Section 7
Presence of Depleted Uranium and Beryllium
at the BFC and Current and Potential Future
Impacts on the Environment
Contents
7.1
Uranium at the BFC KCP ................................................................................................ 1
7.1.1 History of Depleted Uranium (DU) at the Kansas City Plant ....................................... 2
7.1.2 Current Use of DU at the KCP ..................................................................................... 3
7.1.3 Depleted Uranium Decontamination Projects at the KCP ............................................ 3
7.1.4 Detection of Uranium in KCP Groundwater ............................................................... 5
7.1.5 CEARP Program Investigation .................................................................................... 6
7.1.6 MDNR Investigation...................................................................................................... 7
7.1.7 Fate and Transport of Buried DU ................................................................................. 8
7.1.8 Summary ..................................................................................................................... 13
7.2
Beryllium at the BFC ..................................................................................................... 15
7.2.1 Beryllium History and Use ........................................................................................ 15
7.2.2 Concentrations in the Environment and Risks ........................................................... 15
7.2.3 Use at the KCP/Sampling at the BFC ........................................................................ 17
7.2.4 GSA Sampling for Beryllium ..................................................................................... 21
7.2.5 2009 Beryllium Exposure Assessment ...................................................................... 23
7.2.6 Future Potential Releases ........................................................................................... 23
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7.1
Uranium at the BFC KCP
Uranium occurs naturally in all rocks and soil with typical background levels ranging
from approximately 2 to 4 mg/kg (Ahrens 1965, Wedepohl 1968). Thus, any sample of
soil or water from the BFC and its environs, would have detectable uranium—depending
on the chosen analytical technique.
Statistically determined background values were determined for many metals at the KCP,
but this was not done for uranium because there had been limited use, no hard evidence
of onsite disposal, and geochemical conditions that strongly limit uranium migration.
Hence, sufficient data were never obtained to determine onsite background. As described
below, all data that have been obtained indicate only background concentrations.
Uranium is not a component of the typical toxic metal suite investigated at hazardous
waste sites. The Department of Energy (DOE), however, has been the federal agency
most involved with the uranium industrial cycle because of its use in weapons and for
energy production. The KCP, however, is an anomaly among DOE industrial facilities
because its mission has only been manufacture and design of non-nuclear parts for
weapons. There is no history of use of radioactive materials. This last statement may
seem contradictory with even a limited use of depleted uranium (DU), however, as
further discussed below, uranium metal is so mildly radioactive that, when speaking in
generalities about nuclear materials; depleted uranium is not always included.
Depleted uranium (DU), as will be described below, is only slightly radioactive. Its uses
are because of its metallic properties. In that sense, there has been some historical use at
the KCP. There was machining done at an area known as the “heavy machining
inspection area” (Department 20 or D/20). That location was decontaminated in the mid1980s as described below.
Nonetheless, because of uranium’s many links with DOE activities, personnel performing
the original historical and field surveys considered the possibility of DU disposal or use
at the BFC as a high priority. The details of the series of historical surveys and initial site
investigations are presented in Section4. It is worth reiterating that the historical surveys
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were performed by three different entities over a several-year period. Thus, attempts to
learn of disposal of DU were extensive.
7.1.1 History of Depleted Uranium (DU) at the Kansas City Plant
The Kansas City Plant’s history of manufacturing non-nuclear parts for nuclear weapons
has been highly-classified. This was most true, perhaps of the political climate of the
1950’s when, for example, employees on travel could not reveal their destinations to their
families. Limited onsite disposal of wastes occurred at this same time (the 1940s and
1950s) when there were also no laws applicable to any of the waste handling practices.
Thus, despite extensive records searches and employee/retiree interviews, historical
records concerning waste disposal for the BFC/KCP during this time period are mostly
non-existent.
The initial historical environmental survey (DOE-BFEC, 1984) uncovered virtually no
information regarding use of depleted uranium. The document cites one employee who
said he believed machining waste containing DU had been dumped into the Old Landfill
(called IRS landfill in many documents). However, this information was hearsay and
never corroborated. This same employee also said he had heard there was DU in the
classified burial trenches. Later historical surveys failed to uncover additional
information regarding use of DU and the information given regarding the classified burial
trenches proved erroneous. No information was ever provided regarding where the DU
supposedly buried onsite had originated.
Only one historical location where machining of DU occurred was identified based on
employee interviews and plant records. This was the “heavy machining and inspection
area” which was remediated in the mid-1980s (reference). This location encompassed
approximately 12,000 ft2 within the Main Manufacturing Building (figure). Uranium
powder was mixed with an encapsulant and placed on another part and allowed to dry.
Once dry the part was machined. This activity was limited to the Department 20 (D/20)
area and was never placed into production.
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Besides contamination known to exist in D/20, there was an assumption on the part of
plant management that DU was buried in the so-called classified burial trenches—also
remediated in the mid-1980s. In hindsight, the classified nature of the trenches had
prevented general knowledge of their contents and incorrect assumptions were made. Site
records, as reported in a 1977 Environmental Assessment (DOE 1977), described burial
of lead oxide (which was found) in these trenches but nothing was said regarding DU.
