|Licence holder||CSIRO Business and Infrastructure Services|
|Location inspected||Hangar 5 Annex, Evetts Field, Rangehead, Woomera SA 5720|
|Date of inspection||21 July 2022|
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 S0190.
The scope of the inspection included an assessment of performance at ASC North against the Source Performance Objectives and Criteria (POC). The inspection consisted of a review of records, interviews, and a physical inspection of the ionising source storage and exposure locations, in particular the complex open site environment where ionising sources are used onboard the submarine.
The licence holder is authorised under section 33 of the Act to deal with approximately 2000 tons of legacy radioactive waste contained in 9,726 drums awaiting disposal.
The drums are stored in a closely packed configuration (see Figure 1) within a galvanised iron clad store (Hangar 5 Annex) immediately adjacent to aircraft hangar 5 at Woomera test range (WTR) SA awaiting disposal.
The waste stored in Hangar 5 Annex is registered under a single source number in ARPANSA’s database.
CSIRO intends to undertake a ‘Contaminated Waste Remediation Pilot Trial Project’ (Pilot Project) that will include removing drums from the hanger for onsite analysis of their contents. This will inform options for the long-term management/disposal of the material.
The main codes and standards applicable to the source are:
- Code for the Disposal of Radioactive Waste by the User (2018). Radiation Protection Series C-6
- Australia/New Zealand Standard: Safety in Laboratories Part 4: Ionizing Radiations (AS/NZS 2243.4:2018)
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 safety signage; securing the radioactive waste store in accordance with the expectations in the RPP; and monitoring for unauthorised access.
Accountabilities and responsibilities
CSIRO as Australia’s national science agency draws on its mature organisational radiation safety structure with a proven record of effective radiation safety management. CSIRO’s clear lines of responsibility to delegated senior position holders demonstrate leadership commitment to radiation safety throughout the organisation’s varied business units.
A network of radiation safety officers across CSIRO provides an operational structure to share radiation safety knowledge and builds resilience in radiation safety through succession management. Inspectors observed that radiation safety at the remote Woomera Hangar 5 Annex is directly benefiting from this strong radiation safety management structure.
CSIRO’s Business and Infrastructure Services (CBIS) Radiation Protection Plan (version 5.0 June 2022) (RPP) for source licence S0013 covers all CBIS Business Unit (BU) dealings with controlled material and controlled apparatus across three sites. CBIS BU Director, as the S0013 licence nominee, is responsible for overall radiation safety within CBIS, including Hangar 5 Annex radioactive waste store. Inspectors consider management commitment is essential for supporting the development of safety systems and procedures in preparation for actively dealing with the source in the Pilot Project.
Management of source storage within the Woomera Protected Area (WPA) is under the control of CSIRO HSE Radiation Safety Support Officer and the Woomera Project Manager, in consultation with the CBIS BU Radiation Safety Officer. Inspectors consider this breadth of operational responsibility is necessary to ensure safety and effective control as CSIRO transitions to actively deal with this material after a period of prolonged storage.
The RPP documents CSIRO’s future approach in dealing with the radioactive waste stored at WPA from 2022 onwards. CSIRO has contracted a service provider to develop a three-part project for the remediation of radioactive waste. Stage one of the project is to undertake a desktop review and draft a remediation strategy. Inspectors note that as part of stakeholder engagement on the Woomera Pilot Project CSIRO made a presentation of the trial, including the safety methodology and approach, to ARPANSA in May 2022.
Inspectors note that CSIRO has adapted its management approach to the WPA waste holdings to ensure radiation safety and protection of the environment by implementing a ‘Manage-Monitor-Inspect’ strategy.
Risk assessment and mitigation
The RPP Section 3.3 Hazard and Risk Management has a general requirement for a risk assessment to be undertaken for all work with controlled radiation sources under S0013; and that Safe Work Instructions (SWI) should be developed in consultation with the RSO for the use of controlled material using CSIRO’s standardised templates in its ‘DoneSafe’ system. However, the inspectors observed based on the plans and arrangements provided for the inspection that there are no SWIs in relation to dealing with the unsealed source in storage at the Hangar 5 Annex due to the source’s inactive status.
