NIOSH reported similar results in the furnace area and machine shop (near cutting equipment) at a copper-beryllium foundry that manufactures products (0.45 to 2.15 percent beryllium) for the metal die casting industry (NIOSH EPHB 326-11a, 2008). The cutting equipment was used with coolants. In addition to machining, the shop was used for grinding, polishing, and buffing, with most of the equipment fitted with local exhaust ventilation (e.g., canopy hood, side draft, slot). The six samples indicated that 59 to 77 percent of the sample mass concentration was associated with particles less than 18 μm (NIOSH EPHB 326-11a, 2008).
Another study of aerosols generated during beryllium machining under typical working conditions also showed that more than 50 percent of the beryllium machining particles in the workers' breathing zones were less than 10 μm aerodynamic diameter (Martyny et al., 2000).
NIOSH also evaluated respirable and total beryllium mass concentrations in workers' breathing zones at an electronics recycling operation (receiving, sorting, disassembling, glass breaking, packaging, and shipping), but airborne beryllium was not detected at levels above the LOD of the analytical method (less than 0.03 μg/m[3] for both respirable and total particulate samples) (NIOSH EPHB 326-17a, 2009).[,]
The information presented on the previous pages indicates that ventilation system tests with non-beryllium materials can offer information relevant to beryllium control (aerodynamic diameter is more important than the material itself). Additionally, matching similar actions and intensities (as suggested by ACGIH and WHO) further enhances the relevance of control technologies from one industry or material to another. Furthermore, there is substantial evidence from recent studies that current worker exposures are predominantly to respirable size particles (more than half of the mass concentration is due to particles less than 10 μm in diameter). This finding indicates that control technologies proven for respirable dust are relevant to beryllium exposure reduction and likely will reduce exposure to airborne beryllium particles to a similar extent as other dusts.
Beryllium is not always a dry dust. Beryllium particles can be contaminants of metal working fluids, used as coolant and lubricant during metal machining activities, and aerosols emitted from chemical processing activities that generate bubbles. During metalworking, the machine tool releases beryllium particles, which are captured by the metalworking fluid; the small particles remain suspended in the metalworking fluid solution and are typically recirculated with the fluid applied to the machine tool or blade. Over time, the amount of metal particle contaminants builds up in the fluid. This contaminated fluid can become airborne as a fine mist when aerosols are generated by the action of the machine tool it cools (typically during high speed, high energy activities such as grinding and sawing). NIOSH defines metalworking aerosol as the "mist and all contaminants in the mist generated during grinding and machining operations involving products from metal and metal substitutes" (NIOSH Metalworking Fluid, 2012). Once airborne these combined fluid/beryllium aerosols behave according to the same principles of aerodynamic diameter as other particles.
When employees machine beryllium-containing metals the metalworking fluid can become contaminated with beryllium particles and is therefore a potential source of beryllium exposure, both as airborne aerosol and surface contamination. Once distributed throughout the work area, the particles can dry and be re-suspended if agitated by nearby activity or a broom. In a study on machine enclosures, Hands et al. (1996) explain that "metalworking fluid mist exposures in machining and grinding operations can be controlled by many means, including limiting fluid pressures and volumes, applying fluid only when the tool interfaces with the workpiece, adding mist suppressants to fluids, and ventilating and enclosing operations."
A similar situation exists with aerosols ejected into the air when bubbles (from the chemical reaction) burst on the surface of chemical treatment tank liquids. If the liquid is contaminated with beryllium particles (e.g., friable beryllium surface oxides that are released into the fluid) these particles can be emitted as part of the aerosol.
Based on these facts, OSHA preliminarily concludes that the results of ventilation controls tested by evaluating capture of any airborne dust particles, of any type, with similar origin, will be equally applicable to control of beryllium particles. For example, investigators have conducted extensive research on dust controls for respirable crystalline silica. OSHA finds that it is reasonable to consider ventilation control studies for silica grinding (or furnace, machining, or other) operations when evaluating potential controls for similar beryllium grinding (or furnace, machining, or other) operations. This finding is supported by the similarity in the densities of beryllium metal, beryllium oxide, and crystalline silica (see Table IV-4), and the routinely high proportion of respirable particles in airborne beryllium dusts.
Wet Methods for Airborne Beryllium
OSHA finds that there is considerable evidence that water spray droplet size is a primary factor in the efficacy of water (or other fluid) sprays used to control dust. The most effective spray uses a droplet size similar to the particle size that the spray is intended to control (Spray Systems, no date). Therefore, OSHA preliminarily concludes that studies of wet dust control methods applied to airborne dust will be similarly applicable to the beryllium portion of dust. This statement applies regardless of whether the fluid is applied as a spray or as a stream that generates a spray or mist through tool action, as is the case for machine tools (e.g., high-speed grinding and cutting equipment used with cutting oil or water coolant in the precision turned products industry).
Use of Short-Term and Area Sampling Results
The exposure profiles in the portions of this technological feasibility analysis that evaluate 8-hour TWA exposures do not include short-term exposure concentrations, for reasons described above (with the exception of the secondary smelting, refining, and alloying application group, as discussed in an earlier footnote). However, short-term samples can provide important information about the effectiveness of controls. Short-term samples also permit multiple trials of controlled and uncontrolled activities. In studies of this nature, investigators measure intensive periods of an activity (such as machining) without pauses or supplemental activities that can complicate comparisons of airborne dust during controlled and uncontrolled conditions. Results of brief samples, even just a few minutes in duration, can provide useful comparative information. Similarly, area samples obtained near the source of emissions provide information useful for evaluating the effectiveness of exposure controls. OSHA considers these experimental results in the discussion of additional controls for specific groups of workers.
Use of Surrogate Data
In some cases, when exposure information from a specific job category is not available, OSHA has based that portion of the exposure profile on the surrogate data from one or more similar job categories in related industries. The "surrogate" data are selected based on strong similarities between raw materials (e.g., sources of beryllium, percentage of beryllium), equipment, worker activities, and exposure duration in the job categories. Although other factors differentiate the industries, the individual job categories were determined to be sufficiently similar. When used, OSHA has clearly identified the surrogate data and the relationship between the industries or job categories.
Materion Worker Protection Model
A combination of control methods usually offers the most effective option for reducing worker beryllium exposure levels. Materion Corporation has identified a combination of measures that the corporation advocates as reducing airborne exposures to 0.2 μg/m[3] or less for the vast majority of workers in most work areas most of the time. This multi-faceted beryllium exposure control program is known within the beryllium industry as the Materion Worker Protection Model.
The Materion Worker Protection Model includes:
improved workplace orderliness and cleanliness, enhanced dermal protection in the form of polymer gloves and long-sleeve uniforms, dust migration control measures (e.g., tacky mats at entrances/exits and company clothing and boots that do not leave the facility), administrative controls (e.g., routine decontamination procedures in work areas), limiting airborne beryllium concentrations through engineering upgrades, such as enclosure and ventilation of high-risk processes to reduce airborne exposures to predominantly less than 0.2 μg/m[3], and extensive training and involvement of workers" (Thomas et al., 2009).
The control measures (i.e., engineering controls, work practices, and housekeeping) must be used together to ensure that exposure levels are reliably maintained below 0.2 ug/m[3] for the vast majority of workers nearly all the time (Materion Information Meeting, 2012).
Deubner and Kent (2007) and Knudson and Kolanz (2009) present the following basic elements of the comprehensive plan:
Avoid exceeding an 8-hour TWA exposure level of 0.2 ug/m[3].
Keep work areas visibly clean and take steps to ensure they stay that way.
Keep beryllium off the skin by using long sleeves and hand/wrist protection.
Keep beryllium off clothing by keeping work clothes visibly clean.
Keep beryllium at the source and in the work process by taking steps to avoid spreading it.
Keep beryllium in the work area by eliminating causes of migration.
Keep beryllium on the plant site by improving cleanliness standards.
Prepare beryllium workers for safe work with standard operating procedures and appropriate training. Appendix 1 of the Methodology section includes a summary of Materion Corporation's Interactive Guide to Working Safely with Beryllium and Beryllium-Containing Materials (available at http://www.berylliumsafety.com/).
To achieve the first element (avoid exceeding an 8-hour TWA exposure level of 0.2 ug/m[3]), Materion Corporation promotes engineering controls that include partial or full enclosures, minimum prescribed exhaust air flow rate across all openings, and efficient air filtration designed to capture even very small particles. Specifically, the enclosure or booth ventilation should provide 250 feet per minute (fpm) across the opening. It should also be fitted with a HEPA air filter, and personnel need to take special precautions when servicing the enclosure or booth or the blower (including while changing the filter). These precautions minimize the release of beryllium into the workplace, where it can affect the exposure of any workers in the space. However, personnel servicing the enclosure or booth or its air handling equipment require respiratory protection during these tasks. Employers still need to identify repair and maintenance activities that can generate airborne particles so that workers can be protected during those specific activities. Materion Corporation also promotes alarms as an important part of the ventilation system, to indicate when filter performance falls outside an effective range.
In cases where an enclosure or booth designed in this way (i.e., with 250 fpm airflow across openings) does not reliably control exposures to levels of 0.2 ug/m[3] or less, Materion Corporation reports achieving lower exposure levels by increasing the ventilation rate to provide 400 fpm across openings. This strategy has proven successful for a wide range of activities, processes, equipment, and hood designs at Materion Corporation's plants and those of their customers (Materion Information Meeting, 2012).
Employers implementing the Materion Worker Protection Model need to ensure that their ventilation system designers pay attention to the type of operations that will be performed in the area. The designers must match appropriate ventilation systems to the tasks. Materion Corporation reports success using hybrid ventilation systems (pairing two or more dust capture methods) for dusty tasks or high-energy activities, some of which have historically been difficult to control (e.g., grinding on materials that contain beryllium).
Materion Corporation provides a specific example of equipment used successfully to control worker exposure levels for these dusty or high-energy activities. This effective strategy involves using a combination backdraft/downdraft ventilated workstation with partial enclosures (sides and top). For example, Materion Corporation has evaluated grinding booths of this general back-draft-plus-downdraft design, paired with work practices and careful housekeeping methods. This type of ventilation design, used in conjunction with other components of the Materion Worker Protection Model, has reduced exposure levels for workers performing manual grinding (and related tasks using powered or rotary tools, such as polishing and buffing) to concentrations of 0.2 ug/m[3] or less as an 8-hour TWA, Materion Corporation's internal occupational exposure limit (Materion Information Meeting, 2012).
Once enclosures and ventilation systems are in place, the subsequent steps listed in the Worker Protection Model are necessary to ensure that:
Equipment operates properly.
Rigorous housekeeping is conducted on a frequent, routine schedule.
Workers have knowledge and understanding that allow them to recognize situations that could result in beryllium release and understand the importance of taking appropriate action.
These steps create an environment where it is easy for workers to notice something amiss and respond effectively.
Disclaimer
References to specific commercial products or manufacturers in this technological feasibility analysis are included for informational purposes only and do not constitute endorsements by OSHA of such products or manufacturers.
Technological Feasibility Analysis
The remainder of this analysis addresses the technological feasibility of controlling exposures to or below the proposed PEL in general industry.
References
ACGIH, 2010. Sections 6.2 (Enclosing Hoods -- Introduction) and 6.3 (Totally Enclosing Hoods), Chapter 5 (Design Issues -- Systems), Chapter 13 (Specific Operations), and Section 8.9 (Selection of Air Filtration Equipment), Industrial Ventilation: A Manual of Recommended Practice for Design, 27th Edition. American Conference of Governmental Industrial Hygienists. Cincinnati, Ohio.
Alloy Wire, no date. Internet web page for Beryllium Copper CB 101 Specifications. Alloy Wire International. Available online at: http://www.alloywire.com/beryllium_copper_CB_101.html.
Ashley, 2007. Analytical Methods for Beryllium. National Institute for Occupational Safety and Health. Presentation at American Industrial Hygiene Association and Exposition. Orlando, Florida; June 24 - 27.
Deubner D.D. and M. Kent, 2007. Commentary: Keeping Beryllium Workers Safe: An Enhanced Preventive Model. Journal of Occupational and Environmental Hygiene, 4:D23-D30. March.
DeYoung, D.H. and J. Peace, 2009. Beryllium in Dross Production During Aluminum Melting. Light Metals; The Minerals, Metals & Materials Society.
ERG, 2005. Technological Feasibility Materials. Eastern Research Group, Inc. Available in OSHA's beryllium docket as OSHA-H005C-2006-0870-0340.
Hands, D., M.J. Sheehan, B. Wong, and H.B. Lick, 1996.  Comparison of Metalworking Fluid Mist Exposures from Machining with Different Levels of Machine Enclosure.  American Industrial Hygiene Association Journal 57(12): 1173 - 1178.  December.
Hinds, William C., 1999. Aerosol Technology: Properties, Behavior, and Measurements of Airborne Particles. 2[nd] Ed., Chapter 3.
Hornung, W., and L.D. Reed, 1990. Estimation of average concentration in the presence of nondetectable values. Applied Occupational and Environmental Hygiene 5(1):46 - 51.
Kent et al., 2001. Is total mass or mass of alveolar-deposited airborne particles of beryllium a better predictor of the prevalence of disease? A preliminary study of a beryllium processing facility. Applied Occupational and Environmental Hygiene 16(5): 539 - 558. May.
Kent, M.S., 2012. Meeting between Materion Corporation and OSHA, Elmore, Ohio. May 8 - 9.
Knudson, T.L. and M.E. Kolanz, 2009. An Innovative Safety Model and E-Learning Guide to Working Safely with Beryllium throughout the Industrial Supply Chain. Journal of Occupational and Environmental Hygiene 6: 758 - 761. December.
Kolanz, M.E. 2001. Brush Wellman Customer Data Summary. OSHA Presentation, July 2, 2001. Washington DC. (Beryllium Docket ID Number OSHA-HOO5C-2006-0870-0091)
Martyny, J.W., M.D. Hoover, M.M. Mroz, K. Ellis, L.A. Maier, K.L. Sheff, and L.S. Newman, 2000.  Aerosols Generated During Beryllium Machining.  Journal of Occupational and Environmental Medicine 42(1): 8 - 18.
Materion Information Meeting. 2012. Meeting between Materion Corporation and OSHA. Elmore, OH (May 8-9).
Materion Interactive Guide, 2012.  Interactive Guide to Working Safely with Beryllium and Beryllium-Containing Materials. Materion Corporation, Mayfield Heights, Ohio. Online version of the Interactive Guide is available at http://www.berylliumsafety.com/.  Accessed February 7, 2012.
Mishima, et al., 2006. Proposed beryllium metal bounding airborne release fractions (ARFs)/rates (ARRs) and respirable fractions (RFs) for DOE facility accidents analysis; (Document EFCOG/SAWG-CST LA-UR-05-1096). Chemical Safety Team, Los Alamos National Laboratory.
NIEHS, 2011. National Institute of Environmental Health Sciences Report on Carcinogens, Hexavalent Chromium Compounds. 12[th] Edition. Pages 106-109. Available online at: http://ntp.niehs.nih.gov/ntp/roc/twelfth/roc12.pdf.
NIOSH IWS-37-13.  Results of Air Sampling of Kawecki Berylco Plant, at Kawecki Berylco Industries Hazelton, Pennsylvania.  NIOSH Report No. IWS-37-13 (NTIS document number PB83-133397).  U.S. National Institute for Occupational Safety and Health, Division of Surveillance, Hazard Evaluations, and Field Studies, Hazard Evaluation and Technical Assistance Branch, Cincinnati, Ohio.  November 21, 1971.
NIOSH Metalworking Fluids, 2012. Workplace Health and Safety Topic page for Metalworking Fluids. National Institute for Occupational Safety and Health. Available online at: http://www.cdc.gov/niosh/topics/metalworking/.
NIOSH-77-173, 1977. Exposure measurements for an 8-hour TWA standard, Section 3.4. In: Occupational Exposure Sampling Strategy Manual: 40. National Institute for Occupational Safety and Health.
NIOSH 78-17-567, 1979. Health Hazard Evaluation Determination: Kawecki Berylco Industries, Inc.; Reading, Pennsylvania. Report HE 78-17-567. National Institute for Occupational Safety and Health. March.
NIOSH ECTB 233-101c, 1999. Control technology and exposure assessment for occupational exposure to crystalline silica: Case 01 -- A ready-mix concrete plant.  April.
NIOSH EPHB 263-13a.  Control Technology and Exposure Assessment for Occupational Exposure to Beryllium:  Abrasive Blasting with Coal-Slag.  Report No. EPHB 263-13a. U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, Division of Applied Research and Technology. Cincinnati, Ohio. August 2007.
NIOSH EPHB 326-11a. Control Technology and Exposure Assessment for Occupational Exposure to Beryllium: Beryllium Facility #1 -- Copper/Beryllium Foundry. Report No. EPHB 326-11a. U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, Division of Applied Research and Technology. Cincinnati, Ohio. July 2008.
NIOSH EPHB 326-14a, 2008. Control Technology and Exposure Assessment for Occupational Exposure to Beryllium: Beryllium Facility #2 -- Copper/Beryllium Machine Shop. Report No. EPHB 326-14a. National Institute for Occupational Safety and Health. October 2008.
NIOSH EPHB 326-17a.  Control Technology and Exposure Assessment for Electronic Recycling Operations, United States Penitentiary, Lewisburg, Pennsylvania.  Report No. EPHB 326-17a.  U.S. Department of Health and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, Division of Applied Research and Technology, Cincinnati, Ohio.  January 2009.
NIOSH HETA 83-162-1746.  Health Hazard Evaluation Report HETA 83-162-1746.  Handy and Harman, Inc., Fairfield Connecticut, July 6-8 and November 1-4, 1983.  U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control, National Institute for Occupational Safety and Health, Hazard Evaluations and Technical Assistance Branch, Cincinnati, Ohio.  November 1986.
NIST, no date. National Institute of Standards and Technology interactive website for Composition of Materials. Available online at http://physics.nist.gov/cgi-bin/Star/compos.pl?matno=276.
OSHA, 2009. Integrated Management Information System (IMIS). Beryllium exposure data, June 1, 1978 to September 25, 2008, provided to Eastern Research Group, inc., by U.S. Department of Labor, Occupational Safety and Health Administration, Washington, DC. April 21. [unpublished electronic files].
OSHA-H005C-2006-0870-0145. U.S. Department of Labor, Occupational Safety and Health Administration. OSHA Beryllium Docket No. OSHA-H005C-2006-0870. Document ID No. OSHA-H005C-2006-0870-0145. Document title: Attachment (1). Navy Occupational Exposure Database (NOED) Query Report Personal Breathing Zone Air Sampling Results for Beryllium. Comments received from the U.S. Navy Environmental Health Center in response to the Federal Register notice of November 26, 2002. Dated February 2003.
OSHA ID 125G.  OSHA-beryllium analytical method, 2002. OSHA Sampling and Analytical Method, ID-125G: Metal and Metalloid Particulates in Workplace Atmospheres (ICP Analysis). Available online at: http://www.osha.gov/dts/sltc/methods/inorganic/id125g/id125g.html.
Spray Systems, no date. Guidelines for spray nozzle selection (electronic fact sheet). Spray Systems Company. Available online at: http://www.spray.com/pdf/dust_control_nozzle_selection.pdf.
Stefaniak et al., 2007. Differences in estimates of size distribution of beryllium powder materials using phase contrast microscopy, scanning electron microscopy, and liquid suspension counter techniques. Particle and Fibre Toxicology. 4:3.
Succop, P.A., S. Clark, M. Chen, and W. Galke, 2004. Imputation of data values that are less than a detection limit. Journal of Occupational and Environmental Hygiene 1:436 - 441.
Thomas et al., 2009. Efficacy of a program to prevent beryllium sensitization among new employees at a copper-beryllium alloy processing facility. Public Health Reports, 2009 Supplement 1, Volume 124:112-124.
USEPA, 2010. Basic Concepts in Envioronemtal Sciences, Module 3: Characteristics of Particles -- Aerodynamic Diameter. Available online at:  http://www.epa.gov/apti/bces/module3/diameter/diameter.htm.
WHO, 1999. Hazard Prevention and Control in the Work Environment: Airborne Dust (Publication number WHO/SDE/OEH/99.14). World Health Organization, Geneva, Switzerland. August. Available online at: http://www.who.int/occupational_health/publications/airdust/en/index.html.
WI Geological Survey, 2010. Rock Properties -- Porosity and density. Wisconsin Geological Survey webpage. Available online at: http://wisconsingeologicalsurvey.org/porosity_density/about_porosity_density.htm.

