Privacy & Security Notice
		Project Hanford Management Contract Facilities Initial Beryllium Characterization Report Fluor Daniel Hanford Richland, WA September 29, 1999

S. J. Veitenheimer, Director
Quality, Safety and Health Programs Division
U.S. Department of Energy
Richland Operations Office
Richland, Washington 99352

Dear Mr. Veitenheimer:

CONTRACT NO. DE-AC06-96RL13200 - FISCAL YEAR 1999 PERFORMANCE EXPECTATION NO. B8.1.8

This correspondence provides a status report of Fluor Daniel Hanford, Inc. (FDH) progress of performance under the Fiscal Year (FY) 1999 Performance Expectation Plan (PEP) in the topical area of Occupational Safety and Health, Performance Expectation No. B 8.1.8. The Expectation reads: Perform facility characterization and report outcomes of facilities identified as being suspect beryllium facilities.

FDH has completed the four specific objectives designed to improve the PEP rating from Red (Marginal) to Blue (Superior). These activities are summarized below:

• An updated schedule for beryllium sampling and analysis activity was prepared and delivered to the U.S. Department of Energy, Richland Operations Office (RL) ahead of the July 8, 1999, scheduled release. Each step in this schedule was met during the sampling and analysis activities, which followed.

• An outline of the items to be included in the final beryllium report was prepared by FDH/Occupational Safety and Health (OSH) and submitted to your office. No comments were received on the outline, and it was followed in developing the final report.

• A final report on beryllium characterization of suspect facilities has been completed and is attached to this letter. This report discusses in detail the steps that were performed in completing the beryllium facility characterization and the results that were obtained from each facility.

• For each facility that exceeded the Hanford criteria for beryllium contamination as outlined in the Hanford Chronic Beryllium Disease Prevention Program, recommended actions were made for future actions to reduce employee exposure. This list of actions was included in the attached final report.

In addition to the above actions, we have also updated the Project Hanford Management Contract (PHMC) Facility Beryllium Fact Sheets. These are a series of pages describing each of the PHMC facilities in detail with information on the potential for beryllium exposure. They are located on the Hanford Internet, and they can be accessed by anyone who desires additional information on where and when beryllium was used at Hanford. Although this action was not part of the objectives to move from Red to Blue, it was deemed necessary to make this information available to all employees both for informational and planning purposes.

The FDH OSH welcomes the opportunity to verify these closures with you or members of your staff.

Very truly yours,




Duane L. Renberger, Acting Sr. Director
Nuclear and Occupational Safety

sls

Attachment

Project Hanford Management Contract Facilities

Initial Beryllium Characterization Report

Fluor Daniel Hanford

Richland, WA

September 29, 1999

Table of Contents

List of Tables

1.0     EXECUTIVE SUMMARY

2.0     PURPOSE AND SCOPE
2.1     Purpose
2.2     Scope

3.0     BACKGROUND
3.1     Hazards of beryllium
3.2     Beryllium Usage at Hanford

4.0     SURVEY METHODOLOGY
4.1     Objectives
4.2     Project Personnel
4.3     Training and Oversight
4.4     Sampling Strategy
4.5     Sampling Methods
4.6     Analytical Methods
4.7     Current Standards and Criteria

5.0     RESULTS
5.1     Data Quality
5.2     Observance of Procedures
5.3     Quality Control Sample Results
5.3.1   Wipe Samples
5.3.2   Air Samples
5.4     Training and Oversight
5.5     Sampling Results

6.0     DISCUSSION
6.1     Building 324
6.2     Building 333
6.3     Building 334A
6.4     Unsampled Areas
6.5     Limitations on sampling results

7.0     CONCLUSIONS

8.0     RECOMMENDED ACTIONS

List of Tables

Table 1. Criteria for Airborne and Surface Beryllium Contamination

Table 2. Contamination class criteria.

Table 3. Positive Wipe Samples With Estimated Surface Areas

Table 4. Percent Recoveries for Independent Laboratory

Table 5. Facilities by contamination category.

Table 6. Sampling Results.

Table 7. Samples with Measurable Beryllium

Table 8. Unsampled areas with possible beryllium contamination.

1.0   EXECUTIVE SUMMARY

Although beryllium has not been used in production activities at Hanford for many years, a high level of concern exists over the possible presence of beryllium contamination in Project Hanford Management Contract (PHMC) facilities. Currently, the Department of Energy (DOE), the American Conference of Governmental Industrial Hygienists (ACGIH) and the Occupational Safety and Health Administration (OSHA) are all considering revised guidelines or regulations regarding occupational exposure to beryllium. In addition, several Hanford PHMC employees have been diagnosed with either beryllium sensitization or beryllium disease. Although these conditions are probably the result of past exposures during beryllium operations, it is essential that we determine current levels of beryllium contamination.

This study was initiated to determine the current levels of beryllium contamination that are likely to be encountered during routine operations in PHMC facilities which are suspected of having beryllium contamination. Although beryllium monitoring was performed at Hanford facilities during production operations, virtually no monitoring has been performed since these activities were halted. As such, the current level of beryllium contamination in facilities is uncertain even though some clean-up was performed after beryllium production activities were discontinued.

A combination of surface wipe and air sampling was performed to identify contamination and evaluate the potential for beryllium exposure in these facilities. Twenty-five PHMC facilities where beryllium was believed to have been used were sampled. Airborne beryllium was not detected in any of the facilities despite the use of very sensitive air sampling and analytical methods. Levels of surface beryllium contamination above the Hanford surface contamination limit were found in three of the 25 facilities (324, 333 and 334A). Routine work in the remaining 22 facilities should present no beryllium hazard to employees as long as these activities do not disturb the building structure or ventilation systems.

Low levels of beryllium contamination exist in building 334A and portions of the 333 and 324 buildings. While air samples from the facilities confirm that the routine beryllium airborne levels for all areas are below the limits of detection, surface wipe samples suggest that there is a small potential for beryllium to become airborne if the settled dust is stirred up. Although most of the wipe samples from each of these buildings were below the detection limit of the sampling method, the measureable wipe sample results for these areas ranged from the detection limit of 0.5 µg/100 cm² up to 11 µg/100 cm². While several of these results are above the release limit of 1.0 µg/100 cm² in the Hanford Chronic Beryllium Disease Prevention Program (CBDPP), they indicate that only low levels of beryllium contamination currently exist in routine work areas of these facilities. The significance of these sampling results is best understood when considered in terms of work in the facilities. Recommendations are presented to minimize the potential for employee exposure and to perform additional beryllium sampling where these results indicate it is warranted to better define the potential for beryllium exposure.

2.0   PURPOSE AND SCOPE

2.1   Purpose

The purpose of this characterization was to determine the current airborne and surface concentrations of beryllium in buildings with potential beryllium contamination. Although beryllium is no longer used by the PHMC in production activities, employees are still working in or entering many of the facilities where beryllium was used in the past. Non-sparking tools containing low levels of beryllium are being used in some facilities. Because the possibility of beryllium contamination exists in these facilities, this characterization effort was performed to measure both the airborne and surface beryllium concentrations in these facilities.

