Inspection report: CSIRO Minerals Resources, ACT, 3-4 December 2020
|Inspection report details|
|Licence holder:||CSIRO Minerals Resources|
|Location inspected:||Black Mountain, ACT|
|Date/s of inspection:||3-4 December 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 S0064.
The scope of the inspection included an assessment of Minerals Resources’ performance at Black Mountain against the Source Performance Objectives and Criteria (POCs). The inspection consisted of a review of records, interviews, and physical inspection of sources. This inspection focused on the management of disused radioactive materials in storage awaiting ultimate disposal.
CSIRO Minerals Resources (MR) are licensed to deal with a broad range of controlled material and apparatus largely for materials analysis and other resource-related research. The licence covers eight (8) locations around Australia. At the Black Mountain site in ACT, most of the inventory is legacy radioactive materials that are in storage and awaiting ultimate disposal.
The main codes and standards applicable to these sources are those that appear in section 59 of the Regulations plus:
- Australian/New Zealand Standard: Safety in laboratories part 4: ionizing radiations (AS/NZS 2243.4:2018)
- Radiation Protection Series C-6: Code for disposal of radioactive waste by the user (2018)
- Radiation Health Series 28: Code of practice for the safe use of sealed radioactive sources in borehole logging (1989)
The management of safety and security at the Black Mountain site was found to be strong. However, there appeared to be room for improvement with respect to the conduct of annual wipe testing, strengthening the training arrangements by developing a systematic approach to training, implementing a water management system for below ground structures that are at risk of flooding, and hosting familiarisation visitations at source storage locations for emergency services personnel.
CSIRO Minerals Resources described the impact that COVID-19 had on the business unit. This included the need for identifying essential workers, reduced on-site capacity arrangements, project delays due to the lack of availability of contractors and a staged approach to recommencing activities based on jurisdictional-specific restrictions. In discussing the impacts in relation to radiation safety, it was clear that CSIRO more generally was in a stronger position than many other organisations during COVID-19 since their policies on flexible working arrangements and working remotely were already in existence prior to the pandemic. Critical work was identified and radioactive sources and materials have been managed appropriately during this period.
Performance reporting verification
CSIRO continues to provide timely quarterly reports that contain relevant information regarding compliance. CSIRO regularly communicates with ARPANSA on any new endeavours or planned activities regarding the existing inventory. Moreover, CSIRO participates in the CSIRO-ARPANSA Liaison Forum (CALF) where significant information exchange activities occur. CSIRO’s plans and arrangements also clearly describe notification arrangements and requirements.
MR maintains two source stores on site to manage largely disused sealed and unsealed sources awaiting ultimate disposal. The main source store is configured to receive sources in one location and has a fume cupboard so that characterisation activities can be safely performed. Being a former 60Co laboratory, the store is located underground and has walls constructed of 1 m of concrete which provide adequate shielding. Storage racks are elevated above ground level and sources are stored on spill trays with multiple layers of containment. The source stores were very well organised with highly effective labelling in place making for very quick reckoning and identification of the sources.
MR has implemented a training record management system which verifies when staff have completed required training on specific apparatus or equipment. CSIRO has also developed a suite of internal training courses (such as UV training) which are managed and delivered centrally. When discussing the nature of required competencies it was found that MR finds it difficult at times to know exactly what to assess. It was agreed that MR and CSIRO more broadly would benefit from considering developing a systematic approach to training. Part of this would require a detailed training needs analysis which is likely to inform the required assessment. Discussions also highlighted that the benefit of this approach would enhance other areas such as chemical safety in laboratories.
Considerations for external events have been captured in the design and operation of the waste store. Because the store is located underground the racking system used to store the sources has been elevated off the ground to ensure that sources do not become inundated with water during a potential flooding event. It was agreed that the store would benefit from the capability to pump water out of the source store in extreme flooding scenarios. Other events such as fire and criticality have also been considered and addressed appropriately.
The store is currently undergoing a range of protective security upgrades to ensure that it meets the requirements for a Security Category 2 store in accordance with the ARPANSA RPS-11 Code of Practice for the Security of Radioactive Sources. The inspection team reviewed the existing security infrastructure and the proposed schedule of works and determined that continued monitoring and guidance will be required as the store progresses. It should be noted that with the existing inventory the store does not require any additional security infrastructure.
From a radiation protection perspective MR has implemented radon environmental monitoring devices and neutron and gamma dose monitoring for the waste store. Coupled with personnel monitoring and routine contamination control checks, the waste store provides a safe environment to perform work. A fume hood is available should any work be required to be performed with unsealed sources. In regard to sealed sources it was agreed that when MR receives sources that are being consolidated at this store from the entire CSIRO inventory, that the receipt process is an opportune time to initiate the wipe testing requirements to satisfy themselves that CSIRO is receiving legacy sources which are not introducing a contamination risk.
Emergency preparedness & response
The waste store has been equipped with a range of spill kits, decontamination equipment and environmental radiation monitoring detectors. It was agreed that the local fire services would benefit from a familiarisation visit hosted by MR. Further, in some areas of the store there is limited mobile phone signal coverage so it was also agreed that alternative communication methods should be established for those working in the store should there be an emergency.
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:
- MR and CSIRO more broadly would benefit from developing a systematic approach to training including a formal training needs analysis for routine tasks.
- MR should introduce the capability to pump water out of the source store in extreme flooding scenarios.
- MR should undertake wipe-testing of sealed sources on receipt as the CSIRO inventory is transferred to the Black Mountain waste store.
- MR should host a familiarisation visit of the local fire brigade at the waste store.
- Alternative communications methods should be installed in the waste store for emergencies.
It is expected that improvement actions will be taken in a timely manner.