SECTION 2 -- METHODOLOGY, APPENDIX 1 -- MATERION BERYLLIUM WORKER PROTECTION MODEL
Materion Corporation, the primary beryllium producer in United States, has developed a beryllium worker protection model to prevent chronic beryllium disease (CBD) and other adverse effects associated with the inhalation of beryllium-containing particles (Deubner and Kent, 2007; Knudson and Kolanz, 2009). This producer's experience has shown that worker protection is best provided by a comprehensive exposure control program applied to specific tasks and operations. The worker protection model incorporates eight program elements:
Keep beryllium-containing particles out of the lungs by adhering to the beryllium producer's recommended 8-hour TWA exposure guideline of 0.2 ug/m[3] with a very high degree of statistical confidence.
Keep beryllium work areas visibly clean, well lit, orderly, and free of clutter. Systematic cleaning and maintenance of orderliness will make it easier to determine when work surfaces are not visibly clean and to control worker exposure to hazardous materials.
Keep beryllium off the skin (whenever beryllium particulate or salt contact is possible) to prevent beryllium-containing particles from entering the skin through cuts, abrasions and rashes. Prevent skin contact with beryllium particulate or salt-contaminated surfaces or with beryllium-containing liquids or dusts (splashing or falling) through the use of appropriate PPE (such as impervious gloves, wrist covers, long-sleeved shirts and pants; and additional protective clothing as necessary when liquids can contact clothes and penetrate through to the skin). Hand and arm contact with the face can be a source of inhalation exposures.
Keep beryllium off clothing and shoes to prevent the transfer of beryllium between work areas. Prevent clothing contamination by keeping work clothes visibly clean. If work clothes can become visibly dirty, use overgarments to protect work clothes. Beryllium-contaminated clothing can be a source of worker exposure (through redispersion of beryllium-containing particles into the air and from hand to face contact) and a major route for carrying beryllium out of the work area.
Keep beryllium at the source and in the work process. Prevent the generation or release of airborne particles by not producing beryllium-containing particles in the process or by capturing particles (e.g., through the use of ventilation and enclosures) before they can become airborne.
Keep beryllium in the work area. Prevent beryllium-containing particles and solutions from migrating to work areas where beryllium work is not performed (e.g., break, office, meeting room, and cafeteria areas) through the use of engineering controls, work practices, administrative actions, and PPE. "Beryllium migration from work areas occurs when beryllium is carried in air and on tools, vehicles, scrap, product, and people" (Deubner and Kent, 2007).
Keep beryllium on the plant site. Prevent beryllium contaminated people and/or objects from leaving the plant and potentially exposing others in the community. For example, by improving and maintaining cleanliness standards for all products and shipped materials including pallets and trailer vans.
Keep beryllium workers prepared to work safely. Ensure that appropriate safety training (e.g., awareness level or full competency) is provided by operational management (supervisors) prior to potential exposure to beryllium. Include safety standard operating procedures to ensure tasks are performed safely from both general safety and beryllium safety perspectives. Where full competency is required, include observation of competency.
The program elements are described in greater detail in Materion Corporation's online Interactive Guide to Working Safely with Beryllium and Beryllium-Containing Materials (see http://www.berylliumsafety.com/). Applying the worker protection model can reportedly be as simple as implementing the types of controls typically found in most industrial operations in conjunction with full consideration of all elements of the model.

