U.S. Department of Energy 

Office of Inspector General 

Office of Audit Services 

Audit Report 

Beryllium Surface Contamination at 

the Y-12 National Security Complex 

DOE/IG-0783 December 2007 
Department of Energy 

Washington, DC 20585 

December 17, 2007 

MEMORANDUM FOR TI4 SECRETARY 

FROM: Gregory &- H. Friedman 

Inspector General 

SUBJECT: INFORMATION: Audit Report on "Beryllium Surface 

Contamination at the Y- 12 National Security Complex" 

INTRODUCTION AND OBJECTIVE 

Since the 1950s, beryllium processing has been an important part of the mission of the 

Department of Energy's Y- 12 National Security Complex in Oak Ridge, Tennessee. Y-12 has 

made widespread use of beryllium in its activities. As a consequence, the Department's 

worker safety programs have recognized the possibility that beryllium remains in buildings as 

well as on equipment and other surfaces. According to the Department, exposure to beryllium 

can cause beryllium sensitization or Chronic Beryllium Disease, defined as an often 

debilitating, and sometimes fatal, lung condition. 

In accordance with Federal Regulations, the contractor operating Y- 12, BWXT Y-12, 

implemented a Chronic Beryllium Disease Prevention Program. This Prevention Program 

required postings of beryllium surface contamination warnings in non-beryllium operations 

areas when contamination was found to be 0.2 micrograms and above. Further, it required 

that hazard assessments be performed when surface sampling established the presence of 

beryllium. BWXT's Prevention Program builds upon, and in certain cases, exceeds current 

regulatory recluiremcnts for beryllium contamination controls. 

In November 2006, the Office of Inspector General rece~ved an allegation that workers at 

Y- 12 had not bcen adequately protected from beryllium exposure. In response to the 

allegation, we initiated this audit to determine whether BWXT Y-12 had unplemented surface 

contamination controls in accordance with its Prevention Program. Our audit included three 

facil~t~cs where beryllium operations were historically co-located with non-beryllium 

operations and focuscd on surface contaminat~on outside of beryllium operational areas. 

RIJSULTS OF AUDIT 

Our review found that BWXT Y-12 had not consistently implemented key controls in nonberylliun~ operations areas as required by its Prevention Program. Specifically, when surface 

contamination was found outside beryllium operational areas, BWXT Y- 12 had not always: 

Posted signs alerting workers to the potential for beryllium surface contamination; 

and, 

Perfor~ned or documented hazard assessments for beryllium contamination, although 

documented assessments were vital to identifying potential exposure risks. 
For example, in 2002, BWXT Y- 12 identified the presence of beryllium in one area at a level 

requiring further control actions. However, as of August 2006, BWXT Y-12 had not taken 

even the basic step of posting signs to alert workers to the potential risks. 111 April 2007, after 

our inquiries, BWXT Y- 12 performed additional sampling that not only confirmed the 

presence of berylliun~, but indicated contamination that, in some cases, exceeded 15 

niicrograms. 'Phis was 75 times higher than the level at which its Prevention Program 

required further controls. This area was posted in May 2007, almost five years after the initial 

characterization. 

During the course of our review, BWXT Y-12 management pointed out that tlie requirement 

to post warnings of contamination outside beryllium operational areas exceeds the 

Department's regulations, which do not require postings for such surface contamination. We 

agree. In fact, th~s inconsistency was reflective of a gap that we found in the Department's 

current regulations. Department regulations do not address surface contamination found 

outside confirmed beryllium operational areas. In May 2005, to address this gap, the 

Department drafted a technical standard, which reconiniended warning signs when 

contamination occurs outside operational areas. As of August 2007, this standard had not 

been finalized. 

The completion of hazard assessments was an important component of the Preve~ition 

Program. Yet, we found instances where surface sampling established the presence of 

berylliu~n in non-operational areas and BWXT Y-12 had not performed the required 

assessments. This was inconsistent with the Department's implementing guidelines for 

beryllium protection progra~ns, wliich identify hazard assessments as the mechanism for 

determining and documenting potential worker exposure. 

We found that BWXT Y- 12's implementation of its Prevention Program was hampered, in 

part, because the contractor did not track recommendations made by its industrial hygienists 

to post contaminated areas. BWXT Y-12 also did not have a single repository of beryllium 

inforniation that could be used by management and workers to identify contaminated 

locations. 

As a result of these control weaknesses, tlie Department and BWXT Y-12 may not be doing 

all that is possible to minimize the r~sk of worker exposure to beryllium in noti-beryllium 

operations areas. BWXT Y- 12 management asserted that surface contamination can not be 

corrclatcd to airborne beryllium exposures. However, the Department has recognized that 

surface contamination may constitute a pathway for worker exposure to beryllium. 

During tlie course of this audit, we provided our findings to Department personnel who took 

actions to ensure that the areas with surface beryllium contamination were posted. BWXT 

Y- 12 nianagelnent infor~iied us that it is developing a system that will centralize 

characterization data and improve the communication of information pertaining to beryllium. 
MANAGEMENT COMMENTS 

Managcment officials from the Office of Health, Safety and Security (HSS) and the National 

Nuclear Sccurity Administration (NNSA) concurred with the audit report I-ecommendations. 

HSS officials stated that the requirement to post areas when surface beryllium contamination 

occurs in non-operational areas will be addressed during the Fiscal Year 2008 amendment to 

Departmental regulations. NNSA stated that it had initiated a number of corrective actions. 

The actions taken and planned are generally responsive to the recommendations. 

