| Licence holder | The Director of National Parks, a corporation within the Department of Climate Change, Energy, the Environment and Water portfolio |
| Location inspected | Koongarra, Northern Territory |
| Licence number | S0340 |
| Inspection date | 17 July 2024 |
| Report number | R24/05672 |
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 S0340. The scope of the inspection included an assessment of performance at the Koongarra site against the Source Performance Objectives and Criteria (SPOC). The inspection consisted of a review of records, interviews, and physical inspection of sources.
Background
The Director of National Parks (DNP) is responsible for, inter alia, managing Commonwealth reserves and conservation zones, protecting biodiversity and heritage in Commonwealth reserves and conservation zones, carrying out research relevant to Commonwealth reserves, and making recommendations to the Australian Government Minister for the Environment. Specifically relating to the Koongarra licence, the Office of the Supervising Scientist branch (OSS) of the Department of Climate Change, Energy, the Environment and Water undertakes research and environmental monitoring on behalf of the DNP to protect people and the environment from the effects of the legacy uranium mining site at Koongarra in the Alligator Rivers Region of the Northern Territory. The DNP is licensed to deal with unsealed radioactive sources at its Koongarra site under section 33 of the Act. The main codes and standards applicable to this licence are:
- 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 Part 4: Ionizing radiations (AS/NZS 2243.4:2018)
Observations
In general, the management of radiation safety by OSS on behalf of DNP in relation to the controlled material at the Koongarra site was found to be satisfactory. In some cases, however, there appeared to be an area for improvement (AFI) in relation to documentation.
Effective control
Management commitment and statutory and regulatory compliance
OSS has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective storage of radioactive material at the Koongarra site. This is supported by a comprehensive set of Plans and Arrangements for Managing Safety (P&As) to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions. OSS 6-monthly 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. During the inspection however, the following AFI relating to the P&As was identified:
- Discrepancies between the identity of the Radiation Safety Officer (RSO) in the P&As and that recorded in the ARPANSA licence administration database.
Documentation and document control
The S0340 licence was issued to the Director of National Parks on 7 February 2022. Under that arrangement, the OSS assumes the role of the licence nominee with responsibility for overall management of the licence, including the Koongarra site. These management arrangements are described in detail in Section 3 of the P&As. The P&As reviewed during the inspection were the initial version with next review of the document due by the end January 2025 at the latest.
Safety management
Monitoring and measurement
SS performs an inspection of the site once a year near the beginning of the dry season (generally May-June) and on an ad hoc basis at other times. It is noted that the site is effectively inaccessible during the wet season due to impassable creeks and similar environmental issues resulting from the high rainfall throughout that time. These inspections identify: • changes to the integrity of the shipping containers, fences and gates • whether there are any signs of unauthorised access • vegetation build up, and • any changes to radiation dose rates around the containers and boundary fence. The results of these inspections are documented, and the inspection reports were viewed during this inspection.
Managing change
It is intended that the entire Koongarra site, including non-radiological aspects of the former mining area, will be rehabilitated in the future with the object of returning it to a ‘green field’ site for handing back to the traditional owners. The decommissioning and removal of the unsealed source storage compound will be subject to a comprehensive Section 63 or Section 65 request at the appropriate time.
Training and education
The P&As required all personnel attending the site to undergo a safety induction in accordance with the items specified in Appendix C of the P&As. Apart from radiological risks, this induction training also included information on physical and security risks due to the isolation and potentially harmful environmental effects at the site (e.g. heat, humidity, and lack of phone contact in the event of an emergency). Records of safety induction training for all personnel entering the site were seen during the inspection. The Koongarra Source Visitor Register was also seen online during the inspection.
Radiation protection
Radiation safety officer/Radiation safety committee
The OSS RSO, licence nominee and licence manager were in constant discussion during day-to-day work activities at the Eaton laboratories (under the S0015 licence) and any radiation related matter about the Koongarra site would be discussed at the relevant time or by e-mail where necessary. This was considered to negate the need for a formal Radiation Safety Committee.
Planning and design of the workplace
The site is in a remote part of Kakadu National Park and barred to the public by a locked gate. It is only accessible by 4WD vehicles along several kilometres of rough track after passing through the locked gate. The general area of the site contains old buildings, diesel storage tanks (empty) and other mining equipment left over from the old mining operations. The freight containers containing the contaminated equipment, drill cores and other similar potentially contaminated items are located inside a locked cyclone fence encircled compound with clearly visible warning labels and contact details at the front gate. While some containers had isolated spots with elevated dose rates (~10-30 µSv/h), no levels above the background radiation level were found around the perimeter of the boundary fence.
Personal protective equipment
The P&As require that a P2 dust mask must be worn by any person opening a container. These were available but not required during the inspection as it was not considered necessary to open any container.
Monitoring of individuals
Personal radiation monitoring was not required as dose rates at the site are low, and the time spent in and around the compound is short (<1 h per year).
Radioactive waste
Management of radioactive waste
No radioactive waste is produced under this licence as the compound is simply a storage area for legacy mining waste until such time as an ultimate disposal pathway can be determined.
Ultimate disposal or transfer
Management of ultimate disposal or transfer
The intention is to ultimately rehabilitate the whole site, including the radiological and non-radiological aspects, and return the area to the traditional owners. This will require considerable planning and logistics due to the largely inaccessible location of the area.
Security
Security procedures
The sources in storage at the site would not invoke the requirements of RPS 11. Only authorised and inducted personnel have access to the site and access to the area is via a locked gate followed by a ARPANSA-TMP-1943 v1.1 06/23 S0340 R24/05672 4 of 4 narrow ungraded track with creek crossings necessitating a 4WD vehicle. Once at the site, the entry gate to the compound is also locked. Access to the area is limited to the OSS and DNP staff and only after a site induction. This inspection showed that the gate, fences and signage were in satisfactory condition with no sign of unauthorised access.
Emergency plans
Emergency plans and emergency procedures
Section 9 of the P&As outlines procedures that will be followed and the actions taken in the event of a cyclone, fire, flood, etc. in the area. OSS staff will investigate the compound for any containment breaches following such an event but only when safe to do so. ARPANSA will be advised of any damage accordingly.
Protection of the environment
Protection of wildlife and monitoring of the environment
As highlighted in Section 10 of the P&As, ‘the only potential radiation exposure pathway to animals and plants is from gamma radiation passing through the walls of the shipping containers’. Based on measurements taken during the inspection, environmental effects from the site are not considered significant.
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 identity of the Radiation Safety Officer (RSO) in the P&As did not match that recorded in the ARPANSA licence administration database.
It is expected that improvement actions will be taken in a timely manner.
