|Inspection report details|
|Licence holder||Australian Nuclear Science and Technology Organisation (ANSTO)|
|Location inspected:||Lucas Heights, NSW|
|Date/s of inspection:||10-11 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 the Facility Licence F0266.
The scope of the inspection included assessment of ANSTO’s performance in the following areas:
- Performance reporting and verification
- Configuration management
- Inspection, testing and maintenance
- Event protection
- Radiation protection
- Emergency preparedness and response
The inspection consisted of a review of records, interviews, and walkthrough of SyMo facility which is under construction.
Facility Licence F0266 authorises ANSTO to prepare a site and to construct the SyMo facility. The SyMo Facility will be used to process alkaline intermediate level liquid waste from the ANSTO Nuclear Medicine (ANM) facility and the B54 Mo-99 Production facility into a stable immobilised form suitable for eventual disposal.
Construction of the SyMo facility is progressing. A number of items important for safety have been approved for construction under section 66 of the Regulations.
In general, the safety performance at the SyMo facility was found to be satisfactory.
Performance reporting and verification
The effectiveness of the documentation and document control is monitored through the internal audit program of both the ANM SyMo Project and ANSTO. The management systems are also audited by external auditors for ISO certification.
The ANM SyMo Project through the ANM SyMo Project Regulatory Representatives and the ANM Project Managers liaise with the ANSTO Regulatory Affairs Manager to ensure all regulatory requirements for the effective control of the SyMo facility during construction and eventual operation are met according to the Act and Regulations.
ANSTO provided inspectors with the updated plans and arrangements for the SyMo facility. The Effective Control Plan (SyMo-1310-B-AN-0002, rev. 6) and the Safety Management Plan (SyMo-1310-B-AN-0002, rev. 4) have been updated to incorporate changes in project structure and ANSTO arrangements. This includes delegation of the safe management of the facility by the CEO to the General Manager, Engineering Delivery and Special Projects Group.
ANSTO’s quarterly reports have been submitted to ARPANSA in a timely manner and contained relevant information. The quarterly report also includes information on a design change notice that is used for minor or simple modifications to project or engineering design document(s) after they have been approved in either the detailed design, manufacture/fabrication, construction, or commissioning phases. ANSTO maintains open and transparent communication in its dealings including information on safety incidents which are non-radiological in nature. ANSTO GRC events are reviewed weekly and the lessons learned are shared through the ANSTO Licensing Officer Forum. All staff are aware of their reporting responsibility through the ANSTO system and safety issues are discussed at staff meetings. Inspectors found that the SyMo performance reporting and verification system is well structured.
Noting that the facility is under construction, ANSTO manages configuration of the plant and equipment in accordance with the design of such plant and equipment, and the SyMo Project Management Plan (SyMo-1411-E-D-AN-0001). The CEO of ARPANSA or his delegate have approved the construction of a number items important for safety under section 66 of the Regulations as identified in the Preliminary Safety Analysis Report (PSAR). As part of configuration management, ANSTO’s Procedure for Production and Control of Engineering Drawings & Engineering Sketches AP-2931 is applied. This procedure describes how the production of engineering drawings and engineering sketches is controlled and undertaken within ANSTO. Examples of this application were viewed at the time of inspection and no issues raised.
Items important for safety capable of functioning after a loss of support systems (e.g. compressed air) or, if not, designed fail to a safe configuration with acceptable positions, settings and signals (or clear indication of their failed status) were considered in the assessment of granting approval of such items. Performance of these systems will be tested during cold and hot commissioning following documented commissioning protocols and arrangements which are being developed. Inspectors have sighted the inspection and test plans (ITP) development procedure and template (SyMo-1400-E-F-AN-0016 rev. 3) that describes the methods to be applied for both the development of ITP templates and their application & control during applicable SyMo project phases. No significant issues were raised.
All new processes and changes to existing processes and systems that are part of the ANM SyMo Project are managed through the change control system described in SyMo Project Management Plan. Significant changes are documented using the design change notification form ANSTO F-6289 with examples sighted by inspectors. This form includes appropriate controls for change including justification of change, safety assessment, approvals for change and verification.
Inspectors found that the arrangements for configuration management are well structured and satisfactory for the purpose of construction and cold commissioning of the plant and equipment at the facility.
Inspection, testing and maintenance
The Construction Plan for the SyMo Facility (SyMo-1310-B-AN-0008 rev. 4) states that specific processes are used to track, control and manage construction works to ensure that physical plant matches design and is installed/built only after approval. These processes are proposed to be listed in overall construction, inspection and test plan (CITP) documents created during the detailed engineering design phase by each responsible contractor for their systems or equipment items prior to starting any fabrication or construction works.
ANSTO applies QA-QC – Quality Procedures, SyMo-1400-E-F-AN-0016 (rev 3.) for the development of ITP (inspection and test plans) templates, and their application & control during applicable SyMo project phases.