7.1.2 Current Use of DU at the KCP
The KCP currently has one low volume, intermittent, batch process that involves the
etching of a solid DU component. The DU parts are electrochemically etched to remove
any oxides. Because the uranium does not become volatile during the electrochemical
process, there is minimal personnel internal dose hazard with this process. The small
volume of DU waste is contained within the acid etch bath and resin exchange bottles
used to filter residual DU from the rinse water.
The spent acid bath is solidified and
associated contaminated resin exchange bottles are shipped offsite as low-level waste.
The total quantity of DU etched in calendar year 2008 was 1191.8 grams. The estimated
amount that will be etched during the project life is 6771 grams over a nine-year period.
Personnel monitoring is performed on a continuous basis for employees associated with
the above operation. In addition, exhaust stack monitoring has been performed with no
levels of radioactivity detected above background.
7.1.3 Depleted Uranium Decontamination Projects at the KCP
Initially, it should be noted that burial of DU at the KCP would have been an unusual
practice within DOE. A large mass of uranium dust or shavings is hazardous because
hydrogen gas can be generated as it reacts with water. Studies of this reaction and its
characteristics have been reported in the technical literature for many decades (Delegard
and Schmidt 2008) making it unlikely residues would have been buried. As an example,
DU burial was not the practice at other DOE facilities. Tons of DU are still stored at
some other DOE facilities. It is likely, therefore, that if there ever was a significant
accumulation of DU, it probably was containerized and disposed of by shipment offsite.
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Several interviewees did provide hearsay references to what was known as the
“Classified Burial Area” or “classified waste trenches” during the initial historical survey.
Only one suggested DU was buried there, but several others recommended former
employees who would know what had occurred. Unfortunately, personnel who were
believed present when waste was deposited in the area were deceased. As noted
previously, the 1977 Environmental Assessment (DOE 1977) reported burial of lead
oxide but nothing was said about DU. Discussions among plant environmental and
engineering personnel at the time of the initial historical survey revealed a widespread
assumption that DU was probably in the classified trenches.
KCP management demonstrated significant concern and expectations regarding the
potential for DU. First, cleanup standards of background were mandated by plant
management. This represented cleanup criteria below existing regulatory requirements—
a fact highlighted in the Rockwell reports (Rockwell 1985 a,b,c) the documented cleanup
efforts where DU was processed in the D/20 area. In addition, meetings were held with
employees to discuss what was known about the effects of DU and to answer any
questions. Hence, Rockwell, the cleanup contractor for the Classified Trenches,
developed plans for monitoring and handling/removal of DU from the trenches.
Extensive monitoring throughout the project failed to locate any DU or any radiation
above background during the excavation and complete removal of the trench contents.
Department 20 or D/20, inside the MMB, was decontaminated at the same time the
trenches were excavated (Rockwell 1985a,b,and c). There was some follow-on work
because of a leaky sump which required removal of a pipe and some soil. Hence, a final
report was provided in 1987 (Rockwell 1987). As with the trench excavation, Rockwell
noted that the requirements imposed by KCP management were more stringent than was
required by regulations. Once again, KCP management required cleanup to background.
The Rockwell documents were provided in four volumes (Rockwell 1985a,b,c, 1987).
The first volume was a 15-page Executive Summary. The second volume was a 73-page
Technical Report. Volume three consisted of field procedures and raw field data
respectively. The Executive Summary noted that no radioactivity was associated with the
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trenches and that contamination in D/20 was low-level and not subject to disturbance and
inhalation. The Executive Summary had several figures and several pages describing
MDNR presence and inspections during the trench remediation.
The Technical Report also contained many figures and photos but little descriptive
information regarding the trench excavation. In all likelihood, delineation of waste
material from the surrounding natural clay was quite easy. The subsurface clays form a
very distinctive, slick and cohesive surface when excavated. There would have been
little if any penetration of solid waste into the native clay.
The D/20 “heavy machining and inspection area” was cleaned with special tools called
“scabblers and chipping hammers.” The former is a vacuum device which can roughen
and remove surface concrete while collecting all of the dust. These tools were developed
as a means of removing so-called “fixed” contamination which occurred when dusts or
liquids conducted radioactive materials into the surface layers of a concrete or cement
surface. These tools were very effective because they can remove a surface layer. Then,
if radioactivity remains, another layer can be removed until all remnants of radiation are
collected. Contamination was also removed from floor cracks, expansion joints and bolt
anchors. All waste material was placed in drums and shipped offsite.
No other production uses of DU on site are known. The KCP has always been involved in
special “piece-work,” that is, numerous, small, isolated projects relying on high-quality
machining. DU has been used in many weapons and as armor; hence, it is not
unreasonable to suspect other use on site. It is emphasized, however, that there have been
no alleged or surmised uses of uranium in any other form than as metallic pieces of DU.
Any disposal, therefore, was of shavings or powder or metallic pieces.
7.1.4 Detection of Uranium in KCP Groundwater
Site Investigation Program
Uranium was included in the initial analytical suite for groundwater monitoring because
of the hearsay account that it may have been buried onsite. An initial data set included
detections of uranium, but further investigation showed the data to be in error.