DOE is currently proposing new regulations for beryllium (10 CFR Part 850). While these proposed standards are still being finalized, it is clear that the new regulations will lower the allowable beryllium exposure limits, and require that DOE contractors perform a baseline inventory in areas where the presence of beryllium is suspected. To quote from the proposed requirements, “In conducting the baseline inventory, DOE contractors shall: (1) Review employee records; (2) Interview employees; (3) Document the presence and locations of beryllium at the facility; and (4) Conduct sampling to identify the presence of beryllium.”

2.2   Scope

The scope of this characterization was to evaluate surface and airborne beryllium contamination levels in any Hanford PHMC facilities where beryllium usage was known or suspected to have occurred. As part of the Hanford CBDPP, a list of Hanford PHMC facilities was prepared where beryllium was believed to have been used in the past, and a total of 25 facilities were identified where beryllium was known or suspected of being used. Since these facilities belong to several different subcontractors under the PHMC contract, the decision was made for FDH to administer the characterization effort. This would ensure that the same methodology was used to assess each facility, and that the results obtained would be directly comparable across the various facilities.

The project scope was limited to evaluating the surface and airborne beryllium contamination levels in areas where employees were likely to be working. This included walking and working surfaces, light fixtures and other areas that could be easily accessed by employees during routine operations. Routine operations would include facility surveillance, relamping, office work and other activities that do not disturb the building structure or ductwork.

3.0   BACKGROUND

3.1   Hazards of beryllium

The hazards of beryllium were first recognized in the 1940s. Exposure to very high levels of airborne beryllium can result in acute pulmonary beryllium disease, which is a form of chemical pneumonia. Because of the high levels of beryllium required to produce this disease, it does not occur in routine occupational exposure.

Exposure to lower levels of airborne beryllium can result in either beryllium sensitization or chronic beryllium disease. Beryllium sensitization occurs when the body produces anti-bodies in response to beryllium exposure. It can only be measured using specialized tests on blood or lung washings. It is not a disease, and has no symptoms. However, workers with beryllium sensitization are at an increased risk of developing chronic beryllium disease.

Chronic beryllium disease occurs when the body recognizes the presence of beryllium and produces large numbers of cells (lymphocytes) in an attempt to counteract the beryllium. The result is the formation of lumps or granulomas in the lungs, which interfere with breathing by irreversibly reducing gas exchange surface area. Since the disease is generally progressive, a person with chronic beryllium disease will have increased difficulty in obtaining enough oxygen to breathe.

There is a high level of employee concern at Hanford about the potential for beryllium exposure due to recent news stories from other DOE sites. Although we have monitoring data from when beryllium activities were performed, some of these data are over 40 years old and are not indicative of current conditions. While some of these facilities have been cleaned up since the beryllium work was performed, we do not have clearance data quantifying post-cleanup beryllium levels from all of these operations, so it is difficult to establish that no beryllium remains.

Recent medical monitoring determined that a few current PHMC employees at Hanford have become sensitized to beryllium. The fact that these employees are sensitized indicates that their bodies are more sensitive to the effects of beryllium than other workers. To minimize the hazards of beryllium exposure, it is essential that airborne and surface beryllium sampling be performed in any facilities which might have beryllium contamination to document the current potential for exposure.

Another reason to perform this characterization is to comply with current DOE beryllium requirements. DOE Notice 440.1 directs each site where beryllium exposure is possible to prepare a CBDPP. Hanford prepared such a document in March of 1998(Letter, Hank Hatch et al to John D. Wagoner, Chronic Beryllium Disease Prevention Program). Contained in the CBDPP was the requirement for “…identifying facilities where beryllium has previously been used and assessing the potential for exposure….” This characterization would thus satisfy the requirements of both DOE N 440.1 and the Hanford CBDPP.

3.2   Beryllium Usage at Hanford

Beryllium is a light metal which has been used for many years. At DOE sites, beryllium has primarily been used in construction of reactor fuel rods, where a beryllium alloy was utilized. Beryllium has also been used in non-sparking tools for use in hazardous applications. Smaller amounts of beryllium were used for research applications such as analytical chemistry standards preparation and pilot-scale testing.

Beryllium usage at Hanford began in about 1952, when it was originally used in fuel rod research applications. After it was determined that beryllium could be used in construction of nuclear fuel rods, its use expanded, and continued until about 1987.

Only a small number of Hanford facilities were directly involved in the production of nuclear fuel rods. However, other facilities were involved in beryllium activities including research, storage, and testing. Since the hazards of beryllium were known during the earliest beryllium usage at Hanford, precautions were taken to reduce worker exposure to beryllium. Beryllium usage was confined to certain areas within a facility, and industrial hygiene monitoring performed to determine beryllium levels. However, there are few recent monitoring results and almost no data relating to the level of cleanup performed after the beryllium operations were discontinued.

4.0   SURVEY METHODOLOGY

4.1   Objectives

There were five goals for this sampling effort. They were:

1. To determine the current levels of airborne beryllium contamination in selected facilities.

2. To identify readily accessible areas (i.e., floors, desktops, etc.) where beryllium contamination might be present.

3. To obtain a wipe sample from these areas where beryllium could be present that might be disturbed during “routine” activities, along with an area air sample to characterize the airborne hazard potential. Normal production, walk-through evaluations, secretarial work, and training were considered routine activities, while repairing ductwork, ceiling repair and replacement, and large equipment removal were not.

4. To generate a list of locations for each facility where beryllium contamination was suspected, but which were not sampled during this initial characterization effort. This would include crawlspaces, ventilation ductwork and other areas which could not be readily accessed. This list was prepared to assist in future sampling efforts.

5. To obtain additional information on beryllium for each facility that could be used to update our facility fact sheets. This information included discussions with facility managers, reviews of building drawings, and sampling results.

4.2   Project Personnel

The entire project was led by a senior industrial hygienist from Fluor Daniel Hanford, Inc. With 27 years of experience in hazard recognition and control, the Fluor Daniel Hanford Project Manager was responsible for overall conception of the approach and supervised contractor implementation of the study. He selected the contractor to lead the data collection effort, arranged for sample analysis with the analytical chemistry laboratory, and provided guidance on key issues of strategy for the wipe and air sample collection. The Fluor Daniel Hanford Project Manager authored the major sections of the final report and conclusions.

