Inspection report: Department of Agriculture, Water and the Environment, NT, 12-13 and 26 October 2020

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 source licence S0015.

The scope of the inspection included an assessment of the AFP’s performance at the Melbourne CBD and Melbourne airport sites against the Source Performance Objectives and Criteria (POCs). The inspection consisted of a review of records, interviews, and physical inspection of the sources.

Background

SSB undertakes research and environmental monitoring to assure the environment in the Alligator Rivers Region of the Northern Territory is protected from the effects of uranium mining. Some of the research undertaken by SSB involves the use of radiation sources. There is a laboratory dedicated to analysing environmental samples that typically contain levels of radioactivity that are indistinguishable from background. There are a small number of sealed sources that are used for ensuring the accuracy of the sensitive equipment utilised in the analysis of these environmental samples. A second laboratory uses small quantities of unsealed sources, while UV sources are used in another two laboratories. A handheld X-ray Fluorescence (XRF) analyser is stored outside the laboratories.

The main codes and standards applicable to these sources are those that appear in section 59 of the Regulations plus: 

• Australian Standard Safety in Laboratories - Ionizing Radiation (2018) (AS 2243.4-2018).

Observations

Performance reporting verification

SSB has appointed an individual to be the Radiation Safety Officer (RSO). The RSO periodically provides reports to the Work Health and Safety (WHS) meetings. This provides a formal communication channel for the RSO to communicate matters associated with radiation protection and regulatory requirements. Due to the small size of SSB, informal communication with management and senior management is also encouraged.

The WHS system has the capacity for the reporting of incidents. While there have been no radiological incidents in many years, the system is in place and is utilised for other hazards. Staff are highly encouraged to report incidents, these are investigated and corrective actions identified and tracked until completed. This process was used for the areas-of-improvement identified in the previous ARPANSA inspection in 2018.

Configuration management

The Department that SSB sits within has just released its risk management framework. While it is expected that SSB will need to comply with this, it has however, for several years been developing a bespoke safety management system to deal with the risks associated with the work SSB undertakes and the environment the work is conducted in. This involves the identification and assessment of risks and is reviewed annually. It was observed that ionising radiation was on the register but non-ionising radiation was not listed. The hierarchy of controls are used to manage risks. This includes a suite of safety documents, which includes the Plans and Arrangements (P&A) for safely managing radiation sources and is supplemented by procedures for routine tasks. Non-routine tasks are assessed on a case-by-case basis and signed off by the senior manager after the identification of relevant controls for each aspect of the activity have been identified.

The work undertaken by SSB is often project based. Projects are identified that link to an organisational need. The process for managing the approval of these projects is integrated with the safety management system described above. The process for approving a few projects was reviewed. In one instance it was identified that project scope creep had led to deviation from the documented approval and what occurred in practice. It appears that the safety aspects of the revised project were appropriately managed as relevant procedures and training was prepared and conducted. However, this deviation, in conjunction with other observations, is identified as an area for improvement as a useful reminder to maintain awareness of the potential difference between work as imagined and work as conducted.

The inspection included a physical walk-through of the various laboratories. It was observed to be standard practice to mark the areas of the benches where ionising radiation is used with trefoil symbols. This would be expected to isolate the areas where contamination could occur. Another standard practice was the signage on the door to each laboratory. These listed the required apparel and PPE to access the area. With the exception of Laboratory 25, it was also observed that an area manager was listed as being responsible for each area. Laboratory 25 was observed to have a few minor housekeeping issues. These included unwashed glassware in the sink, the bin under the sink was almost overflowing with disused gloves and hand towels, and the surface of the bench itself was starting to show cracks in what is normally an impervious surface. Furthermore, the vent from the fume cupboard appeared to be secured to the ceiling with painter’s tape. While these are minor issues and not expected to result in radiation dose, SSB is expected and encouraged to maintain high standards of lab practices consistent with industry standards.

Inspection, testing and maintenance 

SSB holds a small number of radiation detectors that are used for protection purposes. This includes the capacity to measure both dose rates and surface contamination. The gamma radiation monitor was calibrated on an annual basis and was observed to be within the calibration period. The contamination monitor, however, is only used to perform a qualitative check whether any radioactivity is present or not. As such, ARPANSA accepts calibration every five years as adequate for equipment used for these purposes. It was observed that the contamination monitor had been calibrated less than five years ago.

Annual audits of all sealed sources, unsealed sources, ionising and non-ionising apparatus are conducted and records demonstrating that audits were conducted in 2018, 2019 and 2020 were provided. A similar program exists for the wipe testing of sealed sources that are in use. This is done to confirm the integrity of the source encapsulation. Tests were performed in 2018 and 2020. However, wipe testing did not occur in 2019. At the time of the inspection, it was unclear how these activities were managed and how robust the system is to ensure they occur. Despite this uncertainty, it is concluded that measures could be taken to strengthen the system to perform routine safety functions. This, in combination with other observations within this report, is identified as an area for improvement.

