Inspection report: CSIRO Business Infrastructure Services (CBIS), Woomera Prohibited Area (WPA), South Australia, 10 November 2020

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 S0013.

The scope of the inspection included an assessment of CBIS’s performance at the WPA site against the Source Performance Objectives and Criteria (POCs). The inspection consisted of a review of records, interviews, and physical inspection of the inventory and supporting equipment.

Background

CSIRO holds approximately 10,000 steel and galvanised drums containing low level radioactive waste in the form of contaminated soils and building materials. This waste is stored within a large hangar that exists on Defence controlled land awaiting final disposal.
CSIRO is authorised under section 33 of the Act to deal with this contaminated material.

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

• Australian New Zealand Standard: Safety in Laboratories Part 4: Ionising Radiations (AS/NZS 2243.4:2018)
• Radiation Protection Series C-6: Code for Disposal of Radioactive Waste by the User (2018)

Observations

In general, the management of safety and security at the waste store was found to be strong. In some cases, however, there appeared to be room for improvement with respect to improving the ergonomics of donning and doffing personal protective equipment and establishing thresholds based on the meteorological conditions for safe work practices to commence or otherwise be cancelled. Other areas which require improvement included developing clearer guidance on which instances or occurrences require reporting to ARPANSA and the development and delivery of baseline awareness training for non-technical radiation workers.

Performance reporting verification

CBIS has continued to provide ARPANSA with quarterly reports in a timely manner. Each report contains relevant information regarding CBIS’s compliance with the Act and Regulations. CBIS representatives also participate regularly in CSIRO-ARPANSA Liaison Forum meetings and share their planned activities to discuss regulatory requirements in advance. The inspectors were satisfied with CBIS’s performance reporting and verification activities.

Configuration management

The WPA waste store is configured in a contain, monitor and sustain mode such that all materials within the store remain inactive and are not utilised as they are awaiting final disposal. While CSIRO is planning on more accurately analysing the contents of the legacy drums in the future, the current configuration is not expected to change without regulatory approval from ARPANSA. CSIRO has engaged a private contractor to periodically conduct maintenance on elements of the waste store in order to ensure the integrity of the building. The waste store is equipped with a range of spill equipment, wash stations, PPE and contamination monitoring equipment. However, it was observed that the arrangements for donning and doffing of PPE could be improved from an ergonomics perspective.

Training

The CBIS RSO and CSIRO Chief RSO have conducted relevant advanced radiation safety officer training and have many years of experience dealing with and managing radioactive materials and non-ionising radiation in many forms. On occasion it was noted that personnel without a strong radiation safety background attend the waste store to perform a range of tasks and activities. While these personnel are provided with a comprehensive daily safety and security briefing including a detailed induction package prior to arrival on site, it was agreed that a baseline awareness training package could be provided which is a practice that CSIRO already conducts for other business units.

Event protection

A range of credible event protection measures have been considered by CBIS and implemented in their arrangements regarding the waste store. These include the potential to have a spill event due to extreme weather events due to high winds. The roof infrastructure has also been strengthened to help prevent water inundation should there be significant rainfall at the site. Bunding of the plant area surrounding the store has been installed to capture any bulk materials should there be any release. The WPA is not considered to be in a high bush-fire threat location.

Security

The waste store is located within the Woomera Prohibited Area, the security for which is managed by the Department of Defence. CBIS maintains a detailed list of emergencies and events that require particular actions to commence. However, it was noted that many of the emergencies and events are largely safety related and would benefit from having additional security scenarios included.

Radiation protection

CBIS has established a system of routine passive and active radionuclide monitoring at the site. This includes radon monitoring inside the radiation store and external dose rate monitoring. Recognising the significant environmental exposure hazards due to extreme heat, sun and wind exposure, CSIRO has considerations included in their risk assessments when performing tasks at the site. However, for planning purposes it was agreed that CBIS would benefit from clearly defining the thresholds of meteorological conditions (available at range control) for when work is permitted at the site.

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 areas for improvement:

1. CBIS should establish radiation safety awareness training for non-radiation workers attending the WPA waste store.
2. CBIS should improve the ergonomics for the donning and doffing of PPE.
3. Due to the unique environmental conditions which could lead to reduced human performance outcomes, CBIS should establish clear meteorological condition thresholds for when work is permitted or to be cancelled.
4. Documented emergency scenarios should also extend to security events such as unauthorised access.

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