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Inspection report: Department of Home Affairs (no. R20-09321)
|Inspection report details|
|Licence holder:||Department of Home Affairs|
|Location inspected:||Melbourne Container Examination Facility|
|Date/s of inspection:||30 September 2020|
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 F0131.
The scope of the inspection included an assessment of the Department of Home Affairs performance at the Melbourne CEF against the Performance Objectives and Criteria (POCs). The inspection consisted of a review of records, interviews, and physical inspection of the facility.
Given the current COVID-19 pandemic and the restrictions in place in Melbourne, this inspection was conducted both physically and virtually. An inspector located in Melbourne attended the site whilst the lead inspector remained in Sydney.
The Australian Border Force (ABF), under the banner of the Department of Home Affairs (the Department), is authorised under section 31 of the Act for operation of a particle accelerator under multiple facility licences at different ports across the country. The purpose of these facilities is to aid in the prevention of illegal and harmful goods entering the country. Facility Licence F0131 authorises operations of a 6/9MeV linear accelerator at the Melbourne CEF to assist in examination of containerised sea cargo.
The main codes and standards applicable to this facility are those that appear in section 59 of the Regulations plus:
- Health Physics Society (HPS) Installations using non-medical x-ray and sealed gamma-ray sources energies up to 10MeV (ANSI/HPS N43.3-2008)
- Australian Standard Safety in Laboratories – Ionizing Radiations (2018)(AS 2243.4-2018)
Performance reporting and verification
The requirements for reporting safety and security issues vary depending on the nature of the issue (e.g. whether it is due to the x-ray, radioactive contents within a container, etc.) and the various policies and procedures that are employed which govern the Department’s reporting framework. If a radiological incident were to occur, a notification would be raised through the Department’s electronic system, easySAP. This portal is the system used for all ABF WHS issues and is able to categorise those events related to radiation. It is then the responsibility of the WHS team to triage the event by forwarding it to the departmental radiation safety officer (located in Canberra). Supervisors at the facility are also made aware that an incident has been raised.
Any events are communicated during a shift change so that the next team of workers are aware of any issues.
CEF managers meet monthly via teleconference to discuss a range of issues with a standing agenda item on radiation safety management covering topics such as previously identified areas for improvement from ARPANSA inspections, quarterly reporting, and the notification of incidents to supervisors and use of easySAP.
To date, the Melbourne CEF has not had any radiation related events.
The CEF’s operation is controlled by the use of specific keys. These keys enable power to the CEF, control its interlocks to conduct a scan, and override certain parameters to allow for calibrations. A specific staff member for each shift is assigned the key for operation of the accelerator. This is tracked through an offline register and is updated during a shift handover when the relevant staff member from the subsequent shift is assigned those responsibilities. Outside hours of operation, these keys are kept secure and can only be issued to approved staff.
Previously, where breakdowns had occurred and interlocks were overridden, exclusion zones were put in place so that scans were still able to continue. In 2019, an override mechanism which allowed the use of exclusion zones was removed. Inspectors confirmed that such use is now no longer possible and exclusion zones are no longer employed at the Melbourne CEF. In the case where the CEF cannot be used to conduct a scan, the Department has other means of carrying out its business.
There is a requirement for at least two people to be available during the scan of a container - one person to operate the equipment and one to perform data/image analysis. If for some reason the current operator cannot continue the team leader will take their place.
Inspection, testing and maintenance
Previous CEF inspections (Brisbane and Sydney) identified issues surrounding the preventative maintenance for the accelerators and their arrangements. During a desktop review of information supplied, a maintenance management plan (MMP) was provided along with a schedule. This plan reveals what maintenance is to be performed and when. The Department has now made it mandatory that results of maintenance are supplied to the Department’s contract manager along with the monthly invoice to ensure that work is being performed in-line with the MMP.
Qualifications of the on-site engineer (Nuctech) were all within the requirements of the MMP. However, the certificate supplied showing completion of training for maintenance of the accelerator carries an expiration of 5 years from the date of issue. While currently still valid, it is unknown what this means for the Department and whether recertification of their current engineers will be required. This is an area for improvement.
At the time of inspection, the training of all Department staff was either complete or awaiting sign off. Multiple systems are in place to ensure training is kept up-to-date and alerts are sent out when lapses occur.
Given the nature of the site and the facility, the likelihood of any credible accident scenario with radiological consequences is deemed unlikely.
Previous inspections of CEFs at other locations have identified that the security plan was either not in-line with ARPANSA’s guidance material (Plans and Arrangements for Managing Safety) or was more of an assessment of the arrangements in place (i.e. what was or was not in place) rather than a plan. In comparison, what has been recently implemented at the Melbourne site is considered to be an improvement. The plan describes the site and its purpose, delineates permanent employees from contactors, access control and requirements of visitors, physical security, alarm systems, security clearance requirements (inclusive of the arrangements for the Nuctech engineer), etc.
It should be noted that a security risk assessment is yet to be conducted however the physical security arrangements and access requirements at the facility were found to remain appropriate.
Radiation surveys are performed throughout the year to confirm that doses are low at specific locations around the accelerator thus ensuring operations are routinely safe. Those performed by the Nuctech on-site engineers coincide with the quarterly/annual maintenance schedule. The previous departmental radiation safety advisor (SGS) also conducted an annual independent radiation survey to determine compliance with the applicable standard.
While the doses measured are low, the reports made by Nuctech and SGS were not comparable. It is unknown how extensive the Department’s review of these surveys is and therefore why values within differed. Also, while no survey was completed in 2019 by SGS, the Department has now engaged a new radiation safety advisor who plans to conduct those surveys less frequently.
A long standing issue has been the review and update of the radiation safety management plan (RSMP) for the CEFs which is uniform across all locations. Evidence of a review that took place in October 2018 was provided after inspectors sought clarification as to whether or not the document had been reviewed as described in a quarterly report. Although this review demonstrates that the licence holder has met its obligations in the Regulations the internal requirement for annual review has not been met. To compound this further, multiple instances of outdated information (which have been discussed during other inspections) have remained. This is considered to be an area for improvement.
Emergency preparedness & response
Sections within the RSMP outline the procedure to be adopted where someone is exposed to radiation e.g. someone is present in the scanning hall during a scan or during the examination of goods. Such incidents would lead to the immediate shutdown of the CEF (with subsequent confirmation that the accelerator is powered down) or implementing an exclusion zone if radioactive material is detected (which requires multiple levels of reporting and checks to determine the legitimacy of the cargo).
The emergency response function has been contracted out by the Department and was previously the responsibility of PRENSA. PRENSA no longer hold the contracted responsibility which is now held by HENDRY. Although the contractor has changed, the emergency plan written by PRESNA is considered by the Department to still be valid but it is unknown whether HENDRY has reviewed it for its appropriateness. In addition to this, while response procedures are included for a radiological incident (mainly due to the possible presence of radioactive material) unlike the other CEFs there is no assessment determining the risk of such an emergency at the Melbourne site.
In terms of training, emergency control officers undergo training every six months. If this training were to lapse then they can no longer continue to hold their emergency response position. Also, while it is a requirement that emergency response procedures are tested annually to ensure they are viable and effective, they have been conducted every six months under the control of the previous contactor. These tests include responding to different scenarios such as evacuations and response to an active shooter. Due to the current pandemic, this recent training was performed virtually.
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:
- Training/Qualification requirements of the on-site engineers
- Review and update of the Radiation Safety Management Plan
It is expected that improvement actions will be taken in a timely manner.