Inspection report: ASC Pty Ltd (S0190), South Australia, R22/06782

Inspection report
Licence holder	ASC Pty Ltd and ASC AWD Shipbuilder Pty Ltd
Location inspected	ASC North, Osborne South Australia
Licence number	S0190
Date of inspection	18 July 2022
Report number	R22/06782

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 source licence S0190. 

The scope of the inspection included an assessment of performance at ASC North against the Source Performance Objectives and Criteria (POC). The inspection consisted of a review of records, interviews, and a physical inspection of the ionising source storage and exposure locations, in particular the complex open site environment where ionising sources are used onboard the submarine. 

Background

ASC is a proprietary limited company (ASC Pty Ltd) 100% owned by the Commonwealth of Australia to serve as Australia’s sovereign submarine builder and sustainer. ASC is authorised under section 33 of the Act to deal with ionising sealed sources and X-ray units for industrial radiography, and a range of other controlled apparatus for analysis of submarine components during maintenance. 

The main codes and standards applicable to this inspection are:

1. Code of Radiation Protection Requirements for Industrial Radiography (2018), Radiation Protection Series C-4 (RPS C-4)
2. Code of Practice for the Security of Radioactive Sources (2019) Radiation Protection Series No. 11 (RPS 11). 
3. Australian Standard AS/NZS 2243.4:2018 Safety in laboratories Part 4 Ionising Radiation
4. Safety of laser products Part 1 (AS/NZS IEC 60825.1:2014)
5. Safety of laser products Part 14: A users Guide (AS/NZS IEC 60825-14:2011)

Observations

In general, the management of safety was found to be strong.  In some cases, however, there appeared to be room for improvement with respect to security information and the on-site possession of security enhanced sources by persons who have not undergone a security background check.

Effective control

Documentation and document control

Plans and arrangements for managing safety had recently been reviewed in line with ASC’s Quality Management system document review cycle, including the Radiation Safety Manual (RSM) Revision 16.0 (CMS-52388) and the NDT Laboratory Manual Revision 17.0 (CMS-50998). 

The current ASC Radioactive Source Security Plan (Rev 4) has been signed by two appropriate ASC employees (NDT Technical Officer and NDT & Quality Production Manager). In this version of the plan there is no reference to an ARPANSA assessor or ARPANSA approval officer. There is also no authorisation stamp on the document. However, re-accreditation of plans may not be required if there has been no change in the risk environment. 

Inspectors asked to view a version of the ASC Radioactive Source Security Plan that was previously endorsed by an assessor accredited by the regulatory authority. Version 2 dated 1/2/2018 was signed by an ARPANSA accredited assessor. In addition, it was stamped as endorsed and signed off by a different ARPANSA officer accredited for RPS11 source security plan endorsement. 

The draft ASC Collins Class Submarines Security Plan for Radioactive Sources Revision 05 (Radioactive Source Security Plan Rev 5) has a review date of 4/07/2022. Inspectors note section 1.5 of the Source Security Plan states ASC standard policy as part of the ASC Process Owner Program is that Process Owners are to review their documents every two years in line with ASC corporate documentation. However, as ASC deals with category 2 or 3  security enhanced sources the Code of Practice for the Security of Radioactive Sources RPS 11 (2019) procedural and administrative security requirements in Schedule D apply which stipulate annual review of the source security plan. Inspectors observed the amendment record table on page 2 of the July 2022 Radioactive Source Security Plan Rev 5 indicates that revisions have been undertaken annually since the original plan was created in July 2016. 

ASC lists a number of situations that should trigger an immediate review, including an organisational restructure or a change in the licence. Inspectors noted that the email accompanying the submission of an updated security plan (revision 5) received prior to the inspection flagged such a revision of the security plan as being associated with the change in organisational structure. Inspectors further note that source licence S0190 was reissued in April 2022 which should have triggered an immediate ‘review’ of the plan according to the criteria outlined in section 1.5 of the ASC Radioactive Source Security Plan. 

Inspectors noted that the draft Revision 5 Source Security Plan ‘Authority to Release’ requires the signatures of an ‘assessor’ and a separate ‘approver’ in the employ of the regulator. Under RPS 11 there is only the requirement for endorsement by an accredited assessor. 

