|Licence holder||Australian National University (ANU)|
|Location inspected||Canberra, ACT|
|Licence number||F0073, F0074 and F0075|
|Date of inspection||3 May 2023|
An inspection was 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 F0073, F0074 and F0075.
The scope of the inspection included an assessment of ANU’s performance against the Facility Performance Objectives and Criteria (FPOCs). The inspection consisted of a review of records, interviews, and physical inspection of the facilities.
The Australian National University houses three prescribed radiation facilities (PRFs) in the Research School of Physics (RSPhys). These facilities are shared by two departments. The Heavy Ion Accelerator (HIAF) (F0074) is operated by the Department of Nuclear Physics, and both the Rutherford Backscattering accelerator (RBS) (F0073) and High Energy Implanter (HEI) (F0075) are operated by the Department of Electronic Materials Engineering.
The HIAF has a wide range of applications including materials science, resource/energy exploration, waste management, research in environmental, biological and life sciences, investigating climate change, archaeological and heritage studies, and critical investigations into nuclear science.
The HEI provides for ion implantation and the RBS allows for ion beam analysis. Both these accelerators are used in the fields of materials science, quantum computing, photovoltaics and electrical engineering.
The main codes and standards applicable to this licence are:
- RPS C-1 Code for Radiation Protection in Planned Exposure Situations (Rev 1) (2020)
- IAEA Safety Standard, Radiation Safety of X Ray Generators and Other Radiation Sources Used for Inspection Purposes and for Non-medical Human Imaging, Specific Safety Guide No. SSG-55 (2020)
- IAEA Safety Standard, Radiation Safety of Accelerator Based Radioisotope Production Facilities, Specific Safety Guide No. SSG-59 (2020)
In general, the management of safety and security at the facilities were found to be satisfactory. In some cases, however, there appeared to be room for improvement with respect to documented change management process. A good practice was recognised in relation to use of higher SIL (Safety integrity level) rating in the planned upgrade of safety instrumented system in the radiation protection system for HIAF facility.
The organisational structure of the ANU facilities, and how it fits in the overall ANU organisation is outlined in the Radiation Safety Policy (ANU_001232), which provides a framework to facilitate the safe and effective use of radiation throughout the University. Further details of responsibilities are described in ANU Radiation Safety Procedure, ANU_000682. Reporting channels and process are also described in the Radiation Safety Procedure.
Management’s commitment to maintaining safe and secure operation is documented in the Radiation Protection Policy, and in lower-level procedures including incident reporting procedures. Director’s quarterly reporting on workplace health and safety matters is in place. Access to the controlled area is subject to authorisation and a list of authorised operators was obtained during the inspection. Access to the facilities is subject to categorisation in terms of safety and security depending on the access requirements. University security policy and arrangements apply to the accelerator facilities including information security, administrative security, security patrols etc.
Through the Radiation Protection Policy ANU gives commitment to statutory and regulatory compliance. ANU has 6 -monthly workplace health and safety inspection that includes radiation safety. As part of optimisation ANU uses a quarterly dose constraint of 250 µSv. An appropriate investigation procedure is applied to investigate any radiation incident.
As a Commonwealth entity ANU has significant technical and financial resources and these are allocated in terms of need and priority. Considering that research and development is one of the core activities of ANU, resources are appropriately allocated for safe and secure operations of these facilities. Plans and arrangements for managing safety of the HIAF state that the Director of Research School of Physics is responsible for providing sufficient resources to ensure safety and compliance with licence requirements.
ANU has a procedure for ‘work health and safety communication and consultation’. Relevant radiation safety issues are discussed with the RSO and/or other designated personnel in an open and transparent manner. Safety incidents or issues are recorded in a logbook, and issues rectified applying appropriate mechanisms.
For HIAF, monitoring of safety margins and operating margins are proactively managed by 24/7 monitoring through the control console. Monitoring data are recorded electronically, and 3 years of data are available at one time. These data are analysed to identify any anomalies to further improve safe operation of the facility.
