Inspection report: Australian Nuclear Science and Technology Organisation (ANSTO), Actinide Suite, Lucas Heights Science and Technology Centre, R22/02902

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 F0247. 

The scope of the inspection included an assessment of ANSTO’s performance against the Performance Objectives and Criteria (POC). The inspection consisted of a review of records, interviews, and physical inspection of the facility. 

Background

The Actinide Suite is a research facility used to develop and characterise wasteform materials to immobilise nuclear waste.  

The main codes and standards applicable to this facility are those that appear in section 59 of the Regulations plus: 

• Australian/New Zealand Standard: Safety in laboratories Part 4: Ionising radiations (AS/NZS 2243.4:2018)
• Australian/New Zealand Standard: Safety in laboratories Part 5: Non-ionising radiations -Electromagnetic, sound and ultrasound (AS/NZS 2243.5:2004)
• Australian/New Zealand Standard: Photobiological safety of lamps and lamp systems (AS/NZS IEC 62471:2011)
• Radiation Protection Series S-1 (Rev. 1) Standard for Limiting Exposure to Radio frequency Fields – 100 kHz to 300 GHz (2021)
• Radiation Protection Series 12: Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006)  
• ICNIRP Guidelines for Limiting Exposure to Time-Varying Electric and Magnetic Fields 1 Hz - 100 kHz (2010)
• ICNIRP Guidelines for Limiting Exposure to Electric Fields Induced by Movement of the Human Body in a Static Magnetic Field and by Time-Varying Magnetic Fields Below 1 Hz (2014)

Observations

Performance reporting verification

ANSTO routinely submits reports to ARPANSA providing details related to safety of the facility as is required by the legislation. These documents have reported information relevant to safety at the facility. For instance, occurrences whereby deviations from the expected performance of the plant have been detected and investigated by ANSTO, the revision of the plans and arrangements and the implementation of changes unlikely to have a significant effect on safety. No instance of non-compliance has been identified. 

Configuration management

The Actinide Suite has a Safety Analysis Report (SAR) and a risk assessment. Collectively these documents, demonstrate the safety of the facility, and are useful tools for communicating to internal and external stakeholders how the facility can be operated safely. It is understood that ANSTO had made considerable efforts to review these documents in 2017 but the work was not finished due to changing organisational priorities. The previous ARPANSA inspection conducted in 2019 identified an area for improvement in relation to updating these documents. In the meantime, ANSTO has updated and reissued the risk assessment for the facility but the SAR, which was published in 2010, has not been revised. Hence, the expectation that the SAR will be revised remains. This is identified as an area for improvement below.     

The criticality safety assessment was performed in 2003. This considered both normal conditions and abnormal conditions. It concluded in the establishment of a limit on the total amount of fissile material that can be held in the facility and a second limit on the amount that can be used in solution. The criticality certificate issued in 2019, which is informed by the criticality safety assessment, reiterates the total mass limit for fissile material, however, the limit on the amount of fissile material that can be in solution is not present. The fissile mass limit on material in solution had been dropped by the ANSTO criticality safety officer in the latest document review as it was judged that it would enable easier compliance and auditing. The criticality officer indicated the intention to revise the criticality assessment now to remove any inconsistencies around the limits in place within the facility. It is expected that a criticality safety assessment will fully document the bounds of the system, the safety margins, and the details of the assessment performed. It is also expected that the assessment be conducted in accordance with recognised standards and document compliance with safety criteria, establish requirements and the basis for those requirements. This can be facilitated by the management system for criticality safety. This is identified as an area for improvement below.        

Inspection, testing and maintenance        

Laboratory staff routinely perform many of the inspection testing and maintenance (ITM) actions themselves, and as such, have developed a bespoke system for monitoring and managing the required ITM activities. This system sits within the laboratory itself which is understood to be convenient and effective for the laboratory staff. The facility also uses commercially available software to manage activities performed by other parts of ANSTO and external service providers. The software can display an overview of ITM activities using different coloured dots to distinguish the work which was complete and the outstanding activities. A single example of an ITM activity on this software was examined. Although the example appeared to have been completed, upon further examination it was identified that a planned activity had been postponed. As the overview did not show the activity as outstanding, this aspect of the system introduces the possibility that required maintenance activities may slip through the cracks. This is identified as an area for improvement below.          