The project technical team included a project manager and field team leader from Radian International, and sampling technicians from Radian and a subcontracted technical services firm. The Radian Project Manager was a Certified Industrial Hygienist (CIH), as well as a Certified Safety Professional, with over 18 years experience in industrial hygiene, including having lead comprehensive beryllium assessments of DOE facilities at Rocky Flats and Los Alamos. The Rocky Flats project alone included collection of over 1,500 wipe samples in 35 buildings for beryllium, and over 100 air samples. The Radian project manager developed project plans, selected the field team, oversaw data collection and analysis, and prepared the final report for those projects; he had also managed a project to characterize beryllium hazards in a former beryllium processing facility, collecting over 400 environmental samples in that effort. For the Hanford beryllium assessment, the Radian Project Manager developed project plans, selected the field team, and laid the preliminary groundwork for successful data collection. He provided review of the data, assisted with interpretation of results, and peer-reviewed the final report.

Assisting with the project, first as the field team leader and then as project manager, was another CIH from Radian International. With over 15 years experience in industrial hygiene and environmental projects, including leading several large exposure assessments for toxic chemicals in a variety of occupational settings, this individual had substantial expertise in chemical measurement techniques, air monitoring, data interpretation, and planning and executing field programs. For the Hanford beryllium assessment, the field team leader assisted with the project management functions, oversaw data collection and analysis, and participated in the preparation of the final report.

A Professional Engineer with Radian International prepared the Project Quality Assurance Plan. With over 18 years experience in environmental engineering, including preparation of project sampling and QA plans, such as an assessment of beryllium contamination at DOE facilities in Los Alamos, this person developed the standard operating procedures for the Hanford beryllium study, as well as QA review of the analytical and field data.

The technicians on this project had backgrounds totaling over 12 years of industrial hygiene sampling and chemical analysis, and a proven track record in safe collection of scientific data according to detailed sampling and analysis plans.

Facility personnel provided critical support for the project team. These included industrial hygienists from the organization responsible for building activities, as well as on-site staff responsible for day-to-day operations or knowledgeable about past operations. In many cases these were first-line managers with detailed knowledge about processes and activities from up to 20 years of working on site, but in some cases, the staff had essentially no knowledge about past activities in the facilities, and had become occupants of the building only long after all beryllium operations had ceased.

4.3   Training and Oversight

A training log of all field personnel was maintained on site during the project to document that all field personnel met minimum training requirements. This project training included:

• Project Orientation
• Hazard Communication for Beryllium Hazards
• Wipe / Air Sampling Methodology
• Respiratory Protection
• Project Health and Safety Plan
• Safe Ladder Use
• Hanford General Employee Training (including alarms and security)
• Radiation Worker II, and
• Building-Specific Training for Buildings 324 and 324, K-basin, and 200 Area.

In addition, a kick-off meeting was held with field personnel on June 12, 1999. During the kick-off meeting, personnel were instructed on how to:

• complete field documentation for the project,
• select sample locations,
• calibrate air sampling pumps,
• set-up air sampling pumps, and
• collect wipe samples.

Besides this training, the field team leader was current in HAZWOPER and 8-hr supervisor training as well as CPR and First Aid. The assistant field team leader was current in HAZWOPER and CPR/First Aid.

4.4   Sampling Strategy

Preliminary characterization efforts by Fluor Daniel Hanford reviewed historical records for each facility at Hanford, assessing the building construction date, purpose, occupying organizations and missions. Records were searched for any documentation of the use of beryllium-containing materials or processes associated with beryllium for each facility, and any available beryllium sampling results. These data were followed up with interviews with facility representatives. This review allowed the elimination of most of the facilities at Hanford from the study because there was no evidence of beryllium presence, at any time during past or current operations. In addition, areas in suspect facilities were identified where beryllium was used in the past. Two categories were then defined for those facilities where beryllium usage was suspected or known. These were:

Category 1 Area:	A facility or part of facility where beryllium operations were known to have been performed, or where past sampling data indicates significant beryllium concentrations; and
Category 2 Area:	A facility or part of facility where beryllium operations were not performed, based on a review of building operations, or where past sampling data indicates insignificant beryllium levels.

For facilities where beryllium operations were known to have occurred, it was possible to isolate the areas where beryllium was used (Category 1) based on past process knowledge and facility documentation. The remainder of the facility could in most cases be classified as a Category 2 area (for example, when an office area adjoined a machine shop or laboratory and the two were clearly separated by change room and traffic pattern, ventilation systems, etc). For facilities where beryllium usage was possible but could not be confirmed, the entire building was considered a Category 2 area. The result of this system was that some facilities were divided into two areas (Category 1 and Category 2), while other facilities were treated as one area (either Category 1 or 2).

A nonrandom (biased) sampling strategy was applied to Category 1 areas. A stratified random sampling strategy was applied to Category 2 areas. Some facilities contained both Category 1 and Category 2 areas. All Category 1 and Category 2 areas in a facility were grouped together prior to sampling, so that a given facility has at most two sampling areas.

In each Category 1 area, wipe sample locations were distributed within each area, focusing especially on horizontal surfaces near operations where beryllium activities were thought to have been performed. For example, if beryllium-containing materials were located in a drawer, a wipe sample was collected in the drawer, as well as at nearby locations where beryllium contamination might occur. The remaining sample locations were distributed throughout the balance of the area. For Category 2 areas, the total facility was subdivided into discrete areas, and the wipe sample locations distributed relatively evenly among the areas. In both Category 1 and Category 2 areas, the samples were collected from surfaces most likely to: 1) have beryllium contamination, 2) collect dust, and 3) pose a potential contact hazard. Areas which the industrial hygienist judged to have a reasonable chance of beryllium contamination, but which could not be easily sampled, were logged for future reference. Such areas included ventilation duct interiors, suspended ceilings, crawlspaces and other inaccessible areas. Air samples were located in each Category area of a facility to represent general area air quality. Air sample locations were exposed to air movement, and in or near commonly occupied areas and hallways.

The number of samples for a given Category was determined by statistical analysis. For all of the areas of a facility in Category 1, at least 59 wipe samples were obtained. For all of the areas of a facility in Category 2, at least 29 wipe samples were obtained. Thus, the number of wipe samples at a facility was generally 29, 59 or 88 depending on whether the facility contained both Category 1 and Category 2 areas. At least two air samples were collected in each Category area of a given facility.

4.5   Sampling Methods

Prior to sampling, the industrial hygienist met with cognizant facility representatives with process knowledge. This review was performed to determine the areas staff routinely access and could thus be exposed, where sampling should be performed, and also where wipe sampling cannot be performed, but where beryllium may be present. Areas with other hazards requiring PPE that were protective for beryllium (such as those contaminated with airborne radioactive particulate) were not sampled, even if beryllium was believed to be present, because no exposure was possible if existing PPE requirements were followed.

