Part 6 Waste Store Documents MR18 00544 released July 2022.pdf

Update on the waste storage project
5 April - Gillian Hirth
Late last year, it was announced to all staff that ARPANSA would take ownership of approximately
210 drums of low-level radioactive waste. At this time, it was expected that the initial delivery of 72
drums would be completed by March 2018, however less urgency in the timing of the project has
meant that this is now expected in late April at the earliest.

To date, there have been a variety of communication pieces with staff, including an update on ISAAC
and at the Staff Consultative Forum (SCF), consultations with the Office of the CEO, People and
Culture, Agency Security and ARPANSA Work Health and Safety.

We are now at a stage where the Executive Group (EG) has approved our proposed direction,
including location of a new waste store area within the Yallambie site to store the waste pending
permanent disposal and to accept the initial delivery of 72 drums.

We will be holding a talkshop on 19th April to provide you with further information on the project. In
the meantime, we have put together a set of frequently asked questions below for your information.
We will continue to provide you with regular updates as the project progresses.

Frequently Asked Questions
Why are we expanding our Radioactive Waste holdings?
From the late 1920’s to the 1970’s the Commonwealth Radiation Laboratory (CRL) operated on a site
at the University of Melbourne. The activities that were conducted at the CRL during this long period
of time resulted in contamination of the building, which has subsequently become a ‘legacy site’. The
Commonwealth (represented by ARPANSA) is accepting responsibility for the waste produced from
remediation of this legacy site. Approximately 210 drums containing soil and building material
contaminated with radium-226 require storage in a radioactive waste store that is licenced and
managed appropriately.

While the contamination resulted from activities undertaken by ARPANSA’s predecessor, it is
appropriate and international best practice for ARPANSA to take responsibility for the waste produced
from the remediation of this legacy site, and to implement appropriate storage arrangements for this
waste.  We expect other organisations to take care of their legacies, so this applies to us as well – we
by ARPANSA under FOI
should lead by example.

What considerations were made in regard to different locations for storage?
Several options have been considered in a situation, weakness, opportunity and threat analysis and
presented to the EG. Construction of a new waste storage area within ARPANSA’s Yallambie building
is the preferred option, and is also a safe option. This option, and others have also been discussed
with Regulatory Services Branch. The area to be refurbished currently houses the ‘s 47E - operations in the
s 47E - operations part of the building.

The initial tranche of 72 drums of the waste will be temporarily stored in the s 47E - operations to the rear of
the Yallambie premises.  These will be received late in April at the earliest, and will be transferred to
the new facility within the main building once constructed and the remainder of the drums can be
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received.
A risk assessment for the storage of the initial tranche of 72 drums has been completed. The initial 72
drums includes the lowest activity drums from the site remediation. These drums will be added to the
RHSB Source Licence S0002 Inventory and reported in our quarterly report to the regulator.

What stage is the project currently at?
To date the EG has approved the:
•  Proposed approach to waste management, including
location of the new waste storage area.
•  Transportation costs for initial tranche of 72 drums.
•  Commissioning of the design of the new waste storage
area.
Once the design is completed and tender bids are received and reviewed the EG will be asked to
approve commencement of work on construction associated with the new waste storage area.

How does ARPANSA regulate itself?
ARPANSA is currently licenced under RHSB Source Licence S0002 to store radioactive waste in the
form of obsolete sealed or unsealed sources that are awaiting disposal. The Yallambie building
currently stores approximately 60 drums of predominantly low-level waste with some small quantities
of intermediate-level waste in two waste storage areas in the basement. The majority of the waste is
from the original clean-up of the CRL building and includes radium-226, cobalt-60 and other various
medical radioisotopes, as well as some waste from activities conducted at Maralinga.
In terms of activity, the additional 210 drums of low-level waste equates to only s 47E - operatiof the total
activity of ARPANSA’s currently stored waste in four times the volume. The Radiation Safety Officer
will manage the waste as a part of the current RHSB Source Licence S0002 inventory.
In self-regulation, ARPANSA requests a third party to review the documentation and reasoning behind
the licence. A third party also participates in all regulatory inspections of our activities. We have a
current agreement with s 47G - business
to provide such third-party review.

