|Inspection report details|
|Location inspected:||OPAL Reactor|
|Dates of inspection:||7–8 December 2020|
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 F0157.
The scope of the inspection included an assessment of ANSTO’s performance at the OPAL Reactor in the area of training and security. The inspection followed the respective ARPANSA Performance Objectives and Criteria (PO&C) and consisted of a review of records, interviews, and physical inspection of the facility.
The OPAL Reactor is a 20 MW multipurpose reactor producing mainly nuclear medicine and other radioisotopes for the community. The facility also conducts research using neutron scattering techniques.
The training of the facility operators and support personnel is to ensure that the staff are suitably qualified and experienced to operate the facility and conduct controlled activities safely and securely. ANSTO’s plans, arrangements and practices include security arrangements to ensure that effective measures preventing unauthorised access, theft or damage to the facility and radioactive material are in place.
In general, the management of training and security at the OPAL reactor was found to be sound. No non-compliances have been identified. However, some areas for improvement are highlighted below with respect to the Learning Management System (LMS) performance and training for maintenance personnel. A good practice was identified during the inspection.
The strategic importance of training at ANSTO in general is recognised in the ANSTO top-level policies, procedures and guides such as the Work Health and Safety Training Procedure, Safe Management of Contractors, and WHS Training Workbook. Overarching ANSTO documents are the basis for the OPAL reactor specific training processes and practices documented in the OPAL Business Management System (BMS).
The training needs for safety and security-related roles are identified, analysed and reviewed on an ongoing basis. The ANSTO general training is identified and the respective training programs are developed by senior ANSTO advisors such as radiation, WHS or security advisors. OPAL-specific training needs are identified by managers in consultation with the OPAL training manager. The needs are often identified based on plant modifications, operations experience or employees’ proposals for improvements. The impact of several operational events on training was examined during the inspection. For example, an event involving an incorrect isolation and how that error was addressed in training was examined and found adequate. In addition, special training needs were identified due to the COVID pandemic. Its potential impact on the OPAL operation staff was assessed and new training was identified, developed and delivered.
An inconsistency was recognised in training needs identification for some maintenance tasks. Some instrument modifications and component replacement of both customised and off-the-shelf products are sometimes supplied with insufficient manuals from vendors or instructions for maintenance are not developed in the case of a customised design. As the manufacturer or designer information is not available in such circumstances, the OPAL maintenance personnel do not receive training on how to maintain the equipment. This presents an opportunity for improvement.
The reactor operations training curricula for the safety and security related positions have been developed and they are formally reviewed every five years or earlier as required. The document that summarises the mandatory and supplementary training includes inductions, role specific and refresher training.
The review of documents showed that adequate training standards, specifically the IAEA NS-G-4.5 Operating Organisation and the Recruitment, Training and Qualification of Personnel for Research Reactor, are used for developing the training requirements and programs.
The OPAL reactor uses the site-wide electronic LMS to manage training for all their staff. The system is administered centrally by the ANSTO organisation and it includes all general and specific training requirements. The individuals receive system-generated notifications of the relevant courses that cover their training needs based on WHS or security requirements such as radiation protection training or security training. OPAL role-specific training requirements are developed by the respective managers in consultation with the OPAL training manager and are subject to reactor manager approval before they are entered into the LMS. The workers are responsible for knowing their own training requirements and for attending the training they have enrolled in through the LMS. No variation between the required training and actual training were identified.
OPAL reactor training programs include a recently developed 3-level induction process. Above the ANSTO organisation induction requirements, the 3 OPAL reactor induction training levels depend on the individual’s facility access rights. This arrangement has improved the management of the OPAL-specific induction training.
The LMS report on outstanding training for OPAL personnel indicated that a relatively large number of the staff had various training courses overdue. The overdue training included courses, online training, and refreshers (both mandatory and supplementary in nature). It also included some security-related training. For example, some personnel records indicated online radiation training up to 160 days overdue, radioactive spill/contamination response and recovery training up to 500 days overdue and security training up to 860 days overdue. Some certifications, such as the dogman licences, were also overdue. Some of this data was shown to be incorrect compared to the locally kept records. The staff and managers have recently become aware that the LMS has been generating reports with inaccurate data for some time. The ANSTO organisation has been working on addressing this issue by, for example, analysing the data and removing duplications. This LMS anomaly presents an opportunity for improvement.
A sample of training records of OPAL personnel were obtained for review. The records included staff from OPAL operations, utilisation and maintenance. The records were found complete and the training milestones appropriately signed by the respective supervisors, managers and/or OPAL training manager. Where required, the personnel authorisations were issued by the Reactor Manager. The main control room personnel were appropriately accredited before their authorisation.
The important safety and security processes and emergency procedures are part of the induction and refresher training. Lessons arising from the emergency and security exercises/drills are fed back to the OPAL reactor training program. In addition to monthly emergency desktop exercises and regular emergency exercises to test the ANSTO and/or OPAL emergency preparedness and response (including the introduction of additional security scenario drills), the OPAL reactor has recently been practising emergency and security demonstrations. This new type of emergency test is based on operational experience and developed on demand. For example, a demonstration of a rescue from a crane box was conducted in the Reactor Hall in June 2020, and a OPAL security test of response under duress was carried out in September 2020. Both exercises identified many practical lessons learnt which have been incorporated into the training program. This type of emergency exercise is beyond the required and typical form of exercises and it was recognised by the inspection team to be a good practice.
