ENVIRONMENTAL ASSESSMENT

UPGRADE AND STORAGE OF BERYLLIUM 

Defense Logistics Agency

Strategic Materials 

Fort Belvoir, Virginia 

November 2014
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1 SUMMARY 

2 

3 

4 The Defense Logistics Agency–Strategic Materials (DLA–Strategic Materials) has prepared 

5 this environmental assessment (EA) to address the potential environmental impacts of the 

6 proposed upgrade and conversion of a portion of the existing U.S. National Defense 

7 Stockpile (NDS) of beryllium, as well as the long-term storage of the converted material. 

8 DLA–Strategic Materials is a field activity of the Defense Logistics Agency and is 

9 responsible for providing safe, secure, and environmentally sound stewardship of the 

10 beryllium stockpile and other critical materials that are part of the NDS. 

11 

12 Beryllium is a naturally occurring, but somewhat rare, metallic element found in the earth’s 

13 crust. Its strength and low density make it desirable for use in structural applications for the 

14 military, avionics, optics, aerospace, and nuclear industries. The NDS beryllium is currently 

15 stored as individual solid cylindrical billets at the Hammond Depot in Indiana. The 

16 Hammond Depot is located in Lake County, Indiana, less than 0.1 mile (0.2 km) east of the 

17 border with Cook County, Illinois, which also serves as the southeastern boundary of the city 

18 of Chicago. The NDS beryllium was acquired in the 1980s under contract according to 

19 government specifications that existed at that time. The NDS beryllium stockpile currently 

20 consists of solid metal billets. However, DLA–Strategic Materials has determined that a 

21 portion of the metal billets currently in storage must be upgraded and converted into forms 

22 more readily useable by the U.S. Department of Defense (DOD) or its subcontractors in time 

23 of national emergency. The proposed beryllium upgrade and conversion would result in the 

24 creation of forms of beryllium that are highly compatible with the inputs required for current 

25 manufacturing processes. 

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27 Under the Proposed Action evaluated in this EA, DLA–Strategic Materials proposes to 

28 have up to 20 tons (18,140 kg) of the existing NDS beryllium billets upgraded and converted 

29 at one or more off-site commercial facilities and to then return the converted beryllium to the 

30 Hammond Depot for continued safe and environmentally sound long-term storage. This EA 

31 assesses the potential environmental impacts of the Proposed Action at the Hammond Depot, 

32 as well as along the potential transportation routes. Cumulative impacts of the Proposed 

33 Action are included. The environmental impacts of the No-Action alternative (i.e., not 

34 upgrading the beryllium and leaving it in storage in its existing billet form) are also 

35 presented. 

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37 Because the beryllium upgrade and conversion activities at off-site commercial facilities 

38 would be conducted in compliance with all applicable Federal, state, and local laws, 

39 regulations, requirements and permits, the potential environmental impacts of the activities at 

40 those commercial facilities are beyond the scope of this environmental analysis and are not 

41 addressed in detail in this EA. 

42 
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1 The areas of assessment in this EA include the potential impacts from routine operations 

2 on human health and safety; transportation; land use; water resources; ecological resources, 

3 including threatened and endangered species; socioeconomics; environmental justice; 

4 cultural resources; noise; aesthetics; air quality; and waste management. The potential 

5 impacts from accidental releases of beryllium are also assessed. 

6 

7 Beryllium is a known carcinogen. The primary health effect of concern from exposure to 

8 beryllium is the development of either acute beryllium disease or chronic beryllium disease. 

9 The effects of the former are temporary and would be resolved within a few months after 

10 exposure, but the long-term effects of the latter are very serious and can lead to an overall 

11 deterioration of an exposed individual’s health, including death. However, development of 

12 chronic beryllium disease only occurs among individuals that have become sensitized to 

13 beryllium, and this is estimated to affect only about 6 to 8 percent of those individuals who 

14 have become sensitized. 

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16 Traffic accidents during the off-site transport of the beryllium could result in injuries or 

17 fatalities. Accident analyses are framed in probabilistic terms, in that the accident analysis 

18 can only estimate the likelihood that a particular event might occur. The results of the 

19 accident analysis in this EA show that, statistically, far less than one non-fatal injury—and 

20 much, much less than one fatality—would be expected to result from traffic accidents during 

21 the transport of the beryllium to the off-site conversion facilities and back again to the 

22 Hammond Depot. Because beryllium is a solid, it should be possible to contain and quickly 

23 clean up any accidental spills that were to occur. Therefore, traffic accidents during 

24 transportation of the beryllium stockpile would be expected to produce no significant adverse 

25 impacts on human health or the environment as a result of exposure to any spilled or released 

26 beryllium. 

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28 Based on the analysis of the Proposed Action’s potential impacts to the human environment 

29 from routine operations—including impacts to human health and safety; transportation; 

30 land use; water resources; ecological resources, including threatened and endangered species; 

31 socioeconomics; environmental justice; cultural resources; noise; aesthetics; air quality; and 

32 waste management—this EA concludes that the Proposed Action would produce no 

33 significant adverse impacts. Additionally, indirect (cumulative) impacts would also produce 

34 no significant adverse impacts. 

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36 Based on the results of the analyses documented in this EA and the finding that no significant 

37 adverse impacts would be expected to occur as a result of the Proposed Action, it can be 

38 concluded that an environmental impact statement is not needed, and a finding of no 

39 significant impact is recommended. 

40 
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1 CONTENTS 

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4 SUMMARY .......................................................................................................................... i

5 LIST OF FIGURES .............................................................................................................. vii

6 LIST OF TABLES ................................................................................................................ vii

7 ACRONYMS AND ABBREVIATIONS ............................................................................. ix

8 1. PURPOSE AND NEED FOR THE PROPOSED ACTION ............................................ 1 

9 1.1 INTRODUCTION AND BACKGROUND ........................................................... 1

10 1.2 THE HAMMOND DEPOT .................................................................................... 1

11 1.3 CHARACTERISTICS OF BERYLLIUM .............................................................. 4

12 1.4 SCOPE OF THE ENVIRONMENTAL ANALYSIS ............................................. 4 

13 1.5 PUBLIC INVOLVEMENT .................................................................................... 6 

14 2. DESCRIPTION OF THE PROPOSED ACTION ........................................................... 7 

15 3. ALTERNATIVES TO THE PROPOSED ACTION ....................................................... 11

16 3.1 THE NO-ACTION ALTERNATIVE ..................................................................... 11 

17 3.2 OTHER ALTERNATIVES TO THE PROPOSED ACTION ................................ 11 

18 4. THE AFFECTED ENVIRONMENT AND CONSEQUENCES ................................... 13 

19 4.1 HUMAN HEALTH AND SAFETY ........................................................................ 13

20 4.1.1 Existing Environment ................................................................................. 13 

21 4.1.2 Potential Impacts of the Proposed Action ................................................... 13 

22 4.1.2.1 Beryllium exposure pathways ........................................................ 13 

23 4.1.2.2 Toxicity of beryllium ..................................................................... 14 

24 4.1.2.3 Measures to prevent exposure and adverse health effects ............. 18 

25 4.1.3 Potential Impacts of the No-Action Alternative ......................................... 21 

26 4.2 TRANSPORTATION ............................................................................................. 21 

27 4.2.1 Existing Environment ................................................................................. 21 

28 4.2.2 Accident Analysis ....................................................................................... 21 

29 4.2.2.1 The risk of a transportation accident .............................................. 22 

30 4.2.2.2 The consequences of a transportation accident .............................. 26 

31 4.2.3 Potential Impacts of the Proposed Action ................................................... 28 

32 4.2.4 Potential Impacts of the No-Action Alternative ......................................... 29 

33 4.3 LAND USE ............................................................................................................. 29

34 4.3.1 Existing Environment ................................................................................. 29 

35 4.3.2 Potential Impacts of the Proposed Action ................................................... 30 

36 4.3.3 Potential Impacts of the No-Action Alternative ......................................... 30 

37 
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1 4.4 WATER RESOURCES ........................................................................................... 30 

2 4.4.1 Existing Environment ................................................................................. 30 

3 4.4.2 Potential Impacts of the Proposed Action ................................................... 31 

4 4.4.3 Potential Impacts of the No-Action Alternative ......................................... 32 

5 4.5 ECOLOGICAL RESOURCES ............................................................................... 32

6 4.5.1 Existing Environment ................................................................................. 32 

7 4.5.2 Potential Impacts of the Proposed Action ................................................... 33 

8 4.5.3 Potential Impacts of the No-Action Alternative ......................................... 33 

9 4.6 SOCIOECONOMICS ............................................................................................. 33 

10 4.6.1 Existing Environment ................................................................................. 33 

11 4.6.2 Potential Impacts of the Proposed Action ................................................... 34 

12 4.6.3 Potential Impacts of the No-Action Alternative ......................................... 34 

13 4.7 ENVIRONMENTAL JUSTICE .............................................................................. 35

14 4.7.1 Existing Environment ................................................................................. 35 

15 4.7.2 Potential Impacts of the Proposed Action ................................................... 36 

16 4.7.3 Potential Impacts of the No-Action Alternative ......................................... 36 

17 4.8 CULTURAL RESOURCES .................................................................................... 36 

18 4.8.1 Existing Environment ................................................................................. 36 

19 4.8.2 Potential Impacts of the Proposed Action ................................................... 36 

20 4.8.3 Potential Impacts of the No-Action Alternative ......................................... 37 

21 4.9 NOISE ...................................................................................................................... 37

22 4.9.1 Existing Environment ................................................................................. 37 

23 4.9.2 Potential Impacts of the Proposed Action ................................................... 37 

24 4.9.3 Potential Impacts of the No-Action Alternative ......................................... 37 

25 4.10 AESTHETICS.......................................................................................................... 37 

26 4.10.1 Existing Environment ................................................................................. 37 

27 4.10.2 Potential Impacts of the Proposed Action ................................................... 38 

28 4.10.3 Potential Impacts of the No-Action Alternative ......................................... 38 

29 4.11 METEOROLOGY AND AIR QUALITY ............................................................... 38

30 4.11.1 Existing Environment ................................................................................. 38 

31 4.11.2 Potential Impacts of the Proposed Action ................................................... 39 

32 4.11.3 Potential Impacts of the No-Action Alternative ......................................... 39 

33 4.12 WASTE MANAGEMENT ...................................................................................... 39 

34 4.12.1 Existing Environment ................................................................................. 39 

35 4.12.2 Potential Impacts of the Proposed Action ................................................... 40 

36 4.12.3 Potential Impacts of the No-Action Alternative ......................................... 40 

37 4.13 CUMULATIVE IMPACTS ..................................................................................... 40 

38 4.13.1 Hammond Depot .......................................................................................... 40 

39 4.13.2 Transportation Routes ................................................................................. 41 

40 
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1 5. FINDINGS AND CONCLUSIONS ................................................................................ 43 

2 5.1 FINDINGS .............................................................................................................. 43 

3 5.1.1 Consequences of the No-Action Alternative ................................................ 43 

4 5.1.2 Consequences of the Proposed Action ......................................................... 43

5 5.2 CONCLUSIONS ..................................................................................................... 44 

6 6. LIST OF PREPARERS AND PERSONS CONSULTED ............................................... 45

7 7. REFERENCES ................................................................................................................ 47
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1 LIST OF FIGURES 

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3 Figure Page 

4 1. Aerial photograph of the Hammond Depot and its environs ........................................... 3 

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8 LIST OF TABLES 

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10 Table Page 

11 1. Characteristics of beryllium ............................................................................................. 5 

12 2. Beryllium standards and guidelines ................................................................................. 15 

13 3. Accident statistics for crashes over the past ten years that have 

14 involved large trucks ........................................................................................................ 24 

15 4. Statistically anticipated accidents during proposed beryllium shipments 

16 and their consequences .................................................................................................... 26

17 5. Characteristics of the population around the Hammond Depot ....................................... 35 

18 6. Summary of the impacts of the alternatives ..................................................................... 44
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1 ACRONYMS AND ABBREVIATIONS 

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4 μg microgram = 1 millionth of a gram 

5 μm micrometer = 1 millionth of a meter 

6 ACGIH American Conference of Governmental Industrial Hygienists 

7 AEDL Army Engineer District, Louisville 

8 AMS Aerospace Material Specification 

9 ASTM American Society for Testing and Materials 

10 ATSDR U.S. Agency for Toxic Substances and Disease Registry 

11 BeLPT beryllium lymphocyte proliferation test 

○ 12 C degrees Celsius 

13 CAS Chemical Abstract Service 

14 CEQ Council on Environmental Quality 

15 CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

16 CFR Code of Federal Regulations

17 cm centimeter = 1 hundredth of a meter 

18 CO2 carbon dioxide 

19 COPD chronic obstructive pulmonary disease 

20 DLA Defense Logistics Agency 

21 DOD U.S. Department of Defense 

22 DOT U.S. Department of Transportation 

23 EA environmental assessment 

24 EPA U.S. Environmental Protection Agency 

○ 25 F degrees Fahrenheit 

26 FARS Fatality Analysis and Reporting System 

27 FMCSA Federal Motor Carrier Safety Administration 

28 FONSI finding of no significant impact 

29 ft feet 

ft2 30 square feet 

ft3 31 cubic feet 

32 g gram 

33 gal gallon 

34 ha hectare 

35 HIP hot isostatic pressable 

36 HPP hot pressed powder 
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1 I- U.S. Interstate highway 

2 IARC International Agency for Research on Cancer 

3 IDEM Indiana Department of Environmental Management 

4 IDNR Indiana Department of Natural Resources 

5 in. inch 

6 kg kilogram = 1 thousand grams 

7 km kilometer = 1 thousand meters 

8 lb pound 

9 m meter 

m2 10 square meters

m3 11 cubic meters

12 MCDC Missouri Census Data Center 

13 MMAD mass median aerodynamic diameter 

14 mph miles per hour 

15 N/A not available or not applicable 

16 NAAQS National Ambient Air Quality Standards 

17 NDS National Defense Stockpile 

18 NEPA National Environmental Policy Act 

19 NIOSH National Institute for Occupational Safety and Health 

20 NPDES National Pollutant Discharge Elimination System 

21 NRC National Research Council 

22 NSSL National Severe Storms Laboratory 

23 NTP National Toxicology Program 

24 NWS National Weather Service 

25 ORNL Oak Ridge National Laboratory 

26 OSHA Occupational Safety and Health Administration 

27 PEL permissible exposure limit 

28 PPE personal protective equipment 

29 RCRA Resource Conservation and Recovery Act 

30 REL recommended exposure limit 

31 RfC reference concentration 

32 RFP request for proposal 

33 RISC Risk Integrated System of Closure 

34 SPDES State Pollutant Discharge Elimination System 

35 SPLP Synthetic Precipitation Leaching Procedure 

36 SWPPP Stormwater Pollution Prevention Plan 
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1 TCLP Toxicity Characteristic Leaching Procedure 

2 TLV threshold limit value 

3 TWA time-weighted average 

4 U.S. United States 

5 U.S.C. United States Code

6 USCB U.S. Census Bureau 

7 VMT vehicle miles traveled 

8 yd yard 

yd3 9 cubic yards 

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1 1. PURPOSE AND NEED FOR THE PROPOSED ACTION

2 

3 

4 The Defense Logistics Agency–Strategic Materials (DLA–Strategic Materials) is 

5 responsible for the safe, secure, and environmentally sound stewardship of the National 

6 Defense Stockpile (NDS) of beryllium, which is currently stored at a depot in Indiana. 

7 DLA–Strategic Materials proposes to continue its stewardship of this material by having a 

8 portion of the beryllium upgraded and converted into more useable forms and placing the 

9 converted beryllium back into long-term storage. DLA–Strategic Materials needs to perform 

10 the proposed action because the solid beryllium billets currently in storage are not in forms 

11 readily useable by the U.S. Department of Defense (DOD) or its subcontractors in time of 

12 national emergency. The proposed upgrade and conversion would result in the creation of 

13 more useable forms of beryllium. 

