PDF version: ARPANSA Corporate Plan 2022-23 | HTML version: below
Acknowledgement of Country
The Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) respectfully acknowledges Australia’s Aboriginal and Torres Strait Islander communities and their rich culture and pays respect to their Elders past and present. We acknowledge Aboriginal and Torres Strait Islander peoples as Australia’s first peoples and as the Traditional Owners and custodians of the land and water on which we rely.
We recognise and value the ongoing contribution of Aboriginal and Torres Strait Islander peoples and communities to Australian life and how this enriches us. We embrace the spirit of reconciliation, working towards the equality of outcomes and ensuring an equal voice.
CEO foreword
I am pleased to present ARPANSA’s 2022–23 Corporate Plan.
This plan outlines how our key strategic activities will support the agency’s purpose. These activities represent our significant areas of work and builds on the significant steps we have taken to modernise and mature our systems, facilities and planning information. ARPANSA’s role is diverse, with many integral and complex functions that align our resources and enable us to achieve our purpose.
Every day, Australians are exposed to radiation from a wide range of natural sources, including outer space (cosmic radiation), the sun (ultraviolet radiation), radon gas that is released from the bedrock in our environment, and other naturally occurring radioactive substances that are present in food, soil and water. We are also exposed to artificial (human-made) sources of radiation that are used across a broad range of industrial, communication, medical (diagnostic and therapeutic) and research activities.
The use of radiation in medical procedures, is now the largest source of exposure to the population, with powerful sources of radiation often required for cancer treatments. There are also workplaces, such as mines, radiopharmaceutical production facilities, and hospitals where workers may be exposed to radiation of either natural or artificial origin. With continued development and implementation of new technologies in Australia that involve radiation, ARPANSA must also monitor these developments to understand the risks they may pose.
Working together with ARPANSA’s dedicated and highly capable staff, I am looking forward to continuing our service to the Australian community. We will endeavour to deliver according to the targets outlined in this plan, with the aim of protecting the Australian community and environment from the harmful effects of radiation.
Statement of preparation
I, Gillian Hirth, as the accountable authority of the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA), present the 2022–23 ARPANSA Corporate Plan, which covers the period of 2022–23 to 2025–26, as required under paragraph 35(1)(b) of the Public Governance, Performance and Accountability Act 2013 (PGPA Act).
Introduction
Our purpose
Our purpose is to protect the Australian people and the environment from the harmful effects of radiation.
Our role
ARPANSA is the Australian Government’s primary authority on radiation protection and nuclear safety. We are:
| An independent regulator | A health advisor | A service provider |
|---|---|---|
| We are the independent regulator of Commonwealth entities that use or produce radiation. Using a risk-informed regulatory approach, we ensure that licensees take responsibility for protection of people and the environment from the harmful effects of radiation. | We build and maintain expertise in measurement of radiation and assessment of health impacts, including the assessment of risks and responses to radiation incidents. We provide high quality advice to the government and the community. | We offer high quality services for the purpose of protection against the harmful effects of radiation. |
Outcomes
This plan is directly aligned to the relevant outcomes and programs set out in the Department of Health and Aged Care 2022–23 Portfolio Budget Statements (PBS), specifically:
- Outcome 1: Protection of people and the environment through radiation protection and nuclear safety research, policy, advice, codes, standards, services and regulation
- Program 1.1: Radiation protection and nuclear safety
- Program 1.8: Health Protection, Emergency Response and Regulation.
The Department of Health and Aged Care (Health) contributes to Outcome 1, as Health has strategic regulatory policy and national leadership responsibility for radiation protection and nuclear safety, with particular regard to the regulatory framework. This includes best practice for radiation and nuclear safety health technologies.
Business planning and governance
Our Corporate Plan is the cornerstone of our business planning, budgeting and reporting process that integrates agency-wide initiatives against our Key Activities. The plan demonstrates the interdependencies of all planning information and provides context as to how resources will be prioritised to meet our purpose.
Input
The PBS is primarily a funding document. It sets out funding allocated to the department to achieve the outcomes set by government. It also details how we will measure the impact of that expenditure on the Australian community.
Planning
The Corporate Plan is primarily a strategic planning document. It sets out our purpose, the Key Activities we will undertake to achieve our purpose and the results we expect to achieve over the next four years.
Results
The Annual Performance Statements are produced at the end of the reporting cycle and provide an assessment of how we have progressed towards achieving our purpose. It includes results against planned performance included in the PBS and Corporate Plan.
Figure 1: How ARPANSA’s planning, and performance cycle works
Governance
The Australian Radiation Protection and Nuclear Safety Act 1998 (ARPANS Act) and the PGPA Act are the foundation of ARPANSA’s governance process. This Corporate Plan is complemented by our internal business plan and governance structure, which facilitates risk informed decision-making, the consistent application of resourcing priorities and the escalation and resolution of issues. Our reporting arrangements ensure section and team activities are aligned with our purpose and efficiently undertaken.
As CEO of ARPANSA, Dr Gillian Hirth is responsible for the Agency’s activities, policy directions and efficient performance. ARPANSA’s core governance structure includes three statutory advisory bodies and two senior committees. Our extended governance structure includes internal management committees that support our Executive Group1 in providing oversight and accountability.
The CEO is advised by three statutory advisory bodies established by the ARPANS Act:
Radiation Health and Safety Advisory Council
The role of Radiation Health and Safety Advisory Council (Council) in relation to radiation protection and nuclear safety is to:
- identify emerging issues
- examine matters of major concern to the community
- consider the adoption of recommendations, policies, codes and standards
- advise and report to the CEO, at the CEO’s request or as Council considers appropriate, radiation safety matters.
Radiation Health Committee
The role of Radiation Health Committee in relation to radiation protection is to:
- advise the CEO and the Council
- develop policies and to prepare draft publications for the promotion of uniform national standards
- formulate draft national policies, codes and standards for consideration by the Commonwealth, the states and the territories
- review national policies, codes and standards to ensure that they continue to substantially reflect world best practice
- consult publicly in the development and review of such policies, codes and standards.
Nuclear Safety Committee
The role of Nuclear Safety Committee is to:
- advise the CEO and the Council on matters related to the safety of nuclear installations and the safety of controlled facilities
- review and assess the effectiveness of standards, codes, practices and procedures
- develop detailed policies and prepare draft publications to promote uniform national standards
- report to the CEO on matters related to safety.
