Tables IV-6 and IV-7 shows that exposures in these operations are high. Exposures in powdering operations are characterized by a median of 0.37 g/m[3] and a mean of 0.82 g/m[3], and 71 percent of the 72 samples taken on workers in powdering operations exceed the proposed 0.2 g/m[3] PEL. Material transfer points, where powder is transferred from the process to containers or from containers to other areas of the process, are likely the major sources of exposure in these operations. In addition, the compact loading/sintering operation has another source of exposure--when the worker enters the loading hood to visually (with a flashlight) observe the level of powder as the cylindrical graphite die is filled.
Installing a fail-safe system for handling open drums or fully enclosing the engineered drum-handling system could prevent fugitive emissions at connection points and reduce exposures during material transfer operations. These fugitive emissions in powdering operations may occur when transfer equipment (e.g., drums and tubing) are disconnected, and material retained inside valves and tubing is released in to the air. Additionally, with existing material transfer equipment, a worker may not have the ability to see or otherwise determine if all of the material transfer has occurred and may disconnect the transfer equipment prematurely, releasing emissions in to the air.
One example of a fail-safe system is provided by the pharmaceutical industry. Pharmaceutical quality packing head systems are used for filling/weighing operations involving high-hazard powders.  Packing head systems provide a sealed connection between the filling device and the container for dust-free transfer of product (Hosokawa Micron Group, 2005). Reportedly, pharmaceutical quality high containment powder and granule handling systems can achieve dust control exposure levels of 0.1 ug/m[3] or less (Hosokawa Micron Group, 2005). OSHA does not know whether these controls are suitable for metallic beryllium machining chips (i.e., materials other than powder and granular solids).
Ventilated enclosures around existing drum stations would also reduce exposures during powder transfer activities. The Elmore facility installed ventilated enclosures for scrap handling operations that may also be installed during transferring of powder and chips. Hosokawa Micron Group (2005) also reports that packing heads used in conjunction with ventilated containment booths further ensure operator safety during container filling.  Alternatively, containment booths can be used as secondary containment between two vessels during transferring operations. Typical applications for powder containment booths include large scale dispensing, weighing, and product sampling.
In the compact loading/sintering operations, installing remote viewing equipment (or other equally effective engineering controls) to eliminate the need for workers to enter the die-loading hood during die filling will reduce exposures associated with this work task as well as potential powder spills. The installation of remote viewing equipment for compact loading/sintering operations could be in the form of cameras inside the hood that would transmit the loading process to a control booth equipped with monitors to observe the loading operations, and controls to stop or start the loading process. OSHA notes that while the Materion Elmore plant may not have these controls in place, OSHA believes that control booths are common enough in industry that retrofitting this and similar powdering operations with control booths would be feasible.
Feasibility Conclusion for Powdering Operations
Based on the availability of control methods to reduce exposures for each of the major sources of exposure in powdering operations, OSHA preliminarily concludes that exposures at or below the proposed 0.2 g/m[3] PEL can be achieved in most powdering operations most of the time. However, the Agency believes that achieving an alternative PEL of 0.1 ug/m[3] most of the time would be challenging for this job category most of the time with the use of engineering controls and work practices. Note that even though Hosokawa Micron Group (2005) may suggest that 0.1 g/m[3] may be possible during transferring of powder, OSHA is not certain whether all sources of exposure in powdering operations can be consistently controlled to 0.1 g/m[3].
The Agency also lacks 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.
Hot Work
Hot work is metal shaping and forming using equipment that heats the metal during processing. Hot work includes hot rolling/extrusion, annealing, pickling, degreasing, and welding. Exposures are generally relatively low in these activities. According to Table IV-6, workers in hot work operations experience mean and median exposures of 0.12 and 0.06 g/m[3], respectively, with a maximum exposure level of 2.21 g/m[3]. Table IV-7 shows that 88 percent of hot work exposures are less than or equal to the proposed 0.2 g/m[3] PEL, and 69 percent are less than the alternative PEL of 0.1 g/m[3]. Welding is the highest exposure activity in the hot work category. Welding on beryllium-containing material is discussed in detail in the section on Welding and will not be discussed here because no substantial difference exists between the welding operations conducted at the Elmore plant and those at other establishments potentially affected by the proposed rule. Removing the welding data from the hot work exposures profile, OSHA calculates that 91 percent of exposures related to hot rolling/extrusion, annealing, pickling, and degreasing are less than or equal to the proposed 0.2 g/m[3] PEL.
Exposure controls for workers performing hot work vary depending on the work group and are briefly summarized in Table IV-9.
Table IV-9 -- Baseline Controls for Hot Work
Work Group
Baseline Exposure Controls
Hot Rolling
Use of canopy hoods over the entry and exit mill stands.
Daily housekeeping to prevent accumulation of loose surface oxides along the run-out tables.
Work uniforms.
Extrusion
Use of close-capture exhaust hoods on cut-off saws.
Use of partially enclosed exhaust hood for die-grinding work.
Work uniforms.
Annealing
Use of inert nitrogen atmospheres to reduce formation of loose surface oxides.
Work uniforms.
Pickling (elevated bath temperatures)
Use of pickling and rinse baths that are fully enclosed and exhausted.
Work uniforms.
Degreasing (elevated
solvent temperatures)
Nothing additional -- product is clean and free of loose surface oxides.
Work uniforms.

Feasibility Conclusion for Hot Work Operations
For those situations in which hot work results in exposures above the proposed 0.2 g/m[3] PEL, additional controls are available, as described in the sections on Precision Turned Products; Copper Rolling, Drawing, & Extruding; and Welding, of Chapter IV of the PEA. OSHA preliminarily concludes that exposures at or below the proposed 0.2 g/m[3] PEL and below a 0.1g/m[3] alternative PEL can be achieved in most hot work operations most of the time.
Cold Work
Cold work is the process of shaping and forming beryllium and beryllium alloys without applying heat. Cold work includes rolling, straightening, drawing, and machining the variety of beryllium-containing metal products manufactured at the Elmore facility. In general, these processes have a relatively low potential for beryllium exposure, as they produce very little dust, fume, or other small beryllium-containing particles. As shown in Table IV-7, 80 percent of exposures related to cold work are less than or equal to the proposed 0.2 g/m3 PEL, and 61% are below the alternative PEL of 0.1 ug/m[3]; however, these sample results range from 0.04 g/m[3] to 24.89 g/m[3], indicating that extreme exposures occasionally do occur (see Table IV-6). Mean and median exposures for cold work, according to Table IV-6, are 0.31 g/m[3] and 0.08 g/m[3], respectively.
Cold work operations already have significant and effective control methods in place. Exposure controls for workers engaged in rolling, straightening, drawing, and machining are summarized in Table IV-10.
Table IV-10 -- Baseline Controls for Cold Work Groups
Work Group
Baseline Exposure Controls
Rolling
Use of canopy hoods over mills, coilers, and up-coilers to control oil mist.
Filter rolling oil to minimize the accumulation of beryllium in the oil.
Work uniforms.
Straightening
Remove loose surface oxides (by cleaning) from material surfaces prior to straightening.
Wet material surfaces to contain loose surface oxides and minimize airborne dispersion.
Use LEV along roller stands.
Work uniforms.
Drawing
Remove loose surface oxides (by cleaning) from material surfaces prior to drawing.
Work uniforms.
Machining (alloys)
Remove loose surface oxides (by cleaning) from material surfaces prior to machining.
Machine under flood coolant.
Filter machining coolant (if necessary) to minimize the accumulation of beryllium.
Work uniforms.

The mean and median exposures for rolling, straightening, and drawing are 0.13 g/m[3] and 0.05 g/m[3], 0.17 g/m[3] and 0.06 g/m[3], and 0.07 g/m[3] and 0.05 g/m[3], respectively. For the few exposures in rolling, straightening, and drawing that exceed the proposed 0.2 g/m[3] PEL, additional controls may be needed. These controls are described in detail in Section 8 -- Copper Rolling, Drawing and Extruding.
Overall, machining activities have a significantly wider range of exposures, as can be observed by the highest values for the three machining subgroups (18.97 g/m[3] for billet preparation, 16 g/m[3] for alloys, and 24.89 g/m[3] for high beryllium) when compared to the highest values for rolling, straightening, and drawing (1.08 g/m[3], 1.83 g/m[3], and 0.20 g/m[3], respectively). Therefore, additional controls may be needed for these machining activities to ensure that workers are not exposed to these elevated levels of airborne beryllium. Only those aspects of machining operations that are specific to the Elmore plant (such as machining large billets and machining in close proximity to high-exposure potential beryllium manufacturing operations) are discussed here. Section 7--Precision Turned Products provides a detailed description of machining operations in general, along with the available control methods for reducing worker exposures. Note that the controls discussed below apply to machining with low- and high-beryllium-containing billets.
At the Elmore plant, machining may be done manually or with the use of precision computer-controlled equipment. Activities associated with machining might include milling, turning, cutting, grinding, drilling, deburring, sawing, swaging, slitting, sanding, tool grinding, and other forms of tool maintenance. Machining might be conducted with no engineering controls, wet (with flood coolant) or dry, with or without LEV, and with or without equipment enclosures. The controls utilized depend on the beryllium content of the parts or shapes being machined and the type of machining being performed (i.e., beryllium particle size and generation rate). For example, high-beryllium-content parts are machined wet or dry, with LEV hoods and enclosures. Dry machining utilizes low-volume/high-velocity (LVHV) source capture with specially designed hoods providing close capture. If machining is performed wet, the machining equipment can be enclosed in a high-volume/low-velocity (HVLV) hood to contain the coolant. Beryllium alloys are typically machined wet but without LEV or machine enclosures. Worker exposures are associated with numerous factors, including working in close proximity to high-exposure activities (e.g., melting and casting); work practice issues, such as improper positioning of LVHV source capture exhaust ducts and opening machine enclosures during the machining cycle and/or too soon after the completion of the machining cycle; inadequate management/containment of beryllium-contaminated coolant; and inadequate or absent LEV and/or machine enclosures.