Although NNSA initiated corrective actions, officials expressed disagreement with certain 

statements contained in the report. In particular, NNSA stated that Chronic Beryllium 

Disease is caused by inhalation of airborne beryllium, wh~ch can not be correlated to surface 

contamination. This paralleled the assertions made by BWXT Y-12 during the audit. 

Additionally, NNSA officials pointed out that BWXT Y-12's Prevention Program 

requirement's for surfacc contam~nat~on in non-beryllium areas exceed regulatory 

recluircmcnts. 

We recognize NNSA's position. During the audit, in consultation with Departmental experts, 

wc could find no methodology to accurately predict the amount of beryllium that may become 

airboriic from berylli~~ni surface contamination. Nevertheless, the Department has taken the 

position that surfacc contan~ination is a potential hazard that tnay present an exposure route. 

In fact, airborne beryllium was detected while a BWXT Y-12 employee was testing for 

berylliu~n surface conta~nination in one of the buildings cited in the report. Although the 

amount did not excccd the Department's action level, it clearly demonstrated that surface 

contamination can posc a risk to workers. 

Further, as ack~iowledged in the report, Department officials have recognized the risk 

associated with surface contamination and, in 2005, drafted a technical standard 

reco~nnlending warning signs for contamination occurring outside beryllium operational 

arcas. At the time of audit, however, the standard had not been finalized. In view of the 

Dcpartmcnt's concern for worker health and safety, we concluded that it is prudent that 

beryllium monitoring and control programs are fully implemented to minimize worker 

exposure. 

Management's comments arc included in their entirety in Appendix 3 

Attachment 

cc: Dcputy Sccrctary 

Undcr Sccrctary of Encrgy 

Administrator, Nat~onal Nuclear Security Administration 

Chief of Staff 

Chief I-lealth, Safety and Security Officer 

Manager, Y- 12 Site Office 

Director, Policy and Internal Controls Management, KA-66 
REPORT ON BERYLLIUM SURFACE CONTAMINATION AT THE 

Y-12 NATIONAL SECURITY COMPLEX 

TABLE OF 

CONTENTS 

Beryllium Surface Contamination Management 

Oetai Is of Finding ................................................................................. 1 

Recommendations. ............................................................................... .5 

Comments ............................................................................................. 6 

Appendices 

1 . Objective, Scope, and Methodology ................................................ 9 

2. Related Audit Reports .................................................................... 1 1 

3. Management Comments ................................................................. 12 
Implementation of Beryllium Controls 

Beryllium BWXT Y-12, LLC's (BWXT Y-12) actions were not 

Contamination consistent with its Chronic Beryllium Disease Prevention 

Management Program (Prevention Program). In particular, BWXT Y-12 

had not always posted locations of beryllium contamination 

that were outside of beryllium operational areas in the three 

facilities included in our review. These postings would 

have alerted workers to the potential risks of beryllium 

exposure. BWXT Y-12 also had not performed or 

documented the conduct of hazard assessments to 

communicate potential exposure risks. 

Posting Beryllium Areas 

In August 2002, BWXT Y- 12 collected characterization 

samples in the East High Bay of Building 9201-5. Of the 

samplcs collected, half were above the site surface 

contamination limit with 5 samples showing contamination 

15 times greater than the limit. We noted, however, that as 

of August 2006, this area had not been posted as being 

beryllium contaminated. 

In April 2007, after our inquiries, BWXT Y-12 performed 

an additional characterization of the facility and found that 

5 1 of the 60 samples collected in the East High Bay were 

above the site limit. Moreover, several samples revealed 

contamination exceeding 15 micrograms, which is 75 times 

greater than the level requiring further controls. According 

to the building operations manager, periodic operations had 

been ongoing in an adjacent area of the facility for years; 

however, the East High Bay was not posted as a beryllium 

area until May 2007, almost five years after the initial 

characterization. 

In another case, during a 1998 characterization of Building 

9808, a BWXT Y-12 industrial hygienist determined that 

ventilation ducts were contaminated with beryllium and 

recomnlcndcd that employee access be restricted. 

However, we found that the area had not been posted with 

warning signs and that enlployees assigned to Building 

9808 had access to the beryllium contaminated ductwork. 

In fact, we observed that employees in the facility had 

worked in the contaminated area around the ventilation 

ducts. According to BWXT Y-12, the ductwork outside of 

the building had been properly labeled, but no postings 

were made inside the building. During the audit, 

Page 1 Details of Finding 
BWXT Y-12 initiated additional sampling to determine the 

extent of contamination in the building. Several samples 

revealed contamination that was above 3 micrograms, 

which is 15 times greater than the level requiring posting. 

The highest reported sample was over 10 micrograms, 

which is 50 times greater than the limit. Subsequent to our 

inquiries, the area around the ductwork was posted as being 

beryllium contaminated. 

Finally, we noted that characterization data from 2004 

indicated the presence of beryllium exceeding the surface 

contamination limit in Building 9202. Specifically, 40 

percent of the samples from the first floor foundry were 

above the site surface contamination limit. Although the 

industrial hygienist had recommended restricted employee 

access, BWXT Y-12 had not posted warning signs in the 

contaminated areas. The area was posted in June 2007 

following discussion of our findings with Department of 

Energy (Department) personnel. 

Beryllium Hazard Assessments 

In addition, the Department's regulations state that a hazard 

assessment must be performed when characterization 

samples establish the presence of beryllium. The hazard 

assessment is an analysis of the existing condition, medical 

surveillance trends and exposure potential to workers. 

