F0213, Department of Defence and Australian Defence Force, South Australia, 20-21 July 2022, R22/06710

An inspection was conducted as part of ARPANSA’s baseline inspection program to assess compliance with the Australian Radiation Protection and Nuclear Safety Act 1998 (the Act), the Australian Radiation Protection and Nuclear Safety Regulations 2018 (the Regulations), and conditions of facility licence F0213. 

The scope of the inspection included an assessment of Defence’s performance against the Performance Objectives and Criteria (POC). The inspection consisted of a review of records, interviews, and physical inspection of the facility. 

Background

The facility houses legacy waste made up of unrepairable and obsolete equipment, instruments, repair parts and consumables containing low and intermediate level radioactive materials. The facility is closed and does not receive waste on a regular basis. 

The facility is managed under a Possess or Control licence through which Defence controls its own waste as well as waste stemming from other Commonwealth organisations.

The main codes and standards applicable to this facility are those that appear in section 59 of the Regulations plus: 

• Australian/New Zealand Standard Safety in Laboratories - Ionizing Radiations (AS/NZS 2243.4).  

Observations

Given Defence’s response to numerous areas for improvement (AFI) from previous inspections, no new AFI resulted from this inspection nor were there any non-compliances.  

The licence holder’s performance, as determined during the inspection, was found to be compliant.

Performance reporting verification

The reporting practices in place for this facility are no different to those that exist at other Defence facilities or where sources of radiation are employed. These basically speak to information travelling up appropriate chains of command both locally and offsite as well as electronically through Sentinel, Defence’s event management system. Key staff involved with the facility are also represented on panels and committees in relation to radiation safety at the waste store.

The Defence Radiation Safety and Assurance (DRSA) group, which has responsibility for the facility, is currently undergoing a restructure with a focus on separating the compliance and technical functions. Though both areas will remain under DRSA, the concept is being employed to add some independence to their internal assurance function when conducting self-inspections. 

Since the last inspection, there have been no radiation safety events. 

Configuration management

Since the previous inspection in 2019, Defence has implemented a new set of plans and arrangements (a singular document known as the Radiation Safety Plan (RSP)) and drafted a new safety analysis report (SAR). No issues were identified with the RSP. As the SAR is in its final stages, it was not reviewed by ARPANSA inspectors. However, the previous SAR remains in place until it is superseded. 

Given the nature of the facility and its static state (i.e., not in routine operation), except for security upgrades performed as part of an approved section 63 submission, minimal to no changes occur at the facility.

Inspection, testing and maintenance 

The physical building associated with the facility as well as its immediate surrounds are maintained through Defence’s Security and Estate Group (SEG). SEG has their own program of inspections, however, if DRSA find issues during a site visit which require remediation, SEG will be informed and a maintenance request will be raised. Maintenance for the security system at the site is also performed through a Defence contractor. However, no maintenance work within the building will be conducted without the direct approval and supervision from DRSA.

Aside from these issues, there is little to no maintenance required at the site. 

Training

Requirements for Defence personnel associated with the facility have not changed since the previous inspection. All staff are to be trained as occupational exposed radiation workers as a minimum and will then be supervised by a radiation safety officer (RSO). RSOs are required to complete either the Defence Ionising Radiation Protection Officer (DIRPO) course or the ANSTO 5-day Advanced RSO course. A level of operational experience in Defence’s waste facilities is also required.

All DRSA staff have completed the requisite training and as such no issues were identified. 

Event protection

As mentioned previously, a new SAR is in its final stages and hence the previous SAR is still in force. As such, the analyses currently supporting the facility’s ability to withstand external events remains unchanged insomuch as the waste continues to be stored in a pre-existing building which was designed for the range of conditions expected at the Defence site and it is unlikely that external events, both natural and human-induced, will negatively impact the facility and result in a radiological safety event. 

Security

The facility itself sits well within a Defence base and as such is protected through implementation of standard Defence practices (patrols, contracted guard force, key/vehicle/access management, base security, fencing, security alarm system, and use of Security Construction and Equipment Committee (SCEC) endorsed products, etc.).

If a security alarm were to be raised, a process exists for Defence to initiate a response. This is done locally and offsite (through DRSA). Such a process has been in place for a number of years.

Since the previous inspection, Defence has been in the process of planning and conducting a security exercise. Currently, exercises performed are not specific to the waste store itself but are focussed on the site as a whole. Defence is currently developing procedures and working with those responsible for security response at the site to incorporate the facility into the greater arrangements for the base in order to conduct an appropriate exercise in the near future.

Since the last inspection, no security breaches have occurred and Defence continues to meet the requirements of Schedule D of RPS-11 (Security of Radioactive Sources (2019)) as appropriate for their security enhanced sources and current threat level.

Radiation protection

Radiation surveys continue to be performed at the facility in accordance with procedure. There has only been one change in recent years which saw dose rates increase in a specific area due to the movement of drums to provide access to a certain area of the store. Aside from this, no significant changes have occurred. 

Routine radon monitoring continues in the store with results of the analysis provided to ARPANSA inspectors. Only two readings were slightly elevated above the reference level of 1000 Bq/m3. Given the very low occupancy factor for the facility, such an increase was not identified as an issue.

Licence condition 6 of F0213 requires soil sampling to be performed every 3 years and to provide the CEO of ARPANSA with the information collected along with the results of the data analysis. Defence provided the most recent results to ARPANSA inspectors during the inspection. No indication of a leak to the environment has been identified.

As per previous inspections, all radiation detection equipment continues to be calibrated in accordance with the requirements of AS/NZS 2243.4.

Emergency Preparedness and Response (EPR)

In late 2021, Defence responded to an AFI in relation to conducting an emergency exercise at the facility and the impact of COVID-19 on its performance. ARPANSA considered and accepted the response noting that a desktop exercise would take place beforehand in order to inform the physical task. To date, a procedure has been developed for EPR at the facility but has not yet been promulgated through the appropriate support teams at the site which would allow for further development. Defence has indicated that this is the next step in developing their EPR capacity prior to initiating an exercise.

Security and EPR exercises will be conducted simultaneously as they are virtually synonymous for the facility.

Findings

The licence holder was found to be in compliance with the requirements of the Act, the Regulations, and licence conditions. No areas for improvement or non-compliance were identified.  

It is noted that Defence has addressed/continues to address previously identified findings or has self-identified opportunities for improvement.