|Licence holder||Commonwealth Scientific and Industrial Research Organisation|
|Location inspected||CSIRO Minerals Resources, Clayton, Victoria|
|Date of inspection||3 November 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.
CSIRO Mineral Resources (MR) is authorised under section 33 of the Act to deal with controlled apparatus and controlled material. The role of MR is to deliver cost effective exploration and the discovery of new mineral resources through advances and expertise in detection technologies, mineral systems, resource characterisation and data analysis.
This inspection focussed on the Radiation Protection Plan version 6.2, storage for a small number of legacy radioactive materials, X-ray units, lasers and the safe working instructions and locations of a selected number of group 2 controlled sources.
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)
- 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)
- AS/NZS 2243.4 Safety in laboratories Part 4: Ionizing radiation (2018)
- AS/NZS 2243.5 Safety in laboratories Part 5: Non-ionizing radiation – Electromagnetic, sound and ultrasound (2004)
- AS/NZS IEC 60825.1 Safety of laser products Part 1: Equipment classification and requirements (2014)
- RHS 9 Code of practice for protection against ionizing radiation emitted from X-ray Analysis Equipment (1984)
The Radiation Protection Plan (RPP) provided a comprehensive framework supporting operational documents such as safe working instructions, incident reporting and training requirements for operators of controlled radiation sources. In general, the management of radiation safety at the MR site was found to be satisfactory. During the course of discussions regarding the RPP, minor errors, which were of an editorial nature, were provided to the Chief Radiation Safety officer (CRSO) by the ARPANSA inspectors.
The RPP (2.3.2) provides a clear statement of the role of the CRSO and the importance of that role as part of the broader Health and Safety structure within the organisation. The RPP is approved by the Mineral Resources Director. The CRSO has completed various training courses related to the use of radiation apparatus, radiation safety in laboratories and the use of radioactive substances for density/moisture measurements.
Safety policy & objectives
The RPP has a stated policy intention of continuous improvement. Safety management systems are regularly reviewed by the CSIRO Health and Safety Environment (HSE). Examples of the regular radiation source inventory and safety inspections were viewed during the inspection. The CSIRO Radiation Safety Procedure version 2.2 was provided during the inspection. The Radiation Safety Procedure outlines the requirements for the safe management and use of radioactive material and irradiating apparatus.
Risk assessment & mitigation
CSIRO demonstrated during the inspection that risk assessments are carried out for the use of all controlled material and controlled apparatus. Several risk assessments were shown during the inspection by the CRSO, who also advised that risk assessments are reviewed annually or when an incident or near miss has occurred. CSIRO use ‘Donesafe’ for risk assessments and safe work instructions, a number of examples were provided during the inspection.
Monitoring & measurement
The RPP requires the organisation to undertake self-audits. Checklists using iAuditor have been developed and examples of these were provided. There was evidence to show that there are monitoring programs for staff working with radiation sources. Also, area monitoring of the workplace and the store against established dose limits. Radioisotope laboratory contamination monitoring via wipe tests were sent to an external laboratory and a recent report showing low levels of radiation was viewed during the inspection.
Discussions with the CRSO regarding proposed use of electronic safe working instructions looked at issues around change management. The CRSO advised that CSIRO has a change management policy which looks at managing risks throughout any change process.
Training & education
Staff who use controlled apparatus and controlled materials undertake appropriate radiation safety and operational training prior to using the controlled apparatus or controlled materials. Evidence of staff training and refresher training was provided during the inspection. The CSIRO Radiation Safety Procedure outlines the requirements such as radiation safety training commensurate with the activities and relevant to the type of radiation source being used by the staff member.
Principles of radiological protection
Section 4 of the RPP has a clear statement that CSIRO’s policies for radiation safety are to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions. These align with the ICRP principles of radiological protection and those in RPS C-1.
Radiation safety officer/Radiation safety committee
Radiation safety officers are formally appointed. The CRSO and/or Radiation Safety Support Officer are part of the HSE and are supported by Business Unit Radiation Safety Officers, Site Radiation Safety Officers, and Site Radiation Safety Contacts. Their roles and responsibilities are prescribed in the RPP. The Radiation Safety Committee generally meet quarterly and provides a forum for discussion on radiation safety matters. Evidence of the operation of this committee was provided in the form of agenda and minutes.
Planning & design of the workplace
The workplaces visited during the inspection exhibited appropriate safety requirements for the use of ionizing and non-ionizing radiation sources. Controlled access, warning signs and the use of appropriate PPE was evident. All work sites had current Safe Working Instructions available. The laboratories were compliant with the requirements of the laboratory standards AS/NZS 2243.4 and AS/NZS 2243.5.
The RPP requires all transport of controlled material to be in accordance with RPS C-2. The CSIRO RPP currently specifies a dose rate applicable to the transport of radioactive materials. Discussion with the CRSO revealed this was a legacy requirement applied to a past project. The CRSO advised that the requirement will be removed.
Storage of radioactive waste
The radiation store holds a small number of legacy radioactive sources. The ambient dose rates within the store were low and external dose rates outside the store were only slightly above background levels. The store was assessed against the ARPANSA Checklist based on AS/NZS 2243.4 and met all requirements. The security requirements for the category of sources were appropriate when assessed against RPS 11.
The RPP states that all CSIRO sites have comprehensive emergency management plans and procedures. The current CSIRO Clayton Site Emergency Management Plan version 1.4 was provided during the inspection. This document provided the management structure, response procedure, training requirements and reporting.
The Clayton site is patrolled by an external security agency outside working hours and have electronic security for their buildings in addition to restricted swipe pass access or keys (restricted) for authorised persons who need to work in the radiation laboratories. The radiation store requires key access that is restricted to authorised personnel only who have a need for access. The physical security measures observed at the site are in accordance with the security procedures outlined in the RPP.
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 area/s for improvement:
- Inconsistencies, terminology and editorial updates in the RPP
- Remove statement for transport on CSIRO sites requiring dose rate of not more than 40 Svh-1
It is expected that improvement actions will be taken in a timely manner.