At the strategic level, the CEO is advised by two key committees:
Strategic Management Committee
The Strategic Management Committee (SMC) is focused on the medium and long-term future of the Agency rather than ongoing day-to-day business. The SMC considers the threats and opportunities that may influence the strategic direction of the agency and contributes at key times throughout the year to ARPANSA’s planning and performance framework.
Audit and Risk Committee
The PGPA Act requires Commonwealth entities to establish an audit committee. ARPANSA’s Audit and Risk Committee provides independent assurance and advice to the CEO on the Agency’s financial reporting, performance reporting, system of risk oversight and management and system of internal control.
Figure 2: ARPANSA governance and advisory structure
Our operating context
Environment
To inform our corporate planning process we have evaluated the factors that exist, and are anticipated, within our environment. This has allowed us to plan a proportionate response and consider our capacity to manage their impact. Below are our five areas of focus and our response.
| Areas of focus | How it impacts us | What we can do |
|---|---|---|
| Societal considerations | Ionising and some non-ionising radiation2 is known to damage cell DNA, leading to potentially serious health effects such as cancer, which contributes significantly to the national health and economic burden. Skin cancer, predominantly caused by ultraviolet (UV) radiation from the sun, is one of the most preventable forms of cancer and, if detected early, often treatable. Australia’s skin cancer incidence and mortality rates are among the highest in the world3 with rates expected to rise as our population ages. It is heavily influenced by factors such as our climate, population demographics, our proximity to the equator (high UV levels) and our social attitudes to the outdoors. | ARPANSA works with stakeholders to promote ‘SunSmart’ practices and influence behaviour, as well as providing other services and publishing information to improve people’s understanding of the risks associated with radiation. ARPANSA works closely with the medical sector to ensure radiation exposures delivered to patients in medical imaging are as low as reasonably achievable, while still delivering clinical objectives. ARPANSA also maintains the Australian Primary Standard for absorbed dose and calibrates hospitals’ dose detectors against this standard, to ensure that the correct amount of radiation is being delivered to more than 70,000 cancer patients being treated using linear accelerators (linac) in Australia each year. |
| Regulatory landscape | Our regulatory landscape is influenced by government plans and public expectation regarding the management of radioactive waste, including disposal. The Australian Government is in the process of establishing a National Radioactive Waste Management Facility (NRWMF) in South Australia. The facility, intended only for waste of domestic origin, will manage the disposal of low-level radioactive waste, and serve as a storage facility for intermediate level waste held by the Commonwealth. Siting, construction and operation of the facility requires licences issued by ARPANSA, which in turn requires significant planning and resourcing within ARPANSA. Radiation protection and nuclear safety is a specialised scientific discipline and so it presents a complex operating environment, with longstanding and emerging challenges. | ARPANSA regulates Commonwealth entities who operate nuclear facilities and use radiation. We take responsibility by promoting safety through the research we undertake, and the advice and services we provide. Fundamentally, our objective is to protect the Australian people and the environment from the harmful effects of radiation, part of which is achieved in partnership with radiation regulators in states and territories and achieved through our regulatory framework. |
| Strategic Australian government initiatives | In 2021 an enhanced trilateral security partnership was announced between Australia, the United Kingdom and the United States (AUKUS). In support of this partnership, a multi-agency Nuclear Powered Submarine Taskforce, led by the Department of Defence, was established to identify the optimal pathway to deliver at least eight nuclear-powered submarines for Australia4. Specialists and experts from ARPANSA are embedded within, and closely engaged with, the Taskforce. Supporting the taskforce has already required growth of ARPANSA’s workforce, and while currently undetermined, any of the viable options for the regulation of a nuclear submarine program will require further growth in ARPANSA’s resources in the future. | ARPANSA is providing direct advice to the Australian Government on aspects of nuclear stewardship, in particular regulation of nuclear safety and radiation protection. ARPANSA is considering the current impact on resourcing and infrastructure from the AUKUS agreement and will make further assessments on the impact of this work so we can continue to provide support as we gain clarity on our future role. |
| Telecommunication advancement | Exposures to other sources of radiation found in our environment are generally low but variable. As technology advances, ARPANSA continually reviews emerging science about risks from ionising and non-ionising radiation and engages with stakeholders, including community groups, to inform risk assessments. The continued advancement and use of electromagnetic energy (EME) in wireless services such as 5G will form the focus of our specialised research program over the coming years. | ARPANSA will assess EME exposure from existing and new telecommunications technologies, like 5G, and engage international bodies (such as the World Health Organization), to inform standards and provide expert scientific advice. A major feature of the new program is the construction of a new anechoic chamber that will cater for millimetre wave frequencies that will be used in 5G technologies, and beyond. |
| Pandemics and technology | In line with the broader trends in technological developments, the pandemic has highlighted the role of science and bolstered public trust in scientists, this level of trust is foundational to the position ARPANSA occupies nationally and internationally. Correspondingly, it has also instigated a social shift in how businesses operate and engage internationally and accelerated the adoption of digital connectivity. | The agency will also continue its focus on improving our digital infrastructure and business productivity. During the COVID-19 pandemic, the majority of ARPANSA staff worked from home, while our on-site workers ensured key services were maintained. In 2022–23, as we adapt to COVID-normal, the agency is committed to the development of a workplace culture that supports flexible working arrangements. ARPANSA is exploring the broader strategies required to support an agile and inclusive workforce, in a hybrid working environment. |
Capability
Workforce
ARPANSA’s requirements of its workforce are at a critical juncture in its journey as a national and international source of expertise and leadership in radiation protection, nuclear science and as a nuclear safety regulator. Many of our staff are acknowledged as international leaders in their fields, and our contributions to global forums, frameworks and knowledge development are considerable. Our culture is characterised by a deep commitment to ARPANSA’s purpose, and our staff demonstrate continued strong levels of engagement in the work we do.
There are a range of challenges, risks, commitments and opportunities with implications for ARPANSA’s ability to ensure sustainable capability and reputation as an employer of choice. Over the next two years ARPANSA will implement its Workforce Strategy 2022–25, which takes a holistic enterprise view and identifies the priorities that will support developing a workforce that can adapt emerging challenges. It sets out the workforce implications of current drivers, and the activities that will enable sustainable capability and capacity such as the ARPANSA Graduate Program. The Strategy focuses on three key priorities:
- Expertise and capability
- Health and wellbeing
- Diversity, equality, inclusion and integrity
We seek to deliver against three core outcomes – sustainable capability, employer of choice, and strategic alignment, with implementation governed by project management methodologies.
