Inspection report: Australian National University, Research School of Physics, College of Arts and Social Sciences and College of Asia Pacific, School of History and Language, R24/02402

This inspection was conducted as part of ARPANSA’s source inspection program to assess compliance with the Australian Radiation Protection and Nuclear Safety Act 1998, the Australian Radiation Protection and Nuclear Safety Regulations 2018, and conditions of source licence S0027. The scope of the inspection included an assessment of performance at the ANU Acton premises in RSPhys and CASS against the Source Performance Objectives and Criteria (SPOC). The inspection consisted of a review of records, interviews, and a physical inspection of sources.

Background

ANU is a research-intensive university located in Acton, Australian Capital Territory (ACT), and specialises in a range of activities that require the use of radioactive materials and ionising and non-ionising radiation apparatus. The ANU source licence covers several schools at the Acton campus and one at Mt Stromlo, ACT, many of which use controlled apparatus and controlled materials as part of their research and teaching roles. ANU is licensed under Section 33 of the Act to deal with controlled material and controlled apparatus for research purposes in its various schools.

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) (RHS11)
• RPS C-2 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. 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)
• Radiation Protection Series No. 12 Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006) (RPS12)
• Australian/New Zealand Standard Safety in Laboratories – Non-ionizing radiations-Electromagnetic, sound and ultrasound (2004) (AS 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 60825-14:2022)

Observations

In general, the management of radiation safety at both RSPhys and CASS in relation to controlled material and controlled apparatus was found to be sound. There appeared, however, to be areas where there was room for improvement as follows: 

• Documentation relating to disposal of radiation sources used the word ‘class’ instead of ‘group’ as per regulatory items. The former could cause confusion given that ‘class’ is used for the designation of laser apparatus. 
• A combined contamination and dose rate monitor was out of calibration for dose rate measurements. The monitor was only used for detecting radiation (for which it was in calibration) although there was no indication on the monitor that it cannot be used for dose rate measurements. This same issue was identified during the inspection of the Research School of Biology in May 2023 and could suggest an underlying problem with the system of monitor calibration at ANU. 
• Laser warning labels were not clearly visible or damaged on some laser apparatus. 

The Safe Work Instructions for some lasers were only available on-line. An attempt to access these during the inspection took quite some time (~5 minutes) and were therefore not considered to be readily available. 

• The controller for at least one laser was greater than 2 metres from the aperture without additional warning as required in AS/NZS IEC 60825-1:2014. A laser awaiting commissioning in RSPhys only had warning labels written in German. These would need to be either replaced or added to with labelling in English to match the requirements of AS/NZS IEC 60825-1:2014. 

A laser in storage in CASS had warning labels that were difficult to see. It is acknowledged that this might have been due to its location within the storage room, but the clarity of the labels would need to be checked once the apparatus was returned to service.

Effective control

Management commitment

ANU has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective use, storage and disposal of radiation sources throughout all schools at the university. This is supported by a comprehensive Radiation Management Plan (RMP), ANU’s Plans and Arrangements, to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions. It should be noted that a comprehensive regulatory review of the ANU RMP was conducted during the December 2022 inspection. This current inspection therefore concentrated on the ‘local’ RMP of RSPhys, the RSPhys Radiation Management Plan (RRMP), and the relevant areas of the ANU RMP for CASS. 

ANU has a Radiation Safety Advisory Group (RSAG) that meets quarterly and comprises representation from all schools including RSPhys and CASS. The ANU Work Health and Safety Consultant, as a member of RSAG, coordinates information for quarterly reports through Safety and Wellbeing with input from each school, including RSPhys and CASS. Once collected, this information is consolidated into one final report to ARPANSA. ANU quarterly reports have been submitted to ARPANSA in a timely manner in recent years, and contained relevant information, including details of compliance with the Act and Regulations.

Statutory and regulatory compliance

The RRMP has been written to ensure compliance with the Act, the Regulations and the conditions of licence S0027. 

