Inspection report: The Australian Synchrotron (AS), Clayton, Victoria (R21/09249)
|Inspection report details|
|Location inspected:||The Australian Synchrotron (AS), Clayton, Victoria|
|Date of inspection:||11, 13 and 19 of August 2021|
This 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 F0271.
The scope of the inspection included an assessment of ANSTO’s performance at the AS against the Facility Performance Objectives and Criteria (POC). The inspection consisted of a review of records, interviews, and physical inspection of the facility.
The AS creates a high energy beam of electrons. When these electrons travel on a curved path, in the presence of a magnetic field, extremely intense radiation is produced. This radiation, synchrotron light, is directed down beamlines. There are nine beamlines for scientific research and two beamlines for beam diagnostics.
AS is a prescribed radiation facility (as per the Act and Regulations) that includes the following major subsystems:
- 100 MeV linear accelerating structure,
- 100 MeV to 3 GeV booster synchrotron (Booster Ring); and
- A 3 GeV storage ring that produces synchrotron radiation from infrared to hard X-rays.
The AS licence covers the three major subsystems listed above along with several controlled apparatus and controlled materials used for research purposes carried out at the facility.
The main codes and standards applicable to this facility are those that appear in section 59 of the Regulations.
Performance reporting and verification
While no radiation related incidents have occurred, AS routinely reports details of work health and safety and operational incidents. Details of radioactive samples brought onsite by users for experiments are also provided in relevant quarterly reports.
Configuration and management
The hazards present at AS have been identified and assessed in the safety assessment report. AS plans to implement several new beamlines. Hence, the safety assessment will need to be revised as will the safety analysis report (SAR) which provides a high-level summary of the existing hazards as well as a description of how AS addresses foreseeable external events. AS has developed a set of plans and arrangements, which are supported by numerous documents that describe how they operate the facility safely. These documents reside in the quality management system in accordance with ANSTO’s Work Health and Safety Management System.
The personnel safety system (PSS) provides an important safety function and AS has a procedure on the review and approvals required to restart following a PSS component failure. This requires the approval of the Radiation Safety Assurance Committee (RSAC) or RSAC delegate. However, if the failure is a simple matter, such as loss of power or communications, this is not required.
The safety assessment report identifies scenarios whereby potential exposures of staff and users can occur. Accident probabilities in this report typically involve an assessment of the reliability of both engineered controls and human reliability. Inspectors noted that there are instances where human error probability is stated without detail or a reference describing how the value was derived. Furthermore, there is no transparent evaluation of potential human errors through error categorisation, recovery potential and performance shaping factors.
Licence condition 3 in Schedule 2 of Facility Licence F0271 requires ANSTO to comply with all applicable codes and standards, and at least once every three years conduct a self-assessment against each applicable code and standard to ensure compliance. This self-assessment has not occurred in the past three years, and as such, is identified as a non-compliance.
AS has established a system of area designation. These are radiation area, controlled area, supervised area, and uncontrolled area and provide a graded approach to controlling access to areas where a radiation hazard is present. During the inspection, the different areas were confirmed to be appropriately signposted and/or painted in the designated colour to convey its designation.
Inspection testing and maintenance
AS uses a commercially available program to manage planning and coordination of maintenance activities. Work permits, job safety analysis, standard operating procedures and isolation notices are in place to safely manage maintenance work.
AS uses 18 fixed radiation monitors to determine the annual dose to staff and users of the facility. Although there are two spare radiation monitors, AS was unable to ensure that the radiation monitors that are in use have been calibrated in the last 12 months. Where the calibration of a radiation monitor has lapsed, the measured value cannot be relied on for a quantitative assessment of dose. This is identified as an area for improvement.
AS is required by the operational limits and conditions to perform functional testing of both the accelerator PSS and the beamline PSS every two years. The inspectors observed records demonstrating that testing had been conducted and that all systems had passed.
The inspection held almost 2 years ago identified that the radiation safety training for about 20% of the staff at the AS had lapsed. The training for these staff was brought up to date and a measure was put in place to identify when training lapses to maintain better oversight of the situation. However, this measure failed without detection and during this inspection it was identified that the training for another 20% of staff at AS had lapsed. It was concluded that AS does not have robust and diverse measures to ensure that personnel working at the facility are suitably trained. This is identified as an area for improvement.
A qualitative analysis of the impact of a variety of external events is documented in Appendix A of the SAR. In all instances, the analysis demonstrates that radiological consequences would not occur.