SECTION 3 -- BERYLLIUM PRODUCTION
One primary beryllium production facility is currently in operation in the United States, a plant owned and operated by Materion Corporation, located in Elmore, Ohio. The facility is classified in NAICS 331419, Primary Smelting and Refining of Nonferrous Metal. The Elmore plant is a large integrated facility that, in addition to beryllium metal, also produces beryllium alloys and beryllium oxide ceramics that are further processed on site or shipped to other facilities for processing into a variety of products. Thus, some of the production processes at the Elmore plant, such as rolling, drawing, welding, and machining operations, overlap with industry sectors addressed in other sections of Chapter IV (Technological Feasibility) of the Preliminary Economic Analysis (PEA).
Number of Employees
In response to a Request for Information in 2002, Brush Wellman provided a list of job titles for the Elmore facility, based on an average employment of 616 workers (OSHA-H005C-2006-0870-0092). This total includes workers producing beryllium metal, alloys, and beryllium oxide product, as well as administrative, research, and maintenance personnel. Table IV-5 shows the staffing levels at the Elmore plant by job category and work group.
Table IV-5 -- Employment by Department (1999) -- Brush Wellman, Inc., Elmore, Ohio
                                 Job Category
                                  Work Group
                             Total No. of Workers
Chemical Operations

                                      18

Beryllium Sulfate Salt (GC salt and wet screen operators)

                                      18
Furnace Operations

                                      58

Alloy Induction

                                      30

Alloy Arc

                                      13

High Beryllium Vacuum Cast

                                       3

High Beryllium Atomization

                                       3

Beryllium Oxide

                                       9
Production Support

                                      146

Mix Makeup (furnace charge)

                                       5

Scrap Recycling:

Inventory Control Center

                                       2

Scrap Reclamation

                                       4

Leaching

                                       3

Resource Recovery

                                      13

Maintenance:

Production Equipment

                                      47

Furnaces and Tools

                                      23

Molds and Dies

                                       7

Research and Development

                                      12

QA/QC/Inspection

                                      30
Hot Work

                                      42

Hot Rolling/Extrusion

                                      16

Annealing

                                      14

Welding

                                       1

Pickling

                                       6

Degreasing

                                       5
Cold Work

                                      118

Rolling

                                       8

Straightening

                                       9

Drawing

                                       6

Machining:

Billet Preparation

                                      19

Alloys

                                      33

High Beryllium

                                      43
Powdering

                                       4

Operator/Impact Grinding

                                       1

Compact Loading/Sintering

                                       1

Near Net Shape (operator and welder)