Machining exposures are influenced by the concentration of beryllium present in the material. Beryllium Production Appendix 2 shows that exposures for beryllium alloys (those containing 2 percent or less Be) generally meet the proposed PEL (88 percent) and alternative PEL of 0.1 ug/m[3] (70 percent). The exposures associated with machining materials with high beryllium concentration (those greater than 30 percent) are a bit higher overall, with 59 percent of exposures meeting the proposed PEL and only 41 percent below the alternative PEL of 0.1 ug/m[3]. Additional controls for machining any type of beryllium-containing metal at the Elmore plant would include:
Isolating the machining process (particularly machining billets).
Enclosing machining equipment.
Adding or enhancing ventilation systems.
Workers machining alloy billets work in close proximity to the melting and casting operations, and their exposures might be predominately associated with this co-location issue (Corbett, 2004; Kent, 2005). As exposures in the melting and casting operations are reduced, exposures in the billet machining operations would be reduced accordingly. In addition, reducing co-location exposures by isolating billet machining operations from nearby high-exposure activities associated with melting and casting could potentially further reduce exposures significantly. It might be possible to build a floor-to-ceiling wall to isolate billet preparation or to move the billet preparation activity a greater distance from the melting and casting operations. However, the use and placement of overhead cranes may present obstacles to isolating the billet preparation from melting and casting operations because such an approach may require significant process redesign. The exposure reduction that might be achieved by isolating billet preparation from melting and casting is not known. Discussions with industry experts suggest that exposures below 0.1 g/m[3] might be achievable by isolating the operation (Corbett, 2004).
Enclosing the machining operation is another method of reducing exposure. In an investigation of exposure to cobalt during wet grinding of hard metal blades, Linnainmaa (1995) observed that full-shift PBZ exposures were reduced 50 to 91 percent when two semiautomatic grinding machines with splash guards (minimally enclosed) were fully enclosed. Exposures before enclosing the machines ranged from 6 g/m[3] to 33 g/m[3]; after fully enclosing the grinding machines, exposures were 3 g/m[3]. Post-control exposures are based on three samples and were not reported as a range, but simply as 3 g/m[3]. While these data do not necessarily establish that exposures less than or equal to the proposed 0.2 g/m[3] PEL can be achieved using process enclosure, they do suggest that significant exposure reduction can be realized.
Adding LEV or enhancing existing LEV will also reduce exposures during machining of beryllium-containing material. Section 7--Precision Turned Products describes fully enclosed, sealed, and ventilated machining operations on high-beryllium-content products (including pure beryllium) (ERG Beryllium Site 1, 2002). The section provides detailed descriptions of controls for machining operations that are applicable to the machining operations at the Elmore plant and would provide similarly reduced exposures.
Feasibility Conclusion for Cold Work Operations
As discussed above, 80 percent of exposures in the cold-work operations (rolling, straightening, drawing, and machining) are less than or equal to the proposed 0.2 g/m[3] PEL, and 61 percent are less than the alternative PEL of 0.1 g/m[3]. In those few instances where exposures need to be further reduced, available control methods include work area isolation, process enclosure, and enhanced ventilation, as described above, and the additional controls described in Section 7--Precision Turned Products and Section 8--Copper Rolling, Drawing and Extruding of this technological feasibility analysis. Based on current exposures and the availability of additional controls, OSHA preliminarily concludes that exposures at or below the proposed 0.2 g/m[3] PEL and a 0.1 g/m[3] alternative PEL can be achieved most of the time in most cold-work operations.
Production Support
As shown in Table IV-6, the exposure profile for the production support job category is characterized by a median of 0.08 g/m[3], a mean of 0.51 g/m[3], and a range from 0.02 g/m[3] to 22.71 g/m[3]. Overall, 71% of the 861 full-shift PBZ total beryllium sample results reported for workers categorized in production support work groups were less than or equal to 0.2 ug/m[3], and 56% were less than 0.1ug/m[3]. For this analysis, production support workers include those involved with:
Furnace charge material preparation ("mix makeup").
Onsite scrap recycling (beryllium and copper).
Maintenance (production equipment, furnaces and furnace tools, molds and dies).
Research and development (R&D).
Quality Assurance/Quality Control (QA/QC) inspection.
Mix Makeup workers prepare and charge (load) furnaces with alloy melting mixes. This activity involves using material-handling equipment, such as industrial lift trucks, and transferring bulk material between charge tubs and furnaces. Furnace charges are prepared in ventilated mix stations and loaded into tubs, where they are charged in the furnaces through a pneumatically operated cart (Kent et al., 2001). Mix makeup workers work in a wide-open area in close proximity to the alloy melting and casting operations. A partial enclosure equipped with a slot hood is used to control exposures at the mix station in the Old Cast Shop (floor weigh-scale location). In the New Cast Shop, mix makeup is incorporated into the furnace operator's job, and a sub-grade ventilated pit is used as a mixing station. Other exposure controls for this activity include the use of HEPA filter vacuum systems (centralized and portable) and wet methods for workplace cleaning. Worker exposure is primarily associated with adjacent contaminant-producing operations (i.e., melting and casting) and the handling of dusty scrap in the Old Cast Shop. (The New Cast Shop uses master alloy, pure copper rod, and clean scrap for furnace charges.) How much of the exposure comes from the nearby melting and casting operations and how much is generated by the handling of dusty scrap is not known. The industrial hygienist for the Elmore facility estimated that nearby melting and casting operations might account for up to 70 percent of mix makeup worker exposures (Kent, 2005).
As shown in Table IV-6, the median exposure for mix makeup workers is 0.24 g/m[3], the mean is 0.46 g/m[3], and the maximum exposure level is 4.2 g/m[3]. Additional controls are required to reduce exposures to the proposed PEL of 0.2 g/m3 for workers who perform mix makeup operations.
Using industrial lift trucks equipped with properly enclosed, sealed, and ventilated operator cabs (i.e., no leaks, positive pressure, and effective air filtration) will reduce exposures. Direct reading instruments show that fine particle (i.e., less than 0.3 m) concentrations inside the operator cab can be reduced by an average of 96 percent when cabs are clean; are sealed with effective door gaskets with no cracks or holes; and have a properly designed, installed, and maintained filtration and pressurization system (Cecala et al., 2005). Based on two full-shift area samples and direct-reading measurements with light-scattering aerosol monitors, NIOSH investigators reported respirable dust exposures were reduced by 97 to 98 percent inside a modified ballast regulator cab (NIOSH HETA 92-0311).
According to company estimates, nearby melting and casting operations contribute approximately 70 percent of the daily cumulative exposure experienced by mix makeup workers (Kent, 2005). The melting and casting operations' contribution to the mix makeup workers' exposure will be reduced when effective controls are added to those operations. OSHA believes that the scrap handling tasks that may contribute to mix make-up workers are fugitive emissions from scrap handling and dust suspended by forklift traffic. Installing ventilated enclosures at scrap handling stations and enhancing the housekeeping program may also contribute to lower exposures to mix make-up workers. Additionally, using an enclosed ventilated forklift truck will reduce exposures further, perhaps as much as 98 percent during the time these workers remain within the ventilated enclosure (NIOSH HETA 92-0311). The amount of time workers spend using forklifts is not known. Assuming that workers in this area spend half their time using forklifts, and that these exposure-reduction estimates are realized, the resulting maximum exposure level would be approximately 0.64 g/m[3], and the average exposure level would be reduced to approximately 0.07 g/m[3].
Feasibility Conclusion for Mix Makeup Operations -- Production Support
Based on this analysis, OSHA preliminarily concludes that exposures at or below the proposed 0.2 g/m3 PEL can be achieved for mix make-up workers most of the time. Also based on this information, the Agency preliminarily concludes that exposure levels less than an alternative PEL of 0.1 g/m[3] can be achieved most of the time.
Scrap recycling is another potential source of beryllium exposure for production support workers. Table IV-6 indicates that workers in scrap recycling have a median beryllium exposure of 0.31 g/m[3] and a mean exposure of 1.08 g/m[3]. The scrap recycling work group is responsible for monitoring scrap metal and extracting beryllium that will be processed in the furnaces. This work group has four subgroups: inventory control center, scrap reclamation, leaching, and resource recovery. Beryllium Production Appendix 2 shows that 36 percent of exposures are already at or below the proposed 0.2 g/m[3] PEL. Worker exposures in scrap recycling occur from four sources: 1) the scrap materials often have dust attached that can become airborne during manual handling; 2) beryllium-containing dust can become airborne when drums containing dusty scrap are opened and unloaded; 3) dust can be generated by forklift traffic disturbing surface dust in the scrap recycling area; and 4) dust can be generated during scrap sampling. Information on the relative contribution of each of these sources to workers' exposures is not available. Similarly, the data to determine how much time workers spend on the variety of activities in scrap recycling do not exist. As a result, it is not possible to precisely predict the reduction in exposure that might occur as these sources are controlled. Nonetheless, effective control methods are available for reducing exposures from each of these sources.
Manual handling of scrap materials occurs in ventilated partial enclosures. Since the time that samples in the exposure profile were taken, the facility has enhanced the ventilation throughout the operation by doubling the exhaust flow. Information regarding the exposure reduction that was achieved with this engineering modification is not available. However, Kent (2005) suggests that ventilation enhancements alone might achieve an exposure reduction of 20 to 50 percent. Enhanced engineering and work practice controls together typically might be expected to reduce exposures by half or one-third of previous exposures (Kent, 2005).
