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Inspection report: Geoscience Australia (no. R20-09362)
|Inspection report details|
|Licence holder:||Geoscience Australia|
|Location inspected:||Symonston, ACT|
|Date/s of inspection:||8 September 2020|
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 S0014.
The scope of the inspection included an assessment of Geoscience Australia’s performance at Symonston against the Source Performance Objectives and Criteria (POCs). The inspection consisted of a review of records, interviews, and physical inspection of sources.
Geoscience Australia (GA) is authorised under section 33 of the Act to deal with a range of controlled material and controlled apparatus. These largely include unsealed sources in the form of natural uranium and thorium samples, and a range of x-ray analytical devices that are used to analyse these samples.
The main codes and standards applicable to these sources are those that appear in section 59 of the Regulations plus:
- AS/NZS 2243.4:2018 Safety in Laboratories Ionising Radiation
- AS/NZS IEC 60825.1:2014 Safety of laser products equipment classification and requirements
- Radiation Health Series 9: Code of Practice for Protection Against Ionising Radiation Emitted from X-Ray analysis equipment (1984)
- Radiation Protection Series 13: Code of Practice and Safety Guide for safe use of fixed radiation gauges (2007)
In general, the management of safety and security at GA was found to be satisfactory. In some cases, however, there appeared to be room for improvement with respect to risk assessments, wipe testing, baseline radon measurements and detailed inventory characterisation.
Performance reporting verification
GA has consistently provided timely quarterly reports to ARPANSA and has included relevant information regarding its regulatory compliance. Procedural reviews, updates, changes to OSL wearer information and changes to the inventory have all been provided.
GA has maintained a reasonably consistent inventory for a number of years. Collected samples are stored within the isotope store after their analysis in the laboratories. Samples are not typically disposed or transferred. The Rock Repository, for example, maintains natural core samples collected as far back as 1910. The isotope store also has a range of uranium and thorium samples that have been collected and stored over many decades.
In order to improve the overall management of their inventory, GA are embarking on implementing a new inventory management system called the minerals specimen data management tool. This system is expected to capture a range of specific information on each sample such as: location of where the item is, where it was collected from, the dose-rate of the sample, imagery (in some cases) and a description of the material. It was observed that this database was partially complete, and noting that GA maintain a capability for portable XRF analysis, it was agreed that GA should embark on a project to more accurately characterise the inventory of samples contained within the isotope store to ensure that the data is accurate and up to date.
Staff involved with managing the GA controlled material and controlled apparatus are trained in both the ANSTO General Radiation Safety Officer Course and the Advanced Radiation Safety Officer Course. Specific training is also provided for dedicated equipment such as the hand-held portable XRF apparatus. Training records from 2015 and 2018 were sited, respectively.
The protective security arrangements for the inventory at GA were determined to be satisfactory. Electronic access controls, CCTV and other appropriate administrative arrangements ensure that unauthorised access to controlled materials is maintained.
GA maintains dedicated standard operating procedures (SOPs) and risk assessments for the use of controlled apparatus and specific operating environments such as out-door field work, laboratory work or work conducted in the isotope stores. The risk assessments provided to inspectors highlighted inherent hazards, controls and an analysis of the effectiveness of those controls against the risk tolerance of the WHS committee. However, it was noted that risk assessments were incomplete in some cases and it was agreed that these should be completed to ensure that they form the basis of the SOPs that have been developed.
Emergency preparedness & response
Due to limited time, emergency preparedness and response arrangements were not assessed during this inspection.
Recognising that legacy core samples which may contain naturally occurring radioactive material (NORM) (which ARPANSA does not regulate) still may present a radiological hazard if there is sufficient radon present, the GA representatives gave the inspectors a tour of the mineral fossil collection room to seek advice on whether radon measurements should be collected. This demonstrated to the inspectors that despite being out of scope for regulatory purposes, GA has a good safety culture as they still sought advice on how best to protect their personnel. Guidance was provided and it was agreed that even though there are regular air exchanges with the air conditioning system (when there is power), it would be beneficial to observe what the normal radon levels are in order to compare them to safety levels and address any risks that may be present.
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:
- GA should review their inventory in the isotope store and more accurately characterise their holdings.
- GA should conduct a more formal risk assessment for current and future activities to form the basis of SOPs.
- GA should arrange to conduct annual wipe tests for all non-exempt sealed sources in the isotope store.
- GA should consider conducting background radon characterisations for all core sample storage areas.
It is expected that improvement actions will be taken in a timely manner.