Inspection report: Department of Home Affairs, Brisbane, QLD (R21/13131)
|Inspection report details|
|Licence holder:||Department of Home Affairs|
|Date/s of inspection:||15/12/2021|
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 facility licence F0136.
The scope of the inspection included an assessment of the Department of Home Affairs performance at the Brisbane Container Examination Facility (CEF) against the Performance Objectives and Criteria (POCs). The inspection consisted of a review of records and interviews.
The Australian Border Force (ABF), under the banner of the Department of Home Affairs (the Department), is authorised under section 32 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 F0136 authorises operations of a 9 MeV particle accelerator at the Brisbane 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 (1998), (AS 2243.4-1998))
The licence holder was found to be compliant with the Act, the Regulations, licence conditions and the relevant code and standard. The assessment also concluded that the Brisbane CEF continues to reflect the principles of the POCs in its controls, behaviours, and management system. One area for improvement (AFI) was identified related to the documentation of the configuration control process (change management) which is discussed in this report)
The actions taken for the two areas for improvement from the last inspection in 2019 were reviewed and it was concluded that both have been comprehensively addressed. The actions comprised updating the security plan to reflect ARPANSA security advisor guidance, taking a graded approach and to update the Emergency Plan to record responses to all events that may occur.
The following key observations were made:
Performance reporting verification
Quarterly reports since the last inspection in 2019 were examined by the inspectors. Safety and security reporting and changes under section 64 of the Regulations continue to be reported as per Licence Condition 1 of F0136. No radiological events have been reported since the last inspection. This is not considered unusual for a facility of this nature.
The minutes and document pack of the last Regional Management Review Meeting and the last Container and Cargo Management Quality Management System – Management Review Meeting (at senior executive level) were reviewed and discussed at the time of the inspection. These meetings review a number of items across all the Department’s sites including work health and safety events, tracking of corrective actions raised and effectiveness of implementation, recommendations from internal and external audits, dose surveys and security issues etc. No issues were raised by the ARPANSA inspectors.
The completion of recommendations for improvements against the ANSI/HPS N43.3-2008 code made during a dose survey completed by an external provider were reviewed at the time of the inspection and no issues raised.
It was also noted that there were plans to include the existing Radiation Safety Committee into the same framework as the Department’s National Health and Safety Committee (NHSC) in the future as part of continuous improvement so that the committee operations were fully integrated.
Plans and arrangements continue to be reviewed within the frequency specified by section 61 of the Regulations.
Inspection Testing and Maintenance
The facility has contracts with the manufacturer of the controlled apparatus to provide ongoing inspection testing and maintenance for radiation safety and operationality. These are defined in maintenance plans. The last two maintenance plans (2019-2020 and 2020-2021) were reviewed which cover the type of maintenance to be provided (preventative and corrective) the frequencies, the qualifications of the contractors, including security clearance and state radiation certification and how the contractors will access the facility.
The quarterly and annual maintenance reports were reviewed since 2019 and no issues raised by the ARPANSA inspectors. The Covid-19 pandemic has not interrupted the scheduled preventative or corrective maintenance taking place at the Brisbane CEF and all maintenance was found to have been appropriately recorded.
Corrective maintenance required since 2019 has been limited to the repair of the CEF hall scanner doors on one occasion and an operational issue with start-up due to the age of the apparatus. For the CEF hall scanner door, the use of the approved exclusion zone was employed following a risk assessment and consultation with relevant stakeholders. In line with continuous improvement the Radiation Safety Plan (TI-1956) and associated procedure was then updated to capture this process in more detail for any future occurrences.
Inspectors discussed the change management process employed at the CEFs, focusing on the temporary employment of the exclusion zone whilst the repair to the scanner door was being conducted. This was conducted under section 64 of the Regulations and whilst ARPANSA considers the change was well managed with appropriate stakeholders consulted at the time and a risk assessment completed prior to implementation, it was noted that the change control process is not comprehensively documented in the CEF plans and arrangements. This was raised as an area for improvement against ARPANSA POC 2.2.1 which recommends that ‘BM 2.2.1- change management procedures are always used when making changes to plant, equipment, operating processes and management arrangements’.
The training requirements for staff who are employed to operate the CEF are laid out in the Radiation Safety Plan (TI-1956). The facility continues to make use of competency assessment training officers (CATO) who assess and deliver training of staff. In addition, external approved suppliers are engaged for radiation courses as required.
The training records for the Brisbane CEF Site Radiation Safety Officer (SRSO), deputy SRSO, and the Department Site Radiation Officer (DSRO) were examined and no issues raised.
In addition, the training records of the Nuctech maintenance contractors were reviewed and no deviation from what was detailed in the maintenance plans for training was noted.
The records of new operators employed since 2019 were also reviewed and it was noted all had completed the required Xray courses (such as container Xray operator and container Xray analysis courses). At the time of the inspection a new course had been developed on Xray and radiation safety awareness as part of continuous improvement.
In response to an AFI raised at the 2019 inspection the Security Plan for the Brisbane CEF has been updated to better align with the advice of the ARPANSA security advisors (taking a graded approach). The plan was reviewed by the ARPANSA nuclear security advisor, and no significant issues raised. At the time of the inspection, it was noted that no security incidents had been reported at the Brisbane facility since the last ARPANSA inspection, but a system was in place for management of such incidents.
The Department has, since 2019, contracted ANSTO Radiation Services to act as the Radiation Safety Advisor (RSA) for the facility. The contract notes that ANSTO will provide additional specialist advice where appropriate in relation to radiological issues, conduct DRSO and SRSO training and conduct regular and post modification (for example if controlled apparatus is modified or moved) radiation surveys to the frequency laid out in the Radiation Safety Management Plan.
The two most recent radiation surveys for the CEF were reviewed with no significant issues raised. Surveys are conducted periodically in line with ANSI/HPS/N43.3.2008 and after modifications to controlled apparatus. Nuctech also conducts leakage surveys as part of the quarterly and yearly maintenance. The ARPANSA inspectors reviewed the results and raised no issues.
Calibration certificates for the Brisbane CEF radiation detection devices – GR135Plus Radiation Identifier Device and the RadEye Personal Radiation Detector devices were examined, and each found to be within the annual calibration requirement.
Emergency preparedness & response
The Department engages an external contractor (Hendry) to assist in developing their emergency plan and to coordinate emergency response training activities and drills. In response to area for improvement at the last ARPANSA inspection the plan has been updated to include comprehensive responses to potential scenarios.
As part of the induction program, all employees are familiarised with that plan. It contains an emergency manual that outlines procedures for emergency events which have been identified with potential to give rise to emergency situations. It also defines the responsibilities and requirements of those directly involved with the coordination and safety of staff in the event an emergency takes place.
The Brisbane CEF plan states that drills are conducted annually. Due to the COVID-19 pandemic and the Hendry staff being under travel restrictions, building warden training etc has continued to be delivered but moved online. Drill actions have been discussed at these online sessions as a desktop exercise in place of the physical exercise. Details of this will be reported to ARPANSA at the next quarterly report.
Given the nature of the site and the facility, there are no external events that could potentially give rise to an event with radiological consequences. Evidence of the fire detection system being tested monthly was sighted at the time of the inspection.
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:
- Configuration management (change control) process employed by the Department for temporary and permanent changes is not comprehensively captured in the plans and arrangements.
It is expected that the improvement action will be taken in a timely manner.