What is going to happen with the waste in the end?
The waste holdings that ARPANSA has acquired will be temporarily and safely housed in the
Yallambie waste stores until the National Radioactive Waste Management Facility (NRWMF) is
established and operational. The waste will be then be repackaged to meet the NRWMF waste
acceptance criteria and transported to the NRWMF for disposal.

by ARPANSA under FOI
What is next in the project?
A talkshop is planned for April 19th to update staff on the current status and allow the opportunity to
ask questions before the first tranche of drums is delivered. Invitations will be issued shortly following
the posting of this article.
A building designer has

been engaged and the design is to be completed by the end of April.  The tender process is expected
to be completed by end of May.

Further updates will be provided to staff as we progress through the process.
If you would like any further information or have any concerns, please attend the talkshop – there will
be plenty of time for questions and comments. Feel free to come and have a chat with Marcus
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Grzechnik x2292.

Expansion of ARPANSA’s
waste holdings – an update
Dr Marcus Grzechnik
by ARPANSA under FO
Dr Gillian Hirth
1
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FOUO

Executive Group
Paper
Title:
ARPANSA Waste Store Design Quotation and next steps.
Date:
9 March 2018
Item no:
2.7
Purpose:
For approval.
Issue
Approximately 210 drums of legacy low-level radioactive waste are to be transferred to the Yallambie site
from Melbourne University (see EG paper 2.5, 18 Jan 2018). Approval is required to move forward with
monetary spend for commissioning a designer at $24,140+GST.
Background
Details on the project background and options considered were provided in EG paper 2.5, 18 Jan 2018.
Update
Since the late-January EG meeting;
•  The SWOT analysis has been updated after a walkthrough of the Store with the RSO and RHS
Branch Head (see Attachment 1).  s 47E - operations
option is now moving forward.
•  Confirmation has been received that an initial tranche of 72 drums can be received for interim
storage. These wil  be stored in the locked shed at the rear of the premises until a longer-term
by ARPANSA under FOI
facility is completed (risk assessment to be undertaken). The expansion of RHS’s current source
inventory wil  be reported in the quarterly report.
•  A letter of acceptance for the drums has been sent to Melbourne University for state regulatory
processes (see Attachment 2).
•  A quotation from A.S. Building consultants to undertake work on design has been received (see
Attachment 3).
•  A quotation for transport of first 72 drums has been received from s 47G - business

Additional costs if a pre-transport site visit is undertaken (preferred). Currently coordinating with
ANSTO and ALARA regarding timings.
•
s 47G - business
s 47E - operat
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  Quotations are being sought from
to assist in preparing the
at Yal ambie for receipt
of the waste (minor cost).
<Committee name>
<Meeting date/s>
Page 1 of 3
SMC-EG paper template V.1
FOUO

FOUO
Request for Approval
We request that the EG approves the proposed direction of the project and agrees to the spending of
$24140.00+GST on the design for the waste store.
Sensitivity:
Sensitivities that have been identified include media, the public (immediate neighbours) and staff.
Legislation
No legislative amendments are required.
FOI
Financial Implications
There will be several costs during this project. All costs estimated below are subject to change.
•  Design –approximately $27K
•  Relocation of Linac Chiller – at least $30K
•  Building works – approx. $200 – 250K (tbc)
•
under
  Transportation (each shipment) – approx. $5K
The complete relocation of the Linac control room is of the order of $50K (to be confirmed)
Risk Analysis
The major risks to the Agency are;
•  Reputational – ARPANSA must store its waste safely in accordance with international best practice.
It would be reputational y damaging to the Agency to do otherwise.  There is some risk that the
acceptance of this waste will be perceived badly by the immediate neighbours (see Communication
activities below).
•  Cost – This is an unbudgeted activity with potential for high costs.
The SWOT analysis has identified these risks, and several options have been excluded due to the potential
reputational effect. Costs are still being determined and will be communicated regularly to the EG as more
ARPANSA
information becomes available.
Timing/Handling:
by
Transport of initial tranche of drums will be confirmed after initial meeting. It is expected that this wil
happen near Easter (1st April), or soon after (week of 15th April).
If proceeding with the design is confirmed (as requested above), it may be possible to go out to tender
soon after Easter with the aim to engage a builder by mid-May.
Communication
Consultation
Consultations have been held with the Staff Consultative Forum (SCF), OCEO (on Communications), groups
impacted by Linac downtime, Agency Security and ARPANSA WHS. A lengthy discussion was held at the
SMC on Communication externally (see next paragraph).
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These consultations are ongoing.
Communication activities
There are no community awareness opportunities relating to this item.
<Committee name>
<Meeting date/s>
Page 2 of 3
SMC-EG paper template V.1
FOUO

s 47E - operations

s 47E - operations would

Height may not be
need to be transported
sufficient for forklift
via reception from the
(ventilation ducting is and
basement
services are quite low,
would restrict stacking)

s 47E - operations would
require relocation

by ARPANSA under FOI
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Ref No: D185599