Infrastructure
ARPANSA manages and maintains a number of business-critical specialised assets and infrastructure, including buildings, laboratories, instrumentation and mobile equipment. The agency has a detailed program of works to better support the technology, accommodation and facility needs of the agency in the most cost-effective manner. The program of works comprises:
- ongoing facility maintenance and refurbishment
- replacement of assets and equipment that are nearing end of life
- upgrade of infrastructure to modern standard.
ARPANSA has made significant progress with the upgrade of our physical security systems to ensure we maintain secure and continuous delivery.
ARPANSA commenced the construction of a new anechoic chamber and the procurement of associated field measurement equipment as part of our enhanced EME program in 2021–22. These upgrades, which will be completed in 2022–23, will enable ARPANSA to deliver better information and education, to build the Australian community’s understanding regarding the health implications of technologies that utilise EME.
ARPANSA is currently in the process of replacing the older of its two linear accelerators (linacs), ensuring ARPANSA can continue to mitigate patient risk in a rapidly developing area of clinical practice. The linacs are essential infrastructure for the Primary Standards Dosimetry Laboratory and the Australian Clinical Dosimetry Service, which ensures any Australians undergoing medical procedures receive the correct amount of radiation. The new linac installation and associated building refurbishment is anticipated to be completed in 2022–23.
Information and communication technology
ARPANSA’s technology, information and data systems strategy support the delivery of our regulatory, scientific, consultative and business operations. As part of our Digital Technology Plan, ARPANSA will continue to implement digital technology initiatives to enhance service delivery, improve customer experience and digitally integrate business solutions. ARPANSA will be delivering in-house digital cross-skilling programs to increase ARPANSA’s digital maturity. We will also continue to strengthen our cyber security capability through further investment in our cyber security improvement strategies.
In line with the Australian Government’s overall strategy to transform our service delivery via customer-centric business systems and as part of our Platforms and Systems project, in 2022–23 ARPANSA will continue the implementation of the Laboratory Information Management Systems that will enhance the management and delivery of our scientific services to ensure a responsive and sustainable future. The project will also commence the design and development of a Regulatory Administration Database in 2022–23.
Scientific and technical expertise
As our role and regulatory environment evolves, we will strengthen our technical expertise to ensure the safe and practical application of scientific principles and solutions. ARPANSA will continue to promote a culture that ensures our advice maintains scientific integrity and is based on high quality science, technology, engineering, and mathematics. We will continue to encourage and enhance innovation and research through our collaboration and partnerships with key stakeholders to ensure relevant, trustworthy and high-quality research is undertaken to support radiation protection, nuclear safety, safety in medical uses of radiation and regulatory activities.
ARPANSA has commenced the assembly and commissioning of a new primary standard for megavoltage ionising radiation for Australia. The new standard will be the new dose reference for all radiotherapy throughout Australia, and all patient treatments will be traceable to it. The new Primary Standard will be capable of measuring proton beams, ensuring dose accuracy for this critical industry and enabling advanced audit development for at least two decades.
Risk Management
ARPANSA recognises that risk is inherent and can present both opportunities and threats to the achievement of our Key Activities and broader legislative mandate. Our risk management framework currently in place consists of a policy, procedures, and appropriate tools and templates. To support best practice, ARPANSA will be reviewing this framework and will work to implement a whole of agency platform to provide a more effective system for the management of risks and to foster more transparent monitoring and reporting agency wide. ARPANSA is maturing our strategic approach to ensure it aligns with the international standard ISO 31000:2018 – Risk Management, the PGPA Act and the Commonwealth Risk Management Policy.
ARPANSA’s risk appetite and tolerance is influenced by the nature of our activities, emerging priorities and our multifaceted operating environment. ARPANSA’s Executive Group recognises that to support operational decision making, a low-moderate level of risk taking may be necessary to steadily mature as a contemporary regulator and efficient entity.
Our operating environment is becoming more dynamic, particularly in light of evolving strategic Australian government initiatives. This shifting landscape has heightened our risk profile, and consequently instigated a proportionate adjustment to our risk appetite. To ensure we continue to operate effectively and ultimately achieve our purpose, in areas such as our workforce capacity, we will acknowledge a greater risk appetite in supporting and developing new ways of doing things.
ARPANSA has identified six key strategic risks and the associated strategies that enables us to manage them:
| Risks to our Key Activities | Examples of how we manage these risks |
|---|---|
Loss of confidence in ARPANSA Perceived or actual failures in ARPANSA as a government entity and regulator meeting our obligations or mandate Impact: The Australian Government or public develops a perception that we are an ineffective entity and regulator |
|
Regulatory capture ARPANSA regulatory function is perceived to be subject to regulatory capture Impact: Compromise (real or perceived) in our regulatory decision making |
|
Cyber security event An information security incident Impact: Reputational damage or compromise of information security |
|
Failure to manage Workplace Health and Safety (WHS) risks ARPANSA or its staff fail in their respective duties under the Work Health and Safety Act 2011 and Work Health and Safety (WHS) Regulations Impact: Reputational damage, loss of life or lost time injury |
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Failure to recruit, retain and support a skilled workforce Inability of ARPANSA to competitively recruit, retain and support a highly specialised workforce across scientific, regulatory and corporate support Impact: Inability of ARPANSA to achieve our objectives, knowledge loss, reduced productivity and effectiveness |
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Long term financial sustainability of ARPANSA Unsustainable funding or significant impact to revenue of services Impact: Unviability of ARPANSA’s commercial service offerings or inability of ARPANSA to achieve our mandated objectives |
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Cooperation
As the independent regulator of Commonwealth entities who use or produce radiation, ARPANSA is focused on ensuring its safe and secure management. However, ARPANSA does not perform this role in isolation.
Other Commonwealth entities
Departments and agencies – ARPANSA’s main partner is our portfolio department the Department of Health and Aged Care, where we provide specialist advice to influence the development of health policy and outcomes.
ARPANSA also partners with a range of other government departments that develop policies affecting radiation protection and nuclear safety:
- Department of Climate Change, Energy, the Environment and Water
- Department of Infrastructure, Transport, Regional Development, Communications and the Arts
- Department of Industry, Science, Energy and Resources
- Safe Work Australia
- Department of Foreign Affairs and Trade
- Department of Defence.