The applicable project phases that ITPs are to be used for generally relate to physical activities or items:
- Selected design phase activities during design development
- Procurement of items
- Workshop fabrication / manufacturing (incl FATs)
- Onsite construction & installation (incl post installation tests)
- Pre-commissioning activities (where used with pre-commissioning activities and procedures)
Fabrication and construction ITP forms for plant systems/equipment provided by suppliers/contractors responsible for the item are then reviewed, verified and approved by the ANSTO SyMo Project and ANSTO Synroc teams prior to implementation.
Inspectors sighted an example of an inspection and test plan used by Nepean Engineering Inspection & Test Plan, NE J/N177054, Design, Manufacture & Construction of SyMo Hot Cell HIP Cooling Tower Pipe Assembly (SYMO-0510-F-NE-0000). No significant issues were raised with the content by the inspectors.
Onsite inspection verifications of the relevant equipment item/system are undertaken according to the approved ITP with ANSTO SyMo Project and Synroc team representatives present as nominated on the ITP. Offsite inspections (including Factory Acceptance Tests (FAT’s) where relevant) of the relevant equipment item/system are also undertaken following the same approach. Inspectors sighted the Manufacturing Data Report (MDR) of policing filter (SyMo-2901-E-PF-0039) that contains details of test and verification including the certificate of conformity and test report and found that the document was appropriately completed and signed off.
ANSTO applies the CITP Plan for the Testing and Commissioning of Safety Related Items of the SyMo Facility (SyMo-1310-B-AN-0009 rev. 05) for testing and commissioning of the safety related items in the SyMo facility. Items important to safety include safety category 1 or 2 or, as required under licence condition 2 of F0266, any item of plant that will come into direct contact with radioactive waste during the Synroc process as identified in the PSAR. The plan describes the pre-commissioning activities to verify as much as possible the operability and performance of individual plant items and/or each separate plant system on its own. Pre-commissioning activities involve verification of all of the relevant construction related Specific Inspection and Testing Plans (SITPs) are approved, and then a system level release certificate is typically issued at the end of construction of that system. The document specifies the systems that will be pre-commissioned such as hot cells doors, posting port, shielding windows, radiological protection instrumentation, waste storage tanks and piping transfer systems, powder production system etc.
In addition, pre-commissioning activities of other safety-related items categorised as safety category 3 that will not come into direct contact with radioactive waste during the Synroc Process are described in the CITP. No issues were raised with this document or its application to pre-commissioning activities by the inspectors at the time of the inspection.
The SyMo Safety Management Plan (SyMo-1310-B-AN-0002 rev. 4) requires regular workplace safety inspections during construction and pre-commissioning activities to identify and address potential or real hazards and to monitor implemented control measures and local procedures. This is conducted in line with AG-2432 Workplace Safety Inspection guide using AF-3915 Construction Safety Audit Checklist. Any areas/issues found to be unsatisfactory will be addressed to bring them to a satisfactory level. The inspections are documented and reviewed by project management who will monitor the implementation of corrective actions. Non-conformances found in ANSTO processes and products are addressed by identification of corrective actions which are managed using the ANSTO Action Tracking System.
Inspectors considered that there is a systematic process in place for inspection, testing and maintenance of systems, plant and equipment during construction of the SyMo facility. No significant issues were raised at the time of the inspection.
ANSTO training processes have considered the adequacy of staff qualification and supervision provisions to undertake potentially hazardous activities, which are included in the selection criteria for a specific role. These criteria include the qualifications, knowledge and experience appropriate for the work. Non-radiation safety training including induction for staff and contractors and safety training for supervisory staff are provided by the ANSTO Work Health and Safety Section. ANSTO Guide AG AG-2364 Work Health and Safety Training Needs Analysis describes the full list of courses and the retraining requirements. ANSTO Radiation Protection provides radiation training and regularly conducts refresher training courses to ensure staff competency when working in radiological areas. A record of the training is maintained in the ANSTO Learning Management System. Any necessary task-specific training will be identified in the job planning and SWMES processes. Visitors needing to enter the construction site area will be escorted by site inducted ANSTO staff who will explain the hazards and the controls in place.
Inspectors examined a selection of SyMo staff training records, competencies, skills and knowledge documentation that demonstrated the appropriate safety training and learning outcomes had been achieved at the operational level.
Staff are trained on the SyMo demonstration plant. Such training provides staff with a clear understanding of the structures, systems, components and processes. Staff are also trained in task-based competencies, for example the lifting approval officer is qualified to assess the use of the crane that will be used in operation of the facility.
ANSTO uses training as a strategic performance tool to enhance both operator and facility performance. Managers are responsible for the competence of their staff and work effectively with training staff to ensure their qualification. Managers take ownership of training programs. The initial and continuing training programs are based on the manufacturer’s recommendations, operating procedures of plant and equipment, operation and maintenance manual, and the operational needs of the facility to ensure that workers are always competent to perform the tasks to which they are assigned. Further, the experience to be gained from the cold and hot commissioning of the facility will also be used to enhance training programs. ANSTO advised that authorisation of operators will be in place for operation of the facility. Evidence of this will be submitted as part of the application to the CEO of ARPANSA to operate the facility.