Since 1999, the facility has also designed and installed ventilated enclosures for handling open drums. This equipment captures residual material released during drum connection and disconnection to/from the process. This system reduces the amount of contamination that results when drums are opened and emptied. Installing these ventilated enclosures at all drum-handling stations would contribute to a reduction in workers' exposures. These fugitive emissions in scrap handling operations may occur when transfer equipment (e.g., drums and tubing) are disconnected, and material retained inside valves and tubing is released in to the air. Additionally, with existing material transfer equipment, a worker may not have the ability to see or otherwise determine if all of the material transfer has occurred and may disconnect the transfer equipment prematurely, releasing emissions in to the air.
Exposures associated with forklift operations can be addressed in two ways. First, enhancing the housekeeping program to reduce the level of contamination and migration within the workplace will reduce surface dust that may be disturbed by forklift traffic. Since the time of the 1999 baseline exposure monitoring, housekeeping has been improved in the scrap recycling area. Wet floor sweepers are used to clean the floors on a daily basis to reduce the level of dust generated by material-handling activities (i.e., fork truck traffic), and containers of dusty scrap are kept covered. As previously discussed, significant improvements in the level of housekeeping through more effective and/or more frequent cleaning might further reduce exposures by 60 to 80 percent (OSHA SEP Inspection Report 303207518). Second, forklift cabs can be enclosed and ventilated to reduce exposures during forklift operations. As mentioned above, two studies have shown the effectiveness of such ventilated enclosures. Cecala et al. (2005) demonstrated that concentrations of respirable dust inside the operator cab can be reduced by an average of 96 percent when cabs are clean; are sealed (effective door gaskets and no cracks or holes); and have a properly designed, installed, and maintained filtration and pressurization system. NIOSH investigators reported respirable dust exposure reductions of 97 and 98 percent inside enclosed cabs (NIOSH HETA 92-0311).
Feasibility Conclusion for Scrap Recycling -- Production Support
Beryllium Production Appendix 2 shows that 36 percent of exposures in the scrap recycling area are already at or below the proposed 0.2 ug/m3 PEL. Based on the availability of control methods to reduce exposures for each of the major sources of exposure in scrap recycling, OSHA preliminarily concludes that exposures at or below the proposed 0.2 ug/m3 PEL can be achieved in most scrap recycling operations most of the time.  OSHA seeks additional information and exposure data through the rulemaking process to further evaluate the effectiveness of the control methods described above, and determine whether an alternative PEL of 0.1 ug/m[3] can be considered feasible for scrap recycling operations.
Maintenance workers are primarily exposed when working in production areas. According to Table IV-6, the median beryllium exposure for furnace and tool maintenance workers is 0.53 g/m[3], and the mean exposure is 1.73 g/m[3], with a maximum exposure of 14.62 g/m[3]. Thus, additional controls are required to reduce maintenance worker exposures to the proposed PEL of 0.2 g/m[3] or below.
The highest exposure for maintenance personnel occur during furnace repair and rebuild operations, with a median exposure level of 0.53 ug/m[3]. The frequency with which furnaces require maintenance (rebuilding) can vary from two weeks to two months and depends on the type of furnace and the number of heat cycles it has operated. For example, in the New Cast Shop, furnaces require rebuilding about every 30 to 60 heat cycles and may operate for four heat cycles per day. Because of the approximately 40 furnaces located at the Elmore facility, furnace rebuilding is done on a daily basis. Although some repairs are done in place, most furnaces are not rebuilt in place. For repair-in-place, maintenance workers rely on the furnace's LEV for exposure control. All other furnaces are moved to a segregated rebuilding control room equipped with several bays for working on multiple furnaces simultaneously.
The furnace rebuild room is ventilated (about one air change per minute), and maintenance workers have high exhaust flow LEV hose drops (approximately 10,000 cubic feet per minute of exhaust air per two hose drops) and HEPA filter vacuums (centralized and portable diesel-powered) available for use during rebuilding activities. Additionally, wet methods are reportedly used during demolition activities. Worker exposures are primarily associated with two activities: 1) cleaning contaminated furnaces prior to rebuilding; and 2) mechanically generating beryllium aerosols during repair and reconditioning activities (e.g., manually demolishing furnace linings). Demolition activities probably contribute the most to worker exposures (about 90 percent), whereas cleaning activities may account for about 10 percent of total exposure. In the past, workers reportedly were not properly decontaminating furnaces prior to rebuilding (Kent, 2004).
Based on the available information, an additional control would be using jackhammers equipped with a controlled water spray at the chisel point. Jackhammering on furnace liners is likely the most significant source of exposures in furnace maintenance. Various studies have reported significant respirable dust exposure reductions ranging from 70 to 90percent when jackhammering with water-supplied jackhammers compared with dry jackhammering (NIOSH EPHB 282-11a; Williams and Sam, 1999).  NIOSH investigated a water spray dust control used by workers breaking concrete with 60- and 90-pound jackhammers (EPHB 282-11a). Using both a direct-reading (real-time) instrument and a high-flow cyclone with filter media, NIOSH collected 10-minute readings with and without the water spray activated. Compared with uncontrolled concrete pavement-breaking, PBZ respirable dust concentrations were between 72 and 90 percent lower when the water spray was used. Similarly, Williams and Sam (1999) report that a hand-held pneumatic chipper equipped with a water spray nozzle reduced worker exposure to respirable crystalline silica by 70 percent during concrete truck drum cleaning. Workers periodically spray the interior surface of the drum and have a continuous water spray directed at the chisel point during chipping. The water flow rate is operator adjusted and is described as a controlled mist that does not generate excess water (Sam, 2004).
The use of water-supplied jackhammers during demolition of furnace linings can likely reduce worker exposures associated with demolition activities by at least 70 percent (NIOSH EPHB 282-11a; and Williams and Sam, 1999). OSHA notes that although the facility uses wet methods during demolition activities, it is not clear to what extent this control is currently successful in suppressing dust given the high exposures reported. Similarly, the LEV has high-flow capacity but it is not certain whether it is employed at the point of operation. OSHA believes that a water delivery system that is consistently suppressing dust at the point of operation will allow for similar reductions reported by the NIOSH (EPHB 282-11a) and Williams and Sam (1999) studies. See Section 2 -- Methodology of this PEA for detailed discussions on how some of the same controls methods available for one of these contaminants (silica) will also help control the other (beryllium).
In addition to furnaces, maintenance workers must also maintain (rebuild) contaminated furnace tools. These tools are fabricated in-house and include furnace rub bars and dross rakes that are 10 to 12 feet long. Maintenance workers cut off the contaminated sections of these tools and weld on new sections. Cut-off saws, grinders, and welders are used to repair these tools. Workers utilize operator-positioned LEV hose drops (some with hoods and some without) during these repair activities. Other exposure controls available to furnace maintenance workers include the use of HEPA filter vacuum systems (centralized and portable) and wet methods for cleaning work areas.
Other production support workers who have potential exposure to beryllium during their work activities include R&D and QA/QC/inspection workers. These workers ensure that the production process runs appropriately so as to ensure quality output. Additionally, these workers ensure that the materials sent to downstream users meet the quality standards set by the company. Exposures during these activities are generally well controlled, however. Table IV-6 shows that R&D and QA/QC/inspection workers have mean values of 0.11 ug/m[3] and 0.05 ug/m3 and median values of 0.14 ug/m[3] and 0.05 ug/m[3], respectively.
Beryllium Production Appendix 2 shows that 64 percent of maintenance workers' exposures, 89 percent of R&D workers' exposures, and 95 percent of QA/QC/inspection workers' exposures are equal to or less than the proposed PEL. Table IV-11 presents the control measures that have already been implemented for these workers.
Table IV-11 -- Baseline Controls for Maintenance, R&D, and QA/QC Workers
Work Group
Baseline Exposure Controls
Maintenance of Production Equipment,
Molds and Dies
Decontamination/cleaning of equipment prior to repair/reconditioning.
LEV (hose drops, some with exhaust hoods) during activities/tasks having potential for beryllium exposure, such as demolition activities.
Housekeeping program to minimize dust accumulation and migration.
Cleaning with HEPA filter vacuums (centralized and portable) and wet methods.
Work uniforms, gloves, and respiratory protection.
R&D
Devoted process exhaust ventilation systems with specially designed hoods and enclosures.
Activities reviewed and investigated on case-by-case basis by site safety/industrial hygiene staff for potential exposure and control alternatives.
Work uniforms.
QA/QC/Inspection
Written analytical procedures.
Laboratory exhaust hoods.
Decontamination of parts and assemblies prior to inspection.
Work uniforms.

The exposures to maintenance, R&D, and QA/QC/inspection workers also result from conditions that exist in beryllium production areas of the plant where these workers occasionally perform their duties. As exposures in these areas are reduced through engineering controls and additional housekeeping, maintenance, R&D, and QA/QC/inspection workers' exposures should also be reduced.
Feasibility Conclusion for Maintenance, R&D, and QA/QC Operations -- Production Support
Based on the exposure profile, OSHA preliminarily concludes that the proposed PEL of 0.2 ug/m[3] and an alternative PEL of 0.1 g/m[3] are feasible for R&D and QA/QC/inspection workers. It is not clear whether exposures at or below the proposed PEL and an alternative PEL of 0.1 g/m[3] will be consistently achieved using wet methods for furnace and tool maintenance workers. The workers engaged in this high-exposure activity will likely need to rely on respiratory protection during these maintenance operations (e.g., a tight-fitting powered air purifying respirator would offer a protection factor of 1,000 and protect workers from beryllium concentrations up to 200 g/m[3]).
