|Licence holder||ANSTO OPAL Reactor|
|Location inspected||Lucas Heights|
|Date of inspection||28 and 29 June 2023|
This is the record of an inspection conducted as part of ARPANSA’s planned inspection program to assess compliance with the Australian Radiation Protection and Nuclear Safety Act 1998 (the Act), the Australian Radiation Protection and Nuclear Safety Regulations 2018 (the Regulations), and conditions of facility licence F0157.
The scope of the inspection included an assessment of ANSTO OPAL Reactor’s performance at Lucas Heights against the Facility Performance Objectives and Criteria (FPOC) in the following area: Effective Control. The inspection consisted of a review of records, interviews, and physical inspection of the OPAL facility.
The OPAL facility is a 20 MW multipurpose research reactor that provides a variety of benefits to the community including production of radioisotopes for nuclear medicine and neutron scattering research. The main codes applicable to this facility are those that appear in section 59 of the Regulations plus AS 2243.4:2018 Safety in laboratories: ionizing radiation.
ANSTO is required to have effective control over the OPAL reactor facility at all times. This requirement is broad, extending beyond the direct control of the reactor system, to all aspects of facility management and organisational control that have an impact on the nuclear and radiological safety of controlled apparatus or material authorised under the licence.
The OPAL reactor was found to be well managed with an extensive document management system, supporting business processes, engaged staff, and routine conformance audits. The OPAL reactor operation was found to be compliant with the Act, the Regulations, and licence conditions.
Whilst the reactor facility was found to be compliant several areas for improvement (AFI) were identified. An AFI means an identified opportunity to improve performance to achieve best practice rather than minimal compliance. It is distinct from a non-compliance with the Act, the Regulations, or a licence condition. An area for improvement may be found where, despite reasonably practicable steps taken by the licence holder, an isolated instance of non-conformance with low safety significance has occurred.
Accountabilities and responsibilities
The OPAL management system documents have statements of accountabilities and responsibilities throughout. The responsibilities for front-line workers and their managers were found to be clear and when questioned were found to be understood.
ANSTO has an internal OPAL audit program designed to verify and improve performance against its management system, an important element of effective control. Audit MSA 22.214.171.124, looking at procedural adherence to OPAL Safe Work Method and Environment Statements and Safe Working Permits was examined. It was noted that some non-conformances have been identified but that actions had not been completed by ANSTO’s self-imposed and agreed action due dates. Comparatively, whilst not at OPAL, ANSTO (the licence holder) has recently been found in breach due to problems with its procedural conformance, and OPAL should be aware and learn from this. Timely actioning of internal audit findings, to improve procedural conformance, is an area for improvement.
Statutory and regulatory compliance
ANSTO uses a range of safety performance indicators to help it manage safety and compliance at the OPAL reactor. These are described in an OPAL instruction (OI 27). Two measures (13 & 14) relate to incident reporting. A review of the OPAL reporting system (OI 02) found that it uses the “actual” impact rating as a threshold for incident investigation whereas ANSTO’s site wide standard (AG-2375) uses the “potential” impact rating, a higher standard that provides more opportunities to learn from events that are a near miss. It was noted that OPAL had only three events meeting its investigation threshold (actual impact) in the two years prior to the inspection but had investigated at least one incident that has a lower actual impact. 35 OPAL events met the higher ANSTO wide threshold for incident investigation (potential impact) in the same period. (See inspection report R22/08751 – Sept 2022). OPAL’s alignment to the sitewide incident investigation threshold is an area for improvement.
Several parts of the facility were visited. The facility was found to be clean and tidy without signs of neglect that could indicate a lack of resources. Discussions with workers and managers did not indicate any significant resourcing issues affecting safety. Managers reported that retention and recruitment in the engineering and maintenance groups was more challenging in the Australian employment market, but that OPAL still had an adequate margin on resources before safety or operations was impacted.
