Inspection report: Department of Defence and Australian Defence Force, F0113

This is the record of an inspection conducted as part of ARPANSA’s facility 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 F0113. The scope of the inspection included an assessment of DoD’s performance against the Facility Performance Objectives and Criteria (FPOC). 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 for scientific research, calibration, medical use, non-destructive testing 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 11 Code of Practice for the Security of Radioactive Sources (2019) 
• RPS C-2 Code for the Safety Transport of Radioactive Material (Rev.1) (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 facility was found to be satisfactory. However, there appeared to be room for improvement in the contents of the radiation management plans. 

Effective control 

Management commitment and statutory and 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 of 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 facility has, in turn, prepared its own ‘local’ Plans and Arrangements (designated from here as LP&As) based on the DRSM to suit the sources dealt with at the facility.

The current inventory of material at the facility results in a security requirement in accordance with the methodology in RPS 11. However, DoD incorporates security provisions at the facility to deal with higher requirements. 

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 area for improvement (AFI) relating to the LP&As was identified during the inspection: 

• Clauses 3.a.iii and 8.c.iv.3 of the LP&As identify 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. It should be noted that this conflicts with the administrative arrangements outlined in clause 8.c.vii.1 of the LP&As that effectively prohibits persons under the age of 16 from being employed within the facility. 

Documentation and document control 

Records showed that documentation related to controlled radiation sources at the facility had been reviewed within the required time. The current LP&As, version 16, are scheduled for review by April 2025 as is the facility’s security plan (version 25). 

Safety management 

Monitoring and measurement 

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

These include: 

• daily entry/exit surveys 
• radon and thoron gas monitoring
• wipe tests, and 
• area surveys. 

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

Observation: The radon and thoron monitoring at the facility was live and ongoing. Dose rate monitoring at defined points around the outside of the facility is, however, done manually. While not specifically an AFI given that the monitoring is taking place in accordance with the requirements of the LP&As, changing this dose rate monitoring to live and ongoing by use of external radiation monitors linked to a central computer, in the same way as the radon/thoron monitoring is carried out, would be seen as an improvement of the process. 

Training, education, learning and continuous improvement 

All personnel dealing with the sources at the facility require training related to the procedures to be carried out. Clause 8.c.vii.7 of the LP&As states that “All … RSM and … ROs are to consider the desirability of refresher training every four years”. This vague wording indicates that refresher training is not mandatory and 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 the facility 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”, a group not permitted to be subject to occupational exposure under the requirements of RPS C-1 (Rev.1). This is therefore considered to be an AFI. 

Radiation safety officer/Radiation safety committee The facility has a suitably qualified Radiation Safety Officer to undertake specific duties relating to radiation protection at the facility. The LP&As outline the requirements for a radiation safety working group (RSWG) within the branch including composition and business rules. The RSWG is scheduled to meet biannually in June and December. 

Planning & design of the workplace 

The facility comprises a locked, fully enclosed building on a restricted access military base. Only relevant, appropriately trained staff have access to the facility. All visitors to the facility require induction training at the front gate of the military base and a visitor register is signed acknowledging an understanding of the induction training before entry to the area is granted. 

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 entering the facility 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.

Security 

Security procedures 

The DoD has developed and implemented a comprehensive Security Plan (SP) that outlines: 

• physical security measures 
• site plan and location 
• procedures and administrative security measures 
• access and visitor control details 
• inventory and accounting check requirements 
• security education and awareness details 
• actions to take in a security incident
• response arrangements, and 
• reporting requirements. 

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

Emergency plans 

Emergency plans and emergency procedures 

Emergency plans and procedures for the site are outlined in both the LP&As and the SP. First responders will generally be base personnel, but this can be elevated to include 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 area 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(Rev.1) prohibits persons under the age of 16 from being occupationally exposed to ionising radiation. 

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