CSIRO Agriculture and Food (CAF)
|Location inspected||Black Mountain Site, Acton, ACT|
|Date of inspection||20-21 June 2023|
This is the record of an inspection 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 S0021.
The scope of the inspection included an assessment of performance at Black Mountain against the Source Performance Objectives and Criteria (SPOC). The inspection consisted of a review of records, interviews, and physical inspection of CAF sources at the site.
The stated mission of CAF is to create healthier, trusted, safer and more sustainable food and fibre for the future. CAF uses and stores controlled material and controlled apparatus at the CSIRO Black Mountain site to assist in achieving its mission and is therefore authorised under section 33 of the Act to deal with controlled apparatus and controlled material such as sealed and unsealed radioactive sources, X-ray analysis equipment, UV apparatus and lasers as research tools.
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 (Rev.1) Code for the Safety Transport of Radioactive Material (2019)
- RPS C-6 Code for Disposal of Radioactive Waste by the User (2018)
- Radiation Protection Series No. 12 Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006) (RPS12)
- Australian/New Zealand Standard Safety in Laboratories Part 4: Ionizing radiations (AS/NZS 2243.4:2018)
- Australian/New Zealand Standard Safety in Laboratories Part 5: Non-ionizing radiations –Electromagnetic, sound and ultrasound (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 60825-14:2011)
In general, the management of radiation safety at the CAF Black Mountain site in relation to controlled material and controlled apparatus was found to be sound.
CSIRO has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective use, storage and disposal of radiation sources across all of its Business Units (BUs). This is supported by a comprehensive radiation protection plan (RPP) from which each BU extracts the relevant information for the controlled apparatus and controlled material dealings for that the given BU. These RMPs are in turn, supported by subordinate location or work specific documents called safe work instructions. Access to this information is available to all relevant staff via QR codes attached to or immediately adjacent to the particular source.
Statutory & regulatory compliance
The overall RMP, CSIRO’s Plans and Arrangements, are written to ensure compliance with the Act, the Regulations and the conditions of the licences for each BU, including S0021.
The CAF Radiation Safety Officer (RSO (or BURSO)) coordinates information for quarterly reports combining that from each CAF site. Once collected, this information is consolidated into a single final report to ARPANSA. CAF 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.
Although the inventory of controlled sources for CAF at the Black Mountain site is significant, most controlled material is in storage awaiting ultimate disposal. While this store is ultimately overseen by the CSIRO Chief RSO, the RSO of each BU, including CAF, has a duty of care for the safe storage of the sources within the store through maintaining their own sources on their respective inventories.
CAF uses unsealed radioactive material, sealed source apparatus, X-ray equipment, ultraviolet radiation apparatus and a laser at the Black Mountain site. Of those seen during the inspection, all matched the internal designations assigned to those sources and listed in the source inventory workbook (SIW). It was noted however that the model designation of the controlled apparatus did not appear in the SIW although the information in the CSIRO database did include the model designation. This lack of complete data in the SIW is considered an area for improvement.
Training & education
All CAF personnel using the controlled radiation sources at the Black Mountain site are required to undertake training relevant to the sources they will use during their work. Training records are kept electronically and ARPANSA inspectors observed these records for several individuals authorised to use the controlled sources at the Black Mountain site.
Access to laboratory areas is restricted to personnel who have undergone appropriate training.
All CAF controlled non-ionising radiation apparatus in use at the Black Mountain site were considered to meet the relevant requirements of the laser standard for the laser or RPS12 and AS/NZS 2243.5 for the UV apparatus.
The unsealed source laboratory was considered to meet the low-level laboratory requirements of AS2243.4.
CAF uses a radiation gauge fixed in a trailer for analysing soil core samples. This analysis can be done in the field although since the beginning of the Covid-19 pandemic, it has only been done at the Black Mountain site with the soil core samples being sent to the site for analysis. The gauge was not expected to be used in the field again for at least two months.
While the trailer was appropriately placarded in accordance with the Transport Code, there were no Category transport labels on the ‘package’ nor was there a Dangerous Goods Declaration to accompany the vehicle when on public roads.
The configuration of the gauge in the trailer made it difficult to determine what the ‘package’ would be (the gauge is locked in position inside an acrylic container during transport with the sides of the trailer locked down into position). The Category transport labels identify the potential hazard in the case of an emergency by giving an indication of the dose rates around the ‘package’ and are therefore important for emergency services personnel to determine the potential hazard. Based on the dose rates measured around the gauge during the inspection, two Category-I white labels containing the relevant source details would be sufficient.
In relation to the transport document requirements in the Transport Code, a generic Dangerous Goods Declaration would be acceptable as CAF would be the consignor, the carrier and the consignee.
Acknowledging that these requirements only apply when transport takes place on public roads, the identified areas for improvement need to be rectified before any such transport is affected to avoid a non-compliance.
Radioactive waste including ultimate disposal or transfer
The radiation store contains many disused sealed and unsealed radioactive sources from six separate BUs, including CAF, which are intended for ultimate disposal once a suitable national disposal site is identified and commissioned. Some of these sources have now decayed to levels below that required for licensing under the Regulations based on their original activities and acquisition dates.
All storage is in large, well-labelled containers and the SIW of each relevant BU, including CAF, itemises all sealed sources within the store. Dose rates outside the store did not exceed the requirements of AS/NZS 2243.4 and were found to be not significantly above the background radiation dose rate.
Access to the radiation store is strictly limited to only personnel who have entry privileges under the authority of the CSIRO Chief RSO.
Access to all CSIRO buildings at the Black Mountain site beyond the public areas is protected by an electronic access control system. The aggregation of all sources under CSIRO control at the site, including those in the store, do not invoke enhanced security requirements. The existing security measures were therefore considered appropriate.
Event protection and emergency preparedness and response are handled under the broader CSIRO policy and work health and safety plans and were not assessed during the inspection.
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:
- All labelling and transport document requirements required by the Transport Code be met before the mobile radiation gauge is transported on public roads.
- The model designation of each controlled apparatus needs to be included in the SIW.
It is expected that improvement actions will be taken in a timely manner.