At each location to be wipe sampled, a note-taker drew a sketch of the area on a sample collection log sheet and noted the sample location on a master floor plan map of the facility. The sampler donned clean latex gloves and a fresh cardstock template with a 10 x 10 cm square cutout was placed on the surface to be sampled. If there was insufficient space to place the template on the surface, or the surface was discontinuous (for example, when sampling an exhaust duct grille), the sampler visually estimated the 100 cm² area and proceeded with sampling, noting the estimate on the sampling log sheet. An unopened PACE wipe premoistened with 1% benzalkonium chloride was then opened completely and then folded into a quarter-folded pad (which just fit in the hand). The template opening was wiped vertically, proceeding from left to right and folding the pad in half with each wipe to expose fresh surface and contain the wiped surface within the fold. After wiping the entire surface vertically, the bottom and right edge of the wiped area was wiped horizontally and vertically once again, this time overlapping the template face to adsorb any dust that had adhered to the template. The wipe was folded in half again and inserted into a precleaned 40-ml glass sample vial with a screwtop cap. The wipe touched no other surfaces. The vial was prelabeled with the unique sequential sample number, triplicate copies of which were affixed to: 1) on or adjacent to the sample location, 2) the sample collection log sheet, and 3) the chain of custody for the sample batch. Field duplicates were obtained immediately adjacent to the samples, at a rate of five percent of the samples. Field blanks were obtained by handling the wipe as if sampling, but wiping only the interior edges of a fresh cardstock template. Field blanks accompanied the samples from the site to the lab.

At air sampling locations, a tripod or other support was utilized to position the sampler at a height of approximately five feet. Monitoring locations were selected away from walls and other air movement restrictions. The sample media was a 37-mm mixed cellulose ester filter with backup pad pre-mounted in a three-piece clear polystyrene air sampling cassette. Sample identification labels were used as described above for the wipe samples (no label was affixed to the sample location, but it was shown on the facility map). A programmable personal sampling pump with pressure drop compensation was used. The two cassette plugs were removed just prior to calibration, which was done using a frictionless piston (BIOS Drycal). The calibration target flowrate was approximately 3.5 liters/minute, measured through the sampling cassette. After sampling, the flowrate was remeasured. Temperature was obtained at the location and time of the flow measurement, and ambient barometric pressure was obtained from the Hanford meteorological station. Sample durations were generally 400 minutes, unless logistical constraints required a shorter sample. Field duplicates were obtained immediately adjacent to the samples, at a rate of five percent of the samples. Field blanks were collected by removing plugs from a cassette for a minute or so, then resealing it. Field blanks accompanied the samples from the site to the lab.

Personal breathing zone samples were obtained from one sampling technician per day, covering the entire sample collection period. The equipment and methods used were the same as for the area air samples. Sample durations were determined by the length of time spent collecting samples that day. If more than one area or facility was wipe sampled in a day, the personal exposure sample collection continued across all areas sampled, using the same filter.

4.6   Analytical Methods

Wipe samples were submitted to the WSCF analytical chemistry laboratory in Richland, Washington, operated by Waste Management Federal Services Hanford, Inc. The analytical method used was WSCF method LA-345-400, which is based on NIOSH method 7300 and EPA method 747-R-92-006, using a preparation consisting of dry ashing and acid digestion of the wipe sample, followed by inductively-coupled plasma (ICP) atomic emission spectroscopy. Samples were processed batch-wise with appropriate laboratory quality control samples for each batch. These consisted of reagent blanks, sample duplicates, and independently-prepared check standards. The detection limit for the wipe sample analysis was 0.5 micrograms (µg) per wipe sample. Each wipe was used to sample 100 square centimeters, thus the method detection limit was 0.5 µg per 100 cm².

Air samples were also analyzed by the WSCF laboratory using sample preparation consisting of dry ashing and acid digestion, but with the ICP method modified to include a mass spectrophotometry detector to achieve a lower detection limit. The method used is a combination of WSCF method LA-505-460 and NIOSH method 7300. An identical set of laboratory quality control samples was processed with each batch of air filters analyzed. The method detection limit using this procedure was 0.005 µg per air sample. With the nominal room air sample volume of 1.4 cubic meters (m³), the method detection limit for the typical room air sample was 0.0036 µg/m³. Correspondingly, personal (breathing zone) samples to assess the field team’s compliance with permissible exposure limits while wipe sampling had an average volume of 0.53 m³, thus the method detection limit for the average breathing zone sample was 0.009 µg/m³.

4.7   Current Standards and Criteria

Table 1 shows current standards applicable to the Hanford site, including the Permissible Exposure Limits (PELs) defined by OSHA and the Washington Department of Labor and Industries (L&I), DOE, and the Hanford site Occupational Exposure Limit (OEL) established by the PHMC. Also shown are the surface contamination criteria used to define whether the facility is contaminated with beryllium, for the purposes of this study.

Table 1. Criteria for Airborne and Surface Beryllium Contamination

Relevant Standard	8-hour TWAb (µg/m3)	Surface Contamination (µg/100 cm2)
OSHA PELa	2	NAc
WA L&I PELd	2	NA
ACGIH TLVe	2	NA
NIOSH RELf	0.5	NA
DOE proposedg	0.5	3
Hanford OELh	0.2	1

^aOccupational Safety and Health Administration Permissible Exposure Limit
^bTime Weighted Average
^cNot Applicable
^dWashington Department of Labor & Industries Permissible Exposure Limit
^eAmerican Conference of Governmental Industrial Hygienists Threshold Limit Value
^fNational Institute for Occupational Safety and Health Recommended Exposure Limit
^gDepartment of Energy proposed Administrative Exposure Limit
^hProject Hanford Management Contract Hanford Site Occupational Exposure Limit (and Surface Contamination Limit for wipe samples)

The surface contamination criterion was derived from the Hanford CBDPP and should be evaluated in the context of the background level of beryllium in the Tri-Cities area, defined by the Washington Department of Ecology as 2 mg/kg in soils for the Yakima Basin¹.

To aid in classifying sampled facilities, a set of contamination classes was developed to assign a relative contamination value to each of the sampled facilities. While the sampling program assessed the extent of both airborne and surface beryllium contamination, it is not immediately obvious what these numbers mean or how they relate to each other. For example, does the greater concern arise from measurable airborne beryllium contamination or measurable surface beryllium contamination? By assigning contamination classes based on both the airborne and surface contamination results, the various areas and facilities can be compared, and areas with the highest contamination can be prioritized. Five contamination classes were defined as follows:

• High—This class includes an area or facility where the measured airborne beryllium level for at least one sample was above the current OSHA/DOE allowable level of 2.0 µg/m³. Surface contamination levels were not a defining criterion in this classification.

• Significant—Facilities in this class had at least one airborne contamination sample result between the Hanford Action Level of 0.2 µg/m³ and the OSHA/DOE allowable level of 2.0 µg/m³. Surface contamination levels were not a defining criterion in this classification.

• Low—Facilities in this class had at least one airborne contamination sample result above the detection limit of the sampling method (~0.01 µg/m³) but all results were below the Hanford Action Level of 0.2 µg/m³. The surface contamination levels were not a defining criterion in this classification.