14 

15 Chapter 1 of this environmental assessment (EA) provides essential background information 

16 and describes the purpose and need of the Proposed Action, as well as the scope of the 

17 environmental review and analysis. Chapter 2 defines and describes the Proposed Action in 

18 detail. Chapter 3 describes the No-Action alternative and other alternatives to the Proposed 

19 Action. Chapter 4 describes the existing baseline environmental conditions for each relevant 

20 resource area and evaluates the potential environmental impacts that would occur thereto 

21 under the Proposed Action or the No-Action alternative. The conclusions are presented in 

22 Chapter 5. 

23 

24 1.1 INTRODUCTION AND BACKGROUND

25 

26 This EA has been prepared by DLA–Strategic Materials to address the potential 

27 environmental impacts of the proposed upgrade and conversion of approximately 20 tons 

28 (18,140 kg) of the existing NDS stockpile of beryllium, as well as the long-term storage of 

29 that material following its conversion. The NDS was established by Congress through the 

30 Strategic and Critical Materials Stock Piling Act of 1939 to minimize U.S. dependence on 

31 foreign sources of essential materials during times of national emergency. Between 1949 

32 and 1988, the General Services Administration managed the program. In 1988, the 

33 responsibility for the NDS was transferred to the Secretary of Defense, who assigned the 

34 program to the Defense Logistics Agency (DLA). DLA–Strategic Materials is a field 

35 activity of DLA and is responsible for providing safe, secure, and environmentally sound 

36 stewardship of the beryllium stockpile and other critical materials as part of the NDS. 

37 

38 1.2 THE HAMMOND DEPOT 

39 

40 DLA–Strategic Materials currently manages the NDS stockpile of beryllium which is 

41 stored as individual solid, cylindrical billets at the Hammond Depot in Indiana. The 

42 Hammond Depot is located in Lake County, Indiana, less than 0.1 mile (0.2 km) east of the 
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1 border with Cook County, Illinois, which also serves as the southeastern boundary of the 

2 city of Chicago. The street address for the Hammond Depot is 3200 Sheffield Avenue, 

3 Hammond, Indiana. 

4 

5 Wolf Lake borders the Hammond Depot on the west, and Lake Michigan is about 2.5 miles 

6 (4.0 km) to the north (Fig. 1). The Hammond Depot encompasses approximately 60 acres 

7 (24 ha) that are situated in a previously disturbed industrial setting. The area around and 

8 including the Hammond Depot property was a wetland in the mid-1940s and was filled long 

9 ago with a substantial amount of blast-furnace slag to give the site a stable and level 

10 foundation (Cash 1998). All areas immediately surrounding the depot, other than bodies of 

11 water, are current developed or have been extensively disturbed. 

12 

13 The structure in which the beryllium billets are currently stored (and where the upgraded and 

14 converted beryllium would be stored) is constructed of concrete block walls with firewalls on 

15 a concrete slab. This structure has no climate controls, such as heating or air conditioning. 

16 

17 The items currently located inside the beryllium storage structure include materials and/or 

18 their associated storage packaging with the following characteristics, as categorized by the 

19 codes developed by the National Fire Protection Association: 

20 

21 • Flammability: Materials that require considerable preheating, under all ambient 

22 temperature conditions, before ignition and combustion can occur; flash point at or 

23 above 200 °F (93 °C). 

24 • Health: Intense or continued, but not chronic, exposure could cause temporary 

25 incapacitation or possible residual injury. 

26 • Reactivity: Undergoes violent chemical change at elevated temperatures and pressures, 

27 reacts violently with water, or may form explosive mixtures with water. 

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29 Sodium-chloride type fire extinguishers are available at the Hammond Depot for use in 

30 suppressing any fires that might occur inside the beryllium storage structure. 

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32 The residents located nearest to the Hammond Depot installation boundary are over 600 ft 

33 (180 m) from the property boundary; however, the nearest residence is over 1500 ft (460 m) 

34 from the location where the beryllium billets are currently stored (and where the upgraded 

35 and converted beryllium would be stored). 

36 

37 Access to the Hammond Depot exists by both road and rail. There is easy access 

38 to Interstate-90 and U.S. Highway 41 near the eastern boundary of the depot, as well as to 

39 U.S. Highways 12 and 20 further to the east, I-80 to the south of the depot, and I-94 to the 

40 west of the depot. The receipt and shipment of almost all commodities at the depot 
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Fig. 1. Aerial photograph of the Hammond Depot and its environs. 

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1 occur by truck. The rail access is seldom used at the depot; however, at least once each day 

2 the nearby railways are used for delivery and pick-up of railcars at the commercial facilities 

3 just north of the depot. 

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5 1.3 CHARACTERISTICS OF BERYLLIUM 

6 

7 The characteristics of beryllium are summarized in Table 1. Beryllium is a naturally 

8 occurring, but somewhat rare, metallic element found in the earth’s crust. Its strength and 

9 low density make it desirable for use in structural applications for the military, avionics, 

10 optics, aerospace, and nuclear industries. Beryllium occurs naturally only in combination 

11 with other elements in minerals. The extraction of beryllium from its compounds is 

12 accomplished by thermal processing; however, the United States, China, and Kazakhstan 

13 are the only three countries involved in the industrial scale extraction of beryllium 

14 (Materion 2014). 

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16 1.4 SCOPE OF THE ENVIRONMENTAL ANALYSIS 

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18 This EA assesses and documents the potential environmental effects of the Proposed 

19 Action and its alternatives (as defined in greater detail in Chapters 2 and 3 of this EA). 

20 The Proposed Action is to have a portion of the existing NDS beryllium billets—up to 

21 20 tons (18,140 kg)—upgraded and converted into more useable forms. 

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23 To accomplish the Proposed Action, DLA–Strategic Materials proposes to ship the beryllium 

24 billets to one or more off-site commercial facilities where the upgrade and conversion of the 

25 beryllium would occur. The upgraded and converted beryllium would then be returned to the 

26 Hammond Depot for continued safe and environmentally sound long-term storage. 

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28 Any beryllium billets not upgraded and converted under the Proposed Action would remain 

29 in storage at the Hammond Depot. 

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31 For the purpose of making a conservative estimate of potential impacts, the transportation 

32 analysis in Section 4.2 assumes a larger number of beryllium billets would be transported to 

33 an off-site conversion facility than the 20 tons (18,140 kg) being contemplated for conversion 

34 under the Proposed Action. This assumption results in a significant overestimation of the 

35 amount of off-site transportation required, thereby establishing an upper bound on the 

36 potential environmental impacts that might occur during the transportation of 20 tons 

37 (18,140 kg) of beryllium under the Proposed Action. 

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39 One anticipated form of the upgraded and converted beryllium would be a powdered form. 

40 Beryllium powder is characterized as both a “flammable solid” and a “poison inhalation 

41 hazard” as specified in the U.S. Department of Transportation’s (DOT’s) Hazardous 

42 
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1 Table 1. Characteristics of beryllium 

Chemical formula Be 

CAS number(1) 7440-41-7 

Atomic number 4 

Atomic mass 9.01 

Specific gravity 1.848 

Density 115.3 lb/ft3

 (1480.7 kg/m3) 

Melting point 2349°F (1287°C) 

Flash point None for solid form. Ignition can occur between about 1000 and 1290°F (540 

and 700°C) in the powdered form consisting of 1 to 5 μm particles. Beryllium 

powder at a dust concentration of 3 kg/m3

 (0.19 lb/ft3) was found to be weakly 

explosive. 

Fire suppression Avoid the use of water, carbon dioxide, and halides/halogen gases. Appropriate 

extinguishing media include dolomite, dry powder, dry sand, graphite, soda ash, 

and/or sodium chloride. Appropriate to use a portable fire extinguisher with 

Class D rating (for metals fires). 

Physical properties Light gray, brittle metallic solid. Not soluble in water. 

Principal hazards None for solid form. Powdered form or particulate/dust can create a combustion 

hazard (i.e., rapid oxidation) and can also cause irritation to nose, throat, lungs 

and mucous membranes. Inhalation of powdered form or particulate/dust may 

cause serious, chronic lung disease in some individuals. Human carcinogen 

according to IARC and NTP(2). 

Uses Strong, lightweight metal with high rigidity and/or thermal stability in applications 

for structures for the military, avionics, optics, aerospace and nuclear industries. 

Notes: 

 (1) CAS = Chemical Abstract Service 

 (2) IARC = International Agency for Research on Cancer; NTP = National Toxicology Program 

2 

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4 Materials Table (49 CFR 172.101). Because the U.S. Environmental Protection Agency’s 

5 (EPA’s) criterion for the ignitability characteristic (40 CFR 261.21) defers to the DOT 

6 definition, beryllium powder would be considered a hazardous waste under the Resource 

7 Conservation and Recovery Act (RCRA). 

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9 For the purpose of analysis in this EA, the upgrade and conversion process is assumed to 

10 produce only beryllium powder, even though other forms of converted beryllium are being 

11 contemplated under the Proposed Action. Because the potential human health effects from 

12 exposure to beryllium powder, as described in Section 4.1 of this EA, are the most serious 

13 among all forms of converted beryllium, this assumption provides an upper bound estimate 

14 of the potential human health effects that are associated with the Proposed Action. 

15 
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1 Because the beryllium upgrade and conversion activities at the off-site facilities would 

2 be conducted in compliance with all applicable Federal, state, and local laws, regulations, 

3 requirements and permits, the potential environmental impacts of the activities at those 

4 facilities are beyond the scope of this environmental analysis and are not addressed further in 

5 this EA. 

6 

7 This EA has been prepared in accordance with the National Environmental Policy Act 

8 (NEPA) of 1969 [42 United States Code (U.S.C) 4321, et seq.], the Council on 

9 Environmental Quality Regulations implementing NEPA [40 Code of Federal Regulations

10 (CFR) Parts 1500-1508], and with DLA Regulation 1000.22, “Environmental Considerations 

11 in DLA Actions in the United States.” As required under these regulations, a No-Action 

12 alternative is also considered in this EA (see Section 3.1). 

13 

14 The potential for environmental impacts is assessed at the Hammond storage depot and 

15 along the potential transportation corridors to and from the hypothetical location of the off16 site facility where the beryllium upgrade and conversion activities will occur. Cumulative 

17 impacts of the Proposed Action are included. 

18 

19 The areas of assessment in this EA include potential impacts from routine operations to land 

20 use; air quality; water resources; human health and safety; ecological resources, including 

21 threatened and endangered species; socioeconomics; environmental justice; cultural 

22 resources; noise; aesthetics; waste management; and transportation. Potential impacts to 

23 human health from accidents are also assessed. 

24 

25 1.5 PUBLIC INVOLVEMENT 

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27 DLA–Strategic Materials invites public participation in this NEPA process. Consideration of 

28 the views and information of all interested persons promotes open communication and 

29 enables more informed decision making. Agencies, organizations, and members of the 

30 public having a potential interest in the Proposed Action, including minority, low-income, 

31 disadvantaged, and Native American groups, are invited to participate in the decision-making 

32 process. 
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1 2. DESCRIPTION OF THE PROPOSED ACTION 

2 

3 

4 The NDS beryllium stockpile at the Hammond Depot was acquired in the 1980s under 

5 contract according to government specifications that existed at that time. The NDS beryllium 

6 stockpile consists of metal billets, with a purity of over 99 percent, manufactured by a hot 

7 pressed powder (HPP) process. These HPP beryllium billets are cylindrical in shape, each 

8 having a diameter between 30 and 36 in. (76 and 91 cm) and a length between 38 and 46 in. 

9 (97 and 117 cm). Each billet can thus weigh between about 1800 and 3120 pounds (815 to 

10 1415 kg), with the typical weight being around 2400 pounds (1100 kg). Each billet is 

11 wrapped in sealed polyethylene and is individually packed inside a wooden crate. 

12 

13 DLA–Strategic Materials has determined that the existing HPP beryllium billets do not meet 

14 current specifications for many modern DOD applications. DLA–Strategic Materials 

15 therefore proposes to upgrade a portion of the NDS beryllium stockpile into forms better 

16 aligned with current and future DOD needs. The proposed upgrade would convert the 

17 existing HPP beryllium billets into one or more final products that would be of the same 

18 types used as a feedstock in current state-of-the art manufacturing processes. The upgraded 

19 and converted beryllium is also expected to be applicable to these same manufacturing 

20 processes for the foreseeable future. The upgrade and conversion activities would be 

21 conducted under contracts between DLA–Strategic Materials and one or more off-site 

22 commercial facilities. 

23 

24 Under the Proposed Action, up to 20 tons (18,140 kg) of beryllium billets would be upgraded 

25 and converted into other, more useable forms. However, for the purpose of analyzing and 

26 bounding the potential environmental impacts in this EA, it is assumed that 85 tons 

27 (77,100 kg) of NDS inventory beryllium billets would be transported to a hypothetical off28 site conversion facility. Furthermore, it is assumed that the distance from the Hammond 

29 Depot to that hypothetical conversion facility is 1000 miles (1600 km), even though the 

30 probable facilities are much closer. These assumptions regarding quantities and distances 

31 would result in an overestimation of any resulting transportation impacts and would thus 

32 bound the magnitude and extent of any such impacts associated with the Proposed Action. 

33 

34 Under the Proposed Action, each crate containing a single beryllium billet would be removed 

35 from its storage location at the Hammond Depot by forklift and loaded onto a truck located 

36 adjacent to the storage structure. The load would be appropriately secured inside the truck, 

37 and the truck would then transport the crate/billet to an off-site commercial facility where the 

38 upgrade and conversion process would occur. All such upgrade and conversion activities 

39 would be conducted at the off-site facilities in compliance with all applicable state, local 

40 and federal laws, regulations, requirements, and permits. 

41 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 8 Strategic Materials

1 As a pilot test of the process for upgrading and converting the beryllium billets, DLA–

2 Strategic Materials has executed a request for proposal (RFP) with industry to have two 

3 billets shipped to an off-site facility, converted into hot isostatic pressable (HIP) beryllium 

powder1 4 , and returned to the Hammond Depot. A return shipment for the first processed 

5 billet (as described in the following paragraph) has been received at the Hammond Depot. In 

6 August 2014, DLA–Strategic Materials issued a second RFP to industry for another pilot test 

7 to convert an additional two billets into beryllium powder. 

8 

9 The beryllium powder produced from the first billet was purged with an inert gas (i.e., argon) 

10 and then vacuum packed and sealed in leak-proof bags/liners which were then placed inside 

five sealed 55-gal (0.2 m3 11 ) steel drums at the off-site conversion facility. Each drum was 

12 braced and blocked onto a standard wooden pallet for shipment; however, the future storage 

13 configuration would use flame-retardant polymer pallets for storage of all future shipments, 

14 as well as for storage of the drums already received. Following shipment by truck, the drums 

15 were placed back into storage at the Hammond Depot in the as-received condition. The 

16 receiving process involves moving the transport vehicle adjacent to the storage structure and 

17 then moving the pallets with the drums by forklift to the storage location inside the storage 

18 structure. 

19 

20 DLA–Strategic Materials is in the process of procuring storage enclosures in the form of 

21 metal cabinets, lockers, or vaults that will hold the pallets of converted-beryllium drums. 