The WHS Hazard and Risk Assessment Template is presented in Appendix B of the Work Health and Safety Management System (WHSMS) Handbook, which is used for risk assessment of any changes to tasks, activities, location etc. taking into account the controls in place. The approval mechanisms are also described in this risk assessment template. Further, a separate radiation risk assessment process is used for making any changes with significant safety implications.
ANU applies the WHS Management System Handbook, which provides a practical guide for implementing the university’s WHSMS and for people (both management and workers) with health and safety responsibilities to meet the WHSMS requirements. The WHS Management System is supported by WHS Documentation Management Procedure ANUP_ 015811.This procedure applies to all documents, data and records generated to comply with the WHS Management System. Further, Record Management Procedure, ANUP_000513, describes fit-for-purpose information management processes, practices and systems, and reduces information management inefficiency and risk including record creation in the ANU Electronic Records Management System (ERMS), which is the major central repository for the management of electronic records.
The arrangements demonstrate an established system for clear roles and responsibilities, resource allocation, peer review, internal independent review, internal approval process, clear communication system, appropriate system for managing document in a quality format, clear communication system and an appropriate record management system.
The objective of the ANU Radiation Safety Policy (ANU_001232) is to provide a framework to facilitate the safe and effective use of radiation across the Australian National University and that of the Security Policy (ANU_000463) is to provide the framework for management of security on campus, both within buildings and across the site. The ANU Radiation Management Plan aims to ensure that all operations involving radiation have plans and arrangements in place for operation of the facilities in accordance with the Australian Radiation Protection and Nuclear Safety Act 1998 and the Australian Radiation Protection and Nuclear Safety Regulations 2018. The elements considered in this plan are based on the Code for Radiation Protection in Planned Exposure Situations, RPS C-1 (Rev.1). The Radiation Safety Procedure ANU-000682 underpinning the Radiation Safety Policy provides detailed measures for maintaining safety in operation of the accelerator facilities.
ANU uses the prescribed hazard and risk assessment template, which forms part of the WHSMS Handbook (Chapter 3.1). The hazards and risk assessment process considers the hazards, inherent risks, and control measures in place to identify the residual risk. The approval process for the risk assessment process is also specified in this document.
During the inspection it was observed that a draft safety analysis report (SAR) was prepared for the HIAF facility using the ARPANSA Regulatory Guide – Preparation of safety analysis report for non-reactor facilities (ARPANSA-GDE-1925). ANU indicated that a copy of the SAR would be provided to ARPANSA once finalised.
Although all changes are subject to risk assessment and the internal approval process, the ARPANSA inspector noted that several documents are used to manage changes to the facility, plant and equipment, operating processes, and management arrangements such as Radiation Safety Procedure, Radiation Risk Assessment Checklist etc. A formal documented change management procedure describing key elements of change management such as how internal reviews are performed, how the dispositions resulting from the internal review are addressed and how changes are implemented would strengthen the ANU change management process. This is an area of improvement against Performance Objective and Criteria C11 – Managing Change.
The ANU Training Policy and Plans and Arrangements demonstrate that specific competency requirements, provisions of training and retraining, learning and continuous improvement are adequate. All training records are maintained by the university’s training and development team.
During the inspection the design proposal for a change with significant implications for safety related to a personal radiation protection system (RPS) upgrade at the HIAF was discussed. The ARPANSA inspector examined the design proposal document and noted that the design had considered a very high degree of conservatism in assigning SIL (safety integrity level) rating to the safety instrumented system. The logic solver for the RPS will be a Siemens S71500F, which is SIL 3 rated, and when operating in no-access mode is anticipated to achieve an overall SIL 1 rating. Furthermore, ANU is planning to replace all door switches that allow access across a radiation zone boundary with SIL 3 rated switches. Applying a high degree of conservatism in the proposed upgrade of safety instrumentation by using components with a higher safety integrity level rating is considered a good practice to enhance safety of the facility. ANU will make a formal submission to ARPANSA for this change under section 63 in due course.
