Inspection report: Department of Defence and Australian Defence Force (DoD), A DoD base in Queensland, R24/02827

This inspection was conducted as part of ARPANSA’s source inspection program to assess compliance with the Australian Radiation Protection and Nuclear Safety Act 1998, the Australian Radiation Protection and Nuclear Safety Regulations 2018, and conditions of source licence S0042.

The scope of the inspection included an assessment of DoD’s performance against the Source Performance Objectives and Criteria (SPOC). The inspection consisted of a review of records, interviews, and a physical inspection of sources at two sites within the Base.

Background

DoD is licensed to deal with many different types of controlled material and controlled apparatus at its various Australian sites for scientific research, medical use, non-destructive testing (NDT) of objects, X-ray examination of objects and parcel examination.

The main codes and standards applicable to this licence include, but are not limited to:

• RPS C-1 Code for Radiation Protection in Planned Exposure Situations (Rev 1) (2020)
• RPS C-4 Code of Radiation Protection Requirements for Industrial Radiography (2018)
• Australian/New Zealand Standard Safety in Laboratories – Ionizing Radiations (2018) (AS/NZS 2243.4:2018)
• Australian/New Zealand Standard Safety in Laboratories – Non-ionizing radiations-Electromagnetic, sound and ultrasound (2004) (AS 2243.5:2004)
• Australian/New Zealand Standard Safety of laser products Part 1: Equipment classification (AS/NZS IEC 60825-1:2014)
• Australian/New Zealand Standard Safety of laser products Part 14: A user’s guide (AS/NZS IEC 60825-14:2022)

Observations

In general, the management of safety at the NDT Bunker was found to be satisfactory. However, there appeared to be room for improvement in Wing and Squadron in relation to the contents of the radiation management plans and the labelling of radiation survey meters.

Effective control

Management commitment and Statutory & regulatory compliance

DoD has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective use, storage, and disposal of radiation sources throughout all DoD sites. This is supported by the Defence Radiation Safety Manual (DRSM) and DoD’s Plans and Arrangements, to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions. Each DoD group in turn, has their own ‘local’ radiation safety plan (RSP) based on the DRSM to suit the sources with which they use on the given site.

The Defence Radiation Safety and Assurance (DRSA) section collects information for quarterly reports with input from each DoD site. Once collected, the Defence Radiation Safety Officer consolidates this information into one final report to ARPANSA. DoD’s quarterly reports have been submitted to ARPANSA in a timely manner in recent years, and contained relevant information, including details of compliance with the Act and Regulations.

Configuration Management

All controlled sources under the management of DoD at this site were present and accounted for in accordance with the DoD source inventory workbook.

Inspection, Testing and Maintenance

DRSA has developed a schedule of assurance inspections of Australia wide DoD sites on a quarterly basis although this inspection was held independently of those scheduled audits. It has been proposed that this arrangement of ARPANSA inspections being independent of DRSA audits continue as the DRSA audits concentrate on different issues than those of ARPANSA.

One radiation monitor had a calibration sticker affixed to it stating that it required calibration in May 2025 i.e. over 12 months after the date of this inspection. During the inspection, DoD sent an e-mail to the company that calibrated the monitor seeking clarification as to why the next calibration was over 12 months from the previous one. The monitor was technically within its 12 months calibration period as required by RPS C-4 but the label on the monitor could lead to a non-compliance if used once it had passed the calibration date.
One further radiation monitor had passed its calibration date although it had been danger tagged out from further use until it was calibrated.

Training

Only Level 2 trained industrial radiographers were permitted to operate the industrial radiography X-ray equipment. Training records for each industrial radiographer were sighted during the inspection. Any staff attending the industrial radiography bay required appropriate induction to do so although only staff directly involved with radiography were in attendance during procedures. The compound was inaccessible while radiography was in progress.

Upon inspection of induction training records, some mismatches were noted in the database between the refresher training ‘due’ and ‘completed’ dates. A specific example was that one Defence member had refresher training completed date of February 2025 although it was acknowledged that this might have been a typographical error.

Event Protection and Emergency Preparedness and Response

The broader DoD policy and work health and safety plans outline event protection and emergency preparedness and response requirements for the site. These were not assessed during the inspection.

Radiation Protection

Each group on each Australian site operates under a comprehensive radiation management plan to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions. These plans outline the obligations for all users of controlled radiation sources by each group.

The following areas for improvement were, however, identified during the inspection:

1. The Wing Radiation Safety Plan (WRSP) contained some referencing errors such as outdated or superseded documents including ‘RPS 1’, ‘RPS 3’ (in terms of the ranges for radiofrequency and extremely low frequency fields). The Squadron RSP (SRSP) contained similar referencing errors but it was noted that this was only a draft document as they had not acquired any radiation sources at the time of the inspection.
2. There were no references to ARPANSA in either of the RSPs in relation to notification and reporting of radiation source incidents.
3. Annex E of the WRSP specifically referred to an on-site person (i.e. a First Aid Attendant trained to provide initial treatment for laser injuries to the eye and skin) who does not exist in relation to responding to laser injuries. Further, prompt access to this person was required. Discussions held during the inspection revealed that in the event of a laser injury, the affected person would present to the on-base hospital for examination or treatment.
4. The WRSP required annual assessments of the effectiveness of control for non-ionizing radiation (NIR) apparatus although these were not being done. The licence holder would need to investigate whether this internal requirement were necessary.
5. Not all items required to be displayed in radiation work areas were present although these were available on-line.

Security

There were no sources at the site that would invoke the requirements of Radiation Protection Series 11 Code of Practice for the Security of Radioactive Sources (2019). Civilians were not permitted access to any part of the site without a specific need to be there and then only with an appropriate security pass and a local escort.

Findings

The licence holder was found to be in compliance with the requirements of the Act, the Regulations, and licence conditions.

The inspection revealed the following areas for improvement:

• The WRSP and SRSP contained incorrect references.
• The WRSP and SRSP did not contain appropriate reporting lines for radiation source incidents.
• The requirements of the WRSP protocol for responding to a laser injury were not accurately described.
• Annual assessments of NIR controls were not carried out.
• Not all documentation was displayed in radiation work areas.
• Dates for the next calibration of radiation survey monitors exceeded the 12 months stipulated in RPS C-4 and AS/NZS 2243.4.
• It is expected that improvement actions will be taken in a timely manner.