|Inspection report details|
|Licence holder:||Australian Nuclear Science and Technology Organisation (ANSTO)|
|Location inspected:||Nuclear Forensics Laboratory, Lucas Heights|
|Date of inspection:||15 April 2021|
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 source licence S0045.
The scope of the inspection included an assessment of ANSTO’s performance at the Lucas Height Nuclear Forensics Laboratory (NF) against the Source Performance Objectives and Criteria (POC). The inspection consisted of a review of records, interviews, and physical inspection of the laboratory where ultraviolet (UV) and unsealed sources are used, and radioactive items are forensically examined.
NF is a research laboratory for characterising radioactive material and has the capability of forensic examination of radiologically contaminated items. NF provides national support and advice to law enforcement on radiological crime scenes. NF also participates periodically in international collaborative exercises that may involve the analysis of radioactive material.
The ANSTO source licence (S0045) issued under section 33 of the Act authorises the dealing with unsealed sources and optical light emitting UV radiation sources in NF. NF may also utilise controlled apparatus in other laboratories at the Lucas Heights campus for conducting forensic analysis such as XRF and CT.
The main codes and standards applicable to these sources are those that appear in section 59 of the Regulations plus:
- Australian/New Zealand Standard: Safety in laboratories Part 4: Ionizing radiations (AS/NZS 2243.4:2018)
- Australian/New Zealand Standard: Safety in laboratories Part 5: Non-ionizing radiation – Electromagnetic, sound and ultrasound (AS/NZS 2243.5:2004)
- Radiation Protection Series 12: Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006)
- Radiation Protection Series C-6: Code for Disposal of Radioactive Waste by the User (2018)
In general, the management of safety and security was found to be satisfactory. In some cases, however, there appeared to be room for improvement with respect to documentation and meeting the Safety in Laboratories Standard Part 4 unsealed radioactive materials additional requirements for radiation signage.
Statutory & regulatory compliance
NF demonstrates effective local control over radioactive material through registration on a local register which assigns individual items a unique NFS number. However, NF advised that a source may be recorded in the ANSTO Radioactive Source Register (ARSR) as its individual isotopic constituents rather than as one discrete source which inspectors consider may introduce complexity in ANSTO compliance reporting.
The assignment of a single Licence Administration Database (LAD) identification number would assist ANSTO manage the regulatory approval requirements of a source transfer or disposal in circumstances where multiple isotopes in an unsealed source are recorded in the ARSR.
- A G2-6 unsealed source consisting of irradiated Th metal was initially provided a local NF register number NFS17-001 then subsequently assigned 4 source ID numbers and 2 LAD numbers.
The radioactive source store is kept securely locked and access is restricted to authorised persons. NF provided inspectors with a representative photo of the labelling on a source in the NF source store. The labelling of radioactive material stored at NF generally reflected the requirements of section 5.1 of AS/NZS 2243.4:2018; however, inspectors noted an inconsistency between the recommended terminology in the Laboratory Standard and the description ‘radioactive substance’ used by NF. It was noted the term ‘radioactive material’ as defined in both the IAEA nuclear security glossary and IAEA safety glossary have broad acceptance. However, while the two terms would generally be considered interchangeable, IAEA glossaries acknowledge a potential for different uses of the two terms in certain circumstances.
The mercury discharge lamps installed inside the glove boxes for the purpose of decontamination are capable of emitting UV light at a peak wavelength of 254 nm and are currently on the SIW for S0045. During the inspection, consideration was given to whether the UV lights installed in each glove box constitute controlled apparatus of a kind identified under section 9(b) and (c) of the Regulations.
In April 2017, a WHS UV Radiation Exposure hazard assessment of UV sources inside the NF glove boxes confirmed the exposure limits would not be exceeded during normal operation as the UV sources are completely enclosed within the glove boxes. The WHS assessment also identified a number of reasonably foreseeable abnormal events that could lead to an exposure including: an accidental tear in the glove while the UV lamp is on or when the UV lamp is replaced during maintenance. The inspectors consider section 3.3.2 of I-5499 could be strengthened to include an additional step to ensure the power to the UV sources is switched off before changing glove box gloves.
