Inspection report: Department of Defence and Australian Defence Force, S0042, 24 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 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, medical use, non-destructive testing (NDT) of objects, X-ray examination of objects and parcel examination. 

The main codes and standards applicable to the controlled sources inspected at this site are: 

• 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)

Observations 

In general, the management of safety margins at the site was found to be satisfactory. However, there appeared to be room for improvement in relation to the various Radiation Safety Plans (RSPs). The scope of this inspection was the non-destructive testing apparatus. Other controlled sources, including those covered by the site security plan, would be inspected at a later date, expected to be within the subsequent 12 months. 

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, DRSA consolidates this information into one finareport 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) were, however, identified during the inspection: 

1. One of the Defence Ionising Radiation Safety Notices in the X-ray exposure building was out of date and therefore contained incorrect contacts (related to para 3.1 of the 071, 072 and 075 RSPs). 
2. The link to the risk assessment in the 072 RSP (para 5) did not take the user to the correct document. 
3. One Risk Assessment had not been reviewed within the timeframe specified in the 075 RSP.

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 related to non-destructive testing under the management of DoD at this site were present and accounted for in relation to the DoD source inventory workbook. 

Documentation and document control 

Records showed that most documentation related to the controlled radiation sources at the site, such as the RSP and other associated documents, had been reviewed within the required time. It was noted, however, that the document review schedule varied in some of the RSPs, particularly for the review of risk assessments (RAs). RA reviews were scheduled for 2 years in some cases and as long as 5 years in another. In the latter case, there was the proviso for more frequent review ‘as required’. At least one of the RAs (4201) had not been reviewed in the timeframe specified in the 075 RSP representing an AFI, as already mentioned above. 

Safety management 

Safety policy and objectives 

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

Monitoring and measurement 

The RSPs required annual radiation surveys around the exposure bays. Records of these surveys were seen during the inspection although the 2023 survey results were not readily available. The checklist for that survey had, however, been completed indicating that it had been done. Three survey meters had recently passed their calibration due date (August 2024) and were in the exposure bay area for sending off for calibration. Other than the calibration stickers on the meters, there was no indication that they were not to be used for survey monitoring. Two in-calibration survey meters were located at the industrial CT control panel.

Training and education 

Only trained NDT personnel were permitted to operate the industrial radiography X-ray equipment at the site. Only the current NDT technician, who also doubled as the Defence Ionising Radiation Protection Officer (DIRPO) for the whole site, was currently trained. Three persons, including the trained NDT technician/DIRPO, were listed as approved operators for the industrial CT scanner. Induction training records for relevant staff were viewed during the inspection. 

Radiation protection 

Planning and design of the workplace and local rules and procedures 

The radiography bay was considered fit-for-purpose and all signage, training, personal protective equipment, safe work procedures, usage logs, record keeping for both the industrial radiography procedures and the fully enclosed industrial CT equipment appeared to be satisfactory. Rope barriers and portable signage for open site radiography were observed and considered satisfactory. The RSP required that for industrial radiography with a horizontal primary beam direction, this must only be performed with the beam pointed towards the south wall. While such radiography was very rare, the last one being at least 7 years before the inspection, there was no indication inside the bay itself which wall was the south one. 

Monitoring of individuals 

All personnel using the radiography equipment are required to wear personal monitoring badges issued on a quarterly basis. Results of personal monitoring was seen during the inspection. The RSPs contained three investigation levels although there was no formal sign-off on the quarterly dose reports to indicate that they had been checked against the investigation levels. The 072 RSP required personal monitoring records to be kept for an extended period consistent with the requirements of RPS C-1. There was no evidence that this was being done at the site or at a Departmental level. This is therefore considered to be an AFI. 

Transport 

Given the nature of the controlled sources used at the base, transport was not an issue.

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 

Security procedures 

There were no sources at the site that would invoke the requirements of RPS 11. 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. Access to the industrial radiography bays was further restricted to the NDT technician/DIRPO who kept the keys with him at all times. 

Emergency plans 

Emergency plans and emergency procedures 

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 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: 

1. Some signage in the radiography bay building was out-of-date. 
2. At least one link in the RSPs was not correct. 
3. One RA had not been reviewed within the timeline set in the related RSP. 
4. No evidence that long-term personal radiation monitoring records were being kept. 

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