Inspection report: Australian Nuclear Science and Technology Organisation (ANSTO), Waste Operations, Lucas Heights, (R21/06344)

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 F0260. 

The scope of the inspection included an assessment of ANSTO’s performance against the Performance Objectives and Criteria (POC) in Emergency Preparedness and Response, Event Protection, Performance Reporting and Verification, Inspection Testing and Maintenance and Security. Aspects of the ANSTO Central Emergency Management (EM) and Security function were also inspected in relation to the support service provided to Waste Management Services. The inspection consisted of a review of records and interviews, and was conducted by video.

Background

The Waste Operations facility, under ARPANSA licence F0260, consists of several waste and service specific sub-facilities for the management of ANSTO’s radioactive wastes and nuclear material.

Observations

The licence holder was found to be in compliance with the Act, the Regulations, and licence conditions with respect to Emergency Preparedness and Response, Event Protection, Performance Reporting and Verification, Inspection Testing and Maintenance (ITM) and Security. The inspection also concluded that overall, Waste Operations continues to reflect the principles of these POCs in its controls, behaviours and management system.

Two areas for improvement (AFI) were identified. 

The two ITM-related AFIs raised at the inspection in November 2019 relating to formal acceptance of critical systems post-maintenance and alignment of items important to safety with the Waste Operations Asset Management Plan are being addressed through the continued roll out of the Waste Operations maintenance strategies. This is discussed further on page 3 of this report.

Emergency Preparedness and Response and Event Protection 

Since the last Waste Operations inspection on Emergency Preparedness and Response, ANSTO Central EM has, as part of a sub-committee (which included ARPANSA representatives) authorised by the NSW State Emergency Management Committee (SEMC) and the Sydney Metropolitan Regional Emergency Management Committee (REMC) updated the Lucas Heights Emergency Sub Plan and produced the supporting technical document AG-4552 Lucas Heights Radiological Hazard Assessment and Protection Strategy. This captured changes in ANSTO facilities, revised threat and hazard assessments and aimed to align with relevant parts of IAEA Safety Standard Series No GSR Part 7: Preparedness and Response for a Nuclear or Radiological Emergency. 

In addition, the ANSTO Emergency Management Plan Lucas Heights (AG-5950) and the ANSTO Emergency Management Plan (AG-5945) were updated to reflect these revised documents and included new response sub plans for a number of emergency scenarios.  
The ongoing roll out of the ANSTO Business Resilience Learning and Improvement Strategy (under AG-4532) was reviewed, focussing on the emergency response parts. This strategy aims to, amongst other areas, improve oversight of incident management competencies, incident preparedness, lessons learned and conduct of emergency exercises and training and to ensure the skills and competencies of emergency response staff are developed, measured and documented. 

At the time of the inspection it was noted that the management and oversight of lessons learned (section 7 of AG-4532) had been implemented with actions from drills and exercises now managed centrally using the Governance Risk and Compliance (GRC) software system. Records from a recent power outage incident were reviewed as confirmation of this. No issues were raised. This was considered to be an improvement from past inspections where lessons learned from a number of central exercises and real life incidents had been found to not have been captured due to resourcing issues.

The ongoing roll out of the training under AG-4532 was examined with Incident Controllers, Crisis Management Team members etc. continuing to undertake courses such as the Australasian Inter-Service Incident Management System training and the ANSTO developed Emergency Workers and Guidance Values for Restricting Exposures training. In addition, the ANSTO Radiological and Nuclear Emergency Preparedness and Response training was noted to now be available to and being undertaken by external responders.
Ongoing work with external responders and site familiarisation visits were discussed and evidence sighted of 8 visits from the NSW Police Critical Infrastructure and Fire and Rescue NSW teams over the past year. 

