Inspection report: National Gallery of Australia (NGA) (R21/01962)

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 S0024.

The scope of the inspection included an assessment of NGA’s performance at its Parkes Lane, Parkes ACT premises against the Source Performance Objectives and Criteria (POC). The inspection consisted of a review of records, interviews, and 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 and Communications portfolio. The licence holder is authorised under section 33 of the Act to deal with ultraviolet 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 these sources are those that appear in section 59 of the Regulations plus:

• Radiation Protection Series No. 12 Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006) (RPS 12)
• Radiation Health Series 9 Code of practice for protection against ionizing radiation emitted from X‑ray analysis equipment (1984) (RHS 9)
• Radiation Protection Series C-4 Code of Radiation Protection Requirements for Industrial Radiography (2018) (RPS C-4)

Observations

In general, the management of radiation safety at NGA in relation to controlled apparatus was found to be sound. The licence holder’s latest Radiation Protection Plans (RPP) and Safe Work Procedures (SWP) for the Niton XRF Analyser and the Andrex Industrial Radiography X-ray unit reviewed in April 2020 were examined.

The inspection highlighted that the RPP and both SWPs need to be revised for general terminology.

There appeared to be room for improvement with respect to version control and the training record declaration requirements in the RPP.

Performance reporting verification

NGA’s quarterly reports are submitted to ARPANSA in a timely manner and contain relevant information including details of compliance with the Act and Regulations. Information for quarterly reports is coordinated by the Radiation Safety Officer (RSO) and reported to the Head of Conservation.

Other documentation required by ARPANSA such as submissions for approval under sections 63 and 65 of the Regulations would also be coordinated through the RSO as needed.

Configuration management

The controlled apparatus sighted during the inspection matched the internal designations assigned to the apparatus and listed in the SIW. Further, the apparatus inspected were present and accounted for consistent with the SIW.

Training

The NGA requires that all personnel who use the XRF device undertake induction and training. Training to use the XRF device was provided by the supplier and training records are maintained electronically.

The RSO is the sole operator of the fixed industrial radiography X-ray unit and has received training in the use of industrial radiography equipment. Access to the X-ray room is limited to conservation staff with access to the key to operate the fixed industrial radiography X-ray unit restricted to the RSO.

ARPANSA inspectors observed the training records for authorised personnel. The inspectors were advised that a refresher course will be provided to authorised personnel in 2021.

Event protection and emergency preparedness & response

Event protection and emergency preparedness and response are handled under the broader NGA Work Health and Safety policy and were not assessed during this inspection.

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 control panel for the keys to operate the industrial radiography X-ray unit.

The NGA does not deal with radioactive sources and the Security Code of Practice is therefore not invoked. Existing security measures were therefore considered appropriate.

Radiation protection

The fully enclosed X-ray exposure room is located in the conservation laboratory and is used for the 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 include constraints in terms of the maximum kV and tube current to be used. During the previous inspection in March 2020 it was found that the NGA were not meeting the requirements of RPS C-4 for fully enclosed radiography sites in that there was no visible and audible warning device inside the X-ray room that are activated during exposure.

Due to the situation brought on by the COVID-19 pandemic, NGA have been unable to investigate the options for installing the visible and audible warning device in the X-ray room; however, the installation of the visible and audible warning device will proceed in 2021. The inspectors were advised the fixed X‑ray unit had not been used since last year’s inspection and no use was envisaged in the short term. The NGA survey meter had been calibrated in June 2020; however, the fixed X-ray unit had not been used. NGA staff periodically carry out radiation monitoring during use of the X-ray equipment.

NGA requires that usage of the portable XRF device be recorded in a logbook. During the inspection it was observed that the logbook contained usage details.

Safety culture

NGA management has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective use of radiation. This is supported by a comprehensive Radiation Protection Plan and Safe Work Procedure to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions.

The NGA’s sound approach to safety culture was evident in the extensively documented workplace Health and Safety and Risk Management policies.

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. Version control on all documents.
2. The RPP and both SWPs require some general editorial changes.
3. Ensure all aspects of the RPP are being carried out as prescribed:
   a) Training declaration to be updated every two years.

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