Site Support
For this analysis, site support workers include those involved in nonproduction related activities such as laundry, janitorial, decontamination, facility/site operations (e.g., boilers, maintenance, wastewater treatment), shipping/receiving/material handling, supply room, analytical laboratory, security, and cafeteria work. As shown in Table IV-6, the exposure profile for the site support job category is characterized by a median of 0.05 ug/m[3], a mean of 0.11 ug/m[3], and a range from 0.05 ug/m[3] to 4.22 ug/m[3]. Of the 879 full-shift PBZ total beryllium sample results reported for workers categorized in the site support work group, 92 percent were at or below 0.2 ug/m[3] and 81 percent were less than 0.1 ug/m[3].
Site support workers are not directly involved with beryllium production but may occasionally be exposed when they enter beryllium manufacturing areas or when they handle beryllium-containing materials or materials that have become contaminated with beryllium. Site support workers have significant controls in place.
The Agency believes that the controls installed in the manufacturing operations to achieve compliance with the proposed PEL in those areas will also reduce exposures to the site support workers such that exposures above the PEL will not occur in 10 of 13 site support jobs. The controls that existed at the time of sampling for these 10 support jobs are listed in Table IV-12.
Table IV-12 -- Baseline Controls for Site Support Jobs
Work Group
Baseline Exposure Controls
Laundry
Water sprays (on a timer) and canopy hoods over dirty clothing hampers.
HEPA filter vacuum cleaners for floor cleaning.
Routine housekeeping in dirty locker rooms.
Work uniforms.
Half-mask air-purifying respirators (when removing dirty clothing from hampers).
Janitorial
Written procedures to keep areas clean of beryllium and minimize the risk of beryllium migration.
Wet cleaning methods and HEPA filter vacuum cleaners.
Supplemental HEPA filter vacuums for servicing vacuums (e.g., changing the filters).
Work uniforms.
Half-mask air-purifying respirators (when emptying disposable/dirty personal protective equipment [PPE] receptacles and for vacuum maintenance/service).
Landfill

Store and decontaminate solid waste prior to delivery to the landfill.
Established facility practices and procedures regarding the handling and deposit of material delivered to the landfill.
Work uniforms.
Facility Maintenance
Cleaning before maintenance with wet cleaning methods and HEPA filter vacuums (centralized and portable).
Exhaust hoods in maintenance shops.
Wet commercial road sweepers.
Large-scale equipment decontamination (in segregated area).
Established facility practices and procedures.*
Work uniforms, gloves, and respiratory protection.
Analytical Laboratories
Standardized work practices for tasks relevant to their job description.
Laboratory exhaust hoods (for cutting operations, handling powders).
HEPA filter vacuums (centralized and portable).
Wet processing techniques (e.g., water polishing).
Splash guards on polishing wheels.
Work uniforms and respiratory protection (e.g., when cutting copper-beryllium samples).
Shipping/Receiving
Wet cleaning methods and HEPA filter vacuums (to clean shipping department).
Materials and equipment are containerized or decontaminated prior to delivery to shipping/receiving. Potentially contaminated equipment is cleaned and visually inspected prior to offsite shipment.
Work uniforms.
Supply Rooms
Work uniforms.
Established facility practices and procedures relevant to the tasks they perform, such as storing materials used by other site support workers.
Security
Work uniforms.
Established facility practices and procedures.*
Facility Engineering
Work uniforms.
Established facility practices and procedures.*
Cafeteria
Aprons (over personal clothes).
Lab coat (cashier).
Wet cleaning methods to clean kitchen.
*	Materion did not specify what these practices and procedures are for these individual work groups.

Three other site support jobs have exposures that are somewhat higher, and the occurrence of exposures above the proposed 0.2 ug/m[3] PEL is more frequent. These jobs are:
Decontamination
Boiler operators
Wastewater treatment
Decontamination workers perform large-scale surface cleaning in places that do not get cleaned frequently, such as room and equipment surfaces that are over 8 feet high in the regulated (production) work areas. Entire areas are shut down for cleaning based on a predetermined work schedule. Decontamination workers do not perform cleaning tasks typically associated with the janitorial staff, such as cleaning offices, meeting/break rooms, and toilets. Currently, the decontamination crew consists of four to six workers who primarily perform large equipment decontamination. This equipment includes cranes that need to be serviced or inspected and equipment, such as electric motors, heavy equipment (e.g., a front-end loader), and vehicles, that needs to leave the site for service or repair. Decontamination is a daily activity for these workers. For example, at least one crane is decontaminated nearly every day because the site has approximately 300 cranes that must be serviced and inspected. Decontamination workers clean contaminated equipment surfaces by removing surface contamination with one or more cleaning techniques, including HEPA filter vacuuming and various wet cleaning methods (e.g., wet wiping, high- and low-pressure water washing). A high-power, diesel vacuum mounted on a trailer is also available for cleaning extensive gross surface contamination. Decontamination workers presumably receive higher exposures when cleaning more heavily contaminated equipment. Higher exposures might also be associated with the level of beryllium contamination of the work environment, worker technique, and/or improper work practice, such as using high-pressure water washing before initial gross cleaning by vacuuming and wet wiping.
As shown in Table IV-6, the median exposure for decontamination workers is 0.18 g/m[3] and the mean is 0.47 g/m[3], with a range of .05 g/m[3] to 4.22 g/m[3]. Based on these data, OSHA concludes that the 0.2 ug/m[3] PEL can be achieved in this operation most of the time. However, additional controls will be required to reduce exposures in some cases.
It is difficult to predict the amount of decontamination work that will need to be performed with the improvement of engineering controls in beryllium manufacturing operations. Assuming that the frequency of decontamination remains the same, improvements in process controls and dust collection in the beryllium production operations will result in reduced deposition of beryllium-containing dust on surfaces and equipment. OSHA has no data that indicate the extent to which decontamination workers' exposures will be reduced when the beryllium production operations have better dust control.
Additional measures (not currently installed) for site support workers may offer further exposure reductions. For example, small equipment can be decontaminated in enclosed/sealed cleaning cabinets (NIOSH Testimony, 1977). Using such equipment, decontamination workers' exposures would be greatly reduced. An industry consultant suggests that perhaps 20 percent of the equipment that is decontaminated (e.g., engines) could be cleaned in a leak-tight decontamination chamber (Corbett, 2004).
Improved work practices can further reduce exposures. For example, ensuring that workers remove gross contamination with HEPA-filtered vacuums prior to wet wiping will reduce the amount of airborne contamination created during the decontamination process. Ensuring that workers consistently follow established procedures will reduce the frequency of occasional high exposures. No data exist that suggest the extent to which exposure levels can be reduced through work practices. However, a Materion industrial hygienist at the Elmore plant estimated that beryllium exposures can typically be reduced by approximately 20 to 50 percent through improved work practices or engineering controls (Kent, 2005).
Boiler operators monitor boilers that provide steam to other areas of the plant. The boilers are not themselves a source of beryllium contamination, but higher exposures than would normally be expected occur in these workers because the facility boilers are physically located near several high-exposure operations (i.e., the boilers are out in the open, there is no boiler "room"). Operators monitor the boilers from a small control room equipped with a window air-conditioning unit. Because of the proximity of the boiler control room to high-exposure operations (i.e., the pebble plant, beryllium oxide furnaces, and resource recovery recycling operation), contaminated air infiltration is the primary contributor to the higher exposure levels reported for boiler operators.
According to Table IV-6, boiler operators have a range of exposures from 0.05 g/m[3] to 0.48 g/m[3], with a mean of 0.23 g/m[3] and a median of 0.16 g/m[3]. Subsequent to the 1999 baseline exposure monitoring, the boilers were physically isolated from two operations with higher exposures: the pebble plant and the beryllium oxide furnaces. Additionally, HEPA air filtration was introduced to all operator work stations (pulpits), including the boiler control room. Boiler operator exposures are now significantly lower and are estimated to be approximately one-tenth of what they were prior to HEPA filtration (Kent, 2005). The highest exposure level measured for boiler operators in 1999 was 0.48 g/m[3] (Table IV-6). Assuming the Kent (2005) estimate is correct, the maximum exposure of boiler operators is 0.048 g/m[3] or less, and no additional controls are needed to reduce exposures to, or below, the proposed PEL of 0.2 g/m3 or below an alternative PEL of 0.1 g/m[3].
Wastewater treatment takes place in a separate building, so there is no co-location issue associated with worker exposures, as noted with the boiler operators. Worker exposures result from beryllium contamination in the water that enters the treatment plant and might primarily be associated with the sludge cake operation (operating and cleaning the filter presses and monitoring bag filling). Sludge contamination that has been allowed to dry can become airborne very easily and is a potential source of beryllium exposure. Higher exposures for wastewater treatment workers are reportedly due to improper work practices and inadequate housekeeping (Kent, 2005). Exposure controls within the wastewater treatment plant include enclosed and ventilated tanks for certain processes, as well as ventilated sludge presses.
Beryllium Production Appendix 2 indicates that wastewater treatment workers have a median beryllium exposure of 0.09 g/m[3] and a mean exposure of 0.17 g/m[3]. Only 24 percent of the exposure levels are greater than 0.2 g/m[3]. As control of beryllium emissions in the beryllium production operations improves, the beryllium content in the wastewater and sludge will be reduced similarly. This will, in turn, reduce wastewater treatment plant workers' exposures. In the event that exposures are not reduced to or below the proposed 0.2 g/m3 PEL, improved housekeeping and work practices may be needed.
Sludge contamination in the wastewater treatment plant that is or has been allowed to dry (and accumulate) can become airborne very easily and is a potential source of beryllium exposure. Enhancing work practices through operator training, work practice modifications, and/or better supervision will minimize exposures associated with the sludge cake operation. For example, operators need to limit the number of times the sludge cake is pressed to avoid making it too dry. A dry cake can increase the amount of dust generated during sludge bag filling and directly affect worker exposure and/or contaminate the work environment.