Specifically, traces of uranium were reported in groundwater seepage from the face of the
GSA [IRS] Landfill. Some nearby wells also reportedly contained traces of uranium.
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Attempts to repeat the results failed. Detections were sporadic and did not always
correlate with waste areas. Moreover, by this point in the site investigation, the
subsurface geochemical conditions had been confirmed as unfavorable for uranium
migration. Repeat sampling and analyses using a more sensitive technique showed no
detectable uranium. Initial analyses had not taken into account the highly turbid state of
these water samples.
A 1993 letter (N. Korte, ORNL to D. Brown KCP, July 13, 1993) reviewing these data
notes that the wells had not been developed for the initial sampling and that the analytical
technique used at that time was sensitive to the quantity of sediment in the water. Excess
sediment and inadequate background correction were blamed for the incorrect results. In
fact a review of the four analytical reports associated with samples that detected uranium
indicted that a data entry error into the site database had been made as the actual results
were an order of magnitude lower than that previously presented. Uranium was
eventually deleted from routine monitoring.
7.1.5 CEARP Program Investigation
The hearsay report of depleted uranium machine turnings being disposed of in the
Landfill also prompted the analysis for total uranium in soil and water samples during an
investigation performed by the CEARP program in 1986 (DOE-CEARP, 1986, see
section 4.3.2). As discussed in the historical surveys, there were no data or documents to
confirm the disposal of uranium in the Landfill—only the single hearsay report. It is also
important to note that CEARP, although DOE-sponsored, was independent of the site
characterization being performed by KCP management.
Uranium concentrations detected in the Landfill soil samples ranged from 0.7 to 4.6
pCi/g (1 mg/kg natural Uranium = 1.5 pCi/g Uranium), with a nominal detection limit of
1.0 pCi/g. Analyses of monitoring well samples showed total uranium below detection
limits, nominally 1 pg /L. Analytical results for historical water samples taken from a
seep along the eastern edge of the landfill and tested for total uranium ranged from less
than the detection limit of 5 pg/L to 17 pg/L.—all results within typical background
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ranges. Total uranium values for alluvial monitoring wells ranged from less than 5 to 15
pg / l, demonstrating that the seep results were consistent with background (section 2.3).
Thus, by 1986, two investigations had not found DU associated with the Landfill and the
interviewee who suggested it was buried there had been proven wrong regarding his
belief it was in the classified trenches. Based on these findings, additional site
investigation for DU was deemed unnecessary.
7.1.6 MDNR Investigation
MDNR conducted a study which evaluated additional samples at the Old Landfill
(MDNR 2004). The report’s introduction states that the project was performed to
determine whether “…depleted uranium, placed in the landfill, is leaching out of the
landfill, within the groundwater.” It is emphasized that the premise of this study, as
described, is somewhat erroneous because there is no direct evidence of DU “placement”
in the landfill—only a single hearsay comment from an employee who incorrectly stated
DU was in the classified trenches. The MDNR study was unique from other KCP
investigations in that isotopic signatures were used in an attempt to separate DU from
naturally-occurring uranium. As described below, if DU were present, the isotopic
signature would be different from natural uranium. Care must be taken when interpreting
uranium isotopic activity ratios because the natural variation can be large.
According to the information in the MDNR report, samples were collected either by
pumping or by bailing and then immediately acidified with nitric acid. This approach is
not appropriate for the BFC because the wells have been shown repeatedly to have high
and variable amounts of sediment. Indeed, two peer-reviewed articles appeared in
professional environmental journals reporting studies based on the ease with which
sediment is disturbed in KCP wells (Kearl and others 1992, 1994). Because of excess
and highly variable sediment, results for metals would be expected to be questionable. In
addition, gross alpha and beta results, which were also obtained, probably would be
erroneous. On the other hand, sampling inadequacies would not affect isotopic ratios
unless they were different in the soil (sediment) versus the water.
Gross alpha and total uranium results were low, suggesting that sediment problems were
not severe. On the other hand, there is no way of knowing which if any samples were
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affected. Nevertheless, the author concluded based on gross alpha results, “uranium is
not leaching from the landfill.”
Isotopic ratios also did not suggest presence of DU. Most U-234/U-238 activity ratios
were <2 and all were well within the 0.5 to 40 reportedly possible for natural samples
(Fujikawa and others undated). The ratios were probably also affected by the low
concentrations involved. More than half of the measurements were “qualified” by the
analytical laboratory because results were so near the detection limits. The report
concluded, “Qualitative analysis of the data from nine Uranium isotope sampling events
from 2001 to 2003 does not indicate the presence of depleted uranium in the wells
sampled.” The report suggested additional work including improved sampling methods.
Additional work, however, was never performed.
7.1.7 Fate and Transport of Buried DU
Although there are no known burials of DU at the KCP, this section addresses fate and
transport considerations should it have been buried either at the Old Landfill or some
unknown location on the property. As noted above, only the disposal of uncombined,
metallic DU is considered plausible. Fortunately, uranium geochemistry has been
extensively studied because of its use in energy production as well as its use in munitions.