                                       2
Site Support

                                      127

Laundry

                                      11

Janitorial

                                       6

Landfill

                                       2

Facility Maintenance

                                      24

Analytical Laboratories

                                      18

Ship/Receive/Material Handling

                                      19

Wastewater Treatment

                                       7

Store (supply) Rooms

                                       4

Security

                                       7

Boiler Operators

                                       4

Facility Engineering

                                       9

Cafeteria

                                       9

Decontamination

                                       7
Administrative

                                      103

Operations/Management

                                      44

Human Resources

                                       3

Information Systems

                                       4

Credit Union

                                       5

Environmental Health and Safety

                                       9

Medical

                                       4

Training

                                       2

Production Planning

                                      19

Engineering

                                      13
Total

                                      616

Source: OSHA-H005C-2006-0870-0092

Overview of Process
This section covers the production of beryllium metal, beryllium alloys, and beryllium oxide powder. The processing and machining of beryllium oxide ceramic and composite is covered in the subsection titled Beryllium Oxide Ceramics and Composites, and the processing and machining of beryllium and beryllium alloys is covered in the sections on Precision Turned Products and Copper Rolling, Drawing, and Extruding, in Chapter IV of the PEA.
A survey conducted by the National Institute for Occupational Safety and Health (NIOSH) indicate that exposure to beryllium occurs in the following departments on a routine (i.e., daily) basis: Alloy (Alloy R&D), Pebble/Oxide Plant, Powdered Metal Products, and Resource Recovery.  Maintenance workers can also be exposed when working in these parts of the plant) (McCawley, 2000). The chemical form of the beryllium varies among those departments. In the Alloy department, the beryllium typically is contained in copper-beryllium (CuBe), nickel-beryllium (NiBe), and aluminum-beryllium (AlBe) alloys. Beryllium oxide (BeO) may be produced intentionally as metallic powder, and can form as a byproduct during processing, such as in alloy "hot work" applications (e.g., melting and casting, hot rolling, annealing and extrusion). In the Pebble/Oxide Plant, the beryllium is most commonly present as beryllium oxide, ammonium beryllium fluoride, beryllium fluoride, and beryllium pebbles (98 percent pure beryllium metal). In the Powdered Metal Products department, the beryllium is in its elemental form, and for activities associated with the Resource Recovery Department, the beryllium can be in any of the forms mentioned above.
Beryllium Metal Production
The production of beryllium metal is a multistep process that begins with wet chemical processing of beryllium hydroxide Be(OH)2 obtained from mining and extraction operations in Utah. The Be(OH)2 is dissolved in ammonium biflouride to form an ammonium beryllium fluoride (ABF) solution. The solution is purified through a series of precipitation and filtration steps to form ABF salts, which are then decomposed to beryllium fluoride (BeF2) in the fluoride furnace. The beryllium fluoride is reduced in a reduction furnace at approximately 900C in the presence of magnesium to produce beryllium pebbles. The beryllium pebbles are then separated from the magnesium fluoride in a hammer mill. The result is 98-percent pure beryllium pebbles (National Materials Advisory Board, 1989).
Beryllium pebbles and other high-grade beryllium scrap (e.g., machining chips) are charged into a vacuum-melting furnace. The vacuum-melted beryllium metal is poured into a graphite mold to produce a 400-lb vacuum-cast billet. Vacuum-cast beryllium billets are machined into chips on lathes with multiple machining cutters. The chips are then processed into beryllium metal powder in one of four powder-producing operations: attrition mill, impact grinding mill, ball mill, or atomization.
Beryllium metal powder is consolidated with hot vacuum pressing or near-net-shape (NNS) technologies. In hot vacuum pressing, beryllium powder is loaded into a graphite die; the powder inside the die is subjected to temperatures up to 1,125C and pressures up to 1,200 psi to produce vacuum hot-pressed billets of varying dimensions. The vacuum hot-pressed billets are machined using typical metal fabrication techniques (e.g., lathe turning, milling, band sawing, surface grinding) in the machine shop.
NNS powder consolidation techniques include hot isostatic pressing and cold isostatic pressing. In hot isostatic pressing, NNS beryllium parts are produced by loading beryllium powder into a welded mild steel container, shaped and sized to account for the shrinkage that occurs after hot isostatic pressing. The container is sealed and vacuum-outgassed to remove residual gas inside the container. The container is loaded into an isostatic press, where it is subjected to high temperatures and pressure to compress the powder into a product of a particular size and shape, which is determined by the container volume. The mild steel container is then removed by chemically dissolving the steel in a nitric acid bath. Cold isostatic pressing is similar to hot isostatic pressing in that beryllium powder is loaded into a die (usually made of rubber), which is then sealed, outgassed, and cold-pressed. The rubber mold is then mechanically removed. The NNS parts are generally sent out for final machining at a precision machine shop.
Beryllium Alloy Production
The Elmore facility produces beryllium alloys in a variety of shapes, including bars, rods, tubes, wires, strips, and plates.
To produce beryllium alloys, beryllium hydroxide is calcined into beryllium oxide powder and mixed with carbon/binders to form pellets that are transferred to a charge bin. This is done through a computer-controlled closed system. The charge bin holds approximately 1 ton of beryllium oxide pellets, copper, and petroleum coke. These materials are used to charge the Whiting Arc Furnace. The output from the Whiting Arc Furnace is a 30-lb copper-beryllium "master alloy" that has a beryllium content of 3.8 percent by weight. This product is then used along with other forms of alloy (e.g., scrap) in casting the larger product billets, which are lower in beryllium content. Dross from this and other operations can be recycled into the furnace to be reclaimed.
Melting and casting of master alloys is performed in the cast shop. The cast shop produces billets of copper-beryllium, nickel-beryllium, and aluminum-beryllium up to 40 feet long. Both old and new cast shops are in operation at the Elmore facility, located separately from each other. The large billets (up to several feet in diameter and 10 to 40 feet long) are cast using a direct chill process. A 1- to 2-feet-deep, open-ended, water-cooled mold is used in the process. Hydraulically controlled, tilting melting furnaces are used to pour the molten metal into a tundish that transfers the molten metal to the water-cooled mold in a vertical water-filled pit. As the metal is poured through the mold, it rapidly solidifies and retains the shape of the mold, forming a billet. Further cooling and solidification of the billet occurs in the pit. Either rectangular or cylindrical billets can be produced, depending on the processing needs. Round billets are processed in an extrusion press to make various objects, such as rods, bars, tubes, and wire products. Rectangular billets are also processed to make strip and plate products and to be sold directly to customers.
The casting operation also includes scrap furnace operations, in which scrap (produced by the operations at Elmore, the distribution centers, and customers) is returned, melted, and reused. Scrap contaminated with rolling or cutting oils is melted in the scrap-melting furnace in the old cast shop and cast into ingots. Clean scrap can be introduced directly into the furnaces in which beryllium products are made.
Billet Preparation
Billets are reheated after casting through a process similar to tempering. The reheating homogenizes the various materials within the billet. This homogenization can also be done to the material at other stages in the manufacturing process. For example, Materion regularly heats its products after rolling or cutting. Once the billets have been cast and reheated, they can be cut into multiple lengths, sectioned on a saw, turned on a lathe, or conditioned on the scalping mill. For those billets that will become tubing, a deep hole-drilling machine is used to bore holes before the billet is sent to extrusion.
Production of Final Shapes
This section details the hot and cold work operations used to produce rods, bars, tubes, and sheets of alloy strip.
Both hot-worked and cold-worked items are manufactured from the billets. The hot-worked items are either forged or extruded to dimensionally form the product and refine the cast grain structure. Solution annealing, flattening or straightening, age-hardening, cutting to size, surface cleaning, and inspection operations are used. Shapes commonly manufactured include rods, bars, tubes, rings, and some special cross-sectional shapes, all in a wide range of sizes. Note that the exposure profile contains a major job category titled "Hot Work," and it includes activities such as extrusion and hot rolling, annealing, pickling, degreasing, and welding.
The cold-worked products are manufactured when the application requires closer dimensional tolerance, more refined metallurgical properties, more stringent physical or mechanical property ranges, or better surface finish than the less costly hot-worked products. The additional processing can be as simple as adding a pointing and drawing operation but could also include additional annealing and cleaning steps or other metallurgical, dimensional, and quality assurance tests. Note that the exposure profile contains a major job category titled "Cold Work," and it includes activities such as rolling, straightening, drawing, and machining.
Both cold and hot work operations are described below in relation to the final product being manufactured.
Rod, Bar, and Tube Products
Extrusion (Hot Work)
The extrusion press refines the cast structure by pushing a round cast billet through a die, producing a semi-finished hot-worked product. Rods, bars, and tubes of many dimensions can be produced this way. An abrasive cut-off saw is used to cut the product at the exit end of the extrusion press die. Additionally, a hot coiler is attached to the system to produce wire up to 1.25 inches in diameter. Water spray nozzles along the length of the runout and walking beam tables are used to provide uniform cooling and keep the materials straight. Some products are cut to length on an abrasive cut-off saw at the end of the runout table. The extrusion process is located adjacent to the billet preparation area and not in the rod, bar, and tube mill.
Annealing (Hot Work)
The Sauder furnace complex at the Elmore facility ages and anneals the rod, bar, and tube products. Annealing is a process in which the alloy is heated and then cooled very slowly and uniformly. The time and temperature of the process are set according to the properties desired. Annealing increases ductility and minimizes the possibility of a failure in service by reducing internal strain.
Swager (Cold Work)
Before cold drawing, rods or tubes must be made smaller on one end to be able to feed material through the drawing die to the jaw grips. Additionally, the smaller end must be strengthened to prevent breaking during drawing. A swager is used to cold point all rod and tube products prior to drawing. At the swager, material is fed into four tapered dies that hammer the work piece over a 3-inch length. An 8-inch point length is required before drawing.
Bulk Pickling (Hot Work)
The bulk pickler is used to clean rod, bar, tube, and wire products that either have been cut to length or are in coil form. The operation consists of three steps:
A sodium hydroxide (NaOH) bath for 30 minutes.
A nitric acid bath for 5 minutes or less.
Dipping in stain/oxidation inhibitor (benzotriazole or BTA).
The acid content, bath temperature, copper content, and urea content are computer-controlled to maintain optimal surface cleanliness and minimize fuming.
Drawing (Cold Work)
After annealing, bulk pickling, and pointing, rods and tubes are drawn (pulled) through a die to produce a wide variety of shapes and sizes. The Lombard drawbench utilizes a hydraulic ram to provide the force necessary to achieve the required product reduction. Products finished by this process have very smooth surfaces and are straight within the required tolerance. The product can be further heat treated or subjected to rotary straightening for improved straightness and finish.
Degreasing (Hot Work) and Cutting (Cold Work)
After the drawing process, the Phillips degreaser uses perchloroethylene in liquid and vapor form to remove the drawing lubricant on the products prior to straightening and age hardening. The Marvel band saw is used to cut rods and tubes to specific lengths. The saw gives a square cut for tight tolerances.
Straightening (Cold Work)
The straightening process requires that a material be flexed slightly beyond its elastic limit in both tension and compression. In rotary straightening, two specially contoured rolls inclined at opposing angles cause the round product to rotate while pressure is applied. In bump straightening, sheet metal is guided on a surface by rollers where pressure is applied to straighten the material.
Wire Rolling (Cold Work)
Wire rolling reduces the cross-sectional area of the feed material to produce wires of specific diameters. Two tandem wire mills are used for the initial cold working process. The strands of grooved rolls are alternately opposed to improve the uniformity of the work. The shaped grooves are progressively reduced in size to provide the desired reduction as the wire passes through the mill. Coiled wire from the tandem mills is supplied at various gauges of 0.125 inches and greater.
Strip Operations
Sheets of alloy strip are produced from castings from the induction furnace and are rolled from billets into single coils on the hot mill. Two hot mills are in operation at the Elmore plant -- an old, smaller hot mill and the new, larger hot mill. Smaller coils from the old hot mill are welded together to produce full-length coils weighing approximately 8,000 pounds. The new hot mill produces larger coils, and the intermediate coil-welding step is not required. The coils are then milled, dimensioned, and cut to specification and length. With the exception of hot rolling and slab milling (both described below), these operations are mirrored in the Reading plant. The Reading plant produces multiple dimensions of strip to customer specification, while the Elmore plant primarily produces a limited variety of dimensions and lengths, much of which is shipped to the Reading plant.
Roller Hearth Furnace (Includes Hot Rolling) (Hot Work)
Large coils of alloy are continuously solution-annealed in the roller-hearth furnace to soften them for further cold rolling. The roller-hearth furnace has heating zones in which the strip is heated to recrystallize the microstructure and redissolve the copper-beryllium compounds present after the rolling process. After cold rolling, the strip is annealed again in the furnace.
Slab Milling Machine (Cold Work)
The function of the slab-milling machine is to remove scale, defects, and undesirable metal phases from the surface of the strip of various alloys before further processing. To do this, the strip is fed through the slab-milling machine, where the cutter mills one surface at a time. The depth of the cut is determined by an adjustable pinch roll controlled by the operator.
Light-Gauge Slitter (Cold Work) and Weld Line (Hot Work)
After the material has been processed through the roller-hearth furnace, slab-milled, and cold-rolled on the four-high mill, coils are sent to the light-gauge slitter/weld line for slitting of edges to eliminate edge cracks and provide a uniform width. It is also capable of multiple slit strip widths to increase versatility for meeting customer requirements. A tungsten inert gas (TIG) butt welder is used to connect smaller coils into larger coils to meet customer coil length requirements.
Strand and Light-Gauge Strip Pickle Lines (Hot Work)
The role of the strand pickle line is to chemically remove stains and oxidation formed on the strip during annealing. Sodium hydroxide is used to remove the oils and condition the oxidized surface for pickling. Nitric acid is then used to remove oxide scale and produce a bright surface. There is also a light-gauge strip pickle line that functions in a similar manner.
Sendzimir Mill (Z-Mill) (Cold Work)
The Z-Mill is a 20-roll cluster, reversing, cold-rolling mill. It is designed for precision rolling to thin gauges, with the strip held taut by the winders.
Light-Gauge Strip Annealing (Hot Work)
The light-gauge strip annealing line performs the same task as other annealers noted above. A protective nitrogen atmosphere is used in the heating zone to reduce oxidation. Quenching is also done with a recirculating protective atmosphere.
Plate Leveling (Cold Work)
The roller levelers are used to flatten alloy plate products. The actual flattening or leveling process is performed by bending the material past its elastic limit while it passes over the roller. The amount of bending can be controlled by adjusting the bottom rolls up or down. During the operation, unleveled plate is fed into the pinch rolls and formed into a uniformly bent shape. While still in the machine, the roll is reversed and final leveling is accomplished. The process can be repeated if necessary.
Plate Sawing (Cold Work)
Plates at intermediate, ready-to-finish, or finished gauges are sawed to size or for metallurgical samples. Side trimming can be performed on pieces up to 12 feet long.
Beryllium Oxide Production
Beryllium oxide is made from the beryllium hydroxide produced at the Delta, Utah, mining facility. Ceramic grade and high-purity beryllium oxide powders are formulated using the following processes:
