium Contamination Areas, Airborne Beryllium Areas, Regulated Beryllium Areas, and for designated installed beryllium containing materials. It is acceptable for beryllium contamination on inaccessible surfaces in these areas to exceed these levels.

Table 3 provides surface sample trigger levels and required actions for beryllium contamination in non-beryllium areas, Beryllium Storage Areas, and on accessible surfaces DRAFT

N3B-P101-21, Rev. 0 7 of 44 in Inaccessible Beryllium Contamination Areas. Notifications to the Beryllium Program Lead required in Table 3 must be made within 10 working days.

A QIHSP can assist in making determinations as to what constitutes an accessible surface in a facility based on the physical condition of the area and the nature of the work being performed.

Organizations may choose housekeeping and surface contamination guidelines for their specific beryllium operations that are more stringent than those given in Tables 2 and 3.

Table 2. Surface Sample Trigger Levels and Required Actions for Accessible Beryllium Contamination Areas, Airborne Beryllium Areas, and Regulated Beryllium Areas

Sample Results μg/100 cm2

Actions Required

<3.0 ▪ No corrective action required.

3.0 to 10.0 ▪ Further evaluate the situation to determine source of beryllium contamination and the potential for worker exposure. Evaluate housekeeping efforts and effectiveness of controls.

▪ A QIHSP and the FOD/OM and/or RLM will determine if operations should be stopped.

▪ Clean to below 3.0 μg/100 cm2.

>10.0 ▪ Stop operations that could result in worker exposure to airborne beryllium or contamination spread.

▪ Further evaluate the situation to determine source of contamination and the potential for worker exposure.

▪ Evaluate housekeeping efforts and effectiveness of controls. Determine any needed corrective actions. Clean to below 3.0 μg/100 cm2 and return to operations with approval of the RLM and concurrence from a QIHSP.

Note: Some surfaces in Designated Beryllium Areas (e.g., inside hoods, ducts, partial enclosures, or vessels; elevated surfaces; or at a point of operation) may be expected to have surface levels exceeding Table 2 criteria. Table 2 levels may be exceeded if justified and approved by a QIHSP. Swipe trigger levels are set as an index of surface cleanliness and do not necessarily indicate an airborne beryllium exposure hazard.

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Table 3. Surface Sample Trigger Levels and Required Actions for Beryllium Storage Areas, Accessible Surfaces in Inaccessible Beryllium Contamination Areas, Beryllium

Areas-Otherwise Inventoried, and other work area surfaces (non-beryllium) Sample Results μg/100 cm2 Actions Required

<0.2 ▪ No corrective action required.

▪ Recommendation: If sampling results are consistently detectable or some samples are above 0.1 μg/100 cm2, the area should be evaluated by a QIHSP to determine the source of beryllium.

0.2 to 3.0 ▪ Further evaluate the situation to determine the source of beryllium contamination and the potential for worker exposure.

▪ A QIHSP and the FOD/OM and/or RLM will determine if operations should be stopped.

▪ Clean to below 0.2 μg/100 cm2 or post as a beryllium contamination area.

▪ Notify Beryllium Program Lead and submit a Beryllium Inventory Update.

>3.0 ▪ Stop operations that could result in worker exposure to airborne beryllium or contamination spread. Post entry to the area to warn of beryllium contamination.

▪ Further evaluate to determine the source of contamination and potential for worker exposure.

▪ Determine if the area will be cleaned, access restricted, or taken out of service.

▪ If taken out of service, post as a beryllium contamination area and restrict access to trained and authorized Beryllium Workers operating under an approved IWD.

▪ Notify Beryllium Program Lead of sampling results and planned actions.

Surfaces above the N3B housekeeping criteria may be cleaned using certified High- Efficiency Particulate Air (HEPA) filter-equipped vacuums or wet-cleaning methods. Wet cleaning methods include low-pressure water streams, mobile wet scrubber units equipped with HEPA filtration, wet floor mops, and wet wipes, sponges, and cloths. Dry-sweeping, dry-cleaning methods, and the use of compressed air are prohibited, unless they are used in completely enclosed systems, such as glove boxes. Equipment used for cleaning and decontamination of beryllium areas must be labeled, controlled, and stored in a Designated Beryllium Area, as defined in Section 3.11.

