Inspection report: Australian War Memorial (AWM) (R21/01987)

This 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 S0080.

The scope of the inspection included an assessment of the AWM’s performance at the Mitchell and Campbell sites against the Source Performance Objectives and Criteria. The inspection consisted of a review of records, interviews, and physical inspection of the sources.

Background

The AWM is established in the Minister for Veterans' Affairs portfolio and its functions and powers are outlined in the Australian War Memorial Act 1980. The AWM combines a shrine, a world-class museum, and an extensive archive. The AWM’s purpose is to commemorate the sacrifice of those Australians who have died in war. Its mission is to assist Australians to remember, interpret and understand the Australian experience of war and its enduring impact on Australian society.

Many items in the AWM collection, particularly those dating back to World War II, contain radioactive material above the exemption limits in devices such as aircraft dials on static display. Further, AWM staff use X-ray fluorescence, ultraviolet (UV) and laser apparatus as part of conservation work. Consequently, AWM is licensed under section 33 of the Act to deal with controlled material, and ionising and non-ionising controlled apparatus at its sites.

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

• 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)
• Occupational exposure to ultraviolet radiation, ARPANSA 2006 (RPS 12)
• Australian/New Zealand Standard Safety of laser products part 1: equipment classification (AS/NZS IEC 60825-1:2014)
• Australian/New Zealand Standard Safety of laser products part 14: a user’s guide (AS/NZS IEC 60825-14:2011)

Observations

In general, the management and operation of the controlled material and controlled apparatus at both sites was found to be satisfactory. 

However, areas for improvement were identified during this inspection including minor inconsistencies with information in the plans and arrangements (P&As) and warning labels on the UV apparatus that did not meet the requirements of Australian Standard Safety signs for the occupational environment (AS1319-1994). These will be discussed in more detail in the relevant sections below.

Configuration management

The AWM has controlled sources at its 2 Australian Capital Territory campuses with some historic items containing radium-226 on display at other locations around the world. The Mitchell site also uses X-ray fluorescence, UV and laser apparatus for conservation work although it was expected that the laser equipment would be decommissioned in the short term.

The controlled apparatus observed during the inspection were listed in the AWM’s source inventory workbook. Virtually all radioactive heritage items were in storage with a very small number on display in situ.

Performance reporting verification

The AWM has adopted formal processes, procedures and reporting structures for managing radiation safety. AWM’s reporting obligations are conducted in accordance with their licence requirements in a timely manner. 

A Principal Radiation Safety Officer (PRSO) is employed to coordinate all dealings with controlled material and controlled apparatus, and a second person, also an RSO with defined duties, is appointed as deputy to the PRSO. The PRSO has responsibility for managing the AWM’s P&As.

Training

The PRSO and RSO have received relevant training as evidenced by the certificates issued to each of them from the training provider.

The PRSO, in turn, provides internal AWM radiation awareness training and apparatus-specific training to all staff required to deal with controlled apparatus or controlled material. Training records are held by Human Resources and a sample of these records for relevant staff were sighted during the inspection.

Inspection testing and maintenance

The portable XRF unit is only serviced by the supplier when required. The UV apparatus does not require regular servicing and the laser had not been used in over a year and is expected to be decommissioned and disposed of in the short term.

The PRSO and RSO were reminded that CEO of ARPANSA approval under section 65 of the Regulations would need to be obtained before disposal of any controlled source.  

Security

While the aggregation of radium legacy items containing radium-226 invokes the provisions of RPS 11, the total inventory in any store is not greater than category 4 and therefore only Chapter 7 (Security management – Notification of a security breach and Accountancy and records) of that code applies.  Nevertheless, the radiation stores are not accessible to the public, entry is restricted to relevant personnel only, they are fully locked and are under 24-hour surveillance.

Radiation protection

AWM has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective dealings with controlled material and controlled apparatus at all sites. This is supported by their P&As titled Radiation Management Plan, November 2020 to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions. Several practisc-specific sets of standard operating procedures (SOPs) and work instructions have also been developed and maintained to support these P&As. These SOPs are available online with some located with the relevant equipment in hard-copy form.

Some minor discrepancies were identified in the P&As that, if appropriately addressed, would improve clarity of the documentation. These discrepancies include:

• no specific reference to a laser safety officer (LSO) other than in the glossary. That is, no tasks or functions for an LSO were defined.  It is acknowledged, however, that AWM is in the process of decommissioning the only laser in its inventory. Reference to an LSO and their tasks will therefore no longer be required once the decommissioning and disposal is completed
• precise referencing to document locations that were no longer relevant
• some potentially confusing referencing to reporting frequencies not coinciding with official meeting dates.

The AWM holds a centralised dose register for all personnel identified by the PRSO as requiring personal monitoring. This need is based on whether a particular staff member will be working with radiation at a given time. Those staff required to enter a radiation store for short-term work are issued an electronic dosimeter, the reading of which they enter into a logbook following the task. The logbooks were checked during the inspection and no significant doses were noted.

The PRSO and RSO periodically check radiation dose rates around the stores. The maximum level at the outside boundary of the stores measured during the inspection were significantly lower than the maximum level prescribed in AS/NZS 2243.4:2018.

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:

1. Some minor discrepancies in the information in the P&As.
2. Labelling of the UV source inconsistent with the requirements of the Australian Standard.

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