Diligent housekeeping limits the amount of beryllium dust on floors, equipment, and other surfaces. NIOSH repeatedly recommends effective housekeeping and appropriate cleaning techniques (such as wet cleanup methods and/or vacuuming with an approved HEPA filter vacuum) as methods to minimize worker exposure to hazardous air contaminants such as asbestos, crystalline silica, and heavy metals (NIOSH HETA 89-270-2080; HETA 91-0093-2126; HETA 2003-0114-2924).
Feasibility Conclusion for Site Support Operations
In general, site support workers have very low beryllium exposures. Ninety-two percent of exposures are less than or equal to the proposed 0.2 g/m3 PEL, and 81 percent of exposures are less than 0.1 g/m[3]. Beryllium exposures in all site support activities will be reduced as a result of the general reduction in beryllium contamination that will occur as the plant complies with the provisions of the proposed rule. Even for decontamination, boiler operations, and wastewater treatment, exposures can be reduced by using engineering controls and work practices such as improved housekeeping and following established procedures. OSHA preliminarily concludes that beryllium exposures in most site support activities can be controlled to the proposed 0.2 g/m3 PEL or below, as well as below a 0.1 g/m3 alternative PEL, most of the time.
Administrative Personnel
As shown in Table IV-6, the exposure profile for the administrative job category is characterized by a median of 0.05 μg/m[3], a mean of 0.1 μg/m[3], and a range from 0.05 μg/m[3] to 4.54 μg/m[3]. These values represent 981 full-shift PBZ total beryllium sample results reported for workers categorized in administrative work groups. For this analysis, administrative workers include managers, supervisors, secretaries, office workers, and professional support staff such as engineering, production planning, medical, and environmental health and safety personnel. Ninety-four percent of the samples for administrative personnel were equal to or less than 0.2 μg/m[3], indicating that only on rare occasions will administrative personnel have exposures that exceed the proposed PEL. And, 85% of the samples were less than the alternative PEL of 0.1 μg/m[3].
Administrative workers typically have their offices in administrative buildings and may or may not interface with production operations by entering regulated work areas of the facility. These workers do not work directly with beryllium. Administrative workers who enter production areas of the facility must abide by the same exposure controls and procedures applicable to production workers, including using company-provided work clothing (that is laundered on site) and respiratory protection and showering at the end of the work shift and/or when leaving regulated work areas. Beryllium contamination that could be transferred from regulated areas of the facility to administrative areas is controlled through migration control procedures. Examples of beryllium migration control techniques in place at the time the 1999 samples were taken include the following:
Transition zones that provide a designated area for donning clean PPE before entering a regulated area and removing dirty PPE upon exiting.
Personal protective clothing (e.g., work clothing and shoes, coveralls, lab coats, gloves, head and shoe coverings).
Shoe cleaners and tack (sticky) mats.
Air showers (not plantwide).
Personal hygiene (e.g., hand washing and showering at the end of the shift).
Housekeeping (HEPA filter vacuum systems and wet methods; work surfaces and equipment "visibly" clean).
Other (fabric-covered office furniture minimized; carpeting eliminated).
Because administrative workers do not work directly with beryllium, the few exposures that exceed the PEL result from occasional visits to the beryllium manufacturing operations or from handling materials that may be contaminated. The Agency believes that the controls that will be installed in the manufacturing operations to achieve compliance with the proposed PEL in those areas will also reduce the beryllium exposures of the administrative staff such that exposures above the PEL will not occur. As a result, no additional controls specifically designed to reduce administrative personnel exposures will be needed.
Feasibility Conclusion for Administrative Personnel Operations
OSHA preliminarily concludes that the proposed PEL of 0.2 ug/m[3] and an alternative PEL of 0.1 ug/m[3] have already been achieved for most administrative operations most of the time. Furthermore, an exposure level less than or equal to the proposed 0.2 ug/m[3] PEL can likely be achieved for these operations all of the time once additional control measures are installed in beryllium production areas.
Summary of Technological Feasibility Findings for Beryllium Production
Only 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.  OSHA identified eight job groups at this facility in which workers are exposed to beryllium: chemical operations, powdering operations, production support, cold work, hot work, site support, furnace operations, and administrative work.
The Agency developed an exposure profile for each of these eight job groups to represent the distribution of exposure levels associated with primary beryllium production. The job exposure profiles are based primarily on full-shift personal breathing zone (PBZ) (lapel-type) sample results from air monitoring conducted by Brush Wellman in 1999 at the Elmore primary production facility (Brush Wellman Elmore, 2004).  Starting in 2000, the company developed the Materion Worker Protection Program (MWPP), a multi-faceted beryllium exposure control program designed to reduce airborne exposures for the vast majority of workers to 0.2 μg/m[3] or less in most operations most of the time. According to information provided by Materion, a combination of engineering controls, work practices, and housekeeping, were used together to  reduce average exposure levels to or below 0.2 ug/m[3] for the majority of workers (Materion Information Meeting, 2012).  Also, two operations with historically high exposures, the wet plant and pebble plants, were decommissioned in 2000, thereby reducing average exposure levels.  Therefore, the samples taken prior to 2000 may overestimate current exposures, but OSHA has not been provided with more recent sampling data to verify the effects of the exposure control program and plant changes, or to determine what exposure levels currently exist in the Elmore facility.
In five of the primary production job groups (i.e., hot work, cold work, production support, site support, and administrative work), the baseline exposure profile indicates that most exposures are already lower than the proposed PEL of 0.2 μg/m[3] and the alternative PEL of .1 ug/m[3].  Median exposure values for these job groups range from non-detectable to 0.08 μg/m[3].
For three job groups (chemical operations, powdering, and furnace operations), the median exposure level exceeds the proposed PEL of 0.2 μg/m[3].  Median exposure values for these job groups are 0.47, 0.37, and 0.68 μg/m[3] respectively, and only 15% to 29% of the available measurements are less than or equal to 0.2 μg/m[3] for these three job groups.  Therefore, additional control measures would be required to achieve compliance with the proposed PEL for these job groups.
OSHA has identified several engineering controls the Agency preliminarily concludes can reduce exposures in chemical processes and powdering operations to less than or equal to 0.2 ug/m[3].  In chemical processes, these include fail-safe drum-handling systems, full enclosure of drum-handling systems, ventilated enclosures around existing drum positions, automated systems to prevent drum overflow, and automated systems for container cleaning and disposal such as those designed for hazardous powders in the pharmaceutical industry.  Similar engineering controls would reduce exposures in powdering operations.  In addition, installing remote viewing equipment (or other equally effective engineering controls) to eliminate the need for workers to enter the die-loading hood during die filling will reduce exposures associated with this powdering task and reduce powder spills.  Based on the availability of control methods to reduce exposures for each of the major sources of exposure in chemical and powdering operations, OSHA preliminarily concludes that exposures at or below the proposed 0.2 g/m[3] PEL can be achieved in most chemical and powdering operations most of the time.  OSHA preliminarily concludes that furnace operators' exposures can be reduced using appropriate ventilation, fume capture hoods, and other controls to reduce overall beryllium levels in foundries, but is not certain whether they can be reduced to the proposed PEL with currently available technology.  OSHA requests additional information on current exposure data and potential control measures for primary beryllium production operations to further refine this analysis, and in particular information to demonstrate the feasibility of reducing exposures to or below the alternative PEL of 0.1 ug/m[3].
References
ABB, 2005. Telephone conversation between Raymond Gilli, ABB USA, Norwalk, Connecticut, and Eastern Research Group, Inc., Chantilly, Virginia. January 14.
Absolute Control Systems, Inc., 2004. Absolute Control Systems, Inc. website http://www.absolutecontrolsys.com. Accessed December 9, 2004.
AFS, 2005. Telephone conversation between Fred Kohloff, American Foundry Society, Health and Safety Committee, Schaumburg, Illinois, and Eastern Research Group, Inc., Chantilly, Virginia. January 14.
Air Products, 2005.  Personal communication between Air Products and Chemicals, Inc., Allentown, Pennsylvania, and Eastern Research Group, Inc.  March 3.
Brush Wellman Elmore, 2004. Brush Wellman's 1999 baseline full-shift personal breathing zone (lapel-type) exposure results for its Elmore, Ohio, primary beryllium production facility. Data provided to Eastern Research Group, Inc., Lexington, Massachusetts, on August 23, 2004. [Unpublished]
Cecala, A.B., J.A. Organiscak, J.A. Zimmer, W.A. Heitbrink, E.S. Moyer, M. Schmitz, E. Ahrenholtz, C.C. Coppock, and E.H. Andrews, 2005. Reducing Enclosed Cab Drill Operator's Respirable Dust Exposure with Effective Filtration and Pressurization Techniques. Journal of Occupational and Environmental Hygiene (2): 54 - 63. January.
Corbett, M.L., 2004. Personal communications  between Marc L. Corbett (consultant) and Eastern Research Group, Inc.
Corbett, M.L., 2005.  Personal communications between Marc L. Corbett (consultant) and Eastern Research Group, Inc.
Corbett, M.L., 2006. Personal  communications between Marc L. Corbett (consultant) and Eastern Research Group, Inc.
ERG Beryllium Site 1, 2002. Site visit to an aluminum-beryllium alloy fabrication facility, December 2 - 3, 2002. Eastern Research Group, Inc., Lexington, Massachusetts. Recorded as a supporting document at www.regulations.gov, under Document ID number OSHA-H005C-2006-0870-0341.
