Luckey site Beryllium Variance revision July 2020 MA Final.pdf

DEPARTMENT OF THE ARMY

HEADQUARTERS, U.S. ARMY CORPS OF ENGINEERS

441 G STREET NW WASHINGTON DC 20314-1000

REPLY TO

ATTENTION OF

CESO-SO 07 July 2020

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, Buffalo District, ATTN: CELRB-SO, 1776 Niagara Street, Buffalo, New York 14207

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

1. Buffalo Engineer District requested a change in the language of the original variance (Variance LRB06.01.A, 2 Oct 2012) and variance amendments (Variance LRB06.01.A Amendments, 26 Feb 2013 and 12 Sep 2014) from paragraph Section 06.A.01 a, of EM 385-1-1. Variance is dated 10 August 2012 and is in reference to the Luckey Remediation Project site in Luckey, Ohio.

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, Buffalo District asks to use the OSHA established criteria of 0.2 ug/m3 as averaged over an 8 hour day Permissible Exposure Limit (PEL), use 0.1 ug/m3 as averaged over an 8 hour day as an action level, and 2.0 ug/m3 as averaged over 15 minutes as a Short-Term Exposure Limit (STEL). The variance request is based on current beryllium industry safety practices.

3. This office grants this variance, for the Luckey 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 an Accident Prevention Plan and Site Safety and Health Plan (APP/SSHP) as required by EM 385-1-1. The specific details of these requirements are below in c-j.

b. The Buffalo 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. The OEL which shall be adopted when assessing airborne beryllium concentration levels of which USACE personnel assigned to work or perform activities on the site may be exposed, shall consist of the ACGIH TLV value of 0.05 ug/m3 (Based on an 8 hour duration-TLV). As USACE employees exclusively perform site activities within the support zone, where the potential for anticipated exposures are expected to remain below the established action level, additional sampling will be performed utilizing the ACGIH TLV value of 0.05 ug/m3 as a stringent means to assess employee exposure potential. Personal breathing zone air sampling will be performed on a regular basis to evaluate the various work activities where exposure potential may occur and will assist with the development

CESO-SO 07 July 2020

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

of a written Negative Exposure Assessment (NEA) for each work task based on Similar Exposure Group (SEG).

c. Any Contractor working on the Luckey 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 APP/SSHP or as part of the LRB Beryllium Disease Prevention Plan, a government APP/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 or powered air purifying respirators with a protection factor of 1000.

g. Occupational exposure monitoring for contamination on the project will include Beryllium by approved NIOSH methods. 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 SZ, CRZ, or EZ shall comply with the training requirements specified in latest version of EM 385-1-1. Project specific training 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 who will only

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

be performing administrative functions in the SZ are only 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 latest version 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 visit or work on the Luckey Site.

j. Visitors perform limited duration activities (e.g. deliveries or service calls) to

Site SZs and are expected to have a minimal exposure potential. In advance of a proposed site visit, the Contractor’s CIH must prepare and submit an exposure evaluation to USACE.

The evaluation will be based on the individual, or group of individuals, expected activities and duration in the SZ. Individuals not meeting the definition of a visitor will be considered SZ workers. Visitors are required to complete project specific beryllium awareness training.

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 LRB-SO, LRD-SO and other associated organizations). Please contact Bonnie D Rathbun, CIH, at (202) 761-0419 if you have any questions concerning this variance.

Mark G. Atkins Chief, Safety and Occupational Health Office, HQUSACE

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