16 February 2018

s 47F - privacy
Consultant, Infrastructure Services
The University of Melbourne
215 Grattan Street
Carlton VIC 3053
Re: Building 164 – Acceptance of Radioactive Material

Dear s 47F - privacy

ARPANSA confirms that it will accept and remove Radioactive Material (any material that contains levels of
radioactivity above the exemption limits defined by DHHS) associated with the Australian Radiation
Laboratory and its predecessors and related to the demolition of Building 164 including clean-up and
radiation clearance of the site and surrounding areas as shown on Schedule 1 (attached).
Please note that ARPANSA is unable to accept hazardous material other than Radioactive Material, such as
asbestos.

by ARPANSA under FOI
Yours sincerely,

Dr Gillian Hirth
Chief Radiation Health Scientist

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619 Lower Plenty Road, Yal ambie VIC 3085
38–40 Urunga Parade, Miranda NSW 2228
xxxx@xxxxxxx.xxx.xx
+61 3 9433 2211
PO Box 655, Miranda NSW 1490
arpansa.gov.au

+61 2 9541 8333

FOI
under

ARPANSA
by
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2 of 2

7 February 2018

Andrew Clegg
Facilities Manager
ARPANSA
C/o 619 Lower Plenty Road
VIEWBANK VICTORIA 3084

Dear Andrew

Re:

Alterations & additions to an existing waste storage area
At:

No. 619 Lower Plenty Road VIEWBANK/YALLAMBIE

Thank  you  for  the  invitation  to  provide  the  fee  proposal  for  our  professional  building  surveying,
building design, engineering and consultancy services.

I advise that our proposal is as follows:

1.
The service offered:

Consultation;
Liaise  and  consulted  with  client,  Draftsperson,  engineers  and  Local  Authority  (Banyule
Council);
Obtain the property information from Council;
Arrange to engage a draftsperson to prepare the working drawings;
Arrange to engage the necessary engineering plans together with Certificate of Compliance-
Design
Arrange to engage a suitable qualified Energy Rater, if required;
Arrange to engage a geotechnical Engineer for a soil report, if required;
Carrying out site inspections and attend to site meeting, if required;
Checking of application for compliance with the Building Act 1993 and Building Regulations
by ARPANSA under FOI
2006, Building Code of Australia 2016 and the relevant Australian Standards;;
Issuing a building permit for the proposed building works;
Carry out the mandatory Inspections;
Issuing of an Occupancy Permit and/or the Certificate of Final Inspection upon completion;
Provide copies of all relevant permit documents to applicant and the Council;

General administrations, photocopying, postage/miscellaneous;

2.
Fees:

3.
Disbursements/Exclusions:
eleased

s 47G - business

IMPORTANT:
PLEASE  READ  NOTES  BELOW  WHICH  FORMS  PART  OF  OUR  PROFESSIONAL
BUILDING CONSULTANTANCY SERVICES ENGAGEMENT.

Suite 1, 418-428 Bell Street, PASCOE VALE VIC. 3044    Telephone: (03) 9078 9207    E-Mail:

s 47F - privacy

From:
Sarsha Collett on behalf of $ARPANSA PMAG
To:
Marcus Grzechnik
Cc:
$ARPANSA PMAG; Gillian Hirth; Andrew Clegg; Julie Murray
Subject:
PRO-0025 Waste Storage Area [SEC=UNCLASSIFIED]
Date:
Tuesday, 1 May 2018 3:46:12 PM
Attachments:
image001.png
Dear Project Manager,

The Strategic Management Committee (SMC), together with the Project Management Advisory
Group (PMAG), has completed their assessment of new project proposals for 2017-18.
FOI

I’m pleased to inform you that the PRO-0025 Waste Storage Area was APPROVED for funding in
the 2017-18 budget allocation.

