|Inspection report details|
|Licence holder||ANSTO - Waste Operations|
|Location inspected||Lucas Heights Science and Technology Centre, Sydney|
|Licence number||F0260 and F0292|
|Date of inspection||16-17 and 24 August, 2022|
An inspection was conducted as part of ARPANSA’s baseline 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 F0260 and F0292.
The scope of the inspection included an assessment of ANSTO’s performance against:
- For the Waste Operations Licence F0260: the Performance Objectives and Criteria (POC) in the following areas: Radiation Protection, Configuration Management and Training
- For the Interim Waste Store licence F0292 all of the POC
ANSTO Waste Management Services (WMS) manages the plans and arrangements for safety and security for both Waste Operations F0260 and the Interim Waste Store (F0292).
ANSTO’s Waste Operations Facility (F0260) consists of several sub-facilities for the management of ANSTO’s radioactive wastes and nuclear materials. These include low and intermediate wastes (both solid and liquid), nuclear material, disused sources and decontamination and laundry services.
ANSTO’s Interim Waste Store Facility (F0292) is authorised for the storage of two TN-81 storage/transport casks containing vitrified intermediate level waste and six CBF-C2 cemented drums of technological waste in an ISO container. These wastes were generated from the reprocessing of HIFAR spent fuel overseas in the United Kingdom and France.
The licence holder was found to be in compliance with the Act, the Regulations and licence conditions for F0260 and F0292. Three areas for improvement were identified against F0260.
The progress on the areas for improvement from the last relevant inspections relating to emergency management procedures, change control, security plan update and update of the F0260 Safety Analyses Report were reviewed, and it was noted actions were either implemented satisfactorily or in progress.
Performance reporting verification (F0292 only)
Statutory reporting conducted against licence condition 2 of F0292 since the last inspection was reviewed, and no significant issues raised. No significant radiation related events have been raised related to F0292 since the last inspection.
The sharing of information on relevant events across site was noted to be ongoing with monthly facility meetings and also the use of safety/security alerts and safety themes implemented periodically across the ANSTO site. Lessons learned from the project to place a second TN81 transport/storage cask into the IWS in March 2022 were appropriately captured.
Configuration management (F0260 and F0292)
At the time of the inspection, a new WMS specific change management document was being developed along with a training package which captures all the ANSTO configuration control requirements.
The criticality certificates covering all the WMS facilities were examined along with the required Operating Limit and Condition (OLC) 2 yearly audits. No issues were raised. The physical location of the certificates and the required configuration of the local areas they applied to was verified for a sample of Waste Operation buildings.
The remaining OLCs for the F0260 licence were reviewed and evidence of completion of all surveillances (B41 and B23A Ultrasonic level detector calibrations and the B41 hot cell interlocks for the high activity handling hot cells) was verified. It was noted that a recent event, where WMS did not complete an OLC surveillance requirement, had been investigated and actions completed including highlighting the importance of these checks in the maintenance management SAP system.
Records from a recent project that was approved by ARPANSA to replace transfer valves in the Intermediate Level Liquid Waste Tank Farm were examined. Lessons learned had been appropriately captured and daily doses remained well below the dose constraints.
The most recent version of the WMS project priority live document which forms part of the Nuclear Operations Long Term Planning Process, was examined. The projects continue to be ranked by risk with the Beverly Ryle prioritising method applied to those with equal rating. The management of the project priority was found be appropriate with updates regularly made according to completion of project stages and work that constituted higher risk being added as it emerged. An example of a higher risk project was discussed in detail whereby work had been delayed by unexpected additional work and it was confirmed that additional resources were being recruited to address this.
A sample of safety and security significance categorisation of modifications was reviewed including the replacement of the WMS Drum Dryer feed tank and the replacement of Mixing Tank 5 in the Effluent plant. No issues were raised with the final categorisations.