Hosokawa Micron Group, 2005. Telephone conversation between Eastern Research Group, Inc. and a technical representative from Hosokawa Micron Powder Systems, Summit, New Jersey. January 13. Product information is available at the following websites: http://www.hosokawa.com/web/Stott/ and http://www.hosokawa.com.
Inductotherm, 2005. Telephone conversation between Charles Vivian, Inductotherm Group, Rancocas, New Jersey, and Eastern Research Group, Inc., Chantilly, Virginia. January 13.
Kent, M.S., T.G. Robins, and A.K. Madl, 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.
Kent, M.S., 2004. Personal communications between Eastern Research Group, Inc. and Michael S. Kent, CIH, CSP, Director Environmental, Health and Safety, Brush Wellman Inc., Elmore, Ohio. November.
Kent, M.S., 2005. Personal communications between Eastern Research Group, Inc. and Michael S. Kent, CIH, CSP, Director Environmental, Health and Safety, Brush Wellman Inc., Elmore, Ohio. January and February.
Linnainmaa, M.T., 1995. Control of Exposure to Cobalt During Grinding of Hard Metal Blades. Applied Occupational and Environmental Hygiene 10(8): 692 - 697. August.
Materion and Steelworkers (2012). Industry and Labor Joint Submission to OSHA of a Recommended Standard for Beryllium. February, 2012.
Materion  Corporation, 2012. Letter from Director; Health, Safety and Regulatory Affairs; Materion Brush Division of Materion Corporation; addressed to OSHA Directorate of Standards and Guidance. August 17.
Materion Information Meeting. 2012. Meeting between Materion Corporation and OSHA. Elmore, OH. May 8-9.
McCawley, M., 2000. Air and Surface Sampling for Beryllium. Presentation by the National Institute for Occupational Safety and Health to the Occupational Safety and Health Administration. Washington, D.C. October.
National Materials Advisory Board, 1989. Beryllium Metal Supply Options. NMAB Report No. 452. Washington, D.C.: National Academy Press [limited distribution document available from the Defense Technical Information Center].
NIOSH 85-116F. Glossary of Terms. In: Foundries -- Recommendations for Control of Occupational Safety and Health Hazards. U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control, National Institute for Occupational Safety and Health, Division of Standards Development and Technology Transfer. DHHS (NIOSH) Publication No. 85-116. September 1985.
NIOSH ECTB 113-14a. Preliminary Survey Report: Solid Material Sampling Operations at Cabot Berylco Beryllium Alloy Plant, Level Pennsylvania. National Institute for Occupational Safety and Health, Division of Physical Sciences and Engineering, Engineering Control Technology Branch, Cincinnati, Ohio. Report No. ECTB 113-14a. June 10, 1982.
NIOSH ECTB 113-14b. In-depth Survey Report: Solid Material Sampling Operations at Cabot Berylco Beryllium Alloy Plant, Reading, Pennsylvania. National Institute for Occupational Safety and Health, Division of Physical Sciences and Engineering, Engineering Control Technology Branch, Cincinnati, Ohio. Report No. ECTB 113-14b. (NTIS document number PB83-220442.) March 1983.
NIOSH Elmore database, 2011. Spreadsheet containing beryllium exposure values collected by NIOSH at the Materion Elmore facility in 2007 and 2008; provided by Materion Corporation to OSHA-Directorate of Standards and Guidance. Fall 2011.
NIOSH EPHB 282-11a. In-Depth Survey Report of Control of Respirable Dust and Crystalline Silica from Breaking Concrete with a Jackhammer. 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, Engineering and Physical Hazards Branch, Cincinnati, Ohio. Report No. EPHB 282-11a. February 2003.
NIOSH HETA 89-270-2080. Health Hazard Evaluation Report HETA 89-270-2080. Harrisburg Steam Generation Facility, Harrisburg, Pennsylvania. Department of Health and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, Hazard Evaluations and Technical Assistance Branch, Division of Surveillance, Hazard Evaluations, and Field Studies, Cincinnati, Ohio. November 1990.
NIOSH HETA 91-0093-2126. Health Hazard Evaluation Report HETA 91-0093-2126. Seville Centrifugal Bronze, Inc., Seville, Ohio. Department of Health and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, Hazard Evaluations and Technical Assistance Branch, Division of Surveillance, Hazard Evaluations, and Field Studies, Cincinnati, Ohio. July 1991.
NIOSH HETA 92-0311. Health Hazard Evaluation Report HETA 92-0311. CSX Transportation, Inc., Nashville, Tennessee. National Institute for Occupational Safety and Health, Cincinnati, Ohio. January 2001.
NIOSH HETA 2003-0114-2924. Health Hazard Evaluation Report HETA 2003-0114-2924. Felker Brothers Corporation, Marshfield, Wisconsin. Department of Health and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, Hazard Evaluations and Technical Assistance Branch, Division of Surveillance, Hazard Evaluations, and Field Studies, Cincinnati, Ohio. January 2004.
NIOSH IWS-37-11. Industrial Hygiene Survey of the Brush Wellman Plant, June 12 - 16, 1972 and August 21 - 25, 1972. NIOSH Report No. IWS-37-11 (NTIS No. PB82-100686). Environmental Investigations Branch, Division of Field Studies and Clinical Investigations, National Institute for Occupational Safety and Health, Cincinnati, Ohio.
NIOSH Testimony, 1977. NIOSH Testimony to the U.S. Department of Labor, Occupational Safety and Health Administration, Public Hearing on the Occupational Standard for Beryllium. Statement of Edward J. Baier, Deputy Director, National Institute for Occupational Safety and Health, Center for Disease Control, U.S. Department of Health, Education, and Welfare. August 19.
OSHA-H005C-2006-0870-0092. U.S. Department of Labor, Occupational Safety and Health Administration. OSHA Beryllium Docket No. OSHA-H005C-2006-0870. Docket ID No. OSHA-H005C-2006-0870-0092. Document Title: Attachment 2.1. Primary Beryllium Manufacturing and Processing Facility. Comments submitted by Brush Wellman, Inc. in response to Federal Register of November 26, 2002. Dated February 21, 2003.
OSHA SEP Inspection Report 303207518. OSHA Special Emphasis Program (SEP) Inspection Report 303207518. Recorded as a supporting document at www.regulations.gov, under Document ID number OSHA-2010-0034-0511.
Pillar, 2005. Telephone conversation between Brian Brazinski, Pillar Induction Company, LLC, Brookfield, Wisconsin, and Eastern Research Group, Inc., Chantilly, Virginia. January 13.
Sam, K., 2004. Telephone conversation between Kwasi Sam, Illinois Department of Commerce and Community Affairs (Illinois On-Site Consultation Program), and Eastern Research Group, Inc. October 8.
Sentry Equipment Corporation, 2005. Telephone conversations between Eastern Research Group, Inc. and a sales representative from Sentry Equipment Corporation, Oconomowoc, Wisconsin. February 18 and 22. See also http://www.sentry-equip.com/index.php.
Sentry Equipment Corporation, 2006. Guide to Bulk Solids Samplers. Sentry Equipment Corporation, Oconomowoc, Wisconsin. See http://www.sentry-equip.com/index.php. Accessed September 25, 2006.
Williams, D.R. and K. Sam, 1999. Illinois Ready-Mixed Concrete Association Industrial Hygiene Study: October 1997 through June 1999. Illinois Department of Commerce and Community Affairs, Illinois On-Site Consultation Program, 100 West Randolph Street, Chicago, Illinois. [Unpublished Data]

SECTION 3 -- BERYLLIUM PRODUCTION, APPENDIX 1
Table IV-13 -- Supporting Personal Exposure Profile in the Beryllium Production Industry (2007 - 2008)
(NAICCS 331419)[a,b,c][,d,e]
                               Job Category and
                                  Work Group
                       No. of Full-Shift PBZ Samples[f]
                               Range (μg/m[3])
                                     Mean
                                  (μg/m[3])
                                    Median
                                  (μg/m[3])
ADMINISTRATIVE
                                    NO DATA
SITE SUPPORT
                                    NO DATA
PRODUCTION SUPPORT
                                      42
                                 0.01 to 9.24
                                     1.42
                                     0.40
Mix Makeup (furnace charge material)
                                       5
                                 0.02 to 0.57
                                     0.33
                                     0.41
Scrap Recycling
                                      19
                                 0.01 to 9.24
                                     2.40
                                     2.00
Inventory Control Center
                                       2
                                 0.09 to 0.39
                                     0.24
                                     0.24
Scrap Reclamation
                                       9
                                 0.01 to 9.24
                                     3.63
                                     2.93
Leaching
                                       3
                                 2.10 to 4.59
                                     3.74
                                     4.53
Resource Recovery
                                       5
                                 0.07 to 0.61
                                     0.26
                                     0.19
Maintenance
                                      17
                                 0.04 to 5.90
                                     0.74
                                     0.27
Production Equipment
                                      11
                                 0.05 to 5.90
                                     1.00
                                     0.30
Furnaces and Tools
                                       3
                                 0.08 to 0.69
                                     0.35
                                     0.27
Molds and Dies
                                       3
                                 0.04 to 0.36
                                     0.16
                                     0.08
Research and Development
                                    NO DATA
QA/QC/Inspection
                                       1
                                     0.03
                                     0.03
                                     0.03
COLD WORK
                                      70
                                   0 to 2.91
                                     0.30
                                     0.09
Rolling
                                       8
                                   0 to 0.02
                                     0.01
                                     0.01
Straightening
                                    NO DATA
Drawing
                                    NO DATA
Machining
                                      62
                                 0.02 to 2.91
                                     0.33
                                     0.11
Billet Preparation
                                       8
                                 0.02 to 0.38
                                     0.17
                                     0.15
Alloys
                                      14
                                 0.03 to 0.23
                                     0.07
                                     0.05
High Beryllium
                                      40
                                 0.03 to 2.91
                                     0.46
                                     0.24
HOT WORK
                                      33
                                 0.01 to 1.30
                                     0.13
                                     0.06
Hot Rolling/Extrusion
                                      17
                                 0.03 to 0.61
                                     0.13
                                     0.08
Annealing
                                      11
                                 0.02 to 1.30
                                     0.17
                                     0.03
Welding
                                    NO DATA
Pickling (elevated bath temperatures)
                                       4
                                 0.01 to 0.05
                                     0.03
                                     0.03
Degreasing (elevated solvent temperature)
                                       1
                                     0.07
                                     0.07
                                     0.07
POWDERING
                                      22
                                 0.11 to 11.57
                                     2.60
                                     1.50
Operator/Impact Grinding
                                      11
                                 0.28 to 11.57
                                     2.98
                                     1.57
Compact Loading/Sintering
                                       7
                                 0.63 to 7.45
                                     3.37
                                     3.15
Near Net Shape (operator and welder)
                                       4
                                 0.11 to 0.31
                                     0.19
                                     0.18
CHEMICAL OPERATIONS
                                       3
                                 0.16 to 0.44
                                     0.27
                                     0.24
Be Sulfate (GC salt & wet screening operators)[e]
                                       3
                                 0.16 to 0.44
                                     0.27
                                     0.24
FURNACE OPERATIONS
                                      24
                                 0.01 to 9.24
                                     1.19
                                     0.62
Alloy Induction
                                      11
                                 0.03 to 1.00
                                     0.42
                                     0.33
Alloy Arc
                                       2
                                 0.69 to 0.89
                                     0.79
                                     0.79
High Beryllium Vacuum Casting
                                       3
                                 0.22 to 2.30
                                     1.21
                                     1.11
High Beryllium Atomization
                                    NO DATA
Beryllium Oxide
                                       8
                                 0.01 to 9.24
                                     2.35
                                     0.93
[a]	This supporting profile is a summary of the NIOSH 2007 - 2008 full-shift PBZ (lapel-type) total beryllium exposure results for workers at the Brush Wellman, Inc., Elmore, Ohio, plant (NIOSH Elmore database, 2011).
