Inspection report: National Archives of Australia (R20/09268)

An inspection was conducted as part of ARPANSA’s baseline 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 S0273.

The scope of the inspection included an assessment of National Archives of Australia’s performance at the Mitchell site against the Source Performance Objectives and Criteria (POCs). The inspection consisted of a review of records, interviews, and physical inspection of the source.

Background

The National Archives of Australia (NAA) is authorised under section 33 of the Act to deal with a partially enclosed X-ray fluorescence (XRF) apparatus.

The controlled apparatus is used in support of the archives conservation practices for valuable documents and historic artefacts.

The main codes and standards applicable to this apparatus are those that appear in section 59 of the Regulations and:

• RHS-9: Code of Practice for the Protection against Ionising Radiation Emitted from X-ray Analysis Equipment (1984).
• AS/NZS 2243.4 Safety in laboratories Part 4: Ionizing radiations (2018)

Observations

NAA advised that the controlled apparatus had not been used for some time and this was confirmed during the inspection from their usage records. The apparatus was securely stored within the NAA premises. Correspondence between the NAA and ARPANSA had occurred prior to this inspection regarding the possibility of disposal or transfer.

A number of issues were identified during the documentation review. After physically inspecting the apparatus and the storage area, the inspection team decided to cease the inspection due to the deficiencies noted in this report and seek a way forward with NAA management for expedited disposal of the apparatus.

Configuration management

The NAA deals with controlled apparatus under Source Licence S0273 with offices in Mitchell (ACT) and Chester Hill in Sydney.

NAA had sought to dispose of the unit on a number of occasions prior to the inspection. Discussions with current and former NAA section managers noted difficulties with NAA’s internal processes that impeded a more simplified disposal pathway.

Performance reporting verification

NAA’s reporting obligations are conducted in accordance with their licence requirements in a timely manner. Whilst the apparatus is accurately noted on the NAA’s source inventory workbook, usage records confirmed that it has not been used since 30 November 2017.

The NAA’s current plans and arrangements were out of date and had not been updated since 2016. ARPANSA Regulatory Guide – Plans and Arrangements for Managing Safety – Section 3.1 requires that a Radiation Safety Officer (RSO) be appointed if: “The dealing involves Group 2, Group 3 or hazardous non-ionising radiation sources”. The NAA no longer have a trained and designated RSO who would be in a position to produce updated plans and arrangements. A letter dated 20 May 2019 from ARPANSA to NAA recognised NAA’s situation and outlined the options for transfer or disposal of the apparatus and appropriate administrative controls for its effective security until a disposal pathway could be confirmed.

Training

As noted above, the NAA has not had a formal RSO in position since 2019. General radiation safety training on the apparatus for staff has not occurred since July 2010. Prior discussion between the NAA and the ARPANSA Chief Regulatory Officer in May 2019 noted that the NAA no longer wished to maintain training for current staff and whilst the controlled apparatus was in their possession, it was not used and remained securely stored pending disposal in accordance with the NAA’s procurement procedures.

Security

The Mitchell facility has a manned security desk with appropriate access control. Access to the laboratory where the unit is stored was open and without observable access control and no radiation warning signage was observed on the doors to the laboratory.

Findings

It was considered that NAA was unlikely to be able to continue to comply with the Act and Regulations due to the NAA’s inability to maintain updated plans and arrangements, offer secure and appropriately signed storage and formally advising ARPANSA they would no longer train staff in the safe and proper handling of the apparatus. Noting the above, ARPANSA issued an improvement notice to remedy the situation with the expectation that improvement actions will be taken in a timely manner.