Training (F0292 and F0260)
Since the last inspection was conducted a new role for a Waste Operations training officer has been established. The role objectives include performing evaluation and assessment of effectiveness of the WMS training program. It also covers provision of advice to ensure training programs are suitable for organisational needs and reflect regulatory and legislative standards and collaborating with ANSTO site wide training resources and WMS staff on training needs analyses.
Input from the training officer role in reviewing the training plan and mock-up for a recent project involving intermediate level liquid waste was discussed. This training was noted to include human factor issues such as resourcing, training, response to environment (heat), fatigue etc.
A number of training records for the transition of radiation waste technicians to higher duties were reviewed for completeness. No issues were raised.
Note that training records for the commissioning of the Interim Waste Store TN81 flask had previously been reviewed as part of the supporting evidence to place the second flask in the facility in March 2022.
Event protection/Emergency Preparedness and Response (F0292 Only)
The annual whole site bushfire inspection report by the NSW Rural Fire Brigade was previously reviewed by ARPANSA in June 2021 and evidence of completion of the 17 actions noted across the SAP system and/or via photographic evidence. The next bush fire inspection has been appropriately scheduled.
The last AF-2534 Bushfire Preseason Building Check and Preparation record and actions were inspected
for the IWS. No issues were raised.
The compliance of WMS with the ANSTO Emergency Management Plan Lucas Heights (AG-5950) and the ANSTO Emergency Management Plan (AG-5945) was reviewed during the June 2021 inspection of Waste Operations. This also applied to the IWS and no changes in the ongoing compliance were noted as part of this inspection. An emergency exercise was noted to be planned for the facility as part of the ongoing emergency exercise program which is graded by risk. A security exercise had been conducted in the past 3 months and is described in the security section below.
Pest and fire system maintenance records were inspected for the IWS. No issues were identified.
Security (F0292 only)
ANSTO Security and Safeguards staff have spent the past two years addressing security governance; in particular their policy, plans and procedures. One of their capstone achievements is a revised enterprise ANSTO Security Plan and a newly developed facility security plan template. The ANSTO Security Plan details the enterprise approach to security risk management, considering the Australian Government’s nuclear and radiological security requirements and the Protective Security Policy Framework.
The ANSTO Security Plan is underpinned by a framework of operational security plans, procedures and arrangements that provide additional layers of detail across the range of security-related topics. The Facility Security Plan Template is a new Facility Security Plan (FSP) pro forma template which is subordinate to the ANSTO Security Plan. This is a new approach to ANSTO’s regulatory compliance and will streamline their approach to facility-level (including sources) security requirements. The FSP template considers ARPANSA licence and ASNO permit requirements. The FSP template is adaptable to the requirements for each facility / source and the documentation of the local arrangements. This is considered particularly useful where a facility holds both nuclear material and security enhanced radioactive sources / material.
ARPANSA’s expectation is that this approach will harmonise regulatory requirements in ANSTO’s approach to security at the organisation, site and facility levels; to improve licence holder understanding of their responsibilities; and to lift their overall security compliance.
It was noted that the IWS has a draft facility security plan, in accordance with the current template, and that it was based on the existing approved Security Plan, dated 2020. This has been submitted to ARPANSA for review. The review of the current security plan and supporting documentation highlighted some stepwise changes for the IWS around their oversight, responsibilities and management of security within the facility. This includes the security roles and responsibilities of building managers, among others. This is considered an important step forward in raising the security culture of licence holder staff and the organisation more broadly.
ANSTO has a comprehensive security clearance program in place. In that regard, there are authorised persons lists that capture details on staff access to the Waste Management Services facilities including specific areas requiring higher level security clearances from the Australian Government Security Vetting Agency (AGSVA). The minimum-security clearance (trustworthiness check) is the ANSTO Site Access Clearances (General or Protected) for general access to the site and the protected level to access the protected areas. AGSVA Negative Vetting 1 (NV1) security clearances are required for some areas within the Waste Management Facility, where the IWS largely comprises of NV1 security cleared. A review of IWS access reports over several days in the last month was undertaken and found to have no anomalies.