22 Each storage enclosure would be installed inside the existing beryllium storage structure at 

23 the Hammond Depot and would hold up to 24 pallets (with four drums per pallet). Each 

24 storage enclosure would have walls designed for a 4-hr fire rating. Access to the storage 

25 enclosure would be from the side through a closable, fire-proof door. Each storage enclosure 

26 would be anchored to the existing concrete floor slab to prevent movement of the enclosure 

27 and to protect the contents during tornadoes, other high-wind events, or earthquakes. 

28 

29 Under the Proposed Action, work at the Hammond Depot would be performed one billet at a 

30 time; however, multiple billets might be loaded onto a single truck for transport to the off-site 

31 conversion facility. In a similar manner, multiple shipments of upgraded and converted 

32 beryllium might be received at the same time at the Hammond Depot. 

33 

34 The shipping/loading activities and the receiving/unloading activities at the Hammond 

35 Depot would be conducted by depot personnel; however, personnel under contract to the 

36 off-site conversion facility would be responsible for securing the load inside the truck prior 

37 to shipment, as well as the transport of beryllium to and from the conversion facility. 

38 The upgrade and conversion activities at the off-site facility would be conducted by the 

39 employees of that facility. 

40 

 

1

 The final product specified in the RFP is structural-grade, high-purity beryllium powder. The specifications 

call for the production of HIP beryllium powder with an average grain size of 20μm or less. 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 9 Strategic Materials

1 All workers would be trained in the potential hazards associated with the Proposed Action 

2 and would be subject to health, safety and environmental requirements, including the 

3 Environmental Safety and Occupational Health Policy of DLA–Strategic Materials. 

4 Operating procedures, as well as those in the existing Hammond Depot Emergency Response 

5 Plan (DLA 2014), have been developed to reduce the risk of spreading contamination in the 

6 event a drum of converted beryllium (including beryllium powder) were to spill its contents. 

7 Additionally, personnel protective equipment (such as respirators) appropriate to the airborne 

8 beryllium hazard that may be encountered during the Proposed Action is available onsite. 

9 

10 Procedures have been developed to mitigate potential hazards to workers associated with the 

11 Proposed Action, including the following items: 

12 

13 • a dropped converted-beryllium pallet or drum inside the storage structure or during truck 

14 unloading operations resulting in a spill of the contents, 

15 • penetration of a converted-beryllium drum by a forklift tine, 

16 • exposure (individual and collective) to converted forms of beryllium, including beryllium 

17 powder, and 

18 • periodic beryllium lymphocyte proliferation test (BeLPT) screenings—as described in 

19 Section 4.1.2.2 of this EA—for depot workers to check for sensitization to beryllium. 

20 

21 Required training for workers at the Hammond Depot would minimize the potential risks to 

22 workers. This would include beryllium safety training that is specific to the Proposed Action, 

23 as well as existing training programs in the following general categories: 

24 

25 • Occupational Safety and Health Administration (OSHA) safety training, 

26 • OSHA certification of all forklift operators, 

27 • DOT training for off-site shipment personnel, and 

28 • respirator training as dictated by hazardous waste operations requirements, including 

29 medical approval for the wearing of a respirator. 

30 

31 No revisions or changes to either the existing shipping/receiving facilities or the storage 

32 buildings at the Hammond Depot are envisioned as part of this Proposed Action; however, 

33 studies are in progress to identify any additional storage conditions that would be favorable 

34 for the long-term storage of the upgraded and converted beryllium. 

35 

36 DLA–Strategic Materials expects to complete the beryllium upgrade and conversion portion 

37 of the Proposed Action within a five-year period and before the end of calendar year 2020. 

38 Under the Proposed Action, long-term storage of the upgraded and converted forms of 

39 beryllium at the Hammond Depot would then continue after that date. A minimally intrusive 

40 inspection methodology would be employed by DLA–Strategic Materials for the periodic, 

41 on-going quality surveillance of the upgraded and converted beryllium and to verify the 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 10 Strategic Materials

1 continued integrity of the storage containers, the internal inert atmosphere status, and the 

2 product quality for the duration of the long-term storage period. 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 11 Strategic Materials

1 3. ALTERNATIVES TO THE PROPOSED ACTION 

2 

3 

4 3.1 THE NO-ACTION ALTERNATIVE 

5 

6 Under the No-Action alternative, the NDS beryllium stockpile would continue to be stored 

7 in billet form at the Hammond Depot for the foreseeable future. Routine inspections and 

8 maintenance of this stockpile would continue. No changes, other than maintenance and 

9 repairs needed to ensure continued safe storage, would be made to the present beryllium 

10 storage structure or related facilities at the Hammond Depot. 

11 

12 In the event the beryllium was needed to satisfy future critical U.S. security, military or 

13 aerospace uses, it would not be available in the forms required as input to current 

14 manufacturing processes, and the billets would likely require conversion at that time. 

15 DLA–Strategic Materials has obtained estimates that it takes about 10 weeks to turn 

16 beryllium billets into powder. Hence, the usefulness of the beryllium in billet form would 

17 be questionable for any such future U.S. critical needs. 

18 

19 3.2 OTHER ALTERNATIVES TO THE PROPOSED ACTION 

20 

21 DLA–Strategic Materials has made a determination that the upgrade and conversion of up 

22 to 20 tons (18,140 kg) of beryllium billets into other forms is essential to the continued 

23 usefulness of this material as part of the NDS. Furthermore, the conversion and upgrade of 

24 the NDS beryllium billets would result in forms of beryllium that are compatible with 

25 existing manufacturing processes, as well as the manufacturing processes that might be 

26 available in the foreseeable future. 

27 

28 In addition to the Proposed Action as described in detail in Section 2, other alternatives 

29 and options have been identified: (1) store the upgraded and converted beryllium at some 

30 location other than the Hammond Depot, and (2) delay the upgrade and conversion until 

31 some undetermined time in the future. The following paragraphs discuss each of these 

32 alternatives/options. 

33 

34 Alternative/Option 1: Other depots within the DLA system could be used to store the 

35 upgraded and converted beryllium, but DLA–Strategic Materials has identified the Hammond 

36 Depot as presenting an optimum solution. Because the converted beryllium would be stored 

37 in the same space now occupied by the original beryllium billets that are to be converted, the 

38 Hammond Depot would have adequate space available for the long-term storage of the 

39 converted beryllium. Because workers at the Hammond Depot already have the training and 

40 experience with handling and working around beryllium, the use of the Hammond Depot for 

41 the long-term storage of the converted beryllium would minimize the need for additional 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 12 Strategic Materials

1 worker training. Also, fire protection equipment specific to beryllium (e.g., sodium-chloride 

2 type fire extinguishers) is also already in place at the Hammond Depot and would therefore 

3 not need to be replicated at another depot. In addition, local emergency response personnel 

4 near the Hammond Depot are equipped with, and trained in the use of, self-contained 

5 breathing apparatus that would be used in the event of a fire involving the beryllium at the 

6 depot. This capability would also not need to be reproduced or provided at another depot. 

7 

8 Alternative/Option 2: If the upgrade and conversion of the beryllium billets were to be 

9 delayed (for example, until such time as a different conversion technology became available), 

10 the resulting impacts would be the same as those evaluated for the No-Action alternative. 

11 That is, the beryllium billets would continue to be stored at the Hammond Depot. 

12 

13 There are no practicable alternatives to the Proposed Action that would accomplish the 

14 upgrade, conversion, and long-term storage of the existing NDS beryllium stockpile with less 

15 impact and cost. Accordingly, the Proposed Action is preferred alternative of DLA–Strategic 

16 Materials. 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 13 Strategic Materials

1 4. THE AFFECTED ENVIRONMENT AND CONSEQUENCES 

2 

3 

4 Among the environmental impacts of concern for the upgrade of beryllium billets into more 

5 useable forms of beryllium and the subsequent long-term storage of that material are the 

6 potential human health impacts of exposure to beryllium and the impacts of transporting the 

7 beryllium between the Hammond Depot and the off-site conversion facilities. These two 

8 topics are discussed in Sections 4.1 and 4.2, respectively. The remainder of Section 4 

9 discusses the potential environmental impacts related to land use (Section 4.3), water 

10 resources (Section 4.4), ecological resources (Section 4.5), socioeconomics (Section 4.6), 

11 environmental justice (Section 4.7), cultural resources (Section 4.8), noise (Section 4.9), 

12 aesthetics (Section 4.10), air quality (Section 4.11), and waste management (Section 4.12). 

13 Section 4.13 discusses the cumulative impacts of the Proposed Action. 

14 

15 4.1 HUMAN HEALTH AND SAFETY 

16 

17 4.1.1 Existing Environment 

18 

19 Currently, workers at the Hammond Depot conduct periodic surveillance and maintenance 

20 activities on the beryllium stockpile to ensure that it remains in an acceptable storage 

21 condition. These inspections are conducted at least annually. Because the crates containing 

22 the beryllium billets are not routinely repositioned or handled, the potential for any industrial23 type accidents to adversely impact human health is extremely small. However, the 

24 introduction of other forms of beryllium—especially beryllium powder—into storage at the 

25 Hammond Depot would create new human-health hazards, as discussed in the following 

26 subsection. 

27 

28 4.1.2 Potential Impacts of the Proposed Action 

29 

30 4.1.2.1 Beryllium exposure pathways 

31 

32 Exposure to beryllium may occur through a variety of routes, including breathing air (i.e., 

33 inhalation), eating food or drinking water (i.e., oral), and contact with the skin (i.e., dermal). 

34 The inhalation route is of greatest concern for systemic health effects, because less than 

35 1 percent of beryllium on the skin or in the gastrointestinal tract is absorbed; however, 

36 exposure to skin that is already damaged from scrapes or cuts may result in the absorption of 

37 greater than 1 percent. Dermal exposure may also result in beryllium sensitization which is 

38 an allergic-type response that may subsequently lead to chronic beryllium disease. Oral 

39 exposure may result in gastrointestinal lesions such as necrosis (ATSDR 2002, NRC 2007). 

40 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 14 Strategic Materials

1 The dose received by an individual inhaling beryllium dust or powder would depend on the 

2 exposure concentration, the aerosol particle size distribution, and the breathing pattern. 

3 Aerosol particle size [measured as mass median aerodynamic diameter (MMAD)] is perhaps 

4 the most important parameter when considering adverse health effects, because the 

5 deposition of particles in various portions of the respiratory tract is dependent on particle 

6 size. For example, particles with an MMAD larger than 10 μm may be deposited in the nose 

7 and throat area, but typically would not enter the lower portions of the respiratory tract 

8 because they would be removed from the body via mucocillary clearance. However, particles 

9 smaller than 10 μm may be deposited within the deep lung. Because beryllium powder is 

10 insoluble in water, these small particles may reside in the lungs for years. The upgrade and 

11 conversion of beryllium billets into powdered form is expected to yield an average particle 

12 size of 20 μm or less. Current beryllium machining processes produce fine respirable 

13 particles with more than 50 percent being smaller than 10 μm and more than 30 percent being 

14 smaller than 0.6 μm; the MMAD from various machining processes ranges from 5.0 to 9.5 

15 μm (NRC 2007). Particles less than 0.6 μm are of greatest health concern, because they will 

16 deposit deepest in the lung. Therefore, it is expected that the majority of the beryllium 

17 particles resulting from the proposed upgrade and conversion of billets into powdered form 

18 would be respirable particles that have the potential for being deposited in the lungs. 

19 

20 4.1.2.2 Toxicity of beryllium 

21 

22 Table 2 shows the current standards and guidelines that are designed to protect humans from 

23 exposure to beryllium. It should be noted that OSHA is considering issuing a Notice of 

24 Proposed Rulemaking for changes to the current beryllium standard for general industry 

25 (29 CFR 1910.1000) and for construction (29 CFR 1926.55) (OSHA 2014). 

26 

27 Non-Cancer Dermal-Exposure Effects. Dermal contact with beryllium can result in two 

28 types of dermal effects: an inflammatory reaction and an allergic reaction. Beryllium 

29 exposure may also cause a delayed hypersensitivity (allergic) reaction in the skin, resulting in 

30 granulomas which may be necrotizing and ulcerative (ATSDR 2002). Data show that very 

31 small beryllium particles—with sizes around 0.5 to 1.0 μm—in conjunction with motion, 

32 such as occurs at the wrist, may penetrate the outermost layer of human skin, reaching the 

33 epidermis and occasionally the dermis (Tinkle et al. 2003). Dermal exposure may also be 

34 sufficient to induce the beryllium sensitization necessary for development of chronic 

35 beryllium disease. 

36 

37 Non-Cancer Inhalation-Exposure Effects. The respiratory tract is the primary target 

38 of beryllium toxicity following inhalation exposure. Exposure to high concentrations (i.e., 

greater than 0.5 μg/m3 39 ) of soluble beryllium compounds such as beryllium salts can result in 

40 acute beryllium disease. Chronic beryllium disease can result from exposure to relatively 

low concentrations (0.5 μg/m3 41 ) of soluble or insoluble (such as pure beryllium powder) 

42 beryllium compounds (ATSDR 2002). 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 15 Strategic Materials

1 Table 2. Beryllium standards and guidelines 

Standard/Guideline (Source) Value Health Effect/Target Organ/Basis for Value

WORKPLACE STANDARDS:

Occupational Safety and Health 

Administration (OSHA) Permissible 

Exposure Limit (PEL)

(NIOSH 1999) 

0.002 mg/m3

PEL-TWAa

 

0.005 mg/m3

Ceilingb

0.025 mg/m3

Peakc

 

Chronic beryllium disease (berylliosis); 

Pneumonitis; Beryllium skin granuloma; 

contact dermatitis 

National Institute for Occupational 

Safety and Health (NIOSH) 

Recommended Exposure Limit 

(REL)d

(NIOSH 1999) 

0.0005 mg/m3 

Ceilingb Lung cancer; Kidney stones; enlargement of the liver, spleen, and heart; multiple granulomas of the 

lung, spleen, liver, and lymph nodes; heart failure 

leading to death; tracheobronchitis; pneumonitis;

pulmonary edema leading to death; eye, upper 

respiratory, and skin irritation; contact dermatitis 

American Conference of 

Governmental Industrial Hygienists 

(ACGIH) Threshold Limit Value 

(TLV)

(ACGIH 2013) 

0.00005 mg/m3

TLV-TWAe

 

(inhalable 

particulate matter) 

Skin; SENf

Beryllium sensitization; 

Chronic beryllium disease 

GENERAL POPULATION STANDARDS:

Oral Reference Dose (RfD)g

(EPA 1998) 

0.002 mg/kg/day Intestinal lesions (dog study) 

Inhalation Reference Concentration 

(RfC)h (EPA 1998) 

0.000002 mg/m3

 Beryllium sensitization; 

Chronic beryllium disease 

ENVIRONMENTAL STANDARD: 

Air: National Emission Standard from 

stationary sources 

(40 CFR 61.32)

≤10 g (0.022 lb) 

of beryllium over 

a 24-hour periodi

N/A 

Notes: 

 a PEL-TWA: Highest level of beryllium in air to which a worker may be exposed, averaged over an 8-hour 

workday. 

 b Concentration that should not be exceeded during any part of the working exposure. c 30 minute Peak concentration. d Defined as analogous to the ACGIH-TLV. e The airborne concentration for a conventional 8-hour workday and 40-hour workweek, to which nearly all 

workers may be repeatedly exposed, day after day, over a working lifetime, without adverse health effects. f Danger of cutaneous absorption. Sensitization. g An estimate (with uncertainty spanning perhaps an order of magnitude) of a daily oral exposure to the 

human population (including sensitive subgroups) that is likely to be without an appreciable risk of deleterious 

effects during a lifetime.

 h An estimate (with uncertainty spanning perhaps an order of magnitude) of a daily inhalation exposure of 

the human population (including sensitive subgroups) that is likely to be without an appreciable risk of 

deleterious effects during a lifetime. 

 i Rather than meet the requirement, an owner or operator may request approval from the Administrator 

to meet an ambient concentration limit on beryllium in the vicinity of the stationary source of 0.01 μg/m3

, 

averaged over a 30-day period. 