Inspectors noted that ARPANSA could make it clear that only one accredited assessor is required for the endorsement. Separate endorsement certificates may assist the LH by making it clear which version was endorsed and whether a plan was reviewed without changes requiring re-endorsement.

Inspectors considered that there is sufficient change in the local operating environment in which the dealing occurs to warrant the re-endorsement of the ASC Radioactive Source Security Plan Rev5 taking into account the identification of an area for improvement for radioactive source security.

AFI 1: ASC clarify the RPS 11 (2019) annual review requirements in section 1.5 of the ASC Security Plan for Radioactive Sources (Revision 5), to distinguish this regulatory requirement from the internal ASC two-year document review cycle. 

AFI 2: ASC to submit an updated Radioactive Source Security Plan for re-endorsement by an accredited assessor.

Safety management

Managing change

Open site industrial radiography may take place across the length of the submarine and on various levels. Industrial radiography may be performed using X-ray apparatus or, where necessary, by more hazardous radioactive sources emitting gamma rays to achieve the requisite level of penetration of the hull. When conducting industrial radiography on the hull the public exposure risk extends to outside of the boat. Managing the exposure risk for each task within this complex operating environment is important for ensuring safety. ASC manages this risk environment through a layered approach incorporating structural features with integrated predetermined safety zones and procedures. For example:

• The construction of a new Maintenance Support Tower (MST), a multi-level work platform which surrounds the submarine while undergoing service and heavy maintenance, has required ASC to develop new exclusion zones for on-board radiography testing. 
• The exclusion zones have been formally captured in a new MST/Submarine Radiography Exclusion Zones document which includes a plan view illustration of three colour coded Zones to inform MST personnel in advance as to what areas of the MST will require evacuation during radiography testing. 
• Each zone has been risk assessed and a determination made as to the stringency of the risk mitigation measures required to effectively eliminate the public exposure risk. 

Inspectors noted that the supporting procedures require Exclusion Zone determinations to be confirmed from an initial dose rate survey at the commencement of radiography. In addition, the acquisition of modular units of reusable safety zone tape for installation at predetermined points provides additional visual assurance that access control measures are clearly delineated on the MST during NDT. Inspectors consider ASC’s practices and procedures demonstrate good safety management.

Training and education

The RSM s2.8 sets the qualification requirements required by technicians performing radiography and those persons to be designated as the radiographer in charge (RIC). 

RSM s2.9 identifies the specific training requirements for trainees and qualified radiation workers before they are permitted to take part in any form of radiography; including recovery from emergency situations and notification of the appropriate authorities. 

Learning and continuous improvement

ASC provided the inspection team an internal audit report on a Radiation Hazard - incident (A-1767) that occurred at the ASC site in 2019.  ASC conducted a critical debrief of the incident which was influential in changing procedures relating to performing infrequent tasks. 

Radiation protection

Principles of radiological protection

Inspectors verified the use of compliant signage in the NDT Laboratory, exposure bay, radioactive source store and locked source cabinet. The performance of the safety interlocks was demonstrated. Calibration of equipment, adherence of logbook entry requirements when dealing with radioactive sources stored on site, the use of X-ray apparatus, and the secure stowage of keys for operating controlled apparatus were verified during the site inspection.  

The current selenium (Se-75) sealed source in the source store was originally a category 2 security enhanced source when acquired in July 2021. Se-75 with a half-life of 119.7 days has decayed by three half-lives since acquisition and at the time of inspection is now a category 3 source. The RSM at s3.2.2 gives due recognition of the risks associated with the use of category 2 sources for industrial radiography in noting that they provide the most penetrating power as they cannot be turned off. Accordingly, ASC manages the high-risk factors for radiation exposure by mandating radioactive sources are only to be used for NDT if it is not practical to use an X-ray apparatus. This safety approach is reiterated in s4.2.1. RMS s4.1.8 sets out the safety and control procedures for the access and use of a radioactive source to perform radiography. 

Planning and design of the workplace

ASC conducts radiography in the ASC North radiography facility and on the boat. The NDT Laboratory exposure bay has been designed to meet the Australian and international definition of a fully enclosed site (see: RSM S3.1.8). The inspection determined that the exposure bay meets the requirements of RPS C-4 Code of Radiation Protection Requirements for Industrial Radiography (2018) section 3.4. 