Primary extraction. In the primary production process, beryllium hydroxide is dissolved in sulfuric acid. This solution is then filtered to remove insoluble oxide and sulfate impurities. The resulting clear filtrate is allowed to evaporate and become concentrated, producing high-purity beryllium sulfate upon cooling.
Calcination. The beryllium sulfate salt is then calcined in a hearth furnace at carefully controlled temperatures between 1,150°C and 1,450°C. The temperatures are selected to induce specific properties of the beryllium oxide powders, as required by individual beryllium oxide ceramic fabricators. Commercial beryllium oxide powder, calcined at 1,150°C, consists of crystallites ranging from about 0.1 micrometer (um) to 0.2 um in size. Powder particles are made up of larger clusters or aggregates of the smaller crystallites.
Chelating. Ceramic-grade beryllium oxide is manufactured by adding organic chelating agents to the filtered beryllium sulfate solution and then precipitating out beryllium hydroxide using ammonium hydroxide powder.
Gas atomization. This process converts beryllium oxide powder crystals into smaller, isotropic, spherical beryllium powders used for metal matrix composites.
Packaging. Powdered beryllium oxide is packaged in drums for shipment directly to customers, as well as to Materion Corporation's Tucson plant.
Support Operations
The Elmore plant has its own analytical laboratories for both metallurgical and environmental analyses. Laboratory technicians visit the operations described above. There are also maintenance and janitorial staffs as well as a small laundry staff to care for the company-provided clothes (kept on site) that workers must change into and out of each day. Medical staff is on site and may be out on the plant floor at times.
Engineering and administrative staffs are located in two buildings -- the east and west administrative buildings. In the past, both buildings were open to foot traffic from the plant. Currently, only the west administrative building remains open to foot traffic from the plant, and workers in that building must abide by the same clothing protection rules as the plant workers.
Beryllium Exposure Profile and Technological Feasibility Analysis
Exposure Profiles
The exposure profiles for the major categories at the Elmore primary production facility represent baseline exposure levels for this industry, developed based on air monitoring results at the facility, which is the only U.S. establishment that produces beryllium metal. Individual full-shift personal breathing zone (PBZ) (lapel-type) sample results were obtained from Brush Wellman (Brush Wellman Elmore, 2004). These data represent baseline exposure monitoring conducted by Brush Wellman in 1999 and are summarized in the OSHA beryllium docket (OSHA-H005C-2006-0870-0092). Samples were analyzed by NIOSH Methods 7102 (Beryllium and compounds, as Be) or 7300 (Elements by ICP), and the analytical limit of detection (LOD) was reported to be 0.1 micrograms (ug) per filter. For sample results less than the LOD, a sample weight of 0.05 ug (one-half the LOD) was used by Brush Wellman to calculate the volume-adjusted nondetectable sample concentrations (Kent, 2005). For this general technological feasibility analysis, OSHA has defined a full-shift sample as one having a duration of at least 360 minutes. All of the samples used in the exposure profile from the 1999 survey have durations of at least 400 minutes, and as such, are considered full-shift samples.
Job titles listed in the Brush Wellman exposure database were reviewed with industry experts to obtain information regarding work tasks, sources of beryllium exposure, existing exposure controls, and potential additional exposure controls. Each job title was broadly categorized into one of eight job categories based on the type of work employees perform. Each job category contains work groups that more specifically identify employee job functions. The eight job categories and work groups utilized in the exposure profile are presented in Table IV-5.
The exposure profiles for job categories involved in primary beryllium production are presented Tables IV-6 and IV-7. Table IV-6 summarizes the 1999 full-shift PBZ (lapel-type) total beryllium sample results for workers at Brush Wellman's Elmore, Ohio, beryllium production facility. The frequency distribution of the air sampling results are presented in Table IV-7 in relation to the permissible exposure limit (PEL) options of 0.1 μg/m[3], 0.2 μg/m[3], 0.5 μg/m[3], and 1.0 μg/m[3].
For individual work groups with median exposures greater than or equal to 0.1 μg/m[3], this technological feasibility analysis provides a brief process overview along with the available information regarding potential sources of exposure and existing and possible additional controls. When the majority of samples indicate that workers in a group already have exposures below 0.1 μg/m[3], the technological feasibility discussion for that group includes the available information regarding existing baseline exposure controls (based on telephone interviews with industry consultants and representatives, as cited the discussion). The discussion is supplemented with information obtained from published documents and observations made during a tour of the Brush Wellman Elmore facility by OSHA and Eastern Research Group staff on August 30 - 31, 2004.
Table IV-6 -- Personal Exposure Profile in the Beryllium Production Industry (1999) (NAICCS 331419)[a,b,c]
                               Job Category and
                                  Work Group
                       No. of Full-Shift PBZ Samples[d]
                               Range (μg/m[3])
                                     Mean
                                  (μg/m[3])
                                    Median
                                  (μg/m[3])
CHEMICAL OPERATIONS
                                      20
                                 0.05 to 9.64
                                     1.02
                                     0.47
Be Sulfate (GC salt & wet screening operators)[e]
                                      20
                                 0.05 to 9.64
                                     1.02
                                     0.47
FURNACE OPERATIONS
                                      172
                                0.05 to 254.23
                                     3.80
                                     0.68
Alloy Induction
                                      97
                                 0.06 to 48.07
                                     1.46
                                     0.50
Alloy Arc
                                      38
                                 0.15 to 9.37
                                     1.95
                                     0.95
High Beryllium Vacuum Casting
                                       9
                                 0.13 to 4.03
                                     1.05
                                     0.31
High Beryllium Atomization
                                      13
                                0.54 to 254.23
                                     31.67
                                     5.56
Beryllium Oxide
                                      15
                                 0.05 to 5.13
                                     1.07
                                     0.27
POWDERING
                                      72
                                 0.06 to 11.52
                                     0.82
                                     0.37
Operator/Impact Grinding
                                      26
                                 0.08 to 3.33
                                     0.79
                                     0.59
Compact Loading/Sintering
                                      19
                                 0.06 to 11.52
                                     1.11
                                     0.22
Near Net Shape (operator and welder)
                                      27
                                 0.14 to 5.89
                                     0.65
                                     0.41
HOT WORK
                                      297
                                 0.01 to 2.21
                                     0.12
                                     0.06
Hot Rolling/Extrusion
                                      150
                                 0.01 to 0.56
                                     0.09
                                     0.06
Annealing
                                      64
                                 0.05 to 0.52
                                     0.13
                                     0.08
Welding
                                      15
                                 0.15 to 2.21
                                     0.52
                                     0.33
Pickling (elevated bath temperatures)
                                      47
                                 0.05 to 0.31
                                     0.08
                                     0.05
Degreasing (elevated solvent temperature)
                                      21
                                 0.05 to 0.21
                                     0.07
                                     0.05
COLD WORK
                                      555
                                 0.04 to 24.89
                                     0.31
                                     0.08
Rolling
                                      30
                                 0.05 to 1.08
                                     0.13
                                     0.05
Straightening
                                      56
                                 0.05 to 1.83
                                     0.17
                                     0.06
Drawing
                                      31
                                 0.05 to 0.20
                                     0.07
                                     0.05
Machining
                                      438
                                 0.04 to 24.89
                                     0.36
                                     0.09
Billet Preparation
                                      90
                                 0.05 to 18.97
                                     0.46
                                     0.13
Alloys
                                      216
                                 0.04 to 16.00
                                     0.19
                                     0.06
High Beryllium
                                      132
                                 0.05 to 24.89
                                     0.56
                                     0.17
PRODUCTION SUPPORT
                                      861
                                 0.02 to 22.71
                                     0.51
                                     0.08
Mix Makeup (furnace charge material)
                                      51
                                 0.05 to 4.20
                                     0.46
                                     0.24
Scrap Recycling
                                      111
                                 0.05 to 16.38
                                     1.08
                                     0.31
Inventory Control Center
                                      16
                                 0.08 to 2.66
                                     0.36
                                     0.17
Scrap Reclamation
                                      26
                                 0.05 to 8.89
                                     1.22
                                     0.43
Leaching
                                       6
                                 0.05 to 16.38
                                     3.39
                                     0.44
Resource Recovery
                                      63
                                 0.05 to 6.75
                                     0.98
                                     0.30
Maintenance
                                      345
                                 0.02 to 22.71
                                     0.73
                                     0.12
Production Equipment
                                      232
                                 0.05 to 22.71
                                     0.61
                                     0.11
Furnaces and Tools
                                      58
                                 0.05 to 14.62
                                     1.73
                                     0.53
Molds and Dies
                                      55
                                 0.02 to 2.98
                                     0.19
                                     0.05
Research and Development
                                      119
                                 0.05 to 2.01
                                     0.11
                                     0.05
QA/QC/Inspection
                                      235
                                 0.05 to 13.72
                                     0.14
                                     0.05
SITE SUPPORT
                                      879
                                 0.05 to 4.22
                                     0.11
                                     0.05
Laundry (work clothing and respirators)
                                      48
                                 0.05 to 0.49
                                     0.07
                                     0.05
Janitorial
                                      65
                                 0.05 to 0.65
                                     0.09
                                     0.07
Landfill
                                      30
                                 0.05 to 0.11
                                     0.05
                                     0.05
Facility Maintenance
                                      130
                                 0.05 to 1.23
                                     0.11
                                     0.07
Analytical Laboratories
                                      167
                                 0.05 to 1.52
                                     0.08
                                     0.05
Shipping/Receiving/Material Handling
                                      132
                                 0.05 to 0.19
                                     0.06
                                     0.05
Wastewater Treatment
                                      46
                                 0.05 to 0.99
                                     0.17
                                     0.09
Store (supply) Rooms
                                      32
                                 0.05 to 0.15
                                     0.06
                                     0.05
Security
                                      31
                                 0.05 to 0.22
                                     0.07
                                     0.05
Boiler Operators
                                      18
                                 0.05 to 0.48
                                     0.23
                                     0.16
Facility Engineering
                                      116
                                 0.05 to 1.13
                                     0.08
                                     0.05
Cafeteria
                                      16
                                 0.05 to 0.17
                                     0.07
                                     0.06
Decontamination
                                      48
                                 0.05 to 4.22
                                     0.47
                                     0.18
ADMINISTRATIVE
                                      981
                                 0.05 to 4.54
                                     0.10
                                     0.05
Operations/Management
                                      440
                                 0.05 to 2.68
                                     0.09
                                     0.05
Human Resources
                                      48
                                 0.05 to 0.05
                                     0.05
                                     0.05
Information Systems
                                      45
                                 0.05 to 0.10
                                     0.05
                                     0.05
Credit Union
                                      15
                                 0.05 to 0.10
                                     0.05
                                     0.05
Environmental Health and Safety
                                      132
                                 0.05 to 1.88
                                     0.07
                                     0.05
Medical
                                      52
                                 0.05 to 0.17
                                     0.06
                                     0.05
Training
                                      15
                                 0.05 to 0.34
                                     0.07
                                     0.05
Production Planning
                                      134
                                 0.05 to 4.54
                                     0.16
                                     0.05
Engineering
                                      100
                                 0.05 to 1.98
                                     0.13
                                     0.07
[a] 	The beryllium production exposure profile is a summary of the 1999 full-shift PBZ (lapel-type) total beryllium exposure results for workers at the Brush Wellman, Inc., Elmore, Ohio, plant.
[b]	 Full-shift sample results are based on the actual sample duration. Full-shift samples have a sample duration of 360 minutes or longer (in dataset, all samples are at least 400 minutes duration).
[c] 	Samples were analyzed by NIOSH Methods 7102 (Beryllium and compounds, as Be) or 7300 (Elements by ICP), and the analytical LOD was reported to be 0.1 ug per filter. In the dataset received by OSHA, a value had been assigned to each sample result that was below the LOD; a sample weight of 0.05 ug (one-half the analytical LOD) was used to calculate the volume-adjusted nondetectable sample concentrations (i.e., every sample was assigned a value). Samples with results below the LOD were not identified.
[d] 	PBZ means personal breathing zone (lapel-type) samples.
[e]	 Be Sulfate means beryllium sulfate salt production.

