UNCLASSIFIED

Inspection Report

Licence Holder:Department of Defence and Australian Defence Force (Defence) / Licence Number:S0042
Location inspected:Defence base in North Queensland / Date/s of inspection:28 February - 15 March 2017
Report No:R17/02698
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 1999 (the Regulations), and conditions of Source Licence S0042.
The scope of the inspection included an assessment of Defence’sperformance against the Source Performance Objectives and Criteria (PO&Cs) and consisted of a review of records, interviews, and physical inspection of the X-ray machine.

Background

Defence responds to the identification of improvised explosive devices and explosive ordnance. In this capacity, Defence often uses portable X-ray machines to radiograph the item prior to rendering it safe.

Observations

Performance Reporting and Verification

Defence has developed standardised templates for reporting safety matters to the regulator. These are transmitted through the administrative command relevant to the Unit and then collated centrally for communication to ARPANSA. The chain-of-command relevant to this unit was able to demonstrate that the Unit had been submitting these reports as required. Guidance addressing the type of matters that should be reported is also available.

Inspection Testing and Maintenance

The X-ray machine is sent away for technical inspection by the Australian supplier. This is supplemented by non-technical inspections which are conducted by the operators themselves. These ensure that the equipment is functional and remains ready for use. The physical review occurs in the office and the firing of X-rays is conducted in a controlled environment on a range. It was observed that records associated with the technical inspections and non-technical inspections are held in a central Defence logistics database.

Training

Operators are required to undertake annual refresher training in radiation protection. This is typically provided by the DIRPO. The training package contains general information about hazards of radiation as well as specific information that has been tailored to the safe management of this particular type of X-ray machine. The training package contains several details that are incorrect or out-of-date. This includes references to legislation, internal policy documents, international bodies and the Defence incident reporting framework. A new DIRPO trained officer has just arrived on base. He has identified shortcomings with this package and has started working to update and correct the information.

Event Protection

Arrangements are in place for Defence to respond to the identification of a suspect package or object found in a civilian environment. This is done at the request of the police force controlling the situation. In these circumstances, the police force manages the area that is evacuated and controls the scene including the local civilian population.

Security

The X-ray machine is located in a locked store room within an access controlled building on a Defence base. The keys are held in a secure location.The safety officer and stores officer are authorised to handle the box containing the X-ray machine as well as perform checks to confirm that all of the components are present. However, they are not authorised to operate the device. When the device is sent away for technical inspection, the key does not travel with the device as the service body has its own keys to control the X-ray machines. These arrangements control the access and operation of the X-ray machine.

Radiation Protection

The X-ray machine is typically sold by the supplier as part of a kit. This kit includes an Electronic Personal Dosimeter (EPD). Defence have demonstrated that the EPD supplied with the kit is unsuitable for measuring the radiation produced by the X-ray machine. However, this advice has not been reflected in DEOP 116leading to inconsistent usagewithin the Defence user community.
Until recently, the unit relied upon support from a Defence Ionising Radiation Protection Officer (DIRPO) who was physically located in Sydney. This DIRPO would review documentation when requested. However, records of the review were not being kept in a central location. Similarly, this DIRPO was not reviewing the dose records as they were being received, although, they were being reviewed at a higher level.A new DIRPO trained officer has just arrived on base, and as such, an arrangement has been put in place so that the new DIRPO will in future review the dose records.

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 annual refresher training contains incorrect and out-of-date information.
2.Communication of technical matters associated with the training and use of EPDs.
3.Record keeping associated with DIRPO review of documentation and dose records.
It is expected that improvement actions be taken in a timely manner.

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UNCLASSIFIED