Department of Climate Change, Energy, the Environment and Water Australian Antarctic Division (AAD)
|Location inspected||Kingston, Tasmania|
|Date of inspection||6 June 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 S0055.
The scope of the inspection included an assessment of performance at the AAD Kingston premises against the Source Performance Objectives and Criteria (SPOC). The inspection consisted of a review of records, interviews, and a physical inspection of sources.
The AAD, based in Kingston Tasmania, manages and administers Australia’s presence in the Australian Antarctic Territory and the Southern Ocean, along with the subantarctic territories of Heard Island and McDonald Islands and their adjacent waters. The AAD is responsible for leading, coordinating and delivering the Australian Antarctic program focused on conducting world-class science of critical national importance and global significance, which delivers on Australian Antarctic policy and operational priorities.
In achieving these goals, AAD uses sealed and unsealed radioactive sources, X-ray equipment, UV apparatus and lasers as research tools at its Antarctic bases. Consequently, AAD is licensed under section 33 of the Australian Radiation Protection and Nuclear Safety Act 1998 to deal with controlled material and controlled apparatus for research at its various sites.
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)
- RHS9 Code of Practice for Protection Against Ionizing Radiation Emitted from X-ray Analysis Equipment (1984)
- 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 the AAD Kingston premises 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 below.
AAD has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective use, storage and disposal of radiation sources at its Kingston premises and its Antarctic bases. This is supported by a comprehensive Ionising Radiation Manual (IRM), their Plans and Arrangements, to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions. This is, in turn, supported by subordinate location or work specific documents such as the optics laboratory, the containerised radiation laboratory and others. It should be noted that this particular inspection focussed mainly on the Kingston premises with Antarctic and Southern Ocean bases being inspected electronically at other times.
Some aspects of the documentation were seen as areas for improvement including:
- There was no version identification or most recent revision details listed in the hard copy of the IRM.
- The subordinate documents to the IRM were reviewed on a 5-year cycle although given that these essentially are part of the overall radiation management plan, these need to be on the same review cycle as the IRM.
Statutory and regulatory compliance
The IRM has been written to ensure compliance with the Act, the Regulations and the conditions of licence S0055.
Recently, several legacy items such as radium dials from aircraft instrumentation, pocket watches and similar items along with thoriated glass in camera lenses have been discovered on-site or at the bases. These are expected to be transferred to another Commonwealth licence holder in the short term but are not currently on the AAD source inventory workbook (SIW) where they need to be included under the extant category of G1-6 – Sources awaiting disposal.
The Radiation Safety Officer coordinates information for quarterly reports combining those from Kingston and Hobart with input from each Antarctic base. Once collected, this information is consolidated into a single final report to ARPANSA. AAD quarterly reports have been submitted to ARPANSA in a timely manner in recent years, and contain relevant information, including details of compliance with the Act and Regulations.
The IRM outlines the requirements, safe working procedures and accident/emergency response requirements relating to the radioactive materials store along with emergency procedures for the site in general.
The radioisotope laboratory at the Kingston premises has not been used for approximately 12 years and the enclosed X‑ray unit for 10 years. The latter is stored in a locked case within the main building and is only accessible to personnel with appropriate authorisation.
Of those controlled material and controlled apparatus seen during the inspection, all but one matched the internal designations assigned to those sources and listed in the SIW. The exception was a UV cabinet that did not have the same serial number listed in the SIW although all other aspects (e.g. Make, Model, output etc) were as described.
Training and education
All personnel using controlled apparatus or controlled material at AAD are required to undertake training related to the particular type of source they will use. This training includes general radiation induction, individual laboratory induction and specific use training, the extent of which depends on the proposed dealing for the given individual. Training records are kept electronically and ARPANSA inspectors observed these records for several individuals authorised to use the controlled apparatus and controlled materials at AAD. However, the training record for at least one person was not in the system representing an area for improvement.
Access to laboratory areas is restricted to personnel who have undergone appropriate induction training.
The two new deputy Radiation Safety Officers (RSOs) provided copies of their ANSTO radiation training certificates.
Some radiation monitors on-site were within the calibration requirements for checking the presence of radiation (5 years) but had exceeded the annual calibration requirement for a monitor used for measuring dose rates. It is noted however, that no ionising radiation work has been carried out at the Kingston site for many years as outlined above. This is therefore considered an area for improvement.
In recent times, AAD has replaced higher power Class 4 lasers with Class 2 laser equipment and ARPANSA therefore no longer has regulatory interest in these dealings.
The radiation store contains several disused radiation gauges and contaminated trash in drums arising from work with radioactive material at the Antarctic and Southern Ocean stations. It was noted that the activity of the radiation gauges (cobalt-60) has now decayed to levels below that required for licensing under the Regulations.
All storage is in large, well-labelled containers and the SIW itemises all sealed sources within the store. Dose rates outside the store did not exceed the
requirements of AS/NZS 2243.4.
AAD will confer with the Tasmanian radiation regulator about the possibility of sending the contaminated trash for disposal into landfill.
Access to all AAD buildings beyond the public areas is protected by an electronic access control system. The aggregation of all sources under AAD control, including those in the store, do not invoke enhanced security requirements. The existing security measures are therefore considered appropriate.
Event Protection and Emergency Preparedness and Response are handled under the broader AAD policy and work health and safety plans and were not assessed during the inspection.
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:
- There was no version control information on the main IRM.
- Electronic training records were not up to date.
- Subordinate documents to the IRM were only reviewed on a 5-year basis.
- Some dose rate monitors had not been calibrated for more than one year.
It is expected that improvement actions will be taken in a timely manner.