Att_11.1_SLDA_Be_Variance_LRP_20_Mar_2015_Rev_2.pdf

DEPARTMENT OF THE ARMY

U.S. ARMY CORPS OF ENGINEERS

WASHINGTON, D.C. 20314-1000

CESO-E 20 March 2015

MEMORANDUM THRU Commander, U.S. Army Corps of Engineers, Lakes and Rivers Division, ATTN: CELRD-SO, 550 Main Street, Cincinnati, Ohio 45202-3222

FOR: Commander, U.S. Army Corps of Engineers, Pittsburg District, ATTN: CELRP-

SO,

SUBJECT: Variance Request, EM 385-1-1, Section 06.A.01 a, Exposure Standards

1. Pittsburg Engineer District requested a change in the language of the the original variance (Variance LRP06.01.A, 24 July 2013) from paragraph Section 06.A.01 a, of EM 385-1-1. Variance is dated 24 July 2013 and is in reference to the Shallow Land Disposal Area (SLDA) Remediation Project site in Armstrong County, Pennsylvania.

2. The requested change edits the language of the original variance request package.

The request is for a variance from the use of the acceptable limits specified in the most recently published ACGIH guideline, "Threshold Limit Values and Biological Exposure Indices," or the OSHA standard, whichever is more stringent for beryllium as the occupational exposure limit. In the variance change request, Pittsburg District asks to use 0.2 ug/m3 as averaged over an 8 hour day Occupational Exposure Limit (OEL) and use 0.1 ug/m3 as averaged over an 8 hour day as an action level. The variance request is based on current beryllium industry safety practices.

3. This office grants this variance, for the SLDA Remediation Site for the life of the remediation and long term site management. This variance is granted with the understanding that:

a. There will be a Site Safety and Health Plan as required by Section 28 (2008) or Section 33 (2014) EM 385-1-1, and an Accident Prevention Plan as required by Section 01 EM 385-1-1. The specific details of these requirements are below in c-i.

b. The Pittsburg District will implement a Beryllium Disease Prevention Plan which will include the applicable sections of 10 CFR 850, December 8 1999, Chronic Beryllium Disease Prevention Program.

c. Any Contractor working on the SLDA Remediation site will be required to hire a Safety and Health Manager (SHM) who is a Certified Industrial Hygienist (CIH) and a Certified Health Physicist (CHP) or two individuals, one with a CIH and one with a CHP to develop and oversee implementation of the APP/SSHP. The contractor will also be required to have a Site Safety and Health Officer (SSHO) at the project to implement APP/SSHP requirements when Beryllium contaminated soils/materials are being handled. All work conducted by government personnel shall either fall under the contractor’s AAP/SSHP or as part of the LRP Beryllium Disease Prevention Plan, a government AAP/SSHP shall be written and reviewed and signed by a CIH and CHP.

d. Project activities will be set up so that there is an exclusion zone (EZ), a contamination reduction zone (CRZ) and a support zone (SZ). The EZ will be the area on the site where beryllium contaminated material is handled/processed and treated.

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 are required to pass through the CRZ and be decontaminated before moving into the SZ. Equipment will be tested to assure free release criteria for surface contamination are met before release for use by the general public. Free release criteria for beryllium contamination is 0.2 ug/100cm2 (See free release criteria specified in paragraph 4.2.11 of DOE G 440.1-7A).

e. The CRZ will be set up with equipment and requirements for personnel having been in the EZ to perform gross decontamination remove personal protective equipment and shower before moving into the SZ. A “clean room” will be provided that will allow worker to exit the shower area and change into clean street clothing.

f. Personnel entering the EZ to perform cleanup activities will, at least initially, until exposure levels are defined for the activity, wear personal protective equipment, including respirators. Initial personal protective equipment will prevent dermal exposure and include the use of supplied air respirators.

g. Occupational exposure monitoring for contamination on the project will include

Beryllium by NIOSH methods 7300 or 7301 and NIOSH method 7704. Initially, each activity will be monitored aggressively to verify occupational exposure levels and inform respirator use decisions. The action level for Beryllium shall be set at 0.1 micrograms/cubic meter as averaged over an 8 hour day.

h. Personnel required working in the CRZ or EZ shall comply with the training requirements specified in Section 28 of EM 385-1-1. Project specific training specified in paragraph 28.D.02 shall be modified to require a minimum of 3 hours of training specific to handling and management of Beryllium contaminated materials from these sites.

Personnel required to work in the SZ are required to attend and participate in project specific training.

i. Personnel require working in the CRZ or EZ shall comply with the medical surveillance requirements specified in Section 28. E. Medical Surveillance of EM 385-1-

1. Special emphasis shall be placed on medical examinations and testing to determine baseline lung function and previous exposure to Beryllium. Personnel required to work on these projects (in the EZ, CRZ or SZ) shall be evaluated for Beryllium sensitization by Beryllium Lymphocyte Proliferation (Be-LPT) testing. Personnel testing positive shall not be allowed to work on the SLDA Site.

4. If anything or any conditions deviate from the anticipated conditions, or if there is a documented increase in beryllium disease related to this work, the variance could be considered void (with proper input from LRP-SO, LRD-SO and other associated organizations). Please contact Andrea Pouliot, CIH, at (202) 761-8691 if you have any questions concerning this variance.

Jerry R. Balcom Acting Chief, Safety and Occupational Health Office

HQUSACE