According to BWXT Y-12 management, prior to 2005, 

hazard assessments were conducted but not documented for 

beryllium contamination found outside beryllium 

operational areas. However, we found that since 2005, 

surface sampling had established the presence of beryllium 

in non-operational areas, but BWXT Y-12 had not always 

performed hazard assessments. For example, we noted that 

BWXT Y-12 had not performed documented hazard 

assessments for the previously discussed contamination 

found in areas of Building 9201 -5. In addition, hazard 

assessments for Buildings 9808 and 9202 were not 

con~pleted until July 2007. The lack of documentation for 

assessments prior to 2005, as well as, the absence of such 

assessments for more recently found contamination is 

significant since it is important in defining potential 

hazards. 

Page 2 Details of Finding 
Beryllium During the audit, BWXT Y-12 was unable to provide a 

Contamination definitive reason for not fully implementing its program 

Controls requirements. In responding to a draft of this report, 

however, Department management stated that BWXT Y-12 

had not implemented all procedures required by the 

Prevention Program for surface contamination, such as 

postings and conducting hazard assessments, because of 

higher priority concerns about active beryllium operations 

areas. We concluded that the contractor had not posted 

contaminated areas because it had not fully analyzed 

characterization sample results as required by its 

Prevention Program to detennine the extent of 

contamination. For example, we determined that BWXT 

Y- 12 had not statistically analyzed characterization data 

collected for Buildings 9201-5, 9808 and 9202. Such 

analysis would have disclosed the extent and levels of 

surface contamination in each of these locations. 

BWXT Y-12 management also pointed out that its 

requirement to post areas of surface contamination outside 

operational areas exceeds the Department's regulations. 

We recognize that BWXT Y-12's Prevention Program 

exceeds regulatory requirements; in fact, they address a gap 

in the Department's existing regulations. Specifically, the 

regulations do not address posting surface contamination 

found outside beryllium operational areas; rather it focuses 

on surface contamination within beryllium operational 

areas. However, Department guidance recognizes that 

surface contamination, regardless of location, may present 

a route of exposure other than through airborne 

transmission. The guide includes the following example: a 

worker with beryllium contamination on their sleeve could 

brush the sleeve against their nose, resulting in an inhaled 

dose that could not be captured in a breathing zone sample. 

Further, we noted that in May 2005, the Department drafted 

a technical standard to address this regulation gap by 

recommending warning signs for contamination occurring 

outside beryllium operational areas. As of August 2007, 

this standard had not been finaliled. 

Although the requirement to post areas of surface 

contamination outside operational areas exceeds the 

Department's regulations, it should nevertheless have been 

implemented since it addresses a gap in the regulation and 

was part of BWXT Y- 12's approved Prevention Program. 

Page 3 Details of Finding 
Implementing this requirement is significant since there is 

documented evidence of a potential hazard associated with 

surface contamination outside operational areas. In fact, 

during the audit, a BWXT Y-12 employee was found to 

have received a measurable exposure to beryllium while 

testing for beryllium surface contamination in one of the 

buildings cited in the report. While the amount did not 

exceed the Department's action level, it clearly 

demonstrates that surface contamination can pose a risk to 

workers. 

Perfomlance of Hazard Assessments 

Regarding hazard assessments, BWXT Y- 12 management 

stated that assessments had been conducted but that only 

those performed after 2005 were required by their 

procedures to be documented. We noted, however, that 

BWXT Y-12's lack of documentation was not consistent 

with the Department's 2001 implementing guidelines, 

which required that hazard assessments be conducted to 

determine and document potential worker exposure. 

BWXT Y-12 was unable to provide a reason for not 

conducting assessments of more recently identified surface 

contamination. However, the Department indicated that it 

is taking action to complete the required hazard 

assessments. 

In responding to a draft of this report, Department officials 

stated that resources were deployed and hazard assessments 

conducted in the areas of highest risk, which are active 

beryllium operations. Legacy contamination areas were of 

secondary concern given the relatively low risk. During the 

audit we noted, however, that the areas containing active 

beryllium operations had been assessed and established as 

beryllium operational areas as early as the late 1990s. 

Thus, in our opinion, the legacy beryllium areas discussed 

in the report should have been a higher priority since 

employees in those areas were not aware of the potential 

risks of exposure, trained in the hazards of beryllium, or 

protected by controls to prevent beryllium exposure. 

Page 4 Details of Finding 
Enhancement of Controls 

Beryllium 

Contamination 

Effects 

BWXT Y- 12's implementation of its Prevention Program 

was also hampered because it did not track 

recommendations made by its industrial hygienists. As 

previously discussed, BWXT Y-12 had not implemented 

the hygienists' recommendations to post contaminated 

areas. BWXT Y-12 did not have a system to assign 

responsibility for addressing hygienists' recommendations 

or to track corrective actions. 

Furthermore, we noted that BWXT Y-12 did not have a 

single repository of beryllium information that can be used 

by management and workers to identify contaminated 

locations. For example, characterization information was 

kept in numerous locations and on several separate 

databases. In fact, we provided compiled data to BWXT 

Y-12 and the National Nuclear Security Administration 

officials, which they had not assembled. During the audit, 

BWXT Y-12 informed us that they are developing a system 

that will centralize characterization data and improve the 

communication of information pertaining to beryllium. 

The Department and BWXT Y-12 may not be minimizing 

the risk of worker exposure to berylliun~. Specifically, the 

Department's guidance recognizes that surface 

contamination may constitute a pathway for worker 

exposure to beryllium. However, neither the Department's 

regulations nor BWXT Y- 12's implementation of its 

Prevention Program adequately addressed the potential 

hazards of such surface contamination. This is significant 

since research has shown that once exposed to beryllium, 

an individual carries a lifelong risk of developing beryllium 

sensitization or Chronic Beryllium Disease, even if the 

exposure amount was small or if the individual is no longer 

exposed. 