Characteristics of DU
Depleted uranium is produced as a byproduct of the uranium enrichment process. It is
important to understand that uranium in nature is predominantly the isotope U-238.
Neither naturally-occurring uranium (with its naturally-occurring mixture of isotopes) nor
U-238 are fissionable, that is, useful for weapons or energy production.
Hence, for weapons or nuclear reactors, the natural uranium must be “enriched,” which
means that chemical and physical processes are used to increase the quantity of U-235 by
separating it from some of the U-238. The byproduct of this process, U-238 without U235, is termed “depleted” uranium.
U-238 has a much longer half-life than the lighter isotopes, and DU therefore emits less
alpha radiation than the same mass of natural uranium. A review by the International
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Atomic Energy Agency notes that DU has 60% the radioactivity of natural uranium
(Bleise and others 2003). As shown by Figure 7.1, U-238 decays by emission of an
alpha particle—not only is this a weak form of activity, which can principally cause harm
only by ingestion, but the half-life is 4.5 billion years. Thus, in practical terms, U-238 is
essentially not-radioactive. As an example, independent analyses have shown that
radiation exposure to the local populace following the Gulf War, in which large quantities
of DU-containing conventional weapons were used, “does not differ from the world
average” (Bem and Bou-Rabee 2004) despite considerable press coverage to the contrary.
Finally, much work has been done regarding the risk of environmental exposure to DU.
In a relative sense, uranium does not easily move through the food chain. Typical
exposure assessments, even from areas where training occurred with DU-containing
weapons, indicate little or no ecological risk (e.g. Cheng and others 2004).
Given billions of years, highly-radioactive isotopes are formed from U-238 (e.g. radium226 is three million times more radioactive than DU) and it is those daughter products
which were the targets in historical ore-prospecting with a Geiger-Muller Counter. All
traces of the highly-radioactive isotopes are removed during the milling process and prior
to the enrichment of uranium for use in weapons and reactors. Consequently, addressing
DU is chiefly a problem of potential metal corrosion, dissolution, migration and chemical
toxicity—the same as for disposal of metallic lead or nickel.
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Figure 7.1: A portion of the U-238 decay series.
Uranium has another naturally-occurring isotope: U-234. This isotope is also carried
away in enrichment, but because it is a daughter product of decay from U-238 (Fig. 7.1),
the isotopic activity ratio theoretically would be 1.0 for natural uranium. This ratio,
however, has been found to vary considerably in many waters, soils and sediments
(Fujikawa and others 2000). U-234 can be preferentially leached relative to U-238.
Thus, U-234/U/238 activity ratios in water reportedly vary from 0.5 to 40 while those in
soil can range from 0.5 to 1.2 (Fujikawa and others 2000).
Site Geochemical Effects on DU
The purpose of the discussion in this section is to describe site geochemical conditions
with respect to uranium geochemistry. The discussion demonstrates that no matter what
form inorganic uranium could have been disposed of at the KCP, it would remain
immobile or immediately precipitate and would not migrate. This conclusion is robust
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for any disposal of inorganic forms of uranium including salts that are soluble in many
natural waters.
As described in Section 3, the alluvial aquifer at the KCP has a matrix of clayey-silt. The
resulting low recharge and low flow rate have led to the establishment of reducing
(anoxic or anaerobic) conditions in the aquifer. These reducing conditions have led to the
release of naturally-occurring iron, manganese, and arsenic. Iron and manganese will
only dissolve under anoxic conditions, or conditions described as anaerobic and mildly
reducing (Hounslow 1995, p172). An additional demonstration of the presence of
reducing conditions at the KCP is that the principal contaminant downgradient from
source areas is 1,2-DCE which is an anaerobic biodegradation product of TCE, the
principal solvent spilled at the KCP.
The reason why it is important to understand the redox conditions (determining whether
the site is reducing or oxidizing) is shown in Figure 7.2—the Eh/pH diagram for uranium.
Because Eh is difficult to measure reproducibly, it is often calculated using computer
models. This is unnecessary at the KCP because so many lines of evidence indicate a
very low Eh. Indeed, at several locations, attempts to measure dissolved oxygen (DO)
have shown none detectable. (Note, for very low DO, as at the KCP, only test kit or
chemical measurements are reliable. Use of a DO or an Eh probe will yield drift and
unreliable measurements when values are at or near zero.) By definition, if DO is not
detectable, the Eh is near zero. Referring to figure Y shows that with an Eh of 0 and the
BFC aquifer’s pH of approximately 7, the stable uranium species is the crystalline solid
UO2 or uraninite, a mineral in which uranium is in the +4 oxidation state.
Precipitation of uranium in its +4 oxidation state under reducing conditions is a wellknown phenomenon because searching for a redox boundary is a method for finding
certain types of ore deposits called “roll-fronts.” In these instances, oxidizing water
dissolves uranium and conducts it in the groundwater. If this groundwater encounters an
area where conditions are reducing, usually caused by an abundance of organic matter
which consumes oxygen during decomposition, the uranium precipitates and is
concentrated in an ore body (DeVoto 1978).
