N3B-AP-ER-1001.pdf

N3B-AP-ER-1001, R0

Environmental Remediation Project Preparedness Review

Effective Date: 5/21/19

Next Review Date: 5/21/22

Hazard Class: Low Moderate High/Complex Usage Mode: Reference UET Both UET & Reference

The Responsible Manager has determined that the following organizations’ review is required for initial procedure release as well as subsequent major revisions. Review documentation is contained in the Document History File.

ER Operations Engineering Technical Leads Safety Environmental Compliance Quality Assurance Environmental Programs Training

Classification Review: Unclassified UCNI Classified

Ernest Elliott / 135267 / Signature on File / 5/6/19 Name (print) Z# Signature Date

Responsible Manager, Division and Title

Troy Thomson / 328681 / Signature on File / 5/21/19 Name (print) Z# Signature Date

Working Copy / Information Only (circle one) Initials / Date: /

RFP-0000476

Environmental Remediation Document No.: N3B-AP-ER-1001 Project Preparedness Review Revision: 0 Effective Date: 5/21/19 Reference Page: 2 of 25

REVISION HISTORY

Document No./Revision No. Effective Date Action Description

ER-AP-20272, R0 10/7/2015 New • Incorporated IPC-1 form 20001.

• Renumbered according to organizational changes.

• Edited Attachment 1

• Supersedes EP-DIV-GUIDE-

20001, STR/Field Services Guideline for Field Activity Readiness and EP-DIV-AP- 10009, Readiness Checklist for Associate Directorate for Environmental Program Projects

N3B-AP-ER-1001, R0 5/21/2019 Major • Updated references and technical content, and aligned with new N3B processes. New number assigned and title change. This document supercedes blue sheeted ER-AP-20272.

Reference Page: 3 of 25

TABLE OF CONTENTS

Section Page

TITLE PAGE

CHANGE SUMMARY

TABLE OF CONTENTS

1. PURPOSE

2. SCOPE

3. RESPONSIBILITIES

4. PRECAUTIONS AND LIMITATIONS

5. DEFINITIONS AND ABBREVIATIONS

5.1 Definitions

5.2 Acronyms

6. PROJECT PREPAREDNESS REVIEW PROCESS

7. RECORDS PROCESSING

8. REFERENCES

9. ATTACHMENTS

Attachments

Attachment 1, Project Review Checklist Attachment 2, Incomplete/Open Items List Attachment 3, Project Approval and Concurrence Form

Effective Date: 5/21/19 Reference Page: 4 of 25

1. PURPOSE

The purpose of this procedure is to ensure a thorough review is performed of N3B Environmental Remediation (ER) Program activities, either self-performed or subcontracted, prior to authorizing work on the ER Plan of the Day (POD). This document is used in the upfront planning of fieldwork and project execution.

2. SCOPE

This procedure applies to N3B ER Program fieldwork activities and is used by Integrated Project Team (IPT) members to demonstrate preparedness to initiate fieldwork. This process intends to effectively execute environmental fieldwork in compliance with all applicable permitting and notification requirements, while minimizing safety risks and environmental impacts.

Additional, more rigorous requirements or reviews (e.g., Management Self-Assessments or Federal Readiness Assessments) may be required for activities outside the typical ER scope of fieldwork, to be determined by Operations Director or Project Manager (PM).

The need to complete Attachment 1, Project Preparedness Checklist will be assessed for all field activities meeting any of the following conditions:

▪ New work scope or work that has been modified from previously approved scope

▪ Existing work that has not been through review

▪ Work that is being re-started after a pause work or stop work for safety or health reasons

Routine activities (e.g., groundwater sampling, routine maintenance, etc.) may undergo project preparedness review, though it may not be required. Need for a project preparedness review is determined by PMs with concurrence from the Operations Director.