2 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 16 Strategic Materials

1 Acute Beryllium Disease 

2 

3 Acute beryllium disease is characterized by inflammation of the entire respiratory tract, and 

4 may involve the nose, pharynx, tracheobronchial airways, and alveoli. Symptoms may 

5 include nasopharyngitis, shortness of breath, labored breathing, and chemical pneumonitis 

6 (ATSDR 2002). The effects are usually resolved within several months of exposure, but 

7 acute beryllium disease can progress to chronic beryllium disease if sensitization also occurs. 

8 Acute beryllium disease usually results from exposure to soluble beryllium compounds. 

9 However, because beryllium powder is not soluble, acute beryllium disease is not likely to be 

10 a concern for the upgraded and converted inventory of NDS beryllium. 

11 

12 Chronic Beryllium Disease 

13 

14 Chronic beryllium disease (also called berylliosis or chronic granulomatous disease) is an 

15 immune response to inhaled beryllium deposited in air spaces within the lung; it is observed 

16 only in individuals who are sensitized to beryllium. Chronic beryllium disease can be 

17 classified into three stages: (1) beryllium sensitization; (2) subclinical chronic beryllium 

18 disease; and (3) clinical chronic beryllium disease (ATSDR 2002). Several studies have 

19 attempted to establish associations between beryllium sensitization and/or chronic beryllium 

20 disease and mean, cumulative, and peak exposure levels and duration of exposure and/or 

21 employment. In general, no consistent associations were found; however, repeated exposure 

22 to particles smaller than 1 μm was associated with the prevalence of beryllium sensitization 

23 or chronic beryllium disease (NRC 2007). 

24 

25 Beryllium sensitization occurs in up to 16 percent of exposed workers and may be diagnosed 

26 by a blood test called the beryllium lymphocyte proliferation test (BeLPT); this blood test 

27 can be used for medical surveillance programs. An individual must first be sensitized before 

28 beryllium in the lungs can cause the lung damage (granulomas) associated with chronic 

29 beryllium disease. Beryllium sensitization can progress to chronic beryllium disease, but not 

30 all sensitized individuals develop chronic beryllium disease (ATSDR 2002, NRC 2007). The 

31 proportion of sensitized individuals who will eventually develop chronic beryllium disease is 

32 unknown; however, Newman et al. (2005) estimated that 6 to 8 percent of sensitized 

33 individuals may eventually develop chronic beryllium disease. 

34 

35 Individuals with subclinical chronic beryllium disease are sensitized to beryllium and have 

36 histological evidence of lung granulomas, but no clinical signs. Although no clinical signs 

37 are observed, evidence suggests that there may be some impairment of lung function. Slight 

38 alterations in lung function during exercise were observed in approximately 60 percent of 

39 individuals with subclinical chronic beryllium disease; however, no other consistent 

40 alterations in lung function were found (ATSDR 2002). 

41 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 17 Strategic Materials

1 Individuals with clinical chronic beryllium disease are beryllium sensitized and have 

2 histological evidence of lung granulomas and respiratory symptoms (such as difficulty 

3 breathing, coughing, chest pain, general weakness), changes on chest X-rays, and/or altered 

4 lung function (ATSDR 2002). Other systemic effects that have been observed in individuals 

5 with severe cases of chronic beryllium disease include damage to the right heart ventricle, 

6 liver necrosis, kidney stones, and weight loss; however, these effects are probably secondary 

7 to chronic beryllium disease rather than a direct effect on the tissues. The course of chronic 

8 beryllium disease varies, with some individuals having few or no symptoms for many years 

9 followed by eventual symptom development, including deterioration of health and potentially 

10 death. Possible risk factors for progression from beryllium sensitization to chronic beryllium 

11 disease include smoking status, genetic factors, concurrent exposures, and stressors such as 

12 pregnancy and lactation, combat, and surgery. Almost all patients with chronic beryllium 

13 disease have a positive BeLPT test (NRC 2007). 

14 

15 Non-Cancer Oral-Exposure Effects. Unlike the inhalation exposure route, the primary 

16 effect observed after oral exposure is site-of-contact ulcerative gastrointestinal lesions, rather 

17 than an immune response to beryllium (ATSDR 2002). 

18 

19 Cancer. A number of epidemiology studies have been conducted to assess the carcinogenic 

20 potential of beryllium. Schubauer-Berigan et al. (2011) analyzed cause-specific mortality 

21 data for almost 10,000 workers from seven beryllium processing plants. Workers were 

22 followed for mortality from the years 1940 through 2005. Standardized mortality ratios were 

23 estimated based on U.S. population comparisons for lung, nervous system and urinary tract 

24 cancers, chronic obstructive pulmonary disease (COPD), chronic kidney disease, and 

25 categories containing chronic beryllium disease and cor pulmonale (failure of the right side 

26 of the heart). Associations with maximum and cumulative exposure were calculated. 

27 Overall mortality in the workers, compared with the U.S. population as a whole, was 

28 increased for lung cancer, COPD, and the categories containing chronic beryllium disease 

29 and cor pulmonale. Mortality rates for most diseases of interest increased with time-since30 hire. For the category including chronic beryllium disease, rates were significantly increased 

31 compared to the U.S. population. Workers whose maximum beryllium exposure was greater 

than or equal to 10 mg/m3 32 had higher rates of lung cancer, urinary tract cancer, COPD and 

33 the category containing cor pulmonale than workers with lower exposure. Significant 

34 positive trends with cumulative exposure were observed for nervous system cancers and—

35 when short-term workers were excluded—lung cancer, urinary tract cancer, and COPD. 

36 This study reaffirms that lung cancer and chronic beryllium disease may be related to 

37 beryllium exposure, and it suggests that COPD and nervous system and urinary tract cancers 

38 may also be related to beryllium exposure. The authors of the study concluded that cigarette 

39 smoking and exposure to other lung carcinogens are unlikely to explain these increases. 

40 

41 Studies such as the one described in the preceding paragraph are used as the basis of cancer 

42 classification by organizations such as the National Toxicology Program (NTP), International 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 18 Strategic Materials

1 Agency for Research on Cancer (IARC), American Conference of Governmental and 

2 Industrial Hygienists (ACGIH), and the U.S. Environmental Protection Agency (EPA). 

3 

4 The NTP classifies beryllium in Group 1, a known human carcinogen (NTP 2011). 

5 Based on sufficient evidence for carcinogenicity in humans and animals, the IARC has 

6 classified beryllium in Group 1, carcinogenic to humans (IARC 2010). Based on the 

7 weight-of-evidence from human epidemiological studies, the ACGIH classifies beryllium 

8 in Group A1, a confirmed human carcinogen (ACGIH 2013). The U.S. EPA classifies 

9 beryllium in Group B1, a probable human carcinogen. This classification is based on the 

10 limited evidence of carcinogenicity in humans exposed to airborne beryllium (lung cancer) 

11 and sufficient evidence of carcinogenicity in animals (lung cancer in rats and monkeys 

12 inhaling beryllium, lung tumors in rats exposed to beryllium via intratracheal instillation, and 

13 osteosarcomas in rabbits and possibly mice receiving intravenous or intramedullary injection) 

14 (EPA 1998). 

15 

16 Other Effects. The available data on the potential of beryllium to induce reproductive 

17 and/or developmental effects are inconclusive. In animal studies, reproductive and 

18 developmental effects, as well as other extra-pulmonary effects, have generally been 

19 observed only at doses higher than the lowest doses that induce chronic beryllium disease or 

20 cancer (NRC 2007). 

21 

22 4.1.2.3 Measures to prevent exposure and adverse health effects 

23 

24 Minimizing the Health Risks to Workers. Beryllium sensitization, chronic beryllium 

25 disease, and lung cancer are the principal health concerns related to beryllium exposure. 

26 Because of a lack of quantitative risk information on low exposure and uncertainties 

27 associated with factors that contribute to the development of chronic beryllium disease, it is 

28 difficult to identify a chronic inhalation exposure level that is unlikely to lead to beryllium 

29 sensitization or chronic beryllium disease. Therefore, managing exposure may be appropriate 

30 to minimize health risks. 

31 

32 The National Research Council has recommended measures that should be taken to prevent 

33 skin and respiratory exposure to beryllium to the greatest extent possible (NRC 2008). These 

34 measures—as applicable to the Proposed Action contemplated in this EA—include the 

35 following: 

36 

37 • Know the beryllium content of all materials in the workplace; 

38 • Keep airborne concentrations of beryllium as low as possible; 

39 • Minimize the number of workers exposed to beryllium dusts, fumes, and contaminated 

40 surfaces; 

41 • Install, use, and maintain effective engineering controls for processes that create 

42 beryllium dusts and fumes; 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 19 Strategic Materials

1 • Monitor airborne beryllium concentrations to document the effectiveness of efforts to 

2 reduce airborne exposure; 

3 • Inform workers about the risks of beryllium sensitization, chronic beryllium disease, and 

4 lung cancer and the proper procedures for working with beryllium; 

5 • Keep beryllium dusts and fumes confined to the immediate work area; 

6 • Avoid the use of cleaning methods that may cause dust to become resuspended in air (for 

7 example, dry sweeping, use of compressed air, and other dust-generating methods); 

8 • Prevent beryllium dusts and other contamination from leaving beryllium work areas on 

9 equipment or workers’ skin, clothing, shoes, and tools; 

10 • Establish and maintain an appropriate respiratory-protection program; and 

11 • Establish and maintain a skin-protection program to protect workers’ skin from 

12 contamination with beryllium dusts and solutions by keeping work surfaces and work 

13 areas clean; providing work gloves, long-sleeved shirts, long pants, and shoes that remain 

14 at the workplace; and providing showering and changing facilities. 

15 

16 In addition to the project-specific health and safety measures included in the Proposed 

17 Action, compliance with all OSHA regulations for the type of work associated with the 

18 beryllium stockpile will be required. All workers would be trained in the potential hazards 

19 associated with the Proposed Action. Additionally, each worker would be issued and 

20 required to wear personal protective equipment appropriate to the hazards that may be 

21 encountered during the Proposed Action. Some of the potential hazards to workers 

22 associated with the Proposed Action are listed in Section 2.0. Required training for workers 

23 would minimize the potential risks to workers, and that training includes the general 

24 categories listed in Section 2.0. 

25 

26 The potential beryllium hazards listed above would pose risks to on-site workers at the 

27 Hammond Depot, including those workers involved in moving the upgraded and converted 

28 beryllium from the receiving area and placing it back into storage, as well as those workers 

29 involved in subsequent inspections of the beryllium stockpile while it is in long-term storage. 

30 Periodic examinations of these depot workers via BeLPT blood testing would provide early 

31 indication of any sensitization to beryllium that the worker might be developing. If a positive 

32 BeLPT test result is obtained, an alternate work assignment would be identified for this 

33 worker in order to eliminate any subsequent exposure to beryllium. 

34 

35 To ensure the potential hazards of beryllium are adequately addressed, the contractor(s) 

36 performing work at the Hammond Depot—including the transportation of the beryllium to 

37 and from the off-site beryllium conversion facilities—would be required to have health and 

38 safety plans for addressing these potential hazards. The aforementioned beryllium hazards 

39 would also pose risks to the workers at the off-site facilities where the beryllium upgrade and 

40 conversion activities would occur. However, the off-site facilities would be expected to have 

41 previous expertise in beryllium processing and already have health and safety plans in place 

42 to protect those workers. Therefore, the introduction of the NDS beryllium from the 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 20 Strategic Materials

1 Hammond Depot into the off-site upgrade and conversion facilities would not be creating any 

2 additional hazards that do not already exist in those places. 

3 

4 As discussed in the above paragraphs, it should be possible to avoid serious human health 

5 impacts among workers due to the Proposed Action. 

6 

7 Preventing Impacts to Members of the Public. Members of the public would not 

8 be exposed to beryllium as a result of normal operations during the implementation of the 

9 Proposed Action or during the long-term storage of beryllium at the Hammond Depot. 

10 However, as described in the following paragraphs, in the event of a fire or an accident inside 

11 the storage structure at the Hammond Depot, beryllium might be released into the 

12 environment, thereby potentially subjecting nearby members of the public to beryllium 

13 exposure. 

14 

15 While a fire in the storage structure would not be expected to result in the release of 

16 beryllium from the stored billets, a fire could result in the airborne suspension and downwind 

17 distribution of any converted beryllium—such as beryllium powder—that was released from 

18 its storage container. However, the release of converted beryllium from the storage drums 

19 would not be a likely consequence of a fire inside the storage structure, since the drums and 

20 pallets of converted beryllium would be stored inside a protective metal storage enclosure 

21 with a 4-hr fire rating. That is, a fire would be unlikely to cause a rupture of the converted22 beryllium storage containers. Therefore, the release of converted beryllium from the storage 

23 drums and a fire inside the storage structure would have to occur as separate, but highly 

24 unlikely, events before the beryllium presented any hazard to the nearby population. 

25 

26 DLA–Strategic Materials has conducted an assessment of the potential human health 

27 consequences of an accident involving a fire and the converted beryllium. The results of the 

28 accident analysis indicate that potentially adverse human health effects could occur as a result 

29 of exposure to accidentally released beryllium; however, such an accident would be highly 

30 unlikely to occur and its effects could be mitigated by the actions described in the following 

31 paragraph. 

32 

33 Fire extinguishing equipment (including sodium-chloride type fire extinguishers and 

34 personnel protective equipment) specific to potential fires involving beryllium are available 

35 at the Hammond Depot for use in suppressing any fires that might occur inside the beryllium 

36 storage structure. In addition, local emergency response personnel near the Hammond Depot 

37 are equipped with, and trained in the use of, self-contained breathing apparatus that would be 

38 used in the event of a fire involving the beryllium at the depot. The use of such equipment 

39 would be expected to rapidly extinguish any fire and reduce or eliminate any potential for 

40 off-site human health consequences. 

41 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 21 Strategic Materials

1 In the absence of a fire, the off-site release of a significant quantity of beryllium due to a spill 

2 or the rupture of a storage container would be extremely unlikely due to the lack of a physical 

3 mechanism to get the beryllium airborne. In addition, due to the absence of explosive 

4 materials near the converted beryllium storage containers, the release of beryllium by 

5 explosive mechanisms is also extremely unlikely; hence, these scenarios are not analyzed 

6 further in this EA. 

7 

8 The consequences of a possible accidental release of beryllium powder are described in 

9 Section 4.2.2.2. As discussed in the above paragraphs and in Section 4.2.2.2, no adverse 

10 human health impacts among members of the public would be expected during to the 

11 Proposed Action. 

12 

13 4.1.3 Potential Impacts of the No-Action Alternative 

14 

15 Under the No-Action alternative, workers at the Hammond Depot would continue to conduct 

16 periodic surveillance and maintenance activities for the existing inventory of beryllium 

17 billets. Due to the packaging and the physical state of this beryllium, exposure to beryllium 

18 would not be likely to occur during such activities. Hence, impacts to human health would 

19 be unlikely to occur during the No-Action alternative. 

20 

21 

22 4.2 TRANSPORTATION 

23 

24 4.2.1 Existing Environment 

25 

26 As discussed in Section 1.2, the Hammond Depot is served by roads that provide ready 

27 access to the interstate highway system. The roads immediately surrounding the depot are in 

28 general good condition and are adequately maintained, as is the interstate system of 

29 highways. Normal highway traffic volumes in the vicinity are many times greater than the 

30 volume of traffic entering and exiting the depot. 