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This process has been demonstrated in field tests where injection of dissolved uranium
(UO22+) in the +6 oxidation state into an anoxic aquifer quickly results in precipitation
(Senko and others 2002). These authors suggested abundant nitrate could provide a
mechanism for remobilization of anoxic precipitates. This could occur, for example, in a
highly-organic environment such as some municipal landfills or with sewage wastes.
Nitrate analyses of water from the KCP aquifer have shown either traces or no detections
of nitrate. Hence, this potential mechanism could not be a factor.
The only other manner in which uranium could migrate is with colloidal transport. This
phenomenon has been extensively investigated because of concern regarding long-term
radioactive waste disposal. Those studies have shown that colloidal transport only
occurs in very sandy aquifers. The clayey-silt matrix of the KCP aquifer, therefore,
would impede colloidal transport.
In order to address concerns expressed by workers housed in GSA controlled portions of
the BFC samples were collected for uranium. As reported in a 2011 Health Hazard
Evaluation report prepared by the National Institute for Occupational Safety and Health
(NIOSH) February 2010 air samples were collected at 9 locations and surface wipe
samples were collected at 29 locations for GSA by a private contractor and analyzed for a
number of analytes including uranium. Only one sample detected uranium above the
detection limit for uranium oxide at 0.63 µg/cm2 . All subsequent data was below
detection limits. Additional air sampling in August 2011 by GSA also did not detect
uranium over laboratory reporting limits. The same was true for sampling of surface
dust. Thirteen indoor and five outdoor ambient air sampling locations were sampled
along with eight bulk dust sampling locations with no uranium detected.
None of the above is to say that uranium can never be a mobile element. Pumping and
recirculation of aerated water (now higher both in oxygen and carbon dioxide) has been
shown to mobilize natural uranium from soils (Jurgens and others 2010). Adding an
oxidizing agent and high carbonate can also mobilize uranium (Mason and others 1997).
These facts are also demonstrated by the Eh/pH diagram (Figure 7.2) which shows, for
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example, that Eh of 0.4 (highly oxidizing) and pH of 5, a soluble uranium complex is
formed. At higher pH, soluble carbonate complexes can be formed.
7.1.8 Summary
Uranium occurs naturally in all rocks and soil with typical background levels ranging
from approximately 2 to 4 mg/kg. Thus, any sample of soil or water from the BFC and
its environs, would have detectable uranium—depending on the chosen analytical
technique. Information on the historical use of DU at the KCP is limited. The single area
where it was known to have been managed has been cleaned to levels below cleanliness
standards that existed at the time of cleaning. Efforts to sample for the presence of
uranium in GSA managed areas at the BFC showed that results were below analytical
detection limits in both dust and air or at low levels indicative of background
concentrations. In the unlikely event that DU was buried at the BFC; the geochemical
conditions of the groundwater ensure that it could not migrate from the burial area.
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Figure 7.2
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7.2
Beryllium at the BFC
7.2.1 Beryllium History and Use
Beryllium is a silver-gray metallic element that occurs naturally in about 30 minerals. Minerals
containing beryllium are found in rocks, coal, oil, soil, and volcanic dust. From these sources,
beryllium is emitted into the air and water by natural processes, such as erosion, and by the
burning of coal and oil.
Beryllium was discovered in 1798, but was not widely used in industry until the 1940s and
1950s. Since then, beryllium metal has been produced for various industrial uses to strengthen
other metals. As an industrial material, beryllium possesses some uncommon qualities, such as
its ability to withstand extreme heat, remain stable over a wide range of temperatures, and
function as an excellent thermal conductor.
7.2.2 Concentrations in the Environment and Risks
The following discussion is taken from the publication Toxicological Profile for Beryllium, U.S.
Department of Health and Human Services, Public Health Service, Agency for Toxic Substances
and Disease Registry, September 2002 (ATSDR 2002).
Beryllium becomes a health hazard when particles of the metal become airborne in the form of
dusts, mists or fumes that can be inhaled.
Inhalation of beryllium particles can result in
beryllium sensitization (allergic reaction) which can led to chronic beryllium disease. It is the
worker health based risks that are of primary concern.
Beryllium is an extremely lightweight metal that occurs naturally in rocks, coal, soil, and
volcanic dust. Commercially, bertrandite and beryl ore are mined for the recovery of beryllium.
Because beryllium is one of the lightest metal and is very rigid, it has many uses in the
electronics, aerospace, and defense industries. Beryllium is released into the atmosphere by
windblown dust, volcanic particles, and the combustion of coal and fuel oil. Beryllium
particulates in the atmosphere will settle out or be removed by precipitation. The annual average
concentration of beryllium in ambient air in the United States is typically below the detection
3
limit of 0.03 ng/m . Beryllium concentration in urban air is usually higher due primarily to
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burning of coal and fuel oil; for example, the annual average concentrations in 1982–1992
3
ranged from 0.02 to 0.2 ng/m in Detroit, Michigan. Beryllium can be released into waterways by
the weathering of soil and rocks. Beryllium entering surface water bodies and soil will be
retained in the sediment and soil and will be generally immobile. The average concentration of
beryllium in drinking water samples that were found to contain it was 190 ng/L. The mean
concentration of beryllium in soil in the United States is 0.6 mg/kg. Beryllium enters the air,
water and soil as a result of natural processes and human activities. It occurs naturally in the
environment in small amounts. The drinking water maximum contaminant level (MCL) for
Beryllium is 4 ppb. It is also naturally present in various foods, with a median concentration of
22.5 μg/kg reported across 38 different food types, ranging from less than 0.1 μg/kg to 2,200
μg/kg (in kidney beans). One cigarette contains about 0.5 to 0.7 μg beryllium, with about 2 to
10% found in the cigarette smoke.