OPAL maintenance personnel qualifications are based on the trade qualifications complemented by the ANSTO and OPAL-specific mandatory and supplementary training. According to the IAEA guide NS-G-4.5 Maintenance, Periodic Testing and Inspection of Research Reactors the maintenance personnel should also receive training on maintenance procedures, periodic testing procedures and inspection procedures. This training is part of the initial training but ongoing training in this area was found inconsistent. The need for such continuing training is particularly important for safety-related maintenance tasks carried out less frequently, such as some instrument and control (I&C) calibration activities.
The frequency of some tasks can be as low as 5 years. Due to such low frequency, knowledge management is an important aspect to consider as the tasks can be carried out by personnel with no or little previous experience with the specific process. Although the OPAL organisation regularly updates its business management system documentation with operating experience, it has not been consistently applied particularly to low frequency maintenance tasks. Therefore, systematic retention of knowledge and operating experience in work instructions or in other forms of records that could be used for training purposes in the future, specifically for safety related low frequency maintenance tasks, presents an opportunity for improvement.
The training effectiveness is systematically assessed mainly through questionnaires and OPAL training manager interviews with trainees. The effectiveness of operations personnel training is also assessed by the number of trainees who do not pass the accreditation or authorisation requirements. The number of OPAL reactor incidents with training as a contributing factor is also used as a lagging indicator of training effectiveness.
Good progress was observed in ‘soft’ skills training. The training on human factors has been developed and is now required for safety and security related personnel to complete periodically. Apart from this training, the operations personnel have also participated in other training such as decision making under pressure, safety culture building, effective communication in stressful situations and stress resilience.
OPAL management has made significant efforts over the last few years, in cooperation with ANSTO Security and Safeguards, to better understand the protective security requirements for the OPAL facility. Progress has been made since the last inspection to capture and assess all security documentation that was previously managed across the facility under varying systems and record it in the OPAL BMS. This was a major undertaking that now ensures all OPAL documents are captured in one place. Additional proactive work has ensured a greater level of oversight and ability to manage the governance and operational risks to the facility.
ANSTO Security and Safeguards has reviewed and redrafted a number of high-level ANSTO security documentation such as the ANSTO Nuclear Security and Safeguards Policy and the ANSTO Security Plan and the ANSTO Security Manual. All ANSTO licence holders must refer to, and implement where applicable, the protective security requirements set out in these higher-level documents that capture the requirements under the Act and Regulations. All ANSTO licence holders must develop their own local arrangements based on the higher-level documents.
While the OPAL Reactor Security Plan has been reviewed and completely rewritten, both the OPAL security risk assessment (SRA) and the OPAL vulnerability assessment (VA) requires updating to ensure there is current understanding of the risks and protective security system effectiveness. The conduct and development of both the OPAL SRA and OPAL VA will be incorporated in the Periodic Safety and Security Review (PSSR) which is due December 2021. It was also noted that the draft ANSTO Contingency Plan will be provided to ARPANSA in early 2021.
The OPAL facility has a comprehensive security system as described in its maintenance strategy (OMM 5750-001). Wormald are contracted to provide the service and maintenance of the OPAL protective security system. However, the responsibility for maintenance of the OPAL Reactor Physical Security System is shared with ANSTO Security and Safeguards and the OPAL Facility. An OPAL System Engineer (under OEF 031 System Engineer Responsibility) is delegated responsibility for the electronic security systems, access control, CCTV and alarms and other security system components. This is considered a positive step in managing the facility from a holistic perspective.
All security incidents are recorded and managed via the GRC system. It was observed that senior OPAL staff have a very good grasp on incidents that have occurred at the facility and how the incidents have been managed until their resolution.
ANSTO has a mature program of exercises and drills and this maturity extends to the OPAL facility. Additional security drills are conducted such as the recent duress alarm event to ensure there is ongoing learning for all staff. Further information is found above in the training section. This is considered good practice.
ANSTO Security and Safeguards has a comprehensive security clearance program in place. In that regard, there are appropriate and clear authorised persons lists that capture details on staff access to the OPAL facility 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 such as OPAL. AGSVA Negative Vetting 1 (NV1) security clearances are required for varying areas within the OPAL facility and these clearance processes are conducted by AGVSA. Due to the Wormald security contractor access across the OPAL facility, they require AGSVA NV2 security clearances which aligns with the Australian Government’s Protective Security Policy Framework (PSPF) and APRANSA’s personnel security requirements/expectations. A review of authorised access reports over several days in the last month was undertaken and found to have no anomalies.
OPAL staff meet with ANSTO Security and Safeguards on a monthly basis to discuss relevant security matters across a range of operational requirements including regulatory matters of interest. Training for security has been covered in the training section above.
Review of various documents recorded in the OPAL BMS and those received post-inspection in the areas of governance, access control, test and maintenance, event and reporting, exercises and training and awareness, among others, provide a clear demonstration that there is an effective protective security system in place. Senior OPAL staff have resolutely taken ownership of the protective security system with close assistance and advice from the ANSTO Security and Safeguards team; this is seen to be a positive and important position for OPAL management to be in to understand why security is required, OPAL’s security system design, how the security system is evaluated for effectiveness and how best to manage the risks.
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:
- Identification of training needs for OPAL maintenance staff relating to new equipment and components could be improved.
- The LMS performance could be improved in the area of accuracy of training records.
- Ongoing training in the area of maintenance procedure, periodic testing and inspection procedures should be improved with focus on low frequency safety-related tasks. Associated knowledge management and experience retention should also be improved.
The inspection revealed the following good practice:
- Emergency safety and security demonstrations that are based on often immediate operational experience are considered to be an effective add-on to the regular emergency desktop exercises, and facility and site exercises.
It is expected that improvement actions will be taken in a timely manner.