BRIEFCTAFE/15/325
The Commissioner
Nuclear Fuel Cycle Royal Commission
GPO Box 11043
ADELAIDE SA 5001
Dear Commissioner
Royal Commission into the Nuclear Fuel Cycle
TAFE SA Submission
Issues Papers One, Two, Three and Four of the Nuclear Fuel Cycle Royal Commission
Please find enclosed responses from TAFE SA to some questions relating to potential skills
requirements and training from all four issues papers of the Nuclear Fuel Cycle Royal
Commission. We have extracted relevant questions from the Royal Commission’s issues
papers and repeated them in bold italics throughout this response.
Our responses relate to TAFE SA’s factual knowledge of the current training system, training
packages, and skills needs and the extent to which elements of our training system and
training capability may be utilised, adjusted or would need to be expanded if new industrial
activities related to different elements of the nuclear fuel cycle were to be undertaken.
Our responses are not intended to express any particular opinion or view about the relative
merits or otherwise of expanding the current level of permitted industrial activity in any of
the phases of the nuclear fuel cycle.
1. TAFE SA Comments on ISSUES PAPER ONE – EXPLORATION,
EXTRACTION AND MILLING, questions 1.6 and 1.10
Q 1.6 Does more need to be done now and in the future with factor inputs
(including skills and training, research, education and infrastructure) which are
relevant to decisions made to invest in new projects or expand those that already
exist? What capabilities and capacities would be required for the development of
new projects? What is the evidence that any specific deficiency influences new
TAFE SA Adelaide City Campus
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investment? What needs to be done to address any deficiency and how would it be
done?
Q 1.10 Would a future expansion of exploration, extraction and milling activities
create new environmental risks or increase existing risks? If so, are current
strategies for managing those new risks sufficient? If not, in what specific
respects? How would any current approach need to [be] changed or adapted?
TAFE SA currently delivers a number of mining qualifications which may be relevant to any
expansion of the exploration and extraction phases of the nuclear fuel cycle. Under each of
the qualifications below we have listed the names of units of competency which we currently
deliver that relate to risk assessment, including environmental risks and their management
and mitigation.
It is not within our expertise to provide information at this stage on what new or increased
risks may occur, however, we believe it is relevant to demonstrate, that if those risks are
identified they could be factored into and included in the current training requirements we
provide in relation to risk management and workplace health and safety for mining students.
Table 1 Current TAFE SA Delivery
Current TAFE SA
Currently Delivered at
Qualification Name
the following locations
Diploma of Applied
Geosciences (10263NAT)
This course provides
pathways for further study
into Bachelor of Science
Degrees in Mineral
Geoscience and Geology;
and Geophysics and
Applied Geology at the
University of Adelaide; or
the Bachelor of
Environment at Flinders
University.
Mining, Engineering and
Transport Centre at
Regency Campus
Units of competency delivered
within the qualification which
are relevant to risk assessment,
mitigation, controls and
management
Implement and maintain
environmental management plan
(RIIENV501A).
Geology units processes
- Apply geological process
knowledge (GEOPRO501A)
- Apply mineralogy and
petrology knowledge
(GEOMIN501A)
- Undertake research activities
(CHCPOL403C)
- Prepare reports
(AHCWRK503A)
- Manipulate and analyse GIS
data (CPPSIS5064A)
- Apply economic geology
knowledge and practices in the
workplace (GEOECO501A)
- Plan and Conduct Survey
Expeditions (CPPSIS4032A)
Certificate III in Mining
Exploration (RII30513)
Mining, Engineering and
Transport Centre Regency
Campus
Note: Although none of these
competency units mention the
nuclear fuel cycle, they are broad
units in which the nuclear
information could be included.
For example, in GEOMIN501A
– radioactive minerals can be
introduced.
In GEOECO501A – type
uranium deposits can be
discussed.
In CPPSIS5064A – obtaining
and analysing data can be
covered.
In CPPSIS4032A – a fieldtrip
around Flinders (Mt Gee), Four
Mile could be covered.
One of our current Geosciences
Lecturers has direct experience
in exploring for uranium in
South Australia.
- Identify and assess
environmental and heritage
concerns (RIIENV201D)
- Work safely and follow WHS
policies and procedures
(RIIWHS201D)
- Maintain and monitor site
quality standards
(RIIQUA201D)
- Conduct local risk control
(RIIRIS201D)
- Provide geological field
assistance (RIIEGS303D)
(introduction to minerals and
rocks hosting uranium can be
covered).