31 

32 4.2.2 Accident Analysis 

33 

34 For the Proposed Action, accidents during off-site transportation would produce a potential 

35 source of adverse impacts. The analysis in this section addresses only potential impacts to 

36 individuals because all credible accidents are sufficiently small that they would not produce 

37 large or permanent impacts on a greater scale in the human environment. Because the 

38 anticipated method of transportation between the Hammond Depot and the off-site beryllium 

39 conversion facility is by truck, the analysis is this section focuses on highway accidents. 

40 

41 
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Defense Logistics Agency 22 Strategic Materials

1 4.2.2.1 The risk of a transportation accident 

2 

3 The U.S. Department of Transportation (DOT) has established regulations at 

4 49 CFR Part 177 regarding the transportation of hazardous materials on public highways. 

5 These regulations include provisions that provide an appropriate level of safety and that 

6 protect the public during such transportation activities. While the DOT regulations do not 

7 require that a transportation risk assessment be conducted for the shipment of hazardous 

8 materials, transportation risk assessments are sometimes prepared to identify and assess the 

9 potential risks to members of the public due to accidents during such shipments. 

10 

11 This subsection provides a numerical calculation of risk based on the most recent 

12 information available about national accident statistics for the types of large trucks that 

13 would be used to transport the NDS beryllium. The calculations in this subsection focus on 

14 an analysis of transportation risk using truck crash statistics based upon the number of miles 

15 traveled. Therefore, the number of potential accidents during the off-site transport of the 

16 NDS beryllium was evaluated against statistics available from the DOT in regard to the 

17 transportation of hazardous materials. As described below, hazardous materials transporters 

18 have a better-than-average safety record. 

19 

20 Crash statistics for large trucks are maintained in the DOT’s Fatality Analysis and Reporting 

21 System (FARS). This system compiles all types of data from accidents as collected from 

22 police reports. The latest version of the FARS report for large trucks (FMCSA 2014a) was 

23 used as the basis for the accident analysis presented in this subsection. Large trucks are 

24 defined as trucks with a gross vehicle weight more than 10,000 pounds. The types of 

25 vehicles to be used in the transportation of the NDS beryllium fall into this category. 

26 

27 The following data are given in the FARS trends report for large-truck crashes that occurred 

28 in 2012, the latest year for which such data are available (FMCSA 2014a, 2014b): 

29 

30 • In 2012, large trucks accounted for 9 percent of all vehicle miles traveled and 4 percent 

31 of all registered vehicles in the United States. 

32 • Of the approximately 317,000 police-reported crashes involving large trucks in 2012, 

33 only 1 percent (3,464) resulted in fatalities, and 23 percent (73,000) resulted in non-fatal 

34 injuries. 

35 • Almost two-thirds (63 percent) of all fatal crashes involving large trucks occurred on 

36 rural roads. 

37 • Of the 33,077 people killed in motor vehicle crashes in the United States in 2012, 

38 12 percent (3,921) died in crashes involving a large truck. 

39 • Only 4 percent of the large trucks involved in fatal crashes—and 2 percent of the large 

40 trucks involved in non-fatal crashes—were carrying hazardous materials. 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 23 Strategic Materials

1 • Approximately 0.6 percent of the large trucks involved in fatal crashes—and 0.3 percent 

2 of the large trucks involved in non-fatal crashes—released hazardous material from the 

3 cargo compartment during those events. 

4 • Rollover was the first harmful event (the first event during a crash that caused injury or 

5 property damage) in only 5 percent of all fatal crashes involving large trucks and in only 

6 3 percent of all non-fatal crashes involving large trucks. 

7 

8 The sets of FARS data from the ten-year period 2003 to 2012 are summarized in Table 3. 

9 These data show the number of accidents involving large trucks, as well as the consequences 

10 of those accidents (as measured by three categories: fatalities, injuries, and property-damage11 only). The data on the numbers of accidents in Table 3 have been expressed on a “per 

12 vehicle mile traveled (VMT)” basis so that the resulting rates can be applied to the potential 

13 distances to be traveled by the beryllium shipments. 

14 

15 Under the Proposed Action, up to 20 tons (18,140 kg) of beryllium billets would be 

16 upgraded and converted into other, more useable forms. However, for the purpose of 

17 conservatively analyzing hypothetical transportation accidents in this EA, it is assumed that 

18 85 tons (77,100 kg) of NDS inventory beryllium billets would be transported to an off-site 

19 conversion facility. Furthermore, it is assumed that the distance from the Hammond Depot to 

20 the hypothetical off-site conversion facility is 1000 miles (1600 km), even though the 

21 probable facilities are much closer. These assumptions regarding quantities and distances 

22 would result in an overestimation of any resulting transportation impacts and would thus 

23 bound the magnitude and extent of any such impacts associated with the Proposed Action. 

24 

25 Because the typical weight of each beryllium billet is just over 1 ton (910 kg), the maximum 

26 number of trips required to move the NDS beryllium inventory from the Hammond Depot to 

27 the hypothetical beryllium conversion facility would be about 85 trips. For the assumed one28 way transportation distance of 1000 miles (1600 km), the total amount of round-trip 

29 transportation by truck for the duration of the Proposed Action would not exceed 

30 170,000 vehicle miles (273,500 km). 

31 

32 Table 4 shows the results of the statistical accident calculations for the Proposed Action, 

33 based upon the accident rates for year 2012 as shown in Table 3. For the assumed 

34 170,000 vehicle miles (273,500 km) associated with the Proposed Action, Table 4 shows 

35 that the number of statistically anticipated accidents of all types would be very small 

36 (i.e., 0.20) during the shipment of the beryllium from the Hammond Depot to the 

37 hypothetical beryllium conversion facility and back again. Statistically, less than one of 

38 these accidents (i.e., 0.05) would be expected to result in injuries, and also far less than one 

39 of these accidents (i.e., 0.002) would be expected to result in fatalities. 

40 
Defense Logistics Agency 

24 Strategic Materials 

Table 3. Accident statistics for crashes over the past ten years that have involved la

 Part A. Large truck crashes of all types and crashes with only property damage

Year

Vehicle miles traveled 

(VMT), in millions

All types of accidents Accidents with proper

Number 

of crashes

Accident rate 

(crashes/VMT)

Number 

of crashes

2003 217,876 436,000 2.0 × 10-6 347,000 2004 220,811 399,000 1.8 × 10-6 312,000 

2005 222,523 424,000 1.9 × 10-6 341,000 2006 222,513 368,000 1.6 × 10-6 287,000 2007 304,178 393,000 1.3 × 10-6 317,000 2008 310,680 365,000 1.2 × 10-6 297,000 2009 288,306 286,000 9.9 × 10-7 232,000 2010 286,527 266,000 9.3 × 10-7 207,000 2011 267,594 273,000 1.0 × 10-6 210,000 2012 268,318 317,000 1.2 × 10-6 241,000 

Note: A large truck is one with a gross vehicle weight over 10,000 pounds. Source: Data taken from Tables 4, 7 and 10 in Federal Motor Carrier Safety Administration (FMCSA), Large Truck and Bus Crash Facts 

FMCSA-RRA-14-004, Analysis Division, FMCSA, U.S. Department of Transportation, Washington, D.C., June 2014; Available on-line at http://ntl.bts.gov/lib/35000/35500/35578/LTCF2012-1.pdf 
Defense Logistics Agency 

25 Strategic Materials 

Table 3. (continued)

 Part B. Large truck crashes with fatalities or injuries 

Year

Vehicle miles 

traveled 

(VMT), in 

millions

Fatal crashes Crashes with in

Number 

of fatal 

crashes

Accident 

rate (fatal 

crashes/ 

VMT)

Number 

of 

fatalities

Fatality 

rate 

(fatalities/ 

VMT)

Number 

of 

crashes 

with 

injuries

Accident 

rate 

(injurious 

crashes/ 

VMT)

Num

of in

2003 217,876 4,335 2.0 × 10-8 5,036 2.3 × 10-8 85,000 3.9 × 10-7 1222004 220,811 4,478 2.0 × 10-8 5,235 2.4 × 10-8 83,000 3.8 × 10-7 116

2005 222,523 4,551 2.1 × 10-8 5,240 2.4 × 10-8 78,000 3.5 × 10-7 1142006 222,513 4,350 2.0 × 10-8 5,027 2.3 × 10-8 77,000 3.4 × 10-7 1062007 304,178 4,204 1.4 × 10-8 4,822 1.6 × 10-8 72,000 2.4 × 10-7 1012008 310,680 3,754 1.2 × 10-8 4,245 1.4 × 10-8 64,000 2.1 × 10-7 902009 288,306 2,983 1.0 × 10-8 3,380 1.2 × 10-8 51,000 1.8 × 10-7 742010 286,527 3,271 1.1 × 10-8 3,686 1.3 × 10-8 56,000 2.0 × 10-7 802011 267,594 3,365 1.3 × 10-8 3,781 1.4 × 10-8 60,000 2.3 × 10-7 882012 268,318 3,464 1.4 × 10-8 3.921 1.5 × 10-8 73,000 2.7 × 10-7 104

Note: A large truck is one with a gross vehicle weight over 10,000 pounds. Source: Data taken from Tables 4 and 7 in Federal Motor Carrier Safety Administration (FMCSA), Large Truck and Bus Crash Facts 2012, 

FMCSA-RRA-14-004, Analysis Division, FMCSA, U.S. Department of Transportation, Washington, D.C., June 2014; Available on-line at http://ntl.bts.gov/lib/35000/35500/35578/LTCF2012-1.pdf 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 26 Strategic Materials

1 Table 4. Statistically anticipated accidents during proposed 

2 beryllium shipments and their consequences 

Number 

of 

one-way 

trips

Assumed 

one-way 

distance 

(miles)

Predicted numbers of accidents Accident consequences

Total 

accidents 

of all 

types

Accidents 

with 

property 

damage 

only 

Accidents 

with 

injuries

Accidents 

with 

fatalities

Expected 

number of 

injuries

Expected 

number of 

fatalities

85 1000 0.20 0.15 0.05 0.002 0.07 0.003 

Note: The accident rates used for the calculations in the above table were taken from the data for 2012 as 

shown in Table 3. The calculations in the above table account for the round-trip distance. 

3 

4 

5 The FARS statistics, as used in this analysis, indicate that no significant number of 

6 transport-vehicle accidents would be expected to occur during the off-post shipment of 

7 beryllium billets and the return shipments of upgraded and converted beryllium. 

8 

9 4.2.2.2 The consequences of a transportation accident 

10 

11 Injuries and Fatalities from Accidents. In addition to data on the frequency of crashes 

12 involving large trucks, Table 3 also presents the data for the consequences of those accidents 

13 (as measured by the categories: injuries, fatalities, and property-damage-only). These data 

14 (as expressed on a “per VMT” basis) have been applied to the transportation distances to be 

15 traveled by the hypothetical beryllium shipments. Table 4 shows the results of the accident 

16 consequence calculations based upon the injury and fatality rates for the year 2012 (as shown 

17 in Table 3). For the assumed round-trip transportation distance to be traveled by the 

18 beryllium shipments, Table 4 shows that the number of statistically anticipated injuries 

19 would be far less than one (i.e., 0.07) during the beryllium shipments. The total number of 

20 fatalities expected from accidents involving the beryllium shipments would also be 

21 statistically much, much less than one (i.e., 0.003). 

22 

23 The FARS statistics, as used in this analysis, indicate that no significant number of injuries or 

24 fatalities would be expected to occur during the off-site shipment of beryllium billets and the 

25 return shipments of upgraded and converted beryllium. 

26 

27 Impacts from Accidental Spills or Releases. The impacts of greatest concern during the 

28 return shipments of upgraded and converted beryllium from the off-site conversion facility 

29 back to the Hammond Depot would be associated with accidental spills or releases of 

30 beryllium, particularly beryllium in the form of fine powder. In the unlikely event of such an 

31 accident, beryllium powder could be released from its shipping container and escape into the 

32 environment. As discussed below, any such releases would be expected to be contained 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 27 Strategic Materials

1 within a highly localized area in the immediate vicinity of the accident, and no significant 

2 adverse impacts would be expected to human health, soils, surface water, or groundwater 

3 along the transportation corridor. 

4 

5 Because beryllium is heavier than water and because beryllium is not soluble in water (see 

6 the physical characteristics in Table 1), any accidentally spilled beryllium powder that is 

7 introduced into surface water would settle onto the bottom as sediment. Due to its small 

8 particle size, some of the beryllium powder could be swept away in rapidly moving surface 

9 water; however, the mixing and dispersion motion within such surface waters would be 

10 expected to result in very low concentrations of beryllium within such waters. If such water 

11 were to be subsequently ingested by humans, any resulting health effects would be of much 

12 less concern than the exposure to beryllium through the inhalation pathway (see 

13 Sections 4.1.2.1 and 4.1.2.2). 

14 

15 Because a major portion of any beryllium spilled onto soil would not dissolve in water and 

16 would remain bound to the soil, it is not likely to move deeper into the ground and enter 

17 groundwater (ATSDR 2002). Cleanup of beryllium spilled onto soils and other surfaces 

18 would thus be relatively straightforward because of the localization and adsorption that 

19 would occur. While beryllium does exhibit toxicity, as described in Section 4.1.2.2, any 

20 beryllium powder accidentally spilled would not be expected to become the source of any 

21 significant airborne hazard unless the accident involved a fire or unless high winds existed at 

22 the time of the accident. Either of these two situations could possibly result in the airborne 

23 suspension of fine beryllium particles and the distribution of these particles to locations 

24 beyond the immediate vicinity of the accident. The potential impacts to human health from 

25 such wind-transported particles would depend on a variety of factors, including wind 

26 direction, the population in the area, and the specific distribution of beryllium particle sizes 

27 resulting from the processing at the off-site conversion facility. Any such exposure to 

28 airborne beryllium would be of short duration and would occur only in the unlikely event of 

29 an accident. 

30 

31 The potential for environmental impacts from accidental releases or spills of beryllium 

32 powder would therefore primarily be limited to localized contamination of surface soils 

33 and/or nearby surface waters or groundwater and also to the possibility of human exposure 

34 from wind-borne beryllium particles resulting from the accident. Appropriate emergency 

35 response actions, as described in the following paragraphs, would be expected to eliminate or 

36 greatly reduce the impacts of any such accidental releases or spills. In addition, emergency 

37 response measures, such as instructing the nearby public to shelter in place, would greatly 

38 reduce the potential for any adverse health effects from wind-borne beryllium. 

39 

40 The containers and vehicles used for the beryllium shipments would be appropriately 

41 placarded and labeled. Furthermore, each shipment would be accompanied by either a 

42 hazardous materials manifest or bill of lading. All shipping papers would conform to 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 28 Strategic Materials

1 applicable federal, state, and local regulations in order to provide first responders with the 

2 necessary information in the event of an accidental spill or release. In such instances, 

3 emergency responders are trained to establish isolation and protective action distances for 

4 accidents involving hazardous material and to take appropriate actions to limit the impact of 

5 such accidents. 

6 

7 Under the provisions of DOT regulations at 49 CFR Part 172, licensed carriers and shippers 

8 are required to provide information to emergency responders about the hazardous nature of 

9 their shipments. Specifically, Subpart G of these regulations relates to “Emergency 

10 Response Information” that is to be carried by each transporter, and Subpart H relates to 

11 “Training” for hazardous materials transport personnel. 

