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Enforcement Letter, WEL-2013-01 - May 29, 2013

May 29, 2013

Issued to Los Alamos National Security, LLC, related to Worker Beryllium Exposure during Machining at the Los Alamos National Laboratory's Beryllium Technology Facility

The Office of Health, Safety and Security’s Office of Enforcement and Oversight evaluated the circumstances surrounding a work evolution performed at Los Alamos National Laboratory (LANL) Technical Area 3, Building 141, Beryllium Technology Facility (BTF), on July 11, 2012. The work evolution resulted in a worker exposure to beryllium in excess of the Department of Energy (DOE) action level of 0.2 micrograms per cubic meter for an 8-hour, time-weighted average. Los Alamos National Security, LLC (LANS), which manages and operates LANL under a contract with the National Nuclear Security Administration (NNSA), is subject to the provisions of DOE’s Worker Safety and Health Program rule (10 C.F.R. Part 851) and Chronic Beryllium Disease Prevention Program (CBDPP) rule (10 C.F.R. Part 850). Based on our evaluation of the circumstances surrounding this event, LANS did not collect and control personal exposure assessment air samples according to site-specific procedures and the recognized testing and analysis methodology selected by LANS. In addition, LANS did not meet the requirements of Parts 850 and 851 to establish complete and accurate records associated with the hazard assessment and exposure controls for this work evolution. Collectively, these deficiencies indicate that LANS is not accurately quantifying and consistently controlling worker exposures to beryllium at BTF.