- Operate and Maintain
Instruments and Field
Equipment (RIIEGS301A)
- Collect routine site samples
(RIISTD202A)
- Participate in environmentally
sustainable work practices
(BSBSUS201A)
- Work safely and follow WHS
policies and procedures
(RIIWHS201D)
- Conduct local risk control
(RIIRIS201D)
Certificate II in Surface
Extraction Operations
(RII20213)
Whyalla, Port Augusta and
Mt Barker
Certificate II in Resources
and Infrastructure Work
Preparation (RII20113)
Whyalla, Port Augusta, Mt
Barker, Port Pirie, Kadina,
Regency Park and
Elizabeth Campuses
- Work safely and follow WHS
policies and procedures
(RIIWHS201D)
- Conduct local risk control
(RIIRIS201D)
- Identify and assess
environmental and heritage
concerns RIIENV201D
Certificate II in Civil
Construction (RII20713)
Tonsley Campus
Work safely and follow WHS
policies and procedures
(RIIWHS201D)
TAFE SA also trains many trades apprentices including electrical and engineering
apprentices who work in the mining industry. Their qualifications also require completion of
core workplace health and safety units such as Apply occupational health and safety
regulations, codes and practices in the workplace (UEENEEE101A); and Apply principles of
occupational health and safety in the work environment (MEM13014A), as well as additional
health, safety and environmental sustainability electives.
TAFE SA also notes that the Public Sector Training package contains a specific unit of
competency called Work safely with radioactive ores and minerals (PSPRAD202). Although
this unit of competency is not currently delivered by TAFE SA it could potentially be
packaged into the existing qualifications above or future qualifications to strengthen safe
work practices relating to the handling of radioactive ores and minerals. The unit is
specifically stated to apply to drillers, miners, loader operators, plant operators and samplers/
testers who undertake a variety of tasks, including undertaking ‘exploration surveys of
radioactive ore bodies’ or ‘extract, mill, process or pack radioactive ores, concentrates or
mineral products’.
2. ISSUES PAPERS TWO, THREE AND FOUR
TAFE SA has responded to the following questions in so far as training and the training
system is relevant to the issues raised by the Commission.
ISSUES PAPER TWO – FURTHER PROCESSING OF MINERALS AND
MANUFACTURE OF MATERIALS CONTAINING RADIOACTIVE AND NUCLEAR
SUBSTANCES
2.6 What are the processes that would need to be undertaken to build confidence in
the community generally, or specific communities in the design, establishment and
operation of such facilities?
ISSUES PAPER THREE – ELECTRICITY GENERATION FROM NUCLEAR FUELS
3.9 …What are the processes that would need to be undertaken to build confidence
in the community generally, or specific communities in the design, establishment
and operation of such facilities?
3.13 What risks for health and safety would be created by establishing facilities for
the generation of electricity from nuclear fuels? What needs to be done to ensure
that risks do not exceed safe levels?
ISSUES PAPER FOUR – MANAGEMENT, STORAGE AND DISPOSAL OF NUCLEAR
AND RADIOACTIVE WASTE
4.7 What are the processes that would need to be undertaken to build confidence in
the community generally, or specific communities in the design, establishment and
operation of such facilities?
4.9 …Are there strategies for managing those risks? If not, what strategies would
need to be developed? How would any current approach to management need to be
changed or adapted?
TAFE SA currently provides the following Workplace Health and Safety training as part of
nationally recognised qualifications or courses accredited by SafeWork SA. These courses
could potentially be expanded to meet changing industry needs and as required/directed by
SafeWork SA. Courses are also contextualised to meet the needs of specific industries,
employers and workplaces:
Table 2: Current TAFE SA Workplace Health and Safety Accredited Courses
Course name
Accrediting/ approving body
Certificate IV in Work Health and Safety
National training package/ ASQA
(BSB41412)
Diploma of Work Health and Safety
(BSB51312)
Health and Safety Representative (HSR)
Training Level 1
National training package/ ASQA
Health and Safety Representative Training
Level 2
TAFE SA is approved as a provider of HSR
training by SafeWork SA
Health and Safety Representative Training
Level 3
TAFE SA is approved as a provider of HSR
training by SafeWork SA
TAFE SA is approved as a provider of HSR
training by SafeWork SA
TAFE SA is not currently providing skills training in relation to processes described in Issues
Papers Two, Three and Four. However, we do note that the Australian Training System does
currently provide for a number of qualifications, skill sets or competencies which could boost
skills and confidence in relation to the operation of facilities and the processes described in
these three issues papers.
