ANSTO NUCLEAR MEDICINE Mo99 FACILITY SITING LICENCE SAFETY MANAGEMENT PLAN

ANSTO Nuclear Medicine Facility Siting Licence Application Document ANM-Mo99-S-LA-D2 ANSTO NUCLEAR MEDICINE Mo99 FACILITY SITING LICENCE SAFETY MANAGEMENT PLAN Prepared By Australian Nuclear Science and Technology Organisation September 2012

REVISION SHEET Document ANM-Mo99-S-LA-D2 Print name, date and sign or initial Revision Number Description of Revision Prepared Checked/ Reviewed Approved Client Agreement 0 Original issue 1 Updated from SAC Assessor Comments ANM-Mo99-S-LA-D2 page 2 of 8

CONTENTS 1 PURPOSE AND SCOPE... 4 2 SAFETY CULTURE... 4 3 ADMINISTRATIVE ARRANGEMENTS... 5 4 SAFE PREMISES, BUILDING AND EQUIPMENT... 5 5 COMPETENCY, TRAINING AND SUPERVISION... 6 6 VISITORS, CONTRACTORS AND OTHER PERSONS... 6 7 CONTROL OF HAZARDS... 6 8 DEVIATIONS, ANOMALIES, INCIDENTS AND ACCIDENTS... 7 9 AUDITS AND REVIEW... 7 10 RECORDS AND REPORTING... 7 11 REFERENCES... 8 ANM-Mo99-S-LA-D2 page 3 of 8

1 PURPOSE AND SCOPE Australian Nuclear Science & Technology Organisation The purpose of this Safety Management Plan is to describe the safety management arrangements that are in place within ANSTO relevant to the siting licence application of the ANSTO Nuclear Medicine Mo99 (ANM Mo99) facility at Lucas Heights, NSW. The scope of this plan is all safety and licensing issues in accordance with the ARPANS legislation (1, 2) and the ANSTO safety arrangements. It specifically covers the issues referred to in the ARPANSA licensing guidelines relating to the review of plans and arrangements (3). This plan should be read in conjunction with the other plans and supporting documents comprising the sitting licence application, specifically the Siting Radiation Protection Plan [ANM-Mo99-S-LA-D3] and the Siting Emergency Plan [ANM-Mo99-S-LA-D6]. 2 SAFETY CULTURE ANSTO has a core value relating to safety, security and environmental sustainability safeguarding human health, ensuring high priority to safe and secure operations, and minimising our environmental footprint (4). Following from this, ANSTO is responsible for the safety of its workers and the public as outlined in the Occupational Health, Safety and Environment Policy (5). The ANM Mo99 project will formulate and execute the project activities in compliance with ANSTO Work Health and Safety Management System (WHSMS) which implement the safety requirements of the strategic plan and safety policy. The safety policy and safety arrangements are readily available to and accessed by staff on the ANSTO intranet and are subject to regular review. An aspect important to safety culture is that people have a questioning attitude and adopt a rigorous and prudent approach to work incorporating conservative decision making. Appropriate training and awareness instilled by safety briefings, toolbox talks, safety inspections and use of the STAR (Stop, Think, Act, Review) principle all help to engender such an approach to work. Another aspect important to safety culture is that the implementation of the safety requirements is not subject to inappropriate commercial pressures. In ANSTO the safety approval processes are clearly separated, with safety approvals given by the ANSTO Safety Assurance Committee (SAC). The ANSTO Workplace Health and Safety Management System (WHSMS) has several layers of protection for staff, contractors and the environment. The ANSTO standard Radiation Safety [AS2310] (6) has defence-in-depth as a main strategy. Some general examples of this approach are discussed below. As part of this siting licence package, there has been an assessment of potential reference accidents and this is recorded in the report ANM Mo99 Reference Accident Assessment [ANSTO/T/TN/2012-07]. This assessment found that the potential radiological risk to the public is small. Furthermore, at the construction application phase of the project, a risk assessment for the facility will be conducted following the Work Health, Safety & Environment (WHSE) guide Conduct of a Risk Study [AG-2400] (7). Good communication and consultation are central to providing a good safety culture. At the ANSTO organisational level, the CEO holds regular forums for all staff and promotes a safety theme. ANSTO Engineering and Capital Projects (E&CP) division has a regular forum at which safety is discussed. There is significant consultation with workers including staff and contractors in aspects of safety through the Central Safety Consultative Forum, the Workgroup Health and Safety Committees and the Health and Safety Representatives and deputies. All committees referred to here have terms of reference set out in the WHSMS. Safety indicators for activities and processes are monitored to improve operational and safety performance within the E&CP Business Management System (BMS). At the construction stage, field activities will be undertaken in accordance with procedures and less common activities will be undertaken under Safe Working Method and Environment Statement (SWMES). Radiation Protection Services staff and Work Health & Safety (WHS) Advisers give input to these documents. This process reduces the likelihood and potential consequences of any human errors. ANM-Mo99-S-LA-D2 page 4 of 8

