Navigating Mine Care and Maintenance: Essential Requirements, author Lauren Steen

When a mine enters care and maintenance (C&M), certain steps are necessary to meet radiation regulations, ensure safety, and manage assets effectively. These actions are essential whether the mine may reopen or its future is uncertain. Here’s an overview of the typical steps during the C&M phase.

General Considerations 

The Radiological Council (RC) shall be consulted in relation to the planned C&M actions with an emphasis on continuity of control of all radiation sources (e.g. gauges, xray devices, and lasers).

It is essential that each device is associated with a company registration (RS or RX) and a licence for an RSO (LS or LX) at all times.  This includes if a device is:

• Placed into storage onsite;

• Transferred to another entity (such as Radsol) for storage; or

• Disposed of by an authorised third party (such as Radsol).

Strong consideration should be given to what the future use of the devices will be.  For example:

• Sealed sources have a recommended working life (RWL), beyond which a source shall not be used – if a source only has 5 years left before it reaches its RWL, the best course of action is often to dispose of that source immediately;

• Although x-ray devices do not present a work health and safety (WHS) issue when stored, they require regular maintenance to ensure functionality when they are first used after a period of storage.

Consideration should be given to whether a disposal permit from RC is required.

Should the devices be remaining on-site, RC will advise of their ongoing requirements, which are likely to include:

• Accountability and security of the devices at all times;

• Relaxed requirements for the competence of the RSO / caretaker – they do not necessarily need to have undertaken a full RSO licensing course;

• Site radioactive material store shall be labelled with a radiation warning sign (trefoil) and the contact details for the RSO and / or the Responsible Person;

• Frequent visual inspection of devices, and providing photographic evidence to RC; and

• Portable devices, such as pXRFs shall be securely stored, and their location documented to prevent loss.

• In relation to fixed radiation gauges, the Code of Practice (RPS 13) states that all gauges shall be un-installed, however in recent times, RC has allowed a number of sites to leave their gauges remain in-situ and treat this as ‘storage’.  Gauges shall be locked in the “beam-off” position and assessed for compliance with the Gauges Code.

Consideration should be given to:

• Engagement of a radiation service provider to assist with initial C&M actions if the RSO is not available to do so;

• Ongoing annual wipe (contamination) tests of devices containing sealed sources;

• Documenting all actions such as the change of circumstances and change of RSO, if applicable.

Source Security Plan 

Security Enhanced Sources are subject to a Source Security Plan (SSP) – as detailed in the Security Code (ARPANSA RPS 11).  The Security Code considers the activity of each individual source, but also the aggregate activity of sources in any one location – such as all the sources located in the site radiation store.

It is critically important that the security aspects of such sources is considered early, and either a SSP be developed, if required.  Should an existing SSP be in place, it shall be updated and re-endorsed for the change of circumstances.

Again, consultation with the RC is highly recommended and assistance from a Radiation Service Provider should be sought if necessary.

In Summary 

Adhering to these requirements and recommendations ensures that a mine transitioning into a Care & Maintenance phase operates in compliance with regulations, mitigates risks, and maintains the integrity of its assets for potential future operations.

Clear communication with regulatory bodies and thorough documentation are key aspects of navigating this phase effectively.