Inspection report: Department of Climate Change, Energy, the Environment and Water - Office of the Supervising Scientist, S0015

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 S0015. The scope of the inspection included an assessment of performance at Eaton against the Source Performance Objectives and Criteria (SPOC). The inspection consisted of a review of records, interviews, and physical inspection of sources.

Background

The Office of the Supervising Scientist (OSS) within the Department of Climate Change, Energy, the Environment and Water undertakes research and environmental monitoring in order to protect the environment from the effects of uranium mining in the Alligator Rivers Region of the Northern Territory. It also conducts assessments and audits of uranium mining activities. 

The OSS is licensed to deal with sealed and unsealed sources, irradiating apparatus and optical sources under section 33 of the Act. 

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 Code for the Safety Transport of Radioactive Material (2019) • RPS C-6 Code for Disposal of Radioactive Waste by the User (2018) 
• RPS 12: Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006) 
• Australian/New Zealand Standard: Safety in laboratories Part 4: Ionizing radiations (AS/NZS 2243.4:2018) 
• Australian Standard: Safety in laboratories – Part 5: Non-ionizing radiations - Electromagnetic, sound and ultrasound (AS 2243.5:2024)

Observations

In general, the management of radiation safety at the Eaton premises of the OSS in relation to controlled material and controlled apparatus was found to be satisfactory. There appeared, however, to be some areas for improvement (AFIs) as identified in the report. During the inspection, the OSS Radiation Safety Officer (RSO) self-reported a potential non-compliance with Section 31(1)(a) of the Act in relation to two ultraviolet radiation apparatus that were not individually listed on the source inventory workbook (SIW). Their presence in the laboratories was, however, noted in the SIW in the comments section for a similar piece of equipment. 

Effective control

Management commitment and Statutory & regulatory compliance

OSS has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective use, storage and disposal of radiation sources at its Eaton site. This is supported by a comprehensive Radiation Source Control Plan (RSCP), which constitutes the OSS Plans and Arrangements for this licence, to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions. OSS 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. Further to the self-reported potential non-compliance described above, the following areas for improvement (AFIs) relating to the RSCP were identified during the inspection: 

• No formal records of training for employees working with radiation sources were kept (para 4.1.5). 
• No formal records of authorised employees for the purpose of accessing or dealing with radiation sources were kept (para 4.5.2). 
• No records of radiation source audits were kept, potentially resulting in the non-compliance identified above (para 4.1.8 dot point 10, para 4.5.3 and para 5.2 dot point 13). 
• Outdated references to the previous RSO and deputy RSO were still included in the document (Appendix A).

Documentation and document control

The RSCP had been reviewed at least once every 3 years with the last review, version 20, being signed off on 8 August 2021. The next review of the document, version 21, was in process and expected to be finalised by the due date of 8 August 2024. A summary of changes dating back to version 13 (18 December 2012) was available as the ‘document history’ on the front cover of the RSCP.

Safety management

Monitoring and measurement

The results of wipe tests of in-use sealed sources were seen during the inspection. The board holding personal radiation monitoring badges for employees routinely working with radiation along with the control badge was seen during the walkthrough of the laboratory area. Both the survey meter and the monitor used to detect the presence of radiation had been calibrated on 22 January 2024.

Training and education

Records of basic radiation safety induction training for all new employees were seen during the inspection.

Radiation protection

Radiation safety officer/radiation safety committee

The RSO and the licence nominee were in constant discussion during normal work activities at the laboratory and any matter relating to radiation would be discussed at the relevant time or by e-mail where necessary. This was considered to negate the need for a formal Radiation Safety Committee.

Planning and design of the workplace

The laboratory for sample preparation (L.25) was immediately across an external walkway from the locked and labelled radiation store. Only sources necessary for a sample preparation would be removed from the store and immediately returned once the procedure had been completed. The store was located at the edge of a car park inside a locked compound. The dose rates around the store did not differ significantly from the background dose rate. 

Several AFIs were identified in the main laboratory area as follows: 

• The serial numbers for several controlled apparatus (ultraviolet sources) were not included in the SIW 
• There was no ultraviolet radiation warning sign on the entry door to laboratory L.15 
• The source preparation laboratory, L.25, did not meet all requirements of AS/NZS2243.4 for a low-level laboratory as follows: 
  • The entrance to the laboratory did not contain all personal protective equipment. For example, disposable gloves were located on the opposite side of the laboratory to the entry door. 
  • Records of stocks used were not maintained 
  • Working plans were not displayed in the laboratory 
  • There was no contamination monitoring equipment near the exit

Monitoring of the workplace

Records of 6-monthly surface contamination monitoring in the source laboratory in accordance with para 4.2.4 of the RSCP were provided.

Radioactive waste

Management of radioactive waste and ultimate disposal or transfer 

Minimal radioactive waste was generated during laboratory procedures and all controlled material was stored in the radiation store. Contingencies for radioactive waste management was covered in section 4.3 of the RSCP. Any waste that does not meet the criteria specified in RPS C-6 for disposal into landfill or the sewer would be placed in interim storage in the source store.

Security 

Security procedures

There were no sources at the site that would invoke the requirements of RPS 11. Only authorised and inducted personnel had access to the laboratories and access to the store was limited to the RSO and other relevant staff.

Emergency plans

Emergency plans and procedures

Emergency plans and procedures applied to the entire site and included disasters such as fire and cyclones. In any such disaster, the RSO was the first point of contact for advice.

Findings

The inspection revealed the following self-reported potential non-compliance: 

• Not all controlled apparatus were individually listed in the source inventory workbook. 

The inspection revealed the following areas for improvement: 

• No formal records of training for employees working with radiation sources were kept. 
• No formal records of authorised employees for the purpose of accessing or dealing with radiation sources were kept. 
• No records of radiation source audits were kept, potentially resulting in the non-compliance identified above. 
• Outdated references to the previous RSO and deputy RSO were still included in the document. 
• The serial numbers for several controlled apparatus (ultraviolet sources) were not included in the SIW 
• There was no ultraviolet radiation warning sign on the entry door to laboratory L.15 
• The source preparation laboratory, L.25, did not meet all requirements of AS/NZS2243.4 for a low-level laboratory. 

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