All applicable areas must be verified as adequate/satisfactory and approved by the Operations Manager (OM)/Construction Manager (CM) and Program Director before field activities can begin. Documents reviewed for this verification must be complete (e.g., approval signatures, correct references, and attachments). Pre-start issues shall be identified in the comments section of Attachment 1, Project Preparedness Checklist during the review meeting and shall be resolved before work is authorized. Post-start decision dates and issues shall be defined in the comments section of the Project Preparedness Checklist at the review meeting. Post-start issues shall be resolved by the date decided at the review meeting and before the associated activity commences.

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3. RESPONSIBILITIES

Operations Manager (OM)/Construction Manager (CM): Reviews work control documents and authorizes ER fieldwork to provide assurance that applicable regulatory requirements, procedures, policy, training, Operational Control and Access Agreements are fully implemented. Documents the review and authorization of fieldwork by signing Integrated Work Documents (IWDs) and work control documents. Reviews work control documents to ensure the following:

▪ Work is appropriate to be conducted, and work area hazards are addressed

▪ Activity is within scope of the facility safety basis (e.g., Nuclear Environmental Sites

[NES])

▪ Safety management programs have been fully implemented through hazard identification and the use of appropriate controls

▪ Appropriate subject matter expert (SME) reviews have been completed

Project Manager (PM): The PM leads a cross-functional group of IPT members, assembled to successfully execute a set of project objectives. The PM must ensure project objectives safely meet the Project Owner’s requirements and are fulfilled within cost and schedule constraints.

PM implements and completes the N3B-P351, Project Planning and Regulatory Review procedure requirements and solicits input from all required SMEs. Defines work in sufficient detail to assess safety, security, and environmental compliance risks. Submits records generated by this procedure in accordance with N3B-P1020-1, N3B Records Management.

Responsible Manager (RM) or Responsible Line Manager (RLM)/designee: The RM/RLM is the manager or equivalent subcontractor line manager having the responsibility, authority, and accountability to plan, validate, coordinate, approve, execute, and close out work activities in accordance with Integrated Work Management (IWM) (see N3B-P300, Integrated Work Management).

▪ Ensures work is defined in sufficient detail to assess safety, security and environmental compliance risk.

▪ Identifies, analyzes, and grades work and environmental hazards to determine IWM and environmental work control requirements.

▪ Establishes effective controls to reduce risks to an acceptable level and documents work in IWDs and work control documents so that workers understand when and how they are to be used.

▪ Ensures all applicable SMEs have reviewed and signed the IWD

▪ Ensures the workers possess the knowledge, skills, abilities, and training required to handle the hazards and effectively use the proposed controls.

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3. RESPONSIBILITIES (continued)

Shift Operations Manager (SOM): The manager representing the Operations group that coordinates work in their respective project areas and ensures that all planned work is added to the POD for authorization by the OM or CM. SOMs are included in project planning and provide technical input to the N3B-P351, Project Planning and Regulatory Review) and the project preparedness review processes. SOMs help determine project preparedness including permitting, operational control, Facility Operations Director (FOD) requirements, and any necessary support by ER craft and equipment.

Subcontract Technical Representative (STR): An individual appointed to provide technical and administrative field management of the subcontract and all lower tiered subcontractors.

Subject Matter Expert (SME): An individual identified as being competent in a specific functional area and within their respective discipline. SME involvement may be specifically mandated by other requirements, or may be indicated because of desirable expertise relative to the nature of the work.

▪ Engineering & Nuclear Safety: Designated organizational expert representing the engineering organization that provides input on engineering requirements and controls and radiological safety concerns associated with projects during planning and execution.

▪ Environment, Safety, & Health (ES&H): Designated organizational expert representing N3B core safety programs (e.g., industrial hygienists, environmental protection, occupational safety, ES&H support, etc.). Provides input on environmental requirements, pollution prevention, the Environmental Management System (EMS), and environmental stewardship issues. Provides professional level guidance to reduce overall environmental risk

▪ Radiological Protection: Designated organizational expert representing the radiological control team that provides input on radiological safety and project preparedness throughout planning and execution of the project. Develops Radiological Work Permit (RWP) for completing radiological work.

▪ Regulatory & Stakeholder Interface (R&SI): Designated organizational expert representing the regulatory compliance organization that provides input on regulatory and permitting requirements involved in project planning and execution.