Inspectors suggest that prior to taking steps to transition Hangar 5 Annex site from a static store to a dynamic work site, CSIRO gain an overview of the potential wider risks when actively dealing with the sizeable radioactive source inventory on this storage site. In addition, as CSIRO will be commencing moving drums in the store as part of a pilot project, there will undoubtedly be lessons learned during that trial that may lead to the modification of SWIs. A change in procedures, process design, or the addition of different materials could potentially create new hazards. Inspectors shared lessons learned from international incidents to emphasise the importance of on-going risk assessment as part of change-control management.
As part of the broader examination of the externals of Hangar 5 Annex radioactive waste store, Inspectors observed that a chemical store is also located within the Hangar 5 Annex footprint which displays a range of flammable and toxic chemical hazard signs.
Inspectors requested CSIRO obtain a schematic diagram of Hangar 5 Annex showing the additional storerooms in relation to the adjacent radiative waste store including storeroom 3 with chemical hazard signage. CSIRO subsequently provided Inspectors with a hand drawn schematic of Hangar 5 Annex on 26 July (see: Figure 2 above). Inspectors note a schematic of the Hangar 5 Annex in a 2008 ARPANSA survey report concurs with the general layout displayed in the diagram from a consultant’s report provided by CSIRO.
Inspectors considered it to be an Area for Improvement for CSIRO to obtain a briefing on the contents of the chemicals stored in the Hangar 5 Annex under the control of other agencies as part of the wider assessment of the risk to inform the selection of PPE and site emergency response plans. In the event it is established that there are no toxic or corrosive chemicals or flammable gases and liquids remaining in the chemical store and the store is no longer used by other Agencies for the storage of chemical waste, CSIRO should enter into discussions with Defence for redundant hazardous chemical signage to be removed to clarify the on-site hazards messaging for first responders.
Training and education
Inspectors were advised CSIRO staff are currently undertaking a risk audit course. Inspectors suggested during the inspection that CSIRO also consider providing key personnel with supervisory responsibilities over Hangar 5 Annex formal Emergency Preparedness and Response training in advance of commencing the Pilot Project.
Radiation safety signage
The RPP Appendix D section 2.5 identifies additional controls in place at the WPA Hangar 5 Annex, including radiation warning signs. However, Inspectors observed that radiation signage on the external walls of Annex 5 have deteriorated due to prolonged UV exposure and should be replaced before they further delaminate.
Planning and design of the workplace
CSIRO is in the early stages of planning to access the drums in preparation for characterisation of the contents as part of CSIRO's Legacy Radiation Disposal and Consolidation Project.
A presentation on the ‘Contaminated Waste Remediation Pilot Trial Project’ references the use of Multi-Agency Radiation Survey and Assessment of Materials and Equipment (MARSAME) for some materials. MARSAME is an internationally recognised approach to determine proper disposition of certain materials. Inspectors recognise MARSAME commences with an assumption that the user has some historical knowledge of prior use. Inspectors note that a 2008 ARPANSA survey report references the origin and background of this material being supplied in the Report “Environmental Audit of Evetts Field Waste Facility – January 2004, ARL File H2-04-02” which may assist in this regard.
Initial knowledge of the level of radiation from the drums is also an important starting consideration. Inspectors note that CSIRO has previously utilised small remotely operated vehicles (ROV) to gain information of the radiation activity levels at various locations with the Hangar 5 storage bays, without requiring staff to enter the Annex or remove the closely packed drums.
MARSAME recognises an initial assessment may involve performing a visual inspection to identify the physical characteristics of the source material when a description is not readily available to support a categorization decision. The removal of drums from storage and potentially accessing the waste material elevates the radiological risk in dealing with this source. Inspectors note CSIRO is planning to constrain the scope of the Pilot Project to a trial involving a small subsample of drums. Lessons learned from the trial will help inform the design of the workplace for the Pilot Project.
Local rules and procedures
As discussed in the risk assessment and mitigation section, CSIRO’s current plans and arrangements for Hangar 5 Annex store do not include Safe Work Instructions (SWI). The RPP at section 3.3 state SWI are not required for controlled material that are listed on CSIRO’s Radiation Inventory Database as ‘awaiting disposal’ or ‘in storage’; and were identified in ARPANSA’s Licence Administration Database (LAD) as being ‘Inactive’.