RECOMMENDATIONS We recommend that the Chief Health, Safety and Security 

Officer revise the Department's regulations to require 

controls including posting areas when surface beryllium 

contamination occurs in non-operational areas. 

We further recommend that the Manager, Y- 12 Site Office 

direct B WXT Y- 12 to: 

Page 5 Recornmendations 
MANAGEMENT 

COMMENTS 

AUDITOR 

COMMENTS 

1. Fully implement the procedures within the Chronic 

Beryllium Disease Prevention Program including 

the statistical analyses of characterization data, 

posting warning signs in beryllium contaminated 

areas and performing and documenting hazard 

assessments for beryllium contamination; 

2. Implement a system for tracking Industrial Hygiene 

recommendations to ensure they are addressed 

timely; and, 

3. Ensure that the beryllium information database 

currently under development is completed and 

maintained. 

Both the Office of Health, Safety and Security (HSS) and 

the National Nuclear Security Administration (NNSA) 

concurred with the audit report recommendations. HSS 

officials stated that the requirement to post areas when 

surface beryllium contamination occurs in non-operational 

areas will be addressed during the Fiscal Year 2008 

amendment to Department regulations. As acknowledged 

in the report, NNSA initiated a number of corrective 

actions during the audit, including posting warning signs in 

beryllium contaminated areas. A number of other actions 

have been planned to address the audit recommendations 

and are discussed in NNSA's comnlents which are included 

in Appendix 3. 

However, NNSA believed the report contained certain 

inaccuracies. Specifically, NNSA stated that the report (1) 

inaccurately correlated surface contamination to airborne 

beryllium expose and health effects; (2) did not consider air 

sampling as part of Y-12's documented hazard assessment; 

and, (3) overstated the health effect of Chronic Beryllium 

Disease being fatal. NNSA also commented that, in the 

absence of regulatory guidance, the Y- 12 contractor had a 

conservative internal limit for beryllium surface 

contamination outside of beryllium operational areas and 

that failure to implement an additional self-imposed limit 

does not equal failure to implement a key control. 

The actions taken and planned are responsive to the audit 

report recommendations. However, for the reasons 

provided below, we disagree with NNSA's assertions 

regarding the accuracy of certain statements contained in 

the report. 

Page 6 Comments 
Correlation between Surface Contamination 

and Airborne Exposure 

We recognize that there is no methodology to accurately 

predict the amount of surface beryllium that may become 

airborne. Nevertheless, the potential risk associated with 

surface contamination is a reality as evidenced by an 

occurrence at Y-12 in April 2007. In this case, a BWXT Y12 employee had a measurable exposure to beryllium while 

testing for beryllium surface contamination in one of the 

buildings cited in the report. While the amount did not 

exceed the Department's action level, it clearly 

demonstrates that surface contamination can pose a risk to 

workers. 

Further, as stated in the report, Department guidance 

recognizes that surface contamination, regardless of 

location, may present a route of exposure other than 

through airborne transmission. In fact, in order to 

minimize potential exposure, the Department requires 

beryllium workers to change out of work clothes and to 

shower before leaving the plant. These steps significantly 

reduce the movement of beryllium from the workplace and 

ensure that the duration of beryllium exposure does not 

extend beyond the work shift and, thus, protect workers and 

their families from off-site exposures. 

Documented Hazard Assessments 

As discussed in the report, documented hazard assessments 

were not provided for all of the areas included in the report. 

Management contends that air sampling was conducted in 

each of the areas of concern and thus constituted the 

conduct of a hazard assessment. However, area specific air 

sampling data was not provided to the audit team when 

hazard assessments were requested. In addition, while we 

agree that air sampling is a key element of a hazard 

assessment, according to Department guidance, other 

factors should be considered. For example, employers 

should ensure that hazard assessments take into account 

surface contamination and other routes of exposure. 

Page 7 Comments 
Health Effects of Chronic Beryllium Disease 

The definition cited in the report was obtained directly 

from the Federal Register. In it, the Department defines 

Chronic Beryllium Disease as, "a chronic, often 

debilitating, and sometimes fatal, lung condition." 

We recognize, as stated in the report, that BWXT Y-12's 

written procedures regarding postings in non-operational 

areas exceed the requirements in the regulations. However, 

because the Department has acknowledged a potential risk 

associated with surface contamination in non-operational 

areas, any control designed to alert and protect workers is 

important and should be implemented. Further, 

Department regulations require that all activities must be 

conducted in compliance with an employer's Prevention 

Program. Since the requirement to post warnings in nonoperational areas had been agreed to in the contractor's 

approved Prevention Program, it should have been 

implemented. Further, we noted surface contamination in 

several areas exceeded the regulatory limit of three 

micrograms where personal protective equipment would 

have been required, had the level of contamination been 

found in a beryllium operations area. 

