Inspection report: National Gallery of Australia (NGA), Parkes ACT, 31 July 2024

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 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 at the Parkes, ACT, premises against the Source Performance Objectives and Criteria (SPOC). The inspection consisted of a review of records, interviews, and a physical inspection of sources.

Background

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: 

• Code for Radiation Protection in Planned Exposure Situations (2020) (RPS C-1 (Rev. 1)) 
• Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006) (RPS 12)
• Code of Radiation Protection Requirements for Industrial Radiography (2018) (RPS C-4)
• Australian/New Zealand Standard Safety in Laboratories Part 4: Ionizing Radiations (2018) (AS/NZS 2243.4:2018)
• Australian Standard Safety in Laboratories Part 5: Non-ionizing radiations – Electromagnetic, sound and ultrasound (2024) (AS 2243.5:2024).

Observations

In general, the management of radiation safety at NGA in relation to controlled apparatus was found to be sound.

Effective control

Management commitment

NGA has demonstrated a commitment to radiation protection by establishing Plans and Arrangements (P&As), to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions at its Parkes premises. In essence the P&As comprise 3 main documents: 

• NGA Risk Management Procedures (version GOV2.0) – revised January 2024
• NGA Conservation Department Radiation Protection Plan - Niton Portable XRF (version 1.3) (RPP) - revised May 2024
• NGA Using Andrex X-Ray Machine (SWP (CON) 94) – revised April 2024.

During discussion, it was considered that there was area for improvement by making the RPP a more comprehensive overview of the requirements for the safe use of all controlled apparatus (e.g. radiation monitoring, training, disposal, storage, reporting, record keeping, etc.) at the NGA, and uncontrolled apparatus such as the UVA lamps operating with wavelengths in the region 350-400nm (which are exempt sources under the Regulations - section 44 Exempt dealings, item 7(k)).

Statutory & regulatory compliance

The P&As and subsidiary documents have been written to ensure compliance with the Act, the Regulations and the conditions of licence S0024. The P&As were found to have been reviewed within the timeframe required in section 61 of the Regulations.

Communication

The NGA’s Radiation Safety Officer (RSO) 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

Safety management for the licence is outlined in the P&As and subsidiary documents and includes topics such as: 

• general radiation information
• training of relevant staff 
• PPE and personal monitoring 
• transport
• maintenance and equipment failure
• emergency procedures and incident reporting
• disposal. 

All controlled apparatus inspected matched the details listed in the Source Inventory Workbook (SIW). There were some minor discrepancies in the details of the UVA apparatus listed in the SIW, however these are exempt sources under the Regulations.

Training and education

All personnel who operate the portable (handheld) X-ray unit are required to undertake training relevant to the equipment’s use before being permitted to use it. The training records were found to be in order.

It was found that the current RSO had yet to undertake radiation safety training in the use of the industrial radiography X-ray unit, however the unit has not been used since the resignation of the previous RSO. Evidence was provided that the RSO is scheduled to undertake the training from 19 to 23 August 2024.

Record keeping

All records pertaining to the controlled apparatus including licences, dose assessments, training records, reports and similar were kept; however there were some difficulties in finding items, particularly older information. It is noted that the RSO is currently in the process of maintaining the training register within the NGA’s records management system and improving overall records management.

Radiation protection

The fully enclosed X-ray exposure room is located within 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 signage includes constraints in terms of the maximum kV and tube current to be used. An audible signal is available for deployment while operating the industrial radiography X-ray unit. 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 is 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.

It was noted that the radiation survey meter had passed its calibration date for determining dose rates (annual calibration required). The X-ray unit had not been used since the resignation of the previous RSO and will not be used until the current RSO completes the required radiation safety training course. Therefore, there has been no immediate need to use the survey meter. The meter will need to be calibrated prior to use of the X-ray unit where its use is required to confirm associated dose rates. This is identified as an area for improvement.

Radioactive Waste 

No radioactive waste is generated during any procedure.

Security 

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 only does not invoke the requirements of the Code of Practice for the Security of Radioactive Sources (2019) (RPS 11). Existing security measures were therefore considered appropriate.

Emergency plans 

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.

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: 

• The RPP should more comprehensively cover the safe use of all controlled apparatus (X-ray units) and uncontrolled apparatus (such as the UVA lamps) in use at the NGA.
• The survey meter is to be calibrated prior to use of the industrial radiography X-ray unit, where use of the survey meter is required to confirm associated dose rates.