The ARPANSA inspector considers that the arrangements in place for safety management should provide reasonable assurance that an adequate level of safety will be maintained at the facility. The provisions for management of processes and activities provides confidence in achieving the organisation’s goals without compromising safety.
Through the ANU Radiation Safety Policy, ANU_001232, it gives commitment to:
- provide safe workplace for staff, students, contractors and visitors
- apply fundamental principles governing the radiation protection
- have control measures so that the doses are ALARA (as low as reasonably achievable)
- continuous improvement
The Radiation Safety Policy also describes the responsibilities of key roles to implement the policy. This policy is supported by the Radiation Safety Procedure, ANU_000682. This procedure aims to ensure implementation of the radiation policy including complying with applicable legislation, licence conditions and relevant standards. The procedure lays out a framework to ensure workers receive the appropriate training to perform their duties.
To provide an appropriate level of protection ANU applies the principles of justification (of a practice), dose limitation and optimisation of protection. The ALARA principle is formally applied to the facilities by using monthly (80 µSv), quarterly (250 µSv) and annual dose constraints (1 mSv).
There are designated safety officers at the facilities and their responsibilities in terms of radiation risk management and implementation of the Radiation Safety Policy are described in the Radiation Safety Procedure. New tasks or activities are subject to approval from the Radiation Safety Advisory Group (RSAG).
The work areas have been radiologically classified based on exposure levels and the requirements to be followed. The entire area is classified as white radiation based on the maximum potential exposure level of 10 µSv/hr.
The ARPANSA inspector conducted a facility walkthrough and observed that appropriate engineering and administrative controls were in place for radiation protection including area radiation monitors, automatic shutdown of the accelerator if the radiation level exceeds the pre-set level and work instructions for working in the radiation area.
The inspector considers that the radiation protection program is appropriately supported by management and is properly equipped and staffed. Considering the results of overall personnel exposures, the inspector considers that there is reasonable assurance that arrangements for radiation protection will continue to protect the health and safety.
Radioactive waste management
Operation of these facilities does not generate radioactive waste.
ANU Security Policy ANU_000463 provides the framework for management of security on campus, both within buildings and across the site.
Emergency preparedness & response
There are several emergency procedures in place to deal with emergency situations involving various hazards. These procedures are being re-organised to integrate with an over-arching University WHS Management System Handbook currently being made available on the University web-site (https://services.anu.edu.au/human-resources/health-safety/whs-management-system-handbook). Research School of Physics is in the process of updating these procedures and will make them available on intranet.
ANU applies Emergency Procedure ANUP_000699 to deal with a general emergency. This procedure is developed to meet the requirements of the Work Health and Safety Act 2011 (Cth) (WHS Act), the Work Health and Safety Regulations 2011 (Cth) (WHS Regulations). This emergency response procedure is based on the requirements in Australian Standard (AS) 3745:2010 Planning for Emergencies in Facilities. Fire emergency exercises are conducted at regular intervals (annual). An unscheduled emergency exercise is also conducted to test the preparedness. Radiation emergency procedures are described in Radiation Safety Procedure ANUP_000682.
In terms of ‘external event protection’ ANU has considered bushfire, storm and earthquake and the Emergency Procedure is applied to deal with such emergencies.
Considering the radiation hazard involved in these facilities the risk has been identified as low and the emergency plans and arrangements in place are considered adequate.
Operation of the facilities does not have any radiological impact on the environment as there are no radioactive discharges from these facilities.
ANU was found to be in compliance with the requirements of the Act, the Regulations, and licence conditions.
The inspection revealed the following area for improvement:
- Production of a formal documented procedure for change management.
The inspection revealed the following good practice:
- Applying a high degree of conservatism in the proposed upgrade of safety instrumentation by using components with a higher safety integrity level rating is considered a good practice to enhance safety of the facility.
It is expected that improvement action will be taken in a timely manner.