Training

Over the last five years SSB has been moving towards a coordinated approach to managing WHS. This has included training. One aspect of this is a learning and development database that has been created to make sure that the right people, with the right training, are undertaking work. A training needs analysis has been performed for all staff. This identifies the mandatory training required to safely perform the key tasks undertaken by the individual. Reports of this training are provided to management so that completion levels can be monitored and the required financial commitment can be allocated in the budget process. Although it has not yet been completed, staff indicated that SSB is moving towards being able to assess the effectiveness of training being undertaken. In conjunction with other observations this is identified as an area for improvement.

SSB has appointed a research scientist to also perform the role of RSO. This individual was trained by the previous RSO in the specific requirements associated with this role. This was supplemented by a formal education background relating to radiation and on-the-job training, employment in the field, and engagement with a professional organisation relevant to radiation protection.

The RSO conducts induction training for all staff at SSB to provide an awareness of the radiation hazard that exists in the laboratories. This is done in conjunction with other hazards (i.e. chemical and field work). The aim of the induction is to provide an awareness of the radiation sources, provide an assurance that they are of very low radiological hazard, and outline the framework for managing the risks associated with the radiation sources.

Event protection

SSB has identified external initiating events such as fire and cyclones that have the potential to lead to radiation exposure and has put in place arrangements for responding to these events within the P&A. 

Security

SSB staff indicated that no security breaches have occurred since the last inspection. Physical security to the buildings is implemented via authorisations, access controls and alarms systems. Access to the radiation sources are further controlled so that only those personnel with a need to access the laboratories have access to the keys to enter the designated radiation areas. An exception, however, is the handheld XRF. This is stored separately to the laboratories. While the device itself is stored in a locked cabinet, the keys to access the storage location are not controlled. This is an area for improvement.  

Radiation protection

Personal dosimetry is worn by the small number of staff who undertake activities associated with ionising radiation sources. The RSO routinely reviews the doses recorded by these devices and advises the wearers of their dose. These doses are negligible hence no trending of doses received is performed. This was reviewed and confirmed as part of this inspection. The dosimeters are typically worn at chest height. This is done to avoid shielding effects from the benches that could occur if the badge is worn at waist height. When not being worn the badges are stored along with the control in an office environment away from the sources of radiation that are handled.

Staff indicated that there have been no radiological incidents in the last two years. However, no prospective safety assessments have been performed nor have iterative reviews of the optimisation of protection and comparison against a dose constraint been undertaken. These are fundamental aspects of radiation protection and should be performed. However, it is acknowledged that given the low levels of radioactivity being handled and the negligible doses incurred, a high level approach to the analysis performed may be appropriate. This would be consistent with the graded approach to protection.

A dedicated radiation store is used for securely holding a small number of disused sealed sources, excess quantities of unsealed sources and environmental samples that have previously been analysed. As small amounts of naturally occurring radionuclides are held in the store, radon is vented prior to entry. The extract is located at floor level as radon is known to be heavier than air. An environmental radon daughter monitor was used to measure the potential alpha energy concentration over a two week period. This was used to evaluate the average and maximum expected dose due to radon progeny. The analysis showed that the dose due to radon progeny to personnel accessing the store is negligible.

Emergency preparedness & response

Procedures for responding to accidents involving spills of radioactive solutions and powders or dropping sealed sources have been prepared and documented in the P&A. Procedures are also present for responding to a fire or cyclone. The procedures for spills and drops provide broad descriptions of actions that are expected to decrease the dose received while rectifying the situation. For solutions and powders, this involves absorbing liquid or collecting the powder. A spill kit in the area considered to have the greatest risk was checked during the inspection. The spill kit held absorbent materials, a dustpan, and a bag in which the material could be temporarily stored. The contents of the spill kit were listed on a laminated instruction sheet inside the kit. It was confirmed that all of the expected contents of the kit were present and ready for use. 

For fire, the preservation of human life is first priority. If the fire is small, and the individual is trained and confident to do so, a fire extinguisher or fire blanket can be used to extinguish the fire. There are numerous fire extinguishers and fire blankets on site, stored in designated locations within and around the laboratories and routinely inspected. The arrangements in the P&A require anyone exposed to the smoke plume to be checked for contamination.

For cyclones, SSB relies on the design and construction of the building to provide the first level of defence. Cyclones are forecast and warnings issued prior to the cyclone making landfall. No SSB employee is permitted to be in the buildings when this occurs and they are not allowed to re-enter should the buildings appear to be damaged. Arrangements are described in the P&A to have the buildings assessed by an engineer or other suitable person prior to entry while still managing radiation protection.

Findings

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:

1. Strengthen current arrangements to:
   - control the internal review and approval process to maintain awareness of the potential for scope creep in project work that may result in deviations from work as planned and approved 
   - ensure that routine safety functions are performed as planned
   - consider the effectiveness of training relevant to radiation protection.
2. Review the arrangements for securing the XRF and controlling access to it.  

It is expected that improvement actions will be taken in a timely manner.