Inspection report: Australian National University (ANU) Research School of Physics, ACT, 2 December 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 S0027.

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

ANU is licensed under section 33 of the Act to deal with a range of sealed and unsealed radioactive materials and a broad range of controlled apparatus in the form of lasers and ultraviolet sources. During this inspection the focus was centred on the management of radioactive materials during the pandemic. 

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 9: Code of practice for protection against ionizing radiation emitted from X-ray Analysis Equipment (1984)
• Radiation Protection Series C-4: Code of Radiation Protection Requirements for Industrial Radiography (2018)

Observations

Overall, the management of safety and security at the ANU RSPhys was found to be strong.  However, there appeared to be room for improvement with respect to: clearly defining the thresholds for requesting approval under section 63, linking of access control authorities to training competencies in certain laboratories, clearly documenting the frequency of contamination monitoring surveys and performing leak tests of sealed sources consistently with what ANU RSPHYS does in practice and hosting site familiarisation activities with local emergency services such as police and fire brigade.

COVID-19 considerations

Initial discussions focused on the impact of the pandemic on ANU more generally and specifically with their controlled materials and apparatus. It has been quite public that ANU like other tertiary education and research institutions across Australia were severely affected from an economic perspective and this had resulted in a number of positions becoming untenable. Ultimately some positions were lost and ANU RSPhys also had to cross-train additional staff to cover knowledge gaps and task deficiencies due to departing personnel. Despite an emotionally and psychologically difficult time, ANU RSPhys were very successful at using the opportunity to ‘reset’ the baseline of activities across the school including those associated with radiation safety functions. Staffing was significantly reduced as was the presence of students on site. Lectures were held virtually and in some cases, experiments and laboratory tasks were mailed out to students in their residential locations (excluding radioactive materials).

Performance reporting verification

ANU as a whole consistently provide timely quarterly report information that also contains relevant information about their compliance performance. This information includes acquisitions and disposals of controlled materials and apparatus, information regarding revisions of plans and arrangements and in some cases information regarding non-compliance such as the loss or inadvertent disposal of controlled apparatus without approval. The level of transparency experienced by ARPANSA with ANU has increased over a number of years. ANU also regularly engage ARPANSA inspectors to seek regulatory advice on a range of matters.

Configuration management

The ANU RSPhys activities are managed across a number of buildings within the same precinct. In some cases buildings are shared with other research schools (such as the John Curtin School of Medical Research). ANU maintains dedicated building maintenance personnel, WHS personnel and a radiation safety officer/laser safety officer network across the organisation. All of these personnel were heavily engaged during the peak of the pandemic as it was identified early on that a number of critical equipment, maintenance tasks and activities were required regardless of the pandemic. Further, ANU RSPhys identified that a low-attendance environment could potentially introduce additional security risks to the organisation and therefore appropriately - and successfully - embarked on a campaign to gain authority to manage their own security risks and access controls from the centralised management system. 

During the document review it was noted that thresholds for seeking ARPANSA’s prior-approval (such as those under section 63 of the Regulations) could be more clearly documented in ANU’s plans and arrangements. 

Training

ANU RSPhys maintain a central database of training requirements which largely covers expected tasks to be performed within particular laboratories. This database was sighted during the inspection. Associated with the training matrices is a centralised risk register. The inspectors were satisfied with the training arrangements. However, it was agreed that the access control arrangements could be enhanced by being integrated with demonstrated training records for staff and students within a particular laboratory.

Event protection

ANU RSPhys considers itself the highest-risk facility at ANU due to the vast range of chemical and radiological hazards and the heavy plant equipment and industrial nature of the precinct environs. 

A central register of risk is maintained; these assessments were also reviewed during the pandemic so that as staff and students return to school all risks and training requirements can be verified and performed from the outset. This undertaking was a significant challenge during the pandemic but nevertheless was an example of resourcefulness and resilience being applied and an example of good practice.

The RSPhys radiation waste store was also inspected. Considerations for fire, flood and other external events have been taken into account. The racking for this store was well above ground to prevent water inundation and no significant volume of combustible materials were located inside. Fire protection and contamination control systems were also evident.  ANU RSPhys also makes use of the Chemwatch application which allows ANU and any emergency services full knowledge of dangerous goods and their locations at any given time and during emergencies.

Security

The ANU RSPhys waste store security plan and arrangements were considered to be appropriate and meet the requirements of a Security Category 2 store in accordance with the ARPANSA RPS-11 Code of Practice for the Security of Radioactive Sources. 

Radiation protection

ANU’s Radiation Safety Advisory Group reports directly to the WHS Committee Meeting each quarter. Here matters such as existing or new work to be carried out are reviewed and considered for implementation. Any new or modified tasks require a revised risk assessment to be performed. The risk assessments cited during the inspection covered inherent and residual risks and considered relevant exposure pathways. Risk treatments were often layered and did not only consider engineering or PPE measures but also administrative arrangements, training and optimisation principles.

During the inspection detailed records of sealed source wipe testing and contamination monitoring surveys were promptly presented when requested. However, it was agreed that ANU would benefit from more clearly specifying the frequency for such testing in their plans and arrangements to match what is done in practice.

Emergency preparedness & response

ANU RSPhys maintains a central emergency response plan, adequate personal protective equipment, radiation monitoring equipment, and other emergency equipment such as spill kits etc. At the time of the inspection it was not verified how frequently emergency exercises and drills are conducted and this is expected to be the focus of future inspections. Emergency equipment was also sighted at the main RSPhys source store and all appeared to be in good working order. Nevertheless, it was agreed that ANU RSPhys would benefit from routinely hosting site familiarisation activities with the local emergency services such as law enforcement and fire brigade as these would help to achieve greater situational awareness for responding agencies.

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. Thresholds for when to seek approval under section 63 should be clearer in ANU’s plans and arrangements.
2. Access control arrangements should be integrated into training records of staff and students for particular laboratories.
3. ANU should clearly document the frequency of contamination monitoring surveys and sealed source wipe testing measurement to match what is done in practice.
4. ANU should routinely host site familiarisation activities with local emergency services personnel.

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