Regulators – There are other Commonwealth regulators with a safety or security focus, encompassing a broad range of activities involving radiation. Coordination mechanisms have been established with these agencies through either memorandums of understanding (MoUs) or regular meetings, which aim to reduce and manage areas of uncertainty, or any areas of overlap that could create conflicting requirements for authorised parties.
- Australian Safeguards and Non-Proliferation Office
- Comcare
- Department of Climate Change, Energy, the Environment and Water
- Civil Aviation Safety Authority
- Australian Maritime Safety Authority
- National Offshore Petroleum Safety and Environmental.
State and territory radiation safety regulators
ARPANSA has a legislated function to promote uniformity of radiation protection and nuclear safety policy and practices across all jurisdictions. To effectively deliver this, ARPANSA proactively engages with the state and territory radiation safety regulators and has established MoUs on cooperative work to facilitate collaboration. One of the main avenues for cooperation is the Radiation Health Committee, which provides a forum to collaborate and jointly develop radiation protection codes and standards. ARPANSA also works closely with the Environmental Health Standing Committee (enHealth) and its Radiation Health Expert Reference Panel (RHERP) in the development of national policies and strategies. These partnerships enable ARPANSA to maintain national guidance that is fit for purpose and advocate for the consistency of regulation across all Australian jurisdictions.
Non-government stakeholders
ARPANSA provides specialist advice, services and research to a suite of non-government stakeholders including universities, supporting a research grant through Royal Melbourne Institute of Technology (RMIT), and health organisations such as the Cancer Councils of Australia, Victoria, and New South Wales. ARPANSA seeks to leverage these cooperative arrangements to further expand and promote research related to health impacts of radiation and health protection.
International partners
ARPANSA’s international cooperation includes a range of multilateral and bilateral partnerships and networks. These partnerships enable ARPANSA to shape international best practice for regulation and advice on radiation protection and nuclear safety.
- One of ARPANSA’s most prominent international partners is the International Atomic Energy Agency (IAEA). ARPANSA representatives sit on committees that develop safety standards for nuclear, radiation, waste and transport safety, and for emergency preparedness and response. Agency specialists also support dedicated IAEA training courses on a range of issues.
- ARPANSA closely cooperates with the World Health Organization, where the agency is a Collaborating Centre for radiation protection.
- ARPANSA works with the Comprehensive Nuclear Test Ban Treaty Organization (CTBTO) through the management of our region’s radionuclide detection network.
ARPANSA representatives hold positions on international scientific bodies where we review and endorse various standards supporting international best practice. These include:
- United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR)
- International Commission on Radiological Protection (ICRP)
- International Commission on Non-Ionizing Radiation Protection (ICNIRP).
To foster openness, transparency and a commitment to improvement, ARPANSA invited a cohort of our international peers as part of the IAEA Integrated Regulatory Review Service, to evaluate our regulatory infrastructure for safety against IAEA safety standards. Australia has been working to implement the findings from the peer review mission, which included 23 recommendations and 12 suggestions for improvement. A national action plan that provides a governance structure for monitoring progress was developed and endorsed by the Australian Health Protection Principal Committee (AHPPC). Work is ongoing to address as many findings as possible and prepare for the follow up mission scheduled for October 2023.
Performance
ARPANSA’s performance structure has been established to ensure transparency, clarity and accountability in how we assess our progress towards achieving our purpose. To assist us in achieving our purpose, ARPANSA’s has identified 4 Key Activities, representing our significant areas of work, that contribute to delivering radiation protection and nuclear safety outcomes to the Australian community:
- Initiate, maintain, and promote frameworks for protection and safety
- Undertake research and provide expert evaluations, advice, and services
- Ensure effective and risk‑informed regulation
- Enhance organisational innovation and capability
Our performance information is arranged under the Key Activities in the following format:
- initiatives that we will undertake to support our key activities
- performance measures so that our achievements can be assessed over time
- targets that reflect the main outcomes we want our key activities to achieve
- methodologies to monitor results and track overall progress.
To ensure all activities contribute to achieving our purpose we have also integrated:
- Portfolio Budget Statement measures to provide greater context and correlation between agency’s planning documents
- Projects that demonstrate how our operational and strategic priorities align with our purpose.
In line with agency governance processes, the measures and projects outlined in our Corporate Plan will be monitored and reported to our Executive Group and the Audit and Risk Committee on a quarterly basis. Our annual performance statement, as part of the 2022–23 ARPANSA Annual Report, will provide a detailed perspective of performance results and utilise case studies as a qualitative evaluation of significant initiatives to provide a holistic perspective of agency performance.
1. Initiate, maintain and promote frameworks for protection and safety
ARPANSA will develop our scientific knowledge to support the frameworks for radiation protection and nuclear safety. These frameworks sit across various sectors, nationally and internationally and provide guidance that facilitates optimisation of protection against radiation exposure and any associated health impacts. Proactively, we will continue to support the national skin cancer prevention program, to reduce the incidence of skin cancer in Australia, and cooperate nationally and internationally to support global skin cancer prevention initiatives.
Medical procedures in diagnosis, intervention and therapy are the largest source of ionising radiation exposure to the Australian population. Through our Australian Clinical Dosimetry Service (ACDS) ARPANSA aims to ensure that all use of radiation in medical procedures is performed as accurately as possible and takes account of patient safety. We engage with this aim through calibration, auditing, education and a diagnostic survey program, all of which demonstrably influence practices and behaviour of our stakeholders.
ARPANSA operates the Australian National Radiation Dose Register (ANRDR) for the storage and maintenance of occupationally exposed workers radiation dose records. This enables workers to track their lifetime radiation records across different employers and states. ARPANSA publishes insights into industry trends and comparisons across different work practices to show just how effective radiation protection programs are and help in establishing guidelines to support optimisation of worker protection.
ARPANSA will continue work on its EME program through continued implementation of the EME Action Plan published in 2020. This involves undertaking and partnering on new EME research, undertaking measurement studies, and providing expert advice on EME and health. This program of work will create clear, reliable and reputable information accessible to all Australians.
We will continue to enhance our international relationships, which plays an important role in our ability to deliver against this key activity, particularly as we support meeting Australia’s international obligations for radiation protection, nuclear safety and accident reporting. We will continue to focus on securing valued international partnerships and building our reputation with key international stakeholders.
