Inspection report: Department of Defence and the Australian Defence Force, Western Australia (R21/06336)
|Inspection report details|
|Licence holder:||Department of Defence and the Australian Defence Force|
|Location inspected:||Western Australia|
|Date of inspection:||9 June 2021|
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 source licence S0042.
The scope of the inspection included a performance assessment of a Defence Unit, located in Western Australia, against the Source Performance Objectives and Criteria. The inspection consisted of a review of records, interviews, and a physical inspection of sources.
The Department of Defence and the Australian Defence Force (Defence) are authorised under section 33 of the Act to deal with gaseous tritium light devices (GTLDs) in a range of apparatus.
The main codes and standards applicable to these sources are those that appear in section 59 of the Regulations plus:
- Australian/New Zealand Standard: Safety in Laboratories Part 4: Ionizing Radiations (AS/NZS 2243.4:2018)
In general, the management of safety and security was found to be strong. However, there appeared to be room for improvement with respect to aligning the risk assessments performed by the Defence Capability Acquisition and Sustainment Group (CASG) with the content of the Unit Radiation Safety Plan.
Accountabilities & Responsibilities
The Unit headquarters in Sydney governs the policies and procedures to be followed by all Unit locations, which are geographically dispersed across Australia. The primary Radiation Safety Officer (RSO) is located in Sydney. The responsibilities delegated to Unit headquarters are managed in accordance with the Commanding Officers Standing Orders for the regiment.
Safety policy and objectives
Defence maintains high level radiation safety policies and objectives including the Defence Radiation Safety Policy Statement issued by the Secretary of Defence and Chief of the Defence Force, and the Statement of Commitment and the Radiation Safety Management System both of which are issued by Commander Joint Logistics as single point of accountability for radiation safety across Defence.
These policies support the service-level radiation safety management plans and the Unit Radiation Safety Plan (RSP).
Risk assessment and mitigation
The Unit RSP was reviewed; it describes a range of relevant radiation hazards that personnel are likely to encounter through their daily activities. Hazards included RF, laser and ionizing radiation. The plan itself does not contain a specific risk assessment for the use of GTLDs however the associated technical guide Army Logistics Guide (MM 2-37) developed by the Capability Acquisition and Sustainment Group (CASG) provides a detailed risk assessment and recommended actions on hazards associated with the use of GTLDs. These risk assessments correctly identify that the GTLDs are primarily only a hazard when ruptured within an enclosed space. Furthermore, the RSP also refers to these situations under section 16 although not to the same level of detail. It was agreed during the inspection that the Unit RSP could be strengthened by including the specific risk assessment and guidance on actions in the MM 2-37 guide.
Monitoring and measurement
Combat Service Support Battalions (CSSBs) provide regular non-technical inspection and maintenance of GTLDs. The MM 2-37 guide identifies additional monitoring and measurement requirements for three (3) specific locations across Australia that are authorised for deeper level maintenance activities.
Training and education
All personnel joining Unit are required to perform initial employment training which includes a module on the use, hazards and actions associated with the GTLDs. This training material was reviewed during the inspection and was found to be adequate. The Unit RSO has specific training requirements for laser safety, RF safety and ionising radiation safety. Records of training were sighted during the inspection and found to be up to date.
Principles of radiological protection
The radiation protection principles applied in all instructions for the use of GTLDs includes aspects of time, distance (isolation should a GTLD become damaged) and shielding (in the form of appropriate packaging and the use of PPE when handling a damaged GTLDs). These aspects are addressed in the risk assessment section of the report.
Planning and design of the workplace
When not in use the GTLDs are stored separately from the mortar equipment that it is normally operated with, in a locked container and inside an enclosure that has sufficient ventilation. Access to this enclosure is limited to authorised personnel only. The workplace also contains appropriate radiation warning signage that meet the requirements of AS/NZS 2243.4:2018 and the emergency contact details on the workplace notice board were observed to be current.
Packaging and containment of radioactive waste
Section 55 and 56 of the MM 2-37 guide describes the safe course of action to be taken in the event of a breakage of a GTLD, including for it to be double-contained in transparent plastic packaging resistant to puncture. MM 2-37 Section 51 Table 7 refers to Safety Data Sheet’s PPE precautions which makes specific reference to use of a single pair of ‘leather gloves’ when handling damaged equipment; along with a general reference requiring the observance of precautions for gaseous tritium light sources set out in Annex 8B of the Defence Radiation Safety Manual (DRSM). MM 2-37 should be revised to recommend the use of latex or nitrile double-gloves in order to align with AS/NZS 2243.4:2018 and remain consistent with the existing advice contained in the DRSM in order to reduce the risk of contamination.
The method of packaging a damaged GTLD describes double bagging in sufficient detail to form a reasonable method to contain contaminated waste to reduce the exposure risk as a result of GTLS breakage. Guidance on labelling the package are also included, but could be further strengthened by including guidance on radiation trefoil signage in accordance with the requirements of the laboratory standard (AS/NZS 2243.4:2018).
Ultimate disposal or transfer
Management of ultimate disposal or transfer
Both the RSP and the MM 2-37 guide recognise that all GTLDs contain controlled material and specific guidance is included which requires personnel to seek advice on disposal from the Defence Radiation Safety Assurance (DRSA) team. This action initiates a s65 request for disposal/transfer to ARPANSA for prior approval.
The initial employment training material for the Unit and the MM 2-37 guide adequately describes appropriate actions in the event of a damaged or broken GTLD. These procedures include evacuating enclosed spaces, allowing a minimum of 30 minutes for venting and opening windows and doors of a enclosed space to allow sufficient venting. Isolation of a damaged GTLD and requirements for contacting the RSO are also established in the emergency procedures. All radiation incidents are required to be reported to the Defence Sentinel reporting system and subsequently transmitted to DRSA and ARPANSA. Table 7 of the MM 2-37 guide also identifies a range of first aid and decontamination procedures relevant for exposed personnel.
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:
- The risk considerations in the MM 2-37 guide should also be captured in the Unit radiation safety plan and should also contain specific guidance for training on actions to be taken in the event of a damaged GTLD.
- Guidance on labelling packages containing damaged GTLDs should be revised in accordance with the requirements of AS/NZS 2243.4:2018. It is expected that improvement actions will be taken in a timely manner.