Inspection report: Department of Defence and Australian Defence Force, S0042, 11 September 2024

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 three 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 are: 

• RPS C-1 Code for Radiation Protection in Planned Exposure Situations (Rev. 1) (2020) 
• 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 Radiation Safety Plan (RSP).

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 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 has, in turn, their own ‘local’ RSP based on the DRSM to suit the sources they use on the given site/base. 

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. 

However, the following area for improvement (AFI) relating to the local RSP was identified during the inspection: 

• Several of the links to subordinate documents in the RSP did not take the user to the correct document.

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 continues 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. 

This regiment deals mainly with laser devices. However, an industrial radiography X-ray set was listed on the local source inventory. Regimental staff explained that this apparatus was being transferred from the originating DoD unit for overseas deployment and the inspected regiment was simply facilitating the transfer.

Documentation and document control

Records showed that documentation related to the controlled radiation sources at the base, such as the RSP and other associated documents, had been reviewed within the required time. 

Paragraph 12 of the RSP, however, referred to incorrect Annexes in the document, which would need to be corrected to avoid confusion. Further, there was reference to RPS 3 in the RSP. This has been superseded by RPS S-1 and will therefore need to be updated.

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.

Training and education

All personnel dealing with the laser devices require training before use. This is at the so called LSO2 level. A sample of training records were viewed during the inspection. Changing the configuration of the lasers by the user was only permitted under a specific authorisation of the senior officer as designated in the RSP.

Radiation protection

Radiation safety officer/radiation safety committee

The Unit Radiation Safety Officer and Radiation Safety Officer, LSO1 were both identified in the RSP.

Local rules and procedures

Local rules and procedures are available online and in hard copy form near the laser storage bunker. 

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

Protective laser goggles were not required as, during normal use, the laser equipment only produces a laser output of class 2 or less.

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 ARPANSA of all disposals via the relevant quarterly reports.

Security

The controlled sources used at the site do not invoke the provisions of RPS 11. Regardless, 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 would 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 area for improvement: 

• Some links in the RSP did not take the user to the indicated document. 

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