Your PMAG Partner and Branch Head will be in contact with you shortly to discuss specific
feedback and next steps to progress your project.

under
I would like to take the opportunity to personally thank you for developing high-quality project
documentation and participating in the new project approval process; both of which were well
received by the SMC.

In 2018-19 PMAG will undertake a review of the new Project Management Framework and will
be in contact with you in due course to seek your feedback about how we can further enhance
project management practices at ARPANSA.

Kind regards,
Sarsha

Sarsha Collett
ARPANSA
Chair, Project Management Advisory Group

by
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From:
Andrew Clegg
To:
s 47F - privacy
Cc:
Marcus Grzechnik
Subject:
A Frame in Old Linac Modulator Room - Disposal [SEC=UNCLASSIFIED]
Date:
Wednesday, 2 May 2018 12:24:17 PM
Hi s 47F - priv

Can Comrez please remove and dispose of A Frame in Old Linac Modulator Room please. See
below photo:
Thanks

Andrew Clegg
Facilities Manager
Australian Radiation Protection and Nuclear Safety Agency
by ARPANSA under FOI
619 Lower Plenty Road, Yallambie, VIC 3085, AUSTRALIA
Mobile 04 1864 5596
email xxxxxx.xxxxx@xxxxxxx.xxx.xx
http://www.arpansa.gov.au

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From:
Andrew Clegg
To:
Rose Tenuta
Cc:
Marcus Grzechnik; Robyn Lawler
Subject:
PO Request - Existing Linac Chiller Relocation to Roof [SEC=UNCLASSIFIED]
Date:
Thursday, 3 May 2018 8:51:33 AM
Hi Rose

Can you please raise and print a PO Request for Branch Head Approval for this task?

Price: s 47G - business+ GST
Start: 7-05-2018 Finish 30-08-2018
Supplier: Comrez
CAPEX to be highlighted

Thanks

Andrew Clegg
Facilities Manager
Australian Radiation Protection and Nuclear Safety Agency
619 Lower Plenty Road, Yallambie, VIC 3085, AUSTRALIA
Mobile 04 1864 5596
email xxxxxx.xxxxx@xxxxxxx.xxx.xx
http://www.arpansa.gov.au

by ARPANSA under FOI
Released

From:
Andrew Clegg
To:
Marcus Grzechnik
Subject:
FW: MTA Chiller relocation from Linac Modulator Room [SEC=UNCLASSIFIED]
Date:
Thursday, 3 May 2018 5:13:58 PM
Will work on the PO Friday…

Cheers

AC

From: s 47F - privacy

Sent: Thursday, 3 May 2018 2:14 PM
To: Andrew Clegg <xxxxxx.xxxxx@xxxxxxx.xxx.xx>
Subject: MTA Chiller relocation from Linac Modulator Room

Hi Andrew
As discussed, the budget cost to relocate the pipework and equipment serving existing Linac, will
be $22,500.00 Ex GST.
The anticipated works will include
·    Relocating 7.5kw MTA Chiller out of Linac Modulator Rm to enable room to be
repurposed for other activities
·    Crane movements to facilitate relocation
·    Relocation of hydraulic and electrical services associated with move
·    Pump down and rerouting of refrigerated pipework/ electricals associated Ceiling
cassette unit presently serving existing unit, again to allow Modulator room to be
repurposed
·    Coring holes through Masonry for abovementioned works where necessary
·    Flashing and make good on all external penetrations
·    Recommissioning of equipment and reinstatement to normal operation.
Normal warranties apply to labour to ensure reinstated equipment operates as intended but
things like circulating pump capacity are excluded from such warranties and will be priced
by ARPANSA under FOI
separately if required
Hope this helps. If you have any queries please do not hesitate to call/ catch up to discuss

Regards

s 47F - privacy
Comrez Property Solutions
PO Box 3071
Strathmore
Victoria 3041
s 47F - privacy
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FOI
under
ARPANSA
by
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From:
Jim Scott
To:
Loch Castle
Subject:
RE: Melbourne Uni Waste [SEC=UNCLASSIFIED]
Date:
Monday, 7 May 2018 10:15:04 AM
Hi Loch

That is great. Many thanks. I will provide some feedback to you after the SCF, but that is  most
likely to be tomorrow as I have a meeting at ANSTO this afternoon from 3.00 – 4.30 pm.