3.10 Beryllium Soil Contamination

For purposes of the N3B CBDPP, sites with beryllium soil concentrations above naturally occurring background levels for the surrounding area will be considered contaminated and will be added to the beryllium inventory. ES&H must be contacted when there are concerns about possible soil contamination due to past or present operations, spills, or releases.

Suspect sites will be evaluated on a case-by-case basis using available sampling data.

The soils surrounding Los Alamos also contain naturally occurring beryllium. The QIHSP will take into consideration the potential for detectable beryllium from windblown or tracked-in soil when planning surface sampling and interpreting results.

3.11 Designated Beryllium Areas

N3B recognizes and controls five types of Designated Beryllium Areas. Each Designated Beryllium Area will be given one designation by a QIHSP reflecting the highest hazard based on evaluation of the potential for surface beryllium contamination and exposure to

N3B-P101-21, Rev. 0 9 of 44 airborne beryllium. The five types of areas are listed in order of increasing hazard in Table 4.

Further definitions of these areas are given in Section 9.1.

Table 4. Designated Beryllium Areas

Type of Area Beryllium-Contamination

Permissible?1 Airborne Beryllium

Permissible?1 Beryllium Storage Area2 No 3 No Inaccessible Beryllium Contamination Area Inaccessible Surfaces Only 4 No 5 Accessible Beryllium Contamination Area Yes No 5 Airborne Beryllium Area Yes Yes, below Action Level

Regulated Beryllium Area Yes Yes, may be above Action Level

Notes:

1. Native soils contain some beryllium, typically in concentrations ranging from 0.5 to 2.0 ppm. Surfaces that are visibly dusty or work conducted in dusty conditions may result in measurable beryllium.

2. Beryllium items may be stored in all of the Designated Beryllium Areas.

3. Some beryllium contamination may be present in Beryllium Storage Areas inside innermost wrapping or in the immediate vicinity of unwrapped stored items (such as within a storage container or tool box). Typically this is less than the free release limit of 0.2 µg/100cm2, although elevated contamination due to oxidation or mechanical abrasion may arise. A QIHSP should be consulted if elevated contamination is suspected or compromised wrapping encountered.

4. Contamination above 0.2 µg/100 cm2 limited to posted areas that are not Accessible Surfaces.

5. Under normal conditions, activities that actively disturb surfaces with beryllium contamination may generate airborne beryllium. Consult a QIHSP if you expect to disturb these surfaces.

Establishing a Designated Beryllium Area in a non-emergency situation requires approval from a QIHSP. The QIHSP must complete a Beryllium Inventory Update when establishing any Designated Beryllium Area that is not an emergency situation or a temporary upgrade or downgrade of an existing Designated Beryllium Area.

In emergency situations (e.g., spill/release of beryllium or the discovery of suspect contamination), temporary Designated Beryllium Areas may be established immediately to secure and control the area. A QIHSP and the Beryllium Program Lead must be notified of such situations. The Beryllium Program Lead in consultation with the QIHSP shall determine the need for a documented beryllium hazard assessment or beryllium inventory entry/update.

Designated Beryllium Areas or portions thereof may be temporarily upgraded or downgraded to another designation as directed by a QIHSP (e.g., Airborne Beryllium Area to Regulated Beryllium Area for a ventilation system maintenance job). Temporarily upgraded areas may be downgraded upon confirmation by a QIHSP that the temporary exposure or contamination concern has been resolved. A separate documented Beryllium Hazard Assessment or Beryllium Inventory Update is not required for such temporary changes in designation; however, routine changes in beryllium area designations should be addressed in the Beryllium Hazard Assessment for the work area, and where appropriate, in associated IWDs.

Designated Beryllium Areas shall be identified in the beryllium inventory. Areas with beryllium operations, but that do not meet the definition of a Designated Beryllium Area and areas containing Designated Installed Beryllium Containing Materials will be tracked in the inventory as Beryllium Area-Otherwise Inventoried (BA-OI). Some former operational areas (including areas with suspect but unconfirmed inaccessible beryllium contamination) may DRAFT

N3B-P101-21, Rev. 0 10 of 44 also be tracked as BA-OI. Areas immediately adjacent to Designated Beryllium Areas may also be established as buffer zones in accordance with approved operational procedures.

3.11.1 Beryllium Storage Area Requirements

When beryllium items or beryllium-contaminated items are stored outside of an Accessible Beryllium Contamination Area; Airborne Beryllium Area; Regulated Beryllium Area; or waste storage area, the following requirements apply:

▪ Define the storage area boundaries.

