Activity

Responsible Individual

Required Action

Ensure that:

• Due consideration has been given to beryllium  exposure reduction and minimization prior to initiating a new beryllium activity.
• The Beryllium Program subject matter expert (SME) is contacted to determine if the proposed activity level work (ALW) involving beryllium is covered under the scope of Sandia National Laboratories’ Chronic Beryllium Disease Prevention Plan (CBDPP) or constitutes a new beryllium activity.
• If the beryllium activity is considered new, a preliminary exposure assessment for the proposed activity level work is obtained from the Beryllium Program SME and/or the division ES&H team industrial hygienist.
• New beryllium activities are subjected to National Nuclear Security Administration (NNSA) Department of Energy (DOE) Sandia Site Office (SSO) review and approval.
• SF 2001-BEA, Beryllium Activity Form for DOE Approval is completed and provided to the Beryllium Program SME a minimum of 45 calendar days in advance of the scheduled activity.
• Additional information is provided upon request to the Beryllium Program SME or NNSA DOE SSO in order to facilitate the approval process.
• All applicable portions of this procedure are implemented prior to performing the proposed beryllium activity whether it is a new activity or it is currently covered under the scope of the CBDPP.

Activity

Responsible Individual

Required Action

Ensure that:

• Potential hazards associated with activity level work involving known or potential exposure to beryllium are identified, evaluated, and controlled.
• The division ES&H team industrial hygienist is contacted to perform an exposure assessment of potential hazards related to activity level work involving beryllium and to determine whether a beryllium operational area or beryllium contaminated building/area exists.
• Any control measures specified as a result of the industrial hygiene exposure assessment are implemented and maintained.
• The division ES&H team industrial hygienist is contacted to re-evaluate potential hazards associated with activity level work involving beryllium when a change in workplace conditions indicates a new or increased hazard exists.
• Beryllium-containing materials and other items, including beryllium articles (e.g., beryllium-containing non-sparking tools, excess beryllium alloy metal stock), are not used, re-applied or recycled unless a division ES&H team industrial hygienist has performed an exposure assessment and determined it poses no potential risk of exposure and no conditions are placed on its future use.
• The applicable portions of this procedure, based on the exposure assessment, are implemented (e.g., for operational areas, contaminated buildings/areas, technical work documents, waste disposal, release of equipment and other items, etc.).

Activity

Responsible Individual

Required Action

Ensure that beryllium-contaminated buildings/areas are controlled and/or managed using one of the three following approaches:

Option 1: Placing the beryllium-contaminated building/area in protective storage (mothballing) but maintain it so it can be decontaminated and used in the future or eventually razed by implementing the following actions:

• Demarcating the contaminated building/area from the rest of the workplace in a manner that adequately alerts workers to the boundaries of such areas.
• Posting the following sign SF 2001-BCB, Sign for Beryllium Contaminated Buildings and Areas,at each access point.
• Limiting access to authorized persons, i.e., those individuals with the necessary training and an appropriate need to enter.
• Keeping records of all individuals who enter the contaminated building/area. These records shall include the name, date, time in/out, and work activity performed.
• Contacting the division ES&H team industrial hygienist to perform an exposure assessment when any work (e.g., maintenance, inspections, repairs, etc.) is to be performed in the beryllium contaminated building/area.
• Establishing a temporary beryllium operational area if any work within the beryllium-contaminated building/area can expose workers to airborne beryllium as determined by the exposure assessment.
• Developing, implementing, and maintaining a technical work document (TWD) that addresses the applicable portions of this procedure and:
  • Meets the requirements of ESH100.1.WPC.1, Plan and Control Work and ESH100.2.GEN.3, Develop and Use Technical Work Documents.
  • Is provided to the Beryllium Program SME for review and approval prior to performing work when the TWD is initially developed, or when it is significantly changed.
• Contact the Beryllium Program SME if the contaminated building/area is to be razed (e.g., demolished).

Option 2:  In conjunction with the Beryllium Program SME, decontaminate the building/area to meet industrial hygiene decontamination verification criteria.

Option 3:  Establish the beryllium contaminated building/area as a beryllium operational area and implement all the applicable portions of this corporate procedure.