Inspectors found that ANSTO uses a systematic approach to training to maintain staff competence and this will ensure safety when the facility becomes operational.
The effects of external events were considered in the assessment of the licence application for siting and construction of the facility. Fire, flood, earthquake, lightning strike, severe weather events and loss of services were considered and found satisfactory. Details of the implementation of controls to ensure the effects of external events on its facilities do not result in unsafe nuclear or radiation conditions will be considered in the operational phase. The effectiveness of the engineering systems for event protection will also be considered once the facility becomes operational.
The SyMo facility’s protective security system (SYMO-2470-3-B-AN-0001_SyMo Facility Security Design Basis) was designed to take into account and meet a range of regulatory requirements and expectations (both domestically and internationally) across radioactive sources and material, nuclear material and associated activities and government information, assets and people. There has been no change to the design basis.
ANSTO Security and Safeguards have redrafted a number of high-level ANSTO security documents such as the ANSTO Nuclear Security and Safeguards Policy, the ANSTO Security Plan and the ANSTO Security Manual. The nominees for all licensed facilities must refer to and implement, where applicable, the protective security requirements set out within these higher-level documents. Nominees for all facilities (and source licence) holders must develop their own local arrangements with the higher-level documents in mind, noting these higher-level documents capture the requirements under the ARPANS Act 1998 and ARPANS Regulations 2018. The Security Plan for SyMo (SyMo-1310-B-AN-0006, rev. 7) was developed with this in mind and there were no substantive changes made. The Plan continues to meet the expectations for a construction licence.
The protective security system should form a part of the overall commissioning phase of the facility where system performance must be assessed and verified by an appropriate and independent expert. The results of such verification are expected to be part of the application for an operating licence.
Inspectors considered that the protective security arrangements and procedures in place and the security items installed for the purpose of construction activities are satisfactory.
SyMo Facility Construction Radiation Protection Plan (RPP) (SyMo-1310-B-AN-0004 rev. 5) describes the organisational arrangements and procedures that are to be implemented to control exposure to ionising radiation during siting and construction activities. ANSTO Radiation Protection Services provides health physics services to the SyMo facility. The roles and responsibilities for the management of radiation protection are described in the RPP.
A number of safety systems related to radiation protection have been constructed and some are in the process of construction. The performance of such systems will be checked during cold and hot commissioning of these systems. Radiological hazards and controls and design safety features for radiation protection are described in the RPP in line with the items important for safety identified in the PSAR for the facility.
Workplace practices including workplace monitoring and contamination control measures will be developed taking into account the cold commissioning and hot commissioning results.
The RPP gives commitment to follow the three principles of radiation protection, namely, justification of a practice, optimisation of protection and safety and dose limitation. Details of these aspects will be considered in the assessment of an operating licence application.
Inspectors considered that organisational arrangements and procedures in place for construction activities are satisfactory.
Emergency Preparedness and Response
ANSTO has in place well established requirements for emergency preparedness and response. These requirements are promoted with ANSTO staff and clearly articulated in detail as documented in the following:
- Emergency Planning Standard AS 2305
- ANSTO Emergency Management Plan (EMPLAN) AG 5945
The EMPLAN is based on an integrated all hazards approach to be well prepared for any incident or emergency situation. This plan includes clearly defined roles and responsibilities of ANSTO personnel and emergency service organisations including the NSW Fire Brigade, NSW Police Force, Ambulance Service and NSW Health Department. This plan also reflects the requirements in IAEA General Safety Requirements GSR Part 7 Preparedness and Response for a Nuclear or Radiological Emergency.
The Construction Plan and Testing and Commissioning of Safety Related Items describe the activities which will be performed during construction, installation and cold commissioning of the new facility. A Safe Work Method and Environmental Statement (SWMES) prepared by the responsible contractors during that phase of the project is used to identify risks and controls for works arising from construction and cold commissioning of the facility (SyMo Facility Construction Emergency Management Plan, SYMO-1310-B-AN-0007). The SWMES also discusses the controls in place for test sources which will be used during cold commissioning. During construction the main contractor is responsible for implementing the emergency arrangements under the oversight of ANSTO.
The SyMo Construction Emergency Management Plan states that, in the event of a site safety incident, the main contractor is required to provide first aid response facilities in accordance with WHS laws and is required to maintain a site WHS plan including an evacuation plan. In the event of a major incident ANSTO site control centre (SCC) will be contacted for further support.
ANSTO states that the future plant operations manager and facility officer will be responsible for emergency arrangements during the hot commissioning and ongoing operation of the facility.
Inspectors considered that the arrangements for emergency preparedness and response for construction activities are satisfactory.
The licence holder was found to be in compliance with the requirements of the Act, the Regulations, and licence conditions.
The inspection did not reveal any areas for improvement.