• Slight—At facilities in this class, all airborne contamination sample results were below the limit of detection of the sampling method, but at least one of the surface contamination levels was above the Hanford Surface Contamination Limit of (1.0 µg/100 cm²).

• None—At facilities in this class, results for all airborne contamination samples were below the limit of detection of the sampling method, and all surface contamination samples were below the Hanford Surface Contamination Limit. Thus, no significant beryllium contamination was observed.

Table 2 summarizes the criteria defining each of the contamination classes. The airborne beryllium criteria are defined as the equivalent 8-hour concentration in the air, should actual sample results be of a longer or shorter duration.

Table 2. Contamination class criteria.

^aNot Applicable

5.0   RESULTS

5.1   Data Quality

Data quality was assured by applying the quality assurance/quality control (QA/QC) program described in the Work Plan for this project. The QA/QC program was divided into four major elements including:

1. Strict observation of decontamination, sampling, and analytical procedures;

2. Collection and evaluation of field QC samples;

3. Documentation of project activities; and

4. Training and oversight of field and other project team members.

Evaluation and conclusions for elements 1, 2 and 4 is described in the remainder of this section. Documentation of project activities is discussed within each of the remaining elements.

5.2   Observance of Procedures

Verification that field procedures were strictly followed was determined through reviewing the field logs that described the days activities, reviewing the chain-of-custody (COC) forms that indicated sample possession and holding times, and evaluating the laboratory reports. In addition, the Fluor Daniel Hanford Project Manager independently reviewed field procedures during one of the sampling events.

Sampling procedures were modified slightly when wipe samples were taken from irregular surfaces. In some cases the template could not be properly applied to the area wiped. In this situation, the area wiped was approximated to 100 cm² to the best judgement of the sampler and this diversion was noted in the field log. Approximately 5 to 10% of the wipe samples were collected in this manner. Wipe samples that were collected without a template and which indicated the presence of beryllium are shown in Table 3 below.

It is possible that samples # 315 and # 1492 are false positives relative to the 1.0 µg/100 cm² threshold criteria; however, the results of the remaining samples are far enough removed from the threshold criteria that the sampling procedure would not have had an impact on their classification.

All samples were analyzed within the required 180-day holding time as indicated on the COCs and laboratory reports.

5.3   Quality Control Sample Results

Field QC samples collected in support of this survey included field blanks and duplicates. The purpose of the field blanks is to verify that the decontamination and sample storage procedures were adequate for preventing cross contamination. Additionally, field blanks help verify whether there are any cross contamination concerns during laboratory analysis activities. Field blanks are prepared in the field in the same manner as a regular sample except that it is not used to wipe a surface.

5.3.1   Wipe Samples

A total of 1,337 wipe samples, 80 field blank wipes, and 75 duplicate samples were collected. Therefore, the requirements for collecting at least one field blank and duplicate for every 20 regular samples were met. No beryllium was detected in any of the field blanks. It can therefore be concluded with a high degree of confidence that cross contamination or inadvertent contamination of samples did not occur.

Duplicate wipe samples were collected by wiping an area adjacent to the area of the original sample. In all cases except one, both the original sample and duplicate sample did not contain detectable quantities of beryllium. In this one case original sample contained 1 µg/100 cm² and the duplicate contained 0.7 µg/100 cm². The relative percent difference (RPD) for these results was calculated to be:

V1 – V2        
RPD = -------------------- x 100 = 35%
(V1 + V2) ÷ 2    

These samples were collected from the top of a light fixture on the ground level of Building 334A. Because of the wide variation possible from one surface area to another, even for areas adjacent to each other, a wide variation between duplicate samples is also possible. A particle of beryllium shaped as a sphere with a diameter of 0.1-mm is equivalent to about 1-µg of beryllium. Therefore, a single particle can make the difference between detecting and not detecting beryllium. In consideration of this, an RPD of 35% demonstrates good sampling precision.

A concern was raised by the laboratory concerning interferences from high levels of calcium and iron during the beryllium analyses. High concentrations of calcium and iron could mask samples with low levels of beryllium (i.e., < 1.0 µg per wipe). This concern was identified, evaluated, and resolved during the final validation of the analytical data. Resolution included the re-analysis of certain samples containing high levels of calcium and iron by inductively coupled plasma – mass spectroscopy (ICP-MS), which is not subject to interferences from calcium and iron. As a result of this evaluation, it was concluded that all reported results should accurately reflect actual beryllium concentrations. Results from this reanalysis are maintained with the project files.

The laboratory prepared and analyzed numerous spike samples to evaluate percent recoveries. Out of 88 spikes analyzed, 9 had percent recoveries less than 85% and none had percent recoveries greater than 115%. The average percent recovery was 91.4% and the average relative percent difference (RPD) was 3.2%. There were two high RPDs that were greater than 10%. In both of these cases it was because of poor percent recovery on the duplicate spike sample.

The nine lowest percent recoveries were 74.1, 80.0, 80.8, 80.9, 81.0, 82.8, 83.9, 84.0, and 84.3%. Although these numbers are less than the recommended 85% they are relatively close to the recommended minimum. Based on this evaluation, analytical results that are 26% less than the threshold criteria could possibly have exceeded the threshold criteria. The only sample that fits this criteria is sample # 493 that was retrieved from a light fixture in Building 334A (result was 0.74 µg/100 cm²). Therefore, results relative to the threshold criteria are considered acceptable except perhaps for this one analysis.

5.3.2   Air Samples

A total of 62 area air, 29 breathing zone, 13 duplicate area air, and 67 air field blanks were collected. The collection of field blanks and duplicate samples exceed minimum requirements (i.e., at least 5% of total). The typical detection limit for beryllium air samples was 0.005 µg/L. Beryllium was not detected in any of the air samples or associated QC samples. Because no beryllium was detected, the precision of measurement cannot be quantified; however, qualitatively it may be stated that no concerns with measurement were observed based on the QC sample results.

To further verify sample accuracy, some air samples were analyzed by an independent laboratory (DataChem). None of the results independently evaluated contained detectable quantities of beryllium.

To verify that the independent laboratory had proper quality control for their analyses, WSCF prepared 8 spike samples for analysis. Table 4 provides the results for these analyses. All percent recoveries were within the 85 to 115% range; therefore, the analytical results from this laboratory should be considered valid.

Table 4. Percent Recoveries for Independent Laboratory

5.4   Training and Oversight

Project staff were trained in the study plan and sampling procedures, and were appropriately trained to ensure health and safety during the fieldwork, in accordance with the project planning requirements contained in the project health and safety plan and sampling plan. Only personnel who received the appropriate training were allowed to collect samples and complete the required field documentation.

5.5   Sampling Results

As noted above in Methodology, a facility may either consist of one or two areas depending on the potential for beryllium usage in each area within the facility. The air and wipe sampling results were used to assign each area sampled to a contamination class. Thus, each facility is assigned to either one or two contamination classes depending on whether it was subdivided into one area or two. Table 5 summarizes the final contamination classes for each facility sampled.

