|Licence holder||Australian National University (ANU)|
|Location inspected||Research School of Biology (RSB) and Research School of Chemistry (RSC)|
|Date of inspection||11-12 May 2023|
This inspection was conducted as part of ARPANSA’s source 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 source licence S0027.
The scope of the inspection included an assessment of performance at the ANU Acton premises in RSB and RSC against the Source Performance Objectives and Criteria (SPOC). The inspection consisted of a review of records, interviews, and a physical inspection of sources.
ANU is a research-intensive university located in Acton, Australian Capital Territory (ACT), and specialises in a range of activities that require the use of radioactive materials and ionising and non-ionising radiation apparatus. The ANU source licence covers several schools at the Acton campus and one at Mt Stromlo, ACT, many of which use controlled apparatus and controlled materials as part of their research and teaching roles. ANU is licensed under Section 33 of the Act to deal with controlled material and controlled apparatus for research purposes in its various schools.
The main codes and standards applicable to this licence are:
- RPS C-1 Code for Radiation Protection in Planned Exposure Situations (Rev 1) (2020)
- RPS 11 Code of Practice for the Security of Radioactive Sources (2019)
- RPS C-2 Code for the Safety Transport of Radioactive Material (2019)
- RPS C-6 Code for Disposal of Radioactive Waste by the User (2018)
- Australian Standard Safety in Laboratories – Ionizing Radiations (2018) (AS/NZS 2243.4-2018)
- Radiation Protection Series No. 12 Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006) (RPS12)
- Australian/New Zealand Standard Safety in Laboratories – Non-ionizing radiations-Electromagnetic, sound and ultrasound (2004) (AS/NZS 2243.5:2004)
- Australian/New Zealand Standard Safety of laser products Part 1: Equipment classification (AS/NZS IEC 60825-1:2014)
- Australian/New Zealand Standard Safety of laser products Part 14: A user’s guide (AS/NZS IEC 60825-14:2022)
In general, the management of radiation safety at both RSB and RSC in relation to controlled material and controlled apparatus was found to be sound. There appeared, however, to be areas where there was room for improvement as identified in the report.
ANU has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective use, storage and disposal of radiation sources throughout all schools at the university. This is supported by a comprehensive Radiation Management Plan (RMP), their Plans and Arrangements, to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions. It should be noted that a comprehensive review of the ANU RMP was conducted during the December 2022 inspection and this inspection therefore concentrated on the ‘local’ RMPs of both RSB and RSC.
ANU has a Radiation Safety Advisory Group (RSAG) that meets quarterly and comprises representation from all schools including RSB and RSC. RSB and RSC have local work health and safety (WHS) committees that include radiation safety issues as a standard agenda item. These local committees also meet quarterly and report radiation matters to RSAG as appropriate.
Statutory & regulatory compliance
Both the RSB and RSC RMPs have been written to ensure compliance with the Act, the Regulations and the conditions of licence S0027. The RSC RMP (March 2022) refers to dealing with a total of five fully enclosed X-ray instruments on pages 10 and 13; however, during the inspection it was observed that there are only four such instruments.
Processes relating to the purchase and in-house manufacturing of sources across ANU are aimed at reducing the likelihood of the procurement of unauthorised sources.
Radiation safety matters for both RSB and RSC are reported according to their local WHS plans. The reporting line provides for communication to the relevant Heads of Departments, WHS committee meetings and the ANU RSAG. Example agendas and minutes of WHS meetings were sighted during the inspection for both schools.
ANU requires risk assessments and safe operating procedures in all laboratories where radiation is used, including RSB and RSC. An example of these requirements covering the processes for developing risk assessments, and the review and approvals required for all projects involving controlled materials or apparatus were viewed during the inspection.
The RSB Radiation Safety Plans and Arrangements (RSP&As) require safe work procedures and risk assessments be in place in all laboratories dealing with radiation although this was not always the case. The RSP&As were under review at the time of inspection and the clause could be changed to ‘be available’ to allow for on-line access to the documents.
The local Radiation Plans and Arrangements for RSC contained references to a position that did not exist within the school hierarchy.