Page 8 Comments 
Appendix 1 

OBJECT 

SCOPE 

'IVE The objec 

BWXT Y 

surface cc 

Chronic E 

METHODOLOGY 

The audit 

Novembe 

Security ( 

and the N 

Headquar 

berylli urn 

operation 

We condl 

generally 

standards 

obtain su 

reasonabl 

our audit 

provides 

conclusio 

included 

regulatioi 

revlew w 

all intern; 

time of 01 

:tive of this audit was to deternline whether 

'-12, LLC (BWXT Y-12) had implemented 

~ntamination controls in accordance with its 

3eryllium Disease Prevention Program. 

was performed between December 2006 and 

:r 2007. We conducted work at the Y-12 National 

zomplex (Y-12) located in Oak Ridge, Tennessee 

lational Nuclear Security Administration (IVIVSA) 

-ters in Washington, DC. Our efforts focused on 

1 contamination found outside of beryllium 

a1 areas. 

lplish the audit objective, we: 

eviewed laws, regulations, contractual 

quirements, and policies and procedures relevant 

the management of beryllium contamination; 

etennined if baseline characterizations had been 

ltablished and analyzed for Buildings 9201 -5, 

308, and 9202; 

nalyzed Y-12 documentation relating to beryllium 

oling, medical surveillance, and procurement; 

3ured numerous facilities at Y- 12 to observe 

:ryllium area postings; and, 

eld discussions with officials from the NNSA 

eadquarters, Y-12 Site Office, and BWXT Y- 12 

mcerning the management of beryllium 

mtamination. 

~cted this performance audit in accordance with 

accepted Government auditing standards. Those 

require that we plan and perform the audit to 

fficient, appropriate evidence to provide a 

e basis for our findings and conclusions based on 

objectives. We believe that the evidence obtained 

a reasonable basis for our findings and 

ins based on our audit objective. The audit 

tests of controls and compliance with laws and 

1s related to beryllium operations. Because our 

as limited, it would not necessarily have disclosed 

31 control deficiencies that may have existed at the 

ur audit. We did not rely on automated data 

Page 9 Objective, Scope, and Methodology 
Appendix I (continued) 

processing equipment to accomplish our audit objective. 

Finally, we assessed NNSA's compliance with the 

Government Performance and Results Act of 1993. 

Measures were in place regarding environment, safety and 

health issues that would apply to beryllium. We held an 

exit conference with Management on December 6,2007. 

Page 10 Objective, Scope, and Methodology 
Appendix 2 

RELATED AUDIT REPORTS 

The report on Betyllium Controls at the Oak Ridge National Lahorarory 

(DOEIIG-0737, September 2006) found that the Oak Ridge National Laboratory 

did not properly manage activities related to beryllium contaminated equipment in 

Building 9201 -2, which is located at the Y-12 National Security Complex. In 

particular, beryllium contaminated equipment was transferred to non-beryllium 

areas; employees working with contaminated equipment were not fully identified 

and notified; transferred equipment was not labeled appropriately; and, the 

building was not posted as a potential contamination area. 

The report on Implementution of the Department of Energy's BevylliumAssociated Worker Registty (DOEIIG-0726, April 2006), showed that the 

Department had not: maintained data completeness or accuracy in the worker 

registry; used the registry to evaluate health effects of beryllium exposure; nor 

used the registry as envisioned to examine the prevalence of beryllium disease. 

Thus, the audit results showed that program implementation did not meet 

expectations. 

The report on Betyllium Oxide Operations ut the Y-I2 N~rtiotzal Security Complex 

(DOEIIG-0595, April 2003), disclosed a number of inefficiencies in Y-12's 

beryllium oxide operations. Specifically, operations were spread across the Y-12 

site, and in some cases, were co-located with other Y-12 operations. In addition, 

manufacturing equipment and facilities were outdated, which increased 

manufacturing time and costs, and exacerbated health hazards associated with the 

use of beryllium. 

Page 11 Related Audit Reports 
Appendix 3 

Department of Energy 

Nat~onal Nuclear Secur~ty Administratton 

Wash~ngto~i D(; 20585 

October 27, LOO7 

b11;MOI<AUL~I IM ITOR (~corgc W Collard 

Assistant Ins~?cctor <;encral 

Ibl- Performance .Audits 

Michael C. Kane 

lor Managcmcnt and Administration 

('ommcnts to Draft Report on Y-12 Rcrylllum Surlilce 

Contamination; A07Y.l.040; I LlKMS No 2000-3 1002 

l'llc National huclcal- Security Administration (NNSA) ap~reciatcs the opportl~nity to 

r-c\ icn tlic 111sl)cc101- <;cnc~.al's ( ICi) drali report. "Audit on BcrylIi~~m Surlacr. 

(.'ontamiriation at tlic Y- I? National Security Complex." N'c ~~ndcrstand that the IG 

contluctc~l this audit bccausc of an allegation recei\.ed in No\.embcr 7000. that Y-12 

\vorlic~-s \\.c~-c ]lot adecl~lately protected Srum bcrylli~uii cxposurc and that the IG \\anted 

to dctcr~~~inc il's~u-Sacc contaniination controls were in accordance with Y-12's 

prc\,cntio~~ prograii. 

NNS.4 ~~ndcrstands that allegations of rnis~~~anaging halards mllst be I-csol\,ctl and \\lien 

those ;~llcgations locus on bcrylli~1111 and contamination thc concerns Sor salkty rnllst be 

c\a~~~inetl carcli~liy. In the casc orally allcgation made ahout Y-I2 and bcrylli~lm that 

rcsul~cd in 1111s report. \\;c helie\-e that the complainant did not undcrst:~nd sonlc basic 

iss~~cs rcl;itcd to 11cryllium anti they may have been carried o\.er to the dl-ali report. Most 

spc'cilically. the rcpolt gives the impression that exposure to surtilce contamination ol' 

I>crylli~~n~ can cause berylli~m~ se~~sitization or ('lironic Bcrylli~~m Discasc. 111 filct, 

C'lironic Bcl-yllium Disease is caused by inliala~~on ofairbomc beryllium and should not 

I)c corrclatcd to surfacc contamination. 