According to the official register on training.gov.au there are currently no RTOs in Australia
registered to deliver these qualifications or skill sets, however, RTOs including TAFE SA
could apply to extend their scope of registration to deliver these units within South Australia
if required.
To give the Commission a sense of the current available training package content we have
listed the qualifications, skill sets and units of competency below, with a description of the
aim and content of the training product. More detailed descriptions of the content can be
found on the training.gov.au website by searching using the particular national code of the
relevant skill set or unit of competency.
Table 3: Relevant National Training Content related to radiation safety
Qualification, Units of competency
Description of the aim and content of the
skill set or
included
qualification or unit
unit of
competency
relevant to
skills and
confidence in
operation of
facilities
PSPSS00029
- Work safely in a radiation
This unit applies to personnel who “require
Radiation
Environment
Safety Skill
Set
environment (PSPRAD201)
radiation protection and site safety training prior to
undertaking operational, technical, and/or
maintenance tasks in a radiation environment. It is
relevant to all workers who may receive
occupational exposures of greater than 1
millisievert per annum”.
The units states that those workers could include
those who work in “mines, construction sites,
hospitals and laboratories, for example:
- utility and site service personnel, such as
electricians, plumbers, fitters and equipment service
technicians
- site cleaners and maintenance workers
- operators of equipment that emits ionising
radiation
- those who handle and/or transport radioactive
material; and
- those who use radionuclides”.
PSPSS00031
Radiation
Technician
Safety Skill
set
- Perform basic radiation
safety measures
(PSPRAD310)
- Handle and transport
radioactive material
(PSPRAD303)
- Work safely with radiationsealed source equipment
(PSPRAD304)
- Monitor radiation (PSPRAD
401)
- Participate as a member of a
workplace emergency initial
response team
(PUAWER009B)
Contains seven compulsory
units of competency:
- Lead a quality audit
(BSBAUD503B)
- Consign radioactive
material (PSPRAD302)
- Monitor Radiation
(PSPRAD707A)
Coordinate radiation safety
(PSPRAD708A)
- Select, commission and
The target group of this skill set is: “Authorised
personnel who perform a radiation monitoring role
and who are trained to participate as a member of a
workplace emergency initial response team, and
who work:
- at a mine or plant that processes radioactive ore
and/or minerals
- with instruments that emit ionising radiation at
geotechnical, construction, mining and
manufacturing sites or analytical/research facilities
- in a laboratory or licensed facility that handles
radioactive materials
- in a nuclear facility”
PSP80212 Graduate
Certificate in
Radiation
Safety
This qualification is designed to support people
with responsibility as radiation safety officers
(RSOs). The qualification description states that
the candidate may work in an area that “provides
advice and guidance to others on radiation safety
matters and the development and implementation of
ionising radiation management plans. They will
have responsibility for developing and/or sustaining
a radiation safety culture and ensuring that all
legislative and organisational requirements are
met.”
maintain radiation measuring
instruments (SPRAD709A)
- Apply radiation safety
knowledge and develop and
implement ionising radiation
management plans
(SPRAD710A); and
Participate as a member of a
workplace emergency initial
response team
(PUAWER009B).
TAFE SA notes that there is also an accredited course, a Graduate Certificate in Radiation
Security, which is owned by the Australian Radiation Protection and Nuclear Safety Agency.
We understand that the Commonwealth Attorney General’s Department’s Protective Security
Training College has scope to deliver this qualification.
Further, the Australian Nuclear Science and Technology Organisation currently runs the
following potentially relevant short courses in New South Wales:
-
General Radiation Safety Officer (3 days)
Industrial Radiation safety officer (3 days)
Advanced Radiation Safety Officer (5 days and one evening)
TAFE SA notes that we currently provide significant levels of training to the electricity
generation industry such as apprenticeships through the Certificate III Electrotechnology
Electrician. This and other qualifications could potentially be packaged with additional units
of competency related to working safely in an organisation with a radiation safety culture.
We understand that we have many existing TAFE SA qualifications which are highly
relevant to the types of nuclear industry job roles that exist in the UK and the US and those
existing qualification could be packaged with additional nuclear industry contextualised
content to respond to changing needs. This includes qualifications in the following areas:
Carpentry; Air conditioning; Roofing and Cladding; Plumbing; Welding and Fabrication;
Mechanical and Electrical Maintenance; Machining; Laboratory Operations; Quality
Auditing; Project Management; Human Resources; Accounting and Finance (including
Material Accountancy); Health monitoring; Instrumentation and Control; Information
Technology; and Workplace Training and Assessment.