ARPANSA will support the Nuclear-Powered Submarine Task Force in providing assessment and advice on radiation protection and nuclear safety and relevant aspects of stewardship. This advice will inform government in ensuring the framework for radiation protection and nuclear safety of nuclear-powered submarines is robust and in line with international best practice. ARPANSA has received funding from the Department of Defence to support this effort, and resources have been directed to examine regulatory frameworks, environmental monitoring, dosimetry and emergency preparedness and response.
ARPANSA will support national and regional arrangements for preventing and responding to accidents and security events that may lead to radiation exposure and maintaining and enhancing our emergency response systems to protect the Australian community in the case of a radiological or nuclear event. As part of this, the Agency will continue to work collaboratively to address the radiation emergency findings from the 2017 World Health Organization (WHO) Joint External Evaluation of International Health Regulations.
Initiatives
- Develop and communicate risk-informed protection strategies
- Develop Codes and Standards, and clarify regulatory expectations for nationally consistent implementation
- Promote the safe and effective use of medical radiation
- Engage stakeholders to improve radiation safety, enhance quality of decisions, standards and information material
- Provide assessment and advice to the Nuclear-Powered Submarine Task Force on relevant radiation protection and nuclear safety aspects of stewardship.
Performance measures
We will demonstrate our performance through the following measures:
| No | Measure | 2022–23 target | Methodology | 2023–24 | 2024–25 | 2025–26 |
| 1* | Number of Diagnostic Reference Level (DRL) surveys per category are sufficient to infer national characteristics per annual survey period | >2400 surveys received per calendar year | Examination of survey data submitted to the National Diagnostic Reference Level Service (NDRLS). This helps avoid excess radiation dose associated with diagnostic imaging to patients | |||
| 2* | Radiation doses of occupationally exposed workers indicates optimisation of radiation protection | Worker radiation dose trends, published annually, indicate optimised radiation protection | The ANRDR database collects and stores worker dose information. Radiation doses for a range of dosimetric quantities and exposures will be assessed on a quarterly basis. The data will be used to generate annual statistics and exposure trends, that will improve safety for occupationally exposed workers in Australia | |||
| 3 | Influence international radiation protection, nuclear safety and security to facilitate compliance with related agreements and treaties | Submission of two national reports Proactive collaborations are sought with key international stakeholders, to foster international agreements, best practice and compliance | Determined through submissions of national reports and participation in the peer review activities associated with the Joint Convention on the Safety of Spent Fuel Management and the Safety of Radioactive Waste Management (Joint Convention) and the Convention on Nuclear Safety (CNS). This measure will also establish a baseline to track contributions that influence international safety frameworks and active engagement in the international radiation and nuclear safety sector | |||
| 4* | Provide dosimetry support and measurement services to radiotherapy clinics | 45 audits delivered according to schedule | Measured progressively and reported quarterly based on signed audit reports. The National radiation oncology dosimetry audit program ensures the safety of cancer patients receiving radiation therapy treatment across Australia and New Zealand |
* Indicates reporting periods where performance will be measured against an unchanged target.
PBS related performance measures
| No | Measure | 2022–23 target | Methodology | 2023–24 | 2024–25 | 2025–26 |
| PBS-1 | Provide high‑quality advice to government and the community on health, safety and environmental risks from radiation | Identify, assess and communicate health, safety and environmental risks from radiation to the Australian Government and community through research, communication, provision of radiation protection services, and community consultation and awareness activities Provide information, advice and standards on electromagnetic energy and health to the Australian Government and community through exposure assessment, research, facility upgrades and engagement with international health authorities | Examination of survey data submitted to the National Diagnostic Reference Level Service (NDRLS). This helps avoid excess radiation dose associated with diagnostic imaging to patients | |||
| PBS-2 | Provide emergency preparedness and response systems for a radiological or nuclear incident | Emergency preparedness and response systems for field, network and laboratory measurements, and information management and decision support systems, are calibrated, tested and exercised to ensure availability, and personnel are trained | Based on data collected via network and laboratory measurements, as well as information management and decision support systems |
We will also demonstrate our performance through delivery of the following projects:
| Project | Description | Estimated completion date |
| EME Program | Build and operationalise an anechoic chamber | Dec 2022 |
| Nuclear Powered Vessels Reference Accident | As commissioned by the Department of Defence – update the Reference Accident used to assess the suitability of Australian Ports for visits by nuclear‑powered vessels (NPV) | Jun 2024 |
| Australian Radiation Incident Register (ARIR 2.0) | Enhance engagement with radiotherapy stakeholders to increase the reporting of radiation incidents and near misses into the existing ARIR. This will include the development of a user focused digital system | Dec 2024 |
2. Undertake research and provide expert evaluations, advice and services
ARPANSA is responsible for providing accessible, evidence-based, and risk‑informed advice to the Australian Government, industry, and the public through the work we do. Our aim is to promote continuous improvement and provide useful and current information to a broad range of audiences so practices can be optimised.
To aid us in the delivery of this activity we strive to understand our stakeholder’s needs and meaningfully engage on topics of interest. ARPANSA builds partnerships with a range of stakeholders in targeted areas of scientific research by undertaking research, surveys and studies to enhance our understanding of the effects of radiation. ARPANSA promotes education through our Talk to a Scientist program, which directly connects members of the public with ARPANSA scientists, to address questions or concerns about radiation and nuclear issues.
ARPANSA is responsible for carrying out Australia’s radionuclide monitoring obligations to the Comprehensive Nuclear-Test-Ban Treaty. The Treaty aims to eliminate nuclear weapons by restricting the development and qualitative improvement of new types of nuclear weapons, playing a critical role in working towards a safer and more secure world.
ARPANSA also offers a range of high-quality National Association of Testing Authorities (NATA) accredited scientific activities and services to assess the risks to people and the environment from exposure to radiation, and to reflect this understanding in advice and guidance to the public, government, and other stakeholders. Our Personal Radiation Dosimetry Service is the only NATA accredited service that operates all its services onshore in Australia. ARPANSA provides laboratory testing services to Australian and international customers for sunglasses, shade cloth, window films, clothing, and fabrics to determine, and certify via ultraviolet protection factor (UPF) swing tags the level of protection these materials provide against ultraviolet (UV) radiation from the sun. We also provide calibration services for a range of radiation meters.