LVc hclievc thal there are some ~naccuracics in the rcport and arc pro\ iding comnrcnts in 

thc li)llo\\.ing areas: 

It is inaccurate to correlate surfilcc contamini~tion 10 ;~irbornc bcrylli~lm cxposurc 

i~ncl lic;~ltli c'ficts. 

Ilic rcl>ort docs not consider air sampling that \\,as concluctcd as part of 1'- 12's 

~iocumc~~lcd Iialar-tl assessment. 

'l'hc rcport is overstating the hcaltli eflect of Chronic Beryllium Iliscasc being fatal. 

Page 12 Management Comments 
Appendix 3 (continued) 

'l'lic Y-12 contractor has a conscr\,a~i\e internal limit li)r bcrylli~lm s~~rf:~cc 

conl;lniinalion. in rhc absence of rcglllatory limits, oulside ol~herylliu~li operational ;Ireas. 

I:ailurc lo implcmcnl an additional .sc~lf~rrr~j~osc~(l limi~ does not cqual f(li1rri-c. lo iirrj~lc~r~tc~r~l 

r/ Acl. c,o~/f/.ol. 

SNSA I,cl~c\cs lli;~t tlic ~scport is technically inaccuralc in thal it makes rclcl-crrccs alltl 

;issoci;ltions I,el\\ ccn bcrylli~~n~ sul-lice contamination anti llie potcnllal for pcrsonncl 

tslx)su~-c to ;rirbornc bcryll~um and (lic associared health risks. Surface sampling is ;I 

clualitnti\c indicator ofliousckccl,ing and can not he used lo rnras~rl-c o~'~>rctlict airhornc 

conccn~l-ations of beryllium or asscss potcntinl licalrli risks. An) ~'clkrencc' in the rcporl, 

si~ch as in the first ~p;rragr;rpli, Inlroduct~on and Ohjccti\.c section, regal-(ling "cxpos~irc to 

I)e~.ylli~~~n c;u~sing hcrylli~~m sensili/ntion or Chronic Rcryllium Discnsc" slio~~ld hc

rcslatcd to indic;rtc that "cxposurc lo airborne he)-yllium may cause bcrylli~~m 

sensit~v;~l~on or ('lironic Herylli~lm Discasc." ('hronic Rcl-yllium [)isease is ca~~scrl Ipy 

inhalati011 ol'uishor~rc bcl-ylli~~m, \vh~cll car1 1101 I)c co~~clarcd to surfacc conl;rrnina~io~i. 

I'hc statement I-egal-ding. "~liro~ric Beryllium Discasc bc~lig often dchilirating and 

sonlclimc Iit;rl" is ;in ovcrstatcment of health risks gi\,cn tlic latcst rcscarcli on \\,o~-kcrs 

Ilia1 ~>a~tici]>atc in ;I ~iicdic;~l scrccning program such as the HWX-I' Y- 12 1>1-(~gr;~ni. [)uc 

to early tliagnosis and treatment pro\.ided by meclical scrccning. it 1s not anlicil~alctlllal 

('111-onic Ucrylli~~m L)isc;lsc will bc fr~lal lo any HWX'I' Y-1 7 pcrso~lncl. :\rldition;rlly. 1t1c 

lalest resc;~rcli indicates that rlicrc is likely a dose response relationship \\.it11 regarcl to 

I~cr)lli~rm exposure and hcaltli cfli-cts ('or indivitlunls that do 1101 lia\,c a genetic marker 

rh;~t ~~r~lisl)oscs rhcm lo bcrylli~~m scnsili\.ity and potential Chronic Hcrylli~~m 1)iscasc. 

l'llc 13crylli~1m ('on1;rmination Efli-cts scction of thc rcporl is not lcclinically accur-ate in 

(hat it m;rkes ;in association I>e~\\.een herylliu~n surSacc conlamination ant1 airl~ol-nc 

cs~~osu~-c~~~t)~c~iti;il health cffccts. We recornmend rc\+,riting the Beryllium ('ontamination 

hl'l'ccts scclio~r as follo\\s: "The Department anrl HM'NI' Y-1 Z miry not he lnirlntai~~ing 

cl'li.ct~\e Irousekecl>ing and co~rta~ili~liitio~i control practices in Icgac~, I>c~-blli~~m ;)I-cas. 

I.cgi~c; hcryllil~m surfiicc con~,iniination slio~rld bc maintained ar a Ic\,cl as lo\\. ;is 

pr;~clical but ill no illstance shoulti il reach a lei el that res~rlls in airborne I>erylli~rm 11s 

mc;rsu~-cd by pcrsolial ant1 air arca s;r~i~pling." 

IFaiIi~rc 10 POSI 111-C;IS o/'leg:~ey sllrfircc co~ilanli~lation ;rbo\.c ;I self-iml,oscti I1oi1sckceping 

lin1it docs not rise lo tlic Ic\ el of "not consistently iml~lcmcnting kcy controls." 'flicrc IS 

no ~.cg~~lato~.y li~nit for legacy hcrylli~lm surface contamination outside of a I>c~-ylli~~m 

ol>cr;rtlolial arcir. l3M'X-I' \r.- 12 self-imposed ;I \ cry conscr\.:itivc internal housckccping 

linrlt. No1 consislcntly implementing a self-iniposctl limit docs not equate to "frlilul.c to 

1nr1,lemcnt n kc) control." U'c ~rccommcrid ~.c~iio\ iligthe \\ol.rl "key" lion tlic ~-cl,ort. 