Regards
Jim

From: Loch Castle
Sent: Monday, 7 May 2018 9:56 AM
To: Jim Scott <xxx.xxxxx@xxxxxxx.xxx.xx>
Subject: RE: Melbourne Uni Waste [SEC=UNCLASSIFIED]

Hi Jim,

I can only comment on the regulatory aspects and engagements that we’ve had regarding this
waste.

1.   Communication with the Regulator On the 18th January, Yallambie staff advised
Miranda of the inventory of the waste. This totalled 19MBq of 226Ra. From a Safety
perspective, this is a Group 1 quantity and from a Security perspective, this is considered
a Cat  (i.e. no additional security is required).
s 47E

2.   Risk Assessment On the 30th January, Yallambie staff had a meeting with myself to
discuss other legacy source characterisation issues and also provided advice regarding
their intention to store the Melbourne Uni waste at Yallambie. At the time, I agreed with
the Yallambie staff that this activity didn’t have any significant implications for safety and
by ARPANSA under FOI
agreed with their assessment that a Regulation 52 would apply.

3.   Hazards Technically, from a non-point source perspective, the hazards are:
a.   Dose Rate 0.5uSv.hr-1 @ 1 meter. This is of the order of magnitude of
background radiation. This of course does not take into consideration the
attenuation that will be present due to the 6mm drum thickness and self-
attenuation of the contaminated building materials, which would make the
doses even lower. I suspect that the doses may be as low as 0.2uSv.hr-1 at 1
meter. Given the location will be a s 47E - operations room, the risk is negligible to
staff.
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b.   Inhalation of Radon Regarding the radon gas, it was described that the waste
inventory would be ventilated and live radon monitoring would be installed.
Noting that this waste represents less than 1% of the inventory of Yallambie’s
existing inventory, the contribution to background radon is likely to be minimal.

4.   Communication with Staff In April 2018 Yallambie hosted a talk-shop to describe the

inventory and the storage arrangements. I was present and advised staff that when
there is significant implications for safety (something requiring approval by the CEO i.e. a
decision) or when there is an inspection, that I would engage QLD Health independently.
However, based on the questions that arose from staff directed to Yallambie leadership
during this workshop, I recommended via telephone to Peter Taylor that he should
consider putting this activity and the associated risk assessment through the Yallambie
radiation safety committee for sign-off as we expect from other licence holders.

5. Engagement of QLD Health Because this activity does not have significant implications
for safety, nor is it an inspection of activities performed at Yallambie, I have not engaged
FOI
the QLD Regulator on this matter.

So, my overwhelming view is that there should be no change from our perspective.

Cheers,
under
Loch

From: Jim Scott
Sent: Monday, 7 May 2018 9:23 AM
To: Loch Castle <xxxx.xxxxxx@xxxxxxx.xxx.xx>
Subject: Melbourne Uni Waste [SEC=UNCLASSIFIED]

Hi Loch

CML wants this to be discussed at today’s SCF from 2-4 pm. Can you read and I will have a chat
late.

ARPANSA
Regards
JIm
by
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From:
Andrew Clegg
To:
Marcus Grzechnik
Cc:
Leannda Coote
Subject:
FW: ARPANSA - Waste Store Design for our review and approval [SEC=UNCLASSIFIED]
Date:
Thursday, 10 May 2018 12:07:31 PM
Attachments:
201808 - ARPANSA rev A.pdf
Hi Marcus,

Please review and lets discuss Friday if possible - to review and provide designers approval of
high level plan to continue with detailed design and associated documentation to go to
AusTender.

Regards

AC

From: s 47F - privacy

Sent: Thursday, 10 May 2018 9:47 AM
To: Andrew Clegg <xxxxxx.xxxxx@xxxxxxx.xxx.xx>
Subject: Fwd: ARPANSA

Hi Andrew
I hope that you are well, please find attached revised plans for your view and approval. I will contact you
tomorrow to discussed further.
As always happy to discuss and answer any questions.
Kind regards
s 47F - privacy
A. S. Building Consultants
by ARPANSA under FOI

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