Our Primary Standard Dosimetry Laboratory (PSDL) maintains the primary standard for radiation dosimetry for Australia and is in the process of assembling a new Primary Standard with proton capability. The PSDL collaborates with the ACDS to develop auditing and measurement techniques to reduce the radiation risk to patients.
In delivering all these services, ARPANSA strives to ensure that its capabilities and expertise are high quality, sustainable and reflect best practice in radiation protection.
Initiatives
- Undertake hazard identification, exposure analysis and risk assessments for scenarios involving exposure to radiation
- Maintain and disseminate the national primary standard for absorbed dose
- Operate the stations and laboratory that form part of the Australian operated component of the Comprehensive Nuclear-Test-Ban Treaty (CTBT) International Monitoring System
- Operate and effectively deliver a range of radiation protection related services
- Provide information to support and enable stakeholders to make informed decisions regarding the safe and effective use of radiation
- Enhance UV radiation protection of the public by providing data and promoting strategies for prevention of health effects related to UV skin and eye exposures.
Performance measures
We will demonstrate our performance through the following measures:
| No | Measure | 2022–23 target | Methodology | 2023–24 | 2024–25 | 2025–26 |
| 5 | High quality research in radiation protection, nuclear safety and medical exposures to radiation, are undertaken to improve understanding of radiation and its effects among professionals and the public | ARPANSA to publish >7 peer‑reviewed publications | Peer reviewed publications undertaken will be determined by emerging issue of public interest, to ensure significance, and will be published online | >7 | >8 | >8 |
| 6* | Operation of the CTBTO (Comprehensive Nuclear-Test-Ban Treaty Organisation) International Monitoring System (IMS) radionuclide stations to meet CTBT targets for data availability | Stations operational and reporting verified data to the CTBTO at >95% average per reporting period | Data collected from IMS stations (maintained by ARPANSA) located in Australia and its territories, Fiji and Kiribati will be analysed and the yearly average determined | As per 2022–23 target | ||
| 7* | Operation of the ultraviolet radiation (UV) monitoring network with a high level of data availability to the public | UV information is available to the public >95% of the time | Analysis of data extracted from UV network monitoring system will be averaged over the reporting period to verify availability. The UV data will be collected continuously from detectors that respond to UV in a manner similar to human skin | As per 2022–23 target | ||
| 8* | High quality and efficient radiation protection services are provided to customers | Survey results indicate we improved satisfaction scores and supported continuous improvement | Use of customer service satisfaction surveys to show we have improved our service delivery. This will comprise surveys from the following services: Radiofrequency Calibration services, Personal Radiation Monitoring Service (PRMS), Primary Standards Dosimetry Laboratory (PSDL) calibrations, Ultraviolet Radiation (UVR) Services, ARPANSA radiation meter hire service and the ACDS (Radiation Therapist Audit Feedback). | As per 2022–23 target | ||
| 9 | Engagement with the Australian public through the ARPANSA Talk to a Scientist service | Increase in service engagement over previous year | Assessment of reports extracted from Talk to a Scientist records management system. Service engagement will be based on number emails and phone calls received by the service and response to all queries. In FY21/22 627 emails were received and 300 phone calls | Additional service standards will be evaluated next financial year to assess the quality of this service |
* Indicates reporting periods where performance will be measured against an unchanged target.
PBS related performance measures
| No | Measure | 2022–23 target | Methodology | 2023–24 | 2024–25 | 2025–26 |
| PBS-3 | Promote patient safety in radiotherapy and diagnostic radiology | Report annually on significant deviations and trends discovered through the Australian Clinical Dosimetry Service (ACDS) and Diagnostic Reference Level (DRL) programs | Measured through a combination of annual publications and evaluations based on data collected from the ACDS and DRL programs | X |
We will also demonstrate our performance through delivery of the following projects:
| Project | Description | Estimated completion date |
| Radiation Protection of Patients (RPOP) Review | An updated online RPOP training package and associated referrer and patient supporting material | Jun 2022 |
| CTBTO International Monitoring Service monitoring station upgrades | Deliver, in cooperation with the CTBTO, upgrades to the Macquarie Island radionuclide monitoring station | Jun 2023 |
| Sunscreen testing | A collaborative research program between ARPANSA, RMIT University and Cancer Council Victoria (CCV) to develop evidence-based methodologies for in vitro (non-human) testing of sunscreen | Jun 2022 |
| A primary standard water calorimeter for protons, photons and electrons in the megavoltage range | Commission and deliver a new primary standard water calorimeter to underpin radiation oncology treatment domestically | Dec 2024 |
| Linear accelerator (linac) replacement | The procurement and installation of a new linac to maintain national coverage and functional capability in calibrating hospital radiation equipment used in radiotherapy | Dec 2022 |
3. Ensure effective and risk-informed regulation
ARPANSA is charged with regulatory oversight of facilities and activities under the ARPANS Act and Regulations. Our remit encompasses the whole radiological lifecycle, from controlled sources to facilities. As regulator of commonwealth agencies, we take a graded, risk-informed approach to regulation of radiation sources, radiation facilities and nuclear installations with regulatory activities including licensing, compliance, inspection and enforcement.
Together with physical science and engineering factors, our regulatory focus will include promoting mature processes, attitudes, and behaviours among licensed entities so that their activities can be carried out safely without undue risk to the workers, public and environment. Plans and arrangements that the licence holder must have in place to maintain safety during routine, abnormal and emergency conditions will remain an integral part of our regulatory monitoring activities. Aligned with anticipated work across our licence holder portfolio, ARPANSA will ensure the plans will include post-operational safety, including safe decommissioning of facilities and safe management of radioactive waste including its disposal.
Using review processes and analysis, we will continually improve ARPANSA’s regulatory approach for the benefit of Commonwealth licence holders, applicants, and the Australian community to ensure that regulation is not only effective but also efficient. ARPANSA will use its national engagement work with state and territory jurisdictions to promote national uniformity in radiation protection policies and practices throughout Australia.
Regulatory performance
As part of a concerted effort to reduce unnecessary and inefficient regulation, ARPANSA is committed to driving best practice in regulation by improving regulator performance, capability and culture through our adoption of the Regulatory Performance Guide. This comprises three principles:
- continuous improvement and building trust
- risk based and data driven
- collaboration and engagement.
We take consistent and proportionate risk-based approach, and these principles form the basis of our regulatory activities and undertakings.