▪ Technical: Independent technical expert who has knowledge relevant to the hazards involved in the work.

▪ Waste Management: Designated organizational expert representing waste management organization in providing input on waste characterization, management, and disposal requirements during planning and execution of the project.

Effective Date: 5/21/19 Reference Page: 7 of 25

4. PRECAUTIONS AND LIMITATIONS

This Project Preparedness Review process must, in all cases, demonstrate there is a reasonable assurance for adequate protection of workers, the public, and the environment, as well as ensure project compliance with applicable N3B, local, state, and federal permitting and policies, requirements, standards, and regulations. The project must have completed all of the prerequisite items identified in the attachments before proceeding to the field. This procedure is not intended for the validation of project technical requirements, constructability, or cost and schedule baselines.

5. DEFINITIONS AND ABBREVIATIONS

5.1 Definitions

Integrated Project Team (IPT): The PM is responsible for establishing and leading an IPT that includes required representatives from various technical disciplines as appropriate for the project scope. The primary function of the IPT is to assist the PM with the planning, staffing, organization, management, and tracking of work activities that produce the required deliverables for the project.

Nuclear Environmental Site (NES): An inactive waste disposal area that has been characterized as a nuclear site based on initial categorization of inventory identifying it as Hazard Category 2 or 3 according to DOE-STD-1027 thresholds.

Post-Start Requirement: An action determined to be a project requirement that must be completed at a pre-determined point during project execution, however does not prevent the project from being initiated before its completion.

Pre-Start Requirement: An action that is determined to be a project requirement and must be completed prior to the project being initiated.

Project Preparedness Checklist: A presentation and review of all relevant project documents and records for the purpose of assessing and determining preparedness to begin field activities.

Safety Envelope: The range of conditions covered by the safety documentation of a process or facility under which safe operation is adequately controlled.

Subcontractor Oversight Plan: A document developed by the PM that provides for recognition and management of Key Activities and High Hazard or Critical Events expected during the performance of the subcontract. It identifies SMEs and their minimum level of involvement in overseeing the performance of the subcontractor to ensure subcontractor compliance with the subcontract.

Effective Date: 5/21/19 Reference Page: 8 of 25

5.1 Definitions (continued)

Validation Walk Down: An on-site documented review of the work area to ensure that work conditions are consistent with the IWD. Includes a review of the tasks and steps to ensure “workability,” that hazards have been identified, and that required controls are in place, operational, and functional.

Work Area Hazard: An ES&H/ Safeguards & Security (S&S) or Radiation Control (RC) hazard specific to the location of a work activity and not a hazard inherent in the activity itself.

Work Authorization: The combination of RM/RLM and ER OM approvals of the activity, accepting that the necessary conditions for the activity to be released and executed are clearly established.

5.2 Acronyms

BMP Best Management Practice CM Construction Manager DOE Department of Energy DOT Department of Transportation DSA Documented Safety Analysis EM-LA Environmental Management – Los Alamos Field Office EPS Environmental Programs/Services ER Environmental Remediation Program ES&H Environment, Safety, & Health ESO Electrical Safety Officer EXID Excavation Permit Identification FIP Field Implementation Plan FOD Facility Operations Director HE High Explosives IP Individual Permit IPT Integrated Project Team ISSM Integrated Safety and Security Management IWD Integrated Work Document IWM Integrated Work Management LAFD Los Alamos Fire Department LANL Los Alamos National Laboratory M&TE Materials and Testing Equipment NA-LA National Nuclear Security Administration – Los Alamos Field Office

Effective Date: 5/21/19 Reference Page: 9 of 25

5.2 Acronyms (continued)

NEPA National Environmental Policy Act NES Nuclear Environmental Site NMED New Mexico Environmental Department OCA Operational Control Agreement OM Operations Manager OPSEC Operations Security OSE Office of the State Engineer PED Portable Electronic Device PIC Person-in-Charge PM Project Manager POD Plan of the Day POW Plan of the Week PRID Permits Requirements Identification R&SI Regulatory and Stakeholder Interface RCT Radiological Control Technician RLM Responsible Line Manager RM Responsible Manager RWP Radiological Work Permit

