ANSTO NUCLEAR MEDICINE Mo99 FACILITY CONSTRUCTION LICENCE SAFETY MANAGEMENT PLAN

ANSTO Nuclear Medicine Facility Construction Licence Application Document ANM-Mo99-C-LA-D2 rev 0 ANSTO NUCLEAR MEDICINE Mo99 FACILITY CONSTRUCTION LICENCE SAFETY MANAGEMENT PLAN Prepared By Australian Nuclear Science and Technology Organisation October 2013

REVISION SHEET Document ANM-Mo99-C-LA-D2 rev 0 Print name, date and sign or initial Revision Number Description of Revision Prepared Checked/ Reviewed Approved Client Agreement 0 Original issue ANM-Mo99-C-LA-D2 rev 0 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... 7 8 DEVIATIONS, ANOMALIES, INCIDENTS AND ACCIDENTS... 7 9 AUDITS AND REVIEW... 7 10 RECORDS AND REPORTING... 8 11 REFERENCES... 8 ANM-Mo99-C-LA-D2 rev 0 page 3 of 8

1 PURPOSE AND SCOPE The purpose of this Safety Management Plan is to describe the safety management arrangements that are in place within ANSTO relevant to the construction 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 construction licence application, specifically the Radiation Protection Plan [ANM-Mo99-C-LA-D3] and the Emergency Plan [ANM-Mo99-C-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 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. A safety and risk assessment for the operational facility (7) has been conducted following the ANSTO Risk Analysis Matrix [AG-2395] (8). 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 Programs (ECP) division has a regular forum at which safety is discussed. There is significant consultation with workers in all aspects of safety through the Central Safety Consultative Forum, the Workgroup Health and Safety Committees, and the Health and Safety Representatives. 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 ECP Business Management System (BMS). The construction activities will be undertaken as described in the Construction Plan [ANM-Mo99-C-LA- C4c]. Safe Work Method and Environmental Statements (SWMES) will be developed by the contractors with the support of ANSTO staff where required. At the operational stage, activities are undertaken in accordance with the approved procedures. For non-routine activities SWMES will be developed and 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 hazardous situations. All safety-related events / incidents are reported and investigated following the guide WHS Event Management System [AG-2372] (9). This process also captures near misses and promotes appropriate responses for improvements including identification of preventive and corrective actions. ANM-Mo99-C-LA-D2 rev 0 page 4 of 8

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. Feedback on safety to staff occurs in several ways. Safety is discussed by the CEO at the regular ANSTO staff forums and it is discussed by the division heads at the regular division forums. An important means of providing safety information to staff is in the ANSTO staff intranet web page where key topics are regularly discussed. Health and Safety Services (HSS) staff hold regular meetings with groups to discuss issues and talk about safety. At the construction stage, toolbox talks led by supervisors and regular staff meetings provide learning on safety. At the organisation level, ANSTO conducts surveys on safety culture. The Work Health and Safety (WHS) section reports monthly on the events raised, their type, severity, as well as lost time frequency for workplace injury incidents. The WHS section gives monthly feedback on performance to divisions on safety training compliance and housekeeping inspections outcomes and compliance 3 ADMINISTRATIVE ARRANGEMENTS The safety regime in the safety policy is expanded principally in the work health and safety management arrangements in the ANSTO WHSMS. These are supplemented where needed by project arrangements. For the ANM Mo99 project a contract will be let for the Detailed Design and Construction (DD&C) work. This DD&C contractor will be required under the contract to comply with AS/NZS ISO 9001 for quality management, AS/NZS ISO 14001 for environmental management, and AS/NZS 4801 for occupational health and safety management. As part of compliance with these requirements, the DD&C contractor will produce a safety management plan and an environmental management plan which will nominate key roles including the site manager and site safety officer. Control of visitors is described later in this plan. The ANSTO staff member controlling their access is responsible for their safety. Entry is subject to the conditions of entry to the construction site as well as any other conditions imposed by ANSTO for visitors at LHSTC 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 construction licence application, arrangements for the planning and control of exposure to radiation are described in the Radiation Protection Plan [ANM-Mo99-C-LA- D3]. ANSTO safety requirements are disseminated to staff and contractors, initially through mandatory safety training requirements. This includes induction training at both an enterprise and a local level, and activity and role based safety specific training. The safety requirements are reinforced by the supervisory arrangements which include toolbox talks and the Safe Working Method and Environment Statement (SWMES). 4 SAFE PREMISES, BUILDING AND EQUIPMENT The ANSTO ANM Mo99 facility building is designed to current modern standards specifically for the purpose of molybdenum-99 production. As part of the safety assessment processes during the design, the facility systems were categorised with respect to safety following the methodology given in Guidance on Categorisation of Structures, Systems and Components [AG2494] (10). The safety category 1 and 2 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 Building Owner and Building Manager as defined in Role of Building Manager [AG 3212] (11). The facility will also have in place for designated hazardous areas a delegated Area Supervisor as defined in the Role of Area Supervisor [AG 2952] (12) 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] (13). 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] (14). ANM-Mo99-C-LA-D2 rev 0 page 5 of 8