12 

13 Spills involving more than 10 pounds (4.5 kg) of beryllium powder with a diameter less than 

14 100 μm are required to be reported under the Comprehensive Environmental Response, 

15 Compensation, and Liability Act (CERCLA) (40 CFR 302.4). Notification of such spills 

16 must be made to the National Response Center, as well as to the Local Emergency Planning 

17 Committee and the State Emergency Response Commission. 

18 

19 4.2.3 Potential Impacts of the Proposed Action 

20 

21 Because of the low number of off-post shipments of beryllium (i.e., a total of not more than 

22 85 shipments) that would be spread over the 5-year conversion portion of the Proposed 

23 Action, there would be no significant impacts to local traffic. 

24 

25 The risk of transportation accidents during the off-post shipment of the beryllium billets 

26 from the Hammond Depot and the return shipments of upgraded and converted beryllium 

27 back to the depot has been evaluated and has been found not to be significant; that is, the risk 

28 of such accidents is statistically very, very small (see Section 4.2.2.1). Furthermore, the 

29 consequences of any such transportation accidents have also been statistically evaluated and 

30 found not to be significant (see Section 4.2.2.2). Because (1) nationwide, there are millions 

31 of highway shipments of hazardous materials each year, for which the states already provide 

32 capable emergency response, and (2) some of these shipments involve chemicals (such as 

33 toxic sulfuric acid or flammable gasoline) that present far greater hazards than the beryllium 

34 to be shipped from the Hammond Depot, it is concluded that the intent of DLA–Strategic 

35 Materials to ship beryllium (either in billet form or in other forms, including fine powder) 

36 does not pose any unique safety concerns or unacceptable environmental impacts relative to 

37 those associated with routine commercial and trade industry hazardous waste shipments. 

38 

39 Based on the transportation analyses conducted in this EA, no significant number of 

40 accidents would be expected to occur during the off-site shipment of beryllium, nor would 

41 any significant adverse consequences be expected if such accidents were to actually occur. 

42 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 29 Strategic Materials

1 4.2.4 Potential Impacts of the No-Action Alternative 

2 

3 Operations at the Hammond Depot would continue at approximately the current levels of 

4 traffic. Because these current levels do not create any significant impacts to traffic on the 

5 local roads, no significant impacts to traffic would occur near the depot as a result of the No6 Action alternative. 

7 

8 

9 4.3 LAND USE 

10 

11 4.3.1 Existing Environment 

12 

13 As discussed in Section 1.2, the 60-acre (24-ha) Hammond Depot is situated in a previously 

14 disturbed industrial setting and is located on a previously disturbed site. As seen in Fig. 1, 

15 development and/or disturbed areas exist on all sides of the depot that do not border bodies of 

16 water. 

17 

18 The soil resources at the depot are characterized as being in an “urban land use” class 

19 (Cash 1998). According to the Remedial Investigation conducted at the Hammond Depot 

20 in 2011 (PARS Environmental 2011), the depot is underlain by approximately 7 to 10 ft 

21 (2 to 3 m) of fill. The top 0.5 to 2 ft (15 to 60 cm) of this fill consists of varying amounts of 

22 poorly sorted sand, silt, and gravel with a trace of cinders and ash. Underlying the granular 

23 fill across the majority of the site is slag. Underlying the slag is native fine sand with some 

24 organic material and trace shell fragments. 

25 

26 The majority of the soil samples collected at the depot for the 2011 Remedial Investigation 

27 had concentrations below the applicable Indiana Department of Environmental Management 

28 (IDEM) default Risk Integrated System of Closure (RISC) soil levels for industrial 

29 properties. The IDEM RISC soil-migration-to-groundwater-exposure-route closure level was 

30 exceeded in several arsenic and lead samples and in two thallium samples. However, 

31 Synthetic Precipitation Leaching Procedure (SPLP) and groundwater sample results indicated 

32 that this exposure route is not currently and is not expected to be a concern at the site in the 

33 future (PARS Environmental 2011). 

34 

35 Four relatively isolated areas at the depot were identified as having concentrations of arsenic 

36 or lead above applicable IDEM RISC industrial direct-contact levels. Based on the sample 

results, these areas cover a total of approximately 30,000 ft2 (2790 m2 37 ). Assuming a 

38 thickness of 1 ft (0.3 m), the volume of soil with a concentration above a default directcontact standard is approximately 1,100 yd3

 (840 m3 39 ). Toxicity Characteristic Leaching 

40 Procedure (TCLP) results for applicable metals confirm that any potentially excavated soil 

41 would not be classified as hazardous waste (PARS Environmental 2011). 
Environmental Assessment Upgrade and Storage of Beryllium

Defense Logistics Agency 30 Strategic Materials

1 4.3.2 Potential Impacts of the Proposed Action 

2 

3 There would be no impacts to future land use because no new structures, roads, or shipping 

4 facilities would be constructed at the Hammond Depot as part of the Proposed Action. There 

5 would be no disturbance of lands that have not already been disturbed from previous 

6 activities. Hence, the Proposed Action would be expected to have no significant adverse 

7 impacts to land use at the Hammond Depot or in the surrounding area. Likewise, there would 

8 be no effects on land use either along the transportation corridors or at the existing off-site 

9 beryllium conversion facilities. 

10 

11 4.3.3 Potential Impacts of the No-Action Alternative 

12 

13 The continued, long-term storage of the beryllium billets at the Hammond Depot would not 

14 result in any changes to existing land uses at the depot; hence, there would be no land-use 

15 impacts associated with the No-Action alternative. 

16 

17 

18 4.4 WATER RESOURCES 

19 

20 4.4.1 Existing Environment 

21 

22 The Hammond Depot borders Wolf Lake (see Fig. 1), and Lake Michigan lies about 

23 2.5 miles (4.0 km) north of the depot. The water flow within Wolf Lake empties into Lake 

24 Michigan. A large, man-made tributary borders the southeast portion of the Hammond 

25 Depot, and it empties into Wolf Lake. This man-made tributary was designed to prevent 

26 lakes and city ditches in the area from flooding (Cash 1998). Stormwater from stormwater 

27 outfalls at the depot also empty into this unnamed tributary. Current activities at the 

28 Hammond Depot do not adversely impact any of the aforementioned bodies of water. 

29 

30 Regional shallow groundwater around the Hammond Depot flows north-northeast, toward 

31 Lake Michigan. However, groundwater beneath Hammond Depot may flow toward and 

32 discharge into Wolf Lake, which lies adjacent to the west side of the depot (Parsons 2001). 

33 

34 Federal storm water regulations were first issued in 1990 by the EPA via the implementation 

35 of permits under the National Pollutant Discharge Elimination System (NPDES) and the 

36 State Pollutant Discharge Elimination System (SPDES) to address storm water runoff and the 

37 prevention of pollution therefrom. A SPDES permit has not been issued to the Hammond 

38 Depot, because State of Indiana regulations exempt the depot from coverage. Nevertheless, 

39 in accordance with DLA policy, a Storm Water Pollution Prevention Plan (SWPPP) has been 

40 developed for the Hammond Depot (AEDL 2013). 

41 
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Defense Logistics Agency 31 Strategic Materials

1 4.4.2 Potential Impacts of the Proposed Action 

2 

3 There are no wet processes associated with the Proposed Action at the Hammond Depot, nor 

4 would the proposed activities at the depot consume water (beyond what would be required by 

5 personnel for drinking and sanitation purposes). Potable water is provided to the depot by the 

6 City of Hammond and is withdrawn from Lake Michigan. However, due to the extremely 

7 small number of workers, the quantity of potable water consumed by depot personnel and 

8 workers during the Proposed Action would not be significant in relation to the available 

9 supply. 

10 

11 The depot is connected to the City of Hammond sanitary sewer system. Worker sanitary 

12 wastes would be collected in this system; however, due to the extremely small number of 

13 workers, the impacts from this small volume of liquid waste would not be significant. 

14 Therefore, the Proposed Action would have insignificant, short-term impacts on water 

15 resources at the Hammond Depot. 

16 

17 Actions to be taken in case of a spill or leak at the Hammond Depot are described in the 

18 depot’s SWPPP (AEDL 2013). Beryllium is a solid as opposed to a liquid or gas; hence, if 

19 an accidental spill of beryllium were to occur during drum handling at the depot, the spill 

20 could be contained and cleaned up quickly. 

21 

22 Wolf Lake is over 800 ft (240 m) from the location where the beryllium is stored, as well as 

23 from where the activities associated with the Proposed Action would be conducted. The 

24 distance and the relatively flat terrain would limit the potential for spilled material to reach 

25 surface water; hence, no impacts to nearby bodies of water would be expected to occur as a 

26 result of any spills. A major portion of any beryllium spilled onto soil would not dissolve in 

27 water and would remain bound to the soil, so it is not likely to move deeper into the ground 

28 and enter groundwater (ATSDR 2002). Cleanup of spills onto soils and other surfaces would 

29 thus be relatively straightforward because of the localization and adsorption that would occur. 

30 Similarly, any spills of fuels or oils from materials handling equipment or transport vehicles 

31 would be contained and cleaned up quickly. Consequently, no significant adverse impacts to 

32 surface water or groundwater resources at the Hammond Depots would be expected from 

33 potential spills during the Proposed Action. 

34 

35 The impacts upon water resources due to potential spills of beryllium as a result of a vehicle 

36 accident along the transportation route are discussed in Section 4.2.2.2. No significant 

37 adverse impacts to water resources would be expected from such spills. 

38 
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Defense Logistics Agency 32 Strategic Materials

1 4.4.3 Potential Impacts of the No-Action Alternative 

2 

3 The water resources at the Hammond Depot would not be affected by the continued storage 

4 of the beryllium billets at the depot; hence, there would be no impacts to water resources as a 

5 result of the No-Action alternative. 

6 

7 

8 4.5 ECOLOGICAL RESOURCES 

9 

10 4.5.1 Existing Environment 

11 

12 The area of the Hammond Depot was a wetland in the mid-1940s which has since been filled 

13 with a substantial amount of blast-furnace slag to give the site a stable and level foundation 

14 (Cash 1998). Wolf Lake borders the depot on the west, and industrial properties border the 

15 remainder. Wolf Lake serves as habitat for many aquatic species. While the western bank of 

16 Wolf Lake has a riparian buffer of mature hardwoods that serves as habitat for woodland 

17 species, the eastern bank (near the Hammond Depot) has meager amounts of vegetation, 

18 including grasses and weeds, as well as uneven bank edges that indicate some erosion is 

19 occurring. An unidentified bamboo species is dense along the southeast perimeter of the 

20 depot; the remainder of the area has been disturbed for industrial purposes, and plant 

21 communities are scarce in this area. No wetlands or other habitats suitable to support typical 

22 wildlife species are present at or immediately adjacent to the depot, despite the incidental use 

23 of the depot property by some wildlife (Cash 1998). 

24 

25 The Indiana Department of Natural Resources (IDNR) has identified almost 400 plant and 

26 animal species that either occur in Lake County or have the potential to occur in the county 

27 and that are listed by the State of Indiana as being endangered, threatened, rare, species of 

28 special concern, or state-significant (IDNR 2013). Of these species, only eight are federally 

29 listed. Four of these eight species are listed as endangered [the sheepnose mussel 

30 (Plethobasus cyphyus), the American burying beetle (Nicrophorus americanus), the Karner 

31 blue butterfly (Lycaeides melissa samuelis), and the piping plover (Charadrius melodus)], 

32 and four are listed as threatened [the bald eagle (Haliaeetus leucocephalus), Mead’s 

33 milkweed (Asclepias meadii), the dune thistle (Cirsium pitcheri), and the prairie white34 fringed orchid (Platanthera leucophaea)]. No federally-protected endangered or threatened 

35 species are known to occur on the Hammond Depot site. Although Wolf Lake may serve as 

36 habitat for many wildlife species, no habitat with the characteristics needed to support viable 

37 populations for rare, threatened, or endangered species is present at the Hammond Depot 

38 (Cash 1998). 

39 
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1 4.5.2 Potential Impacts of the Proposed Action 

2 

3 Loading of the crates containing the beryllium billets onto trucks for transport to off-site 

4 conversion facilities would occur adjacent to the location where the beryllium is currently 

5 stored and would use existing, surrounding roadways. Because loading materials stored at 

6 the depot onto trucks is a common activity occurring in the surrounding area, wildlife in the 

7 vicinity are habituated to these types of routine activities. 

8 

9 Because of the absence of significant habitat, and because the Proposed Action would not 

10 cause any other disturbances potentially affecting ecological resources, there would be no 

11 significant adverse impacts to wildlife or vegetation at the Hammond Depot. 

12 

13 In the event of a release or spill of beryllium during transport from the off-site conversion 

14 facilities back to the Hammond Depot, the movement of the spilled beryllium through the 

15 environment and its accumulation in the food chain would determine the potential for 

16 significant adverse impacts. Because beryllium attaches readily to soil, any spilled beryllium 

17 would not be transported long distances in soil (ATSDR 2002). Beryllium does not 

18 concentrate in plants, and there is no evidence that plants are harmed by an uptake of 

19 beryllium. The concentration of beryllium does not increase (biomagnify) in predators when 

20 they consume contaminated prey because fish do not accumulate beryllium from water into 

21 their bodies to any great extent, and most of the beryllium ingested by wildlife is eliminated 

22 quickly in urine and feces (ATSDR 2002). Hence, there would be no expected significant 

23 adverse impacts to ecological resources from releases or spills of beryllium, including 

24 beryllium in the form powder. 

25 

26 4.5.3 Potential Impacts of the No-Action Alternative 

27 

28 Under the No-Action alternative, routine activities would continue at the Hammond Depot. 

29 Species on or near the depot have become accustomed to those routine activities and, hence, 

30 would not be expected to experience any adverse impacts. No adverse impacts would be 

31 expected to occur to other ecological resources, such as habitats, at the depot as a result of the 

32 No-Action alternative. 

33 

34 

35 4.6 SOCIOECONOMICS 

36 

37 4.6.1 Existing Environment 

38 

39 The level of employment at the Hammond Depot is an extremely minor part of the total 

40 employment in Lake County, Indiana, which has a total population of nearly 500,000 people, 

41 and the Chicago metropolitan area, which has more than 9 million people. Currently, less 
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Defense Logistics Agency 34 Strategic Materials

1 than 10 percent of one person-year is associated with the storage of the beryllium billets at 

2 the Hammond Depot. 

3 

4 4.6.2 Potential Impacts of the Proposed Action 

5 

6 No change in the numbers of permanent staff personnel at the Hammond Depot would be 

7 required under the Proposed Action. The contractor personnel (i.e., truck drivers) who would 

8 move the beryllium to and from the off-site conversion facility would be at the Hammond 

9 Depot for extremely short periods of time. 

10 

11 Small increases in utility usage (including water and electricity) at the depot may result from 

12 the Proposed Action; however, because neither water nor electricity is in short supply in the 

13 area, no significant impacts would be expected to result from the increased use of utilities. 

14 

15 There could be a temporary, positive impact on the local economy around the Hammond 

16 Depot caused by the presence of the small number of contractor personnel during the 

17 Proposed Action, since such personnel might make local purchases of food, equipment, and 

18 fuel. Because of the short duration and intermittent nature of the loading/unloading activities 

19 at the Hammond Depot during the Proposed Action, no adverse impacts to social services 

20 would be expected to occur. 

21 

22 No more than 85 shipments by truck would be needed to move the beryllium billets to the 

23 off-site conversion facility and back again to the Hammond Depot. Over the 5-year duration 

24 of the Proposed Action, this small number of shipments would create an insignificant amount 

25 of additional traffic on the roads near the Hammond Depot. Therefore, the truck traffic 

26 associated with the Proposed Action would produce no significant adverse impacts to local 

27 traffic. 