Table 5. Facilities by contamination category.

Many of the facilities were divided into two areas (Category 1 and Category 2) for sampling purposes as discussed under Methodology. However, to simplify reporting the sample results, the two areas were combined unless the sampling results differed between the two areas. The 25 facilities sampled and a summary of the overall sample results are shown in Table 6.

Table 6. Sampling Results.

Facility	Area Category	Number of Wipe Samples	Number Above Hanford Surface Limita	Highest [Be] (µg/100 cm2)	Number of Air Samples	Air Samples Above Detection Limit
1706KE	1	59	0	<0.5	2	0
209E	2	29	0	<0.5	2	0
222T	2	29	0	<0.5	2	0
231Z	1&2	88	0	<0.5	4	0
234-5Z	1&2	87	0	<0.5	2	0
272AW	1	60	0	<0.5	2	0
272WA	1	59	0	<0.5	2	0
272W	1	59	0	<0.5	2	0
2101HV	1	59	0	<0.5	2	0
2703E	2	29	0	<0.5	2	0
303F	2	29	0	<0.5	2	0
303K	2	29	0	<0.5	2	0
303M	2	29	0	<0.5	2	0
304	2	30	0	<0.5	2	0
306E	1	60	0	<0.5	2	0
309	1&2	88	0	<0.5	4	0
313	1	59	1	~0.5	2	0
313	2	29	0	<0.5	2	0
324	2	29	1	1.1	2	0
327	1&2	88	0	<0.5	4	0
328	1&2	88	0	<0.5	4	0
333	1	74	14	11	2	0
333	2	29	0	<0.5	2	0
334A	2	29	6	1.1	2	0
3706	1	60	0	<0.5	2	0
3712	2	29	0	<0.5	2	0
3716	2	29	0	~0.7	2	0

^aHanford Surface Contamination Limit (1 µg/100 cm²)
< = less than
~ = approximately

6.0   DISCUSSION

A total of 62 air samples were collected in these 25 facilities to evaluate airborne beryllium levels. All 62 of these samples indicated airborne beryllium levels that were less than 0.008 µg/m³, the limit of detection of the sampling method. Since this detection limit is 1/25^th of the Hanford action level of 0.2 µg/m³, there is no indication of exposure to airborne beryllium during normal facility operations.

A total of 1,337 wipe samples for beryllium surface contamination were collected in the 25 facilities. Of these samples, 1,313 samples (98.2%) were below the detection limit of the sampling method, 0.5 µg/100 cm². This indicates that, overall, the facilities had very little beryllium surface contamination.

A total of 24 surface contamination samples were at or above 0.5 µg/100 cm². The levels ranged from 0.5 µg/100 cm² to 11 µg/100 cm². As noted under Current Standards and Criteria above, the limit for surface beryllium contamination at Hanford is 1.0 µg/100 cm² as specified in the Hanford CBDPP. This sampling effort was thus able to detect surface beryllium contamination levels that were below the Hanford limit. In fact, 10 of the 24 samples that were above the detection limit were at or below the Hanford limit. It is possible that the beryllium levels observed in some of these samples resulted from large accumulations of background dust that was not high in beryllium. This observation is based on the fact that some of the wipe samples had very large amounts of dust. Although the sampling method is efficient for measuring beryllium, it does not measure the total dust amount on a surface, so the beryllium concentration in the dust can not be determined. For the 10 samples that were above the detection limit, no actions would be required based on these samples since they were not above the Hanford limit.

The fourteen samples that were above the Hanford surface contamination limit are shown in Table 7. These samples came from three buildings (324, 333 and 334A). Each of the these facilities is discussed in detail below:

Table 7. Samples with Beryllium Levels above Hanford Contamination Limit

6.1   Building 324

A total of 29 wipe samples (plus two duplicates) and two air samples (plus two duplicates) were obtained in Building 324 (the Chemical Materials Engineering Laboratory). The air samples were obtained at two locations: in the southeast corner of Room 137, and at the junction of corridors 21 and 22, outside Room 218. All air results were below detection limits. In this 3-story building, 15 wipe samples were obtained on the first floor, 12 on the second floor, two on the third floor and two in the basement. A variety of interior surfaces were sampled using the wipes, including seven floor areas, three exhaust vent exteriors, three supply vent exteriors, three light fixtures, four equipment surfaces, four furnishings, and four miscellaneous horizontal surfaces (such as electrical conduits and door jambs). All sample results were below detection limits with the exception of one wipe sample from the top of a fluorescent light fixture in Room 309, the Grout Area on the third floor, which was found to be 1.1 µg/100 cm².

In the Room 309 area, grout formulations are prepared for pilot-scale testing. There is little information available defining the past uses of this portion of the building, and why measureable beryllium might be found there. At this time, information has not been found to rule out current or recent operations in the area as a source of beryllium. Based on the single positive result, which was only 10% above the Hanford surface contamination limit and the lack of explanatory information, further evaluation of the source and extent of beryllium contamination on the third floor of Building 324 is warranted. Although the surface beryllium levels are very low, and employees working in the area wear respiratory protection during dusty operations, additional sampling would be prudent to determine the extent of the contamination.

6.2   Building 333

A total of 103 wipe samples (plus seven duplicates) and five air samples (plus one duplicate) were obtained in Building 333 (the former Fuels Manufacturing Building). The air samples were obtained at several locations in this two-story building: At the southeast corner of storage room A015; outside the men’s restroom in the West Mezzanine offices; directly outside the locked ‘Beryllium Maintenance Room’ on the main floor; and in the south third of the East Mezzanine. All air results were below detection limits. A variety of interior surfaces were wipe sampled, including 34 floor areas, eight exhaust vent exteriors, two supply vent exteriors, six light fixtures, 19 equipment surfaces, 17 furnishings, and 17 miscellaneous horizontal surfaces (such as ledges and support structures).

The building was broadly divided into a Category 2 area which was comprised of second-floor office areas and mezzanines, where beryllium was not expected, and a Category 1 area which contained all industrial production areas where beryllium was used, and ancillary rooms on the first floor where foot traffic might have spread potential beryllium contamination. Of the 103 samples, 29 were obtained in the Category 2 area and 74 in the Category 1 area. Special emphasis was made on sampling in the immediate vicinity of the locked Beryllium Maintenance Room which was suspected of gross beryllium contamination and had not been opened in over a decade.

All wipe and air results from the Category 2 area (second floor mezzanines and offices) were below detection limits. These areas do not show evidence of beryllium contamination, and may be considered clean in that regard.