Inspectors attended a routine morning meeting to brief workers on work being undertaken and issues at the reactor. The meeting, headed by the OPAL shift manager, had groups from different sections and disciplines present. It was conducted professionally and observed to be an effective way of sharing current information on the facility.
Discussions were held with several workers during two facility walk-downs. Respect between different groups and management and workers was evident. It was stated that any worker can raise issues and that management responded well to suggestions for workplace improvement. Some examples were provided including an upgrading of utilisation equipment to improve human factors. Interaction between workers and managers was observed as healthy, with a good rapport, openness, and valued contributions by both parties.
Some issues were identified with information posted around the facility. One issue involved whiteboards adjacent the reactor hall hotcells complex being used to provide the maintenance status of equipment. The use of the whiteboards, in a facility that operates on a 24/7 basis with different shift teams is useful, however these noticeboards also indicated that some in-cell equipment had been out of service for excessive periods.
OPAL management were asked about their knowledge of recent safety/compliance issues from elsewhere across the ANSTO business. It was apparent safety conversations within the OPAL environment was part of daily work but that the sharing of safety information (including regulatory issues) and integration of learning across divisional boundaries should be improved. The open sharing of safety incident and compliance information for the enhancement of safety across divisional boundaries is an area for improvement for whole of ANSTO.
Several defined business management processes were reviewed during the inspection. ANSTO has a comprehensive management system for controlling these processes.
An inspection and test plan for an equipment modification project was examined as part of SWMES and SWP conformance checks. The plan had been implemented accurately, documented and appropriately signed off. Whilst the plan, associated with start-up channel fission counter instrument holders fabrication appeared effective, it was noted that a referenced drawing had inconsistent revision numbering to that stated in the plan. A review of OPAL instructions suggested that guidance for the development and management of ITPs, specifically relating to revision control may be beneficial for configuration management.
Documentation and document control
A walk-down inspection was conducted which included visual examination of the facility and discussions with operations staff and other workers.
During the walkdown a Safety Assurance Committee (SAC) Approval Notice was observed on the wall that had a 2019 expiry date on it. The SAC system was replaced in 2020 with an alternative system approved under Regulation s63 by ARPANSA. In this instance, the presence of an expired notice does not imply that the processes conducted are unsafe, but it may undermine ANSTO’s visual representation of work authorisation and its encouragement of safe behaviours.
In another location a Safety Hazard Notice Board was observed to be hidden behind a door that was latched open. Hazard notice boards should be visible when entering a room to which they apply. This door when closed would have still obscured the notice board when entering the room.
The inspection sampled hard copy instructions required to be held in both the main control room and emergency control room. Two emergency operating instructions were found to be an old revision in the main control room. Ensuring that hard copies are available in the main and emergency control rooms is a requirement of ANSTO’s management system and therefore this represents a non-conformance to the management system. The availability of hardcopies of these instructions is important to be immediately accessible, and reliance on IT to store softcopies is not a safety system demonstrated to be available in all emergencies.
These examples indicate a weakness in ANSTO housekeeping arrangements and its application of the STAR (Stop, Think, Act, Review) principle. It was noted that the hard copy instructions were promptly updated during the inspection. Housekeeping issues have been identified in previous ARPANSA inspection (R22/08751 – Sept 2022). ANSTO housekeeping at the OPAL reactor remains an area for improvement.
ANSTO OPAL Reactor was found to be in compliance with the requirements of the Act, the Regulations, and licence conditions.
The inspection revealed the following areas for improvement:
- OPAL to improve procedural conformance by the timely actioning of internal audit findings.
- Improve OPALs alignment with the ANSTO sitewide incident investigation threshold.
- ANSTO to improve the open sharing of safety incident and compliance information for the enhancement of safety across ANSTO divisional boundaries.
- ANSTO to improve housekeeping at the OPAL reactor.
It is expected that improvement actions will be taken in a timely manner.