Inspection report: ANSTO (Waste Operations), R24/02113

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 F0260. The scope of the inspection included an assessment of ANSTO (Waste Operations) performance against four of the Facility Performance Objectives and Criteria (FPOC): Effective Control, Ultimate Transfer and Disposal, Radioactive Waste and Environment. The inspection mainly consisted of a review of associated documentation, records and interviews.

Background

Waste Operations consists of several waste and service specific sub-facilities for the management of ANSTO’s radioactive wastes and nuclear materials. The key processing activities and waste management areas are generally grouped according to waste types. These include low and intermediate wastes (both solid and liquid), nuclear material, disused sources and decontamination and laundry services. Under F0260, ANSTO are authorised for the safe and secure storage, handling and processing of the aforementioned radioactive wastes.

Observations

In general, the management of radioactive waste under the control of Waste Operations was found to be sound. As a result of this inspection, one Area for Improvement (AFI) was identified.

Effective control

Though Waste Operations are responsible for the processing and management of radioactive waste on-site and maintain expertise in doing so, the establishment and continued revision of their safety case including the supporting safety assessments are developed in conjunction with ANSTO’s System Safety and Reliability group (outside of simple editorial/typographical changes). To ensure the safety case is as current as possible and reflects the ongoing operations of their facilities, ANSTO’s internal requirement is to ensure timely update and review of their Safety Analysis Report (SAR) within a five-year period. Currently, though the SAR is undergoing review, at the time of the inspection, revision was ongoing with a number of areas outside of the nominated review period due to resourcing. To address this, Waste Operations have engaged an external contractor to review what is currently in place, conduct a commensurate reassessment where it is considered appropriate and determine what gaps exist. Some high risks have been identified and have subsequently led to those processes ceasing. Once the review and update process has been completed, these documents will follow ANSTO’s Safety and Reliability Assurance process as per ANSTO’s standard process. 

ARPANSA published guidance material for emergency exposure situations (Radiation Protection Series G-3: Guide for Radiation Protection in Emergency Exposure Situations (2019)) which draws on international best practice in relation to emergency preparedness and response. In line with the other facilities at ANSTO, Waste Operations are conducting hazard assessments to inform emergency preparedness categorisation of buildings and facilities. At the time of the inspection this work was ongoing and delayed due to resourcing issues. 

Within procedures and instructions, where deemed appropriate by the licence holder, simplified and condensed risk assessments are added as an appendix to inform the occupationally exposed workers of the risk associated with the work being conducted. However, it is not clear whether these align with the greater safety assessments or are something separate. 

The above is considered to constitute an AFI not dissimilar from that which was identified in a 2020 inspection report (R20/05792). It has been reiterated in this inspection as reminder of its importance.

Radioactive waste management

ANSTO Waste Operations manage multiple streams of radioactive waste that are classified as either low or intermediate level waste and are largely in solid and liquid form (airborne discharges are controlled via systems in place such as active ventilation). Their solid waste drums which hold low level waste are internally required to undergo inspection every two years to ensure continued storage is safe (no corrosion, leaks, etc.). Approximately 16% of these drums have fallen outside of this inspection period, in part, due to a failure of the technology used. This has been rectified and inspections are once again taking place. 

Waste Operations use multiple inventories to record their holdings and are purposefully separated (disused sealed sources as well as safeguarded material inventories are independent of the other routinely managed wastes). Access to these inventories is managed appropriately on a need-to-know basis. 

ANSTO is also moving from their previous strategy of safe storage to a characterisation and conditioning approach which is aimed at preparing waste for eventual disposal or long-term storage at a future facility. Currently, 11% of ANSTO’s waste has been appropriately analysed with a confirmed process for conditioning, however, this has not been broadly resourced. ANSTO continue to emphasize their commitment to this work whilst routinely managing their growing waste streams. 

Legacy molybdenum waste management remains a priority for ANSTO with projects planned for treatment and conditioning as well as ongoing storage options. 

Inspectors reviewed evidence of compliance with the operating limits and conditions for the safe management of the Interim Waste Store which holds returned reprocessed spent fuel residues from the HIFAR reactor. No issues were identified.

Ultimate disposal or transfer

Prior to the inspection, multiple requests were made to the regulator to move material from the Commonwealth jurisdiction to the state level (NSW EPA). This along with examples of ‘scanned waste assessments’ were shown to inspectors in relation to how Waste Operations facilitates the removal of waste from the site. No issues were identified with the process.

Environmental protection

According to Waste Operations Plans and Arrangements, environmental objectives and targets have been set in relation to the management of waste in order to assist the organisation in attaining its overall environmental objectives. These include environmentally conscious programs to use solar energy for hot water, rainwater for washing effluent holdings tanks, use of lower energy LEDs, etc., to reduce the facilities impact on the environment. Further, Waste Operations licence conditions stipulate airborne discharges notification levels that have been determined in such a way as to keep doses below public limits, discharge authorisation limits have been determined and approved with Sydney Water, and internal policies for safe management and movement of radioactive waste are in place. 

Inspectors also queried some events that were raised and questioned aspects of the effluent management process in relation to their environmental aspects. No issues were identified.

Findings

ANSTO (Waste Operations) was found to be in compliance with the requirements of the Act, the Regulations, and licence conditions. The inspection revealed the following area for improvement: 

1. Timely review/update of the safety case and clear distinction of potentially associated risk assessments. 

It is expected that improvement actions will be taken in a timely manner.