Inspectors were granted unrestricted access to the boat to understand the complexity of undertaking open site radiography in this workplace and determined that ASC met the additional requirements of RPS C-4 section 4.2. 

Local procedures for prevention of exposure incidents and accidents

As stated above, ASC stipulates that industrial radiography with dangerous high activity radioactive sources is only to be undertaken if it is impractical to radiograph an item using an X-ray machine. (RSM s4.3.1). 

When performing radiography, the RIC develops a plan based on a risk assessment (RA0760) for open site radiography and determines the site exclusion boundary. (RSM s4.3.10). Survey meter readings are taken throughout the NDT process.

Inspectors noted the meticulous attention to detail paid to checking the winder and all facets of the wind out capable for damage, paying particular attention to the connection points that secure the source to the cable. NDT technical staff demonstrated the use of a specific measuring tool to verify that the finely engineered metal components for connecting the source to the cable are within strict tolerance for safe use and have not been damaged to such an extent that this could increase risk of a retrieval failure when undertaking NDT in confined spaces on board the boat.

Personal protective equipment and monitoring of the workplace

Inspectors verified the availability of personal monitoring devices (OSLs) for NDT personnel, including the appropriate placement of a control and the calibration of survey meters. In addition, inspectors noted that lessons learned from an internal audit report on a Radiation Hazards incident (A-1767), concerning the use of a radiation survey meter to assess actual exposure levels for an activity, are incorporated into RSM section 4.3 ‘Performing site radiography using an isotope’ and the key checks (CMS-52388 REV 16 p.10) that are required when performing radiography in the boat. 

Security

Security procedures

ASC has risk based physical security measures in place to meet the security outcomes for the storage of a category 2 security enhanced source as required in s4.2.2 of RPS 11. The radioactive source used to conduct industrial radiography on board the boat requires the source be moved across the site from its secure storage using a trolley. Inspectors walked the open route and noted the proximity of this route to the water. Inspectors established that adequate measures are in place at the water perimeter to satisfy RPS 11 security management in s7.1.3 such that ‘persons that deal with the radioactive source should be alert to suspicious behaviour in relation to not only the radioactive source and the asset in which it is housed but also the immediate environs.’ 

Inspectors note that s7.5 of the Draft ASC Security Plan for Radioactive sources (Rev 5) states ‘Department Manager/ supervisors are required to ensure that their employees are adequately security cleared for the duties they are employed to undertake’. However, RPS11 s2.3.1 requires this condition apply to all persons irrespective of their association to the ASC ‘responsible person’ . 

ASC Security Plan for Radioactive sources (Rev 5) section 7.8 ‘Procedures required for a technical service’ indicates the process for handover and return of a source includes: ‘(a) accredited Transport Company is escorted from ASC security gate to NDT Laboratory’. However, ASC advised inspectors of occasions where they may have been unescorted on-site deliveries of category 2 sources from the gate to the laboratory. 

The possession of a portable category 2 sealed source by a person not in the employ of ASC who has not undergone a security background check does not meet the requirements of RPS 11 s2.3.4. 

ASC should take steps to ascertain whether local licensed operators providing ASC with the temporary use of their high activity radioactive source have undergone the appropriate security checks for unescorted transport the source on the ASC North site.

AFI 3:  ASC to review their onsite security arrangements for delivery of a security enhanced source.

Information security and the threat level for the security of radioactive sources

ASC Security Plan for Radioactive sources (Revision 4; and draft Revision 5) s7.10 indicates information security at ASC is managed in accordance with CMS-53887 and that all employees are to be made aware of the Information Security Manual. Inspectors note ASC’s stated intention to ensure the highest standards of information security and integrity is to be achieved by requiring ‘departmental managers must regard Information Security training with the same gravity as Health and Safety training’; however, there are areas for improvement in the application of classified information and its management across security and safety documentation. 

ASC Security Plan for Radioactive sources 7.11 addresses RPS 11 procedural and administrative security requirements in the event of an escalation of threat. ASC Security Plan indicates threat level can be confirmed by accessing the National Terrorism Threat Advisory System or advice from NTAC. Additionally, RPS 11 s2.1.10 recommends ‘Awareness of Threat Level’ requirements to update the source security plan when advised by the police or the regulatory authority of a change in the specific sectoral threat level for a radiological attack in Australia. 

