National Gallery of Australia (NGA)
|Location inspected||Parkes Place, Parkes ACT|
|Date of inspection||19 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 S0024.
The scope of the inspection included an assessment of performance of the NGA against the Source Performance Objectives and Criteria (SPOC). The inspection consisted of a review of records, interviews, and a physical inspection of sources.
The NGA is the Commonwealth of Australia’s national cultural institution for the visual arts and is part of the Department of Infrastructure, Transport, Regional Development, Communications and the Arts portfolio. The licence holder is authorised under section 33 of the Act to deal with ultraviolet radiation sources, an industrial radiography X-ray unit and X-ray analysis equipment for the examination and conservation of artworks.
The main codes and standards applicable to this licence are:
- RPS C-1 Code for Radiation Protection in Planned Exposure Situations (Rev 1) (2020)
- Radiation Protection Series No. 12 Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006) (RPS 12)
- Radiation Protection Series C-4 Code of Radiation Protection Requirements for Industrial Radiography (2018) (RPS C-4)
- Australian Standard Safety in Laboratories – Ionizing Radiations (2018) (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)
In general, the management of radiation safety at NGA in relation to controlled apparatus was found to be sound.
NGA has demonstrated a commitment to radiation protection by establishing a Radiation Protection Plan (RPP), their Plans and Arrangements, to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions at its Parkes premises. The RPP is, in turn, supported by procedural documents relating to radiation protection and X-ray safety management. These documents were last reviewed in May 2023.
It was noted that the RPP was specifically targeted towards the use of the handheld X-ray analysis device with the procedural documents providing the specific safety requirements for the individual devices. Further, the procedural document for the handheld X-ray analysis device repeated some information that appeared in the RPP. During discussion, it was considered that there was an area for improvement by making the RPP a more general overview of the requirements for the safe use of controlled apparatus (e.g. radiation monitoring, training, disposal, storage, reporting, record keeping etc) at the NGA and leave the procedural documents for outlining the specific requirements for their respective apparatus.
Statutory & regulatory compliance
The RPP and its subsidiary documents have been written to ensure compliance with the Act, the Regulations and the conditions of licence S0024.
The Radiation Safety Officer coordinates quarterly reports into a single final report to ARPANSA. NGA 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.
Safety management for the licence is outlined in to the RPP and its subsidiary documents and includes topics such as:
- general radiation information,
- training of relevant staff,
- PPE and personal monitoring
- maintenance and equipment failure
- emergency procedures and incident reporting, and
Of those controlled apparatus seen during the inspection, all matched the internal designations assigned to those apparatus and listed in the Source Inventory Workbook.
Training & education
All personnel who operate the handheld X-ray unit are required to undertake training relevant to the equipment’s use before being permitted to use it. The RSO is the only person trained to use the industrial radiography equipment. Training records for those staff permitted to use the handheld X-ray unit were verified by the ARPANSA inspectors for each person who had completed the training.
All records pertaining to the controlled apparatus including licences, dose assessments, training records, reports and similar are kept in chronological order in a single folder. This creates difficulties in finding a particular item, particularly older information. Separate folders for each major topic would facilitate easier extraction of a relevant record and this segregation of information was identified as a potential area for improvement.
The fully enclosed X-ray room is located in the conservation laboratory area and is used for radiography of artwork. The X-ray room is fitted with an interlock on the door that prevents exposure unless the door is closed. Appropriate warning signs and a warning light are in place at the entrance to the X-ray room and include constraints in terms of the maximum kV and tube current to be used. An audible signal operates while the industrial radiography unit is producing X-radiation. All radiation protection provisions of RPS C-4 and AS2243.4 were seen to be used including, but not limited to:
- warning signage,
- relevant warning labelling on X-ray equipment,
- the use of audible and visible warnings when the industrial radiography unit was in use,
- the use of a fully enclosed and appropriately shielded X-ray room for the industrial radiography adoption of the justification principle when determining the need for an X-ray, and
- the availability of a radiation survey meter.
It was noted that the radiation survey meter had passed its calibration date for determining dose rates (annual) but within the calibration date for detecting the presence of radiation (5 years). The X-ray unit has not been used for at least 3-years negating the need for the measurement of dose rates. However, detection of the presence of radiation is still an important aspect of using such an exposure room. That being the case, it was agreed that the monitor need not be calibrated annually but it does need to be labelled to the effect that it cannot be relied on for dose rate measurements, only the presence of radiation. Once recalibrated though, it can again be used for dose rate measurements until such time that the annual calibration date is passed.
No radioactive waste is generated during any procedure.
Access to all NGA buildings beyond the public areas is protected by security and an electronic access control system.
Keys to the X-ray room are centrally located and accessible only through use of a personalised swipe card. The RSO is the only person who has access to the keys to operate the industrial radiography X-ray unit.
The use of controlled apparatus does not invoke the requirements of the Code of Practice for the Security of Radioactive Sources (2019) (RPS11). Existing security measures are therefore considered appropriate.
Emergency procedures are outlined in Section 7 of the RPP including incident reporting procedures. These were considered satisfactory for the type of equipment and foreseeable incidents at NGA.
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:
- The RPP be restructured to be more general for the overall use of radiation at the NGA with specific requirements placed in subsidiary documents.
- Records be segregated into separate folders relating to their major regulatory topic.
The survey meter be clearly labelled that it can only be relied on for detecting the presence of radiation after the annual calibration date is passed.