▪ Minimize the number and size of storage areas (i.e., consolidate storage).

▪ Post the location as a Beryllium Storage Area in accordance with Section 3.12.

▪ Require Beryllium Awareness Level training for access to area.

▪ Keep non-beryllium material out of the area as much as is practical.

▪ Package and label beryllium in accordance with Section 3.20.

▪ Perform periodic reviews in accordance with Section 3.27.

▪ Perform periodic surface wipe sampling in accordance with Sections 3.4 and 3.9. As determined by a QIHSP, include areas immediately adjacent to the Beryllium Storage Area to ensure beryllium contamination is not spreading.

▪ Clean surfaces using only wet-wiping methods or a certified HEPA filtered vacuum.

▪ Include the storage area in the beryllium inventory (Section 3.2).

▪ Whenever feasible, store beryllium items or beryllium-contaminated items in Beryllium

Storage Areas in appropriate packaging or an appropriate container to minimize the potential for contamination spread associated with direct contact.

▪ Inner packaging of beryllium items or beryllium-contaminated items (i.e., packaging in direct contact with beryllium) may be opened only by authorized Beryllium Workers unless otherwise authorized by a QIHSP in which case Beryllium Awareness Level training is required.

▪ When performing hazard assessments for Beryllium Storage Areas, the QIHSP must consider anticipated item handling within the storage area. If the assessment indicates spread of beryllium contamination to adjacent or nearby work surfaces or worker exposure to airborne beryllium is likely to occur, the area posting should be upgraded or the item moved to another appropriate Designated Beryllium Area.

The Beryllium Storage Area may be restricted to a limited area such as a shelf or cabinet drawer. In such a case, the entire room would not have to be posted and would not be subject to routine sampling or release requirements. If workers are entering a room with a posted Beryllium Storage Area, yet not opening/entering the storage area, then Curriculum 118, Beryllium General Employee Training, will apply.

When beryllium waste is stored in a designated waste storage area, the area is not required to be identified and posted as a designated Beryllium Storage Area. Coordinate with a waste management coordinator for beryllium waste packaging, labeling and storage.

Beryllium materials that are packaged for shipping and in transit typically do not require establishment of a Beryllium Storage Area. However, if such materials are expected to remain in the same location for an extended period a QIHSP may establish a Beryllium Storage Area. DRAFT

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3.11.2 Inaccessible Beryllium Contamination Area Requirements When a historical record review, hazard assessment, and/or sampling have indicated the presence of beryllium contamination above 0.2 μg/100 cm2 on inaccessible facility surfaces, but no expected airborne beryllium, then the following actions are required:

▪ Perform periodic surface wipe sampling in accordance with Sections 3.4 and 3.9 to ensure beryllium contamination is not spreading from the inaccessible areas to adjacent work areas.

▪ Include the area of inaccessible beryllium contamination in the beryllium inventory.

▪ Post the location as an Inaccessible Beryllium Contamination Area in accordance with

Section 3.12.

▪ Evaluate work to be performed involving the contaminated surfaces (e.g., repairs, maintenance, Decontamination and Decommissioning construction, etc.) for the potential to cause contamination to become airborne, and/or spread to workers, equipment, tools, or materials.

▪ Ensure beryllium hazards and required controls are included if the evaluation indicates the need for IWDs or other work control documents.

▪ Limit access to the contaminated surfaces and surrounding areas (as needed) to authorized Beryllium Workers during activities that could cause beryllium contamination to become airborne and/or spread to workers, equipment, tools, or materials.

Note: There are generally no beryllium exposure hazards expected or beryllium specific entry requirements for routine work on accessible surfaces in this type of area. Beryllium Awareness Level workers may access contaminated surfaces if a QIHSP determines generation of airborne beryllium is not expected to occur

▪ Ensure workers in the vicinity are not exposed to airborne beryllium and beryllium contamination does not spread to accessible surfaces. This may require physical isolation of the work area (e.g., barricades, containment structure) and/or scheduling the work when areas are not occupied.

▪ Perform exposure monitoring in accordance with Sections 3.5 and 3.6 during work in beryllium-contaminated inaccessible areas.

▪ Perform post-work surface wipe sampling in accordance with Sections 3.4 and 3.9 to confirm beryllium surface contamination did not spread to accessible surfaces.

▪ Perform periodic reviews in accordance with Section 3.27.

