LANL Legacy Waste Cleanup Contractor Under Self-Imposed Stop Work Since October 13

N3B Los Alamos President and Program Manager Kim Lebak speaks at Wednesday’s EM-LA Community Forum at Fuller Lodge. Photo by Maire O’Neill


Department of Energy Environmental Management Los Alamos Field Office Manager Michael Mikolanis told attendees Wednesday at a community forum at Fuller Lodge that DOE supports N3B’s proactive decision October 13 to initiate a stop work at LANL. He said the stop work was put in place to ensure the safety of workers and high quality outcomes of the LANL legacy waste cleanup.

“This stop work allows us to continue to demonstrate that we emphasize safety as our top priority as we do our mission,” Mikolanis said.

He said the stop work was a proactive decision from N3B leadership to enable an evaluation of their operations and to conduct a management review in oversight of all the work that’s being performed in the field.

“The Department of Energy places a high value on ensuring that our contractors continually assess operations and proactively take actions to address issues or trends and I’m really proud of Kim Lebak and her N3B leadership team in identifying this trend proactively and taking this affirmative action to look over the enterprise, take a time out like this and address the issues and trends that they are seeing in the field. In this case, N3B chose to stop work and reassess the formality within their operations,” Mikolanis said.

He said in this case a stop work means N3B will continue to operate in a “minimum safe, minimum compliance”, in terms of the safety bases and regulatory permits and commitments EM-LA has with the state for environmental and nuclear operations for its work.

The Los Alamos Reporter sat down with Lebak earlier this week. She is the President and Program Manager for N3B Los Alamos. Lebak said N3B stopped field work on October 13.

“We had basically been seeing a series of events that we wanted to look into further and it’s not just individually that we will be looking at the events but in a collective manner. Putting a field stop work in place would let us do that in a methodical fashion,” she said.

Lebak gave examples of safety issues N3B having. One was a head bump where somebody was getting into a Polaris vehicle and cracked their head against the vehicle.

“We had also had a couple of other head bumps in probably the last six months. One was a worker who hit their head on a desk-type cabinet in an office space, and one was another field activity involving a truck bed. We also had an employee out taking environmental samples and they lost their footing and they landed in a cactus and had the splines in their arms,” Lebak said. “These are some of the things we had. We had an environmental sample being taken and the work required a long-sleeved shirt and a nitrile glove. The employee had both and there was like a 4ml acid sample preservative that splashed right between the glove and the sleeve.”

She said the company has also had some vehicle issues this year – mainly obstructing stationary objects or a piece of heavy equipment striking a stationary object.

“Those are a couple of other things that we pursued particularly earlier in the year. Many of these activities are on the order of scrapes and not like a total damage to the vehicle but we look at those as smaller things. We realized we were having a series of these operational events and we needed to stop and take a full look at what we’re doing,” Lebak said.

She said the stop work process includes chartering a team to review policies, processes, procedures, training and in this case the company brought in some outside experts to help.

“We get in a conference room and we pull out the procedure, the job hazard analysis, the training records and then we have a representative sample of workers in the room. If the work involves radiological hazards we have our radiological control technicians there. We may have our person in charge that we call the PIC and we say, ‘Walk us through this activity”. So we walk through and talk through the hazards, the procedures in place. We pull up the training records real time and then we have this chartered committee and if we’re satisfied with the discussion and the objective evidence we see on the training records and the supporting documentation, we’ll release the activity to go back to work,” Lebak said.

She said the activity is cleared if the team believes they have the underpinning documentation of training and they’re demonstrating their situational awareness of the activity. If gaps are found they are documented and it is determined if they are gaps that need to be closed immediately before work resumes.

“My estimate is that we will have gone through all the activities by Nov. 2-4,” Lebak said.

As of Wednesday, some 50 percent of the environmental remediation activities and waste operations had been released and Lebak said they will keep going with the reviewing process until they knock it out.

 “I don’t want even a paper cut. I don’t want anything. I want everybody to go home the same way they came to work and so it’s a process that we need to reinforce with our workers, we need to talk about it, we need to enforce it, we need to do whatever we can to make safety their top priority and our slogan is, ‘Safety first, safety always’. We have been deviating from that by these incidents so we needed to delve into them further. We are making progress,” Lebak said.

She said N3B stood down its field work but remained in what’s called a “min-safe, min-compliant” posture.

“We are doing our regulatory inspections, our waste inspections, we’re operating our hexavalent chromium plant in Mortendad Canyon and we have used this term ‘min-safe, min-compliant’ when we were in COVID and when we were in the fire last spring and those are the minimum speed of activities that we feel are necessary to maintain our regulatory compliance,” Lebak said. “The waste preparation and shipment activities were stopped but we have four waste activities that we have resumed and waste shipping for transuranic waste has been authorized to resume. We still need to review our mixed and low-level waste activities and that’s on our docket.”

She said there will be minimal impact on shipping because that operation was down for a very short period.

“We really feel like if we see issues that are coming up we need to investigate them so our workforce needs to understand that when things are going well, we still check, but when we see indicators that we need to look further we will pause or stop and do what we need to do. We have our pause and stop policy procedure and any employee at N3B can pause or stop work. It’s just part of our business and so a stop work, it sounds ominous but we are working through it in a methodical manner, we’re communicating with our employees and if we need to do this again in 13 months, we’ll do it again in 13 months,” Lebak said.

She said a stop work is a judgment call.

 “You don’t want to get to where you’re thinking you should have done it three months ago. I got together with my senior team and we talked about some of our indicators and the senior team all was in agreement,” Lebak said.

The Reporter asked Lebak about an early in September involving the Corrugated Metal Pipe project (separate story on CMPs to some) where a crew was engaged in digging up one of the pipes.

“The objective was to dig it up, put it in a protective bag and then take it to another pad. They started the operation and they kept working. We had a crew out there including a couple of radiological technicians, a person in charge, a couple of operators, a person in the excavator, a spotter, a safety rep and a management rep. So the crew kept working and they kept digging on the pipe and towards the end of that particular operation they did see a bit of crumbling of the ends of the pipe that they wanted to look at further and so they eventually paused that job. But the crew did not practice good work/rest regimen. They kept working and one of the workers in the crew experienced heat illness,” Lebak said.

She noted that 911 was called and provided ice, Gatorade and fluids to the individual. Los Alamos Fire Department showed up and the individual was treated on the scene.

“The individual came back to the next shift, so the individual was treated on the scene and went home. The individual felt well enough to drive himself home and they returned to the next shift,” Lebak said.

She noted that she looked at this as an extremely serious event because “heat illness can start with cramps, go into exhaustion, dehydration and then heat stroke which is very serious”.

“We declared an event through our event notification process on September 8. We also later performed a fact-finding. We are in the root cause analysis right now. We reported it through another mechanism in the DOE Headquarters system. We are going through our process on this event. We brought in outside experts to participate in the root cause analysis – people from our parent companies who worked in Department of Energy and Department of Defense type activities. That job was paused or stopped. It has not continued since September 8 and it has to go back through our processes that we’re going through now,” Lebak said.