Neither school has had a radiation related incident since the last ARPANSA inspection. Should such an incident occur, it would be reported through the internal incident reporting system and identified as a radiation related incident. Once flagged as a radiation related incident, the ANU WHS office would investigate it and the results of the investigation, including any actions taken to mitigate the problem, would be reported to ARPANSA in accordance with the regulatory requirements.
Training & education
All personnel using controlled apparatus or controlled material at ANU are required to undertake training related to the particular type of source they will use. This training includes:
- Tier 1: general induction,
- Tier 2: school induction, and
- Tier 3: individual laboratory induction and specific use training, the extent of which depends on the proposed dealing for the given individual.
Access to laboratory areas is restricted to those personnel who have undergone appropriate induction training or are otherwise closely escorted by appropriately trained staff.
Training records are kept in physical form and electronically. The ARPANSA inspectors verified these records for several individuals authorised to use the controlled apparatus and controlled materials in both RSB and RSC as having completed the training.
Reminders of refresher training for relevant staff are sent out manually by the school WHS manager. While this notification commences 6 months before the due date, human intervention of the relevant school WHS manager is required to complete this process. It was noted however that several staff had not completed their 5-year refresher training in accordance with ANU requirements. This deficiency was identified and reported in the inspection of March 2019.
Comprehensive training records are kept in each of the schools but these did not translate to the ANU central record system. This was identified in the previous inspection of April 2023 and reported at that time.
Exposure meters are calibrated annually, and contamination monitors are calibrated every 5 years in accordance with current regulatory requirements. Calibration certificates for the survey meters were sighted during the inspection. One RSB radiation monitor capable of measuring both the presence of radiation (5-year calibration requirement) and dose rate (annual calibration requirement) was noted as being overdue for calibration for dose rate.
Not all laboratory entry doors containing UV equipment were labelled although each individual device bore the appropriate warning label in accordance with section 1.5.5 of AS/NZS 2243.5.
Personal protective equipment
Appropriate laser protective eyewear is available to staff and students in laser laboratories.
Monitoring of the individuals
Personal radiation monitors are used for work with ionising radiation, and personal exposure records are kept in the central record system. Staff and students can request to view their exposure records but are notified if exposures are above limits or different from the usual pattern of exposure for their work.
RSC no longer uses unsealed radioactive sources and there is no intention to resume doing so in the foreseeable future. However, legacy waste from previous work is located in a secure, labelled store in the RSC precinct awaiting ultimate disposal. This store also contained flammable material, which therefore did not meet the dangerous goods segregation requirements of AS/NZS 2243.4.
Notwithstanding the deficiency with the RSC store outlined above, both stores have been constructed to minimise the likelihood of flooding impacting on the radioactive materials therein. All waste storage is in large, well-labelled containers. Both schools maintain a radioactive source inventory for their respective stores and both stores were secure from unauthorised access. Dose rates outside the two stores did not exceed the background radiation level.
The RSB store was considered to meet the requirements of AS/NZS 2243.4.
Access to all RSB and RSC buildings is protected by an electronic access control system only available to those who have completed the appropriate training. The aggregation of all sources under both RSB and RSC control do not invoke enhanced security requirements and the existing security measures are therefore considered appropriate.
It was noted that once inside an authorised area, access to some laser laboratories was not further restricted. In a laboratory operating an open-beam laser system the responsible researcher expressed his expectation that access should not occur in his absence. However, an interlock has been installed on the access door to shut down the laser if not disarmed shortly after entry.
The ANU has an overarching emergency plan and each school has their own plan based on the risks at that location. ANU maintains an ongoing arrangement with ACT emergency services to ensure an awareness of the potential hazards on the site in the event of a radiation incident. ACT Fire has periodic tours of radiation sites on campus. Any alarm on campus provides an email and text to the Radiation Safety Officer (RSO) and other radiation site RSOs.
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:
- The local RSC P&As contained references to a position that did not exist within the school hierarchy.
- The radiation store for RSC contained flammable liquids.
- Staff members from RSB had not completed their 5-yearly refresher training. This area for improvement was also identified in the report of inspection of 20-22 March 2019.
- Safe work procedures and risk assessments were not in place in all RSB laboratories dealing with radiation.
- An RSB radiation monitor was overdue for calibration for dose rate.
It is expected that improvement actions will be taken in a timely manner.