Source: Brush Wellman, 2004

Table IV-7 -- Distribution of Full-Shift PBZ Exposure Results for Total Beryllium in the Beryllium Production Industry by Job Category (1999) (NAICCS 331419)[a,b,c]
                                 Job Category
          Number of Full-Shift PBZ Sample Results in Range (ug/m[3])
                             Total No. of Samples

                                   < 0.1
                              >= 0.1 to <= 0.2
                              > 0.2 to <= 0.5
                              > 0.5 to <= 1.0
                              > 1.0 to <= 2.0
                                   > 2.0

CHEMICAL OPERATIONS
                                       1
                                     (5%)
                                       2
                                     (10%)
                                      10
                                     (50%)
                                       4
                                     (20%)
                                       2
                                     (10%)
                                       1
                                     (5%)
                                      20
                                    (100%)
FURNACE OPERATIONS
                                       8
                                     (5%)
                                      20
                                     (12%)
                                      42
                                     (24%)
                                      46
                                     (27%)
                                      25
                                     (14%)
                                      31
                                     (18%)
                                      172
                                    (100%)
POWDERING
                                       8
                                     (11%)
                                      13
                                     (18%)
                                      22
                                     (31%)
                                      14
                                     (19%)
                                      11
                                     (15%)
                                       4
                                     (6%)
                                      72
                                    (100%)
HOT WORK
                                      205
                                     (69%)
                                      56
                                     (19%)
                                      29
                                     (10%)
                                       6
                                     (2%)
                                       0
                                     (0%)
                                       1
                                     (0%)
                                      297
                                    (100%)
COLD WORK
                                      335
                                     (61%)
                                      107
                                     (19%)
                                      74
                                     (13%)
                                      13
                                     (2%)
                                      17
                                     (3%)
                                       9
                                     (2%)
                                      555
                                    (100%)
PRODUCTION SUPPORT
                                      484
                                     (56%)
                                      129
                                     (15%)
                                      105
                                     (12%)
                                      54
                                     (6%)
                                      43
                                     (5%)
                                      46
                                     (6%)
                                      861
                                    (100%)
SITE SUPPORT
                                      711
                                     (81%)
                                      100
                                     (11%)
                                      45
                                     (5%)
                                      15
                                     (2%)
                                       6
                                     (1%)
                                       2
                                     (0%)
                                      879
                                    (100%)
ADMINISTRATIVE
                                      833
                                     (85%)
                                      90
                                     (9%)
                                      39
                                     (4%)
                                      10
                                     (1%)
                                       6
                                    (0.5%)
                                       3
                                    (0.5%)
                                      981
                                    (100%)
[a]	The beryllium production exposure profile is a summary of the 1999 full-shift PBZ (lapel-type) total beryllium exposure results for workers at the Brush Wellman, Inc., Elmore, Ohio, plant.
[b]	Full-shift sample results are based on the actual sample duration. Full-shift samples have a duration of 360 minutes or longer (in dataset, all samples are at least 400 minutes duration).
[c]	Samples were analyzed by NIOSH Methods 7102 (Beryllium and compounds, as Be) or 7300 (Elements by ICP), and the analytical LOD was reported to be 0.1 ug per filter. In the dataset received by OSHA, a value had been assigned to each sample result that was below the LOD; a sample weight of 0.05 ug (one-half the analytical LOD) was used to calculate the volume-adjusted nondetectable sample concentrations (i.e., every sample was assigned a value). Samples with results below the LOD were not identified.

Source: Brush Wellman Elmore, 2004

OSHA also obtained more recent exposure samples taken by NIOSH at the Elmore facility from 2007 through 2008 (NIOSH Elmore database, 2011). This dataset, which was made available to OSHA by Materion Corporation, contains fewer samples than the 1999 survey. OSHA did not incorporate these samples into the exposure profile due to the limited documentation associated with the data. The lack of detailed information has made it difficult for OSHA to correlate job classifications and identify the exact working conditions associated with the samples. Also, OSHA does not know if this was a targeted sampling effort by NIOSH and Materion to identify the most problematic exposure areas, or if any other sampling strategy was employed. A more recent effort allowed OSHA to better understand the general tasks performed by workers reported by NIOSH at the time of sampling. Also, in a meeting held between OSHA and Materion Corporation in May 2012 at the Elmore facility, the Agency was able to obtain information on the exposure control modifications that Materion Corporation made between 1999 and 2007. OSHA still, however, cannot confirm what the baseline working conditions were at the time of sampling (NIOSH took the samples in 2007 and 2008) (Materion Information Meeting, 2012). Further, the dataset, as provided, did not include information documenting how the data might have been handled before they were made available for this analysis. For a more detailed breakdown of the supporting data by work groups, refer to Beryllium Production Appendix 1.
Overall, OSHA is cautious about drawing any conclusions from the supporting data, as it is not clear what the workers were doing and what controls were in place at the time of sampling. However, the dataset shows that the maximum values are considerably lower than those presented in the exposure profile in Table IV-6 (i.e., the highest exposure levels dropped dramatically between 1999 and 2008). This may be due to the exposure control improvements made by Materion at the Elmore facility between 1999 and 2007 (Materion Information Meeting, 2012). These controls may have helped reduce the variability of exposures. Additionally, three of the six mean values for the major job categories in the 2007 - 2008 dataset are lower than those in the profile, and two of the six median values are lower than those reported in the profile.
Table IV-8 -- Supporting Personal Exposure Profile in the Beryllium Production Industry (2007 - 2008) (NAICCS 331419)[a,b,c][,d,e,f]
                               Job Category and
                                  Work Group
                       No. of Full-Shift PBZ Samples[f]
                               Range (μg/m[3])
                                     Mean
                                  (μg/m[3])
                                    Median
                                  (μg/m[3])
CHEMICAL OPERATIONS
                                       3
                                 0.16 to 0.44
                                     0.27
                                     0.24
FURNACE OPERATIONS
                                      24
                                 0.01 to 9.24
                                     1.19
                                     0.62
PRODUCTION SUPPORT
                                      42
                                 0.01 to 9.24
                                     1.42
                                     0.40
COLD WORK
                                      70
                                   0 to 2.91
                                     0.30
                                     0.09
HOT WORK
                                      33
                                 0.01 to 1.30
                                     0.13
                                     0.06
POWDERING
                                      22
                                 0.11 to 11.57
                                     2.60
                                     1.50
SITE SUPPORT
                                    NO DATA
ADMINISTRATIVE
                                    NO DATA
[a] 	This supporting profile is a summary of the NIOSH 2007 full-shift PBZ (lapel-type) total beryllium exposure results for workers at the Brush Wellman, Inc., Elmore, Ohio, plant.
b 	Full-shift sample results are based on the actual sample duration. These sample durations are of 360 minutes or longer. Exceptions were made for several job categories due to the limited number of samples, and samples greater than 300 minutes were included for Production Support (i.e., ICC, Furnace and Tools, and Mold and Dies workgroups).
[c] 	Samples were analyzed by NIOSH Methods 7102 (Beryllium and compounds, as Be) or 7300 (Elements by ICP), and the analytical LOD was reported to be 0.1 ug per filter. For sample results below the LOD, a sample weight of 0.05 ug (one-half the analytical LOD) was used to calculate the volume-adjusted nondetectable sample concentrations.
[d] 	No sampling data was available for the following job categories and work groups: Administrative, Site Support, Production Support (Research and Development), Cold Work (Straightening, and Drawing), Hot Work (Welding), Furnace Operations (High Beryllium Atomization).
[e] 	Three outliers were excluded: a 321 μg/m[3] sample for Production Support (Leaching), a 33 μg/m[3] sample for Powdering (Impact Grinding), and a 29 μg/m[3] sample for Powdering (Compact Loading).
[f]	PBZ means personal breathing zone (lapel-type) samples.