28 

29 4.6.3 Potential Impacts of the No-Action Alternative 

30 

31 Under the No-Action alternative, the level of employment at the Hammond Depot would not 

32 change, and the expenditures for local services and equipment in the communities around the 

33 Hammond Depot would continue at the current levels. There would thus be no 

34 socioeconomic impacts to these surrounding communities as a result of the No-Action 

35 alternative. 
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1 4.7 ENVIRONMENTAL JUSTICE 

2 

3 4.7.1 Existing Environment 

4 

5 The residents located nearest to the Hammond Depot site boundary are over 600 ft (180 m) 

6 away; however, the nearest residence is over 1500 ft (460 m) from the location where the 

7 beryllium billets are currently stored (and where the upgraded and converted beryllium would 

8 be stored). 

9 

10 The Hammond Depot is located in Lake County, Indiana, and the depot is less than 

11 0.1 mi (0.2 km) east of the boundary with Cook County, Illinois, which also serves as the 

12 southeastern boundary for the city of Chicago. Data from the 2010 census show that 

13 83,361 residents live within 3.1 mi (5.0 km) of the depot (see Table 5). According to data 

14 from the 2010 census, minorities make up 35.6 percent of the population in Lake County 

15 and 44.6 percent of the population in Cook County (USCB 2014); however, larger 

16 percentages of minorities exist in the vicinity of the depot (see Table 5). 

17 

18 

19 Table 5. Characteristics of the population around the Hammond Depot

Population/Attribute 

Distance from the center of the Hammond Depot 

3.1 mi (5 km) 6.2 mi (10 km) 10 mi (16 km) 

Total population within 

specified distance 83,361 344,756 929,599 

Minority Category: 

 Black or African 

 American 23,912 (28.7%) 184,270 (53.4%) 589,579 (63.4%) 

 American Indian or 

 Native Alaskan 643 (0.8%) 1688 (0.5%) 3155 (0.3%) 

 Asian 330 (0.4%) 1624 (0.5%) 6068 (0.7%) 

 Native Hawaiian or 

 Other Pacific Islander 21 (0.0%) 68 (0.0%) 224 (0.0%) 

 Some Other Race 13,713 (16.5%) 37,698 (10.9%) 57,544 (6.2%) 

 More than One Race 2293 (2.8%) 7961 (2.3%) 18,023 (1.9%) 

 Aggregate Minority(1) 40,912 (49.1%) 233,309 (67.7%) 674,593 (72.6%) 

 Hispanic 35,614 (42.7%) 89,528 (26.0%) 136,877 (14.7%) 

 White 42,449 (50.9%) 111,447 (32.3%) 255,006 (27.4%) 

Note: Aggregate minority” is calculated by subtracting the percentage of reported “White” from the total 

population. The aggregate minority percentage in all of Lake County, Indiana, is 35.6%, and in all of Cook 

County, Illinois, is 44.6%. 

Source: Missouri Census Data Center, Circular Area Profiling System (CAPS), Version 10C, Office of Social 

and Economic Data Analysis, University of Missouri, Columbia, Mo., 2014. Accessed April 29, 2014, at 

http://mcdc.missouri.edu/websas/caps10c.html. 
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1 Data for 2012 on small-area income and poverty estimates from the Census Bureau show that 

2 persons at or below the poverty level make up 19.6 percent of the total population in Lake 

3 County, Indiana, and 18.0 percent of the total population in Cook County, Illinois. The 

4 poverty rates in each state as a whole are 15.5 percent for Indiana and 14.7 percent for Illinois 

5 (USCB 2013); therefore, higher percentages of low-income populations exist near the 

6 Hammond Depot than on average for either state. 

7 

8 4.7.2 Potential Impacts of the Proposed Action

9 

10 While minority and low-income populations do exist near the Hammond Depot, the analyses 

11 in this EA have identified no significant adverse impacts resulting from implementation of 

12 the Proposed Action. Hence, there would be no disproportionately high and adverse impacts 

13 to minority or low-income populations from the activities associated with the Proposed 

14 Action. 

15 

16 4.7.3 Potential Impacts of the No-Action Alternative 

17 

18 Under the No-Action alternative, there would continue to be no adverse impacts to the human 

19 environment. Hence, there would be no disproportionately high and adverse impacts to 

20 minority or low-income populations as a result of the No-Action alternative. 

21 

22 

23 4.8 CULTURAL RESOURCES 

24 

25 4.8.1 Existing Environment 

26 

27 Because of its method of construction (i.e., slag fill in a previous wetland area), there are no 

28 recoverable archaeological artifacts at Hammond Depot. In addition, an architectural survey 

29 conducted in 1998 for the assessment of cultural resources at the depot found no structures, 

30 buildings, or objects that are eligible for listing in the National Register of Historic Places. 

31 A portion of the Hammond Depot containing Cold War era structures was previously 

32 excessed and is no longer part of the depot; furthermore, the buildings have been modified to 

33 the point where they no longer have historic integrity (DeLeon and Whetsell 1998). 

34 

35 4.8.2 Potential Impacts of the Proposed Action 

36 

37 Activities under the Proposed Action at the Hammond Depot would not adversely impact any 

38 cultural, archaeological, or historic resources since no such resources are present at the depot. 

39 Likewise, transporting the beryllium on existing highways to and from the off-site conversion 

40 facilities would not adversely impact any cultural, archaeological, or historic resources along 
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1 the transportation route. Hence, no impacts would be anticipated to any cultural, 

2 archaeological, or historic resources as a result of the Proposed Action. 

3 

4 4.8.3 Potential Impacts of the No-Action Alternative 

5 

6 Because no cultural, archaeological, or historic resources are present at the Hammond Depot, 

7 no impacts would be anticipated to any such resources at or near the depot as a result of the 

8 No-Action alternative. 

9 

10 

11 4.9 NOISE 

12 

13 4.9.1 Existing Environment 

14 

15 The Hammond Depot is located within an industrial area associated with the normal levels of 

16 noise produced by transportation and material-moving equipment. Other than vehicle traffic, 

17 no noise-generating equipment is in operation at the depot either currently or for the 

18 foreseeable future. 

19 

20 4.9.2 Potential Impacts of the Proposed Action 

21 

22 No noisy equipment would be used for the Proposed Action, other than the normal forklifts 

23 and vehicles used for loading and unloading the beryllium. The noise produced by this 

24 vehicle traffic would be intermittent and temporary, and would not generate noises loud 

25 enough to create a nuisance off-site. 

26 

27 4.9.3 Potential Impacts of the No-Action Alternative 

28 

29 Under the No-Action alternative, operations at the Hammond Depot would continue with 

30 occasional trucks and trains and their associated typical noises. Such noise would not be 

31 expected to produce any significant adverse impacts. 

32 

33 

34 4.10 AESTHETICS 

35 

36 4.10.1 Existing Environment 

37 

38 The Hammond Depot is located within an industrial area, and the structures and facilities at 

39 the depot are similar to those in the surrounding area. 

40 
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1 4.10.2 Potential Impacts of the Proposed Action 

2 

3 There would be no new construction associated with the Proposed Action; hence, the visual 

4 characteristics of the existing structures at the Hammond Depot would not be altered by the 

5 Proposed Action. Therefore, there would be no significant adverse impacts to the aesthetic 

6 resources at the Hammond Depot as a result of the Proposed Action. 

7 

8 4.10.3 Potential Impacts of the No-Action Alternative 

9 

10 Under the No-Action alternative, operations at the Hammond Depot would continue, 

11 including the long-term storage of the beryllium billets. There would be no new construction 

12 associated with these storage activities, nor would the visual nature of the existing storage 

13 facilities be altered. Therefore, there would be no impacts to the aesthetic resources at the 

14 Hammond Depot under the No-Action alternative. 

15 

16 

17 4.11 METEOROLOGY AND AIR QUALITY 

18 

19 4.11.1 Existing Environment 

20 

21 The air quality at the Hammond Depot is characteristic of the large, surrounding industrial 

22 area. The area is classified by the EPA as being in nonattainment for ozone but is in 

23 attainment for all other criteria pollutants listed under the National Ambient Air Quality 

24 Standards (NAAQS) (40 CFR 81.315). 

25 

26 Extreme meteorological events may be expected infrequently in the area. The quantity of 

27 precipitation during extreme events has been estimated by the National Weather Service 

28 according to the expected frequency of occurrence (NWS 2014a). The amount of 

29 precipitation during a 24-hr period that would be expected to occur, on average, once every 

30 10 years is 4.5 in. (11.4 cm) at the nearby Chicago Midway Airport. The quantity of 24-hr 

31 precipitation that would be expected to occur, on average, once every 100 years is 7.4 in. 

32 (18.8 cm). With regard to snowfall, the greatest total amount of seasonal snowfall recorded in 

33 Chicago was 89.7 in. (2.3 m), which occurred during 1978 and 1979 (NWS 2014b). 

34 

35 Tornadoes occasionally occur in the area. Based on the 20-year period of record 

36 between 1980 and 1999, the mean number of days per year with one or more tornadoes 

37 within 25 miles (40 km) of the Hammond Depot is 0.9 (NSSL 2003). Therefore, the 

38 probability of a tornado occurring within the boundaries of the Hammond Depot is 

approximately 4.3 × 10-5 39 annually. Based on the same period of record, the mean 

40 number of days per year experiencing thunderstorms with wind speeds of at least 58 mph 

41 (93 km/hr) within 25 miles (40 km) of the depot is 4.5 (NSSL 2003). 
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1 Based upon historical records, the probability of a hurricane striking the Hammond Depot 

2 is vanishingly small. However, the remnants of tropical storms have passed through the 

3 area on rare occasions. 

4 

5 4.11.2 Potential Impacts of the Proposed Action 

6 

7 Under the Proposed Action, the activities that would take place at the Hammond Depot 

8 would involve moving the beryllium billets while inside their existing packaging and the 

9 return receipt of the upgraded and converted beryllium packaged inside steel drums. 

10 Because the drums would be sealed and would not be opened at the Hammond Depot, there 

11 would be no atmospheric emissions from the drums. 

12 

13 Atmospheric emissions of pollutants from the small amount of truck traffic required to 

14 move the beryllium to and from the off-site conversion facilities would be inconsequential 

15 for the industrial area surrounding the Hammond Depot, as well as for the system of state 

16 roads and interstate highways. 

17 

18 Phenomena such as tornadoes or high-winds could occur at the Hammond Depot; however, 

19 the converted beryllium would be stored within steel drums inside a metal storage enclosure 

20 (i.e., cabinet, locker, or vault) that is bolted to the concrete floor inside the beryllium 

21 storage structure. It is therefore highly unlikely that such high-wind events would affect the 

22 contents inside the converted beryllium drums. 

23 

24 For the reasons described in the above paragraphs, the Proposed Action would be expected 

25 to produce no significant adverse impacts to air quality. 

26 

27 4.11.3 Potential Impacts of the No-Action Alternative 

28 

29 Under the No-Action alternative, current levels of depot activities would continue, and no 

30 impacts to air quality would be anticipated. 

31 

32 

33 4.12 WASTE MANAGEMENT 

34 

35 4.12.1 Existing Environment 

36 

37 Currently, wastes generated at the Hammond Depot are managed through a facility 

38 maintenance contract and are disposed of at a local landfill in Newton County, approximately 

39 40 miles (65 km) south of the depot. The depot generally has no hazardous waste to report 

40 on an annual basis. 

41 
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1 4.12.2 Potential Impacts of the Proposed Action 

2 

3 Implementation of the Proposed Action would generate waste at the Hammond Depot, 

4 potentially including wooden crates, plastic liners, pallets, personal protective equipment, and 

5 tools. These wastes would be disposed of at the local landfill already used by the depot 

6 and/or at licensed commercial facilities. The expected quantity of such waste is expected to 

7 be extremely small and would therefore not be expected to produce any significant adverse 

8 impacts either to the waste management services in the area or to the capacity of nearby 

9 waste disposal systems, such as landfills. 

10 

11 4.12.3 Potential Impacts of the No-Action Alternative 

12 

13 Under the No-Action alternative, very small quantities of non-hazardous waste would 

14 continue to be generated as a result of maintenance activities. These wastes would continue 

15 to be disposed of at the local landfill and/or licensed commercial disposal facilities. Because 

16 the quantities of waste would be small, there would be no significant adverse impacts to 

17 waste management services or capacity in the area. 

18 

19 

20 4.13 CUMULATIVE IMPACTS 

21 

22 Cumulative impacts may result when the environmental effects of the Proposed Action are 

23 added to or overlaid upon the effects associated with other past, present, and reasonably 

24 foreseeable future activities in the same project area. Cumulative impacts can result from 

25 individually minor, but collectively significant, actions taking place over a period of time. 

26 

27 4.13.1 Hammond Depot 

28 

29 Cumulative impacts from past and ongoing activities at the Hammond Depot are generally 

30 reflected in the “existing environment” subsections within Chapter 4 of this EA. 

31 Regarding reasonable foreseeable future actions, no publicly announced future actions or 

32 changes in the mission of the Hammond Depot were identified that could contribute to 

33 cumulative impacts. 

34 

35 Other projects in the area might be in competition with the Proposed Action for resources, 

36 such as potable water, transportation equipment, motor vehicle fuel, electricity, and 

37 manpower; however, none of these commodities is in short supply, and the quantities of 

38 such resources required by the Proposed Action are small in comparison to the total 

39 quantities available. 

40 
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1 During the Proposed Action, other transportation activities on the depot unrelated to the 

2 Proposed Action may remain the same. Up to 10 tractor/trailer rigs not related to the 

3 Proposed Action may be entering and leaving the depot each day. The small increase in 

4 traffic from the Proposed Action, in conjunction with existing traffic near the depot, 

5 would be expected to create no significant cumulative impacts to the local transportation 

6 infrastructure that is already appropriately sized for an active industrial area. 

7 

8 Based on the information given above, no significant adverse cumulative impacts would 

9 be expected to occur at the Hammond Depot as a result of the Proposed Action. 

10 

11 4.13.2 Transport Routes 

12 

13 The total truck transport distance for the duration of the Proposed Action [i.e., up to 

14 170,000 vehicle miles (273,500 km); see Section 4.2.2.1] would be an insignificant portion 

15 of the 267,207 million miles (429,936 million km) driven by large truck in the United States 

16 in a calendar year (see Table 3). There would be no adverse cumulative impacts from the 

17 additional traffic associated with the Proposed Action. 

18 

19 The emission of pollutants, including carbon dioxide (CO2) and other greenhouse 

20 gases, from vehicles associated with the Proposed Action have not been quantified. 

21 Nevertheless, these vehicle emissions could contribute to the cumulative impacts of such 

22 emissions either regionally, nationally, or internationally. Because the Proposed Action 

23 could involve up to 85 trips between the Hammond Depot and the off-site beryllium 

24 conversion facilities, and because this number of trips is extremely small in comparison to 

25 the other vehicle traffic on U.S. highways, the emissions of pollutants from the vehicles 

26 involved in the Proposed Action would contribute insignificantly to the overall levels of 

27 pollutants in the atmosphere. The EPA has estimated that annual CO2 emissions are 33 

28 billion tons (30 trillion kg) globally and 6 billion tons (5.4 trillion kg) for the United 

29 States alone (EPA 2012). Because the average U.S. passenger vehicle emits 

30 approximately 5.7 tons (5200 kg) of CO2 annually (EPA 2005), and because of the 

31 extremely small number of trips associated with the Proposed Action in comparison to 

32 other vehicle traffic—either regionally, nationally, or globally—it is concluded that the 

33 cumulative impacts of vehicle emissions during the Proposed Action would not be 

34 significant. 

35 

36 During the beryllium-conversion portion of the Proposed Action—an approximately 

37 5-year period ending by the end of calendar year 2020—no extraordinary or conflicting 

38 uses would be expected for the local roads around the Hammond Depot or for those 

39 portions of the interstate highway system that connect the Hammond Depot to the off-site 

40 beryllium conversion facility. 

