Potential Inadequacies Of Safety Analyses Situation At LANL Improves With 17 PISAs Reviewed And Resolved


Joe Legare, vice president of N3B, the legacy waste cleanup contractor at Los Alamos National Laboratory, had some good news to share with the Los Alamos Reporter last week concerning the amount of waste the company has shipped from LANL in the first three years of its contract and the resolution of 17 of the Potential Inadequacies of the Safety Analyses (PISAs) that have been restricting work at TA-54’s Area G.

Legare, who always stresses N3B’s focus on shipping out LANL waste, said any day a waste drum leaves the site is a good day.

“Let’s get it off the mesa top. Every drum that leaves is one less drum that’s at risk for a fire or a breach,” he said. “I don’t think people realize how much waste we’ve shipped. We’ve shipped almost 10,000 cubic meters of material since we started this contract from Technical Area 54, TA-21 and the Aggregate Areas, as well as remediation soils and transition materials in the first three years of our contract. An Olympic swimming is 2,500 cubic meters so a lot of waste has been dispositioned.”

On the transuranic waste side, N3B has made 50 shipments and is way ahead of what the company had proposed to do. Legare said the next shipment is in the queue and ready to go and that the company is continuing waste mining.

“We have waste in the domes and we have a database that tells us what waste is where. We work to not move drums any more often than we need to. We give the Waste Isolation Pilot Plant in Carlsbad the payload information and they make sure it complies with all their criteria, the weight, the size etc., he said.

Legare noted that a lot more waste has been shipped this year than last year and that this summer N3B is working on readiness for the next processing line in Dome 231. He said his teams are analyzing waste continually to have new drums ready for shipment.

“We are also shipping lots of low-level waste, mixed low-level waste and remediation waste. We’ve made more than 450 shipments since we started on this contract and we’re getting close to 500 shipments. That’s a tremendous amount of activity,” he said.

Legare also announced that 17 PISAs connected to TA-54 have been reviewed and resolved. The PISA process is part of the Department of Energy’s overall unreviewed safety question process under the Code of Federal Regulations to ensure that DOE contractors take proper action when they become aware that a safety analysis for a nuclear facility may not be adequate.

Legare acknowledged that quite a few issues were identified, particularly by the contractor’s engineers, many of whom come from the shipbuilding environment where N3B’s parent company installs nuclear reactors.

“They’re trained to go hunt out issues and make sure that we’re operating safely. So they did identify issues. Many of those, the lion’s share, were re-submitted in an Evaluation of the Safety of the Situation Report to DOE that was approved just a couple of weeks ago and 17 PISAs have been reviewed and approved,” he said.” We still have a next step which is what controls will you put in place – called Justification for Continuing Operations (JCOs).”

Legare said while the PISAs were open a process called the “Situation Room” was implemented where N3B meets and collaborates with DOE daily on activities the company intends to perform.

“This gives us the benefit of operations and nuclear safety folks from all the parties asking, ‘Did you think of this, did you think of that, is it safe to proceed?’. And we’ve had an outstanding track record of approving work on a weekly basis. In fact the last five shipments to WIPP were approved through this process,” he said. “This Situation Room has improved collaboration and has picked up the pace of operations. It has allowed us to process and ship waste off site despite the PISAs. It’s been quite a success story.”

Legare noted that there has been some corporate reach-back by N3B involved and DOE Headquarters have been involved. There are still a few out there that impact operations and those are in that same process of submitting the report and writing the JCO. The resolution of 17 PISAs will enable N3B to get to readiness on Dome 231, Legare said.

“It doesn’t connote readiness but what it says is you’re now ready to be reviewed. Once the JCOs are in place, we’ll be able to have the federal readiness review and get that process going. Our workers are trained up. We did the contractor readiness review during the fourth quarter of the calendar year and we’ve been working through these PISAs. What these PISAs represent are gaps in analysis, not unsafe conditions. We would not operate if we thought we were unsafe. They’re gaps in analysis and that’s what the whole process is about,” Legare said.

In terms of environmental remediation, he said N3B has been working on the Southern External Boundaries Campaign which involves characterization and remediation at multiple Aggregate Areas.  

N3B is also implementing the Preliminary Screening Plan approved by the New Mexico Environment Department for cleanup on the Middle DP Road project where contaminated materials were discovered last year on property previously transferred to Los Alamos County.

“We’re poking the holes and surveying out there and we’ll finish up that work this summer so that we can turn that property back over to the County and their contractor,” Legare said.

On the hexavalent chromium plume project, Legare said N3B continues to operate injection and extraction wells as the project heads towards the final remedy stage.

“DOE has not submitted a formal proposal to NMED. Conceptually what we’re seeing, based on the modeling and the sampling results is that while there were many options long-term for chromium It seems like there’s one that’s effective and that’s extraction, treatment, reinjection”,  he said.

Meanwhile N3B and EM-LA are hosting a virtual community meeting from 5:30 p.m. to 7:30 p.m., Thursday, June 24, using the WebEx platform to discuss their mission at LANL including recent progress and future cleanup priorities. There will be an opportunity for community members to ask questions. For meeting information including login details, visit www.n3b-la.com/outreach.

N3B And Department Of Energy/EM-LA To Hold Virtual Environmental Management Cleanup Forum June 24

N3B And Department Of Energy/EM-LA To Hold Virtual Environmental Management Cleanup Forum June 24