Inspection report: Department of Agriculture, Water and the Environment - Australian Antarctic Division (AAD) (R22/02510)

This inspection was conducted as part of ARPANSA’s planned inspection program using documents, photographs, and records sent by the licence holder, without inspectors attending the site.  

The purpose of the inspection was 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 S0055. 
The scope of the inspection included an assessment of AAD’s performance against the Source Performance Objectives and Criteria.  

Background

The AAD, based in Kingston Tasmania, manages and administers Australia’s presence in the Australian Antarctic Territory and the Southern Ocean, along with the subantarctic territories of Heard Island and McDonald Islands and their adjacent waters.  The AAD is responsible for leading, coordinating and delivering the Australian Antarctic program focused on conducting world-class science of critical national importance and global significance, which delivers on Australian Antarctic policy and operational priorities.

In achieving these goals, AAD uses sealed and unsealed radioactive sources, UV apparatus and lasers as research tools at its Antarctic bases.  Consequently, AAD is licensed under section 33 of the Australian Radiation Protection and Nuclear Safety Act 1998 to deal with controlled material and controlled apparatus for research at its various sites.

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) (RPS12)
• Australian/New Zealand Standard Safety in laboratories - Non-ionizing radiations-Electromagnetic, sound and ultrasound (2004) (AS/NZS 2243.5:2004) (the NIR Standard)
• 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 of radiation safety at the AAD at its Antarctic Bases at Casey and Davis in relation to controlled apparatus was found to be sound. However, in some cases there appeared to be room for improvement as follows:

• Some sets of standard operating procedures (SOPs) had not been reviewed by the review date specified in each document.
• There were minor discrepancies in the serial numbers on some equipment and their record in the source inventory workbook (SIW). 

Performance Reporting Verification 

The Radiation Safety Officer coordinates information for quarterly reports combining that from each Antarctic base as well as the main Kingston premises. Once collected, this information is consolidated into a single final report to ARPANSA.  AAD 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.

Configuration Management

Of those controlled apparatus investigated during the inspection, there were some minor discrepancies with the serial numbers of the UV apparatus listed in the SIW at both the Casey and Davis bases.  

Training

All personnel using controlled apparatus at AAD are required to undertake training related to the type of source they will use.  This training includes general radiation induction, individual laboratory induction and specific use training, the extent of which depends on the proposed dealing for the given individual.  Training records are kept electronically and ARPANSA inspectors have observed these records on previous inspections of the main Kingston premises.  

Access to laboratory areas is restricted to personnel who have undergone appropriate induction training.  The ARPANSA inspectors sighted induction-training records during the inspection.

It should be noted that the UV apparatus at Casey and Davis stations have not been used for many years and as such, refresher training has not been provided.  No-one, including on-site service personnel, is permitted to use these devices until the relevant refresher training has been completed.  ARPANSA will be advised that this has occurred in the relevant quarterly report if and when AAD decides to recommission the equipment.

Security

Only authorised staff have access to AAD buildings at the Antarctic bases.  The existing security measures were therefore considered appropriate. 

Radiation Protection

AAD has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective use of radiation.  This is supported by two comprehensive radiation management plans that form AAD’s plans and arrangements (P&As).  One document is for ionizing radiation sources and the other for non-ionizing radiation equipment.  AAD also has a separate set of guidelines in place that covers sources used specifically at Antarctic bases AAD guidelines for scientific use of sources of ionizing radiation in Antarctica and on sub-Antarctic Islands.  This document was originally authorised in February 2017 and is due for review in April 2022.  AAD uses these documents to achieve compliance with radiation legislation and ARPANSA licence conditions.  

Some SOPs, sub-ordinate documents to the P&As, were due to be reviewed in 2019 although there was no evidence that this had been done.  Even though the UV equipment is currently not in use, these SOPs should reflect this as a result of the review.

Warning signs restricting access to only approved staff are displayed on the entrance to laboratories using radiation sources.  

Event Protection and Emergency Preparedness and Response

Event protection and emergency preparedness and response are handled under the broader AAD 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 areas for improvement:

1. The source inventory workbook did not reflect all relevant aspects of each piece of equipment.
2. Standard operating procedures and other documents sub-ordinate to the main plans and arrangements for AAD had not been reviewed at the date specified.

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