Activity

Responsible Individual

Required Action

Ensure that:

• A technical work document (TWD) is developed, implemented, and maintained that addresses the applicable portions of this procedure and:
  • Meets the requirements of ESH100.1.WPC.1, Plan and Control Work and ESH100.2.GEN.3, Develop and Use Technical Work Documents.
  • Is provided to the Beryllium Program SME for review and approval prior to performing work in a beryllium operational area when the TWD is initially developed, or when it is significantly changed.
• Beryllium operational areas are demarcated from the rest of the workplace in a manner that adequately alerts workers to the boundaries of such areas.
• SF 2001-LUN, Sign for Beryllium Operational Areas is posted at each access point.
• Access is limited to authorized persons, i.e., those individuals with the necessary training and an appropriate need to enter.
• Food, beverages, and tobacco products are not used, nor are cosmetics applied in beryllium operational areas.
• SF 2001-BER, Label for Containers of Beryllium, Beryllium Compounds, or Beryllium-Contaminated Clothing, Equipment, Waste, Scrap, or Debris, is affixed to all containers of beryllium, beryllium compounds, or beryllium contaminated protective equipment, clothing, waste, scrap, or debris.
• Members of the Workforce who perform beryllium activities  are identified as beryllium workers for training and medical surveillance purposes. Refer to sections on training and medical surveillance for additional requirements.
• Members of the Workforce are provided with personal protective equipment based on the exposure assessment.
• Personal protective equipment is provided to any Member of the Workforce requesting the use of personal protective equipment (including respiratory protection) for protection against airborne beryllium, regardless of measured exposure levels.
• Donning, doffing, handling, and storing practices are implemented for personal protective equipment use in operational areas that:
  • Meet the requirements of ESH100.2.IS.8, Assess Workplace Hazards and Provide and Maintain Personal Protective Equipment, and ESH100.2.IH.3, Control Inhalation Hazards Using Respiratory Protection.
  • Ensure personal protective equipment is appropriately used and maintained.
  • Prevent workers from exiting beryllium operational areas with contamination on their bodies or their personal clothing.
  • Prohibit the removal of beryllium from personal protective equipment and clothing by blowing, shaking, or other means that may disperse beryllium.
  • Prohibit laundering of beryllium-contaminated personal protective equipment and clothing unless authorized by the Beryllium Program SME.
  • Prohibit the removal of beryllium-contaminated personal protective equipment and clothing from beryllium operational areas, except for workers authorized to launder, clean, maintain, or dispose of the clothing and equipment.
  • Ensure personal protective equipment and clothing is cleaned, laundered, repaired, or replaced as needed to maintain effectiveness.
  • Ensure beryllium-contaminated personal protective equipment and clothing, when removed for laundering, cleaning, maintenance, or disposal, is placed in containers that prevent the dispersion of beryllium dust and the container is labeled with SF 2001-BER, Label for Containers of Beryllium, Beryllium Compounds, or Beryllium-Contaminated Clothing, Equipment, Waste, Scrap, or Debris.

Activity

Responsible Individual

Required Action

Ensure that:

• Surfaces are maintained below a removable beryllium contamination level of 3 micrograms of beryllium per 100 square centimeters (µg Be/100 cm2) during non-operational periods using acceptable housekeeping methods described in this section. This would not include the interior of installed closed systems such as enclosures, glove boxes, chambers, or ventilation systems.
• Floors and surfaces are cleaned using wet methods, high-efficiency particulate air (HEPA) vacuuming, or other methods, such as sticky tack cloths, that avoid the production of airborne dust. Compressed air or dry methods must not be used for such cleaning.
• HEPA vacuums used for cleaning meet criteria established in ESH100.2.IH.15, Control Hazards Using Local Exhaust Ventilation and High Efficiency Particulate Air Filters.
• Cleaning equipment (e.g., HEPA vacuums) used to clean removable beryllium-contamination from surfaces is labeled with SF 2001-CBS, Label for Equipment Used to Clean Beryllium, controlled, and is not used for clean-up of non-hazardous materials.

Activity

Responsible Individual

Required Action

Ensure that all requirements for a beryllium operational area and the additional requirements presented below are met for a beryllium regulated area:

• In lieu of SF 2001-LUN, Sign for Beryllium Operational Area post SF 2001-BHR, Sign for Beryllium Regulated Area at each access point.
• Records are kept of all individuals who enter the regulated area. These records shall include the name, date, time in/out, and work activity performed.
• Respirators are provided to beryllium worker when working in regulated areas and their use is ensured.
• Change rooms or areas that are used to remove beryllium-contaminated clothing and personal protective equipment are maintained under negative pressure or located so as to minimize dispersion of beryllium into clean work areas.
• Separate facilities free of removable beryllium contamination are provided where beryllium workers change into and store personal clothing and clean personal protective equipment to prevent cross-contamination.
• Hand washing and shower facilities are provided for beryllium workers who work in regulated areas.
• Beryllium workers who work in regulated areas are required to shower at the end of the work shift.
• Lunchroom facilities are provided that are readily accessible to beryllium workers; tables for eating are free of removable beryllium contamination; and no Member of the Workforce in a lunchroom facility is exposed, at anytime, to beryllium at or above the action level.
• Beryllium workers do not enter lunchroom facilities wearing or carrying personal protective equipment, unless removable beryllium contamination has been cleaned from clothing and equipment by high-efficiency particulate air (HEPA) vacuum or other methods that remove beryllium without dispersing it.
• Changing room areas, showers, hand washing facilities, and lunchrooms comply with 29 Code of Federal Regulations (CFR) 1910.141, Sanitation.

