Inspection Report: Australian Nuclear Science and Technology Organisation (ANSTO); Nuclear Materials Facility (NMF), Lucas Heights Science and Technology Centre; 28 February – 2 March 2022

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 F0248. 

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 Nuclear Materials Facility (NMF) is comprised of two separate areas that are involved in research into nuclear and radiological materials. These two areas are: 

• The Materials Fabrication Bay (MFB) which is a nuclear fuel cycle research and development facility designed to process, use and store nuclear and radioactive material for various research and development projects. 
• The Post Irradiation Examination (PIE) Hot Cells which is a hot cell facility that has been designed to allow irradiated structural materials and non-actinide waste-form ceramic materials to be examined, characterised, and tested. 

Both areas are licensed to manage a number of sealed and unsealed radioactive sources that are necessary to carry out the research. The inspection focussed on the MFB as the PIE hot cells facility has not yet been fully commissioned to handle active samples.  

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: Ionizing radiations (AS/NZS 2243.4:2018)
• Australian/New Zealand Standard: Safety in laboratories Part 5: Non-ionizing radiations -Electromagnetic, sound and ultrasound (AS/NZS 2243.5:2004)
• Radiation Protection Series S-1 (Rev. 1) Standard for Limiting Exposure to Radiofrequency Fields – 100 kHz to 300 GHz (2021)
• Radiation Health Series 9: Code of practice for protection against ionizing radiation emitted from X-ray Analysis Equipment (1984)
• ICNIRP Guidelines for Limiting Exposure to Time-Varying Electric and Magnetic Fields 1 Hz - 100 kHz (2010)

Observations

Performance reporting verification

ANSTO routinely provides reports to ARPANSA detailing matters relevant to safety on a quarterly basis. Facility management compiles these reports, and if needed, discusses any items of significance with their senior management. These reports typically detail the movement of sources in and out of the facility and the review of plans and arrangements for managing the safety of the facility. In responding to the covid pandemic, ANSTO put in place some changes. Although these changes were unlikely to affect safety, the facility still reported to ARPANSA that the changes had been made in a timely and open manner as required by the legislation. A log of all changes made at the facility is kept as part of their standard assurance processes. 

Configuration management

The MFB has a current criticality certificate which was issued in June 2019. The criticality assessment that supports this certificate was prepared in 2010 and then reviewed in 2015. This recommended that a limit on fissile mass involved in a single ‘wet’ experiment be introduced in addition to the operational fissile mass limit. Both limits, however, are not present on the criticality certificate itself. The fissile mass limit on ‘wet’ experiments was dropped by the criticality safety officer as it was judged that it would enable easier compliance and auditing. The criticality officer indicated the intention to address this observation and to revise the criticality assessment to remove any inconsistencies around the limits in place. 

It is expected that the 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 will 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.            

The MFB uses spreadsheets to maintain visibility and control over the sources and material entering and leaving the laboratory. The spreadsheets have been developed to evaluate holdings on a nuclide-by-nuclide basis so that limits are not mistakenly exceeded. The system was tested in a couple of instances. Facility management were able to demonstrate that sources selected at random from the spreadsheet could be promptly identified within the radioactive waste store.       

Inspection, testing and maintenance

ANSTO uses commercially available software to manage planned maintenance activities. Use of the software requires that strategies are created in the system to address foreseeable maintenance needs for each piece of plant. ANSTO is working to put the calibration of NMF radiation monitoring equipment onto the software system. The radiation detectors held by the facility were confirmed to be within their calibration dates. In addition to the software, facility management has developed a spreadsheet for predicting the maintenance activities throughout the year and maintaining oversight to confirm that the maintenance was completed.  

Training

The previous ARPANSA inspection conducted in 2019 reported that there was a relatively high percentage of employees with overdue training including participation in a refresher course in radiation and nuclear materials. At the time, the facility management were developing the tools to monitor and measure worker performance in this area. As a user-based facility it is difficult for the facility to predict whether a worker who has previously used the facility will need to use the facility again. If the worker does not use the facility, there is no need for them to complete the training associated with the facility. However, if the worker does use the facility they need to keep renewing their training as it expires over time. Since 2019, facility management has continued monitoring the training status of workers and has used this as an informal indicator of workplace culture. The efforts of the facility management have decreased the number of workers with outstanding training. Those employees who were currently listed as having outstanding training was reviewed. Examples where the training was no longer required due to changes in work/managerial responsibilities and retirement were identified. A further sample of the remaining workers were individually examined. None of the workers in the sample were continuing to access the facility.     

Event protection

The building housing the facility has been challenged by the recent rainfall which has been greater than typical levels. This has resulted in leaks in the roof, rising water levels and this translated into elevated humidity levels. Despite this, no impact with radiological consequences has been identified. Work to address leaks is undertaken when needed and the use of greater degrees of negative pressure in the areas with greatest radiological risk conveniently minimises the risk due to water ingress. However, it is expected that ANSTO will continue to monitor and manage the impact of water on the facility. 

Security

ANSTO’s security has recently completed a review of the template for describing the security of a facility. A standardised template is used to ensure the references to corporate policies are correct. However, the details are tailored so they are relevant to each facility. No issues with security were identified.   

Radiation protection

ANSTO has a cohort of Radiation Protection Advisors (RPA) that provide advice and assistance to each of the facilities and other users of radiation sources. The NMF is assigned an RPA from this group on a rotating basis. By rotating the RPAs through the various facilities, ANSTO is able to routinely introduce fresh eyes and reduce the risk of blind spots developing. In recent times the RPA has been involved in the implementation of the PIE hot cells and the review of the safety assessment for the cutting of active material using a low-speed saw. The RPA is also routinely involved in the review and identification of lessons that can be learned from events that occur in the facility.  
Consistent with ANSTO practice, the RPA has implemented a facility-specific dose constraint that can be used for the planning of future work and the monitoring of doses received by workers. Radiation dose rates and contamination levels in the MFB are typically low in occupied areas. The facility is equipped with a variety of radiation detectors to empower workers to monitor their work areas themselves. An independent group also conducts formal radiation dose rate and contamination surveys on a monthly basis. If any radioactivity is identified away from the area where the work is being conducted it is considered to be unplanned contamination and facility management acts accordingly to identify the source of the radioactivity and review the controls that are in place for that work.      

Emergency preparedness & response

The facility, in conjunction with the ANSTO Emergency Coordinator, organised and conducted an emergency exercise in late 2021. The scenario that was used involved an unconscious worker who had spilled chemicals and radioactivity on themselves. This scenario was defined in advance of the inspection, and an actor was employed to portray the unconscious worker. ANSTO checked that the area to be used for the exercise was free from contamination and other hazards. Simulants were used to represent the chemical and radiological hazard. Facility management was on-hand and prepared with technical details, such as radiation dose and contamination rates, and health details of the worker, such as heart rate, to feed into the exercise. Although these details were invented for the exercise, they were chosen to be realistic to the situation and the equipment being used. The facility filmed the exercise so that lessons can be learned now and into the future. ARPANSA expects emergency exercises to be conducted as part of the normal process of planning for possible future emergencies. However, it is identified that the MFB went above and beyond the normal standard in the level of the detail, planning, and effort involved in this particular exercise to make it as realistic as possible without endangering those involved in the exercise. Consequently, it is identified as a good practice.             

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. Criticality safety assessment and the management system associated with criticality safety.   

The inspection revealed the following good practice:

1. The level of the detail, planning, and effort involved in the emergency exercise conducted at the MFB in 2021 was above and beyond that typically seen elsewhere.  

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