The Department of Energy last month issued a preliminary notice of violation to Fluor-BWXT Portsmouth LLC (FBP) for failing to adequately adhere to nuclear safety requirements in its radiation protection program.
The notice, issued Jan. 13, flagged two radiation monitoring failures at the Portsmouth Gaseous Diffusion Plant site in Piketon, Ohio that occurred from 2011 through 2019.
After conducting its investigation, DOE reduced FBP’s contract fee by $2.6 million, though it proposed no civil penalties.
FBP began addressing the failures as soon as it learned of them, well before the DOE issued its notice.
Bioassay samples not requested
USW Local 1-689 members decontaminate and decommission the buildings at the former uranium enrichment site, while members of the building trades tear down the facilities after this work is done.
The nature of a person’s work determines how frequently they must provide bioassay samples to measure radiation exposure. The more contaminated an area, the more frequently the worker is tested, said Local 1-689 President John Knauff.
Knauff said a number of workers noticed they had not been asked to provide a bioassay sample at their expected frequency, and in November 2018, an FBP employee approached FBP dosimetry personnel about it. Dosimetry personnel measure, calculate and assess the absorbed doses of radiation for individuals.
FBP determined the problem was in the software used to tell people when to submit their samples, a glitch that should have been flagged by the original programmers.
In March 2019, FBP determined that 193 workers had not received their required bioassays. Knauff said the contractor then had them all provide samples.
DOE said in the cover letter for the preliminary notice that the failure did not result in expected worker exposures to radiation, but Knauff was less certain.
“That is, that the agency knew of,” Knauff said. He said radiation exposure—unless it is a large amount—will not show up in a bioassay sample taken long after the exposure.
Second monitoring failure
FBP identified a second monitoring failure in May 2019. This time it was a calculation error in a spreadsheet that showed the contractor underreported both onsite and offsite environmental radiological monitoring information in its past eight annual site environmental reports.
Another software program that had not met DOE’s quality control standards caused the problem to go undetected.
The DOE told FBP’s program manager that the contractor’s failure to implement its software testing program in this case, too, resulted in no public or environmental impacts above regulatory limits.
The notice said FBP’s regulatory violations concerned work processes, personnel training and qualification, quality improvement, and documents and records involved in the implementation of its software quality assessment.
To address these issues, the contractor overhauled its software quality assurance program, which included creating a new organization to oversee it, new procedures, new training modules for all site personnel and additional training for software owners.
FBP also implemented organizational changes and culture-change strategies, and started a contractor assurance improvement initiative.
Risk mitigation key
These are not the first monitoring failures at the Portsmouth facility. The DOE cited FBP in 2015 for nuclear safety and radiation protection violations, and proposed a $243,750 civil penalty. The violations concerned improper alteration of radiation protection documents and other radiation protection violations in April 2013.
Knauff said all radiological exposure carries some risk, and the key is to mitigate it. Not monitoring worker radiation exposure in a timely manner and not having accurate environmental monitoring potentially leads to a negative impact on workers and the public, said the DOE.