▪ Clean contaminated surfaces (when practical) to reduce the level of beryllium contamination, minimize the size of the area, or eliminate the Inaccessible Beryllium Contamination Area.

▪ Treat invasive work on structures or equipment within an Inaccessible Beryllium Contamination Area with unknown surface levels of beryllium contamination (e.g., removal of exhaust ventilation duct) as having a potential for airborne beryllium unless an evaluation by a QIHSP determines otherwise.

3.11.3 Accessible Beryllium Contamination Area Requirements

When a hazard assessment and/or sampling have indicated the presence of beryllium contamination on accessible facility surfaces above 0.2 μg/100 cm2, but no expected airborne beryllium under routine conditions:

▪ Define the accessible beryllium contamination area so that boundaries are clear. DRAFT

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▪ Post the location as an Accessible Beryllium Contamination Area in accordance with Section 3.12.

▪ Evaluate work to be performed for the potential to cause beryllium contamination, the beryllium to become airborne, and/or spread to workers, equipment, tools, or materials.

▪ Initiate exposure monitoring in accordance with Sections 3.5 and 3.6 if the evaluation indicates the work to be performed could potentially result in airborne beryllium.

▪ Perform periodic surface wipe sampling in accordance with Sections 3.4 and 3.9, including areas adjacent to the Accessible Beryllium Contamination Area to ensure beryllium contamination is not spreading.

▪ Initiate housekeeping and personal hygiene measures (see Sections 3.9 and 3.17).

▪ Limit access to authorized Beryllium Workers unless otherwise authorized by a QIHSP.

▪ If a QIHSP determines generation of airborne beryllium is not expected to occur for work in a given location or for a given activity, authorized workers who have completed Beryllium Awareness Level Training (or equivalent briefing) may perform work in locations delimited by the QIHSP. In some cases, an escort may be specified to identify areas of elevated beryllium contamination.

▪ Control visitor access in accordance with Section 3.27.

▪ When practical, clean contaminated surfaces to reduce the level of beryllium contamination; minimize the size of the area; or eliminate the Accessible Beryllium Contamination Area.

▪ The area and its operations must be included in the beryllium inventory.

3.11.4 Airborne Beryllium Area Requirements

When a hazard assessment and/or monitoring have indicated the reasonable potential for measurable levels of airborne beryllium below the action level for ongoing activities in that location:

▪ Post the area in a manner to ensure that the boundaries are clear.

▪ Post the location as an Airborne Beryllium Area in accordance with Section 3.12.

▪ Limit access to authorized Beryllium Workers during operational periods.

▪ Control visitor access in accordance with Section 3.27.

▪ Perform exposure monitoring in accordance with Sections 3.5 and 3.6.

▪ Perform periodic surface wipe sampling in accordance with Sections 3.4 and 3.9, including areas adjacent to the Airborne Beryllium Area to ensure beryllium contamination is not spreading.

▪ Initiate housekeeping and personal hygiene measures (see Sections 3.9 and 3.17).

▪ Implement practical measures that can be taken to reduce levels of airborne beryllium.

▪ The area and its operations must be included in the beryllium inventory.

3.11.5 Regulated Beryllium Area Requirements

When a hazard assessment and/or monitoring have indicated the reasonable potential for airborne beryllium at or exceeding the action level, then:

▪ Define the regulated beryllium area so boundaries are clear.

▪ Post the location as a Regulated Beryllium Area in accordance with Section 3.12.

N3B-P101-21, Rev. 0 13 of 44

▪ Limit access to authorized Beryllium Workers.

▪ Restrict visitor access in accordance with Section 3.25.2 (only visiting Beryllium

Workers).

▪ Log worker entry into the area (see Section 3.13).

▪ Perform exposure monitoring in accordance with Sections 3.5 and 3.6.

▪ Perform periodic surface wipe sampling in accordance with Sections 3.4 and 3.9, including areas adjacent to the Regulated Beryllium Area to ensure beryllium contamination is not spreading.

▪ Initiate housekeeping and personal hygiene measures (see Sections 3.9 and 3.17).

▪ Develop exposure reduction and minimization plans in accordance with Section 3.8.

▪ The area and its operations must be included in the beryllium inventory.

3.12 Posting

The FOD/OM and/or RLM must ensure Designated Beryllium Areas are posted at Designated Beryllium Area access points to alert workers to potential hazards and to prevent inadvertent or unauthorized entry. In some cases, it may be necessary to post or warn of beryllium hazards at access control, work control, or other locations that are separate from the Designated Beryllium Areas. Examples of approved Designated Beryllium Area signs are shown in Attachment 2, Beryllium Signs and Labels.