41 
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1 While routine highway construction and/or maintenance activities would be expected to 

2 occur on the routes between the Hammond Depot and the off-site beryllium conversion 

3 facilities during the period of the Proposed Action, such activities would not be expected 

4 to adversely affect the Proposed Action due to the large number of alternate routes 

5 available. In addition, the transportation associated with the Proposed Action would not 

6 be expected to contribute to the need for additional highway construction and/or 

7 maintenance. 

8 

9 Based on the information given above, no cumulative adverse impacts would be expected 

10 along the transportation routes as a result of the Proposed Action. 
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1 5. FINDINGS AND CONCLUSIONS

2 

3 

4 5.1 FINDINGS 

5 

6 5.1.1 Consequences of the No-Action Alternative 

7 

8 Under the No-Action alternative, DLA–Strategic Materials would continue to store the 

9 NDS inventory of HPP beryllium billets, and the routine inspection and maintenance of this 

10 inventory would continue for the foreseeable future. No changes, other than repairs needed 

11 to ensure continued safe storage, would be made to the present storage buildings or facilities 

12 at the Hammond Depot. There would thus be no significant adverse environmental impacts 

13 associated with the No-Action alternative. 

14 

15 However, the HPP beryllium billets currently in storage are not in a form readily useable by 

16 the DOD or its subcontractors in time of national emergency. In the event the beryllium was 

17 needed to satisfy future critical U.S. security, military or aerospace uses, it would not be 

18 available in the forms required as input to current manufacturing processes, and the billets 

19 would likely require conversion at that time. DLA–Strategic Materials has obtained 

20 estimates that it takes about 10 weeks to turn beryllium billets into powder. Hence, the 

21 usefulness of the beryllium in billet form would be questionable for any such future U.S. 

22 critical needs. 

23 

24 5.1.2 Consequences of the Proposed Action 

25 

26 The Proposed Action would result in no significant adverse impacts—including cumulative 

27 impacts—related to human health and safety; land use; water resources; ecological resources, 

28 including threatened and endangered species; socioeconomics; environmental justice; cultural 

29 resources; noise; aesthetics; air quality; and waste management. Transportation accidents 

30 were also examined because they have the potential for adverse impacts during the Proposed 

31 Action; however, it was found that the risk of an accident during transportation is extremely 

32 low and the Proposed Action would not be expected to produce any significant adverse 

33 impacts resulting from such accidents. 

34 

35 Table 6 provides a summary of impacts by resource area for the No-Action alternative and 

36 the Proposed Action. 
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1 Table 6. Summary of the impacts of the alternatives 

Resource Area Proposed Action No-Action Alternative 

Human Health and Safety No significant impact No impact 

Transportation No significant impact No significant impact 

Land Use No significant impact No impact 

Water Resources No significant impact No impact 

Ecological Resources No significant impact No impact 

Socioeconomics No significant impact No impact 

Environmental Justice No impact No impact 

Cultural Resources No impact No impact 

Noise No significant impact No significant impact 

Aesthetics No impact No impact 

Meteorology and Air Quality No significant impact No impact 

Waste Management No significant impact No significant impact 

2 

3 

4 5.2 CONCLUSIONS 

5 

6 Based on the environmental impact analyses conducted for and documented in this 

7 EA, it is concluded that the implementation of the Proposed Action would have no 

8 significant adverse or cumulative impacts on the quality of the natural or human 

9 environment. The results of these evaluations and analyses indicate that preparation 

10 of an EIS is not needed; and, therefore, a Finding of No Significant Impact is 

11 recommended. 
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1 6. LIST OF PREPARERS AND PERSONS CONSULTED 

2 

3 

4 This EA could not have been prepared and completed without the assistance and 

5 contributions of many individuals who provided data, information and/or text that has been 

6 incorporated into the analyses during the development of this document, as well as those who 

7 provided review comments on the early versions of this EA and made constructive 

8 suggestions for improvement. It would have been impossible to prepare this EA without 

9 their aid. The preparers, contributors, and key reviewers are listed below. 

10 

11 Defense Logistics Agency Coordinators

12 Deal, Eric; Materials Management Office 

13 Gibson, Alexandra; Environmental Protection Specialist, Materials Management Office 

14 Olszewski, John; Depot Manager, Materials Management Office 

15 Porter, Gary; Director, Materials Management Office 

16 Silverberg, Ira; Installation Support, Environmental 

17 

18 Oak Ridge National Laboratory Personnel (Preparers and Reviewers) 

19 Bast, Cheryl; Ph.D., biomedical sciences, University of Tennessee; B.S., biology, 

20 Hope College; Experience: 24 years. 

21 Smith, Ellen; M.S., water resources management, University of Wisconsin-Madison; B.A., 

22 geology, Carleton College; Experience: 35 years 

23 Terry, James; Ph.D., physics, Vanderbilt University; M.S., astronomy, University of South 

24 Florida; B.S., astronomy, University of South Florida; Experience: 35 years 

25 Zimmerman, Gregory; M.S., mechanical engineering, University of Tennessee; 

26 B.S., mechanical engineering, University of Tennessee; Experience: 37 years. 
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Defense Logistics Agency 46 Strategic Materials

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

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1 7. REFERENCES 

2 

3 29 CFR (Code of Federal Regulations) 1910.1000; Occupational Safety and Health Standards; 

4 Subpart Z: Toxic and Hazardous Substances, “Air Contaminants” 

5 29 CFR (Code of Federal Regulations) 1926.55; Safety and Health Regulations for Construction; 

6 Subpart D: Occupational Health and Environmental Controls, “Gases, Vapors, Fumes, Dusts, 

7 and Mists.” 

8 40 CFR (Code of Federal Regulations) 61.32; National Emission Standards for Hazardous Air 

9 Pollutants; Subpart C: National Emission Standard for Beryllium, “Emission Standard.” 

10 40 CFR (Code of Federal Regulations) 81.315; Designation of Areas for Air Quality Planning 

11 Purposes; Subpart C: Section 107 Attainment Status; Indiana. 

12 40 CFR (Code of Federal Regulations) 302.4; Part 302—Designation, Reportable Quantities, and 

13 Notification; Section 302.4: Designation of Hazardous Substances. 

14 40 CFR (Code of Federal Regulations) Parts 1500–1508; Regulations for Implementing the 

15 Procedural Provisions of the National Environmental Policy Act. 

16 42 USC (United States Code) 4321, et seq.; National Environmental Policy Act (NEPA) of 1969, as 

17 amended. 

18 49 CFR (Code of Federal Regulations) Part 172; Hazardous materials table, special provisions, 

19 hazardous materials communications, emergency response information, and training 

20 requirements. 

21 49 CFR (Code of Federal Regulations) Part 177; Carriage by public highway. 

22 ACGIH (American Conference of Governmental Industrial Hygienists) 2013. Documentation of 

23 Threshold Limit Values (TLVs) and Biological Exposure Indices (BEIs). ACGIH, Cincinnati, 

24 Ohio. 

25 AEDL (Army Engineer District Louisville) 2013. Hammond Depot Storm Water Pollution 

26 Prevention Plan (Final), prepared for Defense Logistics Agency, Strategic Materials, Hammond 

27 Depot, Hammond, Ind., prepared by Army Engineer District Louisville, Louisville, Ky., April. 

28 ATSDR (Agency for Toxic Substances and Disease Registry) 2002. Toxicological Profile for 

29 Beryllium, U.S. Department of Health and Human Services, Public Health Service, Washington, 

30 D.C. 

31 Cash, C.M., 1998. Natural Resources Assessment for Hammond Defense National Stockpile Center, 

32 U.S. Forest Service, Gifford Pinchot National Forest, May. 

33 DeLeon, M., and R. Whetsell, 1998. Cultural Resources Assessment of the Defense Logistics 

34 Agency/Defense National Stockpile Center, Hammond, Indiana, prepared by M. DeLeon, Forest 

35 Archaeologist, Okanogan National Forest, and R. Whetsell, Historian, Monongahela National 

36 Forest, prepared for Defense Logistics Agency and Indiana Division of Historic Preservation and 

37 Archaeology, June. 
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1 DLA (Defense Logistics Agency) 2014. Hammond Depot Emergency Response Plan, prepared for 

2 Defense Logistics Agency–Strategic Materials, Hammond Depot, Hammond, Indiana, May. 

3 EPA (U.S. Environmental Protection Agency) 1998. Toxicological Review of Beryllium and 

4 Compounds (CAS No. 7440-41-7) in Support of Summary Information on the Integrated Risk 

5 Information System (IRIS), EPA/635/R-98/008, Washington, D.C., April. Available on-line at 

6 http://www.epa.gov/iris/toxreviews/0012tr.pdf. 

7 EPA (U.S. Environmental Protection Agency) 2005. Emission Facts: Greenhouse Gas Emissions 

8 from a Typical Passenger Vehicle, EPA420-F-05-004, Office of Transportation and Air Quality, 

9 Washington, D.C., February; Available on-line at 

10 http://www.epa.gov/oms/climate/420f05004.htm. 

11 EPA (U.S. Environmental Protection Agency) 2012. Inventory of U.S. Greenhouse Gas Emissions 

12 and Sinks: 1990-2010; Executive Summary, EPA 430-R-12-001, Office of Atmospheric 

13 Programs, Washington, D.C., April; Available on-line at 

14 http://www.epa.gov/climatechange/Downloads/ghgemissions/US-GHG-Inventory-2012-ES.pdf. 

15 FMCSA (Federal Motor Carrier Safety Administration) 2014a. Large Truck and Bus Crash Facts 

16 2012, FMCSA-RRA-14-004, Analysis Division, FMCSA, U.S. Department of Transportation, 

17 Washington, D.C., June; Available on-line at 

18 http://ntl.bts.gov/lib/35000/35500/35578/LTCF2012-1.pdf. 

19 FMCSA (Federal Motor Carrier Safety Administration) 2014b. 2012 Large Truck Crash Overview, 

20 Analysis Division, FMCSA, U.S. Department of Transportation, Washington, D.C., July; 

21 Available on-line at http://www.fmcsa.dot.gov/safety/data-and-statistics/large-truck-and-bus22 crash-facts-2012. 

23 IARC (International Agency for Research on Cancer) 2010. Monograph 101-c7, Beryllium and 

24 Compounds. pp. 95-120. 

25 IDNR (Indiana Department of Natural Resources) 2013. Indiana County Endangered, Threatened 

26 and Rare Species List; County: Lake, Indiana Natural Heritage Data Center, Division of Nature 

27 Preserves, Indianapolis, Ind., April 16. Accessed April 29, 2014, at 

28 http://www.in.gov/dnr/naturepreserve/4666.htm. 

29 Materion (Materion Brush Inc.) 2014. Beryllium, The Miracle Metal: Sources of Beryllium. 

30 Accessed on April 3, 2014, at http://www.beryllium.com/sources-beryllium. 

31 MCDC (Missouri Census Data Center) 2014. Circular Area Profiling System (CAPS), Version 10C. 

32 Office of Social and Economic Data Analysis, University of Missouri, Columbia, Mo. Accessed 

33 April 29, 2014, at http://mcdc.missouri.edu/websas/caps10c.html. 

34 Newman, L.S., M.M. Mroz, R. Balkissoon, and L.A. Maier, 2005. “Beryllium sensitization 

35 progresses to chronic beryllium disease: a longitudinal study of disease risk.” Am J Respir Crit 

36 Care Med 171:54–60. 

37 NIOSH (National Institute of Occupational Safety and Health) 1999. International Chemical 

38 Safety Card 0226, Beryllium. Validated October 20, 1999; partially updated October 2005 and 

39 January 2008. 
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1 NRC (National Research Council) 2007. Health Effects of Beryllium Exposure: A Literature Review, 

2 Committee on Beryllium Alloy Exposures, Committee on Toxicology. National Academies 

3 Press, Washington, D.C. 

4 NRC (National Research Council) 2008. Managing Health Effects of Beryllium Exposure, 

5 Committee on Beryllium Alloy Exposures, Committee on Toxicology. National Academies 

6 Press, Washington, D.C. 

7 NSSL (National Severe Storms Laboratory) 2003. “What is the total annual threat of severe 

8 thunderstorms in the United States?,” Severe Thunderstorm Climatology, August. Accessed 

9 June 10, 2014, at http://www.nssl.noaa.gov/hazard/totalthreat.html. 

10 NTP (National Toxicology Program) 2011. Report on Carcinogens, Twelfth Edition, Department of 

11 Health and Human Services, Public Health Service, National Toxicology Program, Research 

12 Triangle Park, North Carolina. 

13 NWS (National Weather Service) 2014a. “NOAA Atlas 14 Point Precipitation Frequency Estimates: 

14 Chicago Midway AP 3 SWIL,” Hydrometeorological Design Studies Center, Precipitation 

15 Frequency Data Server (PFDS), Silver Spring, Md., February 24. Accessed June 10, 2014, at: 

16 http://hdsc.nws.noaa.gov/hdsc/pfds/pfds_map_cont.html?bkmrk=in. 

17 NWS (National Weather Service) 2014b. “Seasonal Snowfall Totals for Chicago, Illinois, from 1884 

18 to Present,” Weather Forecast Office, Romeoville, Ill., May. Accessed June 10, 2014, at 

19 http://www.crh.noaa.gov/lot/?n=chi_seasonal_snow. 

20 OSHA (Occupational Safety and Health Administration) 2014. OSHA Request for an Advisory 

21 Committee on Construction Safety and Health (ACCSH) Recommendation—Options for the 

22 Construction Industry in the Proposed Rulemaking for Beryllium. Accessed June 30, 2014, at 

23 https://www.osha.gov/doc/accsh/beryllium.pdf. 

24 PARS Environmental, Inc., 2011. Final Remedial Investigation Hammond Depot Hammond, 

25 Indiana, PARS Project No. 773-02, prepared by PARS Environmental, Inc., Robbinsville, 

26 New Jersey, prepared for U.S. Army Engineer District, Louisville, Ky., September; 

27 Available online at 

28 http://www.strategicmaterials.dla.mil/Documents/I%20Am%20The%20Key/HammondIN_RI

29 -%20HAMMOND%20Final%209.9.2011.pdf. 

30 Parsons (Parsons Engineering Science, Inc.) 2001. Final Focused Site Investigation Report, 

31 Hammond Depot, Hammond, Indiana, prepared for the U.S. Army Corps of Engineers Huntsville 

32 Center, Westmont, Ill., Feb. 

33 Schubauer-Berigan, M.K., J.R. Couch, M.R. Petersen, T. Carreón, Y. Jin, and J.A. Deddens, 2011. 

34 “Cohort mortality study of workers at seven beryllium processing plants - update and associations 

35 with cumulative and maximum exposure.” Occup Environ Med 68(5):345-53. 

36 Tinkle, S.S, J.M. Antonini, B.A. Rich, J.R. Roberts, R. Salmen, K. DePree, and E.J. Adkins, 2003. 

37 “Skin as a Route of Exposure and Sensitization in Chronic Beryllium Disease.” Environmental 

38 Health Perspectives 111: 1202-1208. 
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1 USCB (U.S. Census Bureau) 2013. Small Area Income and Poverty Estimates, “SAIPE Interactive 

2 Data Tool (Lake County, Indiana, and Cook County, Illinois).” Washington, D.C. December. 

3 Accessed on April 29, 2014, at http://www.census.gov/did/www/saipe/data/interactive/. 

4 USCB (U.S. Census Bureau) 2014. 2010 Census Interactive Population Search. Washington, D.C. 

5 Accessed April 29, 2014, at http://www.census.gov/2010census/popmap/ipmtext.php.