Section 6 - Record keeping

6.1 Record keeping for sealed sources

It is essential that proper up-to-date records of all radioactive materials be maintained.

6.1.1 In the case of sealed sources, there will be no division of the radioactive material and thus the nominal activity will remain the same (i.e. the activity referenced to a quoted date - this is usually provided by the manufacturer of the sealed source). The nominal activity should be activity entered in the records at all times for sealed sources. Alteration of the identifying activity to take account of decay is likely to lead to considerable confusion and ambiguity in the records, especially if a number of similar sources of varying nominal activities and ages are involved. In this context it should be noted that the plate identifying the source will state the nominal activity.

6.1.2 It is of course necessary in many applications to know the actual activity. It is also useful for regulatory purposes to know the actual activity. It is thus essential that the date of the nominal activity be an integral part of the identifying nominal activity.

It may also be desirable to enter the actual activity in the records from time to time, but this should be entered as additional information and not as part of the source identification.

6.1.3 It would probably be best to have one only (plus duplicates) sealed source log for each station so that the Site RSO is able to determine at any time the status of all sealed sources on the station. At least one duplicate shall be kept and should be normally physically separated from the original to minimise the risk of both being accidentally destroyed or lost. It would seem appropriate, taking into account the current relative ease of communications between the Australian Antarctic Division (AAD) and stations, for a duplicate copy to be held by the Laboratory Manager, Australian Antarctic Division, 203 Channel Highway, Kingston,Tasmania and to be updated whenever an entry is made in the original.

The original log should be located on each station and the information safeguarded against loss by at least one duplicate log in another location. It is desirable that a duplicate station log be located at the AAD, Kingston, Tasmania which should be updated as soon as practicable after each new entry.

6.1.4 The sealed source log should show the following.

1. The nominal activity as purchased and the date of that nominal activity.
2. Details of the purchase including the form of the isotope, details of any encapsulations and details of any housings.
3. The location of any certificates relating to the source, any encapsulations and any housings (including location of type testing results of housings).
4. The types and energies of all emission from the radionuclide both as a bare radionuclide and as housed for use.
5. Details of shipping to Antarctica including off loading into store.
6. The location of a source in use and its current application, including the expected duration of its current application.
7. The storage location of a source not in use and its expected application and area of use.
8. Anticipated date of return to Australia of source.
9. The date of the routine safety checks carried out and whether satisfactory or unsatisfactory--if unsatisfactory, the log shall record the remedial action taken.
10. The date of the next routine safety check; or dates due, where different checks are carried out at different intervals.
11. The results of safety checks on the sealed source shall be logged. It is probably more convenient not to enter the actual details in the station log (the register of sealed sources) but to keep this information separately for each source. Any results of tests that will be required for later use or in an emergency should be kept in duplicate copy in a physically separate location from the original.
12. If the source is in storage pending anticipated use, how long it should be stored before being returned to Australia due to not actually being put into use.
13. Confirmation that copy of each entry has been entered into the duplicate log(s).
14. Details of shipping out of Antarctica.

6.2 Record keeping for unsealed sources

6.2.1 Current balanced records showing all operations of the isotopes shall be maintained and kept fully up-to-date.

6.2.2 Each original separate quantity of radioactive material is to have its own unique identifier as determined by the AAD, irrespective of whether or not the radioactive material belongs to the AAD. That identifier is to be semi-permanently marked on the radioactive material container and referred to in the record keeping. Where the original amount is later subdivided (e.g. in order to take a quantity into the field) each new source amounts will be assigned a unique identifier, the characters of which include the identifier characters of the parent source and each new container shall be semi-permanently marked with its identifier. 'Semi-permanent marking' in this context means marking which will remain legible for the duration of the use.

6.2.3 Each shipment of radioactive material is to have its own records, including materials the same as previous shipments. The records shall show for each original quantity of radioactive material, and for each later derived quantity of radioactive material.

1. The activity purchased and details of the purchase and the form of the radioactive material at time of purchase; or the activity and date of separation of source quantities derived from the original parent quantity.
2. Details of shipping to Antarctica including off loading into store.
3. The nominal activity of that radioactive material. This will normally be the quoted activity at time of purchase. However, it should be the actual activity landed in Antarcticawhere there is a material discrepancy (i.e. not due to decay in transit) between this figure and that of the quoted activity at time of purchase. Any discrepancy shall be fully explained in the log before using the actual activity landed (eg. not all the isotope purchased was shipped; isotope purchased so long ago that activity as shipped is markedly different from that originally purchased). At all future dates in the log the amounts listed under various categories shall sum to equal the nominal activity of that radioactive material; where the half-life is sufficiently short as to require adjustment to volumes drawn during the life of the project, the amount decayed may be entered in order to properly balance the books.
4. All operations involving the radioactive material. An entry might typically record the activity remaining in store, the activity withdrawn for the particular experiment on that date, the amount injected, the amount estimated to be withdrawn from the subject animal, the amount not recovered from the subject animal, the amount added to waste stored, etc. The actual categories to be summed will need to vary according to the particular experiment but all accounting shall address all the various paths followed by the radioactive material and the accounting shall balance. It is recognised that some categories will be estimates only and cannot be precise. In this case, footnotes in the log should indicate the assumptions on which the estimates were made and realistic error bounds for those estimates. For the purposes of this log it is not necessary to follow the paths of releases to the environment. This may be covered by one category (eg. 'activity not recovered from animal'). Environmental release paths are to be dealt with in the environmental impact report rather than in the record keeping log.
5. All log entries shall be of activity. This is a log of the amount of radioactivity and weight or volume entries are not acceptable. SI units are required.
6. The storage location of the source and its expected application and areas where it will be used.
7. The form of the isotope and storage and shielding requirements, e.g. not allowing liquid radioactive material to freeze where this would damage the container or otherwise promote leakage).
8. Anticipated date of return to Australia of samples, waste, unused isotope, etc.
9. When routine checks carried out and whether satisfactory or unsatisfactory. If unsatisfactory the log shall record the remedial action taken.
10. Location of copies of results and details of safety checks (it would probably be better not to enter that information into this log).
11. If the radioactive material is in storage pending anticipated use, how long it should be stored before being returned to Australia due to not actually being put into use.
12. Confirmation that copy of each entry has been entered into the duplicate log(s).
13. Details of shipping out of Antarctica.
14. A duplicate copy of the records log is to be maintained and kept safely separate from the original so as to preserve the records in the event of one of the logs being destroyed. The original should normally reside in the radioactive store.
15. Where operations with the radioisotope make precise knowledge of the amount in category impossible, reasonable estimates shall be made and the rationale of those estimates noted in the log. For instance, the amount of radioisotope injected into a seal should be known accurately but the amount withdrawn when taking a blood sample will usually be an estimate until the sample is measured.

6.2.4 All accidents and incidents shall be fully documented. The log shall note the accident or incident with brief details and shall identify the existence of the full report so that it may be obtained for the benefit of future users. Minor unsealed radionuclide contamination within the controlled area for use shall not constitute an incident provided that the log records details of the contamination, the remedial action taken, and provided that the remedial action has been successful.