I'crson;~l ;III- sampling (lala. n liicli is the only recogni/ed metlrotl to asscss 1,ersonnel 

~YPOSLII-'. \\;IS 1101 co~is~(Ici-e~l ill tlie report. 'l'li~s data. along \\.it11 area air saml>llng, arc 

key clcmcnts ol'a Iia/ilrtl asscssnrcnt. While the auditor \\as looliing for a coml,lctctl 

ha/al.tl assessment tiwnl. the ~rcport sliould notc that air s:r~npling \\-as corld~ictcd in c;tcli 

ol~llic areas ofconcc~-11 slid tIi;rt tlic for~ii;rli/cd process for clocumcntir~g thcsc 

Page 13 Management Comments 
Appendix 3 (continued) 

iIsscssmcnts \\as insrirl~ted by BWXT Y-17 in 7005 ;IS pu.1 ol'ils(('11sonic 13c1.ylli1111l 

1)iscasc I'rc\,cnrion I'rograni. 'fliis sampling documents cxposu~-c Lo o or kc^-s 2111tl tlocs 

constitulc ~lic canducr of a hazard asscssnlcnt. 

M'itli regartl lo ~hc sla\cmcnt "BLi'X'I' \'-I2 was unable to pro\,~dc dcfiniti\,c reason Solnot li~lly implcmc~lling il's prvgrarn rcq~~ircmcnrs. B\I:X'T' Y-I 7 Jlanagcnlcnt did discuss 

rllar and in ;lccortlance \\ill1 I0 C'FII 850, resources \\ere deployed and Iia~ard 

asscssmc~lts cond~~ctcd in tllc arcas of llighcst risk \\ hich are acti\;c beryllium opcratio~ls. 

1,cgacy con(arni1ialion awas ere ofsccolldary co11cc1-11 gi\w the relalively lo\\, risk. 

In lllc co\ cr nicmorandu~ii, ir should cad, "BWXI- Y-1 7 had not ~l\5ays pas~cd slgns 

;~lcrling \\orkcrs lo rhc polcnli;~l for bcrylli~~ni surface conlaminarion" \,s. "l)ostt.cl signs 

,rlcrting \\orkcrs lo the ~~otcntial for cxl~osurc." Again, surSacc con[amirlario~i can not be 

co~.r.clatetlo i~irbomc bcryllill~n exposure or IicaIt11 rsishs. Fcll~ally. [lie scntcllcc. "I3\I'S'P 

)'- 17 1111t1 1101 ill\\ ilys pcrli~rrned or doculnentcd hazard asscssnlcnts for hcrylli~~nl 

conraminalion ;~lrliougli documented assessment \\:as \,iral to conilnunication of cxposusc 

I-isks." is ~iiislc;~clin~. .Ail- sampling, which is Ilic ori~nary colnponcnt ol'a hai.ard 

assessmen(. \+as conducted in each arca ofconccrli noted in rlie repoll. 

'I'llc fi)llo\\ ing corrccti\,c aclions arc taking place in relation to the rcconimc~idario~~s. 111 

tl~cr. Industrial I lygicnisrs from tllc Officc of Ilcnlrll. Safely ancl Security ;\lid NKSA 

Ilc;~tlq~~a~-~css lia\.e r.e\ ie\r.etl rlie corrccti\:c actions ant1 bclic\c thar rlie acrions \\,ill li~lly 

atltlrcss lllc rcco~nmc~ltlalio~ls li.o~n tlir I>~.ali Keporl. 'l'llcsc corrccri\.c acrions li;~\-c 

~III-catly hccn cnlcrcd illto tlic BWXT Y-17 Corrccri\.c Actions Planning System and \\III 

ix rrackcd rllro~rgh ro closure. 

i\'c sl~l)port ~llr actions rhat I3WX.f Y-12 has ~~nplcmcntctl in rclar~on lo tllc 

1.ccor111ncndarions: 

1. I.ull!. implcmc~lr 111c pl-occd~lrcs wirllin tlic Chronic Hcrylli~~~n 1)iscasc l'rc\ cntion 

I'~-ogri~rn including the staristical analysis of cllaraclcri/;~tion data, posting naming signs 

In I)cs\ Ilium conramirlatcd areas and perfomling and docu~llcnti~lg hazard asscsslnenls for 

I)c1-!4li11m coml~oc~ntls. 

Actio~is. 

Incrcasc the li-ccl~~cncy ol'bcryllium Area Validations kom a~irlllal 10 sc~ili-annual 

,111cl rccluirc li~lc ~na~lagc~ncnt co~~cun~c~icc thar the \.alitlation is accul-ate. Sratus: 

~~olll~>lcrc. 

Re-cllaracleri/e tlic Building 9202 Fo~otlry and disposition ally samplcs 

0,2ug.'IOOc1n2 in accorda~ice \\it11 I11 procedurts. Status: ('o~l~plctc. 

I'osl 13uilcIing 0808 in accordance \\:it11 IH P~.occtlu~-cs. Status: ('oml)letc. 

Issue ;I Sli~ntlrng Ortler lo slrcnglhcn FS&l I Keq~~irelncnrs k)r- ;ill \\ ork acti\.ity ill 

13~1lltling 0201 -5, Slalus: ('omplcre. 