A number of inconsistencies noted in a previous inspection by ARPANSA in the overarching central documentation are still present. These included inconsistencies in training and refresher training requirements, incident level nomenclature, number of emergency scenarios and the role of the Business Resilience Working Group and are across documents such as AG-4532, AG-5945, AG-5950 and AP-2361. In addition the requirement in section 9.3 of AG 5945 regarding the frequency of exercises for ‘high risk’ buildings was considered to be unclear since the exercise type and risk assessment process were not identified.  An area for improvement was raised to encourage rectification of these discrepancies in order to be in line with ARPANSA POC 5.1.2 which promotes the use of clear guidance in emergency procedures and instructions. 

Since the last inspection on Emergency Preparedness and Response, Waste Operations has conducted two emergency exercises/drills for buildings 57 and 41 (as well as one for B42 which is out of the scope of this inspection as it is covered under the HIFAR licence).  
These exercises covered testing of the Emergency Response Team (ERT) response, fire response and failure of active ventilation. The exercise reports were examined and no significant issues were raised. All lessons learned had been captured and actioned through the ANSTO GRC. 

The annual whole site Bushfire Inspection report by the NSW Rural Fire Brigade was reviewed and evidence of completion of the 17 actions noted across the SAP system and/or via photographic evidence. No issues were raised. 

The last AF-2534 Bushfire Preseason Building Check and Preparation record and actions were inspected for all of the buildings under Waste Operations. No issues were raised. 

Pest, fire and security system maintenance records were also inspected and are discussed in the ITM and Security sections below. 

Performance reporting and verification

Reporting conducted against licence condition requirements including quarterly reporting, since the last Performance Reporting and Verification inspection in 2019, were reviewed and no significant issues raised. 

A number of event investigations (both WHS and Security related) including GRC 5837, 6199, 8143, 9992, 10213 and 9222 were reviewed and the status of actions checked. No significant issues were raised with actions ranked as important to radiological safety noted to be completed.

Since the last inspection, the use of a business analytics service has been employed to provide improved visualisation and report/dashboard creation for the GRC software. The status of outstanding investigations/actions was viewed at the time of the inspection using this dashboard and no issues raised. 

The sharing of information on relevant events across site was noted to be ongoing with monthly facility meetings and also the use of safety/security alerts and safety themes implemented periodically across the ANSTO site. 

Longer-term trends in event causes were noted to be age management related and actions taken by the licence holder to address these with the roll out of the Waste Operations Asset management program were examined with no issues raised (see ITM section for more information).  

Recent proposed improvements related to human factors were noted such as the update of instruction I-6587 to improve the way in which inspection of the LLSW drums are undertaken. This improvement was based on safety feedback from operators.

Inspection Testing and Maintenance (ITM)

A sample of records for Operating Limits and Conditions (OLC) and other safety critical related inspection testing and maintenance was examined including the B23 and B41 pond analyses surveillances, the 6-monthly checks on the B41 alarms and the annual checks of the condition of the low level waste solid drums in B59. No significant issues were raised. 

Work conducted under the stages of the ongoing project on the legacy B57 Intermediate Level Liquid Waste (ILLW) tank farm were examined in detail. This included review of the risk assessment paperwork and safety and security significance categorisation on installation phases 1a, 1b, 2a and 2b which covers replacement of catch valves, main transfer hose sampling system sight glass and luer valve and the vent/vacuum valves. No significant issues were raised.

The Nuclear Operations Long Term Planning process was inspected, comprising examination of the project priority live document, the project resource documentation, and the waste operations resources documentation. The projects were noted to be ranked by risk with the Beverly Ryle prioritising method  applied to ones with equal rating. The management of the project priority was found to be appropriate with updates regularly made according to completion of project stages and work that constituted higher risk being added as it emerged. 

