Inspection report: The Director of National Parks, a corporation within the Department of Climate Change, Energy, the Environment and Water portfolio, F0093

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 facility licence F0093. The scope of the inspection included an assessment of performance at SADF against the Facility Performance Objectives and Criteria (FPOC). The inspection consisted of a review of records, interviews, and physical inspection of the site.

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 SADF licence, the Office of the Supervising Scientist (OSS) within 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 waste at SADF in the Alligator Rivers Region of the Northern Territory. 

The DNP is licensed to deal with unsealed radioactive sources at its SADF 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)

Observations

In general, the management of radiation safety and security by OSS on behalf of DNP in relation to the controlled material at the SADF site was found to be satisfactory. In some cases, however, there appeared to be areas for improvement (AFIs) in the 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 SADF site. This is supported by a comprehensive set of Plans and Arrangements (P&As) for safety management and environmental monitoring  to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions. OSS annual 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 AFIs relating to the P&As were identified: 

• There were no version or review details in the P&As. 
• References to persons occupying the positions of the licence holder and site manager who no longer work in the organisation
• 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

Section 1.3 of the P&As outlines the arrangements between the DNP and the OSS. Under that management arrangement, the OSS assumes the role of the licence nominee with responsibility for overall management of the licence and, therefore, the SADF site. Accompanying the P&As is a comprehensive safety case for SADF that details all aspects of the site including, but not limited to: 

• site selection process 
• regional characteristics 
• geology
• groundwater characteristics 
• design and construction 
• local biology 
• management arrangements 
• operational safety arrangements 
• radiation monitoring such as external radon groundwater and vegetation 
• long-term results of radiation monitoring 
• quality analysis/quality control, and 
• a placeholder for closure criteria and decommissioning. 

The safety case had some minor internal referencing errors that most likely arose from the software program used to create the document. These were not considered significant as the content was still valid, but should be rectified during a document review. The safety case is scheduled for review on a three yearly basis. The current version, version 1, was approved in August 2022 with the next review being by August 2025 at the latest.

Safety management

Monitoring and measurement

OSS performs an inspection of the site once a year near the beginning of the dry season (generally May-June) and at other times on an ad hoc basis. 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 consider changes to the integrity of the fences and gates, erosion, whether there are any signs of unauthorised access, evidence of water retention, vegetation build-up, as well as any changes to radiation dose rates around the site. 

The results of these inspections are documented, and the inspection reports were viewed during this inspection.

OSS also maintains a visitation register for the facility. This was seen during the inspection.

Managing change

It is intended that the SADF site will eventually be rehabilitated with the object of returning it to a ‘green field’ site for handing it back to the traditional owners. This is briefly outlined in Section 10 of the P&As as indicated above.

Training and education

No specific training is required for personnel routinely accessing the site due to surface radiation levels not differing significantly from the background level for the area. However, the P&As require any personnel who are involved with significant repair of the growth medium or clay cap to receive radiation safety training. As there has been no need for any such procedures at the site to date, no training of this type has been performed.

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 SADF 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. At the time of inspection, the road was blocked to the public by a gate although it might be open again in future. The nearby road is driveable with a normal (non-4WD) vehicle in the dry season although this would not be the case during the wet season due to severe flooding of several watercourses along the way. The site is surrounded by a cyclone fence topped with barbed wire. Two sets of gates are located on the perimeter fence although only one is used for access. Entry points are clearly labelled with radiation warning signs and contact details. The four corners of the burial area inside the fenced area are each marked by a concrete plinth with a radiation warning sign. No radiation levels above the background level for the general area were found above or near the burial area.

Personal protective equipment

No personal protective equipment relating to radiation exposure was required for anyone visiting the site.

Monitoring of individuals

Personal radiation monitoring was not required for personnel accessing the site as dose rates do not differ from the background dose rate in the general area, based on the results of long-term monitoring.

Radioactive Waste

Management of radioactive waste

No radioactive waste is produced under this licence as the site is the ultimate disposal location for the waste buried there.

Ultimate disposal or transfer

Management of ultimate disposal or transfer

The current intention of DNP is to ultimately rehabilitate the whole site and return the area to the traditional owners. This will require considerable planning and logistics due to the depth and volume of the buried waste but is not expected to happen in the short term.

Security 

Security procedures

Only authorised personnel have access to the site and entry is via a gate which is secured by a lock and key. Access to the area is currently limited to OSS and DNP staff and it is unknown whether the public will have access to the general area again in future. 

Emergency plans

Emergency plans and emergency procedures

No specific procedures for an emergency are outlined in the P&As although para 3.16 requires a check of the site following an extreme event such as a cyclone, bushfire, flood, etc. in the area. OSS staff will investigate the facility for any damage 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 

Ongoing monitoring on and around the site for radon, gamma exposure, hydrology, groundwater, vegetation, erosion, and meteorology is conducted in accordance with the requirements contained in Schedule C of the P&As. The results of this testing are incorporated into an environmental monitoring report, a copy of which was seen during the inspection. 

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 areas for improvement: 

• There were no version or document review details in the P&As. 
• The P&As contained incorrect references to relevant staff. 
• There were discrepancies between the identity of the RSO in the P&As and that recorded in the ARPANSA licence administration database.

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