Designated Beryllium Area signs have space for entering additional needed information. In the Description lines briefly describe the area and/or operation, including any special entry requirements or associated hazards. Where appropriate, maps, floor plans, or additional information describing the area, operation, or entry requirements may be posted adjacent to the Designated Beryllium Area sign.

The Contact line on the signs must be filled in with the name and phone number of knowledgeable and responsible office, individual, or group that can identify the individual serving as the point of contact for information about the area and requirements for entry and work.

For Inaccessible Beryllium Contamination Area signs, the location of the beryllium contamination must be identified in the Description line. Requirements (or a reference to requirements) for work on or access to the contaminated surfaces must be entered in the Requirements lines. Specific work requirements for work being performed may be provided in related IWDs or equivalent work documents.

Printable, fillable, electronic copies of Designated Beryllium Areas signs are available from the QIHSP. Signs are available in multiple sizes to suit specific applications.

3.13 Access Control

Only authorized Beryllium Workers are permitted to enter Airborne Beryllium Areas or Regulated Beryllium Areas while a beryllium operation is being performed.

A log or record of personnel entering and exiting Regulated Beryllium Areas must be maintained that includes name, Z-number, date, time in, time out, location, and operation performed. The log may be electronic or recorded on paper. N3B-Form-2119, Regulated Beryllium Area Entry Log, can be used to record entry. Entry logs must be maintained as beryllium records as part of work activity records in accordance with Section 8.2. DRAFT

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3.14 Hazard Control Measures

A hierarchy of hazard controls measures will be implemented by the FOD/OM and/or the RLM. The hazard controls will be, in order of preference: (1) elimination or substitution of beryllium; (2) engineering controls, such as local exhaust ventilation systems;

(3) administrative controls, such as access control, Integrated Work Management (IWM), personal hygiene practices, housekeeping procedures, employee training, and equipment release criteria; and (4) PPE, such as respirators and protective clothing.

3.15 Ventilation and Engineering Controls

Whenever feasible, operations generating airborne beryllium will be controlled with ventilation and/or containment that prevents worker exposure and workplace contamination.

Ventilation systems and controls will be selected, designed, reviewed, approved, tested, and labeled in accordance with N3B-P101-16, Local Exhaust Ventilation and HEPA Filtration Systems.

Users must check ventilation systems before use to ensure they are functioning as required.

Operating parameters and user verification procedures should be specified in an operating procedure, IWD, or other document; or posted at the ventilation system.

Wet methods, containment vessels, non-vented enclosures, or other means of controlling the release of beryllium particles may also be employed. Any such control methods must be evaluated by a QIHSP before being used for beryllium. Control systems may also require review and approval by safety professionals, facility engineers, or others before use.

When feasible, Airborne Beryllium Areas and Regulated Beryllium Areas will be maintained under negative pressure in relation to adjacent areas. Change rooms or areas that are used to remove beryllium-contaminated clothing and protective equipment must be maintained under negative pressure or located to minimize dispersion of beryllium into clean areas.

3.16 Personal Protective Equipment

A QIHSP will assist in determining specific PPE requirements based on the hazard assessment for beryllium operations. Required PPE must be included in IWDs or other work control documents. Refer to N3B-P101-6, Personal Protective Equipment.

Respirator use is mandatory when:

▪ exposures are at or above the action level;

▪ there is potential for acute worker exposure (short term, but high level);

▪ there is reasonable potential for failure of a critical control system; or

▪ it is expected that new or modified operations may exceed the action level (until sampling results demonstrate the operation is being adequately controlled).

When there is potential for exposures below the action level or contact with beryllium contamination, individual workers may request, and must be provided with, a respirator or protective clothing for their use.

Gloves must be worn when there is potential for direct contact with beryllium or beryllium contamination through handling beryllium articles, beryllium items, beryllium-contaminated items, or beryllium waste. Exceptions to the use of gloves may be specified by a QIHSP in cases where the use of gloves would present a safety hazard; the level of dexterity/tactile sense required for the job would be impeded by the use of gloves; or the potential for dermal

N3B-P101-21, Rev. 0 15 of 44 exposure is negligible due to use of tools or fixtures, handling procedures, or other factors.