Progress on key actions from the Waste Management Asset Management Plan G-3233 was reviewed. This plan covers the planning horizon of 20 years in alignment with planning considerations for the National Radioactive Waste Management Facility (NRWMF). A key action from this is the development of the overarching maintenance strategies for the waste operations plant. The maintenance strategies including B20A, B23 (waste operations areas), B59, B41, B27, B11, the effluent plant system, the segmented gamma scanner plant, the supercompactor and the UF6 Glovebox were reviewed in detail and no significant issues raised, noting that some are in draft and require further development. These strategies have been based on the Reliability Centred Maintenance and Failure Modes Effects and Critical Analyses (FMECA) principle approach which amongst other areas, relates maintenance to plant failure modes to determine the optimal maintenance strategy. Factored into this is the critical safety of the plant items as well as other considerations. 

The roll out of the maintenance strategies aims to address technology and obsolescence issues with the waste operations plant since when complete, the strategies are intended contain all identified critical spares. These are then intended to be integrated into the SAP system where appropriate. This will further assist with age management issues relating to radiological safety and the waste operations plant.

Examples of maintenance strategies that are managed by the ANSTO Asset Management Services (so not under the control of Waste Operations) were also inspected also including the pest control and fire system testing. Evidence of completion of recent testing and treatment in line with these strategies was examined and no issues raised. 

Evidence of the engineering assessment for replacement components (non like-for-like) for waste operations projects were examined, including the B57 ILLW Tank valve replacements and B20B drum dryer feed tank. No significant issues were raised. 

Evidence of training of contractors engaged in maintenance were reviewed including 10 non-employee business contractors involved in the characterisation of remote handled waste. The training was noted to be in line with the ANSTO contractor management requirements. 

Security 

The Waste Operations protective security system was designed to take into account and meet a range of regulatory requirements and expectations (both domestically and internationally) across radioactive sources and material, nuclear material and associated activities and government information, assets and people. There has been no change to the design basis since the last inspection.

ANSTO Security and Safeguards have redrafted a number of high-level ANSTO security documents such as the ANSTO Nuclear Security and Safeguards Policy, the ANSTO Security Plan and the ANSTO Security Manual (including a new generic security plan template to be shortly rolled out across site). The nominees for all licensed facilities should refer to and implement, where applicable, the protective security requirements set out within these higher-level documents. Nominees for all facilities (and source licence) holders should further develop their own local arrangements with the higher-level documents in mind, noting these higher-level documents capture the requirements under the Act and Regulations. The revised Waste Operations Security Plan and Annexes were noted at the time of the inspection to be in the planning stages with intention to reissue in line with the soon to be issued security plan template.  The need to update and re-issue the security plans was noted as an AFI. 

Maintenance test sheets for security-related equipment in the Waste Operations buildings covering 2020/2021 were reviewed along with the maintenance schedules for the next quarter. No issues were raised. It was noted that assets were currently being configured in the SAP maintenance system with the intent of forming a new maintenance strategy for further continuous improvement. 

Training records for Waste Operation staff were inspected for the past 12 months and it was determined that the required security training has been completed by appropriate staff. 

Access control activity reports were examined for a key Waste Operations’ building against the authorised personnel access list (including clearance levels) for a period of time in June 2021. No discrepancies were found. 

The recent exercise conducted for a key waste operations building was noted along with the intention to consider integrating the security exercises required under ARPANSA Code Radiation Protection Series 11 with the site wide emergency response exercises/drill schedule. This exercise had been attended by an ARPANSA inspector, at the time, and no significant issues were raised. 

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. A number of inconsistencies including discrepancies in training and training refresher requirements, incident level nomenclature, number of emergency scenarios and the role of the Business Resilience Working Group exist across documents such as AG-4532, AG-5945, AG-5950 and AP-2361. In addition, there is clarity needed around the risk assessment process for buildings and the type of annual exercise required in AG-5945. 
2. The Waste Operations Security Plan should be updated to ensure alignment with the ANSTO Nuclear Security and Safeguards Policy, the ANSTO Security Plan, the ANSTO Security Manual and to be in the format of the soon to be rolled out generic security plan template. 

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