Activity

Responsible Individual

Required Action

Ensure that:

• All equipment and other items are only released/removed from beryllium operational areas and beryllium-contaminated buildings/areas using one of the following processes:
  • Uncontrolled release to non-beryllium areas at a Department of Energy (DOE) facility (including Sandia-controlled premises) and to the general public
  • Controlled release to non-beryllium areas and to the general public
  • Release to a beryllium operational area or beryllium-contaminated building/area on Sandia-controlled premises or another DOE facility (e.g., Los Alamos National Laboratory, Oak Ridge National Laboratory)
  • Release as beryllium-containing or beryllium-contaminated waste. See the section in this Procedure on Waste.
• Wipe surface sampling of equipment and other items is performed by the division ES&H team industrial hygienist to establish removable beryllium contamination levels and/or decontamination verification prior to uncontrolled releases and controlled releases.
• Uncontrolled releases only occur when the division ES&H team industrial hygienist has performed an exposure assessment for the release of the equipment or other items and determined the release poses no potential risk of exposure to the recipient and no conditions are placed on its future use (e.g., no labeling requirements).
• Equipment and other items with removable beryllium contamination are decontaminated to the lowest contamination level practical, but not to exceed a representative level determined by a division ES&H team industrial hygienist of 0.2 µg Be/100 cm2 for controlled releases and 3 µg Be/100 cm2 for releases to other beryllium operational areas, both on-site and off-site.
• The Beryllium Program SME is contacted to prepare and transmit a beryllium equipment release letter to the recipient for controlled releases and to document the receipt of the corresponding recipient's commitment. Equipment or other items are not to be released until the written recipient’s commitment is received by the Beryllium Program SME.
• Label SF 2001-PBC, Label for Potential Internal Beryllium Contamination, is affixed directly to equipment or other items for controlled releases and releases to other beryllium operational areas.
• All equipment or other items released from one beryllium operational area to another beryllium operational area (i.e., removable beryllium contamination present) are enclosed or placed in sealed, impermeable bags or containers to prevent the release of beryllium dust during handling and transportation. Double bagging is required if plastic bags are used.
• Label SF 2001-BER, Label for Containers of Beryllium, Beryllium Compounds, or Beryllium-Contaminated Clothing, Equipment, Waste, Scrap, or Debris, is affixed to all bags, containers, and enclosures used for containment of equipment or items being released to another beryllium operational area.
• A log, database, or other means of tracking items released from beryllium operational areas and beryllium-contaminated buildings/areas is implemented and maintained. The log shall be treated as a record.

Activity

Responsible Individual

Required Action

Ensure that:

• Waste minimization principles are applied to the generation of beryllium-containing and beryllium-contaminated waste.
• The release of beryllium dust is controlled by disposing of the beryllium-containing and beryllium-contaminated waste in sealed, impermeable bags or containers or enclosures to prevent the release of beryllium dust during handling and transportation. Double bagging is required if plastic bags are used.
• Label SF 2001-BER, Label for Containers of Beryllium, Beryllium Compounds, or Beryllium-Contaminated Clothing, Equipment, Waste, Scrap, or Debris is affixed to all containers of beryllium, beryllium compounds, or beryllium-contaminated clothing equipment, waste, scrap, or debris.
• ESH100.2.ENV.26, Manage Other Waste at SNL, is followed for additional waste disposal requirements.

Note: A recipient's commitment, decontamination, and wipe sampling are not required for waste disposal.

Activity

Responsible Individual

Required Action

Activity

Responsible Individual

Required Action

Manage Activity Level Work by Construction and Service Contractors

Sandia Delegated Representative (SDR)

Ensure that:

• Contracted activity level work involving beryllium on Sandia-controlled premises meets the requirements of ESH100.1.GP.1, Manage Safety for Contracted Activities, this Corporate Procedure, and 10 CFR 850, as applicable.
• Contractors performing work involving beryllium are informed of the presence of beryllium and associated protective control measures.
• The Current Beryllium Inventory is referenced for the list of beryllium operational areas and beryllium contaminated building/areas.
• The Multi-Employer Workplace section of ESH100.2.IH.4, Evaluate and Control Chemical Hazards is referenced for hazard communication requirements.
• The Beryllium Program SME is notified as soon as possible after receipt of any contractor personal breathing zone monitoring results exceeding a beryllium Occupational Exposure Limit (i.e., American Conference of Governmental Industrial Hygienists [ACGIH] Threshold Limit Values [TLVs] or DOE Action limit).
• The Beryllium Program SME is provided, in writing, all contractor personnel personal breathing zone monitoring results within 10 working days after the contractor’s receipt of results.
• Contractor personnel identified as beryllium-associated workers are provided Beryllium Awareness for Beryllium-Associated Workers (BEA100) training.
• Contractor personnel who are identified as beryllium workers receive Beryllium Awareness for Beryllium-Associated Workers (BEA100) and Beryllium Associated Workers Site-Specific (BEA101)  training.
• Contractor personnel who are not beryllium-associated workers or beryllium workers, but who work at a site (e.g., Radioactive and Mixed Waste Management Facility, Z-Machine, Disassembly Sanitization Operation, and Hazardous Waste Management Facility) where beryllium activities are conducted, are provided Beryllium Awareness (BEA100A) training.

BEA100, Beryllium Awareness for Beryllium Associated Workers.

BEA101, Beryllium Workers Site-Specific

Members of the Workforce who are not identified as beryllium-associated workers or beryllium workers, but who work at a site (e.g., Z-Machine, DSO, HWMF, RMWMF) where beryllium activities are conducted.

BEA100A,Beryllium Awareness

N/A

Administrative

Added

• Added a link for the ES&H Emergency Management Center in the activity to Respond to Beryllium Related Emergencies.
• Added a link in forms, links & tools for "Current Sandia Inventory of Beryllium Operations and Locations of Beryllium Contamination."
• Added BEA101 training for beryllium workers in training requirements.
• Added a dictionary link to "controlled release (beryllium)."
• Added a link to the specific records series for this procedure and to the Records Retention and Disposition website.

Modified

Changed link to BEA100A to link only to that course rather than both BEA100 and BEA100A.

Administrative

Modified

Corrected the name of BEA100 from Beryllium Awareness to Beryllium Awareness for Beryllium Associated workers in Training Requirements.

Added

Added more specific information to change summary of 01/04/2012.

Administrative

Added

Added a link to "Current Beryllium Inventory" in the activity to Manage Contract-Directed Activity Level Work Involving Beryllium.

Modified

• Updated the training requirements to reflect the change request on 12/23/2011.  
• Corrected the dictionary link in "Performing Work in a Beryllium Operational Area" under the seventh main bullet where the link encompassed text in addition to dictionary term.
• Updated the forms, links & tools to reflect the change request on 12/23/2011.

Administrative

Modified

Corrected a few dictionary links that did not work after substantive changes done on same date in Requirements & Instructions.

Substantive 

Modified

The procedure was extensively modified throughout to meet the requirements of 10 CFR 850, Chronic Beryllium Disease Prevention Program. Because of the extensive nature of this modification, this procedure should be read in its entirety. 

Added

• A new requirements & instructions table was added for "Manage New Beryllium Activities."
• New requirements were added in the following tables:
  • "Beryllium Contaminated Buildings and Areas." 
  • "Performing Work in a Beryllium Operation Area."
  • "Release of Equipment and Other Items."
  • "Managing Contractor-Directed Activity Level Work Involving Beryllium."

Administrative

Modified

Updated dictionary term links to  term identification numbers.

Administrative

Modified

Administrative

Modified

• Updated dictionary link to "beryllium emergency." (Requirements & Instructions, Beryllium emergencies)
• Replaced SAPLE links for subject matter experts with links directly to e-mail.

Administrative

Modified

• Updated SAPLE links for subject matter experts for system consistency.
• Relocated reference to HR100.2 from "Related Procedures" to "Related Processes."

Administrative

Modified

• Corrected dictionary links throughout the document.
• Corrected link to industrial hygienist throughout the document.

Administrative

Modified

Revised all dictionary links to use the alias dictionary link.

Administrative

Modified

• Html code for the "Important Notice" was changed to format text correctly. (Applicability)
• Split merged cell in "Identify, Evaluate, and Control Beryllium" table to correct display problems. (Requirements & Instructions)
• Updated SAPLE links of subject matter experts for system consistency. (Contacts)

Administrative

Modified

• Deleted extra period in Forms, Links & Tools.

Administrative

Added

• Added the heading “Signs” under Implementing Tools. 

Modified

• Moved the sign data from the heading “Forms” to “Signs.”

Administrative

This documents changes made 6/3/2010 linking the following terms to the corporate dictionary:  contractors, exposure assessment, action level (beryllium), removable contamination, regulated area, Members of the Workforce, beryllium-contaminated, beryllium workers, operational area, recipient's commitment, beryllium risk assessments, uncontrolled release, beryllium-containing and beryllium-contaminated waste, beryllium articles, beryllium emergencies, beryllium-associated worker, beryllium activities, contaminated buildings and areas, SDR, and site.