All safety related events / incidents are reported and investigated following the guide WHS Event Management System [AG-2372] (8). This process also captures near misses and actions for improvements. Safety issues and learning are communicated to staff in the following ways. Feedback to management occurs both informally and by reports, through line management and the Facility Officer. The Facility Officer monitors issues relating to the ARPANSA licence and reports to the Nominee on regulatory matters. At the construction stage, toolbox talks and regular staff meetings provide learning on safety. At the organisation level, ANSTO conducts surveys on safety culture. Safety, Environmental and Radiological Assurance (SERA) division reports monthly on the events raised, their type, severity and lost time frequency and gives monthly feedback to divisions on safety training and housekeeping inspections. 3 ADMINISTRATIVE ARRANGEMENTS The safety regime in the safety policy is expanded principally in the occupational health and safety management arrangements in WHSMS. These are supplemented where needed by divisional arrangements. Some project work during the siting licence stage may be performed by contractors under the supervision of ANSTO staff. Contractors will be managed following ANSTO procedures. If necessary, any field work they perform will be assessed by SWMES reviewed by ANSTO which will identify the hazards and specify the safety controls. Control of visitors is described later in this plan. The ANSTO staff member controlling their access is responsible for their safety. The arrangements for radiation protection and radiation safety are given in Radiation Safety [AS-2310] (6) and supporting practices which together form a comprehensive suite of arrangements consistent with international best practice. In this siting licence application, arrangements for the planning and control of exposure to radiation are described in the Radiation Protection Plan [ANM-MO99-S-LA-D3]. ANSTO safety requirements are disseminated to staff and contractors, principally through the training requirements. This includes appropriate induction training and safety specific training. The safety requirements are reinforced by the supervisory arrangements. 4 SAFE PREMISES, BUILDING AND EQUIPMENT The ANSTO ANM Mo99 facility building will be designed to modern standards specifically for the purpose of molybdenum-99 production. As part of the safety assessment processes during the design, the facility systems will be categorised with respect to safety following the methodology given in Guidance on Categorisation of Structures, Systems and Components [ANSTO/T/TN/2008-11 Rev 1] (9). The safety category 1 structures, systems and components will require a detailed safety assessment which will be submitted to SAC and ARPANSA under ARPANS regulation 54. When constructed, the building will have a formal owner and Building Manager as defined in Role of Building Manager [AG 3212] (10). Areas within the building will be classified as red, blue or white for radiation and radiological contamination in accordance with Classification of Radiation and Contamination Areas [AG-2509] (11). The classification of areas and any subsequent changes will be made on the advice of the Radiation Protection Adviser. Local hazard noticeboards will be used to inform staff, contractors and visitors of hazards and controls in each area in accordance with Safety Hazard Notice Board Process [AG-2414] (12). The security provisions, including safe entry and exit from the site, are discussed later in this document and in the ANM Mo99 Security Plan [ANM-Mo99-S-LA-D5]. The responses required in the event of an emergency during construction are discussed in the ANM Mo99 Emergency Plan [ANM- Mo99-S-LA-D6]. ANM-Mo99-S-LA-D2 page 5 of 8

