Regulatory Assessment Report
Regulation 51 Change
Date received
Wednesday, 24 October 2018
RELEASED
Licence holder
CSIRO Business Infrastructure Services
Licence number:
S0013
File No.
R18/12955
Documents assessed
R18/12951 Regulation 51 Application
R18/12950 Site Activities, Radiation Protection Plan and
Radiation Risk Control Plan
BY
Contact details of person making
Jen Baxter
the request:
ARPANSA
Assessor(s)
Loch Castle
1. Summary of the proposed change
As part of continuing to assess and pre-characterise the radiological contents at Woomera Hangar 5, CSIRO
UNDER
intend to conduct an upgrade to the hangar access doors, install active radon monitoring, recover passive
radon monitors and continue further robotics assessments of the waste contents. In particular, a 3D Lidar
mapping task is intended to be performed on this occasion.
2. Background on the proposed change
FOI
CSIRO provided a R51 application on the 24th October, consistent with a previous R51 which was approved
in early 2018. ARPANSA requested additional information ARPANSA attended the most recent activities in
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early 2018 in order to monitor their activities in accordance with their plans. ARPANSA regulatory officers
were satisfied with CSIRO’s management and performance of those activities and they were conducted
safely.
3. Scope of the assessment
The assessment includes the R51 application itself, the proposed site activities, the radiation protection plan,
and considering the remote nature of the location, the adverse environmental conditions which could impact
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the performance of staff and reduce their alertness and energy/concentration levels, the normal WHS
considerations are also in scope as they have the potential to cause accidents.
4. Arrangements for maintaining safety and security
The following criteria have been considered:
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Safety Analysis Report
Not applicable as this is a source licence.
Effective Control
Effective control is maintained by CSIRO for the inventory. Access control is maintained by the Australian
Defence Organisation. Technical control is maintained by CH2M and Jacobs contractors, under the
supervision of CSIRO BIS.
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Safety Management Plan
The analysis activities generally do not have the potential alter the safety of the site. Most of the activities
involve passive data collection techniques which are unlikely to introduce safety concerns. However, one
activity to upgrade the hangar access door is a positive action. CSIRO’s Risk Management Plan has considered
this risk, and has introduced a number of measures to the satisfaction of the assessor, to mitigate their
likelihood and consequences.
BY
Radiation Protection Plan
ARPANSA
The contents being analyses are of very low hazard. Nevertheless, the supplied Radiation Protection Plan
demonstrates a range of measures, including spill kits, decontamination arrangements and PPE use, which
are appropriate for this activity. The assessor is satisfied that radiation protection is adequately addressed.
Radioactive Waste Management Plan UNDER
Generally not applicable. However, CSIRO have described arrangements for containing, collecting and
removing any generated waste, which may occur through either contaminated robots/components or
through the toppling/damaging a drum. The assessor considers these arrangements to be adequate.
Security Plan
FOI
Security is managed by the Australian Defence Organisation and the assessor is confident that the
arrangements are adequate.
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Emergency Plan
Emergency management arrangements are coordinated with the Australian Defence Organisation. Specific
emergency and notification arrangements have been developed for this particular activity. Spill kits,
decontamination equipment, PPE, radiation detection equipment, waste collection tools, HEPA-filtered
vacuums and heavy plant equipment are available in the event of an emergency. The assessor is satisfied
with the arrangements in place.
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5. Additional matters taken into account
The following criteria have been considered:
Whether the application includes all the information asked for
The applicant has supplied all of the information required to make an assessment.
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Whether the information establishes that the proposed change will not result in undue risk to the
health and safety of people, and to the environment
The proposed activity is unlikely to result in any undue risk and is similar in nature to a previous activity that
was undertaken in early 2018. The assessor is satisfied that people and the environment will be protected.
Whether the applicant has shown that the change has a net benefit
The proposed activity has demonstrated that additional characterisation information will provide a net
RELEASED
benefit to CSIRO’s future activities and that doses are expected to be negligible.
Whether additional doses are likely
Additional doses are highly unlikely due to the risk control measures in place.
Whether the change will affect the applicant’s capacity to comply
BY
The applicant has demonstrated their capacity to perform similar tasks which were observed by the
assessor in early 2018, and without event.
ARPANSA
Whether the application has been signed by an office or holder or authorised person or other
appropriate person
Jen Baxter has signed the application and is authorised to do so.
Whether the applicant has shown the proposed change is consistent with international best
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practice
By conducting risk assessments, apply a risk control plan and a radiation protection plan across all planned
and unplanned activities, the applicant has demonstrated international best practice to the assessor.
6. Summary of recommendations and conclusions
FOI
I recommend:
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That the R521 application be approved without delay.
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