A range of engineering and administrative controls were identified by ANSTO WHS in the UV Radiation Exposure assessment of the glove box UV lamps. Inspectors consider that signage, access controls and training verification instruction in I-5499 procedures mitigate exposure and are compliant with AS/NZS 2243.5:2004; however, an identified engineering control involving a safety interlock was found to be absent. Based on this assessment report it has been decided to maintain control of the UV light sources as prescribed in section 9(b) and (c) of the Regulations.
Documentation and document control
A number of ANSTO documents that apply to laboratories with radioactive sources across the site may have already been earmarked for rectification. ANSTO uses an electronic system (green sheets) to identify and track documents that require review. Inspectors noted a number of documents that perform an overarching safety advice role that have been through the review process still reference out of date ARPANS Regulations and standards. Inspectors recommend a general AFI that ANSTO maintains a complete set of safety plans and arrangements documentation that correctly reference the current Regulations and relevant code and standards to comply with licence condition 4.
Local rules and procedures
Inspectors suggest ANSTO reviews the use of the title ‘regulatory constraints’ in sub-section 2.1.3 of I-5499 substituting ‘constraint’ with another appropriate term to reflect the subject matter covered such as ‘regulatory approval requirements’. In addition, the word ‘0shows’ in the second sentence under section 2.2 should be corrected or clarified.
I-5176 ‘Handling of radioactive items using a disposable glove bag’ sub-paragraph numbering under section 1.3 may require correction; or the introduction of a heading to more clearly signify that sub-paragraphs 1–5 are steps in the procedure for retrofitting different gloves to the glove bag.
Training and education
Training records for staff were sighted during the inspection. The radiation area-specific training requirements were considered appropriate for the specific requirements of working in the NF laboratories.
Risk assessment and mitigation
The safe work instruction I-5176 indicates its scope does not address sample-specific hazards such as chemicals or radiation and therefore a sample must first be risk assessed before being handled. However, there is no reference to the relevant risk assessment procedure in I-5176. Inspectors consider the document could include a reference to the risk assessment approach used in NF including the ‘Analytical Plan – Nuclear Forensics’ (F-4579).
Principles of radiological protection
Inspectors sighted NF’s use of radiation contamination clearance certificates in accordance with the requirements of ANSTO Radiation Safety Best Practice (AG-6288) and the ANSTO Source Licence S0045 Plans and Arrangements for Managing Safety (AG-2673) section 3.9 ‘Transport and Movement of Radioactive Materials’.
Inspectors observed a high standard of cleanliness in the NF laboratory and noted that this is consistent with AS/NZS 2243.4:2018 additional requirements for unsealed radioactive material.
Planning and design of the workplace
Highly specialised glove boxes for the examination of radioactively contaminated exhibits are operated under reduced (negative) pressure relative to the sealed room in which they are located. Visual pressure gauges are fitted on each glove box to monitor the pressure gradient between the glove box and the room to ensure radioactive material does not migrate towards the external workspace. The integrated design of this examination workspace reduces the risk of potential contamination in the NF capability area.
Inspectors observed that imaging equipment is permanently installed within the glove box which can be operated remotely by software on an external laptop providing complete control of the camera. This safety design feature greatly reduces the risk of contamination of staff and equipment.
Inspectors noted the installation of two external video cameras capable of providing a live video feed to a separate laboratory designated as a nuclear forensics ‘white’ area (an area where radiological materials are not in use). Inspectors consider the safe observation from outside the laboratory when forensic examination of radiological materials takes place thereby limiting the risk of exposure to be a good practice.
Personal protective equipment
NF Laboratory Induction F-5496 addresses the personal protective equipment (PPE) requirements for radiation areas. The PPE requirements in F-5496 reflects the requirements of AS/NZS 2243.4:2018 for working with unsealed sources 4.8.5 (f)–(i) and was verified during the inspection that the appropriate PPE was available.
