Inspection report: Geosciences Australia, Symonston ACT, R24/00390

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 S0014. 

The scope of the inspection included an assessment of Geoscience Australia’s performance at Symonston against the Source Performance Objectives and Criteria. The inspection consisted of a review of records, interviews, and physical inspection of sources. 

Background 

Geoscience Australia (GA) is authorised under section 33 of the Act to deal with a range of controlled material and controlled apparatus. These largely include unsealed sources in the form of natural uranium and thorium samples, and a range of x-ray analytical devices that are used to analyse geological specimens. 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) AS/NZS 2243.4:2018 Safety in Laboratories Ionising Radiation 
• Australian/New Zealand Standard: Safety of laser products Part 1: Equipment classification and requirements (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) 
• Radiation Health Series 9: Code of Practice for Protection Against Ionising Radiation Emitted from X-Ray analysis equipment (1984) 

Observations

In general, the management of safety and security at GA was found to be satisfactory. In some cases, however, a number of areas for improvement (6) were identified including: training renewals for Radiation Safety Officers (RSOs), updating calibration of instruments, inventory survey and formalising regular inspections of the isotope store, conduct a survey of the High-Pressure Store/workshop due to potential Radon leakage into the area, updating of the Source Inventory Workbook (SIW) – addition of Olympus XRD and clarity of GA’s quarterly report submissions. 

One (1) non-compliance was identified in relation to the current Radiation Management Plan (RMP) notably the review period required under s61(1) of the Regulations for Plans & Arrangements (P&As) had not been met. 

At the time of the inspection some discrepancies within the P&As including the reference to equipment already disposed of were also identified. 

Effective control 

Accountabilities & Responsibilities 

GA’s organisational and radiation safety structure resides under the control of the Radiation Safety Officer and Deputy Radiation Safety Officer (RSO-DRSO) with the licence nominee being CEO Geoscience Australia. 

The RSO is the nominated responsible officer and in conjunction with the DRSO, manages GA’s Radiation Management Plan (RMP), is the regulatory point of contact and is responsible for implementation, training, and distribution of current controlled apparatus under the S0014 licence. 

GA’s Manager Technical Safety (MTS) has also been tasked to work with the radiation team with a view to strengthening and improving safety processes and procedures. 

Risk assessment & mitigation 

GA maintains dedicated standard operating procedures (SOPs) and risk assessments for the use of controlled apparatus and specific operating environments such as out-door field work, laboratory work or work conducted in the labs and isotope stores. The risk assessments provided to inspectors highlighted inherent hazards, controls, and an analysis of the effectiveness of those controls against the risk tolerance of GA’s existing risk management processes. Further to the provided risk assessments, the GA team (RSO, DRSO & MTS) briefed the inspection team on initiatives currently underway to update and align GA’s Risk and WHS management practices and protocols. This initiative has CEO ‘buy-in’, approval and will occur across the organisation including management and controls across GA’s radiation inventory. 

Performance reporting verification 

The document history table of GA’s RMP submitted for the inspection noted last document review as 23 October 2020 with no further entry contrary to their stated annual review requirement. 

GA’s RMP at 1.2 notes that: ‘The RSO shall review this RMP on an annual basis or more often as required by changes to workplace activities. Changes may also be initiated by the Radiation Safety Officer, WH&S management, in response to changes in legislative requirements or licence conditions.’ 

On discussing this subject, Inspectors also reminded the GA team of s61(1) of the Regulations and the requirement to review plans and arrangements, ‘…at least once every 3 years.’ 

GA has consistently provided timely quarterly reports to ARPANSA and Inspectors advised the GA team that a review of their submitted quarterly reports had been conducted as far back as 2020. Question 10 of the reporting template specifically asks, ‘were plans and arrangements reviewed?’ GA’s response to question 10 going back to 2020 stated that ‘Nil review of plans and arrangements (the RMP) had occurred’. 

Inspectors discussed this with the GA team who agreed that the quarterly reporting questions should have prompted GA to conduct the review and update the RMP potentially avoiding a non-compliance finding. Reviewing the document within GA’s annual review requirement and/or at the time of disposal of the Multi Sensor Core Logger (MSCL) may have also identified other issues such as continued reference to the disposed controlled apparatus and RSO training requirements not being met at an earlier stage. 