In cases where the use of gloves is exempted, other dermal exposure control measures such as limiting contact time and hand washing frequency must be considered.

Where PPE is required, entrances and exits to/from Designated Beryllium Areas must have appropriate locations for the donning, doffing, cleaning, and/or disposal of PPE that will prevent worker exposure and contamination spread. Required PPE and clothing will be provided by the employer and must be readily accessible to workers. Workers must not remove beryllium contamination from protective clothing and equipment by blowing or shaking.

Beryllium-contaminated protective clothing or equipment that is removed from Designated Beryllium Areas for cleaning, service, or disposal must be bagged and labeled with a Danger Beryllium Label (see Fig. 2-6, Attachment 2, Beryllium Signs and Labels).

Subcontractors that launder, clean, or service beryllium-contaminated protective clothing or equipment must be informed of beryllium hazards so they can employ appropriate controls to prevent exposure or contamination spread. Contracts with organizations providing these services must identify the potential for beryllium contamination; specify how beryllium-contaminated items will be identified, packaged, and/or labeled; and recommend how the contaminated items should be handled to prevent the release of airborne beryllium. The Beryllium Program Lead must review the contract language before the contract is issued.

3.17 Hygiene Facilities and Practices

3.17.1 Hygiene Facilities

The following are required for Accessible Beryllium Contamination Areas, Airborne Beryllium Areas, and Regulated Beryllium Areas:

▪ Designated locations for:

- donning and doffing of any required protective clothing and PPE,

- worker preparation for entry into the areas,

- collection/storage of contaminated protective clothing, PPE, and waste, and

- storage of personal items, clean protective clothing, and PPE.

▪ Hand and face washing and toilet facilities must be available to authorized Beryllium Workers. In locations where plumbed-in washing facilities are not feasible, portable washing stations or packaged wet wipes may be employed.

▪ Lunch/break areas must be available that are accessible to authorized workers, have tables or eating areas free of beryllium contamination, and do not expose workers to airborne beryllium.

Work involving contaminated surfaces in Inaccessible Beryllium Contamination Areas may require the above hygiene facilities. Such requirements must be considered during the work evaluation process and specified in job-specific IWDs or work packages.

In addition to these requirements, the following additional facility requirements will apply to Regulated Beryllium Areas:

▪ Separate areas, free of beryllium contamination, must be provided for workers to change into provided protective clothing and PPE, and to store personal clothing and property. DRAFT

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▪ Change rooms or areas that are used to remove beryllium-contaminated clothing and protective equipment must be maintained under negative pressure or located so as to minimize dispersion of beryllium into clean areas.

▪ Shower facilities must be available to workers at the end of the work shift.

▪ Laundry and cleaning facilities/services must be provided for non-disposable protective clothing and PPE.

3.17.2 Hygiene Practices

The following hygiene practices apply to Accessible Beryllium Contamination Areas, Airborne Beryllium Areas, and Regulated Beryllium Areas:

▪ IWDs or other work control documents for beryllium operations must include measures to prevent workers from leaving these beryllium areas with beryllium contamination on their bodies, personal clothing, or personal property.

▪ No eating, drinking, tobacco products, chewing gum, cosmetics, lip balm, food preparation, or food storage is permitted. An exception to the drinking restriction may be granted by a QIHSP to allow workers to adequately re-hydrate where hot environments or PPE may increase risk of heat-stress related illnesses. The QIHSP must evaluate the drinking procedure to ensure there is no exposure risk.

▪ Workers with open cuts, wounds or abrasions in the skin may not enter these beryllium areas without prior approval of Occupational Medicine. Open cuts, wounds, or abrasions must be completely covered by a bandage or medical dressing. Cuts, wounds or abrasions on the hands must be additionally covered by an impermeable glove (e.g., latex or nitrile) before entering the area and must remain covered during the entire time in the area.

▪ Cuts, wounds, or abrasions that occur in these beryllium areas must be reported to the RLM and evaluated by Occupational Medicine.

▪ Contaminated PPE will be doffed or cleaned in a manner that prevents beryllium particles from becoming airborne or contaminating surfaces.

▪ After leaving beryllium areas and before commencing other tasks, workers will thoroughly wash hands.

▪ Workers must not enter lunch/break areas wearing protective work clothing with potential beryllium contamination.

Work involving contaminated surfaces in Inaccessible Beryllium Contamination Areas may require the above hygiene practices. Such requirements must be considered during the work evaluation process and specified in job-specific IWDs or work packages.