5 COMPETENCY, TRAINING AND SUPERVISION ANSTO has comprehensive processes which collectively ensure that potentially hazardous work is performed by and supervised by properly authorised and qualified staff. This starts with the recruitment process for staff and long-term contractors where selection is based on the technical and personal selection requirements for the role. The criteria include the qualifications, knowledge and experience appropriate for the work. Radiation Protection Services staff in SERA division play an important safety role. Radiation Protection Advisers (RPA) are recruited with the necessary knowledge, skills and experience or are trained and authorised within ANSTO. The Health Physics Surveyors (HPS) are given comprehensive theoretical and practical training and are authorised within ANSTO. ANSTO is well recognised for its radiation training capability and the Radiation Consultancy & Training Services offer external radiation safety courses. The SERA Health & Safety Services (HSS) section provides advice on conventional work health and safety and provides non-radiation safety training, including induction for staff and contractors and safety training for supervisory staff. An overview is given in ANSTO WHS Training [AG-2363] (13). The full list of courses and the retraining period requirements is given in Work Health and Safety Training Needs Analysis [AG-2364] (14). The training requirements include courses on Contractor Supervisor Training and OHS Risk Management for Supervisors. ANSTO staff have significant experience in radiation hazards. Any workers required to do specialised tasks will be provided with task-specific training prior to their assignment to the job. A record of the training is maintained in the ANSTO training management system. 6 VISITORS, CONTRACTORS AND OTHER PERSONS ANSTO has a duty of care for the safety of non-ansto workers, including contractors and visitors. As noted earlier, long-term contractors are treated as staff in terms of safety training and requirements and there are special arrangements for short-term contractors and visitors. The general provisions for site and building access are described here and in the separate Siting Security Plan [ANM-Mo99-S-LA-D5]. Access to the Lucas Heights site is controlled by ANSTO Security and the Australian Federal Police through the ANSTO security swipe card system. Only trained staff and approved contractors are given unaccompanied access. Visitors must be escorted by trained staff. Entry into the radiation areas is through radiation / contamination barriers. Only trained staff and contractors with the appropriate safety and radiation training are given the access to swipe unaccompanied through these barriers. These arrangements are described in the Radiation Protection Plan [ANM-Mo99-S-LA-D3]. As referred to earlier in this plan, there are comprehensive safety training requirements in place for contractors and these are described in Work Health and Safety Training Needs Analysis [AG-2364] (14). For short-term contractors this includes contractor induction training and a radiation safety course. Prior to commencing work, contractors demonstrate their knowledge of the hazards and safety controls by their involvement in the preparation of the SWMES and their sign-off of these documents. Contractors demonstrate their knowledge of the general hazards in the area and the safety controls by their sign-off of the SWP before work. Further to these general arrangements, the specific arrangements that will be put in place during the construction stage will follow the established ANSTO WHS and project procedures. These will be described in the construction licence application at the next stage in the project. 7 CONTROL OF HAZARDS ANSTO processes for the control of hazards are at several levels. During the siting licence and construction licence stages of the ANM Mo99 facility, the project engineers are responsible for safety. This includes identifying the hazards and assessing and controlling the associated risks and recording this in relevant documentation including SAC submissions, safety assessments and SWMES as required. The principle of hierarchy of controls is followed. ANM-Mo99-S-LA-D2 page 6 of 8