Inspectors note that the status of the source is currently set as ‘Inactive’ in LAD. The source status in LAD will change when CSIRO recommences dealing with the contents of the drums; and SWI will then be expected to form part of the S0013 plans and arrangement for managing safety of sources at Hangar 5 Annex.
Personal protective equipment
RPP section 3.4 deals with Personal Protective Equipment (PPE). Inspectors observed that subs-section 3.4.1 specifically addresses ‘unsealed radiation source protection’; however, there is no mention of a requirement for inhalation protection, such as masks or respirators. Inspectors considered it to be an Area for Improvement for section 3.4’s safety advice to be strengthened to include specific information on the inhalation risk posed by unsealed sources; including the risk from the inhalation of alpha emitting dust particles to emphasise the safety rationale for the inclusion of P2 respirators in the Hangar 5 Annex spill kits and its use in the Drum Emergency Response procedure.
The RPP Appendix E: Radiation and spill kit contents list identifies P2 ‘disposal’ respirators in the Radiation Kit and Spill kit; and the Drum emergency spill response procedure requires the response team to don PPE including a P2 disposable respirator. However, the type of respirator and non-particulate protection is not specified.
As different types of P2 mask are effective against different hazards, such as particulates or chemical vapours, the use of the correct mask is important. Based on the historical information and potential hazards present inspectors consider it an area for improvement that CSIRO review and clarify the requirements on PPE provided in the spill kits.
This review should consider the suitability and compatibility of safety glasses and disposable P2 respirators in the emergency response kit for mitigating a potential mixed inhalation risk posed by possible presence of both alpha emitting radionuclides and chemical hazards such as acids in drums contents. The review should also consider if any reasonably foreseeable emergency scenarios, resulting from the dealing with the source, warrant the inclusion of a full-face mask respirator with an appropriate cartridge filter that could provide protection of the eyes, face and lungs from any combined toxic chemical, vapours, aerosols, and radioactive dust hazardous release incident at Hangar 5 Annex.
Monitoring of the workplace
Appendix D Radiation Safety Management in Hangar 5 Annex at section 2.6 Radon Monitoring refers to two Continuous Radon Monitors interfaced with the Telstra network to allow for remote data access. However, inspectors were informed during the inspection that remote monitoring of the radon levels in the store is to cease. Radon exposure risk to staff will be monitored when on-site.
Monitoring of individuals
The RPP requires all staff entering Hangar 5 Annex be equipped with a personal dosimetry badge (OSL) and where possible a personal electronic dosimeter (EPD) which provides an audible alarm and dose rate for immediate exposure mitigation action.
Management of radioactive waste
The AECOM presentation (dated 17 May 2022) on the Pilot Project at Step 1 involves the selection of a random start point for pallet removal from an area in Bay 3 shown as shaded on a diagram. The source contained in 9,726 drums come under a single ARPANSA LAD source number; however, Inspectors recall drums may have previously been assigned individual identification numbers. The specific identification number for individual drums selected for the trail should recorded in order to facilitate crossmatching with historical records of individual drum contents which may be relevant to safety. Inspectors suggest CSIRO provide the regulator with individual drum identification numbers for those drums selected for the Pilot Project.
Inspectors were not present when the Annex doors are initially opened for ventilation 30 minutes before an inspection. Inspectors observed that there were practical difficulties moving and securing the large sliding access doors on the Annex at the end of the inspection. Inspectors and CSIRO staff were escorted off the range by a maintenance contractor with the Hangar 5 Annex doors still open. Inspectors were advised that maintenance on the doors would be arranged by the contractor.
CSIRO informed inspectors that it is no longer CSIRO practice to lock the Hangar 5 Annex radioactive waste store. However, inspectors note that the current RPP Section 5.2 states: ‘The Hangar 5 Annex is locked, and the keys are held by the Defence Support Centre in Woomera. CSIRO staff and affiliates wishing to gain access to the WPA must do so with the permission of the Department of Defence’. In addition, Section 7.1 Security Procedures states: ‘CBIS will maintain effective security control of sources by ensuring: (a) locations where controlled sources are present are secured from unauthorised access, theft, or damage at all times.’