[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., Inventory Control Center, Furnaces and Tools, and Molds and Dies work groups).
[c]	Samples were analyzed by NIOSH Method 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

Table IV-14 -- Distribution of Supporting Full-Shift PBZ Exposure Results for Total Beryllium in the Beryllium Production Industry (2007 - 2008) (NAICCS 331419)[a,b,c][,d,e]
                          Job Category and Work Group
          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

ADMINISTRATIVE
                                    NO DATA
SITE SUPPORT
                                    NO DATA
PRODUCTION SUPPORT
                                      12
                                     (32%)
                                       3
                                     (8%)
                                       5
                                     (13%)
                                       3
                                     (8%)
                                       4
                                     (11%)
                                      11
                                     (29%)
                                      38
                                    (100%)
Mix Makeup (furnace charge)
                                       1
                                     (20%)
                                       1
                                     (20%)
                                       2
                                     (40%)
                                       1
                                     (20%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       5
                                    (100%)
Scrap Recycling
                                       1
                                     (11%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       1
                                     (11%)
                                       7
                                     (78%)
                                       9
                                    (100%)
Inventory Control Center
                                       0
                                     (0%)
                                       1
                                     (50%)
                                       1
                                     (50%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (6%)
                                       2
                                    (100%)
Scrap Reclamation
                                       3
                                     (11%)
                                       2
                                     (8%)
                                       9
                                     (35%)
                                       4
                                     (15%)
                                       5
                                     (19%)
                                       3
                                     (12%)
                                      26
                                    (100%)
Leaching
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       3
                                    (100%)
                                       3
                                    (100%)
Resource Recovery
                                       1
                                     (20%)
                                       2
                                     (40%)
                                       1
                                     (20%)
                                       1
                                     (20%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       5
                                    (100%)
Maintenance
                                       8
                                     (47%)
                                       0
                                     (0%)
                                       3
                                     (18%)
                                       2
                                     (12%)
                                       3
                                     (18%)
                                       1
                                     (6%)
                                      17
                                    (100%)
Production Equipment
                                       5
                                     (45%)
                                       0
                                     (0%)
                                       1
                                     (9%)
                                       1
                                     (9%)
                                       3
                                     (27%)
                                       1
                                     (9%)
                                      11
                                    (100%)
Furnaces and Tools
                                       1
                                     (33%)
                                       0
                                     (0%)
                                       1
                                     (33%)
                                       1
                                     (33%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       3
                                    (100%)
Molds and Dies
                                       2
                                     (67%)
                                       0
                                     (0%)
                                       1
                                     (33%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       3
                                    (100%)
Research and Development
                                    NO DATA
QA/QC/Inspection
                                       1
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       1
                                    (100%)
COLD WORK
                                      36
                                     (51%)
                                       9
                                     (13%)
                                      15
                                     (21%)
                                       5
                                     (7%)
                                       3
                                     (4%)
                                       2
                                     (3%)
                                      70
                                    (100%)
Rolling
                                       8
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       8
                                    (100%)
Straightening
                                    NO DATA
Drawing
                                    NO DATA
Machining
                                      28
                                     (45%)
                                       9
                                     (15%)
                                      15
                                     (24%)
                                       5
                                     (8%)
                                       3
                                     (5%)
                                       2
                                     (3%)
                                      62
                                    (100%)
Billet Preparation
                                       3
                                     (38%)
                                       2
                                     (25%)
                                       3
                                     (38%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       8
                                    (100%)
Alloys
                                      10
                                     (71%)
                                       3
                                     (21%)
                                       1
                                     (9%)
                                       0
                                     (7%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      14
                                    (100%)
High Beryllium
                                      15
                                     (38%)
                                       4
                                     (10%)
                                      11
                                     (28%)
                                       5
                                     (13%)
                                       3
                                     (8%)
                                       2
                                     (5%)
                                      40
                                    (100%)
HOT WORK
                                      24
                                     (73%)
                                       5
                                     (15%)
                                       2
                                     (6%)
                                       1
                                     (3%)
                                       1
                                     (3%)
                                       0
                                     (0%)
                                      33
                                    (100%)
Hot Rolling/Extrusion
                                      10
                                     (59%)
                                       5
                                     (29%)
                                       1
                                     (6%)
                                       1
                                     (6%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      17
                                    (100%)
Annealing
                                       9
                                     (82%)
                                       0
                                     (0%)
                                       1
                                     (9%)
                                       0
                                     (0%)
                                       1
                                     (9%)
                                       0
                                     (0%)
                                      11
                                    (100%)
Welding
                                    NO DATA
Pickling (elevated bath temperatures)
                                       4
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       4
                                    (100%)
Degreasing (elevated temperatures)
                                       1
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       1
                                    (100%)
POWDERING
                                       0
                                     (0%)
                                       3
                                     (14%)
                                       2
                                     (9%)
                                       3
                                     (14%)
                                       5
                                     (23%)
                                       9
                                     (41%)
                                      22
                                    (100%)
Operator/Impact Grinding
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       1
                                     (9%)
                                       1
                                     (9%)
                                       5
                                     (45%)
                                       4
                                     (36%)
                                      11
                                    (100%)
Compact Loading/Sintering
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       2
                                     (29%)
                                       0
                                     (0%)
                                       5
                                     (71%)
                                       7
                                    (100%)
NNS (operator and welder)
                                       0
                                     (0%)
                                       3
                                     (75%)
                                       1
                                     (25%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       4
                                    (100%)
CHEMICAL OPERATIONS
                                       0
                                     (0%)
                                       1
                                     (33%)
                                       2
                                     (67%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       3
                                    (100%)
Beryllium Sulfate Salt (GC salt and wet screen operators)
                                       0
                                     (0%)
                                       1
                                     (33%)
                                       2
                                     (67%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       3
                                    (100%)
FURNACE OPERATIONS
                                       5
                                     (21%)
                                       1
                                     (4%)
                                       4
                                     (17%)
                                       9
                                     (38%)
                                       1
                                     (4%)
                                       4
                                     (17%)
                                      24
                                    (100%)
Alloy Induction
                                       2
                                     (5%)
                                       1
                                     (13%)
                                       3
                                     (32%)
                                       5
                                     (27%)
                                       0
                                     (14%)
                                       0
                                     (9%)
                                      11
                                    (100%)
Alloy Arc
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       2
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       2
                                    (100%)
High-Beryllium Vacuum Cast
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       1
                                     (33%)
                                       0
                                     (0%)
                                       1
                                     (33%)
                                       1
                                     (33%)
                                       3
                                    (100%)
High-Beryllium Atomization
                                    NO DATA
Beryllium Oxide
                                       3
                                     (38%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       2
                                     (25%)
                                       0
                                     (0%)
                                       3
                                     (38%)
                                       8
                                    (100%)
[a]	This supporting profile is a summary of the NIOSH 2007 - 2008 full-shift PBZ (lapel-type) total beryllium exposure results for workers at the Brush Wellman, Inc., Elmore, Ohio, plant (NIOSH Elmore database, 2011).
[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., Inventory Control Center, Furnaces and Tools, and Molds and Dies work groups).
[c]	Samples were analyzed by NIOSH Method 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).