The security provisions, including safe entry and exit from the site, are discussed later in this document and in the Security Plan [ANM-Mo99-C-LA-D5]. The responses required in the event of an emergency during construction are discussed in the Emergency Plan [ANM-Mo99-C-LA-D6]. 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 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 section offer external radiation safety courses. The Work Health & Safety (WHS) 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] (15). The full list of courses and the retraining period requirements is given in Work Health and Safety Training Needs Analysis [AG-2364] (16). The training requirements include courses on Contractor Supervisor Training and OHS Risk Management for Supervisors. 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 safety 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, contractors are treated in the same way 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 Security Plan [ANM-Mo99-C-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 ANSTO ID pass holders with escorting privileges as per the ANSTO Security Manual [AG 1028] (17). 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-C-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] (16). 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 Safe Working Permit (SWP) before work. ANSTO employs contractor supervisors to liaise, inform and interface with construction contractors. Further to these general arrangements, the specific arrangements for the construction stage are described in the Construction Plan [ANM-Mo99-C-LA-D5] and the Security Plan [ANM-Mo99-C-LA- D5]. ANM-Mo99-C-LA-D2 rev 0 page 6 of 8

7 CONTROL OF HAZARDS ANSTO adheres to the requirements of the WHS Act 2011 including the identification and control of risks. Specifically the WHS Regulations 2011 require taking appropriate steps to identify all reasonably foreseeable hazards and risks arising from work which may affect the health, safety and welfare of workers and other persons working for or at ANSTO. The processes to do this are at several levels. During the construction stage of the ANM Mo99 facility, the project managers 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. The specific arrangements for controlling hazards on the construction site are described in the Safety Management Plan and Environmental Management Plan prepared by the contractor. 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] (18). 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 construction licence stage are in the WHS management system and ECP project procedures. If potentially unsafe conditions are found or incidents occur during field work, these will be managed by the relevant manager following the ANSTO event reporting system described in Event Response Process [AG-2372] (19). 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 WHS in the HR & WHS Human Resources and Workplace Health and Safety division. Outstanding event reports are monitored by key performance indicators prepared by WHS 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-C-LA-D6] will be invoked. These provide for the initial response with progressive support by 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] (20). 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 The requirements to audit and review both the safety management system and the implementation of the system in the work areas are documented in the WHSMS which is maintained under an ISO9001:2008 certification. This ensures regular management reviews and audits of the WHS systems and procedures. As described in section 4, the DD&C contractor will implement safety management and environmental management plans compliant with the appropriate standards. Under these arrangements there will be regular audits of safety and environmental performance. The radiation protection arrangements are described in the Radiation Protection Plan [ANM-Mo99-C- LA-D3]. The effectiveness of this plan will be monitored by the project team taking into account any incident reports. ANM-Mo99-C-LA-D2 rev 0 page 7 of 8

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. General requirements for safety records are given in Control of Records [S-P-003] (21) which details the storage locations, retention periods and responsibilities for maintaining the records. The safety documents for construction, 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] (15). These are maintained in a database management system and this facilitates record retrieval and usage. The event reporting arrangements are described earlier in this plan. Event reports and records are maintained by WHS in the HR & WHS 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 OS-LA-SUP-240B Regulatory Guide Plans and Arrangements for Managing Safety v4, January 2013 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 Ellis, B. ANSTO-T-TN-2013-12, ANM Mo99 Operations Safety Assessment. ANSTO, 2013 8 ANSTO WHSMS AG-2395 Risk Analysis Matrix, December 2012 9 ANSTO WHSMS AG-2372 WHS Event Management System, November 2012 10 ANSTO WHSMS AG-2494 Guidance on Categorisation of Structures, Systems and Components, February 2012 11 ANSTO WHSMS AG 3212 Role of Building Manager 12 ANSTO WHSMS AG-2952 Role of Area Supervisor 13 ANSTO WHSMS AG-2509 Classification of Radiation and Contamination Areas, September 2006 14 ANSTO WHSMS AG-2414 Safety Hazard Notice Board Process, November 2009 15 ANSTO WHSMS AG-2363 ANSTO WHS Training, September 2006 16 ANSTO WHSMS AG-2364 WHS Courses and Retraining Requirements, January 2010 17 ANSTO AG 1028: ANSTO Security Manual 18 ANSTO WHSMS AG-1094 Operation of the Safety Assurance Committee (SAC) 19 ANSTO WHSMS AG 2372 Event Response Process, September 2006 20 ANSTO WHSMS AG-2376 Reporting to ARPANSA, September 2006 21 ANSTO SERA S-P-003 Control of Records, August 2009 ANM-Mo99-C-LA-D2 rev 0 page 8 of 8