The RSM (Revision 16) section 4 ‘Security of Equipment’ commences by noting the rating of the security enhanced source as category 2 is in accordance with RPS 11. However, subsection 4.1.5 makes comment in regard to the ‘threat level for ASC sites’ which is not the relevant threat consideration for determining the level of threat for a radioactive source to comply with RPS 11 Schedule D scalability requirements. 

The threat level referenced in the RSM is incorrect for the purpose of applying RPS 11’s procedural and administrative security requirements at the current level of threat. The application of the RSM threat level by a Radiation Protection Officer (RPO) in accordance with the RPS 11 Schedule D would introduce additional procedural requirements for a category 2 source.  

In addition, the actual radiological threat level for Australia is classified information and should not appear in a document that does not carry an appropriate security classification. Inspectors recommend the removal of this threat level wording in subsection 4.1.5. Inspectors also observed this threat level was displayed in the source store during the on-site inspection but was not specifically attributed to threat advice.

AFI 4: ASC to review the use of classified threat level information to address RPS 11 procedural and administrative security requirements in the event of an escalation of threat.  

Emergency plans

The RSM Annex has a radioactive isotope emergency recovery procedure and references additional Emergency Response Process (CMS-52445) and Security Lockdown Procedures (CMS-53944). Inspectors made particular note that this RSM procedure is supported by additional scenario-based procedures to aid key decision makers in the initial declaration of an emergency situation; and determining a safe recovery process for specific events such as a sealed source delivery tube damaged or severed by falling items on the boat when conducting industrial radiography. The scenarios also include additional actions in the event a source is lost or considered stolen and situations where there is a suspected high dose to an individual for any reason when conducting radiography. 

Inspectors were informed of ASC’s intention to conduct an emergency training exercise for recovery of a high activity radioactive source when undertaking NDT in confined work environments aboard the submarine. 

Cross-cutting human factors

Human performance

ASC provides NDT equipment operators with full access rights to the submarine and, in doing so, promotes domain awareness over all locations onboard the submarine when planning for NDT, including the development of risk assessments, and assessing the shielding requirements. Inspectors also noted during the inspection that this familiarity with the boat empowered NDT technicians to identify potential points from which to recover a source from the boat in an emergency response situation.  

Performance improvement

Under s4.8.5 ASC’s RSM states ‘prior approval is required under regulation 65 of the ARPANS regulations for any disposal of controlled apparatus and material’. However, ASC source licence S0190 Schedule 2 contains conditions which permit the licence holder to dispose of sealed sources used for industrial radiography without the prior approval of the CEO of ARPANSA as required by subsection 65(1) of the Regulations. 

In granting other disposal arrangements for hazardous sources S0190 licence condition 6 takes into consideration the licence holder’s ‘routine’ disposal of sealed sources only. Inspectors note that ASC currently has only one radioactive source on its SIW which was acquired in July 2021; however, this may not reflect ASC’s temporary acquisition of high activity sources at the ASC North site.

Inspectors consider this disposal condition warrants specific attention in the RSM as it circumvents the prior regulatory checks for the most hazardous ionising sources of radiation that ASC deals with and does not apply to controlled apparatus.

Human factors consideration

As other ASC controlled apparatus are not routinely disposed of attention should be paid to the risk of human factors contributing to a failure to comply with the Regulations when undertaking the infrequent task of disposing of controlled apparatus. ASC should be mindful of past lessons learned in an ASC Audit Report (A-1767) Executive Summary in undertaking infrequent tasks or activities without clear guidance and refresher training on procedures. 

Findings

The inspection revealed the following areas for improvement:

1. ASC to clarify the annual review requirement of RPS 11 in section 1.5 of the ASC Security Plan for Radioactive Sources to distinguish this regulatory requirement from the internal ASC two-year document review cycle.
2. ASC to submit an updated ASC Collins Class Submarines Security Plan for Radioactive Sources (Revision 5) for re-endorsement by an accredited assessor.
3. ASC to review their onsite security arrangements for delivery of a security enhanced source.
4. ASC to review the use of classified threat level information to address RPS 11 procedural and administrative security requirements in the event of an escalation of threat.

It is expected that improvement actions will be taken in a timely manner.