All of the working level arrangements for the control of hazards are assessed and supplemented by the SAC review and approval process given in Operation of the Safety Assurance Committee (SAC) [AG-1094] (15). All documents in this licence application are included in the submission to the SAC. The SAC assessment process includes a review of the submission to ensure that the all of the ANSTO WHS requirements (not just those relevant to the ARPANS legislation) have been followed. 8 DEVIATIONS, ANOMALIES, INCIDENTS AND ACCIDENTS Arrangements to deal with deviations, incidents and accidents during the siting licence stage are in the WHS management system and E&CP project procedures. There will be minimal field activities during the siting licence stage. If potentially unsafe conditions are found or incidents occur during field inspections, these will be managed by the relevant manager following the ANSTO event reporting system described in Event Response Process [AG-2372] (16). This process captures safety near misses and deviations as well as incidents and accidents. The follow-up process involves an initial investigation by supervisory staff and a later review by the line manager or investigator with sign off by the division General Manager. All event reports are reviewed and recorded in the ANSTO system which is managed by HSS in SERA division. Outstanding event reports are monitored by key performance indicators prepared by HSS and reviewed regularly by ECP. In the unlikely case of an accident or injury, the emergency arrangements described in the ANM Mo99 Emergency Plan [ANM-Mo99-S-LA-D6] will be invoked. These provide for the initial response with progressive support by radiation and safety specialists and, if required, the external emergency services. The reporting and follow-up is through the event response process. The process for reporting to ARPANSA is described in Reporting to ARPANSA [AG-2376] (17). This requires reporting of any accidents involving a significant failure in the safety provisions within 24 hours and a subsequent written investigation report. The arrangements described here to deal with deviations, accidents and incidents are implemented in the ANSTO WHS Management System which is maintained under an ISO 9001 certification. 9 AUDITS AND REVIEW Arrangements to audit and review both the safety management system and the implementation of the system in the work areas are documented in the WHS Management System. The SERA division maintains ISO9001:2008 certification of its procedures and conducts regular management reviews and audits of the WHS systems and procedures (which includes Radiation Protection Services and Health & Safety Section). The radiation protection arrangements are described in the Radiation Protection Plan [ANM-Mo99-S- LA-D3]. The effectiveness of this plan will be monitored by the project team taking into account any incident reports. 10 RECORDS AND REPORTING The ANSTO WHSMS are within the ANSTO certified ISO 9001:2008 systems and an ISO 14001:2004 system. This is important to ensure there is appropriate reporting and retention of records. The requirements for safety records and reporting are described in the SERA document Quality Manual [S- QM] (18) and supporting documents. General requirements for safety records are given in Control of Records [S-P-003] (19) which details the storage locations, retention periods and responsibilities for maintaining the records. The safety documents for siting, including the submission to SAC and the supporting documents will be stored in an ANSTO SAC file for the project and in project records. The safety training arrangements are described earlier in this plan. The training records are maintained by the WHS Training Officer following Work Health and Safety Training [AG-2363] (13). These are maintained in a database management system and this facilitates record retrieval and usage. ANM-Mo99-S-LA-D2 page 7 of 8

The event reporting arrangements are described earlier in this plan. Event reports and records are maintained by HSS in SERA division. These records contain information on the incident, the follow-up investigation reports and summary information on any injuries. Summary information on each incident is entered into a database to facilitate retrieval of details, follow-up and closure. 11 REFERENCES 1 Australian Radiation Protection and Nuclear Safety (ARPANS) Act 1998 2 Australian Radiation Protection and Nuclear Safety (ARPANS) Regulations 1999 3 ARPANSA RB-STD-15-03 Regulatory Guideline on Review of Plans and Arrangements, August 2003 4 ANSTO 2010-2015 Corporate Plan 5 ANSTO Occupational Health, Safety and Environment Policy, March 2010 6 ANSTO WHSMS AS-2310 Radiation Safety, August 2009 7 ANSTO WHSMS AG-2400 Conduct of a Risk Study, September 2006 8 ANSTO WHSMS AG-2372 WHS Event Management System, September 2006 9 ANSTO/T/TN/ 2008-11 Rev 1 Guidance on Categorisation of Structures, Systems and Components 10 ANSTO WHSMS AG 3212 Role of Building Manager 11 ANSTO WHSMS AG-2509 Classification of Radiation and Contamination Areas, September 2006 12 ANSTO WHSMS AG-2414 Safety Hazard Notice Board Process, November 2009 13 ANSTO WHSMS AG-2363 ANSTO WHS Training, September 2006 14 ANSTO WHSMS AG-2364 WHS Courses and Retraining Requirements, January 2010 15 ANSTO WHSMS AG-1094 Operation of the Safety Assurance Committee (SAC) 16 ANSTO WHSMS AG 2372 Event Response Process, September 2006 17 ANSTO WHSMS AG-2376 Reporting to ARPANSA, September 2006 18 ANSTO SERA S-QM Quality Manual, August 2009 19 ANSTO SERA S-P-003 Control of Records, August 2009 ANM-Mo99-S-LA-D2 page 8 of 8