| Inspection report | |
|---|---|
| Licence holder | CSIRO Land and Water |
| Location inspected | Black Mountain Site |
| Licence number | S0009 |
| Date/s of inspection | 21 - 21 June 2023 |
| Report no: | R23/05007 |
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 S0009.
The scope of the inspection included an assessment of performance at Black Mountain against the Source Performance Objectives and Criteria (SPOC). The inspection consisted of a review of records, interviews, and physical inspection of CLW sources at the site.
Background
CLW uses and stores controlled material and controlled apparatus at the CSIRO Black Mountain site to assist its research into various projects involving economic, social and environmental issues related to water, land, cities and ecosystems. In achieving these goals, CSIRO deals with sealed and unsealed radioactive sources, X-ray analysis equipment, UV apparatus and lasers as research tools.
CLW is authorised under section 33 of the Act to deal with controlled apparatus and controlled material.
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 (Rev.1) 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. 12 Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006) (RPS12)
- Australian/New Zealand Standard Safety in Laboratories Part 4: Ionizing radiations (AS/NZS 2243.4:2018)
- Australian/New Zealand Standard Safety in Laboratories Part 5: Non-ionizing radiations –Electromagnetic, sound and ultrasound (AS/NZS 2243.5:2004)
Observations
In general, the management of radiation safety at the CLW Black Mountain site in relation to controlled material and controlled apparatus was found to be sound.
Effective control
Management commitment
CSIRO has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective use, storage and disposal of radiation sources across all of its Business Units (BUs). This is supported by a comprehensive radiation protection plan (RPP) from which each BU extracts the relevant information for the controlled apparatus and controlled material dealings for that the given BU. These RPPs are in turn, supported by subordinate location or work specific documents called safe work instructions. Access to this information is available to all relevant staff via QR codes attached to or immediately adjacent to the particular source.
Statutory and regulatory compliance
The overall RPP, CSIRO’s Plans and Arrangements, are written to ensure compliance with the Act, the Regulations and the conditions of the licences for each BU, including S0009.
Communication
The CLW Radiation Safety Officer (RSO (or BURSO)) coordinates information for quarterly reports combining that from each CLW site. Once collected, this information is consolidated into a single final report to ARPANSA. CLW 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
Although the inventory of sources for CLW at the Black Mountain site is significant, all controlled material is in storage awaiting ultimate disposal. While this store is ultimately overseen by the CSIRO Chief RSO, the RSO of each BU, including CLW, has a duty of care for the safe storage of the sources within the store through maintaining their own sources on their respective inventories.
CLW uses some ultraviolet radiation apparatus at the Black Mountain site. Of those seen during the inspection, all matched the internal designations assigned to those sources and listed in the source inventory workbook (SIW). It was noted however that the model designation of these apparatus did not appear in the SIW although the information in the CSIRO database did include the model designation. This lack of complete data in the SIW is considered an area for improvement.
Training and education
All CLW personnel using the controlled apparatus at the Black Mountain site are required to undertake relevant training. Training records are kept electronically and ARPANSA inspectors observed these records for several individuals authorised to use the controlled apparatus at the Black Mountain site.
Access to laboratory areas is restricted to personnel who have undergone appropriate training.
Access to the radiation store is strictly limited to only personnel who have entry privileges under the authority of the CSIRO Chief RSO.
Radiation protection
All CLW controlled apparatus in use at the Black Mountain site were considered to meet the relevant requirements of both RPS12 and AS/NZS 2243.5.
Radioactive waste including ultimate disposal or transfer
The radiation store contains many disused sealed and unsealed radioactive sources from six separate BUs, including CLW, which are intended for ultimate disposal once a suitable national disposal site is identified and commissioned. Some of these sources have now decayed to levels below that required for licensing under the Regulations based on their original activities and acquisition dates.
All storage is in large, well-labelled containers and the SIW of each relevant BU, including CLW, itemises all sealed sources within the store. Dose rates outside the store did not exceed the requirements of AS/NZS 2243.4 and were found to be not significantly above the background radiation dose rate.
Security
Access to all CSIRO buildings at the Black Mountain site beyond the public areas is protected by an electronic access control system. The aggregation of all sources under CSIRO control at the site, including those in the store, do not invoke enhanced security requirements. The existing security measures were therefore considered appropriate.
Emergency plans
Emergency preparedness and response are handled under the broader CSIRO policy and work health and safety plans and were not assessed during the inspection.
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 area for improvement:
- The model designation of each controlled apparatus needs to be included in the SIW.
It is expected that improvement actions will be taken in a timely manner.