Safety management 

Following the disposal of the MSCL, GA’s inventory consists primarily of portable X-ray analysis-controlled apparatus (XRD and XRF) as well as those isotopes in storage. Observations of the inspected portable apparatus showed all equipment in good condition with appropriate PPE (Laser Safety Glasses etc) and signage. Equipment work instructions were all stored on accompanying laptops that are allocated to the apparatus by the RSO. Re-familiarisation of the controlled apparatus as well as the pre-loaded work instructions on the accompanying laptops is provided by the RSO to the requesting GA staff member at the time of issuance of the equipment pre-deployment.

GA is licensed for Group 1-13 controlled apparatus. During the inspection, one (1) new/recently acquired Olympus XRD was found to not be on GA’s Source Inventory Workbook (SIW). This was raised with the GA team who have assured this will be updated during the next quarterly report. 

Calibration of survey monitors

During the inspection of the controlled apparatus, a handheld survey monitor was produced showing calibration was due February 2021. The GA RMP Section 12.1 Calibration notes: ‘Handheld radiation contamination, survey monitors and EPDs must undergo periodic calibration. The RSO will coordinate the ‘annual’ calibration of meters.’ The GA Radiation team agreed to rectify this in a timely manner.

Training & education 

Staff involved with managing the GA controlled material and controlled apparatus are trained in both the ANSTO General Radiation Safety Officer and the Advanced Radiation Safety Officer Course. Specific training is also provided for dedicated equipment such as the hand-held portable XRF apparatus. 

The RSO or the DRSO control allocation of portable controlled apparatus and are responsible for training staff members on the allocated apparatus. Allocation and training records were sighted as confirmation.

GA’s RMP Chapter 6 notes that ‘RSOs must undergo appropriate training with renewals of certificates every five (5) years.’ Training records provided noted both the RSO and deputy’s last ANSTO RSO course was completed in June 2018. 

The GA team agreed that this was over the 5-year stipulated requirement and will ensure both team members will be booked into ANSTO training as soon as possible. 

Radiation protection isotope store 

Safety & Security 

GA maintains a dedicated isotope store external to the main building adjacent to GA’s stores and loading dock area. An Area for Improvement (AFI) from the 2020 inspection identified that ’GA should review their inventory in the isotope store and more accurately characterise their holdings.’ This is a large and ongoing task and will take some time to fully address and will remain an outstanding AFI. 

The isotope store is a segmented area of the general utilities facility which also houses diesel generators, HAZCHEM storage and the High-Pressure (HP) workshop testing area. 

Principles of radiological protection 

For entry into the isotope store, the Standard Operating Procedure (SOP) is to open and vent the store of potential radon gas prior to entry. It was noted during the inspection that the wall between the HP workshop and the isotope store is not completely sealed floor to ceiling. This may allow radon gas transfer between the isotope store and the HP workshop.

Confirmation of a similar ventilation procedure when accessing the HP workshop could not be confirmed by the GA team. It was agreed that a similar procedure should be instigated to ensure radon buildup is vented prior to entry to the HP workshop. 

Storage of HAZCHEM in close proximity to the isotope store was also questioned. The GA team agreed to assess the risks of storage requirements - both HAZCHEM and isotopes - within the combined external storage/HP workshop/services building.

Findings

The inspection revealed the following non-compliance: 

GA’s RMP had not been reviewed annually in accordance with their own plan requirements for the previous 3 years. At the time of the inspection, it was found that that a review of plans and arrangements in accordance with s61(1) of the Regulations had not been commenced contravening the Regulations. 

The inspection revealed the following areas for improvement: 

• Address RSO and Deputy RSO training requirements in accordance with the RMP.
• Calibration of radiation detection instruments. 
• Survey of inventory isotope store.
• Formalise regular inspection of isotope store. 
• Radon survey and formal entry procedure for High Pressure workshop
• Update GA’s SIW with new XRD controlled apparatus. 

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