Communication

Radiation safety matters for both RSPhys and CASS are reported according to their local WHS plans. The reporting line provides for communication to the relevant Heads of Departments, WHS committee meetings and the ANU RSAG. Example agendas and minutes of WHS meetings were sighted during the inspection.

Safety management

ANU requires safe operating procedures be located in all laboratories where radiation is used, including RSPhys and CASS. Examples of these requirements covering the processes for developing risk assessments, and the review and approvals required for all projects involving controlled materials or apparatus were viewed during the inspection. Many of these are on-line although in one instance, it took several minutes to access the document. 

The RRMP outlines the training requirements, safe working procedures and accident/emergency response requirements relating to the use of radiation within the school.

Training and education

All personnel using controlled apparatus or controlled material at ANU are required to undertake training related to the source they will use. This training includes: 

1. Tier 1: general induction 
2. Tier 2: school induction
3. Tier 3: individual laboratory induction and specific use training, the extent of which depends on the proposed dealing for the given individual. 

Access to laboratory areas is restricted to those personnel who have undergone appropriate induction training or are otherwise closely escorted by appropriately trained staff. Only CASS personnel with the appropriate training are permitted to operate the hand-held X-ray analysis equipment. 

Training records are kept in physical form and electronically. The ARPANSA inspectors verified these records for several individuals authorised to use the controlled apparatus and controlled materials as having completed the training for both RSPhys and CASS personnel. 

RSPhys had implemented a system for all relevant personnel to undergo refresher training at 5-yearly intervals. Ninety days before the refresher training is due and periodically thereafter, reminder e-mails are sent out those staff that they need to complete the refresher training before the required date. Failure to do so results in that person being refused electronic access (the ANU Cardax and Salto systems) to the related laboratory thus providing incentive for the staff member to complete the refresher training. This system had some manual intervention at the time of inspection but was expected to be fully automated in the near future. This is considered to be a good practice.

Radiation protection

Exposure meters are calibrated annually, and contamination monitors are calibrated every 5 years in accordance with current regulatory requirements. Calibration certificates for several survey meters were sighted during the inspection. One monitor in the accelerator control room was capable of monitoring both dose rate and the presence of radiation. While the monitor was out of calibration for dose rate, it was still within calibration for contamination checking. This monitor was not used for dose rate measurement however, there was no indication on it that it should not be used for that purpose.

Personal protective equipment (PPE)

The inspectors observed the PPE identified in the RRMP such as masks, gloves, handling tools, lead aprons during the inspection. 

Appropriate laser protective eyewear was available to RSPhys and CASS staff and students in laser laboratories.

Monitoring of the individuals

Personal radiation monitors are used for work with ionising radiation, and personal exposure records are kept in the central record system. Staff and students can request to view their exposure records but are notified if exposures are above limits or different from the usual pattern of exposure for their work.

Radioactive waste

Access to the RSPhys radiation store in the accelerator building was limited to relevant staff and the storage area/cage was locked with a combination lock independent of the Cardax system. Usage logbooks were located inside the storage area and appeared to be kept up to date. Dose rates around the storage safes inside the storage area did not exceed the requirements of AS/NZS 2243.4.

Security

Access to RSPhys and CASS buildings is protected by the Cardax system only available to those who have completed the appropriate training. The aggregation of all sources under RSPhys control does not invoke enhanced security requirements and the existing security measures are therefore considered appropriate.

Emergency plans

The ANU has an overarching emergency plan, and each school has their own plan based on the risks at that location.

Findings

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: 

• Potentially confusing wording in the documentation relating to disposal of controlled sources. Dual reading survey meter/contamination monitor out of calibration for dose rate
• Laser warning labels not clearly visible or damaged
• Some safe work instructions not easily accessible
• Laser warning labelling inconsistent with the configuration of the aperture and the controller. 

The inspection revealed the following good practice: 

• Refresher training requirements in RSPhys are linked to the Cardax and Salto systems with reminders sent to relevant staff 90 days beforehand and laboratory access revoked if training not completed by the due date. 

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