Beryllium is naturally emitted to the atmosphere by windblown dusts and volcanic particles. The
major anthropogenic emission source to the environment is the combustion of coal and fuel oil,
which releases particulates and fly ash that contain beryllium into the atmosphere. Other
anthropogenic processes, such as ore processing, metal fabrication, beryllium oxide production
and use, and municipal waste combustion, release only a fraction of the amounts emitted from
coal and oil combustion. Beryllium naturally enters waterways through the weathering of rocks
and soils. The sources of anthropogenic release of beryllium to surface waters include treated
waste water effluents from beryllium or related industries and the runoff from berylliumcontaining waste sites. Deposition of atmospheric beryllium aerosols from both natural and
anthropogenic sources is also a source of beryllium in surface waters. Some beryllium
compounds are naturally present in soil, but the concentration of beryllium in localized soils can
be increased because of the disposal of coal ash, municipal combustor ash, industrial wastes that
contain beryllium, and deposition of atmospheric aerosols.
Beryllium is found in the soil within the Kansas City area to be approximately 1 part per million
(ppm) by mass. Average beryllium concentrations in shallow soil at the BFC are approximately
0.7 mg/kg based on review of BFC historical sampling data.
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7.2.3 Use at the KCP/Sampling at the BFC
The following discussion related to worker exposure controls is provided as a means of showing
the controls implemented to minimize exposure to workers at the KCP also ensure releases
beyond the facility to the public and the environment are also negated.
Typically, the beryllium-copper alloys used at the KCP contain 1.8% to 2% beryllium to add
strength to the alloy. These alloys are machined into different products under wet (flood
coolant) conditions to capture related dust and particles. However, after machining, the products
often required manually performed dry abrasion operations, such as deburring, lapping,
resurfacing and polishing, to remove blemishes on the machined surface. Although two different
pure beryllium metal components have been used at the Kansas City Plant, both products were
government-furnished components that were placed in assemblies without machining, cutting, or
grinding operations, therefore creating no airborne hazard.
On February 10, 1961, the Kansas City Plant established procedures for setting up an area to
machine beryllium alloys; however, the first record of actual machining does not occur until
1963. Use of beryllium at the Kansas City Plant is the result of using DOE/NNSA specified
parts. The Kansas City Plant has never machined pure beryllium or used significant amounts of
pure beryllium but it has been a continuous user of beryllium in the form of metallic alloys and
ceramic compounds since the early 1960s.
Beryllium becomes a health hazard when particulates become airborne in respirable dusts, mists,
or fumes. As of 2010, 14 KCP activities involved beryllium, which is a hazardous material. The
KCP has implemented a Chronic Beryllium Disease Prevention Program (CBDPP) to reduce the
number of worker exposures from beryllium and to minimize the potential for exposure. The
program includes routine surface and air sampling in beryllium processing areas, work
authorization permits that establish specific controls for beryllium processing for a specified
period, beryllium characterization and cleanup, medical surveillance to ensure early detection of
precursor conditions, and beryllium sensitization. The Kansas City Plant’s CBDPP addresses
both airborne and surface contamination. The CBDPP applies to all processes that use
beryllium, beryllium alloys, or beryllium compounds in a manner that could result in airborne
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exposure. It also applies to all equipment and areas that may be contaminated with beryllium
from past processes. In the event that a new process is initiated at the KCP or an existing process
is modified so that the process would involve activities outside of the scope of the approved
CBDPP, the process will not be allowed to begin until the CBDPP is modified and approved by
DOE.
A KCP Action Level is established at 0.1 ug/m3 for detectable concentrations of airborne
beryllium. If personal air monitoring reveals detectable airborne beryllium in excess of the KCP
Action Level, the KCP will stop the process until controls can be implemented to reduce
exposure to below the KCP Action Level. Note: In some monitoring cases, due to the short
duration of many KCP processes, the calculated actual exposure may yield a value of “< n
ug/m3“where n is greater than 0.1. In these cases, exposure will not be considered to have
exceeded the KCP Action Level since no beryllium was detected in the sample (above the
detection limit of the analytical method). The OSHA permissible exposure limit based on an
eight hour time weighted average (TWA) is 2 µg/m3. The American Conference of
Governmental Hygienists (ACGIH) TLV is 0.00005 mg/m3 or 0.05 µg/ m3.
