|Australian National University (ANU)
|Date of inspection
|25-26 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 HRD and RSES 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) (RHS11)
- 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 HRD and RSES 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 HRD and RSES.
ANU has a Radiation Safety Advisory Group (RSAG) that meets quarterly and comprises representation from all schools including HRD and RSES. RSES has a local work health and safety (WHS) committee that includes radiation safety issues as a standard agenda item. This local committee meets quarterly and reports radiation matters to RSAG as appropriate. HRD is effectively part of the WHS group and reports directly to RSAG.
Statutory & regulatory compliance
Both the HRD and RSES RMPs have been written to ensure compliance with the Act, the Regulations and the conditions of licence S0027.
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. As HRD controls the radiation store, no sources from outside ANU are procured by HRD.
Radiation safety matters for both HRD and RSES 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 RSES WHS meetings were sighted during the inspection.
ANU requires risk assessments and safe operating procedures in all laboratories where radiation is used, including HRD and RSES. Examples 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 HRD Guidelines and Radiation Management Plan (GRMP) outlines the requirements, safe working procedures and accident/emergency response requirements relating to the radioactive materials store. While comprehensive, there was an error within the document relating to the placarding of vehicles transporting radioactive sources from their school of origin to the store on the public roads within the ANU grounds. This area for improvement was identified during the inspection and requires amendment to ensure that there is no confusion during the transport of radioactive material on campus.
Observations that were not necessarily areas of improvement relating to the GRMP included, inter alia:
- There was information on how to handle spills of chemicals that are not, and would not be, stored in the store.
- ‘significant’ was not defined in reference to checking the store for structural damage following an earthquake in the area. It was noted that a 3.1 magnitude earthquake near Canberra in January 2019 did not trigger this provision.
- The identity of ‘key participants’ in emergency drills was not defined.
- References to records software that are no longer used.
These should be considered during the next review of the document.
During the inspection, an incident was identified where a radioactive source was inadvertently collected during a routine chemical disposal. The disposal contractor discovered the source upon return to their premises and notified ANU immediately. The contractor subsequently returned the source in the week leading up to this inspection and ANU is still in the process of investigating the situation.
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
- 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 RSES as having completed the training. HRD is essentially Safety and Wellbeing (formerly WEG) staff who are fully inducted.
The senior RSES laser person has not received the formal training necessary to be qualified as a Laser Safety Officer in accordance with the laser standard although attendance has been organised for late June 2023.
Comprehensive training records are kept in RSES but these did not translate to the ANU central record system. This was identified in the 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 several survey meters were sighted during the inspection.
The GRMP identified items included in the spill kit. These were all present at the time of inspection although one item on the list, ‘Mobile phone (required to be carried by the person accessing the store)’, seemed to be more a procedural requirement than an inclusion in the spill kit.
The GRMP required that any package placed in the store must not exceed 10 × 10 × 10 cm although many packages exceeded those dimensions. This is considered an area for improvement and HRD should investigate the requirement with a view to changing the statement in the GRMP or repackage the material to meet the requirement.
The hand wash tap near the entry door to the store was difficult to operate and there were no clear instructions as to how to turn it on and off.
A hand wash sink and a portable eyewash bottle were located next to the door to the unsealed source laboratory in RSES. A shower was available in the changerooms near the laboratory but there was no guidance as to where it was or how to get to it from the laboratory.
Personal protective equipment
Appropriate laser protective eyewear is available to RSES staff and students in laser laboratories.
The GRMP outlined personal protective equipment that had to be maintained within the store although two items, safety glasses and coveralls, were not present representing an area for improvement.
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.
The HRD radiation store has been constructed to minimise the likelihood of flooding impacting on the radioactive materials therein including a 200 L sump in the floor to contain floodwater. All storage is in large, well-labelled containers and the ANU source inventory workbook itemises all sources in the store. Dose rates outside the HRD store did not exceed the requirements of AS/NZS 2243.4.
The RSES store could not be inspected due to asbestos in the entry door that is currently being replaced. An inspection of this store will be therefore scheduled for a later time.
Access to RSES 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 RSES control does not invoke enhanced security requirements and the existing security measures are therefore considered appropriate.
The aggregation of all sources within the HRD store does not exceed Security Category 4 although its physical structure and extant security provisions would meet the Security Category 3 requirements of RPS11 should there be the need to increase the activity aggregation to such a level. Access to the store is restricted to Safety and Wellbeing staff only and ANU security monitors the store on a 24/7 basis with all entries noted and logged.
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 inspectors observed that the RSES Plans and Arrangements’ description of emergency procedures were of a general nature and differed from the ANU Radiation Management Plan.
The licence holder was found to comply with the requirements of the Act, the Regulations, and licence conditions. The inspection revealed the following areas for improvement:
- References to the transport of radioactive material in the GRMP were not consistent with those in the Transport Code (RPS C-2).
- Many boxes in the HRD radiation store exceeded the maximum dimensions given in the GRMP.
- Some personal protective equipment items prescribed in the GRMP were not available.
It is expected that improvement actions will be taken in a timely manner.