ANSTO Security and Safeguards has redeveloped and delivered a Security Training and Awareness Management Plan (STAMP) which comprises both online module delivery and face to face training and awareness. This plan includes annual security training for all staff and a twice yearly ANSTO ‘security focus’ event. The STAMP and Security Essential Training module were reviewed and are considered suitable for the induction and annual training for all staff and contractors. No issues were identified with IWS staff security training.
A program of ‘spotlight’ exercises, in conjunction with the Australian Federal Police, have been rolled out across ANSTO with one occurring for the IWS in the previous quarter. The scenario involved a person of interest (POI) approaching the facility. It was noted that even before the exercise could play out that an ANSTO contractor working in the facility (not knowing about the exercise) noticed the POI and called the ASOC. This positive security culture is to be commended.
Evidence of testing and maintenance of the physical and electronic infrastructure for security for the IWS was examined and no issues raised.
Waste Management Services maintains a key log which was examined on the day. Key management audits are conducted annually however are not documented. An area for improvement was raised to consider documenting the key management audits.
Radiation protection (F0260 and F0292)
A review of waste management services worker doses for the last 10 years shows that maximum effective doses for individual years typically range between 1.5 and 2.5 mSv for about 10% of the workforce, with the rest of the workforce incurring lower or negligible doses. Skin, eye, and extremity equivalent doses are correspondingly low.
Possible internal contamination continues to be below detection limits indicating that committed effective doses are of low concern. Airborne discharges, which are reported quarterly to ARPANSA continue to remain well below regulatory limits with the off-site dose demonstrated to be negligible through modelling.
Records from the Health Physics routine workplace monitoring program were reviewed for B27, B41, B57 and the IWS and no issues raised.
Radioactive Source Integrity Check records for the relevant sealed sources under F0260 were reviewed and found to be up to date with surface total activities well below 200 Bq or housing total activities well below 20 Bq. Sources were found to be within recommended working life as per ARPANSA-GDE-1746WEB.
Calibration of radiation monitors was checked at a sample of buildings and found to be within the required timeframe.
New risk mitigations introduced into B27 following a review of the remote solid waste handling safety assessment were sighted including rescue equipment and a pit cover.
A number of event investigations were reviewed including GRC 11912, 11771, 11867 and 11868. Actions were noted to have been completed or were in progress. One event concerned water ingress into a waste building following an issue with the water proofing. This is now being addressed through maintenance. The event investigation did not include discussion of whether the additional temporary water ingress had a potential to affect the current risk assessment. This was raised as an area for improvement for future relevant event investigations.
Records of the last two vehicle scanner tests were reviewed and no issues raised. Records from the analysis of pond water were reviewed and again no issues noted.
At the time of the inspection the B41 dangerous good-rated crane had failed although the load was able to be recovered. Failure of the crane had occurred multiple times in the past and plans are in place for replacement. An area for improvement was raised to document a recovery plan for failure of the crane.
Inspection Testing and Maintenance (F0292 only)
The records all OLCs for the IWS, namely the surveillances on heat transfer, surface temperature and interspace pressure checks and external doses of the DV78 ISO container were reviewed and no issues raised.
Records from the procedure ANSTO- D0719 Transport and Storage of TN81AU02 CSD-V were examined in full including final helium tests and certification, storage position, dose survey and the transport documentation file. No issues were raised noting that ARPANSA inspectors were present to witness this work in March 2022.
The IWS is captured under the existing WMS Asset Management Plan G-3233. This plan covers the planning horizon of 20 years in alignment with planning considerations a future national waste disposal/storage facility. The facility is captured in the plans for development of the overarching maintenance strategies based on the Reliability Centred Maintenance and Failure Modes Effects and Critical Analyses (FMECA) principle approach which among other areas, relates maintenance to plant failure. No issues were raised with this plan.
The licence holder 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:
- Event investigations should identify whether relevant events have the potential to affect existing risk assessments
- Documenting a crane recovery plan for B41
- Recording Key Management Audits.
It is expected that improvement actions will be taken in a timely manner.