Source: NIOSH Elmore database, 2011

SECTION 3 -- BERYLLIUM PRODUCTION, APPENDIX 2
Table IV-15 -- Detailed Distribution of Full-Shift PBZ Exposure Results for Total Beryllium in the Beryllium Production Industry (1999) (NAICCS 331419)[a,b,c]
                          Job Category and Work Group
          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

ADMINISTRATIVE
                                      833
                                     (85%)
                                      90
                                     (9%)
                                      39
                                     (4%)
                                      10
                                     (1%)
                                       6
                                    (0.5%)
                                       3
                                    (0.5%)
                                      981
                                    (100%)
Operations/Management
                                      368
                                     (84%)
                                      45
                                     (10%)
                                      20
                                    (4.5%)
                                       4
                                     (1%)
                                       2
                                    (0.5%)
                                       1
                                     (0%)
                                      440
                                    (100%)
Human Resources
                                      48
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      48
                                    (100%)
Information Systems
                                      45
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      45
                                    (100%)
Credit Union
                                      15
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      15
                                    (100%)
Environmental Health & Safety
                                      119
                                     (90%)
                                      11
                                     (8%)
                                       1
                                     (1%)
                                       0
                                     (0%)
                                       1
                                     (1%)
                                       0
                                     (0%)
                                      132
                                    (100%)
Medical
                                      48
                                     (92%)
                                       4
                                     (8%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      52
                                    (100%)
Training
                                      14
                                     (93%)
                                       0
                                     (0%)
                                       1
                                     (7%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      15
                                    (100%)
Production Planning
                                      106
                                     (79%)
                                      16
                                     (12%)
                                       4
                                     (3%)
                                       4
                                     (3%)
                                       2
                                    (1.5%)
                                       2
                                    (1.5%)
                                      134
                                    (100%)
Engineering
                                      70
                                     (70%)
                                      14
                                     (14%)
                                      13
                                     (13%)
                                       2
                                     (2%)
                                       1
                                     (1%)
                                       0
                                     (0%)
                                      100
                                    (100%)
SITE SUPPORT
                                      711
                                     (81%)
                                      100
                                     (11%)
                                      45
                                     (5%)
                                      15
                                     (2%)
                                       6
                                     (1%)
                                       2
                                     (0%)
                                      879
                                    (100%)
Laundry
                                      42
                                     (88%)
                                       5
                                     (10%)
                                       1
                                     (2%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      48
                                    (100%)
Janitorial
                                      52
                                     (80%)
                                      11
                                     (17%)
                                       1
                                    (1.5%)
                                       1
                                    (1.5%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      65
                                    (100%)
Landfill
                                      29
                                     (97%)
                                       1
                                     (3%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      30
                                    (100%)
Facility Maintenance
                                      96
                                     (74%)
                                      21
                                     (16%)
                                       9
                                     (7%)
                                       3
                                     (2%)
                                       1
                                     (1%)
                                       0
                                     (0%)
                                      130
                                    (100%)
Analytical Laboratories
                                      144
                                     (86%)
                                      14
                                     (8%)
                                       8
                                     (5%)
                                       0
                                     (0%)
                                       1
                                     (1%)
                                       0
                                     (0%)
                                      167
                                    (100%)
Ship/Receive/Material Handle
                                      122
                                     (92%)
                                      10
                                     (8%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      132
                                    (100%)
Wastewater Treatment
                                      27
                                     (59%)
                                       8
                                     (17%)
                                       9
                                     (20%)
                                       2
                                     (4%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      46
                                    (100%)
Store (supply) Rooms
                                      31
                                     (97%)
                                       1
                                     (3%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      32
                                    (100%)
Security
                                      27
                                     (87%)
                                       3
                                     (10%)
                                       1
                                     (3%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      31
                                    (100%)
Boiler Operators
                                       5
                                     (28%)
                                       5
                                     (28%)
                                       8
                                     (44%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      18
                                    (100%)
Facility Engineering
                                      105
                                     (90%)
                                       7
                                     (6%)
                                       1
                                     (1%)
                                       2
                                     (2%)
                                       1
                                     (1%)
                                       0
                                     (0%)
                                      116
                                    (100%)
Cafeteria
                                      14
                                     (88%)
                                       2
                                     (12%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      16
                                    (100%)
Decontamination
                                      17
                                     (35%)
                                      12
                                     (25%)
                                       7
                                     (15%)
                                       7
                                     (15%)
                                       3
                                     (6%)
                                       2
                                     (4%)
                                      48
                                    (100%)
PRODUCTION SUPPORT
                                      484
                                     (56%)
                                      129
                                     (15%)
                                      105
                                     (12%)
                                      54
                                     (6%)
                                      43
                                     (5%)
                                      46
                                     (6%)
                                      861
                                    (100%)
Mix Makeup (furnace charge)
                                      14
                                     (27%)
                                       9
                                     (18%)
                                      17
                                     (33%)
                                       5
                                     (10%)
                                       5
                                     (10%)
                                       1
                                     (2%)
                                      51
                                    (100%)
Scrap Recycling
                                      14
                                     (13%)
                                      26
                                     (23%)
                                      30
                                     (27%)
                                      14
                                     (13%)
                                      11
                                     (10%)
                                      16
                                     (14%)
                                      111
                                    (100%)
Inventory Control Center
                                       3
                                     (19%)
                                       7
                                     (44%)
                                       5
                                     (31%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       1
                                     (6%)
                                      16
                                    (100%)
Scrap Reclamation
                                       3
                                     (11%)
                                       2
                                     (8%)
                                       9
                                     (35%)
                                       4
                                     (15%)
                                       5
                                     (19%)
                                       3
                                     (12%)
                                      26
                                    (100%)
Leaching
                                       1
                                     (17%)
                                       0
                                     (0%)
                                       2
                                     (33%)
                                       1
                                     (17%)
                                       0
                                     (0%)
                                       2
                                     (33%)
                                       6
                                    (100%)
Resource Recovery
                                       7
                                     (11%)
                                      17
                                     (27%)
                                      14
                                     (22%)
                                       9
                                     (14%)
                                       6
                                     (10%)
                                      10
                                     (16%)
                                      63
                                    (100%)
Maintenance
                                      155
                                     (45%)
                                      65
                                     (19%)
                                      43
                                     (12%)
                                      29
                                     (8%)
                                      26
                                     (8%)
                                      27
                                     (8%)
                                      345
                                    (100%)
Production Equipment
                                      109
                                     (47%)
                                      50
                                     (21%)
                                      25
                                     (11%)
                                      16
                                     (7%)
                                      21
                                     (9%)
                                      11
                                     (5%)
                                      232
                                    (100%)
Furnaces and Tools
                                       6
                                     (10%)
                                       5
                                     (9%)
                                      16
                                     (27%)
                                      12
                                     (21%)
                                       5
                                     (9%)
                                      14
                                     (24%)
                                      58
                                    (100%)
Molds and Dies
                                      40
                                     (73%)
                                      10
                                     (18%)
                                       2
                                     (4%)
                                       1
                                     (2%)
                                       0
                                     (0%)
                                       2
                                     (3%)
                                      55
                                    (100%)
Research and Development
                                      91
                                     (76%)
                                      15
                                     (13%)
                                      10
                                     (8%)
                                       2
                                     (2%)
                                       0
                                     (0%)
                                       1
                                     (1%)
                                      119
                                    (100%)
QA/QC/Inspection
                                      210
                                     (89%)
                                      14
                                     (6%)
                                       5
                                     (2%)
                                       4
                                     (2%)
                                       1
                                    (0.5%)
                                       1
                                    (0.5%)
                                      235
                                    (100%)
COLD WORK
                                      335
                                     (61%)
                                      107
                                     (19%)
                                      74
                                     (13%)
                                      13
                                     (2%)
                                      17
                                     (3%)
                                       9
                                     (2%)
                                      555
                                    (100%)
Rolling
                                      24
                                     (80%)
                                       2
                                     (7%)
                                       3
                                     (10%)
                                       0
                                     (0%)
                                       1
                                     (3%)
                                       0
                                     (0%)
                                      30
                                    (100%)
Straightening
                                      42
                                     (75%)
                                       7
                                     (12%)
                                       3
                                     (5%)
                                       2
                                     (4%)
                                       2
                                     (4%)
                                       0
                                     (0%)
                                      56
                                    (100%)
Drawing
                                      26
                                     (84%)
                                       5
                                     (16%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      31
                                    (100%)
Machining
                                      243
                                     (55%)
                                      93
                                     (21%)
                                      68
                                     (16%)
                                      11
                                     (3%)
                                      14
                                     (3%)
                                       9
                                     (2%)
                                      438
                                    (100%)
Billet Preparation
                                      38
                                     (42%)
                                      29
                                     (32%)
                                      13
                                     (15%)
                                       4
                                    (4.5%)
                                       4
                                    (4.5%)
                                       2
                                     (2%)
                                      90
                                    (100%)
Alloys
                                      151
                                     (70%)
                                      40
                                     (18%)
                                      20
                                     (9%)
                                       1
                                     (1%)
                                       2
                                     (1%)
                                       2
                                     (1%)
                                      216
                                    (100%)
High Beryllium
                                      54
                                     (41%)
                                      24
                                     (18%)
                                      35
                                     (26%)
                                       6
                                     (5%)
                                       8
                                     (6%)
                                       5
                                     (4%)
                                      132
                                    (100%)
HOT WORK
                                      205
                                     (69%)
                                      56
                                     (19%)
                                      29
                                     (10%)
                                       6
                                     (2%)
                                       0
                                     (0%)
                                       1
                                     (0%)
                                      297
                                    (100%)
Hot Rolling/Extrusion
                                      109
                                     (73%)
                                      33
                                     (22%)
                                       7
                                     (4%)
                                       1
                                     (1%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      150
                                    (100%)
Annealing
                                      37
                                     (58%)
                                      16
                                     (25%)
                                      10
                                     (16%)
                                       1
                                     (1%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      64
                                    (100%)
Welding
                                       0
                                     (0%)
                                       4
                                     (27%)
                                       6
                                     (40%)