Inspectors assessed the detailed instructions on safe handling of radioactive items (I-5176 and I-5499) address the radiological contamination risks from handling and the manipulation of unsealed source samples and exhibits when undertaking forensic examination.
Monitoring of the workplace
Inspectors note that the glove box alarm system is configured to provide a local audible and visual alarm for the operator if a release of radioactive material into the examination room is detected and to register remotely with the ANSTO Site Operations Centre (ASOC). In addition, surveys are regularly conducted in the NF capability area by external health physics staff.
Monitoring of individuals
NF staff are issued with individual thermoluminescent dosimeter (TLD) badges. NF laboratory staff also receive induction training and must demonstrate their knowledge of when the use of an EPD is required in conjunction with a TLD. The additional requirement of electronic PPE for staff undertaking work in the NF capability area is an appropriate safety requirement to raise immediate awareness of a potential radiation hazard arising during the course of their forensic examinations.
Laboratory staff are required to use fixed monitoring equipment to establish that they are free of radioactive contamination when crossing the barrier delineating the designated ‘blue’ radiation hazard/ contamination laboratory area to the clean area before exiting the NF capability laboratory. As part of the NF Laboratory induction procedure, F-5496 requires staff be scheduled for a whole body monitoring program prior to being granted frequent unescorted access to the radiation areas of the NF laboratories.
Instruction I-5499 requires staff place a contamination monitor near the glove box before commencing work with unsealed radioactive sources and regularly screen for contamination. The instruction recommends the use of a detector capable of detecting alpha and beta radiation which inspectors consider appropriate to monitor for potential radiation hazards from unsealed radioactive materials that may be present on items being forensically examined.
Management of radioactive waste
Inspectors verified that signs bearing the radiation symbol and appropriate wording are placed at the entrances to NF radioisotope laboratories in accordance with AS/NZS 2243.4:2018. Inspectors initially observed an absence of radioactive symbols on the sinks connected to the B-line which potentially allow for the direct disposal of low-level radioactive liquids down the sink. AS/NZS 2243.4:2018 section 4.8.5(l) imposes a mandatory signage requirement for the display of a radiation symbol on benches where unsealed radioactive materials are handled and flushing sinks where low-level liquid waste is disposed of. Inspectors consider the placement of a radiation sign over a sink where low-level liquid waste is disposed of is an appropriate safety measure for warning others of a potential radiological hazard requiring RPA assessment prior to undertaking maintenance work as identified in s4.8.5(t) of the Laboratory Standard, such as repairs to sinks. A trefoil symbol has now been placed on the glovebox and the Dynaflow fume cabinet. While all plumbing in the laboratory is connected to the B-line, disposal of low-level radioactive liquids is required to be undertaken in the fume cabinet only. NF has placed additional trefoil signage over laboratory sinks which state ‘radioactive waste prohibited down drain’.
Inspectors assessed the electronic access control system in conjunction with the formal administrative approval process for granting staff access are adequate to mitigate the risk of theft or unauthorised access to unsealed radioactive material stored under NF control. In addition, NF Laboratory Induction F-5496 requires staff gain an appropriate security clearance prior to being granted unescorted access into that part of the Nuclear Forensics capability area in which unsealed radioactive material is used and stored.
Local emergency procedures consider a range of scenarios, including ventilation failure of the glove box and examination room, fire in glove box, tear in glove box glove during forensic examination, and possible leaks from the glove box. Inspectors note an automatic notice sent to the ANSTO Site Operations Centre (ASOC) activates ANSTO’s site emergency response procedures provide for the timely responses to a range of radiological risks that could potentially be encountered by staff examining MORC or contaminated items from a crime scene.
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 general area for improvement:
- ANSTO should maintain a complete set of safety plans and arrangements documentation that correctly references the current Regulations and Standards.
The inspection revealed the following good practice:
- The use of external video cameras capable of providing safe observation from outside the laboratory when forensic examination of radiological materials takes place thereby limiting the risk of exposure.
It is expected that improvement actions will be taken in a timely manner.