CSIRO agreed during the inspection to seek internal advice on why a decision was made to not lock the Hangar 5 Annex doors. CSIRO subsequently advised inspectors by email on 26 July that when updating the protection plan it was agreed that locks to the radioactive waste store were not needed because of ‘three levels of site security in place including: A secure defence site with restricted access; the lock on the Compound; and a camera on the Compound (which they understood to provide 24hr surveillance)’. CSIRO’s email response regarding their practice of not locking the radioactive waste store further indicates this change in security procedure may have been influenced by discussions with an ARPANSA employee; however, Inspectors were not provided with a record substantiating this advice.
Inspectors consider that in not locking the Hangar 5 Annex Radioactive Waste Store CSIRO is inconsistent with their RPP and this is considered an area for improvement. The fact that the gate to the compound is locked does not sufficiently mitigate the risk of unauthorised access to the waste store as other Defence personnel access the compound to undertake activities in the adjoining hangar when CSIRO is not on site.
Inspectors highlighted the difference between the unlocked status of the CSIRO radioactive waste store in Hangar 5 Annex with the locked Defence radiation store at a nearby location within the WPA. The Defence Radioactive Waste store contains a mixed inventory, nonetheless, this store sets an example of good protective security.
ARPANSA is advised that alarm monitoring for another nearby radiation store is undertaken off-site at a Security Alarm Monitoring Centre near Adelaide. It is the off-site licence holder (LH) representative who undertakes a separate remote visual assessment on being notified of an alarm. While CSIRO has advised there is a camera mounted above the Annex, Inspectors note there is no means within the Hangar 5 Annex to set off an alarm. In addition, CSIRO is unclear as to the procedures or the person responsible for checking the Hangar 5 camera vision in order to verify whether unauthorised access to the waste store has occurred.
Inspectors encourage CSIRO to consider lessons learned from Defence in overcoming technical challenges to establishing a reliable alarm monitoring and video assessment capability for a radioactive waste store located on the WPA.
Inspectors considered an area for improvement to be that CSIRO seek clarification on the nature and extent of the detection and assessment capability for Hangar 5 Annex and develop procedures setting out responsibilities for remotely assessing CCTV surveillance footage to determine unauthorised access to the waste stored in Hangar 5 Annex.
Emergency plans and procedures
The RPP section 2.9.2 has specific emergency procedures for staff in the event of an emergency in Hangar 5 Annex or its surroundings including emergency procedures in the event of a security incident. Inspectors acknowledge that the emergency procedures incorporate a staff awareness and induction briefing by the Chief Radiation Safety Officer at the commencement of each field work campaign at WPA Hangar 5 Annex; this includes information on emergency equipment procedures and the location of emergency equipment on site.
In addition, the RPP version 5.0 Appendix C ‘Key Contacts and Appendix D section 2.8 Emergency Contact numbers are current. However, the Emergency Response Plan signage attached to the exterior of Hangar 5 Annex displays the name and mobile phone number of a CSIRO HSE Radiation Safety Specialist who is no longer in the employ of CSIRO. Inspectors consider it is important to ensure that the emergency contact details on signs intended for ready access in the event of an emergency also be kept current through a formal process to ensure onsite safety information is periodically checked and this is considered an area for improvement.
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:
- CSIRO obtain a briefing on the contents of the chemicals stored in the Hangar 5 Annex under the control of other agencies as part of the wider assessment of risk to inform the selection of appropriate PPE; and update the Hangar 5 Annex site emergency response plans and signage if necessary.
- Radiation Protection Plan safety advice should be strengthened to include specific information on the inhalation risk posed by unsealed material that contains alpha emitting dust particles.
- CSIRO review the effectiveness of the current P2 disposal respirator and safety glasses in the radiation kit and spill kit for protection in the presence of mixed radiation and chemical hazards including irritants such as acids.
- CSIRO lock the Hangar 5 Annex radioactive waste store when CSIRO staff are not on site.
- CSIRO review the detection, monitoring and assessment capability of the site CCTV at Hangar 5 Annex and document a procedure for assessing and notifying CSIRO of a potential unauthorised access to the source stored in Hangar 5 Annex.
- Radiation safety and emergency response plan signage on the external walls of Hangar Annex 5 should be updated.
It is expected that improvement actions will be taken in a timely manner.