S&S Safeguards & Security SAWA Service Agreement/Work Authorization

SME Subject Matter Expert SOM Shift Operations Manager SOW Statement of Work STD Standard STR Subcontractor Technical Representative SWPPP Storm Water Pollution Prevention Plan TA Technical Area TSDF Treatment Storage & Disposal Facility TSR Technical Safety Requirement UET Use Every Time USQD Unanswered Safety Question Documentation UXO Unexploded Ordnance WCSF Waste Characterization Strategy Form

Effective Date: 5/21/19 Reference Page: 10 of 25

6. PROJECT PREPAREDNESS REVIEW PROCESS

This Project Preparedness Review process will be conducted utilizing the attachments to this procedure. Documents identified in the attachments will be available for review during the final Project Preparedness Review meeting. The process for conducting Project Preparedness reviews follows these steps:

PM

[1] INITIATE the process by establishing an IPT and providing the project fieldwork execution schedule to the project SOM. For subcontracted projects, a STR Oversight Plan may also be developed.

SOM

[2] ENSURE execution schedule, provided by the PM, is added to the ER 2-month Look Ahead schedule.

PM/STR

[3] ENSURE all SMEs, as identified in the IPT and/or Oversight Plan and in accordance with N3B-P351, Project Planning and Regulatory Review provide review of the sections of Attachment 1, Project Preparedness Checklist that are their assigned responsibility.

Project IPT

[4] COMMUNICATE any lagging actions with the PM to develop appropriate actions to ensure project success.

[5] SCHEDULE a formal Project Preparedness Review meeting, preferably no later than two weeks before fieldwork is scheduled to start.

[6] CONDUCT the Project Preparedness Review meeting and DISCUSS identified items.

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6. PROJECT PREPAREDNESS REVIEW PROCESS (continued)

NOTE Assigned SMEs identified in the IPT and required to sign approval must attend the project preparedness review meeting unless arrangements are made in advance for a pre-meeting approval signature.

Assigned SMEs

[7] ATTEND the project preparedness Review and STATUS required activities as complete, with any necessary documentation, or as a Pre-Start or Post-Start activity with the expected completion time.

OM/CM

[8] Once the project preparedness Review process has been completed, PROVIDE work authorization and SCHEDULE the work on the POD.

[9] IF a change in work scope or conditions occurs, THEN ASSESS the need for a new project preparedness review.

7. RECORDS PROCESSING

[1] ENSURE that documents generated by the performance of this procedure are processed as follows:

Record Identification Record Type Determination

Protection/Storage Methods Processing Instructions

Attachment 1, Project Preparedness Checklist

Attachment 2, Incomplete/Open Items List

Attachment 3, Concurrence Form

QA Records Supervision SHALL implement a reasonable level of protection to prevent loss and degradation. In-process records SHALL be maintained in a metal file cabinet when not in use.

When the records are ready for final disposition, the record is transferred to Records Management in accordance with N3B-P1020-1, N3B Records Management

Effective Date: 5/21/19 Reference Page: 12 of 25

8. REFERENCES

N3B-P300, Integrated Work Management

N3B-P351, Project Planning and Regulatory Review

N3B-P1020-1, N3B Records Management

N3B-SD400, Environmental Protection

9. ATTACHMENTS

Attachment 1, Project Preparedness Checklist Attachment 2, Incomplete/Open Items List

Attachment 3, Project Approval and Concurrence Form

UET Page: 13 of 25

ATTACHMENT 1

Project Preparedness Checklist

NOTE: Each project has differing requirements; the PM must identify applicable responsible groups and requirements per project.

