| Inspection report | |
|---|---|
| Licence holder | Australian Nuclear Science and Technology Organisation |
| Location inspected | Lucas Heights Science and Technology Centre, Lucas Heights, NSW 2234 |
| Licence number | F0245 |
| Date of inspection | 24-25 November 2022 |
| Report no: | R22/10743 |
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 source licence S0190.
The scope of the inspection included an assessment of performance at ASC North against the Source Performance Objectives and Criteria (POC). The inspection consisted of a review of records, interviews, and a physical inspection of the ionising source storage and exposure locations, in particular the complex open site environment where ionising sources are used onboard the submarine.
Background
OPOF offers consultation and research services to the mining industry sector in Australia and abroad, particularly when working with uranium, lithium and rare earths. OPOF receive sample material from mining sector businesses and this material is prepared then tested in research and experimental plant. More elaborate plant can be designed and constructed to meet customer needs such as proof of concept pilot plant, batch plant or continuous processing plant.
OPOF facilities include a cluster of buildings containing laboratories and workshops used for research purposes linked to mining and minerals exploration using dry or wet laboratory techniques. Management at OPOF combines and integrates with ANSTO corporate management thus ensuring that OPOF labs and workshops are operated and maintained in accordance with the design and licensing requirements as expressed in relevant documentation. The main codes and standards applicable to Licence F0245 are those that appear in section 59 of the Regulations and Australian Standard AS/NZS 2243.4:1997 Safety in laboratories Part 4: Ionizing Radiations.
Observations
In general, the management of safety and security at OPOF was found to be satisfactory and in accordance with the POC for facility licences. However, there appeared to be room for improvement with respect to OPOF plans and arrangements (currently showing information which is out of date and needs to be updated) and training. These matters are further detailed below as areas for improvement.
Effective control
OPOF is committed to safety. The management accepts responsibility for hazard identification and management evident from documents reviewed and interviews. The work conducted at OPOF involves rare earth minerals and/or ore samples contain naturally occurring radioactive material (NORM) in low specific activities from mining or mineral processing businesses. This is reflected in the risk assessment which showed that most risks are associated with WHS hazards.
All staff are familiar with and encouraged to use the GRC system for reporting issues including incidents or hazard identification. New starters are introduced to the software and guided to use the system. The number and nature of the registered events showed there was a very good reporting culture. Many entries recorded hazards for tracking purposes and improvement. The actual events reviewed were well and timely documented, good lessons were drawn and actions implemented. It was clear that OPOF uses the system effectively to continuously improve its operations.
Safety Management
Safety documentation is informed by the safety policies and objectives developed both at ANSTO and more specifically at OPOF level. All levels in the organisation contribute to management of WHS and radiation risk at ANSTO.
The recently updated risk assessment identified several ‘medium’ inherent risks but most of these were conventional in nature. Only two risks related to radiological impact. The controls (the ventilation system) mitigating the risks were checked and found to be implemented. Their effectiveness was maintained by regular maintenance which has been carried out according to the schedule.
Change management is led by ANSTO WHS management using controlled processes and based on the ANSTO overarching change control process.
Considering the risk associated with the facility this was considered appropriate and no deviations were identified. For example, the inspectors reviewed a project to make temporary changes to the SWMES formwork for a recent project where safety provisions were deemed necessary.
Minerals division has an elected Health and Safety Committee with multiple channels for staff to connect and share information, ideas or concerns about safety issues. Occasionally these forums have given rise to a radiation issue that is followed up and addressed. OPOF seek advice from subject matter specialists such as health physics surveyors and the designated area radiation protection advisor (RPA).
Training and education
Training generally comprises mandatory and role specific segments. While the former is mainly site-wide training such as security or radiation protection, the latter is more focused on specific OPOF hazards, e.g. hazards associated with NORM. The staff training records over the last 2 years showed some outstanding training in security (e.g. 123 days overdue) and risk assessment (maximum 1331 days overdue). The majority of the staff with incomplete training were shown to be casual employees not recently employed by OPOF, or ANSTO employees seconded elsewhere within ANSTO. A relatively small fraction of the current OPOF staff have not completed their scheduled training. Overdue training management is identified as an area for improvement.