KCP Housekeeping Goal for all plant areas is 1 ug/100cm2. Note: Note: Active beryllium
Designated Areas may exceed this level while processing beryllium. Once processing is
completed, the area must be cleaned, and verified to meet the DOE Housekeeping Limit, prior to
deactivating the Designated Area. Verification includes collecting surface samples on the
equipment used to process beryllium, other surfaces within the Designated Area, and surfaces
outside the Designated Area to ensure contamination does not migrate to other areas of the plant.
While the DOE Housekeeping Limit must be achieved prior to deactivating the Designated Area,
the KCP Housekeeping
850.11 General CBDPP requirements. The CBDPP covers processes similar to those that may
occur in general industry and include: machining, deburring, cleaning, welding, plating, physical
testing, destructive testing, manufacturing, and other related activities (that are more specifically
detailed in departmental Chemical Safety Plans (CSP) for Chemicals Including Carcinogens. In
addition to the industrial activities, construction and demolition work is performed in areas
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where beryllium work has occurred. Decontamination of equipment and areas is also performed.
The elements of the CBDPP have, to the extent possible, been incorporated into health and safety
programs that are already in existence. These programs and this CBDPP (especially baseline
inventory, hazard assessment, and monitoring) are managed by qualified individuals who have
sufficient knowledge and experience to perform the activities. Routine processes have CSPs and
JHAs that identify hazards and the necessary controls to perform those processes safely.
Nonroutine processes follow good work planning and control methodology. New or modified
processes are addressed through the KCP’s Management of Change process. In general, the
intent of the CBDPP is to:
1. Include formal plans and measures for maintaining exposures to beryllium at or below
the permissible exposure level prescribed in 850.22;
2. Satisfy each requirement in Subpart C of 10 CFR 850, and
3. Contain provisions for:
a. Minimizing the number of workers exposed and potentially exposed to beryllium,
b. Minimizing the number of opportunities for workers to be exposed to beryllium,
c. Minimizing the disability and lost work time of workers due to chronic beryllium
disease, beryllium sensitization, and associated medical care, and
d. Setting specific exposure reduction and minimization goals that are appropriate
for the beryllium activities covered by the CBDPP to further reduce exposure
below the permissible exposure limit prescribed in 850.22.
The DOE CBDPP addresses the following requirements: baseline beryllium inventory, hazard
assessment, Permissible Exposure Limit, Action Level, exposure monitoring, exposure reduction
and minimization, regulated areas, hygiene facilities and practices, respiratory protection,
protective clothing and equipment, housekeeping, release criteria, waste disposal, beryllium
emergencies, medical surveillance, medical removal, medical consent, training and counseling,
warning signs and labels, recordkeeping and use of information, and performance feedback.
Many of these requirements are not unique to beryllium but are part of base industrial hygiene
programs at the KCP.
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The KCP takes precautions to reduce worker exposure to airborne beryllium to a concentration
not only below the Occupational Safety and Health Administration (OSHA) Permissible
Exposure Limit (PEL), the DOE action level, and the KCP action level but also to a
concentration as low as reasonably practical. In addition, the KCP tries to minimize the
opportunities for exposure. This includes minimizing surface contamination and the spread of
contamination, limiting the number of current beryllium workers, and restricting access to
Designated Beryllium Work Areas.
During CY 2000, the KCP characterized the entire plant for beryllium surface contamination.
This characterization included review of historical records, plant-wide departmental surveys of
current beryllium operations, interviews of current and past employees, and collection of air and
surface samples. The KCP used the results of the characterization survey as well as other data,
such as medical surveillance trends and current beryllium processes to perform a hazard
assessment. Priority was given to current processes since these processes offered the greatest
opportunity for exposure. Legacy areas were addressed based on their residual contamination. In
2000, twenty-one departments processed beryllium in a way that generated particles. The
processes in these departments have been evaluated and Chemical Carcinogen Safety Plans
(CSPs) written to address the hazards and to ensure that the tasks can be performed safely.
The CY 2000 plant-wide surface contamination characterization survey identified sixteen areas
that exceeded the DOE housekeeping limit of 3 ug/100cm2. These areas were cleaned (where
feasible) and verification samples collected to ensure that the housekeeping limit was met.
A second plant-wide characterization survey was conducted in 2003 to verify the results of the
first survey, ensure that no areas of contamination were missed in the first survey, and to ensure
that operating controls were preventing contamination migration for active beryllium processing
areas. In 2009, all but three of the areas that were found to have surface contamination above the
Housekeeping limit (>3 ug/100cm2) have been cleaned.. These areas will be cleaned once this is
economically and technically feasible.
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Hazardous material controls, established in compliance with Atomic Energy Commission (AEC),
DOE, EPA, and OSHA regulations, are in place to ensure proper management of beryllium at the
KCP. The BFC does not emit beryllium into the air or discharge it into groundwater,
surrounding streams or rivers. Although not required by regulation, all beryllium waste, as well
as the filters and cleaning materials used to collect it at the DOE KCP, are shipped to a special
hazardous waste landfill for disposal.
Also in January 2000, the DOE established an aggressive expectation for cleaning any residual
surface contamination at its facilities by issuing a standard requiring its facilities to develop an
implementation plan to baseline surface contamination and clean surfaces in all present and
former beryllium processing areas to no more than three micrograms per 100 square centimeters
(3 ug/100 cm2). This expectation applies to beryllium processing areas that are in operation.