Dc\clop iuntl cornl>lelc rrli-cslier [raining hr III Sraff on rhe si~slirce herylli~rm 

cllaractcri/alion process ant1 rrqc~iremrnts to conduel ant1 documcrlr Ii~i/ard . ,~s~~ssnlcrlrs . . .. . 

in accortlancc \\ ill1 Y73-201 H\VS'I \'-I7 CBDI'P Manual. Sr;rr~~s: C'omplcrc. 

Page 14 Management Comments 
Appendix 3 (continued) 

Scarrli databases ancl capture all surface conrariiination ~scsults 0.2 LI~/ IOOcm2 

(1908-present). 'I'he purpose of this action is to adtlrcss potenrial legacy surl'dcc 

contamination in accordance \vi~li the most recent \,ersion of~lie 13WXI Y- 12 (-'BDPP. 

Statlls: ('ornl>lete. 

1:slahlish a s\istcrn to track the dislIosition of all surface co~itaminat~o~i 1.esu1ts 

-.0.2 II~ I OOcm2 an11 tiocumcnl the decision maki~lg process \ ia the 1iar:il-tl asscss~ncnt 

requirccl ill 1'73-20 I. Status: 1)uc 1 1,15/07 

2. Iml>lcn~cnt asystem k)~- t~xcking 111 recommentlalion:. to cnslll-c they arc 

atl(lrcssetl t~~ncly. 

Action. li5tahlish and implement ;r systcm to [I-nck Ill rcco~nmcnd;~tic,ns toline 

Illunageliicnl Slatus: L)ilc 12 15:07. 

3. 1ins~r1.c thal Ilic hcsyllillm infol-mation database c~ri-I-cntly i~ntlcs tle\.clopnlcnt is 

coml~lctctl ant1 ii~ai~~taincd. 

!\~;III~. NNS/\ a~psccialcs the oppol-[unity to rcvicii this draft report. Slio~ilcl ~OLI lin\,c 

;III! clncstions ahoi~~ this response. please cont;lct Kicliard Spcidcl. Dil-ccto~-. I'olicy and 

lnlcrnal ('ontsols k,l;i~ingcmc~it. 

cc: I'ccl Sherry, Manager, Y- 12 Site Oflice 

[:rank Kusso, Selllor. 12di.1sor. I:n\,iron~iient. Safely and Health 

I)a\'id Hoyd. Senior Procuscmcnt I:sccuti\ c 

Ki~rcn Roal.dnian. [)irt.ctor. Scr\ icc ('enter 

Page 15 Management Comments 
Appendix 3 (continued) 

Department of Energy 

v!,istr~r~yr~~~?, iC58i 

October 5. 2007 

!! i 27 

\II.I\lOI<ANI)I .M ]:OR CiRE(;OKY [[. I~RIL<I)~lAN 

INSPE('T0R GENERAL - z s., ,,- /- - 

[:'ROM: GLEN& S~?ODO&~KY ,,--I - 

('W~F 1I~@2fii, SA-@f~ AKD SECUR~~~' 0I:I:IC't~K 

O~'I;IT-E~I' I Ik.4L'I'I 1. SAFE7')' AND SF('I.:KII'\' 

'l'lle Ol'licc ol' I Icalth. Sakfy and Security (HSS) has ie\\ ed rhe sul>lcct d~.;~li ;iucIrt I-~~OI.I 

~~'o\.idcd by rhc Inspector Gcncl-al's Oflice (IG) on Scptclnhcr 20. 2007. Uclo\\. is rhc r.csponsc 

10 ~llc lillclillg and rccom~ncntlafiorl ;itltlrcsscd lo HSS. 

\\!c ~-ccornn~cn(l th;~~ lllc 1lcp;u-rmcnr ol'1:llcrgy. CI~icl'Heslth. Safely ant1 Sce~~l-iry Ol'licct. I-c\.isc 

rhc Ucp;~rtlllcllr's scglrlatious to rcclu~rc colltrols including posting :u.eas \\,hen surl;~cc bc~-yll~~lln 

eolltalllill;~llon OeeLIrS Ill 11011-0per;l~io11a~ 3rClS. 

( 'o~lcul-: 'l~rlc 10 CI:R 850 "Chronic Beryllium Discasc 1'1-orcction I'rogs;~m" (Rulc) \\.as 

~~~rl~lishcd as a Iinal ~.ulc in rhe 1;ecieral [ieyisrer on [)cccmhcr 1000. Slncc tllaf IIIII~. t-iSS has 

hccn \\ orkillg \\ it11 all of its stakchol(icrs to cllaractcrizc a nunlher of iss~~es ~)o.;cd h\ IIIC Kulc 

a~~d h;ls publisllcd a numbel- of technical clarifications of the Rulc. I ISS 112s scllcdulccl the 

clc\clol~rllent ol';un amcnclmcnt rn rhc Rule for F\' 7008 10 address tllosc ~ssucs ant1 fo~-rn;\l~/c 

tllclsc (ccl~l~ical cl;lrrlications. During tllc process of developing an~c~l~l~llcll~s 10 (Ilc Rulc, l lSS 

\\-ill :~dtircss tllc I(;'s sccolnrncndatio11 regarding the posting o1'arc;rs \\he11 sul.lilcc he~.yllium 

conlamin;~t~orl occurs in non-ol~crat~or~al arcas. 

I I' ~)LI II;I\.c ;111y q~~estiolls. you 11l;ly e0111;~ct me at (301 ) 00.7--7777 or Ila\ c. a ~llernl~c~. of' your staff 

conlac1 I'alricla LVortlli~lgton at (301 ) 003-5020. 

@' I 

Page 16 Objective, Scope, and Methodology 
IG Report No. DOEJIG-0783 

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