A similar area for improvement was identified in the previous ARPANSA inspection in February 2020. However, it is recognised that the management of training has improved and the amount of training now due or past due has dropped significantly.
Radiation Protection
The principles of radiological protection have been adequately reflected in the documents describing the processes OPOF conducts. The physical inspection of the OPOF building demonstrated that appropriate safety practices are maintained. The safety analysis report (SAR) references the radiation safety standards of OPOF.
The OPOF staff annual radiation doses were found to be well below the dose constraint of 1 mSv which is aligned with the statutory annual dose limit for a member of the public. Average effective doses over the last 4 years showed a general downward trend with the maximum individual dose as at September 2022 of 0.27 mSv.
The OPOF facility has a dedicated RPA who provides a timely support on demand. The RPA is involved in the project design, such as pilot plants, training and risk assessments. The annual health physics survey records of the relevant areas were sampled and reviewed. No deviations from the plan were identified. The area contamination was found to be at background levels.
Maintenance of the safety and security systems was found adequate considering the facility risks. The most important systems with impact on safety are the ventilation systems with HEPA filtration. The systems were shown to be maintained appropriately using the computerised maintenance system SAP and conducted according to the schedule.
Radioactive waste and ultimate disposal/transfer
OPOF receives NORM from customers who are seeking to learn how to unlock and exploit the value of the mineral properties of this material stream. Whether ANSTO handling of the material is very basic or quite complex, ultimately all the material will be returned to the owner at the original location from where it was mined or milled. Essentially that material is native to that site and its ownership does not transfer to ANSTO or OPOF. ANSTO contractual documents, which OPOF customers are required to accept, state that all material is the property of the original consigner and will be returned to the customer. In this way, OPOF produce no waste material and there is no radioactive material to manage beyond the term of the service contract or agreement.
Protection of the environment
All OPOF facilities are bunded to prevent the release of chemicals and NORM from the facility and ultimately to the environment. The potential for liquid and airborne releases into the environment is monitored by ANSTO Environment by periodic analysis of water and soil samples. The environmental samples are independently verified by ARPANSA. The ventilation system is monitored for airborne discharges and quarterly reports are provided to ARPANSA. The OPOF monitors have not detected any radionuclides discharged into the atmosphere.
Security
OPOF follows the ANSTO site-wide security protocols to manage the general security aspects. ANSTO Security is a service provider to OPOF in matters specific to the facility. Due to the nature and scope of OPOF work, the security expertise is not required in day-to-day activities and therefore reliance on the ANSTO overarching processes is dominating.
ANSTO Human Resources conducts periodic enquiries every 3-6 months to screen non-employees who hold a site-pass and the building access rights for this cohort. ARPANSA emphasises that the licence holder must drive these checks for security to make sure they are timely.
The OPOF Plans and Arrangements for Managing Safety include the facility Security Plan. ANSTO requires that the document be reviewed annually. The last revision was dated in August 2021 and therefore, it was slightly out of date. Some information presented in the Security Plan was not up to date, such as names and contact details. It is acknowledged that ANSTO Security has recently developed a format for facility Security Plans which intends to contain all expected information. That format has been gradually implemented across ANSTO and the OPOF Security Plan will be updated in a due course. This is another area for improvement.
Emergency plans
OPOF periodically conducts emergency evacuation exercises. The division recently conducted an emergency exercise which involved a local laboratory evacuation to the ANSTO safety point. This involved a smoke emission and smoke door closures to isolate areas of adjacent buildings and other facilities. Another example of exercise management tested LPG emergency valve shut off operation for gas leakage. Although Covid has been disruptive to emergency management practice and drills, Minerals Division is now meeting with a new ANSTO emergency operations manager and drills and exercises will be resumed.
Findings
The licence holder was found to comply with the requirements of the Act, the Regulations, and licence conditions.
The inspection revealed the following areas for improvement:
- Managing overdue training
- Updating the Security Plan
It is expected that improvement actions will be taken in a timely manner.
