Inspection report: Department of Defence and Australian Defence Force (Defence), NSW (R22/01115)

An inspection was conducted as part of ARPANSA’s baseline 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 F0113.

The scope of the inspection included an assessment of Defence’s performance at the Radioactive Waste Storage Facility against the Performance Objectives and Criteria (POC). The inspection consisted of a review of records, interviews, and physical inspection of the facility.

Background

The Radioactive Waste Storage Facility is a prescribed radiation facility which stores obsolete or unrepairable equipment, or parts of components that contain low level radioactive materials. The radioactive material will be stored in the facility for an interim period until a national radioactive waste management facility is established.

The main codes and standards applicable to this facility are those that appear in section 59 of the Regulations plus:

• Australian Standard - Safety in Laboratories - Ionizing Radiations (AS/NZS 2243.4:2018)

Observations

The facility management of radiation safety and security was found to be in compliance with the Act and Regulations and was generally well aligned with the ARPANSA POC. In some cases, however, there was room for improvement with respect to the documentation, radiation protection and emergency preparedness.

Performance reporting verification

The reporting of information was verified and found to meet the requirements specified in the licence and relevant legislation.

The facility uses a centrally operated electronic event management system for registering, managing and tracking events or near misses to share lessons learnt among Defence facilities. The system provides instructions on what type of events must be recorded. There have been no recent radiation events at the facility, but personnel were familiar with the reporting requirements and the system operation.

Inspectors observed that the communication and interaction between staff and management was open and healthy including that between the facility and headquarters staff.

The previous inspection in March 2019 identified the absence of a decommissioning plan as an area for improvement. The plan is required by section 46 of the Regulations to show that the licence holder broadly understands how the facility will eventually be closed and removed from regulatory control. In many facilities this will also be a consideration in deciding the range of processes performed during the operational life of the facility, i.e. the use of the facility must be compatible with decommissioning it safely. An advanced draft of a decommissioning plan for another facility that will form the basis for a plan at this facility was provided. However, it is important that the plan for this facility is developed. This continues to be an area for improvement since the plan is yet to be finalised.

Configuration management

The facility uses the Defence corporate documentation system for managing operations. This system is supplemented with local procedures specific to the activities carried out within the facility. All activities were found to be covered by overarching procedures, however Defence has recognised the need and started to write an additional suite of detailed instructions to describe how to carry out specific tasks. These tasks involve dismantling the obsolete or damaged equipment and components, removing radioactive sources and storing them safely and securely within the facility. Currently, the work is carried out based on manufacturers’ information or information from the operators. It is important for safety to have instructions to ensure the sources remain intact during the deconstructing operation. Instructions are also important to retain the corporate knowledge and experience for new staff members. A brief review of the contents of documents being prepared indicated them to be of a good standard. Although the current range of instructions is less than optimal, Defence’s intention and plan to complete the documents is acknowledged. ARPANSA will monitor progress in this area.

The change control process is managed using the corporate protocols observed to be in place. The facility operation appears to be optimised and has not recently undergone any change with significant implication for safety. Contractors are escorted on site and managed by applying the corporate processes.

Inspection testing and maintenance

Maintenance of the facility and equipment is managed using a corporate electronic system. All maintenance is carried out by contractors. The facility personnel are not involved in maintenance directly. The maintenance schedule and records were examined, and no issues were identified. The calibration of the radiation and contamination monitors had been conducted within the required intervals as demonstrated by calibration certificates. However, the facility walk-around showed that not all radiation monitors bear a calibration sticker. This is considered to be important information presented on each instrument so any user can immediately verify the monitor is ready for use. This constitutes an area for improvement.

Training

The training records of all personnel were examined. All staff members are appropriately qualified and trained. Refresher training is completed annually according to the relevant Defence protocols and adequately recorded. The refresher also includes emergency training. Due to COVID-19 health restrictions the training was carried out virtually in 2021.

Event protection

The licence holder maintains appropriate controls regarding minimising and mitigating hazards including the presence of combustibles and land care around the building to protect against external influences such as bush fire and flood. Grass within the facility fence is mechanically cut and within the main site is grazed by sheep and kangaroos. There are only two or three small trees within the facility. It was judged that there was no credible risk to the facility from bush fire and all gutters and stormwater drains were observed to be clear of debris. Flammable liquids used to carry out the work tasks are stored in a metal cabinet outside the building. Their quantities are kept at household levels and regularly verified by WHS audits. No deviations were identified.

The fire extinguishers are maintained appropriately. No significant build-up of natural fuel loads in the vicinity of the building was observed. There was no evidence of pest damage. Pest controls were sighted to be in place.

Security

There has been no significant change to the facility security arrangements since the last inspection in 2019. The facility Security Plan and associated procedures have been updated in accordance with the relevant Defence schedule and licence requirements. There are overarching Defence corporate systems in place to assess and approve security related changes. The records of the facility personnel showed the security training refresher is completed annually in accordance with procedures.

Radiation protection

Dose records were reviewed and found complete. The doses received by personnel over the last two years are very low and close to background levels.

The facility has reported no recent radiological events. The operational risk assessment that assumes appropriately conservative hazards is updated biannually. The risk controls identified in the assessment were checked and found readily available to personnel. This included, among other things, nitrile gloves for general work, respirators and tyvac suits for tasks involving work with more heavily contaminated items. The PPE does not include protective clothes such as lab coats to be used exclusively within the radiation area for work with a relatively low risk of contamination. The use of lab coats would provide useful additional protection and is required by clause 4.8.5(f) of AS/NZS 2243.4:2018. It is noted that the emergency protocol for a leak or spill contains instructions for dealing with contaminated clothing but it does not mention how the contaminated items are replaced. This and the standardised use of lab coats is considered an area for improvement.

The facility is periodically checked for contamination by implementing the health physics survey schedule. The work areas are surveyed for tritium and alpha emitters weekly at minimum, the outside area is surveyed annually, and airborne radon monitoring is continuous.

The source inventory and process tracking were found comprehensive, complete and accurate.

Emergency preparedness & response

The facility emergency structure has been maintained with minimal changes over previous years. The emergency procedures are based on the facility Emergency Plan which includes external hazard scenarios. The emergency response involves several off-site responders e.g. NSW RFS/HAZMAT, AWMA First Responders, NSW Ambulance. The emergency instructions are well developed considering the type of facility. The responders annually participate in evacuation drills. The records indicated that the last evacuation drill was completed in February 2021.

Although the Emergency Plan contains a set of emergency scenarios, there were insufficient records of impact assessment to investigate consequences on workers and the environment. It is good practice that appropriate and auditable safety assessments are conducted to assure adequate controls are in place to prevent postulated scenarios occurring and mitigate their impact. This is an area for improvement.

Emergency equipment is appropriately maintained and regularly checked according to the Emergency Plan schedule. The relevant records were found to be complete. The emergency decontamination shower is located outside the facility on a sloped concrete surface. Although the portable bund to prevent shower runoff into the stormwater drain system had been provided in the past, it was not present at the time of inspection. This is an area for improvement.

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:

1. The Decommissioning Plan should be finalised as soon as possible
2. A calibration sticker should be located on each radiation monitor and a system to maintain the sticker information up to date should be developed
3. Arrangements for tasks that potentially include contaminated items should be reviewed against applicable standards including AS/NZS 2234.4:2018, particularly in regard the PPE used for the full scope of work conducted in the facility
4. Consideration should be given to reviewing and documenting the facility emergency scenario assessments to assure appropriate risk controls are in place for EPR management
5. Reintroduction of the emergency shower portable bund

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