Prior to January 2000, no U.S. standards for beryllium surface contamination existed. The DOE
was the first government agency to set a surface standard. To this day, OSHA has not set a
surface contamination standard for other industries. These standards prescribed for workers.
According to data collected by the EPA, the average concentration of airborne beryllium in the
United States is very small (0.03 nanogram/cubic meter - a nanogram is one-billionth of a gram).
7.2.4 GSA Sampling for Beryllium
In 2011 GSA sampled for beryllium in three locations. Q19, F25, Roof ECAI. All three results
were ND with a detection limit of 1 µg.
As requested, OCCU-TEC conducted air and surface sampling for the presence of uranium
oxide, beryllium as well as six other metals at Building #1 of the Bannister Federal Complex,
Missouri.
The assessment included the following:
•
Air sampling for Uranium Oxide, Beryllium, Lead, Zinc, Antimony, Manganese, Copper
and Iron
•
Wipe sampling for Uranium Oxide, Beryllium, Lead, Zinc, Antimony, Manganese,
Copper and Iron
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•
Air sampling for metals was conducted at nine distinct locations within Building #1.
Dust wipe sampling for metals was conducted on horizontal surfaces from 29 distinct locations
throughout the building. Mechanical spaces, offices, and common areas were selected for
sampling. . Each wipe sample was collected from a 10 x 10 cm area. The horizontal surfaces
selected for sampling consisted of areas that appeared to have consistent dust distribution. Areas
not subject to regular cleaning were selected when available. Surfaces included: floors, nonmetal shelving, and other nonmetal surfaces. All beryllium results from the air sampling for
metals were below the method detection limit for indoor air sampling of Beryllium. Wipe
sampling results were below the analytical detection limit of Beryllium < 0.05 μg/100 cm2.
Sampling by GSA in 2011 for beryllium included an analysis for the compound yttrium. DOE
has historically machined beryllium that does not contain yttrium. It was believed that a high
beryllium to yttrium ratio (i.e., an absence of yttrium) would indicate a manmade source of
beryllium in the dust inside the buildings while dust containing both beryllium and yttrium
would be indicative of dust derived from natural soil. Based on results of sampling for beryllium
and yttrium in GSA managed portions of Buildings 1 and 2 (MMB) in August 2011 dust samples
were consistent with concentrations of beryllium and yttrium in Missouri soils (Terracon 2012).
VA Sampling
As requested, OCCU-TEC conducted air and surface sampling for the presence of beryllium as
well as 12 other metals at the VA leased space, located on the Mall Level of Building #1 at the
Bannister Federal Complex in Kansas City, Missouri. Substantial concern has been expressed by
occupants in the Bannister Federal Complex regarding the potential for exposures to these
materials based on the historical use of the premises. Therefore, VA commissioned this sampling
event to address those concerns. Air and surface sampling was conducted to determine the
current levels of airborne and surface concentrations of these metals. The sampling was
conducted on April 20, 2010, by Mr. Jeff Smith of OCCU-TEC.
Air sampling for metals was conducted at four distinct locations within the VA Space. In
summary, all air sample and surface dust sampling results resulted in concentrations less than the
laboratory’s reporting limit.
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7.2.5 2009 Beryllium Exposure Assessment
In December 2009, the U.S. Public Health Service, Federal Occupational Health (USPHS/FOH)
received a request from the Federal Emergency Management Agency (FEMA) to conduct air and
surface sampling for beryllium and other metals at the Bannister Federal Complex located at
1500 East Bannister Road in Kansas City, MO. The evaluation was conducted in response to
concerns about potential exposure to beryllium dust which is present in small percentages of
metals used by the Department of Energy (DOE). The DOE is also located in the Bannister
Federal Complex.
All of the air sample concentrations were below the Occupational Safety and Health
Administration (OSHA) Permissible Exposure Limits (PELs) and the American Conference of
Governmental Industrial Hygienist (AGGIH) Threshold Limit Values (TLVs). Beryllium,
cadmium, copper, chromium, nickel, cobalt, iron, and manganese were all less than 0.01
milligrams per cubic meter (mg/m3) of air. All surface sample concentrations for beryllium
were less than 0.000025 ug/100 cm2). Sampling was conducted in 2002 at GSA for Be in a
number of locations. All results were below detection limits.
7.2.6 Future Potential Releases
Should buildings at the BFC be removed as a part of redevelopment activities precautions must
be taken to address the potential airborne release of beryllium and its effects on workers and
individual living in the area from airborne dust.
No actual or potential impacts to the environment are expected from past or current use of
beryllium containing alloys at the DOE KCP. Beryllium concentrations used at the site were
extremely low and precautions were taken historically and, to a greater extent, since 2000 to
prevent emissions.
The background soil concentrations in soil samples collected at the BFC are approximately 0.7
mg/kg. Impacts from the BFC to a degree that would affect the background concentrations are
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extremely unlikely This issue will be addressed in greater detail as part of the baseline
assessment for the BFC that will be prepared in the near future.
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