Source: NIOSH Elmore database, 2011.

Technological Feasibility Analysis
This section presents the sampling data and information on exposure control methods that OSHA is relying on to evaluate the feasibility of a proposed PEL of 0.2 μg/m3 in the beryllium production industry. One indication of the feasibility of the proposed rule is the support that it has received from Materion Corporation, which worked closely with the United Steel Workers to produce a draft standard that was subsequently presented to the Agency for consideration (Materion and Steelworkers, 2012). Materion Corporation's adoption of a voluntary exposure limit of 0.2 μg/m[3] demonstrates its belief that achieving compliance with the proposed PEL is feasible. Materion Corporation provided a letter to OSHA stating the following:
Based on many years' experience in controlling beryllium exposures, its vigorous product stewardship program in affected operations, and the judgment of its professional industrial hygiene staff, Materion Brush believes that the 0.2 μg/m[3] PEL for beryllium, based on median exposures, can be achieved in most operations most of the time. Materion Brush does recognize that it is not feasible to reduce exposures to below the PEL in some operations, and in particular, certain beryllium production operations, solely through the use of engineering and work practice controls. (Materion Corporation, 2012)
OSHA recognizes that the professional staff at Materion Corporation has substantial experience with controlling beryllium exposure. Its staff has a unique perspective and understands how control measures perform in actual workplace conditions. Thus, OSHA recognizes that Materion Corporation's perspective is useful in the technological feasibility analysis that the Agency must conduct to support the proposed rule. However, in the technological feasibility analysis of the proposed rule for beryllium production, OSHA has collected and analyzed all available data to determine the lowest feasible exposure level that can be achieved in most operations most of the time.
Chemical Operations
The first step in beryllium oxide production involves a chemical operation that occurs in the wet plant, where high-purity beryllium sulfate salts are produced by dissolving beryllium hydroxide in sulfuric acid, filtering the solution to remove insoluble materials/impurities, and concentrating the resulting filtrate through evaporation/cooling.
The exposure profile for chemical operation workers (see Tables IV-6 and IV-7) is characterized by a median of 0.47 g/m[3], a mean of 1.02 g/m[3], and a range from 0.05 g/m[3] to 9.64 g/m[3]. According to Table IV-7, 85 percent of the full-shift PBZ total beryllium sample results for workers classified in the chemical operations job category were greater than 0.2 g/m[3].
The wet plant manufacturing process is almost entirely enclosed and isolated from workers (i.e., chemical additions and mixing are automated and enclosed), except at the process entry and exit points. At the process entry point, operators load drums of beryllium hydroxide into a barrel tilter inside an enclosed and ventilated feed station. After the beryllium hydroxide is loaded into the process, the operator cleans/rinses the empty drums with water inside the enclosure before removal. At the process exit point, the material is separated and sized by an automated wet-screening step and then dropped into drums at a filling station equipped with local exhaust ventilation (LEV) (collar-type local exhaust hood on drums during filling). After the drums are filled, the operator installs and seals the drum lids and removes and transfers the drums to the beryllium oxide furnaces using a lift truck equipped with a barrel grabber.
During chemical operations, operator exposure is attributable to: 1) filling/overfilling drums at the process exit and 2) handling, loading, dumping, and washing drums at the material feed station (process entry). Of the two, worker exposures are primarily associated with drum-filling at the process exit (Kent, 2005).
Exposures during drum-filling/overfilling can be reduced by installing a fail-safe drum-handling system to prevent fugitive emissions at connection points during material transfer operations, or by fully enclosing the engineered drum-handling systems. Potential problems with the existing drum-handling system also include material being retained inside valves and tubing, perhaps due to surface roughness, and the inability to see or otherwise determine if all the material has transferred. Ventilated enclosures around existing drum positions would reduce exposures during powder transfer activities. Exposures that result from drum overfilling can be reduced by automatic systems for detecting when a drum is full and automatically stopping the flow of product into the drum overflows (e.g., interlocked product containers with a weigh scale or timer function to prevent drum overflows).
Automated systems for cleaning and disposing of containers have been developed for other industries. For example, dust-free tipping booths have been designed for the pharmaceutical industry for handling highly hazardous powders and granules and reportedly can achieve dust control levels of 0.1 ug/m[3] or less. Exposures are reduced with automatic container lifting/tipping, high-visibility viewpoints, and glove port access. A modular design allows application customization for handling a wide variety of containers. Empty container disposal and cleaning systems can also be incorporated into the tipping and discharge systems (Hosokawa Micron Group, 2005). While OSHA has no data to show that such equipment can be adapted to the heavy industrial environment at the Elmore plant, the design concepts and approaches may be useful for addressing beryllium salt exposure.
Working in the same building with other high exposure operations (such as the wet plant, pebble plant, oxide furnaces, and resource recovery) also contributes to worker exposures (i.e., co-location exposures). Subsequent to the 1999 baseline exposure monitoring, the pebble plant and oxide furnaces were physically isolated from the rest of the building. Additionally, in 2000, the wet plant and pebble plants were decommissioned. The exposure reduction due to these changes is not known; however, an industry expert estimates that exposures might have been reduced by as much as 50 percent (Kent, 2005). Assuming a 50-percent reduction associated with isolating adjacent processes, a new exposure profile could be calculated with a median exposure of 0.23 g/m[3] and 40 percent of exposures at or less than the proposed 0.2 g/m[3] PEL. See Beryllium Production Appendix 2 for details.
Feasibility Conclusion for Chemical Operations
Besides removing the chemical operations from their physical proximity to other higher exposure operations, OSHA has limited information on the potential reduction in exposures that might occur as a result of the control methods discussed in this section. Based on the availability of control methods to reduce exposures for each of the major sources of exposure in chemical operations, OSHA preliminarily concludes that exposures at or below the proposed 0.2 g/m[3] PEL can be achieved in most chemical operations most of the time. However, the Agency does not have sufficient information to conduct a more quantitative assessment for this operation. As a result, significant uncertainty exists in its preliminary conclusion. OSHA seeks additional information and exposure data through the rulemaking process to further refine this analysis. Further, the Agency has insufficient information to preliminarily conclude that reducing exposures to or below a 0.1 g/m3 alternative PEL is feasible.
Furnace Operations
As shown in Table IV-6, the exposure profile for the furnace operation job category is characterized by a median of 0.68 g/m[3], a mean of 3.80 g/m[3], and a range from 0.05 g/m[3] to 254.23 g/m[3]. Only 17 percent of the of 172 full-shift PBZ total beryllium sample results reported for workers categorized in furnace operations work groups were at or below 0.2 g/m[3]. For this analysis, furnace operation workers include those involved with pure beryllium, both high- and low-beryllium-content alloys, and beryllium oxide furnace operations. Furnace operations involving the manufacture of beryllium pebbles from beryllium fluoride (fluoride and reduction furnaces) were in operation during the 1999 baseline exposure monitoring but have since been decommissioned and will not be discussed further.
The median exposures for all of the work groups included in the furnace operation job category exceed 0.2 g/m[3]. The median levels include:
0.27 g/m[3] for the beryllium oxide furnaces
0.31 g/m[3] for high-beryllium vacuum casting
0.50 g/m[3] for the alloy induction furnaces
0.95 g/m[3] for the alloy arc furnace
5.56 g/m[3] for high-beryllium atomization
Beryllium Production Appendix 2 also shows that all of the furnace operations sub-groups have exposures that exceed the current PEL of 2 g/m[3]. The highest exposures are reported for the alloy induction (48.07 g/m[3]) and high-beryllium atomization (254.23 g/m[3]) furnace operations. Table IV-7 indicates that 5 percent of the full-shift PBZ total beryllium sample results reported for furnace operations are less than 0.1 g/m[3] and that 83 percent of the sample results are greater than 0.2 g/m[3].
The size and operation of the furnaces at the Elmore plant vary substantially, and not all of the furnaces have the same sources of exposure. However, six major sources of exposure, if controlled, will reduce exposures in the various furnace operations:
Sampling furnace charge materials
Furnace charging
Dross removal
Fugitive emissions
Drum filling
Inconsistent work practices
The Agency has no data on the relative contribution of these sources to the overall exposure level in furnace operations. Controls for these major sources of exposure, where applicable, are discussed below for each of the types of furnaces at the Elmore facility.
The alloy arc furnace operations produce an ingot of 4 percent copper-beryllium master alloy that is subsequently remelted and diluted with other metals to form alloys with a reduced percentage of beryllium. These alloys are cast, hot rolled, and otherwise fabricated (NIOSH IWS-37-11). The process begins when beryllium hydroxide is rotary calcined to create beryllium oxide. Pelletizer feed materials consisting of beryllium oxide, carbon, and ventilation fines (dust collected from ventilation systems) are mixed and pelletized to create beryllium pellets. Copper and beryllium pellets (following sampling) are then charged remotely into the arc furnace. After charging, the furnace is tapped into a transfer ladle and dross is removed using a specialized tool. The metal is allowed to cool and then is degassed with nitrogen lances and poured into an ingot conveyor machine that generates 50-pound ingots. The pelletizing and furnace operations are fully enclosed and ventilated by a 40,000 cfm dust collection system (Kent et al., 2001).
The pelletizer's work tasks include monitoring feed material bin levels, unplugging storage bins, and ensuring proper operation of the calcining and pelletizing systems. Furnace operators weigh the raw copper, transfer 55-gallon drums of beryllium hydroxide into the calciner feed station, wash empty drums in the calciner feed station, charge and tap the furnace, remove and recycle dross, add furnace electrodes, and cast ingots (Corbett, 2006; Kent et al., 2001).
The arc furnace is charged through a computer-controlled closed system and is completely covered with a ventilated enclosure (furnace/room hood). An enclosed and ventilated operator control booth is available, and upon leaving the furnace area, workers must step onto a tack mat and pass through an air-wash chamber. Reportedly, the work tasks associated with the highest potential exposure include preparing the pelletizer feed material and sampling pellets for quality control (Kent et al., 2001). Operator interaction with the furnace is also a possible source of exposure. For example, furnace operators manipulate long tools (approximately 10 to 12 feet long) so that they slide in and partially out of the furnace. Operator movement and positioning with respect to access openings in the furnace hood and contaminated tools might be a factor associated with potential exposure. Additionally, the pelletizing and arc furnace operations are integrated with each other. Beryllium contamination and migration associated with the pelletizing operation might be factors in the exposure of the arc furnace operator and vice versa. Other sources of exposure include electrode replacement (not conducted on a regular basis) and process-related leaks associated with the calciner (e.g., gasket/seal failures). Process equipment leaks and fugitive emissions might account for up to 40 percent of worker exposure (Kent, 2005). Enhancing the preventive maintenance program for the calciner and other process equipment will prevent process-related leaks and resultant exposures. Reducing the number or magnitude of process-related leaks will reduce fugitive emissions and contribute to lower worker exposures.
Exposures may also be reduced by improving engineering controls for pellet and oxide sampling. For example, creating a small opening (or some other type of engineering intervention) for workers to sample pellets, as opposed to opening the pelletizer access door, would reduce contact with large amounts of beryllium-containing material. NIOSH reported on a beryllium alloy plant that uses five automatic Isolok(R) solid-material samplers in their calcining and reduction operation to sample fresh beryllium oxide from the calciner and storage bins, flue dust, blended material, and finished product (4 percent beryllium-copper alloy) (NIOSH ECTB 113-14a; NIOSH ECTB 113-14b). The pneumatic samplers operate on a positive displacement, closed collection principle. A fixed amount of solid sample is withdrawn with each stroke of the single moving plunger. The extracted sample falls into a closed sample container (plastic collection bottle) that is manually removed on a periodic basis and carried to the laboratory for analysis. A new collection container is manually attached to the sampler for the next sampling cycle. In addition to the automatic samplers, the plant also utilizes a negative pressure isolation/enclosure chamber for the beryllium oxide storage bin and the calciner operation. To evaluate the solid material sampling operations, NIOSH investigators collected area air samples over five shifts at 13 locations in the calcining and reduction area. The average beryllium concentrations ranged from 0.1 ug/m[3] to 1.06 ug/m[3]. NIOSH investigators concluded that the design of the automatic solid material samplers significantly contributed to lower worker exposures (NIOSH ECTB 113-14a; ECTB 113-14b).
Further reductions in exposure can be achieved by incorporating Isolok solid material samplers with pharmaceutical-quality glove boxes to control exposures associated with removing and capping sample collection containers (Sentry Equipment Corporation, 2005). The suitability of Isolok solid material samplers in conjunction with pharmaceutical-quality glove boxes for beryllium pellets is not known and is likely contingent on the size and flow characteristics of the pellets. The equipment manufacturer indicates that its solid material point samplers (Isolok series and other models) may be used with free-flowing and non-free-flowing bulk solids with particle sizes up to (3/4)-inch (depending on model); samplers for larger product sizes are available upon request (Sentry Equipment Corporation, 2006). This equipment could potentially be used at the Materion pellet and oxide sampling operations. The samples at the Elmore plant can be both free- and non-free flowing, and the oxide powder and beryllium metal pellets particles are both expected to be less than (3/4) of an inch in size.
Improving work practices can minimize potential exposures associated with some of the arc furnace operation, such as rubbing/skimming, tapping, casting, and drum loading. Work practice improvements might include additional employee training, better supervision of existing procedures, and/or the development of new or revised procedures to better control workplace exposures. For example, arc furnace operators could lower their beryllium exposures by waiting until their tools have cooled (and are not fuming) before withdrawing them from the furnace. During casting, workers need to skim dross from the ingot mold and carefully place it in the appropriate collection containers. If workers handle the dross in a careless and sloppy manner, they increase the level of contamination in the work area and their exposure to beryllium. While OSHA has no data to estimate exposure reductions that may be realized by improving these work practices, it seems clear that substantial opportunities exist for reducing exposures through improved work procedures.
The induction furnace melting and casting operations produce beryllium alloys containing a lower percentage of beryllium (0.1 to 2 percent). Furnace charges are prepared in mix stations, placed in tubs, and charged in the furnaces through pneumatically controlled carts. After the charge has melted, the furnace walls are rubbed to remove buildup, dross is skimmed off the surface, and the molten metal is degassed and cast into water-cooled molds (Kent et al., 2001).
Two workers operate each furnace: a deck worker and a floor worker. Tasks with potential exposure that are conducted by the deck worker include charging, rubbing, skimming, degassing, and changing full dross barrels. Tasks with potential exposure that are performed by the floor worker include setting up the mold; heating, placing, and cleaning the tundish; and pouring the furnace. The tasks associated with the most significant exposures are reported to be rubbing and skimming, changing full dross barrels, and cleaning the tundish (Kent et al., 2001; Kent, 2005). Dross-related tasks present the greatest exposure potential -- accounting for as much as 70 percent of worker exposures -- because the dross may contain up to 16 percent beryllium (Kent, 2005). Dross formation can be minimized, but not eliminated, by melting under inert gas (e.g., inert gas blanketing with liquid argon) or by melting in air with a graphite cover or blanket. The percent reduction in dross formation achieved with these techniques is not available. However, inert gas or molten metal blanketing technologies developed by one company reportedly reduce dross/slag formation by up to 50 percent (Air Products, 2005).
At the time the 1999 baseline exposure data were collected, some engineering controls were operational, such as custom-designed LEV hoods and/or enclosures at furnace openings, LEV for tool holders and integrated dross chute/collection systems, and LEV for tundish cleaning activities. Several controls have been added since the 1999 baseline exposure data were collected, including operator control booths equipped with air conditioning and HEPA filters installed near the furnaces (for furnace and casting operators). In addition, workers exiting the melting and casting area in the New Cast Shop must clean their work shoes with a foot cleaner and pass through a HEPA-filtered air shower, both of which serve to limit the spread of beryllium contamination from the furnace operation to other areas of the plant.
Another improvement that will reduce exposures is enhancing and/or installing LEV where appropriate. Potential examples in the Old Cast Shop include the following: 1) modifying the dross chute LEV to accommodate the extremes during filling of the dross barrel; 2) ensuring adequate LEV throughout drossing (reportedly there is a short period of time with inadequate LEV when the filled dross tray is tipped into the dross barrel); and 3) using LEV while mechanically removing (i.e., prying/chipping) solidified dross and metal from the tundish. Improved LEV and work practices together might be expected to reduce exposures by one-half or one-third of previous exposures (Kent, 2005).
Exposures can be further reduced by automating (partially or fully) the drossing operation to eliminate manual skimming, rubbing, and changing of the dross barrel. The feasibility of mechanically removing dross and deposits on furnace walls needs to be investigated. Several induction furnace manufacturers suggest that it is possible to automate dross removal and retrofit existing furnaces (Pillar, 2005; Inductotherm, 2005; ABB, 2005). One furnace manufacturer is creating partially automated dross removal for iron and aluminum furnaces for some of its customers (ABB, 2005). Because beryllium furnaces operate at a higher temperature, this technology is not directly applicable, but it suggests that such technology is promising if it can be adapted to higher operating temperatures.
Removing slag deposits on furnace walls requires applying the correct amount of hand pressure during rubbing and scraping of the furnace lining after casting. If done incorrectly, the refractory lining could be damaged (cracked), possibly resulting in superheated molten metal and/or a furnace explosion during subsequent melting cycles. Furnace manufacturers suggest that employers might be reluctant to allow modifications to furnace designs because of concerns that dross removal features might impact the safety of furnaces. Although automated dross removal (i.e., skimming dross off the surface of molten metal) appears possible, manual rubbing of furnace walls is likely more efficient than mechanical removal and may be preferred due to safety concerns (Pillar, 2005; Inductotherm, 2005; ABB, 2005; AFS, 2005).