Category 1 area results had detectable levels of beryllium in a number of the wipe samples, but not in the air samples. Measureable levels of surface beryllium contamination ranging from 0.61 to 6.4 µg/100 cm² were found in the Stepcut Area (Room A016) on floors, light fixtures, furnishings and equipment. Detectable levels were also found on floors, in marked (beryllium hazard) cabinets, and on storage shelves in the End Cap Braze Area, ranging from 1.4 to 11 µg/100 cm². In the End Weld Area (A009), measureable beryllium surface contamination ranged from 1.2 to 4.6 µg/100 cm² on fluorescent light fixtures and duct exteriors marked “beryllium hazard”. Finally, a floor sample, vent and duct outlet samples outside the Beryllium Maintenance Room had measureable beryllium surface contamination ranging from 0.7 to 7.4 µg/100 cm². All surfaces in the immediate vicinity of these areas should be considered to have similar levels of surface contamination, unless future sampling demonstrates levels below the Hanford Surface Contamination Limit. The unopened Beryllium Maintenance Room should be considered grossly contaminated until proven otherwise.

6.3   Building 334A

In this former waste processing facility, a total of 29 wipe samples (plus two duplicates) were obtained, 24 from the main floor and five in the large sump area beneath. Of the wipe samples, 10 were obtained from various floor areas, five were obtained on fluorescent light fixtures and 11 were obtained on miscellaneous horizontal surfaces such as ledges and support structures. Two air samples were collected on the main floor.

No detectable beryllium was found in the air samples, but five wipe samples (and one wipe sample duplicate) had measureable beryllium. The levels ranged from 0.5 to 1.1µg/100 cm², with only one sample slightly above the Hanford surface contamination limit of 1.0 µg/100 cm². This sample was obtained from the top of a fluorescent light fixture. This facility was considered a Category 2 facility prior to sampling, because the building had been cleaned and almost all internal equipment and furnishings removed. This building is kept locked, and personnel only enter the facility on an average of once a week. Because only one sample was slightly above the Hanford surface contamination limit, it is highly unlikely that any significant exposure would occur from the light fixture contamination. However, further activities within the building should consider the fluorescent light fixtures as being slightly contaminated, along with elevated structural surfaces at or above the light fixture height, until additional sampling has been performed to evaluate the extent of the contamination.

6.4   Unsampled Areas

Table 8 summarizes key areas in sampled facilities where wipe samples were not obtained, but where beryllium contamination is considered possible.

Table 8. Unsampled areas with possible beryllium contamination.

Facility	Area Category	Potential Beryllium-contaminated Area
1706KE	1	Exhaust ventilation ductwork formerly serving fume hoods and equipment in Labs number 2 and 4. Fume hood interior and exhaust in lab 1A. – ANRA*: area inaccessible
209E	2	Non-office areas within the facility, including the Critical Mass Laboratory and associated radioactive contamination areas. – ANRA: other airborne hazards present.
222T	2	Process and fume hood exhaust ducts in former laboratories. – ANRA: area inaccessible.
231Z	1	Process exhaust ducts and filter boxes in Room 202 (duct level), especially those serving rooms 23, 24, 34, 39 and 49. – ANRA: area inaccessible
231Z	2	NAa
234-5Z	1&2	Interiors of gloveboxes and associated exhaust ducts in Room 179 of Plutonium Process Support Labs, especially glovebox 179-4. Interior of standards cabinet in Standards Lab, Room 221E; Interiors of storage cabinets and gloveboxes in Analytical Lab, Room 157, especially interior and exhaust ducts servicing glovebox 157-2. Process exhaust duct and filter box interiors in Rooms 262 and 308 (duct level), which serve Rooms 157, 179, and 221E, as well as any duct level surfaces above 8 feet. – ANRA: area inaccessible. Beryllium contamination in exhaust ducts servicing Tool Crib Room 194A is possible, but not likely. – ANRA: area inaccessible.
272AW	1	Interiors of exhaust ducts servicing Tool Crib, Supply Room, HPT Area, Electrical Shop, and Mechanical Maintenance Area. – ANRA: area inaccessible.
272WA	1	Interiors of exhaust ducts servicing Tool Crib, Maintenance Supply Shop, Electrical Shop, Grinding Area, Maintenance Shop, and Rooms 25-1 through 25-3. – ANRA: area inaccessible.
272W	1	Interiors of exhaust ducts in NW corner of main shop on north wall. – ANRA: area inaccessible.
2101HV	1	NA
2703E	2	Interiors of exhaust ducts servicing Tool Crib and Machine Shop. – ANRA: area inaccessible.
303F	2	Interiors of remaining pumps and basins. . – ANRA: area inaccessible.
303K	2	NA
303M	2	NA
304	2	Interiors of gas heater and exhaust ducts. ANRA: area inaccessible.
306E	1	Interiors of exhaust ducts servicing Rooms 165 and 180, and interior of beryllium storage cabinet in Bay 2. –ANRA
309	1&2	Interiors of ductwork servicing Rooms 121, 212, 220, 300, 304, and adjacent areas. – ANRA: area inaccessible.
313	1&2	Interiors of beryllium storage cabinet and machinery in EDL. Interiors and exteriors of exhaust ducts servicing Engineering Development Lab, Hot Lab, and Billet and Components Inspection.- ANRA
324	2	Interiors of exhaust ducts servicing hoods and gloveboxes in Rooms 146 and 147; Interiors of hot cells and associated exhaust ducts. – ANRA: area inaccessible
327	1&2	Interiors of exhaust ducts servicing Rooms 15, Machine Shop, Hot Cells, and Canyon. Machine Shop equipment interiors. Interiors of Hot Cells, exhaust hood in Room 15, and filtration units servicing Canyon. – ANRA: area inaccessible.
328	1&2	Interiors of machinery in Machine Shop and exhaust ducts servicing Room 328A, Machine Shop, Pipefitting Shop, and adjacent areas. – ANRA: area inaccessible.
333	1&2	Interior of Maintenance Repair Room. Interiors of machinery and storage cabinets in and exhaust ducts servicing End Braze, End Weld, Step Cut, Chem Bay, Maintenance Repair, and adjacent areas. Saw, Lathe, and Press rooms, including the interior and exterior of service exhausts. – ANRA: area inaccessible.
334A	2	Surfaces above light fixtures. – ANRA: area inaccessible
3706	1	Interiors of exhaust ducts servicing Rooms 3, 102, 112, 114, 210, 226, and 228, which all contain lab hoods. This includes the attic area through which the ductwork runs. – ANRA: area inaccessible.
3712	2	NA
3716	2	Structural supports and equipment above 9 feet elevation. – ANRA: area inaccessible

^aNA--Not Applicable, all suspect areas sampled.
*ANRA--Area not routinely accessed.

6.5   Limitations on sampling results

This project sampled extensively in areas where beryllium contamination was considered probable, and in those areas where beryllium contamination was considered possible but unlikely. The sample design was planned to be able to say that 9 out of 10 samples obtained in the future will be below the highest concentration this study found in a facility, 95 times out of 100. In spite of this effort, it must be recognized that surface contamination can vary widely, even in areas separated by only a few centimeters. This is a function of the uneven distribution of both dust and beryllium content of the dust.