The facility is equipped with a series of gloveboxes for handling material. Laboratory staff routinely inspect the seals on the gloveboxes and repair them when needed. The gloves and o-rings are also inspected and replaced if visible damage is present. However, all gloves and o-rings are also pre-emptively replaced on a regular basis. 

Training

The facility uses a colour coded approach to manage the training and re-training of workers. This differentiates who has current access, who is approaching the point where retraining will be required, and those who have had their access removed until retraining is performed. The level of training required by an individual is comparable to the degree of access and independence that the worker is given.    

Event protection

A variety of external initiating events are identified and analysed in the SAR for the facility. None of these are expected to result in a significant release of radioactivity or otherwise represent material risk. One of the initiating events, loss of offsite power, has occurred in recent times. However, the facility is designed to accommodate this, and when it has occurred, the appropriate components have performed as planned.  

Security

Workers and management are required to undertake security training. Training is normally managed within ANSTO’s learning management system (LMS). ANSTO has over the last 18 months been working to redevelop/refresh this training. In order to implement these changes, the security training was removed from the LMS. One of the advantages of the LMS is that it allows management to receive reports of outstanding training for their workers. Although this change had the potential to result in lapses in worker training, no instances were identified where mandatory security training was missed.  

Radiation protection

ANSTO has a system for monitoring the radiation doses received by workers. This involves thermoluminescent dosimeters (TLDs) for measuring the external radiation and a whole body monitor for measuring internal radiation exposure. Although, these systems are able to assess the magnitude of most exposures, there are some situations where radioactivity that is taken internally is difficult to detect with a whole-body monitor. ANSTO has had a long-standing arrangement with an international partner that would measure the radioactivity in a biological sample if needed. This arrangement for bioanalysis services filled the gap in ANSTO’s capability. However, it was recently conveyed to ANSTO that the partner organisation was no longer able to provide this service on demand. While the service has not been needed for a substantial number of years, it is expected that ANSTO have comprehensive measures to assess doses received by workers if needed. This includes capability to measure radioactivity in a biological sample. Hence, it is expected that ANSTO assess the options for fulfilling this capability and enact suitable measures. This is identified as an area for improvement below.  

IAEA General Safety Requirements Part 6 Decommissioning of Facilities indicates that the planning for decommissioning a facility should begin prior to being needed. Hence the IAEA suggests the preparation of a decommissioning plan which is maintained ‘throughout the lifetime of the facility…in order to show that decommissioning can be accomplished safely to meet the defined end state.’ A plan containing the appropriate level of detail does not currently exist for the future decommissioning of the facility. Although, it is observed, that there is currently no explicit regulatory obligation requiring this and it is understood that ANSTO intends to continue operating the facilities for a substantial time, yet this, nevertheless, is identified as an area for improvement below as it would align with accepted best practice. The facility has, however, been collaborating with ANSTO’s waste operations to perform a waste stream analysis. This enables ANSTO to plan for the capacity and capability to handle the foreseeable future waste from each facility.     

Emergency preparedness & response

ANSTO has an emergency exercise schedule which forecasts several years into the future. The schedule is an all-hazards approach that assesses the occupancy and usage of each building in order to understand the type of risk that may be present and combines this with an assessment of the magnitude of the risk to achieve a risk-informed approach that is tailored to each specific building. This analysis is used to determine the scope of the next exercise to be conducted. This can be either a drill, table-top exercise, partial exercise, or full exercise. Planning for an exercise of the emergency arrangements for the Actinide Suite were commenced. However, this was not completed and no exercise was conducted as priorities needed to be realigned due to the COVID pandemic. ARPANSA expects that suitable emergency arrangements are made relevant to the hazard that is present at a facility and are routinely tested to enable confidence that those arrangements will perform if required. The length and breadth of an emergency exercise can be altered depending upon the aspect that is to be tested or the degree to which the emergency arrangements are challenged. It is expected that the planning will be completed and an exercise conducted for the Actinide Suite in a timely manner. This is identified as an area for improvement below.        

Findings

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:

1. Maintaining an up-to-date SAR for the facility. 
2. Criticality safety assessment and the management system associated with criticality safety.   
3. The arrangements for oversight of the ITM activities.
4. Enable options for maintaining capacity to perform bioanalysis of hard-to-detect nuclides if needed.  
5. Development of a decommissioning plan.  
6. An appropriate emergency exercise and the learning of any lessons from it to improve capability to address any future events should they occur.  

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