Work practices can be enhanced through operator training, work practice modifications, and better supervision. For example:
1.          During drossing in the Old Cast Shop, operators should avoid overfilling the dross tray. When the overfilled tray is tipped into the dross barrel, the dross chute LEV can be overwhelmed by excessive fumes, causing increased worker exposure.
         When removing rub bars from the furnace, operators need to lay the tools on the furnace deck to allow the fuming parts to cool near the furnace LEV before placing the tools in the ventilated holder.
         After casting, furnace operators need to clean the tundish and furnace pour spout and carefully place "cleanings" in the appropriate collection containers. If operators handle the cleanings in a careless and sloppy manner, they increase the level of contamination in the work area and their exposure to beryllium.
Although beryllium exposure reductions specifically associated with enhanced housekeeping practices in foundries are not available, information on other common foundry dusts demonstrates the point. An OSHA inspection report describes crystalline silica and respirable dust reductions in a ferrous sand casting foundry after the facility vacuumed and washed walls and dust accumulation points in the casting cleaning department (OSHA SEP Inspection Report 303207518). Initially, general area samples indicated that the background respirable silica level in the casting cleaning department was 63 ug/m[3]. After the foundry-wide cleaning, no respirable silica was detected in the casting cleaning department air (estimated as less than 12 ug/m[3] or an exposure reduction of at least 81 percent). Additionally, total respirable (which contains respirable silica and other particles) dust levels were 60 percent to 80 percent lower than the original level of 1.4 mg/m[3].  While it is not known whether a similar exposure reduction could be achieved in the Elmore plant, this example demonstrates the extent to which worker exposures can be influenced by diligent housekeeping efforts.
High-Beryllium Vacuum Casting is a furnace operation designed to produce feedstock (vacuum-cast billets) for powder-making operations (National Materials Advisory Board, 1989). Beryllium feed material (e.g., reclaimed chips and scrap) is vacuum-melted inside a tilt-pour induction furnace and poured into graphite molds to produce round billets that are approximately 3 to 4 feet long. The billets are manually cleaned (pressure washed) and prepared inside an exhaust hood and then transferred to the powder-making operation. Likely sources of exposure include charge makeup (i.e., the job task in which the furnace charge is prepared inside a hood that the operator enters), and cleaning/preparing billets for powder making.
Workers currently enter the charge makeup hood to charge the furnace and, as a result, are exposed to furnace emissions that exist within the hood. Isolating or automating the furnace charge operation such that the operator no longer needs to enter and work inside the hood will reduce worker exposure as well as furnace emissions that also contribute to exposure. More effective LEV that is enhanced through additional exhaust flow and/or better hood design will also contribute to reduced exposures.
Additional opportunities for reducing exposures can be identified by performing a task analysis to determine which tasks associated with billet preparation contribute most to worker exposure and then implementing work practice improvements and LEV changes/modifications to further reduce worker exposures. For example, the effectiveness of the billet preparation hood could be enhanced through additional exhaust flow and/or better hood design. An LEV system meeting design criteria developed by the ACGIH would be expected to achieve a significant reduction in exposure (assuming that the existing billet preparation hood is not effective enough in controlling operator exposure).
High-Beryllium Atomization is a furnace operation where the final product is aluminum-beryllium or beryllium powder. Appropriate feed material (e.g., aluminum, beryllium scrap, virgin materials) is melted, refined, and degassed in a small vacuum induction melting furnace (approximately 8 to 10 inches in diameter and 18 to 24 inches long) (Corbett, 2004). The refined furnace melt is poured through a preheated tundish system into a gas nozzle, where the melt stream is disintegrated by the kinetic energy of a high-pressure gas stream of argon. The metal powder that is produced solidifies in flight in the atomization tower located directly beneath the atomization nozzle. The powder-gas mixture is transported through a conveying tube to a cyclone where the course and fine powder fractions are separated from the atomization gas. The metal powder is collected in sealed intermediate product containers located directly below the cyclones. The powder is screened, blended, and collected in final product containers (Kent, 2005).
Atomization work tasks include manually charging the furnace, cleaning the furnace and tundish after each pour, and cleaning the atomization cyclone at periodic intervals. Atomized powder is screened and collected in product containers that are connected to the process through engineered drum-break valves with LEV (Kent, 2005).
Potential worker exposure is associated with powder leakage when removing filled collection containers at the base of the atomizer. A number of other factors also might affect exposure. The atomizer operator prepares the furnace charge in a separate LEV hood and manually transports it to the furnace chamber. Operators charge the furnace by physically picking up the charge material and manually placing it in the furnace chamber. This operation was done without LEV during the 1999 baseline exposure monitoring. The operator performs rubbing and skimming and also cleans the atomizer cyclone and the ceramic tundish inside the furnace. The tundish is manually cleaned (by chipping with a bar) between pours. It is cleaned in place inside the furnace chamber, which is under negative pressure. The chipped material is removed from the furnace chamber and placed in a ventilated chute, where it drops into a collection drum. Information regarding the potential exposure associated with this task is not available. Reportedly, the LEV associated with the furnace chamber was insufficient for controlling beryllium particulate generated during tasks requiring chamber access (Kent, 2005).
The atomizer cyclone is cleaned infrequently (about once a year) and is also under negative pressure. It is large enough that the operator can physically get his head/torso inside, and it is cleaned by vacuuming and scraping down the sides. Potential exposure is associated with this cleaning task because the operator can place his head inside the cyclone; however, no information is available regarding the exposure associated with this task.
After the 1999 baseline exposure monitoring, several engineering changes were made to the atomization operation. These changes include the following: 1) replacing the baghouse collector with a new, larger capacity HEPA-filtered collector; 2) replacing the ventilation ductwork with correctly sized ductwork for maximum effectiveness; 3) installing a HEPA-filtered makeup air system (laminar flow design); 4) modifying the powder collection system to reduce the total number of times drums are opened or handled per shift (by using larger collection containers); 5) enclosing the furnace/tundish access area with a box-like Plexiglas enclosure (with access door) to better contain beryllium contamination and migration; and 6) installing LEV over/around the furnace charging area.
After the installation of the additional engineering controls, peak exposures were reduced more than 90 percent, from 253 g/m[3] to 24 g/m[3], and mean exposure was reduced more than 67%, from 31.76 g/m[3] to 9.82 g/m[3] (based on 13 samples) (Kent, 2005). Information on how much the median exposure was reduced is not available. However, based on Kent's (2005) estimate that engineering controls reduce exposures by an average of 20 to 50 percent, OSHA estimates that these engineering improvements reduced the median exposure level by 35 percent (average of 20 to 50 percent), from 5.56 ug/m[3] to approximately 3.61 ug/m[3].
Performing a task analysis for the atomization process would identify work methods (e.g., charge makeup, rubbing/skimming, and make/break connections) that contribute most to worker exposure, and work practice improvements. For example, there is a proper sequence of steps (such as avoiding spills by ensuring that the transfer equipment is empty before breaking connections) that must be followed during make-break connections. Workers might not realize that following a certain sequence of steps impacts their beryllium exposure. Work practice improvements might include additional employee training, better supervision of existing procedures, and/or the development of new or revised procedures to better control workplace exposures.
Once engineering and work practice improvements have been implemented, worker exposure associated with opening powder drums and removing filled collection containers at the base of the atomizer should be re-evaluated. Additional controls include installing a fail-safe drum-break system to prevent fugitive emissions from the collection container connection point at the base of the atomizer or fully enclosing the powder drum break (e.g., with a high-containment isolation booth). Potential problems with the existing drum-break system also may include material retained inside valves and tubing -- perhaps due to surface roughness -- and the inability to see or otherwise determine if all the material transfer has occurred.
The beryllium oxide furnaces produce beryllium oxide powders when wet-screened beryllium sulfate salt is calcined in hearth furnaces. The furnaces have top-ventilated, full enclosures at the loading/unloading point that consist of removable metal wall panels. To load the furnaces, operators remove one of the front wall panels from the enclosure, empty drums of wet beryllium sulfate salt into large rectangular refractory containers with a lift truck equipped with a barrel grabber, and then load the refractory containers into the furnace chamber. The refractory containers are thick walled (approximately 1 foot thick), about 10 feet wide and 20 feet long, and are positioned on a roller track that leads into the furnace chamber. The furnace chamber is under negative pressure and is accessed through a set of doors. Although the furnace has LEV, bake-out emissions are released into the workplace and significantly affect worker exposure. After the furnace is loaded and closed, operators reinstall the removable wall panel on the enclosure. The beryllium sulfate salt gets fired in the furnace for several days and is transformed into a fluidized bed of beryllium oxide powder. After a cooling period (approximately one day), the operators again remove a front wall panel from the enclosure and manually vacuum-convey and screen (size) the beryllium oxide powder to collection containers. The beryllium oxide powder inside the vacuum-conveyance system is enclosed and isolated from the operator, and the product collection containers are located in a ventilated hood. Operators use a vacuum wand that is about 10 feet long to vacuum-convey the beryllium oxide powder.
Key sources of potential operator exposure include the following activities: charging the furnace with beryllium sulfate salt, empty drum handling and cleaning, manually vacuum-conveying the beryllium oxide powder to collection containers, filling/overfilling the collection containers, and changing out product drums.
Rough estimates of exposures by activity are provided by Kent (2005). Exposures associated with furnace charging and bake-out emissions are estimated to account for 50 percent of worker exposure (fifteen percent might be attributed to furnace charging and empty drum handling and cleaning, and 35 percent could result from bake-out emissions). Kent estimates that the other 50 percent of worker exposure is due to filling and changing out product collection containers.
As shown in Table IV-6, the median (and baseline) exposure level for beryllium oxide furnace operators is 0.27 g/m[3]. Additional controls are required to further reduce worker exposures. Based on the available information, these additional controls include:
Performing a task analysis to identify work methods that contribute most to worker exposure, and implementing work practice improvements to further reduce exposure. For example, during furnace charging and vacuum filling, workers should never have more than one panel removed from the furnace enclosure. Removing more than one panel can adversely affect the exhaust flow within the enclosure. Additionally, during container filling, the vacuum wand gets contaminated and contributes to worker exposure if it is pulled too far out. To reduce the potential for exposure, workers need to leave the wand inside the ventilated enclosure. Such work practice improvements might also include additional employee training, better supervision of existing procedures, and/or the development of new or revised procedures to better control workplace exposures.
Increasing the effectiveness of the exhaust ventilation in the paneled furnace enclosure by replacing/fixing damaged wall panels and/or increasing the exhaust flow. The exposure reduction that might be achieved with this improvement is estimated to be about 10 percent (Kent, 2005).
Enhancing engineering controls associated with filling and changing out product collection containers (estimated to account for 50 percent of worker exposure). For example, high-hazard, laminar-flow powder booths (containment isolators) with integrated weighing systems can reduce operator exposure associated with drum filling operations.
Enhancing/installing engineering controls for furnace charging and empty drum handling and cleaning (estimated to account for 15 percent of worker exposure). For example, dust-free tipping booths have been designed for the pharmaceutical industry for handling highly hazardous powders and granules and reportedly can achieve dust control levels of 0.1 ug/m[3] or less. Exposures are reduced with automatic container lifting/tipping, high-visibility viewpoints, and glove port access. A modular design allows application customization for the handling of a wide variety of containers. Empty container disposal and cleaning systems can also be incorporated into the tipping and discharge systems (Hosokawa Micron Group, 2005). While OSHA has no data to show whether such equipment can be adapted to the heavy industrial environment at the Elmore plant, the design concepts and approaches may be useful.
Eliminating bake-out emissions from the 1950s-era furnace (perhaps by sealing/ventilating furnace openings and/or redesigning the furnace doors). The estimated exposure reduction that might be achieved with this engineering control is 35 percent. However, OSHA lacks adequate information regarding the source(s) of the emissions and whether engineering improvements are feasible.
Feasibility Conclusion for Furnace Operators
Overall, furnace operations have the highest exposure levels in the Elmore plant and therefore present a significant challenge in controlling exposures to or below the proposed 0.2 g/m[3] PEL. A variety of sources of beryllium exposure are associated with the furnace operations. Each source contributes to workers' exposures, but data are not available to estimate the relative contribution of each source to workers' overall exposure. The Elmore plant has implemented many control measures since the 1999 survey and, as a result, has achieved significant exposure reductions. OSHA has identified additional control measures for reducing exposures for each major source of exposure. Employers have additional control options that have been shown to be effective in other industries. Whether controls developed for other industries are directly applicable to the beryllium production environment is uncertain, but the design concepts and general approaches may be effective in further reducing workers' exposures to or below the proposed 0.2 g/m[3] PEL. However, OSHA acknowledges that furnace operations pose perhaps the greatest challenge to controlling beryllium exposures in beryllium production operations. The furnaces in Materion's Elmore facility are unusual compared to furnaces in aluminum and copper foundries, in that they contain either pure beryllium or high-beryllium content alloys in addition to low-beryllium alloys. OSHA preliminarily concludes that exposures at or below the proposed 0.2 g/m[3] PEL can be achieved in some furnace operations most of the time. However, the Agency is not certain whether exposures can be reduced to the proposed PEL in most operations most of the time. Additionally, the Agency believes that reducing exposures to a 0.1 g/m3 alternative PEL would also be challenging. Therefore, OSHA requests additional information, including exposure data and effectiveness of controls, which demonstrate the ability of control strategies to maintain exposures to the proposed PEL or an alternative PEL of 0.1 g/m[3].
OSHA acknowledges that respiratory protection may be needed in some high-exposure furnace operations. The Agency does not have sufficient information to conduct a quantitative assessment for this operation. As a result, there is significant uncertainty in its preliminary conclusion. OSHA seeks additional information and exposure data through the rulemaking process to further refine this analysis.
Powdering Operations
The Elmore plant produces beryllium powder, which is then used in other processes. Three major powdering operations are:
Impact grinding. Vacuum-cast billets are prepared for machining, loaded into lathes, and milled into chips. The beryllium chips are vacuum-conveyed into collection containers and subsequently loaded into an impact-grinding (powder-generating) operation. During impact grinding, beryllium chips are injected into a high-speed air stream and impacted against a beryllium target to generate beryllium powder. The beryllium powder is sized using screens, collected in containers, and transferred to powder blenders for mixing. The powder containers are manually loaded and unloaded into/from the blenders. The blended powder containers are then transferred to the compact loading operation for subsequent processing. The primary source of exposure is associated with fugitive emissions when connecting and disconnecting chip-containing drums from chipping operations, and when connecting and disconnecting powder-containing drums from blenders.
Compact loading/sintering. During compact loading, workers load and cap vertically oriented cylindrical graphite dies with beryllium powder. The dies are placed in a tall, fully enclosed loading hood (approximately 15 to 20 feet tall) equipped with back and side-draft exhaust ventilation and are top-loaded with beryllium powder received from the impact grinding operation. A worker is located inside the hood to physically observe the loading process (with a flashlight) in an effort to prevent overloading of the die and a subsequent powder spill. During loading, the beryllium powder is packed by vibrating the drum (shaken and compacted as much as possible). The loaded die is capped with a graphite plug, removed from the loading hood, and transferred to a belowground sintering furnace. During the sintering process, the powder is consolidated into a billet in an inert environment using heat and pressure. The finished billet is removed from the die (pushed out with a hydraulic ram) in a die-stripping hood that is equipped with back-draft exhaust ventilation. Worker exposure is primarily associated with two activities -- installing and removing containers of powder from the compact loading hood and die loading.
Near Net Shape. NNS refers to a process in which beryllium powder is consolidated into a part of a shape that is determined by the container volume. The powder is created after beryllium chips are minimized through impact grinding. This beryllium powder is loaded into dies and consolidated into preformed shapes with one or more techniques involving heat and/or pressure (cold and hot isostatic pressing). After consolidation, the dies are unloaded using different techniques depending on the type of die (i.e., rubber, steel, or copper). Rubber dies are used for cold isostatic pressing, and steel and copper dies are used for hot isostatic pressing. Dies are unloaded differently depending on the type of die. Rubber dies are cut open inside an exhaust hood. Steel and copper dies are loaded into a nitric acid bath and dissolved. The acid tank is located in a separate room and is equipped with an exhausted partial enclosure that is open at the top/face for loading purposes.  Worker exposure is primarily associated with the loading of powder into dies, and removal of the consolidated shape from the die.