Initiatives
- Using a holistic approach, influence licence holders to improve safety culture, inclusive of leadership and management for safety
- Monitor and report on regulatory performance and compliance to promote continuous improvement
- Provide a risk-informed and fit-for-purpose regulatory framework and standards for safe management of sources and facilities, including nuclear installations, over the entire lifecycle
- Operate consistently to the Commonwealth Regulator Performance Guide by being accountable, applying best regulatory practice and enhancing the professionalism of the service we provide.
Performance measures
We will demonstrate our performance through the following measures:
| No | Measure | 2022–23 target | Methodology | 2023–24 |
| 10* | Communication with regulated entities, licence applicants and key stakeholders is open and transparent | Regulated entities, licence applicants and key stakeholders are consulted on major licence decisions and key ARPANSA initiatives | Analysis of records associated with formal consultation activities, this will also provide awareness as to which mechanisms (e.g. public forums, have your say page, national advertisement, etc) are being used. | As per 2022–23 target |
| 11* | Airborne discharges and radiation dose rates near major nuclear installations are at low concentrations, well below notification levels | Independent assessment of the licence holders environmental monitoring program verifies their reported results | Analysis of Australian Radiation Monitoring System (ARMS) gamma dose rate data, captured via an automated cloud-based system. Environmental and stack radiation levels are verified in ARPANSA’s radiochemistry laboratory and compared to confirm that the majority of the radionuclides released to the environment are at levels below the detectable level. The Australian Nuclear Science and Technology Organisation (ANSTO) is the only licence holder authorised to discharge small quantities of radioactivity into the environment. | As per 2022–23 target |
| 12 | Commonwealth licence holders apply the principles of radiation protection:
| The radiation dose of the 100 most exposed workers at licensed Commonwealth entities trends downwards over the monitoring period | Analysis of ARPANSA Personal Radiation Monitoring Services records – based on the quarterly dosimetry data submitted by licensed Commonwealth entities. Any observed trends are assessed to identify causal association. | Continued reduction in exposed workers radiation dose trends |
| 13* | Implement and enhance regulatory activities in accordance with the Commonwealth Regulator Performance Guide | An annual review of regulatory performance is undertaken and demonstrates conformance with Commonwealth Government guidance for regulatory functions | An annual review, using claims, arguments and evidence, will be conducted to establish if essential controls are applied with minimal burden to form a risk informed, open, transparent and trusted service | As per 2022–23 target |
| 14 | Constructive feedback from licensed entities is encouraged to ensure consistency and continuous improvement in our regulatory approach | Above average satisfaction levels | Analysis of ARPANSA regulatory surveys – review of information from post regulatory service surveys to ensure consistency and continuous improvement in our regulatory approach. Post inspection survey indicates an improvement in average satisfaction levels. Qualitative analysis of survey commentary is utilised to highlight opportunities for improvement. | As per 2022–23 target |
* Indicates reporting periods where performance will be measured against an unchanged target.
PBS related performance measures
| No | Measure | 2022–23 target | Methodology | 2023–24 | 2024–25 | 2025–26 |
| PBS-4 | Ensure protection of people and the environment through efficient and effective regulation | Finalise the 14 ARPANSA-specific findings from the International Atomic Energy Agency Integrated Regulatory Review Service (IRRS) mission to Australia. Support the implementation of multi-jurisdictional findings via the enHealth process, including development of the National Strategy for Radiation Protection | Quarterly analysis of project progress in accordance with schedule | X |
We will also demonstrate our performance through delivery of the following projects:
| Project | Description | Estimated completion date |
| National Radioactive Waste Management Facility Project (NRWMF) | Preparation to receive a licence application for the NRWMF, ensuring appropriate resourcing for activities that will underpin the licence decision and application assessment | Dec 2022 |
| Self-assessment tools for licence holders | Develop digital checklists, with industry working groups, to allow licence holders to assess their compliance against codes and standards | Dec 2022 |
| IRRS follow-up mission | Establish a project team to prepare the advanced reference material for the follow-up IRRS mission in October 2023 | Dec 2023 |
| General Safety Guide 12 and 13 alignment | Alignment of the ARPANSA regulatory framework with international best practice | Jun 2023 |
4. Enhance organisational innovation and capability
By enhancing our organisational innovation and capability ARPANSA ensures our systems, assets, and staff effectively support and efficiently deliver on our purpose. ARPANSA will implement the Workforce Strategy 2022–25 to ensure sustainable knowledge and capability and an improved employee experience that attracts and retains high performing people.
We will continue to invest in projects that build capability, increase agility, and focus on future needs. Over the 4-year planning period, we will continue the implementation of digital technology projects identified in the 2020 review of business systems and technology platforms. The agency will continue to implement the ARPANSA Management System (AMS) and deliver a comprehensive high-quality research program to support radiation protection, nuclear safety and regulatory activities and mitigate radiation risks in the Australian context.
Initiatives
- Ensure APANSA has sustainable operations and appropriate infrastructure
- Implement and improve integrated processes that enable ARPANSA to deliver high-quality products and services
- Deliver workforce initiatives that enable sustainable capability, continuity of service to stakeholders, an attractive employee experience and a clear line of sight between our work and ARPANSA’s purpose
- Develop and maintain secure and stable platforms, systems and internal frameworks to enable effective service delivery.
Performance measures
We will demonstrate our performance through the following measures:
| No | Measure | 2022–23 target | Methodology | 2023–24 | 2024–25 | 2025–26 |
| 15 | Efficient implementation of a whole of agency information technology roadmap to support the modernisation of services provided | Implement digital technology initiatives to enhance service delivery, improve customer experience and streamline internal processes | Analysis of project records – comparison between projected and actual milestones and budget for IT roadmap program of works | X | X | |
| 16 | Implement the ARPANSA Workforce Strategy and develop a Knowledge and Learning Management Plan | Deliver the workforce strategy as per the program plan schedule | Analysis of project records – program plan milestones are met according to the agreed schedule | As per 2022–23 target |
We will also demonstrate our performance through delivery of the following projects:
| Project | Description | Estimated completion date |
| Workforce strategy | Implement the ARPANSA Workforce Strategy and Program Plan covering the following three areas:
| Jun 2025 |
| Cyber security enhancement | Strengthen perimeter security and implement additional cyber security features | Jun 2023 |
| Platforms and systems | A whole-of-agency roadmap, schedule, investment strategy and prioritised roadmap for the future design of our digital technology platforms and systems to meet current and future business requirements including:
| Jun 2024 |
| ARPANSA website rebuild | Develop a modernised website to make it easier for the Australian public to access our radiation health information and engage with our digital services | Nov 2022 |
| Risk management | The review and consolidation of agency risk management (safety, health, security, operational, strategic) with clear documentation and a user-friendly, online risk management and reporting system | Jun 2023 |
Appendices
Appendix 1 – Changes to our performance information
ARPANSA’s review of our performance information was driven by an intent to strengthen the quality of our information and begin maturing our performance framework. Following our annual review of our performance measures and initiatives, all measures and targets were reviewed to ensure our indicators were not only meaningful but presented in a manner that fostered transparency and supported Public Governance, Performance and Accountability Rule requirements.
