Inspection report: Department of Defence and Australian Defence Force, S0042

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 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-2 Code for the Safe Transport of Radioactive Material (Rev. 1) (2019) 
• RPS 5 Code of Practice and Safety Guide for Portable Density/Moisture Gauges Containing Radioactive Sources (2004) 
• RPS 11 Code of Practice for the Security of Radioactive Sources (2019) 
• Australian/New Zealand Standard Safety of laser products Part 1: Equipment classification and requirements (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 margins at the base was found to be satisfactory. However, there appeared to be room for improvement in relation to the contents of the Ionising Radiation Management Plan (IRMP) and the Laser Safety Plan (LSP). 

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, to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions. Each DoD group in turn, has their own ‘local’ plans and arrangements based on the DRSM to suit the sources they use on the given site. 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 local IRMP and LSP were identified during the inspection: 

• There were no records of the refresher training required by paras 11b and 16 of the IRMP. 
• The officer in charge of the gauges was not providing individual dose readings for operators to medical staff in accordance with para 11e of the IRMP. This task was left to the individual users. 
• There were no records of quarterly laser inspections, and the LSO was not present during these laser inspections (para 11 of the LSP).

Resources

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 inspections. It has been proposed that this arrangement of ARPANSA inspections being independent of DRSA inspections continue as the DRSA inspections concentrate on different issues from those of ARPANSA. 

All controlled sources under the management of DoD at this site were present and accounted for in relation to the DoD source inventory workbook for the equipment inspected. Sources at the base include portable moisture density gauges (PDMGs) used for teaching purposes and lasers used for operational procedures. Each are covered by the IRMP and LSP respectively.

Documentation and document control

Records showed that documentation related to the controlled radiation sources at the base such as the IRMP, LSP and other associated documents had been reviewed within the required time. However, there were references to the previous edition of AS/NZS IEC 60825.14:2022 in the LSP.

Safety management

Safety policy and objectives

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

Monitoring and measurement

Annual maintenance and calibration of the PDMGs was performed by a third-party external provider. Wipe tests of the sources were done during this maintenance procedure with reports of the maintenance outcomes given to the Barracks senior staff.

Training and education

Only personnel who had received the relevant training from an external civilian provider were permitted to operate the gauges. A sample of the training records was viewed during the inspection. The IRMP required all operators to complete refresher training on the PDMGs every 12 months although there were no records to show that this training had taken place, thus resulting in an AFI. 

The nominated Laser Safety Officer was not located at the base although this was permitted under the provisions of the LSP. The laser radiation safety notice included in the LSP contained the name and contact details of a different person from that provided during the inspection. This needs to be rectified to avoid confusion for personnel using lasers at the base. 

Laser radiation awareness training is included in induction and annual awareness training programs for users of the laser equipment. Records of this training are kept on individual, personal files and were not readily accessible during the inspection.

Radiation Protection

Principles of radiological protection

The IRMP outlines dose constraints for occupationally exposed personnel for all conducts or dealings with the PDMGs. The IRMP also includes investigation levels with ranges that dictate the level of investigation required should the measured dose fall into that prescribed range. At 5 mSv in any one quarter, all ionising radiation work was to cease pending a full investigation of the reason for exceeding that level. To date, no dose had been received that warranted even the lowest level of investigation.

Local rules and procedures

Local rules and procedures are available online and in hard copy form near the PDMG store and the laser storage bunker. All signage, portable barriers, the radiation store itself including security and dose rates outside the store, and transport needs (e.g. placards, package labels) were considered to have met the requirements of the relevant codes for the PDMGs. All lasers were stored inside a secure bunker when not in use. Appropriate signage and documentation were in evidence around the bunker.

Personal protective equipment and monitoring of individuals

All personnel operating the PDMGs or accessing the PDMG store are required to wear personal radiation monitoring badges. Records of the results arising from the personal monitoring were viewed. It was noted that paragraphs 46 and 47 of the IRMP conflicted in the naming of the personal monitoring service provider and would need to be amended to avoid confusion. 

Paragraphs 3e, 3h and 3j(1) of Annex B of the IRMP contained conflicts in the distance a person is permitted to be from a PDMG when in use and whether or not that person must be wearing a personal monitoring badge. This needs to be clarified to avoid confusion.

Radioactive Waste

Given the nature of the controlled sources used at the base, no radioactive waste is produced.

Ultimate disposal or transfer

Management of ultimate disposal or transfer

Disposal or transfer of controlled sources is managed through DRSA who apply for approval via Section 63 applications. DRSA advises all disposals in the relevant quarterly reports.

Security 

The aggregation of the sources at the site would not exceed Category 4 in accordance with the methodology outlined in RPS 11. The safety requirements in RPS 5 are therefore adequate for security purposes on the base. 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. 

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 base. These were not assessed during the inspection due to the size of the base. 

Protection of the environment 

Protection of wildlife and the environment 

Given the nature of the controlled sources used at the base, there should be no effect on either wildlife or the environment. 

Findings 

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

The inspection revealed the following areas for improvement: 

• There were no records of refresher training. 
• Individual dose records were not being provided to medical staff by the Officer-in-Charge of Gauges. 
• There was no evidence that quarterly laser inspections were being carried out and the LSO was not present during these laser inspections. It is expected that improvement actions will be taken in a timely manner.