Inspection report: Australian Nuclear Science and Technology Organisation (ANSTO), R24/02112

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 F0293.

The scope of the inspection included an assessment of ANSTO’s performance against the Facility Performance Objectives and Criteria (FPOC). The inspection consisted of a review of documentation, interviews, and physical inspection of the site.

Background

The Little Forest Legacy Site (LFLS) is a legacy waste disposal site. Between 1960 and 1968, the site was operated by the then Australian Atomic Energy Commission (AAEC). It is a non-operational site that is currently managed under a ‘possess or control’ licence.
The site includes about 1600 m3 of material disposed in shallow trenches dug out in clay rich soil. The material consisted of equipment and waste contaminated with low levels of radioactivity, effluent sludge, chemicals and beryllium. After emplacement of the waste, the trenches were initially covered with a 1 metre thick layer of local clay rich soil.

The main code applicable to this licence is: 
RPS C-1 Code for Radiation Protection in Planned Exposure Situations (Rev 1) (2020)

Observations

It’s been approximately four and a half years since the last inspection in 2019 (no inspection was conducted during COVID-19 pandemic period). In that time, there has been no significant changes made to the site nor have any changes had an impact on safety. Work is expected to commence in the middle of this calendar year which is considered to provide a medium-term solution to the management of the site.

No issues were identified during this inspection.

Effective control

It is a condition of licence that the holder must, at least once every three years, review and update (if necessary) their Plans and Arrangements (P&As) for managing safety. ANSTO’s Waste Management Services (WMS), who are responsible for the site, are currently undertaking this review with an aim to consolidate multiple documents into a singular form for all its licences.

The work performed at the site remains unchanged and consists of routine inspection, monitoring, environmental sampling and maintenance (largely grass cutting/mowing). All non-routine works are required to go through ANSTO’s standard evaluation and approval process.

The future work mentioned in the Observations section of this report is only a medium-term solution and has already been approved by ARPANSA under section 63 of the Regulations. The solution will see a cap added above the trenches to ensure greater control over the site. A final solution for the site has not yet been determined however multiple options are being considered. The cap is to be designed in such a manner that it can be removed to facilitate decommissioning of the site once a decision is made.

Safety management

Since the last inspection, no events have occurred at the site nor have any safety related changes been made. The safety assessment for the site has been updated since 2019 and supplied to ARPANSA as part of the approved section 63 submission. A Safety Analysis Report has also been developed. Both of these documents address an area for improvement (AFI) from the previous inspection (R19/10665).

Radiation protection

There is no specific radiation safety training for the site. ANSTO staff must complete the requisite inductions and training in line with ANSTO’s global WHS management system based on their position description. The requirements specific to contractors also fall within these arrangements but are limited to informal safety briefings given the area classification of the site. ANSTO do not consider that more detailed training is needed. No issue with this was raised by the ARPANSA Inspector.

Nominee oversight of training was considered an AFI as per R19/10665. Though the nominee has accountability for safety and security of the site, no arrangements exist at ANSTO which allow for management to have oversight of or access to training records for staff that do not reside within the business unit for which they are responsible. It is the responsibility of each business unit’s management to ensure their staff are trained appropriately for the tasks they are expected to undertake. However, in response to the AFI, oversight of training specifically in relation to WMS staff has been improved.

At present, the site has no routine involvement from ANSTO’s Radiation Protection Services team given the site’s non-operational state. Though they have been engaged for work in the past, future involvement will be based on need.

Radioactive waste management

Records of waste from the disposal work conducted in the 1960’s has been used to estimate the inventory buried at the site. Further work is being undertaken to get an even greater understanding of the inventory. As the site is not operational, no additional material will be added, nor will it be removed outside of small environmental samples (these are taken at distances away from the buried inventory).

Ultimate disposal or transfer

There is no disposal or transfer of radioactive material from the site. Any removal of radioactive material from the site will require approval from ARPANSA.

Security

While the LFLS P&As are being reviewed as part of the planned document consolidation, WMS will remove the security plan and develop a stand-alone security document in accordance with ANSTO Security’s current guidance and template to adopt the organisations more uniform approach.

That said, the security arrangements for the site have not changed nor does ANSTO consider that they need to.

Emergency preparedness & response

No changes have taken place for the site in terms of emergency preparedness and response between the last inspection and now. Should an emergency take place, it has been reinforced to staff that they’re to leave the site immediately and engage ANSTO’s emergency response team through the site-wide protocols in place.

Emergency exercises are currently being planned for multiple areas at the Lucas Heights location including LFLS, however, it is not considered to be high priority.

Environmental protection

As previously discussed, one of the only activities performed at the site is routine environmental sampling/monitoring. This is a documented program which lists the specific requirements for the site and its surrounds and includes airborne, soil (if collected), groundwater sampling in conjunction with visual inspections and environmental dose rate monitoring. The results of these are reported to ARPANSA bi-annually.
To-date, there have been no significant changes in the results of the analyses reported.

Findings

ANSTO LFLS was found to be in compliance with the requirements of the Act, the Regulations, and licence conditions.