In addition to these practices, the following additional hygiene practices apply to Regulated Beryllium Areas:

▪ Personal clothing, jewelry, and property will not be taken into Regulated Beryllium Areas. Rings that cannot be removed must be covered by an impermeable glove (e.g., latex or nitrile) before entering the area and must remain covered during the entire time in the area.

▪ Respiratory protection is required.

▪ Workers in Regulated Beryllium Areas must shower at the end of the work shift and before donning personal clothing. Where showers are not available at the Regulated Beryllium Area site, workers may be transported to showers after removing

N3B-P101-21, Rev. 0 17 of 44 contaminated clothing (e.g., coveralls, booties, and gloves), washing hands and face, and donning any needed clean modesty clothing.

Note: A QIHSP, in coordination with the RLM, may specify the above hygiene practices for Regulated Beryllium Areas for work in other Beryllium-Contaminated Designated Beryllium Areas. This must be incorporated into procedures, IWDs, or other work control documents.

3.18 Beryllium Waste Management

Waste management coordinators must be contacted regarding the handling of any beryllium waste to ensure it is properly packaged, handled, and stored and that an appropriate path forward has been identified for disposal.

Beryllium-contaminated waste and equipment disposed of as waste must be sealed in impermeable containers (e.g., plastic bags, wrap, drums, or other containers) to prevent the release of beryllium dust during handling and transportation. Bags or containers of beryllium waste must be labeled as to the contents and have a Danger Beryllium Label applied (see Attachment 2, Fig. 2-6, Beryllium Signs and Labels).

3.19 Use of Beryllium Alloy Tools

Beryllium alloy (non-sparking) tools are useful for work in potentially flammable atmospheres. Whenever possible, use of beryllium alloy tools should be eliminated, reduced or strictly controlled in order to manage and control potential worker exposure. When beryllium alloy tools are deemed essential, they must be managed and used according to Attachment 3, Use of Beryllium Alloy Tools.

3.20 Packaging and Labeling of Beryllium

Beryllium items and beryllium-contaminated items must be packaged in a manner that safely contains the material, prevents dermal or airborne exposure, and prevents the spread of contamination. Packages and containers must be appropriate for the size, weight and form (i.e., solid, liquid, powder) of the item.

A Beryllium Danger Label (or its equivalent if provided by a supplier or another DOE/ National Nuclear Security Administration site) must be attached to packages containing beryllium items or beryllium-contaminated items in a manner that allows it to be clearly seen prior to accessing the beryllium item or beryllium-contaminated item. Examples of the Beryllium Danger Label are shown in Fig. 2-6, Attachment 2, Beryllium Signs and Labels.

Beryllium Danger Labels are available from a QIHSP. Labels may be attached to plastic or cardboard tags to aid in affixing them to packages or equipment. Labeling of outer packages is preferred.

The outer package surfaces must have a removable beryllium contamination level on accessible surfaces of <0.2 μg/100 cm2. This can be verified by sampling or ensured by the use of new, clean packaging materials and handling in a manner that will prevent beryllium contamination on package surfaces. If the package is stored in and does not leave an Accessible Beryllium Contamination Area, Airborne Beryllium Area, or Regulated Beryllium Area, the outer package surface contamination limit is 3.0 μg/100 cm2.

If the size or configuration of beryllium items prevents packaging or there is a need for immediate access to the items during operations, then the non-packaged items may be used or stored in a Designated Beryllium Area provided there are postings, labels, or other means to clearly indicate the items are beryllium and access is restricted to authorized and knowledgeable Beryllium Workers. DRAFT

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If a beryllium item is a component of a system that cannot be packaged or labeled (e.g., beryllium item in use, beryllium window in an instrument, or a beryllium alloy structural element), then the RLM, with support from a QIHSP performing the hazard assessment, must determine appropriate packaging and/or labeling requirements for that system.

Double packaging with adequate containment volume for spills or leaks is required for transport and storage of beryllium or beryllium compounds in powder or liquid form.

Secondary containment, such as a spill tray, is considered adequate double packaging for beryllium in liquid form during use or storage. Double packaging is recommended, but not required, for other forms of beryllium.

3.21 Transfer of Beryllium Items and Beryllium-Contaminated Items Under this CBDPP, if an item is in a beryllium-contaminated Designated Beryllium Area, or has been used for a beryllium…