The ARPANSA inspection in 2019 identified that the facility had not been categorised in accordance with the currently recommended IAEA methodology published in the General Safety Requirements Part 7 Preparedness and Response for a Nuclear or Radiological Emergency (2015). As this still has not occurred, it is identified as an area for improvement.
Security at the AS is aligned with the expectations articulated in ARPANSA’s regulatory guide on plans and arrangements for managing safety and the principles of the Protective Security Policy Framework and uses a graded and balanced approach to protecting the facility and its operations. A security risk assessment has been performed which guides the implementation of security at the facility. Physical security controls include the use of surveillance systems, physical guard presence, and a swipe card access system. Administrative controls include supervising and escorting visitors and short-term contractors, and the vetting of personnel given access to the facility.
All staff and users of the facility are defined as occupationally exposed persons although AS has implemented a dose constraint of 1 mSv/annum for all personnel.
Numerous interlocks and safety rated programmable logic controllers have been installed as part of a PSS which prevents access to the accelerator systems and beamline hutches when radiation is present. This system aims to protect personnel from potentially significant radiation exposures.
Outside the shielded enclosures and beamline hutches, the dose rates are typically less than 0.5 µSv/h. Elevated dose rates occur when the beam in the storage ring is lost although this is short lived (typically no more than a second) and localised to the area where the beam is lost.
An extensive monitoring program is in place to measure the radiation doses at strategic locations around the facility. This consists of primary and secondary active radiation monitoring systems, with 18 and over 50 monitors respectively, along with over 100 passive monitors. The active radiation monitors measure both photon and neutron radiations. Data is instantaneously relayed to the control room and logged for later analysis. This data is used to prepare annual assessments which demonstrate that doses remain within the constraint. Furthermore, this data is also used as part of the ongoing improvement of radiation protection within the facility as it enables a deeper understanding of how the facility operates. For instance, poor injections of electrons into the storage ring can be identified and actions taken to rectify this.
Electronic personal dosimeters (EPDs) are held in the control room for staff use, and when used, the doses measured by the EPDs are recorded in a logbook. Most of the measured doses are negligible, and all doses are substantially less than the AS dose constraint of 1 mSv/annum.
AS has arrangements in place to control access to areas where activation of materials can occur. When personnel need to access these areas, a survey is performed to identify any potential activation. If a component is found to have been activated, access to that area is restricted until such time as the radiation dose rate emanating from the component has decreased to an acceptable level.
AS has developed safe work procedures for use of other radiation sources associated with the facility. When samples containing radioactivity are brought onsite, they remain the property of the user. However, AS assesses all hazards associated with samples coming onsite. AS requires all users to seek prior approval to use radioactive material onsite and to take the material with them when they leave. Should any spill or leak of material occur onsite, the user is required to take the waste with them when they leave the facility. AS does not accumulate radioactive waste and does not discharge radioactive waste to the environment or to landfill.
The last ARPANSA inspection highlighted the need to assess the radiological hazard of the twenty Am‑241 sources that are part of an old piece of equipment being held onsite until the future management arrangements could be determined. Since then, the sources have undergone wipe testing to demonstrate that they remain sound and have been positively secured to control access and exposure to them. Arrangements have been made to return these sources to the manufacturer.
Emergency preparedness and response
The AS emergency plan only applies to on-site personnel as a radiological emergency with off-site consequences is not considered credible. The emergency plan requires that appointed wardens evacuate and marshal workers, secure the site, and ensure that first aid assistance is available. However, most radiation emergencies can be terminated by activating an emergency stop or closing a shutter.
AS has made preparations to manage foreseeable emergency situations as part of the broader ANSTO emergency arrangements and uses a site specific and risk-informed approach. If an incident occurs, AS will use the Australasian Inter-Service Incident Management System to enable effective communication with third parties such as the emergency services who may attend the site. The AS Director has overall responsibility for managing and controlling emergency incidents at the facility and is assisted in this responsibility by the emergency planning committee which plans for emergencies and manages them should they occur.
The inspection revealed the following non-compliance:
- A self-assessment against the applicable codes and standards in the past three years for the facility as required by licence condition 3 in Schedule 2 of Facility Licence F0271 has not been conducted.
The inspection revealed the following areas for improvement:
- The system for ensuring the calibration of radiation monitoring equipment.
- The system for ensuring that personnel are properly trained.
- The categorisation of the facility with regard to emergency preparedness and response.
It is expected that improvement actions will be taken in a timely manner.