This study concludes that the presence of detectable levels of beryllium in wipe samples is reason to consider the potential for a beryllium exposure hazard to personnel, but the presence of beryllium contamination found in a wipe sample does not quantitatively relate to the exposure hazard. It may be that a single shaving of beryllium metal is present in a wipe sample, but if that shaving is not inhalable, there is no immediate hazard.

The air samples were obtained in areas where the industrial hygienist believed facility personnel were most likely to have potential exposure to beryllium. Unless the background facility data leading to this conclusion was inaccurate or incomplete, airborne beryllium levels in other areas of the facility should not be higher than the sample results. However, any air sample only represents the air in the facility at the time of the sampling. Future conditions could arise that cause a latent source of beryllium dust to contaminate the room air in a facility, but as long as no latent sources of airborne beryllium are activated, beryllium levels greater than those found in this study are not considered likely for routine activities.

7.0   CONCLUSIONS

Based on the results of this sampling, the following conclusions can be made:

1. No measurable airborne beryllium contamination was observed in any of the 25 facilities sampled for beryllium. This indicates that the background beryllium exposure level is less than 0.008 µg/m³, which is the detection limit of the sampling method. None of these facilities should pose a risk to employees entering the facility if the activities do not disturb settled dust in the facility.

2. In 22 of the 25 facilities sampled, surface beryllium contamination levels were either nondetected or below the Hanford surface contamination limit of 1.0 µg/100 cm². These facilities do not currently present a beryllium risk to employees performing routine work in the facilities even if they do disturb the settled dust in the facilities.

3. One wipe sample out of 29 collected from the 334A facility exceeded the Hanford surface contamination limit of 1.0 µg/100 cm². However, this sample was only slightly above the limit (1.1 µg/100 cm²), and this facility is locked and not routinely entered. As such, there is little chance of employees being exposed to elevated airborne beryllium levels in this facility, as they would need to disturb large amounts of dust to create measurable levels of airborne beryllium.

4. One wipe sample out of 29 collected from the 324 facility exceeded the Hanford surface contamination limit. However, this sample was only slightly above the limit (1.1 µg/100 cm²). Since this facility is currently in use, there is a slight potential for beryllium exposure in the area of the detected beryllium sample on the third floor, particularly if other surfaces with beryllium contamination are present in the vicinity.

5. All of the 29 wipe samples from the office area of the 333 building were below the Hanford surface contamination limit. This area does not currently present a beryllium risk to employees performing routine work even if they do disturb the settled dust in the facility.

6. Twelve of the 74 surface wipe samples collected from the process areas of the 333 building were above the Hanford surface contamination limit. All of these samples were in or directly adjacent to four areas where beryllium operations had been performed in the past (end weld, step cut, end cap braze, outside beryllium maintenance room). This indicates that low levels of beryllium contamination remain in the process areas of this facility. The beryllium maintenance shop has been closed since 1987 with no entry. This shop was not opened during this study, since it was not an area that employees routinely entered. However, wipe samples were collected from around the door and other entry points into the room, and two of these wipe samples showed levels above the Hanford surface contamination limit.

7. Because the sampling program was designed to assess contamination that might be encountered during routine activities, all of these facilities may still present a risk of beryllium exposure when nonroutine work is performed that affects the structure of the facility, in areas where beryllium is likely to be encountered. Nonroutine activities would include entering walls, removing ceilings, removing ventilation ducting, entering crawlspaces, moving large machinery or equipment, etc. Areas where beryllium is likely to be encountered are defined in the building-specific discussion in Section C, and in Tables 7 and 8.

8.0   RECOMMENDED ACTIONS

The following actions are recommended based on the results of this study:

1. Employees performing routine work in any of the sampled facilities except 324, 333 and 334A should not be exposed to beryllium. As such, no special precautions are needed when doing routine work and employees do not need to be monitored for beryllium exposure during those activities, or entered into a mandatory medical surveillance program.

2. Although low levels of beryllium contamination were found in the 334A facility, this building is currently locked and unoccupied. To ensure that beryllium surface contamination is considered prior to entry into the facility, each door into the facility should be posted to indicate the presence of beryllium surface contamination. Entry procedures for the facility should be reviewed and updated as necessary to ensure that an Automated Job Hazard Analysis (AJHA) is completed for each entry into the facility. This facility should remain locked, and an AJHA should be completed for each task that requires entry into the 334A building to ensure that the potential for beryllium exposure is considered..

3. Although only one surface beryllium sample from the 324 facility was above the Hanford surface contamination limit, the possibility exists that other locations within the facility also have elevated surface beryllium levels. The following actions are recommended to address this concern. First, post Room 309 in the 324 facility as have surface beryllium contamination. Analyze the grout material currently being used in the room to determine if it might be the source of the beryllium contamination, and review records of other grout materials that have been used in this room. Ensure that routine operations, such as cleaning or sweeping, are performed in a manner that minimizes the generation of airborne dust. Perform additional beryllium wipe sampling in this room to determine if additional areas are present with elevated surface beryllium contamination. Evaluate airborne beryllium levels in this room while operations are being performed using personal beryllium sampling. Conduct additional wipe sampling on the third floor of the 324 building outside Room 309 to determine if beryllium surface contamination is present in adjacent areas. Review the results of the above measures to determine if additional actions are necessary. Based on the low surface contamination level, which was only observed in one sample, and the lack of detectable beryllium in 28 other samples in the building, additional measures are not deemed necessary at this time.

4. Because of elevated beryllium surface contamination, each door into the 333 building should be posted to indicate the presence of surface beryllium contamination in the facility. The potential for beryllium exposure should be assessed using either surface wipe sampling or airborne personal sampling for each task performed in the process areas of the 333 building. Each of the areas where surface contamination was measured (end weld, step cut, end cap braze and outside the beryllium maintenance room) should be barricaded to prevent inadvertent entry. Because beryllium contamination was measured on the floor in some areas, the use of a high-efficiency particulate air (HEPA) vacuum should be considered for cleaning. For people who work routinely in these areas, their EJTAs should be reviewed and the potential for beryllium exposure considered. Prior to performing any activities that involve entry into the beryllium maintenance room, extensive wipe and air sampling should be performed to establish current beryllium contamination levels. An AJHA should be completed with industrial hygiene involvement for each task in the process areas of the 333 building to ensure that the potential for beryllium exposure is considered.

5. If non-routine work is performed in any of these 25 facilities, the potential for beryllium contamination needs to be considered as part of the work planning process. The AJHA should be utilized for this purpose in combination with the list of unsampled areas with potential beryllium contamination (Table 8). This would also apply to work in the office areas of the 333 building.

1 Washington State Department of Ecology. Natural Background Soil Metals Concentrations in Washington State. Publication 94-115. Washington State Department of Ecology. Olympia, WA. October, 1994.

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