Inspection report: Department of Defence and Australian Defence Force (DoD) (S0042), VIC, R24/06073

This is the record of an inspection conducted as part of ARPANSA’s source 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 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 physical inspection of sources at the site.

Background

DoD is licensed to deal with many different types of controlled material and controlled apparatus at its various Australian sites/bases for scientific research, calibration, medical use, non-destructive testing, 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 11 Code of Practice for the Security of Radioactive Sources (2019)
• RPS C-2 Code for the Safety Transport of Radioactive Material (2019) 
• RPS C-6 Code for Disposal of Radioactive Waste by the User (2018)
• Australian/New Zealand Standard Safety in Laboratories – Ionizing Radiations (2018) (AS/NZS 2243.4:2018)

Observations

In general, the management of safety margins at the base was found to be satisfactory. However, there appeared to be room for improvement in the contents of the radiation management plan.

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 its sites. This is supported by a comprehensive Defence Radiation Safety Manual (DRSM), DoD’s Plans and Arrangements (P&As), to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions. This particular DoD site has, in turn, prepared its own ‘local’ Plans and Arrangements (designated from here as LP&As) based on the DRSM to suit the sources used at the site. The activity of the sources located at this site also necessitates a Source Security Site Plan.

The Directorate of Defence Radiation Safety and Assurance (DRSA) collects information for quarterly reports with input from each DoD site. Once collected, Defence 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. 

The following areas for improvement (AFIs) relating to the LP&As were identified during the inspection: 

• Paragraph 3(c)(iii) of the LP&As provides a dose constraint for persons under the age of 16 whereas clause 3.2.13 of RPS C-1 prohibits persons under the age of 16 from being occupationally exposed to radiation. 
• There were no records to show that annual site analyses to determine potential exposure pathways for airborne, gas and liquid contamination were being carried out (section 4.c.xvii.2 (page 16) of the LP&As). 

Documentation & document control 

Records showed that documentation related to the controlled radiation sources at the site such as the LP&As and other associated documents had been reviewed within the required time.

Safety Management

Monitoring & measurement

The LP&As require a series of inspections and checks of the site ranging from daily to annual depending on the particular task. These include: 

• daily entry/exit surveys
• removable surface contamination checks
• area surveys
• daily background radiation level surveys, and 
• ionising radiation level surveys on the sources.

Records of these inspections are kept on DoD’s electronic records management system and were viewed during this inspection.

Managing change 

The DoD intends to ultimately dispose of the sources held at the site as they have not been in regular use for many years. Disposal is not, however, expected until an appropriate Australian disposal facility is commissioned. 

Training, education, learning & continuous improvement 

All personnel using the sources require training related to the procedures to be carried out. Section 8 of the LP&As state that “All …. Radiation Technical Control Network personnel are to consider the desirability of refresher training every 4 years”. This vague wording indicates that refresher training is not mandatory and it needs to be rephrased to reflect current training requirements.

Training for emergency preparedness is required every two years or if there is a significant change to sources or procedures. Training records are kept on the electronic records management system and were viewed during the inspection.

Radiation protection

Principles of radiological protection 

The LP&As outline dose constraints for occupationally exposed personnel for all conducts or dealings with the controlled sources. These dose constraints included “persons 16 years old and below”, which includes a group not permitted to be subject to occupational exposure under the requirements of RPS C-1. This is therefore considered to be an AFI. 

Radiation safety officer/Radiation safety committee 

The site has a suitably qualified Radiation Safety Officer to undertake specific duties relating to radiation protection at the site. The LP&As outline the requirements for a radiation safety working group (RSWG) including composition and business rules. The RSWG is scheduled to meet annually. A sample of recent agendas and minutes was seen during the inspection. 

Planning & design of the workplace 

The controlled sources are located inside a locked brick building inside a locked and signposted compound on the base. Only relevant, appropriately trained staff have access to the building and, therefore, the sources. All visitors to the building require induction training and a visitor register is signed acknowledging an understanding of the induction training before access is granted. The register is signed again on exit. During the walkthrough of the building, some older style radiation warning notices were observed. The colours of these were magenta and yellow rather than the black and yellow as per the relevant Australian Standard. While not considered to be an area for improvement, replacement of the signs to meet the Australian Standard should be carried out at the next available opportunity. 

Local rules & procedures 

Local rules and procedures are available online and in hard copy form inside the building. 

Personal protective equipment and monitoring of individuals 

All personnel accessing the sources room are required to wear personal radiation monitoring badges. Electronic personal dosimeters are also available. Records of the results arising from both types of personal monitoring were viewed.

Radioactive Waste 

Management of radioactive waste 

The only radioactive waste produced is during infrequent work with tritium. Records of any waste are kept in an inventory workbook that gives a full description of all waste produced during past and current dealings. These records were viewed as part of this inspection. 

Ultimate disposal or transfer 

Management of ultimate disposal or transfer 

Radioactive waste is stored in a safe inside the building until it is transferred to an appropriate Defence storage facility.

Security

Security procedures 

The activity of the sources in the sources room result in a security enhanced categorisation in accordance with the methodology in RPS 11. DoD has developed and implemented a comprehensive Source Security Site Plan (SSSP) that outlines:

• protective measures 
• personnel access provisions
• procedures to follow for a radiological security incident
• response arrangements, and 
• reporting requirements. 

Lists of authorised personnel and alarm system operators are included in the SSSP. 

Emergency plans 

Emergency plans and Emergency procedures 

Emergency plans and procedures for the site are outlined in both the LP&As and the SSSP. First responders will generally be base personnel but this can be elevated to civilian firefighters and police depending on the nature of the incident.

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 local P&As gave a dose constraint for persons under the age of 16 whereas clause 3.2.13 of RPS C-1 prohibits persons under the age of 16 from being occupationally exposed to ionising radiation.
• There were no records to show that annual site analyses to determine potential exposure pathways for airborne, gas and liquid contamination were being carried out.

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