Our review verified that our performance measure will enable the agency to:
- demonstrate how we are using public resources to make a difference and deliver our purpose
- make decisions about how best to deploy our resources to achieve competing priorities.
The ARPANSA Corporate Plan identifies 19 initiatives, 16 performance measures and 17 significant projects for the reporting period 2022–23 to 2025–26. Key changes have been summarised below with the accompanying table identifying ‘significantly revised’ and ‘closed’ measures:
- Thirteen performance measures are unchanged or only marginally changed to improve the clarity of the performance information. Unchanged measures supported consistency in reporting and demonstrates performance over time, whilst minor changes to targets were instigated to foster continuous improvement
- Three performance measures have been significantly revised and updated to reflect the evolution of the related work activities and a refinement in our performance information. Two were a result of benchmarking and standardising our data
- Four performance measures will be closed. Two of these measures were scheduled for conclusion this financial year, one was considered by leadership to be better suited to the ARPANSA operational plan and one was absorbed into an existing measure and will be reported on as part of a broader strategic target
- The addition and closure of projects as captured within the ARPANSA project management framework, were updated to reflect the progress made.
To comply with recent legislative changes, ARPANSA integrated our Key Activities within 2022–23 PBS. The PBS complements this plan as it continues to provide high level performance information for current and ongoing areas of work and has been linked to a specific Key Activity.
| Key Activity | Measure | Outcome of 2022 review | Significantly reviewed | Closed |
| 1. Initiate, maintain and promote frameworks for protection and safety | Contribute to international radiation protection, nuclear safety and security and facilitate compliance with related agreements and treaties | Reviewed to encompass a wider range of strategic partnership work and international collaboration. Previously this measure was limited to the development and publication of our two national reports and our participation in the corresponding international conventions. This measure will also now encompass key international collaborations such as the WHO emergency findings and our contributions to frameworks developed in collaboration with international partners (IAEA, UNSCEAR, ICRP, ICNIRP, etc.). We will be reviewing and assessing the contributions made this year to establish a baseline | X | |
| 2. Undertake research and provide expert evaluations, advice, and services | Engagement with stakeholders to support information exchange on the proposed licence application to site a NRWMF | This was developed as a pre-emptive measure to anticipate the resourcing impact a siting application would have on the agency. It is being removed in recognition that this work can be better captured as part of performance measure (PM) 10, which encompasses regulatory licencing decisions and associated engagement and consultation requirements. If a proposed licence application to site a NRWMF is received this financial year, ARPRANSA will evaluate this as part of PM10 in the Annual Performance Statement | X | |
| 2. Undertake research and provide expert evaluations, advice, and services | Engagement with the Australian public through the ARPANSA Talk to a Scientist service | This measure and target were re-evaluated to reflect technological advancements the agency made during COVID. The use of remote telephony has ensured this service can be 100% available to the public regardless of staff work location, so the Agency leadership agreed this was an opportunity to assess the effectiveness of this service. The focus was redirected to increase in service uptake (among the Australian public). A 100% response rate will be maintained | X | |
| 3. Ensure effective and risk-informed regulation | Communication with regulated entities and key stakeholders is open and transparent | This was reclassified to better demonstrate how our use of public resources are making a difference and delivering on our legislated requirement. This measure now encompasses the work instigated within PM 5 – associated with the consultation upon receipt of a NRWMF licence | X | |
| 4. Enhance organisational innovation and capability | Maintaining and improving infrastructure to facilitate efficiency in business-as-usual activities | This measure was scheduled for closure this year. This program of work is nearing completion | X | |
| 4. Enhance organisational innovation and capability | Review of business models | This measure was scheduled for closure this year. These reviews were completed within the FY 2022–23 reporting period. | X | |
| 4. Enhance organisational innovation and capability | Employee engagement score in annual APS employee census | This performance measure provides meaningful insight for internal management purposes, but was recognised as having limited effectiveness to measure our Key Activity of enhancing organisational capability. This measure will instead be monitored as part of the agency’s internal business plan and utilised to inform the plans developed as part of our workforce strategy program (PM16). ARPANSA will use this reporting period to evaluate more robust quantitative measures of organisation innovation and capability | X |
Appendix 2 – Reporting requirements
This corporate plan has been prepared in accordance with the requirements of:
- subsection 35(1) of the PGPA Act
- subsection 16E(2) of the PGPA Rule 2014.
The table details the requirements met by the ARPANSA Corporate Plan:
Introduction
- Statement of preparation
- The reporting period for which the plan is prepared
- The reporting periods covered by the plan
Purposes
Key Activities
Operating context
- Environment
- Capability
- Risk oversight and management, including key risks and its management
- Cooperation
- Subsidiaries (where applicable)
Performance
- Performance measures
- Targets for each performance measures (if reasonably practicable to set a target)
1 The ARPANSA Executive Group comprises our CEO and Branch and Office Heads
2 Radiation is energy travelling as waves or particles. Ionising radiation has enough energy to ionise (remove an electron from an atom) which can change the chemical composition of the material. Non-ionising radiation has less energy but can still excite molecules and atoms causing them to vibrate faster.
3 Ferlay J, Soerjomatram I, Ervik M, Dikshit R, Eser S, Mathers C, Rebelo M, Parkin D, Forman D, Bray F. GLOBOCAN 2012 v1.0, Cancer Incidence and Mortality Worldwide: IARC CancerBase No. 11. IARC, World Health Organisation, 2013.
4 Department of Defence, 2022. Nuclear Powered Submarine Taskforce [online]. Available at: https://www.defence.gov.au/about/taskforces/nuclear-powered-submarine-t… [Accessed 23 June 2022].