Project Title/Number: Date:

Check Activity Type:

Drilling Investigative and Characterization

Decommissioning and Demolition Remediation

Construction Storm Water/Groundwater/Sediments/Waste Sampling

Other:__________________________________

NOTIFICATION & SCOPE

Applicable

Yes/No Complete

Yes/No Responsible

Person Comments

PM or Designee

15 Day Sampling Notification to NMED

15 Day Drilling Notification to NMED

PM or Designee

DOE EM-LA invited to project preparedness review

DOE EM-LA notification

DOE NA-LA notification

Office of State Engineer (OSE) notification

LA County notification

Pueblo de San Ildefonso notification

M&O Contractor notification

Other:

UET Page: 14 of 25

NOTIFICATION & SCOPE (continued)

Yes/No

Complete Yes/No

Responsible Person Comments

PM or Designee

ER Work Plan

Drilling Plan

IPT Memorandum

Sampling Plan

Engineering Design (Drawings, Specifications)

Additional Requirements (specify in comments)

Project Schedule

Work Task Request

Scope of Work (SOW)

Other:

PM or Designee

Materials List

Equipment List

Specifications

Specialty Items

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GENERAL SITE/WORK AREA HAZARDS

Complete

Yes/No Responsible

Person Comments

PM or SOM TA, FOD (N3B Access Agreement or OCA for access requirements where work will be conducted)

Radiological Area Explosives Area UXO Area Beryllium Area HAZWOPER Work Wildland Fire Area

Responsible (Line) Manager/Operations or Construction Manager

Hazard Grading (N3B-P300):

Low, Moderate, High

List applicable project-specific IWDs/Work Control Documents by title:

WASTE MANAGEMENT

Waste Management Coordinator Waste Characterization Strategy Form (WCSF)

Support personnel

Waste Storage Site Configuration (map or sketch)

Containers

Shippers

TSDF designation

Manifests

Schedule

UET Page: 16 of 25

SUBCONTRACTOR WORK

Complete

Yes/No Responsible

Person Comments

Subcontractor Technical Representative

Assigned STR (name):

Subcontract Award (name):

Project Contacts:

Field Leader (PIC):

Subcontract Oversight Plan

STR: ES&H – Exhibit F

Pressure Safety Requirements

Exhibit F Special Requirements Checklist

Corporate ES&H Plan

Site Specific ES&H Plan (for HAZWOPER scope of work)

ES&H Representative / Specialist / Professional (Approval)

Forklift Certification and Training

Traffic Plan

Wildland Fire Hazard Control Plan

Electrical Work Identified Lock Out/Tag Out

Spark and Flame Permit

STR: Security – Exhibit G

Integrated Safety and Security Management (ISSM) Checklist

Operational Security (OPSEC) Plan

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SUBCONTRACTOR WORK (continued)

Complete

Yes/No Responsible

Person Comments

STR: Security – Exhibit G (continued)

Portable Electronic Devices (PED) Required:

▪ Laptop

▪ Cell phone

▪ Flash drive

▪ GPS/Survey equipment

▪ Camera/Downhole Camera

▪ Printer

Radioactive Source

STR: Quality Assurance – Exhibit H

All applicable Quality Assurance QC Requirements submitted

STR: Subcontractor Submittals – Exhibit I

Submittal Table Developed Submittal Table Reviewed and Due Dates Identified

Submittal table to include:

▪ Schedule

▪ Rig Inspections & Forklift

Inspections

▪ Equipment Declaration

▪ Electrical Equipment UL listed and/or Inspected by

ESO

▪ Fuel/Oil Storage Quantity

▪ Chemical Inventory

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PRPP PROCESS

Complete

Yes/No Responsible

Person Comments

R&SI

Required permits (SWPPP, Air, 404, etc.)

NESHAP

(10-day waiting period)

PM or Designee

PRPP #

Signed Environmental Impact Assessment (attach copy)

National Environmental Policy Act (NEPA) Compliance

All items identified, requirements closed

PRPP Revised (for new scope)

Excavation Permit/EXID

New Mexico One-Call (for work not on LANL property)

Utility Locates scheduled with M&O

NUCLEAR ENVIRONMENTAL SITES

NES SOM: Work Within or Adjacent to an NES

Documented Safety Analysis (DSA) approved

Technical Safety Requirement (TSR) Implementation Document(s) complete

Management Self-Assessment Unanswered Safety Question Documentation

(USQD)

UET Page: 19 of 25

INDIVIDUAL PERMIT (IP), WORK CONTROL, OPERATIONAL SUPPORT

Complete

Yes/No Responsible

Person Comments

PM

Site Walk-down Required (coordinate with IP Lead)

Individual Permit (IP) Restrictions

BMPs

Post-Project Walk-down

M&O IP SME notified of start

RM (RLM)/SOM

Access/Operational Control Agreement, M&O Access

ER POD/POW Scheduling

ER OPS Pre-job Walk-down

RM (RLM)/SOM: Field Service, Waste Services, ES&H, Security, Maintenance, Quality Assurance

Site Walk-down Required

Waste Staging Area

Emergency Notification Provided to N3B

Site Access/ Egress Off-road established

Communication ER Field or TA-21 Operations Center

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IP, WORK CONTROL, OPERATIONAL SUPPORT (cont.)

Complete

Yes/No Responsible

Person Comments

RM (RLM)/SOM: Field Service, Waste Services, ES&H, Security, Maintenance, Quality Assurance

Overhead Hazard Review

POD/POW Scheduled

2-Month Look-Ahead

Work Schedule (4/10, 5/8, 5/10, 24/7 [for drilling])

Weekend work

List Applicable ER Standing Orders

RCT Support

Radiological Work Permit

(RWP)

Equipment/sample release requirements

Rad Source (Geophysics)

M&O or N3B HE Safety Review

M&O or N3B HE Safety

HE Walk-down

HE Waiver

Beryllium Review

Security Requirements/Clearances

UET Page: 21 of 25

Complete

Yes/No Responsible

Person Comments

RM (RLM)/SOM: Field Service, Waste Services, ES&H, Security, Maintenance, Quality Assurance

Downhole Video/Geophysical

Traffic Impediment Form

(M&O SAWA)

Traffic Plan

Traffic Signage

Fire Hydrant – Non- Emergency Use Request

Wildland Fire Requirements/Restrictions

Contract-furnished Equipment/Materials

Lessons Learned (list below):

RM (RLM) and Construction Manager/SOM: Craft Support

Road Maintenance

Drill Site Pad Construction

Snow Removal

Re-fueling

Portable toilets/hand wash stations

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Complete

Yes/No Responsible

Person Comments

RM (RLM) and Construction Manager/SOM: Craft Support (continued)

Electrical Equipment

Electrician

Lineman (M&O)

Pest Control

Heavy Equipment

Fitter Support

Traffic Signage/Flagmen

Tree/Vegetation Removal

Laborers

Equipment Operators

Teamsters

Carpenters

QUALITY ASSURANCE

Complete

Yes/No Responsible

Person Comments

QA

Items designated as M&TE

M&TE Custodian

Storage Requirements

Inventory Requirements

Required training records verified

UET Page: 23 of 25

ATTACHMENT 2

Incomplete/Open Items List

INCOMPLETE/OPEN ITEMS LIST

Date Project Title/No.

Item No.

Action Item Description Pre-Start/ Post-Start

Responsible Person

Due Date Completion Date

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ATTACHMENT 3

Project Approval and Concurrence Form

PROJECT APPROVAL AND CONCURRENCE FORM

Project Title: Date:

The following IPT members have participated in a readiness meeting for the above project and concur with project readiness to start work in the field.

Project Manager

Signature Z Number Date

Health & Safety

ENV

Quality Assurance

Regulatory Compliance

Waste Management

Environmental Programs/Services

Radiation Protection

STR

Operations – SOM

Acquisitions Services Management

UET Page: 25 of 25

ATTACHMENT 3

PROJECT APPROVAL AND CONCURRENCE FORM

Subject Matter Expert

Subject Matter Expert

Training Manager Signature Z Number Date

Approval: Responsible Line Manager

Approval: Operations or Construction Manager

Approval: Operations Director

Approval: Program Director